.s AUSA Ainarjeet S. Bhachu. (312) 469-6212 AUSA Megan Cunniff Church. (312) 8864173 AUSA Matthew Kutcher, (312) 469-6132 A0 106 4510) Affidavit for Search Warrant UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION UNDER SEAL MM . In the Matter of the Search of: Case NumberThe office located at 121 North IiaSalle Street, Room 304, Chicago, Illinois, further described in Attachment A-l APPLICATION AND AFFIDAVIT FOR A SEARCH WARRANT I, Steven D. Noldin, a Special Agent of the Federal Bureau of Investigation, request a search warrant and state under penalty of perjury that I have reason to believe that on the following property or premises: See Attachment located in the Northern District of Illinois, there is now concealed: See Attachment The basis for the search under Fed. R. Crini. 41th) is evidence and instrumentalities. The search is related to a Violation of: LI ode Sectio n. Offense Description conspiracy to commit an offense against the United Title 18, United States Code, Sections 371, (366, 1343, States; bribery and gratuities concerning programs 1346, 19 1 receiving federal funds; wire fraud; honest services wire fraud; conspiracy and attempt to commit wire and MAY 2 7 2015 honest services fraud; and extortion, attempted extortion and conspiracy to commit extortion MAGISTRATE JUDGE on these facts: See Attached Af?davit, Applicant?s Signature Continued on the attached sheet. Investigation Printed name and title Sworn to before me and signed in my presence. Date: ?Judge?s Signature I KI 154$ agistra?ge?gludge City and State: Printed name and. title Case: 1?16-mc?0025 - 1 Document#' 1 FM - - ed. 05/27/16 Pa ge 2 Of 46 Page?) #26 STATE OF ILLINOIS SS COUNTY OF COOK AFFIDAVIT I, STEVEN D. NOLDIN, being duly sworn on oath, state as follows: I. Preliminary Matters 1. I am a Special Agent with the FBI and have been employed by the FBI since June 2008. In connection with my official FBI duties, It have experience investigating violations of federal criminal law, including conspiracy'to commit an offense against the United.States, in violationc?ETit15118, United.States Code, Section 371; bribery and gratuities concerning programs receiving federal funds, in violation_of Title 18, United States Code, Section 666; wire fraud, in violation of Title 18, United States Code, Section 1343; honest services fraudq in violation.of'ritle 18, United.States Code, Section.1346; commit wire and honest services fraud, in violation of Title 18, United States Code, Section 1349; and extortion, attempted extortion and conspiracy to commit extortion, in violation of Title 18, United States Code, Section 1951 (the?Subject0ffenses?). also been involved in various types of electronic surveillance, as well as in the debriefing of defendants, witnesses, informants and others who have knowledge of criminal activities. I have participated in the execution.of multiple federal search warrants. 2. This affidavit is made for the purpose of establishing probable cause in.support of an application.for a warrant to search the following locations (the ?Subject Premises?): C6138. .1 - - - a. 304, Chicago, Illinois (hereinafter, ?Subject Location which is the City Hall office of Alderman.DANIEL SOLIS, which.is further described in Attachment A?l; b. The office locatedzu;1645 SouttiBlue Islandevenue, Chicago, Illinois (hereinafter, 25th Ward office for Alderman DANIEL SOLIS and the location of Citizens for Danny Solis and the 25?h Ward Regular Democratic Organization, which is further described in Attachment B?l; c. The residence located at 800 South Wells Street, Unit 522, Chicago, Illinois (hereinafter, ?Subject Location which is residence, d. The residence located at 1135 South Delano Court, Unit 812 East, Chicago, Illinois (hereinafter, ?Subject Location which is a residence used.by SOLIS, wife, and SOLIS's son, which is further described in Attachment D~l; e. The business known as ?Copper Tan.and Spa," located Location which is further described in Attachment Eel; f. The cellular telephone bearing the number (312) 208~0292, International.Mobile Subscriber Identity'Number 310410840352309, a cellular telephonecnithe service provider subscribed to ?Daniel Solis, 6148 Rob Roy Dr. Oak.Forest4 and hereinaftery ?Target Phone which is further described in Attachment Case: 1: - - 16 me 00261 Document 1 Filed: 05/27/16 Page 4 of 46 PagelD #?28 3. As set forth below, there is probable cause to believe that the Subject Premises contain evidence and instrumentalities of violations of the Subject Offenses. The statements in this affidavit are based.on.my personal knowledge, and.on information I have received.fron1other law enforcement personnel and.fron\persons with knowledge regarding relevant facts. Because this affidavit is being submitted for the limited purpose of securing search warrants, I have not included.each and_every fact known to me concerning this investigation? I have set forth facts that I believe are sufficient to establish probable cause to believe that evidence and instrumentalities of violations oft?naSubject Offenses are located within the Subject Premises. 4. Reference is made to lawfully recorded conversations in this affidavit. In certain instances, these conversations are summarized enui placed context. N57 understanding (If these conversations (which often appears in brackets) is aided by the 'familiarity'with.the facts and.circumstances of this investigation, my experience as a law enforcement officer, my discussions with other law enforcement officers, the experience of other law enforcement agents and officers in this investigation, and other evidence developed.during the course.of the investigation. The times listed Further,summaries of the recorded conversations herein do not represent finalized transcripts and may not represent the entire conversation that occurred between the identified individuals. II. Sumary drobable Cause 5. DANIEL SOLIS, an Alderman for the City of Chicago, is the subject of an investigation being conducted by the Federal Bureau of Investigation . As described in greater detail herein, there is reasonable cause to believe that SOLIS and others have committed the Subject Offenses by engaging in a series of transactions that involve the abuse of position as a public official. 6. In particular, SOLIS has agreed to use and used his position as a public official to obtain private benefits for himself and for others, in violation of 18 U.S.C. 1951. SOLIS has received a flow of private benefits from individuals for whom SOLIS offered to take, has taken or will likely take official action, in violation of 18 U.S.C. 1343, 1346, and 1349. Additionally, SOLIS has solicited, accepted, and agreed to accept private benefits and campaign contributions intending to be influenced and rewarded in connection with his official acts, in violation of 18 U.S.C. 666. 7. In this paragraph, and in paragraphs 8 and 9, I am offering my interpretation of the evidence that is further described in the rest of this affidavit. As detailed below, SOLIS has agreed to take action in his official capacity as an Alderman for private benefits directed to MICHAEL MADIGAN. Specifically, a cooperating individual has assisted a businessman, Businessman l, in his efforts Case: 1:16-mc-00261 Document #2 1 Filed: 05/27/16 Page 6 of 46 PageID #:30 to have the zoning of a piece of property located in Chicago changed so that a hotel could be built on the property. SOLIS assured the cooperating individual that, in return for Businessman retaining personal law firm on tax matters, Businessman 1 would project. After SOLIS was advised of Businessman 1?s agreement to hire firm, SOLIS provided a letter of support for rezoning of the property to be used for the hotel development project. See pages 11 through 29. 8. There is reasonable cause to believe that SOLIS has benefits fronrvarious individuals for whom SOLIS has taken official action, (ii) has offered to take official action.or is likely to take official action in the future, including the following: a. ROBERTO CALDERO. CALDERO has provided.SOLIS with.a stream of benefits, to include Viagra, arranging for prostitution services for SOLIS, and. securing campaign. contributions from relatives of Elgin Sweeping, a company CALDERO represented, in efforts to obtain an exemption from the City?s water ordinance. In return for these benefits, SOLIS assisted CALDERO in obtaining the requested exemption for Elgin Sweeping. b. FREDERICK LATSKO. LATSKO has provided SOLIS with the use of a multi?million dollar farm so that SOLIS could hold a graduation party for his son. LATSKO also agreed.to lease a dance studio property at direction so SOLIS could take economic revenge on his daughter's former business partners. SOLIS for his part has taken steps to propose a city ordinance favorable to - business interests, and has participated in the approval of multiple projects involving LATSKO. 9. There if; reasonable cause tx) believe that SOLIS has actively solicited monetary contributions in telephone calls, and these solicitations have repeatedly coincided with promises Case: Document #1 1 Filed: 05/27/16 Page 7 of 46 PagelD #:31 in these very same calls to take official action benefitting the contributors, who have official business with the City. a. For example, SOLIS has solicited. monetary contributions from VICTOR REYES, and has explicitly promised that in returrifor monetary donations steer legal business to REYES. See pages 81 through 83. Moreover, a revieWcof financial records reflects that, while such_contributions are represented to be campaign contributions, at times SOLIS uses forliiscnalpersonal use, including the payment of school tuition for his son. b. SOLIS also agreed with JUAN GAYTAN to accept a gratuity from McHugh Construction that was given as a reward for official acts favoring McHugh Construction in connection with the company?s efforts to obtain approval of a BOO?room hotel and data center project. On September 29, 2014, two days after GAYTAN told SOLIS that McHugh Construction wanted to back SOLIS ?big time? because they were tired of the (that is, delays to the approval of their project), and.on.the'very same day that GAYTAN advised SOLIS that GAYTAN would make McHugh Construction think SOLIS was helping out McHugh Construction ?all the way? concerning their project, and (ii) SOLIS told GAYTAN to tell a representative from McHugh Construction.that SOLIS would be prepared_to call a special meeting to approve the project, McHugh Construction made a $1,500 contribution to Citizens for Danny Solis. c. SOLIS assisted Elgin Sweeping in an attempt to obtain an exemption from a water ordinance that would have required_Elgin Sweeping to pay a significant amount of revenue to the City of Chicago. After SOLIS rendered this assistance, he told Elgin Sweeping?s representative, CALDERO, that he hoped the president of Elgin Sweeping ?would. ?remember? assistance, and. then discussed.how much money CALDERO would raise from the president of Elgin.Sweepingenuihis familytmanbers. SOLIS subsequently?received a $5,400 contribution from the family's real estate company. 10. There is reasonable cause to believe that the Subject Premises will contain evidence concerning the commission of the Subject Offenses. See pages 116 through 131. By way of example, there is reasonable cause to believe that Subject Location 1, office at City Hall, will contain documents relating to takenwofficial actionijlreturn . I . for illicit private benefits; (ii) Subject Location.2, 25th Ward.constituent office, will contain records relating to monetary contributions solicited SOLIS, including details c?f money received? the identity of contributors, and the timing and receipt of such contributions, as well as records of expenses incurred by proof of what are permissible expenditures as opposed to expenditures made by SOLIS to satisfy his personal expenses; Subject Location 3, residence, will contain records of his personal expenditures, which would constitute evidence that SOLIS has not paid for benefits lavished on hintby'others and that he has used funds from the 25th Ward Regular Democratic Organization to pay for such expenses; (iv) Subject Location 4, a residence used by SOLIS, his wife, and his son, will also contain records of his personal expenditures, which would constitute evidence that SOLIS has not paid.for personal benefits and that he has used funds from, the 25? Ward Regular Democratic Organization to pay for such expenses; Subject Location 5, a massage parlor where SOLIS received prostitution services for which CALDERO may have paid, will contain records relatingtxipayments fort?uaprostitutionanuiother servicesreceivedlanOLIS;and TargetPhoneiL SOLIS'scellular telephone, will contain evidence concerning SOLIS's use of the facility and communication with others concerning the Subject Offenses. Cas . l. - - Facts Establishing Probable Cause 11. According to public records, the City of Chicago is a municipal corporation and municipal subdivision of the State of Illinois. According to the website the City received more than $10,000 in federal funds in.fiscal years 2014 and 2015. 12. The City's legislative branch.is the City Council, which is comprised. of approximately fifty alderman, each. of whom represents one 'legislative (iistrict or ?ward.? Aldermen. are compensated enni publicly?elected. The City" Council inn; the authority to set policy and.pass ordinances and.resolutions related to the responsibilities of City government, including approving zoning regulations. 13. Aldermen are assisted in their official duties by staff members, who are paid City employees. 14. Aldermen have offices within.City Hall, which.is located at 121 North LaSalle Street in Chicago, as well as offices within their wards. 15. Accordingtxipublic records, DANIEL.SOLIS ist?maAlderman for the 25? Ward and a member of Chicago' 5 City Council. Information correspondence from SOLIS and a consensual recording of SOLIS) reflects that SOLIS is the Chairman of the City Council's Zoning, Landmarks alalilding Standards Committee. The responsibilities of this committee include approving Changes to the zoning of real property within the City of Chicago. 16. In his Statement of Financial Interests filed with the City of Chicago on or about May 12, 2015, SOLIS answered.?no? to the question, ?In 2014, did you receive from any person (other than relatives a domestic partner) one or more gifts having an aggregate value in excess of $250?? In his Statement of Economic Interests filed.with.the Cook County Clerk.on.or about May 1, 2015, SOLIS answered in response to the following question: ?List the names of any entity from which a gift or gifts, or honorarium or honoraria, valued singly or in the aggregate in excess of $500, was received during the preceding calendar year.? 17. In his Statement of Financial Interests filed with the City of Chicago on or about May 2, 2016, SOLIS answered.?no? to the following question; ?In.2015, did you receive than relatives or a domestic partner) one or more gifts having an aggregate value in excess of $250?" In his Statement of Economic Interests filed with.the Cook County Clerk on or about May 2, 2016, SOLIS answered in response to the following question: ?List the names of any entity from which a gift or gifts, or honorarium or honoraria, valued singly or in the aggregate in excess of $500, was received during the preceding calendar year.? 18. available information,eaStatement of Financial Interest for the City of Chicago may be filed online or inwperson; Cook County Statements of Financial Interest are filed Case: 1:16?mC?00261 Document #2 1 Filed: 05/27/16 Page 11 of 46 PagelD #:35 online. Based on a review of City and Cook County Statements of Financial Interest, they appear to have been filed electronically. A. SOLIS's Efforts to Obtain Private Business for the Benefit of MADIGAN, and Illicit Promise to Take Official Action in Return for Business Steered to MADIGAN. 19. In.or around.May 2014, a cooperating individual began providing information to the PEI. has historical involvement in a variety of real estate investment and.development projects in the Chicago area, and as a result of this activity has had contact with SOLIS. 20. has been advised that will be charged for his participation in_a fraudulent scheme that included CS?l?s material false representations to a financial institution and.purchasers of real property, and. misappropriation of funds obtained from purchasers through false representations made by On May 1, is cooperating in hopes of receiving a reduced sentence in connection with this future charge. While understands the United States may recommend to sentencing judge a reduced sentence on these charges, no promises have been.made to as to what CSvl? sentence will be or what recommendation the United States will make at sentencing. who was the director of a financial institution, was investigated by the FDIC for alleged structuring of cash deposits at a financial institution over the course of several years. Civil charges seeking his removal and prohibition 10 ., "CaSe: 1:1 6 mt 00261 Document 1 Filed: 05/27/16 Page 12 of 46 PagelD #?36 from the banking industry were not brought due to evidentiary concerns and statute of limitations issues. has previously provided information.to law enforcement and.has been determined to be reliable. Information provided.by in connection.with this investigation.has been corroborated by the information provided in this affidavit, including the consensual recordings referenced herein. 21. In or around May 2014, advised the FBI that represented Businessman 1, a Chinese businessman and property developer, in his efforts to have the zoning of a piece of land located at 2020 South Archer in Chicago, Illinois (the ?Hotel Property?), changed so that a hotel could be built on the Hotel Property.1 22. When interviewed in or around May 2014 and June 2014, CSel stated that approximately two to three months earlier, had.met with SOLIS in an attempt to obtain a letter of support from SOLIS for a change in the zoning of the Hotel Property. reported that after this meeting, CSw1.believed.that SOLIS would provide a letter of support for the zoning change. SOLIS had.specified.that he?would support the rezoning if two conditions were met: (1) the parcel of land adjacent to the Hotel Property was not used to build another 1 explained that in order to finance the construction of the hotel, Businessmenxl planned.to sell off real estate abroad.and then send the proceeds to the United States, and that if these proceeds were not sufficient, Businessman 1 would attempt to take out a loan with a U.S. bank. advised that Businessman I planned for the hotel to cater, in.part, to tourists and.businessmen traveling from abroad. Accordingly, I believe the planned construction of the hotel would.have resulted in the movement of currency and people in commerce. 11 hotel, and Businessman I provided letters of support from the community supporting the proposed rezoning. However, stated that after the meeting, SOLIS did not communicate with about decision to support the proposed zoning change. believed SOLIS was purposely trying to avoid stated that approximately two to three weeks earlier (within the April 2014 to May 2014 timeframe) attended a fundraiser for SOLIS. Businessman I requested that donate $2,500 to SOLIS at this fundraiser on Businessman l's behalf, and did so. According to SOLIS began communicating with again after the donation.2 23 . stated that provided multiple letters of support to SOLIS concerning the rezoning of the Hotel Property from various neighborhood organizations. 24. advised that on or about July 21, 2014, met with SOLIS at Subject Location 1 regarding the proposed zoning change for the Hotel Property. Also present were Businessman l; a legislative aide and scheduler for and an attorney representing Businessman in connection with the rezoning of the property. This meeting was not recorded. advised that during this meeting, SOLIS stated that he wanted all of the letters of support from the community in favor of the zoning change, and that two letters were missing one from the Chinatown Chamber of Commerce and another from 2 A review of Illinois State Board of Elections records revealed a Democratic Organization in the name of a limited liability company associated with Businessman and the Hotel Project. 12 Case: - 1 16 m0 00261 Document 1 Filed: 05/27/16 Page 14 of 46 PagelD #?38 the Chinese.American Service League. advised.SOLIS that these letters would be provided in the coming days. 25. advised that SOLIS had told that the most of Commerce. provided an email that received from the Chinatown Chamber of Commerce that reflected that SOLIS was sent a letter of support from the Chinatown Chamber of Commerce on.August l, 2014. also received an electronic copy of this letter on August I, 2014, and has provided a copy of this letter to law enforcement. advised that received.the Chinese American Service League?s letter of support on August 8, 2014, and then immediately forwarded this letter to the attorney representing Businessman 1. 26. CSHI advised law enforcement that on or about August 5, 2014, received_a telephone call frontSOLIS?s legislative aide. At the time this call was received? records maintained by the City of Chicago reflect that an application for an amendment to the Chicago zoning ordinance to allow the construction.of the hotel had been filed. The aide instructed to call SOLIS as Soon as possible. CSel advised.that hejplacexia return call to SOLIS. This call was not recorded.2 During this call, SOLIS asked if knew who MADIGAN was . responded that knew who MADIGAN was. 3 had been instructed not to have unrecorded contact with SOLIS without first consulting with law enforcement agents. explained that because had been asked to call back SOLIS as soon as possible, it was best to call immediately, otherwise the Alderman might not provide his support. Case: 1:16-mc-00261 Document #2 1 Filed: 05/27/16 Page 15 of 46 PagelD #:39 Businessman l, MADIGAN and himself. agreed and stated would.have to translate for Businessman.l because Businessman 1 the conference room, continued to discuss the taxes that would be levied on the hotel. 38. asked.what the charge would.be for hiring firm. partner explained.that the fee would.be 12 1/2% of any tax savings generated by the firm, or a fixed fee of approximately $3,000 to $3,500 a year. SOLIS added: ?There is no better firm than this firm in terms of doing real estate taxes in the State.? 39. said: ?First of all, [Businessman l] wants to know, there?s any, uhm, cause he, he, he?s in business. He?s in Chicago, he wants to do business. Any other opportunities open, like, like, maybe for him?? suggested ?real estate deals, any deals.? SOLIS replied_that there were a lot of opportunities in Chinatown. SOLIS added: ?And uhm, I think that there's, just general growth across the City, uhm, I can see that in my committee right now, as Chairman of Zoninglook out in terms of the number of cranes that are working, so I would.be happy to sit down and talk.? 18 Case: Document 1 Filed: 05/27/16 Page 20 of 46 PagelD #:44 40. MADIGAN thereafter asked about the ?status of the representation of this hotel we?re talking about.? MADIGAN asked whether Businessman was ?committed to other people,? and replied: ?Not yet.? MADIGAN confirmed that his firm was ?under consideration.? MADIGAN then.discussed options concerning the fee payment structure. MADIGAN added: ?We?re not interested in a quicklcillirm;here. We?re MADIGAN thereafter indicated his belief that his firm provided quality representation. 41. The meeting then concluded. At the conclusion of the meeting, SOLIS asked MADIGAN if he had ?a couple of minutes,? and MADIGAN replied: ?Oh yeah, sure After took photographs of Businessman I posing with SOLIS and MADIGAN, SOLIS began telling MADIGAN that he had aineeting ?we? had. asked SOLIS if and Businessman 1 should ?wait outside" for SOLIS. SOLIS responded: ?Yeah.? MADIGAN told and Businessman I ?If you.could.wait, why don?t you.wait in here.? MADIGAN then directed and Businessman to another room in the office. SOLIS and MADIGAN rejoined and Businessman 1 approximately four minutes later. MADIGAN escorted SOLIS, and Businessman 1 out of the office. SOLIS, and Businessman ltdeparted.the office together. 42. Immediately after leaving the office space, said to SOLIS: ?Alderman, uh? that, uhq I, he, he love to, uhq uhs give the business to, uhq Mr. Speaker,'but3xniknow, like, without your support, that hotel, you know, zoning change is 19 Ca - se 1.16 mc 00261 Document 1 Filed: 05/27/16 Page 21 of 46 PagelD #?45 very critical, you_know like, without, we have to go through zoning change~ SOLIS replied; ?Well, if he works with the Speaker, he will get anything he needs for that hotel." I understand SOLIS to be telling that if Businessman hires MADIGAN as his private attorney for future taXInatters planned hotel, SOLIS will take any official action needed to benefit Businessman with respect to the proposed.hotel, including but not limited.to SOLIS's official support as the Chairman of the City Council?s Zoning, Landmarks Building Standards Committee of any zoning change for the land the hotel will be built on. replied: ?Okay, thank you. SOLIS added: ?And.he's going to benefit fronlbeing with the Speaker . . . okay?? thanked SOLIS. I understand SOLIS to mean that by hiring private firm, Businessman 1 would ensure that SOLIS and MADIGAN would take official action benefitting Businessman in their capacity as public officials. 43. After being promised by SOLIS that Businessman I would receive ?anything? he needed for the hotel in return for hiring MADIGAN, CS?l.told.SOLlSv?I?1respect toai?fundraisercnithe 4th,"5 Businessman.l had ?sent in.money to be a vice chair,? and.that would ?go on his behalf to the fundraiser.? SOLIS replied: ?Thank you . Okay, very good, very good.? added: ?He wants to do 5 advised law enforcement that SOLIS scheduled a fundraiser for September 10, 2014. attended.this fundraiser and.consensually recorded his attendance at the fundraiser at the instruction.of law enforcement. provided a donation of $2,500 (in the form of a check written by Businessman l) at the SOLIS fundraiser. Based on this, I believe misspoke when he referenced the fundraiser being on the 4th. 20 Case: 1:16?mC?00261 Document 1 Filed: 05/27/16 Page 22 of 46 PageID #:46 it long term." SOLIS replied: ?So do I, so do Shortly thereafter, said: ?Hopefully, he can break ground this year. believe expressed hope that Businessman 1 could begin building the hotel this year.] SOLIS replied: ?Yeah. I will do whatever I can to speed up the process and get everything he needs to begin, uh, breaking ground, alright?" understand SOLIS to mean that he would take whatever official action he was able to ensure that construction of the hotel could begin SOLIS added: ?This is important. Very important.? [My understanding is that SOLIS indicated that it was ?very important? for Businessman to hire MADIGAN to ensure official action would be taken for Businessman l? benefit.) replied: ?Okay, yes. Yes. So I will make sure [Businessman will give him the business.? SOLIS replied: ?Good. Good." ii . Contacts SOLIS to Discuss the Retention of Law Firm. 44. On August 21, 2014, at approximately 1:15 p.m. placed a call to SOLIS. This call was lawfully recorded. During this call, advised SOLIS that Businessman I had agreed to hire law firm. Specifically, told SOLIS that Businessman I had told to call SOLIS and thank SOLIS for arranging a meeting for Businessman with MADIGAN. added: ?And also, he [Businessman 1] has, he has decided to uh, use, uh his law firm for his . . . tax service . . . asked if he should contact MADIGAN or his partner. SOLIS told ?You can contact him, uhm, ah, and I?ll call him too, and let him know you will be 21 Case: 1:1 - 6 mo 00261 Document #2 1 Filed: 05/27/16 Page 23 of 46 PageID #?47 calling him.? explained that ?because it?s a long term relationship, uh, probably [Businessman 1] want to do it with him like?armilti?year like, uh? uhq'uh, like, engagement, something like that . . . SOLIS replied: ?Good, good, good." CSel then said for his zoning change, because the zoning change is coming'upcmithe September'e,? and asked; ?Carthe get the letter fron1you.before that . . . date?? SOLIS told CSel to call his legislative aide and ?tell her to get it ready.? SOLIS then asked to locate ?anybody else in the network of people you know that uhm, would like to agreed to look for more people ?to support this event.? I believe that SOLIS was attempting to further use his agreement to provide a letter of support as a means of extorting additional financial benefits from CSml. SOLIS Provides a Letter Supporting a Zoning Change for the Hotel Property and Speaks in Favor of the Zoning Change for the Hotel Property at a Zoning Committee Hearing. 45. In connection.with this investigation, has provided law enforcement with email correspondence concerning the zoning change for the Hotel Property. On or about August 21, 2014, an forwarding an application for an amendment of the Chicago zoning ordinance that sought to rezone the Hotel Property. 22 Case: 1:16?mc?00261 Document 1 Filed: 05/27/16 Page 24 of 46 PagelD #248 46. On or about Friday, August 22, 2014, the aide replied to this email: ?Please prepare a draft of the letter of support from the Alderman.? 47. On or about August 29, 2014, provided law enforcement with.a copy of an.email he had.received from aide via CS?l?s Gmail account. Attached to the email was a signed letter of support from SOLIS, supporting the requested zoning change to the Hotel Property. Specifically} the letter, which.was on official City Council letterhead, was dated August 26, 2014, and addressed to Patti Scudiero, the ZoninguAdministrator, Bureau of Planning and Zoning. The letter carried a subject line referring to the Hotel Property, and provided as follows: I am writing to pledge my support for the zoning change of the aforementioned address. The applicant . . . proposes to develop the subject property to a new multi~storey [sic] building consisting'ofaihotel with retail and offices on the ground floor. To accomplish this, the applicant will require a zoning change from a current Commercial, Manufacturing and Employment Zoning to a Commercial, Manufacturing and Employment Zoning District. Please feel free to contact [name redacted], Legislative Aide and Scheduler, at my office on (773) if you have any questions or require further information. Thank you for your time and attention. Respectfully, Daniel Solis Daniel Solis Alderman, 25th Ward 23 Case: Document 1 Filed: 05/27/16 Page 25 of 46 PagelD #:49 Chairman, Committee on Zoning, Landmarks and Building Standards 48. attended 51 hearing iheld In! the City' Council?s Committee on Zoning, Landmarks and Building Standards in or around September 2014. consensually recorded the hearing. SOLIS presided over the hearing. During the hearing, Businessman 1?s attorney presented the proposed change to the zoning of the Hotel Property, and asked for support of the proposed change. SOLIS replied: do give my support. I do give my support." SOLIS explained.that he was giving his support because the population in Chinatown was ?exploding? and there was a need for a place where Chinese could feel ?comfortable? within walking distance of Chinatown. SOLIS noted another committee member supported the zoning change, and during his remarks, SOLIS also asked for the support of the rest of the committee for the proposed.zoning change. During his remarks at the hearing, SOLIS did not reference his promise to give ?anything? he needed for the hotel in return for business steered.1x: MADIGAN. The committee approved the proposed change to the zoning of the Hotel Property. 49. In. September 2014, placed additional consensually?recorded.calls to law firm. For example, on September 15, 2014, at approximately 10:12 placed an outgoing call to MADIGAN, who was using telephone number (773) 581~8000. Based on publicly available information, (773) 581?8000 is the telephone number for MADIGAN's Illinois General Assembly District Office. During the call, spoke to MADIGAN 24 Case: Document 1 Filed: 05/27/16 Page 26 of 46 PagelD #250 about arranging a time to meet with MADEGAN about the retention of firm. Specifically, advised MADIGAN that Businessman wanted to meet with MADIGAN to ?go over the contract,? which I understand to refer to the agreement to retain firm. MADIGAN'replied that had called and left a message, but that MADIGAN had gotten the ?wrong telephone number.? Thereafter, provided his cell phone number to MADIGAN, and MADIGAN confirmed that he had the wrong number for MADIGAN asked if he could call back and set up a time for to come in and meet think what you want to do is to come in and sit down, and we?ll, um, we'll, we?ll, we'll agree that we?re going to represent the property [the Hotel Property]." 50. On September 15, 2014, at approximately 10:19 placed an outgoing call to SOLIS, who was using Target Phone 2. This call was recorded. During the call, updated SOLIS on his contact.witl1MADIGAN. Specifically, advised.SOLIS that he had spoken to ?Mr. Speaker and that ?he would call me back and.to set up a time with.me so chulgo over the contract with him.? SOLIS replied: ?Excellent. Excellent. Very, very good. Thank you.? 51. placed. additional follow?up) calls txa office. Despite the calls, neither nor Businessman.l has yet signed a retention agreement with law firm. 25 Case: 1: - - 16 me 00261 Document #2 1 Filed: 05/27/16 Page 27 of 46 PagelD #?51 B. SOLIS Has Received A Flow Of Benefits From Individuals For Whom SOLIS, In His Capacity As An Elected Official, (I) Has Taken Official Action, (II) Has Offered To Take Official Action Or Is Likely To Take Official Action Benefitting These Individuals And Their Clients. 52. Interceptions conducted over Target Phone 2 confirm that SOLIS has poor credit and multiple unpaid debts.6 For example, on or about May 28, 2015, at approximately 10:19 a.m. (Session #12019), SOLIS received.an incoming call from Byline Bank. During the call, although SOLIS claimed he had done pretty well financially in the past several years, he explained.that he experienced a foreclosure onerhome three years earlier. As another example, oncmrabout April an incoming call on Target Phone 2 from Monterrey Collection Services. in fees for a time share contract that had been turned over for collection? SOLIS advised that he was ?out of a job so I?m sorry.? SOLIS was asked for information concerning the deliquency, and SOLIS replied: ?because I can't pay it, I?m sorry.? SOLIS then hung up the phone. Multiple other calls from debt collectors seeking payment from SOLIS have been intercepted over Target Phone 2. 53. While SOLIS has recently gone through foreclosure proceedings, has received multiple calls from debt collectors, and 6 On September 26, 2014, October 27, 2014, December 1, 2014, March 12, 2015, April 10, 2015, May ll, 2015, June ll, 2015, July 23, 2015, and August 21, 2015, the Chief Judge or Acting Chief Judge of the United States District Court for the Northern District of Illinois authorized the interception of wire communications over Target Phone 2. Case: Document #2 1 Filed: 05/27/16 Page 28 of 46 PagelD #:52 has been unable to readily obtain credit, he has been able to rely limitedtx>ROBERTO CALDERO, and hinxwith.a steady flow of personal benefits in 2014 and.2015, and the evidence detailed.below reflects that in return, SOLIS, in his capacity as an elected official, has taken official action, (ii) has offered to take official action. or is likely' to take official action henefitting these individualsanxitheir'clients as:aummarizedi11the following chart and as discussed in greater detail below: Individual Benefit?sz Official Action(s) CALDERO Viagra (M 56?60, 73) 0 Assistance with obtaining I Arrangement of prostitution exemption for Elgin services 69w75, 88?89) Sweeping from water 0 Campaign contributions, including ordinance 63~69, contributions from relatives of 76-86) Elgin Sweeping executive (ii 78*79, 86*87) LATSKO 0 Use of multi?million dollar farm 0 Proposing ordinance favorabletx>LATSKO(11109) 0 Agreement to lease dance studio 0 Participatingijiapproval property at instruction of projects involving (1198?108) LATSKO (1113) EL Furthermore, the investigation to date does not reflect that SOLIS has reimbursed CALDERO or LATSKO for the benefits he has received.fron1them. Despite the absence:of any evidence that SOLIS has for these numerous benefits, SOLIS has filed Statements of Financial Interests and Statements of Economic Interests with both the City of Chicago and the Cook County Clerk, for the years 2014 and 2015, in which he has repeatedly answered ?no" to questions asking whether he has received gifts in each year from any person with an aggregate value greater than 27 . . - ase. 1.16 mc 00261 Document #2 Ftled: 05/27/16 Page 29 of 46 PageID #?53 $250; and (ii) from any entity with.an aggregate value greater than $500. Based on the foregoing and the other evidence gathered during there is reasonable cause to believe that SOLIS has attempted to conceal the considerable benefits he has received. fronx the individuals and that he has taken official action in return for this stream of benefits as detailed below. i . 8 Receipt of Benefits from ROBERTO CALDERO and Official Action on Behalf of 5 Client, Elgin Sweeping, in Obtaining an Exemption from a Water Ordinance. 55 . As described below, conversations intercepted over Target Phone 2 between SOLIS and ROBERTO CALDERO have shown that CALDERO supplies SOLIS with Viagra.on an.on?going basis. Moreover, CALDERO has arranged for SOLIS to receive massages at a location where the workers will perform sexual acts upon SOLIS. During the same period, CALDERO requested.SOLIS?s assistance in.his official capacity as a Chicago alderman on a variety of issues, including assistance for bill involving the City?s Water Department. Shortly after SOLIS interceded in the matter to assist Elgin Sweeping, SOLIS solicited campaign contributions from.the president of Elgin Sweeping, Chris Cacciatore, as well as his family members by making reference to, among other things, official acts taken in favor of Elgin Sweeping. Shortly thereafter, SOLIS received a $5,400 monetary contribution from a company operated by Cacciatore?s siblings. 28 Case: 1: - 16 me 00261 Document 1 Filed: 05/27/16 Page 30 of 46 PageID #?54 56. On.or about October 12, 2014, at approximately 11:42 a.m. (Session #1323), SOLIS placed a call to CALDERO. During the call, SOLIS asked CALDERO if he had any of that ?medicine.? CALDERO responded that he would make a call because ?they? told him yesterday that they had it. CALDERO said that he would see if he could pick it up. Based on subsequent intercepted conversations between SOLIS and CALDERO, I believe SOLIS was referring to Viagra? when he asked for ?medicine.? 57. On.or about November 13, 2014, at approximately'le4 p.m. (Session #4378), SOLIS placed a call to CALDERO. During the call, SOLIS asked CALDERO if he could bring any of that ?blue medicine," which I understand to be a reference to Viagra. CALDERO agreed to make a call to see if he could get it done. 58 . On or about November 15, 2014, at approximately 12:31 pm. (Session #4559) SOLIS called CALDERO. During the call, SOLIS asked CALDERO whether he had located any Viagra for SOLIS. Specifically, SOLIS asked if CALDERO had any luck with the ?blue medicine . CALDERO responded: ?They told me it was supposed to come in yesterday.? CALDERO explained that Viagra and Cialis are more difficult to get due to the Affordable Care Act, informing SOLIS that 10 pills cost approximately $400, which.surprised_SOLIS. that his supplier was supposed to receive a shipment of a couple of hundred 7 According to publicly available information, Viagra is a drug used to treat erectile dysfunction. According to photos of Viagra.pills included in marketing materials for the pharmaceutical, the pills are blue. 29 Case: 1:16?mc?00261 Document#: 1 Filed: 05/27/16 Page 31 of 46 PageID #255 Viagra.pills and that so that he would.have enough for a while. In a subsequent recorded conversation, SOLIS and CALDERO arranged to meet in person. Because SOLIS expressed surprise regarding the cost of this pharmaceutical, the lack of discussion regarding payment in any of these calls, and the availability of this drug for purchase with prescription, I believe that SOLIS did not pay CALDERO for Viagra. 59. On or about December 25, 2014, at approximately 9:47 p.m. (Session #6885), SOLIS texted CALDERO. In the text, SOLIS asked: ?Will have any medicine [Viagra] tomorrow?? CALDERO responded, ?Yes SOLIS then responded, ?Good, will contact you tomorrow.? 60. #6908, 6916, 6918, 6920), CALDERO agreed.to meet SOLIS near Cicero and Belmont in Chicago to provide SOLIS with the Viagra. 61. On or about March 31, 2015, at approximately 11:28 a.m. (Session #8176), CALDERO called SOLIS. During the call, CALDERO asked SOLIS about whether it was possible to receive approval for re?zoning on.a property located at Throop Street and Cermak Avenue in Chicago since SOLIS was reelectedr SOLIS told CALDERO that he didn?t know and needed.to take a look at it. CALDERO said that he would call to set up a meeting with SOLIS to discuss that and other matters- 62. On or about April 3, 2015, at approximately 9:46 a.m. (Session #8334) SOLIS called CALDERO. During the call, SOLIS asked CALDERO why he wanted.t01neet wittihim. CALDERO informed SOLIS that 30 Case: Document #2 1 Filed: 05/27/16 Page 32 of 46 PagelD #?56 he had a ?bunch" of different issues to discuss with SOLIS. SOLIS agreed to meet, specifying, bring anybody." 63. On or about May 27, 2015, at approximately 12:02 p.m. (Session #11974), SOLIS called CALDERO. During the call, CALDERO asked to talk with SOLIS regarding a water bill involving Chris Cacciatore, Specifically; CALDERO said: ?Look, I want to catch up with you. Could we have some time? need to talk you today though about this water bill thing with Chris Cacciatore.? According to open source searches, of Chicago?s website, Elgin Sweeping has several nmlti?million dollar contracts with the City of Chicago. 64. As the call continued? CALDERO said: just need.to give you the basic information on it [referring to the water bill issue with Chris Cacciatore]. That?s all I need to do.? SOLIS directed CALDERO to provide the information to a legislative aide.B 65. On or about May 31, 2015, at approximately 8:41 p.m. (Session #12183), SOLIS called CALDERO. During the call, CALDERO requested.SOLIS?s assistance with.obtaining approval by the City of Chicago for a special?use permit for.A Fresh Start RecoveryHomes,9 as well as his assistance with a water permit for Chris Cacciatore. 8 Based on interceptions over Target Phone 2,]Zbelieve the individual referenced in this call works for SOLIS. 9 According to public records, on May 28, 2015, the Zoning Board of Appeals denied A Fresh Start Recovery Homes' a special use permit to operate a particular community home group living facility in Chicago. 31 Case: Document 1 Filed: 05/27/16 Page 33 of 46 PageID #:57 Specifically, CALDERO said that he needed to talk with SOLIS about A Fresh Start Recovery Homes and that ?Judith [Judy the new Buildings Commissioner for the City of Chicago] had told us that we should go in and apply for a special use permit. . . Later in the conversation, CALDERO added: really need to help Chris Cacciatore with this water permit, ?cause otherwise, he?s going to start. . . SOLIS responded: told you, I told you I would set up a meeting just to find out how the hell they came up with that conclusion, you know?" CALDERO said: have no idea. So, ah, so if you want to call, you know, set up the meeting. But the other thing is the Fresh Start Recovery Homes. So, the, Judith told them, was very confident, that if we went in for a special use permit, that we could get it. But I think [Alderman Joe] Moreno Changed his mind. ?Cause Moreno had been like neutral. Like I really don? t, you know, like he had not been. So, when Moreno changed his mind and the Zoning Board of Appeals ruled against him . . . SOLIS said: ?Yeah, but if you are going to ask Joe [Moreno] or any. alderman to do something like that before an election, they are going to be at the very least hesitant." CALDERO responded: ?No, no, no, we didn?t. That?s why we waited ?til after the election. No, I wouldn?t have even tried it before the election. So, so, anyway, anyway, it got denied on Wednesday. So, we got to figure it out. I got to figure it out. I think I have a solution. We can tigure out something that would protect them. It?s kind of a weird thing. ?Cause here? the thing, the Zoning Board of Appeals only rules, what 5 Case: 1:16?mc?00261 Document 1 Filed: 05/27/16 Page 34 of 46 PageID #:58 the City is telling them, is that they can have eight people plus twoimanagers inaaplace liket?u?; and.they don?t headerspecial?use permit. But the problenlis that,'unless'youck3twelvejplus two, it?s really kind of economically unfeasible to do it, because of all the testing, all of the other extra services you?ve got to do to keep that place going. So, anyway, let?s sit down.? CALDERO said that he would call or text SOLIS in the morning. 66. On or about June 4, 2015, at approximately 1:06 p.m. (Session #12438, 12439, 12440), SOLIS received text messages from CALDERO. The text messages contained information from an employee of the City*of Chicago?s Water Department. The texts stated: ?Water Department[;] h] Perunit $83.78 a day for 5 days a week[;] From the start of the season to the end of the season[;] April 6?November 27, 2015; $83.782c5 days $418.90 34 weeks per unit); 75 trucks Mike Tucker, Water Department.?10 10 Based on my review of the contract Elgin.Sweeping entered.into with the City Of Chicago, which was obtained from the City of Chicago?s website, as well as my review of Elgin Sweeping?s website, I understand that Elgin Sweeping is in the business of providing street cleaning services to the City and in connection with this type of service, Elgin Sweeping uses a fleet of vehicles. Based on my review of a City ordinance that was passed by the City Council on or about July 29, 2015, I know that when a fire hydrant is used to provide water for the filling of a truck or street sweeper, the amount charged for the water shall be $83.78 per day. I believe this text message is meant to reflect the revised charges that Elgin Sweeping will incur as a result of this ordinance.. While the text message reads I believe this amount is a typographical error, and the amount should be $1,068,195. Accordingly, I believe that as a result of the new ordinance, Elgin Sweeping would incur costs exceeding $1 million, and that CALDERO wished SOLIS to prevent the new ordinance from fully applying to Elgin Sweeping. efforts to limit the application of the new ordinance to Elgin 33 Case: Document 1 Filed: 05/27/16 Page 35 of 46 PagelD #:59 67. On or about June 9, 2015, at approximately 7:42 p.m. (Session #12794), SOLIS received a call from CALDERO. During the call, CALDERO asked if SOLIS had a chance to talk with the Water Commissioner. SOLIS said ?not yet,? and asked CALDERO to remind SOLIS's scheduler to ?set up a meeting [with the Water Commissioner]." 68. On or about June 15, 2015, at approximately 12:36 p.m. (Session #13027), SOLIS called CALDERO. During the call, CALDERO began to inquire about the Water Commissioner? before In: was interrupted by SOLIS. Specifically, CALDERO said: ?[W)hat was I going to tell you . . . the Water Commissioner-? SOLIS then interrupted, informing CALDERO that he had just finished with the Finance Committee and just left because they were about to vote on the bond deal. SOLIS said he was going to bug his scheduler, ?to get that scheduled.? I regarding the Water Commissioner. 69. On July 2, 2015, at approximately 3:05 p.m. (Session #14202), SOLIS called CALDERO. During the call, SOLIS informed CALDERO that he was looking for a massage with a ?nice ending." I believe that SOLIS was interested:h1a massage iniahich.the1nasseuse would perform.a sex act on SOLIS, which was referred to as a ?nice ending."11 CALDERO agreed.to arrange such aInassage for SOLIS later Sweeping is discussed further herein. NCIC criminal history records reflect that ROBERTO CALDERO has a prior arrest for that 10 years ago. On or about May 30, 2015, at approximately 10:44 a.m.(Session #12128), CALDERO called SOLIS. During this call, 34 Case: 1:16?mc?00261 Document #1 1 Filed: 05/27/16 Page 36 of 46 PagelD #:60 that night and.also asked.SOLIS if he had.received feedback from.the Water Department. Specificallyn ?[Lletzmetel15nniwhy I called. I want to get a good massage, with a nice ending. Do you know any good.places?? CALDERO informed SOLIS that he knew of such a place, and explained that he ?and [name redacted] were just there like Monday.? SOLIS responded: ?You want to go tonight sometime?? CALDERO agreed to do so and said.that he would make an appointment: ?You got to give me a time and I can call. You got to call for an appointment." SOLIS asked: ?What kind.of women do they got there?? CALDER01responded; ?Asian." SOLIS saidz?T?lgoodJ Good? good,qgood. I like.Asian." CALDERO:responded: ?It?s [name favorite.? SOLIS asked: ?Asian?? CALDERO confirmed? SOLIS then specified: ?Okay, you.tell, tell thenlI want the same one that does [name redactedl.? CALDERO said he would schedule an appointment. CALDERO said: ?Let me make sure that it?s available, and then what else was I going to tell you? Oh, the Water Department~did you get any feed back?" I believe CALDERO is asking SOLIS if he received SOLIS asked CALDERO to investigate a massage parlor that might be offering prostitution services. SOLIS directed CALDERO to send someone to the massage parlor to see what services they offered. Specifically, SOLIS said: ?[Jlust send somebody over there to get a massage. See what happens. CALDERO asked for the address, which SOLIS provided. As the call continued, SOLIS said: ?Just check it out, you know. ?Cause they just opened on the 15th so they may not do anything for now. But it?s not just happy endings [sex act performed on the customer]. I think the idea that they also have girls without any? licenses, masseuses without any licenses." CALDERO responded, ?I?ll check out whether the licenses and the names. I?ll check it out.? SOLIS instructed CALDERO to send someone else to investigate because be identified. In a subsequent call, SOLIS suggested this business might.be associated with former girlfriend. Case: Document #2 1 Filed: 05/27/16 Page 37 of 46 PagelD #:61 can talk when we get together 70. On July 2, 2015, at approximately 5:35 p.m. (Session #14245), SOLIS called CALDERO. During the call, SOLIS and CALDERO discussed their visit to a massage parlor. Specifically, SOLIS asked CALDERO where he was. CALDERO said that he was five blocks away. CALDERO instructed SOLIS: ?Her name is [nsame redacted] . Just tell her you?re there to see, you're with.me. Tell her you?re there for the six o?clock with Roberto.?12 71. FBI surveillance observed SOLIS enter Subject Location 5, which is on the north side of Chicago, at approximately 5:36 p.m. later that evening. .A vehicle registered to CALDERO was observed parking in front of Subject Location 5 at approximately 5:42 p.m. A lone male exited the vehicle and entered Subject Location 5. 72. On July 9, 2015, at approximately 12:17 p.m. (Session #14652) CALDERO called SOLIS. During the call, CALDERO asked SOLIS to join him at the same massage parlor, Subject Location 5. SOLIS agreed to go. Specifically, CALDERO said: ?Hey, listen, tomorrow at nine o?clock. You want to get together with [name redacted] in the evening?" SOLIS said: ?Yeah, yeah. That?s ?cause, that?s tomorrow is the last day I'm here. Yeah, let?s do that.? CALDERO said: ?Yeahs yeahr That's'whatlithought. He just calledrma. He?s None of the 'bank. records obtained. during the course (If this investigation and relating to accounts used.or controlled by SOLIS show* any payments to or credit card transactions at Subject Location 5. Case: 1:16?mc?0026l Document #2 1 Filed: 05/27/16 Page 38 of 46 PagelD #262 gonna come in at . . . I?m picking him up at the airport at eight. We? re gonna go to the place we went to on Milwaukee13 at nine. SOLIS responded, ?Excellent, excellent. That's great." CALDERO said: ?Okay. I?ll try to set it up.? 73. On July 10, 2015, at approximately 11:53 a.m. (Session #14799) SOLIS called CALDERO. During the call SOLIS asked CALDERO if they were still getting together at Subject Location 5 that evening. Specifically; SOLIS asked: ?Are we still meeting today?" CALDERO responded: ?At'what time? Hold.on, hey; Danny. Yeah, we?re meeting. I?nipicking up [name redacted] at Later, SOLIS asked CALDERO: ?Okay, so are you making the arrangements with the, uh, massage place?? CALDERO responded: ?Yeah, those are already'made, and we? re set up for nine o? clock . Same girl you had last time . SOLIS said: ?Okayg okay. Hey; I?Hxleavingfkanaiwan tomorrow morning.? CALDERO responded: ?Yeah, you told me you?re leaving?tomorrow, right?" SOLIS then.asked: ?Yeahq is thereeumzway you can get me, uh, any more of that medicine [Viagra] you got me last time?? CALDERO said: ?I?ve got some on me. I can let you.have some, yeah.? SOLIS responded: ?Yeah, yeah. Whatever you can would be appreciated.? 74. About.an hour later, at approximately 12:51 p.m. (Session #14814), Thetxnd:messagesaid: ?Can have someone follow up with the water department concerning Elgin SOLIS responded to the text message (Session 13 The street CALDERO referenced is the same street where SOLIS was observed on July 2, 2015, when heentered Subject Location 5. 37 Case: Document 1 Filed: 05/27/16 Page 39 of 46 PagelD #:63 #14815) by telling CALDEROtxncall.an.individual, Wh?iWaS referenced by their first name. Based on that first name, and my review of CALDERO to contact a legislative aide who works for Subject Location 1, to set up a meeting to discuss the offical action.SOLIS may take on behalf of Elgin Sweeping. 75. FBI established surveillance in the area of Subject ?Location 5 that evening? the same location where the FBI had seen SOLIS and CALDERO on July 2, 2015. At approximately 8:55 the reception area. At approximately 9:05 surveillance observed vehicle pull in front of Subject Location.5. At that time, a third man exited the vehicle. Surveillance observed the third man enter Subject Location 5 after being let inside the locked.door of Subject Location arrived at Subject Location 5 shortly after the third man. Surveillance observed the third man proceed past the reception area. Shortly thereafter, CALDERO approached Subject Location on foot and entered Subject Location 5 at about 9:08 p.m. Surveillance observed CALDERO walk past the reception area. At approximately 9:53 pm., surveillance observed a woman at the front counter of the reception area appear to conduct a transaction with a male, believed to be CALDERO. Surveillance then observed CALDERO walk out of Subject Location 5. Surveillance then observed CALDERO park his vehicle on the street at10:083LnL andreenterSubjectLocationS. .Atapproximatelyl?zla Case: Document 1 Filed: 05/27/16 Page 40 of 46 PageID #:64 surveillance observed.CALDERO exit Subject Location 5. Exfew minutes later, surveillance observed vehicle conduct a u?turn and park in front of Subject Location 5, and then CALDERO exited the vehicle and reentered Subject Location 5. At approximately 10:22 surveillance observed SOLIS, CALDERO and the third man exit Subject Location 5. Surveillance observed that SOLIS, CALDERO and the third man exited.Subject Location 5 without appearing to conduct a transaction.at the counter and then entered CALDERO's vehicle, which then departed the area. 76. On or about July 27, 2015, at approximately 1:54 p.m. (Session #14970), SOLIS During the call, CALDERO discussed an ordinance relating to the City's Water Department. to you for a few minutes on this ah, bill for the water, ah the ordinance for the Water, ah Department." SOLIS said: ?Did Chris ever talk to Tom Powers [the Commissioner of Water Management)?" CALDERO saidg don't they'communicatedq I don?t think.they have. I sent3mnia draft by including one sentence in there. Did you take a look at it?? SOLIS said: ?No, no. I?ve been running around. Ah, give it to legislative aidel.? CALDERO agreed to send the draft to' the aide and said.that he also sent it to ?personal email.?? 14 investigation, danielsolis4lO?gmail.ccm1 as his personal email address. For example, information provided by Google reflects that the recovery email associated with the account is As noted above, SOLIS is employed 39 Case: Document #2 1 Filed: 05/27/16 Page 41 of 46 PagelD #?65 Later, CALDERO explained his proposed revision to the ordinance would provide that if a person was providing ?water, for a public service on.behalf of the state, the city or the federal government, that you would.be limited to an increase of no more than.25 percent over your last bill.? I believe CALDERO asked SOLIS to use his client will not have to pay the City as much for water usage. Thereafter, SOLIS instructed CALDERO to tell his aide to ?bring it to the attention of Claudia . . . . Claudia from the mayor?s office.? 77. On or about July 27, 2015, at approximately 3:03 p.m. (Session #14999), SOLIS called Joe Cacciatore, a sibling of Chris Cacciatore. Joe Cacciatore suggested that he and SOLIS get together for a game of golf. SOLIS agreed, and added: met with your brother and_Robertc>a couple of weeks ago, I?m.trying to help then1with.that housing thing [in.reference toEXFresh.Start Recovery'Homesl." Joe Cacciatore replied that was ?good" and that he wanted to talk to SOLIS about other matters. SOLIS then.said: ?The reascmil alsc>called you is for my event on the 10th, September 10th, my Taste of the 25th Ward. I?nihoping you.and.your family can.help me out as you usually do. Joe Cacciatore replied.?we definitely will-" SOLIS asked if by the City of Chicago as an Alderman. Accordingly, the use of an email address associated with.the City of Chicago)in connectitxiwith danielsolis410?gmail.com confirms this account is used by SOLIS. As discussed above, Gmail is an email service offered by Google. I have reason to believe that the delivery of the email from Caldero to Gmail account required the use of the channels of interstate commerce. Based on this, I believe SOLIS caused an interstate Wire transmission in order to carry out this offense. 40 Case: Document 1 Filed: 05/27/16 Page 42 of 46 PagelD #?66 JtmaCacciatorexmished.to ?coordinate that? [donationstanOLIS] with the rest of the family, or if Joe Cacciatore preferred.that SOLIS call the ?other guys separately.? Joe Cacciatore indicated that he preferred.to coordinate themove out.? SOLIS replied: ?Excellent. That?s excellent. Excellent Case: 1:16?mc?00261 Document it 1-1 Filed: 05/27/16 Page 14 of 39 PagelD #184 103. On or about April 15, 2015, at approximately 5:15 p.m: (Session #8969), SOLIS received an incoming call on Target Phone 2 from Marisol Solis. During the call, SOLIS provided Marisol Solis with a cover story to use concerning involvement in the plan to rent the dance studio property. Specifically, SOLIS said: ?It's very important Sol, that you know nothing. . . . Okay, so whatever I told you in your mind is forgotten about. You don?t know any of theperties. Htthinkfm's a family friend, you know, I don?t know anything else.? You don?t know anything. This is the same thing Brian was telling us last week [unintelligible] ten.days ago SOLIS advised Marisol Solis to only confide in her attorney: ?Just listen to whatever [name redactedl is telling you because he?s your attorney. You don?t talk to Maya, or to me, just tell everybody just to shut up and not say anything.? SOLIS added: ?The only person you talk tc>is hnamezredacted]. 104. On or about April 30, 2015, at approximately 5:52 p.m. (Session #10076), SOLIS placed an outgoing call on Target Phone 2 20 SOLIS has indicated that he had an interest in Marisol Solis?s business when it was first purchased, and that BRIAN HYNES acted as SOLIS's attorney in connection with the purchase of the business. However, SOLIS has indicated that he no longer has a financial interest int?uabusiness. 14,2015, at approximately 5:23 p.m. (Session received an incoming call on Target Phone During the call, SOLIS explained his previous ownership interest in the business: ?Actually, I?m the one that invested the first money in it, Brian wasrm/attorney, ThenIIgave:U:all tormzdaughter and [first name of Marisol?s former business partner].? However, during recent indicating that HYNES is acting as an attorney for SOLIS in connection with the business dispute involving Marisol Solis, Case: 1: - 16 mo 00261 Document 1-1 Filed: 05/27/16 Page 15 of 39 PageID #?85 to Marisol Solis. During the call SOLIS and Marisol Solis discussed her business dispute. SOLIS explained to Marisol Solis that she had a position of advantage due to plans with LATSKO to rent the space where the dance studio operated: ?You, I really think Sol that, I mean, I don? t, I think you? re really in a good position. They can do all kinds of stuff that they want but as soon as you hit ?em where they don' have a studio, they? re gonna come back crawling and saying: ?How can we work things out?? SOLIS explained that Marisol Solis could negotiate a resolution with her business partners, and then let them discover afterwards that they no longer had a space to operate their business: ?Let?s say you negotiate, Sol. Instead of $60,000 or whatever your amount is, you cut it in halfthird, alright? Bear with me. So instead of sixty, let' 5 say it? twenty and in exchange for the twenty you keep the no?compete out; you can compete anywhere you want. Alright?" SOLIS continued ?So once you get that?sand even if it?s only for like $20,000, then she thinks she?s won. You know, well she?s won almost 100%. . And then she goes ah, to the ah, the owner and she finds out that she doesn't have that studio, okay? . . . . Put yourself in her shoes. What is she going to do then?? SOLIS continued on to explain what Marisol Solis could do at that time: ?Yeah, she' gonna reach out to you and you? re gonna say: Oh yeah, you know what? Well you? re gonna have to pay me amount, a $100,000, or you're gonna have to pay me this.? Then you put her on the defensive.? 60 Case: 1:16?mc?00261 Document 1?1 Filed: 05/27/16 Page 16 of 39 PagelD #:86 105. On or about August 4, 2015, at approximately 9:09 p.m. (Session #15790) SOLIS received an incoming call on Target Phone 2 from LATSKO. During the call, LATSKO asked SOLIS whether he should rent a piece of real estate in connection with daughter?s business and SOLIS confirmed that he should. Specifically, LATSKO said: ?Quick question. Ah, that landlord [the owner of the space where Marisol Solis and her partners operated a dance studio] called me from over in that area, over in your area. Should I call him back and rent the space?? SOLIS instructed LATSKO to rent the space: ?Yeah, yeah. Cause, ah, they, they ah, they [Marisol Solis and her former partners] settled and they? re breaking apart and I think it?d be a good idea." LATSKO said: ?Okay. He called me so I just wanna make sure I?m still going forward. Okay." As the call continued, LATSKO asked, ?Oh, Brian?s telling you, Brian?s working with you on the idea of mine about the, ah, charging for the encroachments?? believe LATSKO is referring to an idea he has had that will result in the generation of revenue for the City from real estate holders (?charging for the encroachments") SOLIS said: ?Yeah, yeah. He told me about it last week. Is he still in London or did he get back?" LATSKO said: ?No, he got back. He?s in, oh that?s what I mean to ask him. I didn?t know how that went. He?s in New York right now.? 106. On or about August 6, 2015, at approximately 10:12 p.m. (Session #15931) SOLIS received an incoming call on Target Phone 2 from Marisol Solis. During the call, SOLIS and Marisol Solis discussed the settlement of a lawsuit between Marisol Solis and her 61 Case: Document #1 1-1 Filed: 05/27/16 Page 17 of 39 PagelD #:87 former partners, and SOLIS informed Marisol Solis that LATSKO was going to rent the property that held the dance studio. Specifically, Marisol Soliszasked: ?What??;goingwan?? SOLIS saidq ?What happened with the, um, did you give, ah, {Marisol?s attorney], the, the okay to go ahead and deal with [Marisol' former business partner] on the, ah . .. Marisol Solis said: ?We officially, finally today, Pa, um, I settled [the lawsuit] today. Got my check." SOLIS said: ?Oh, good. Cause, cause Fred called yesterday cause, um they former business partner] the information because sh?they?ll deal with you." Marisol Solis said: ?You said giveHWho did you say to give [Marisol?s formerfbusinessixartner] information?? SOLIS said: ?Wasn?t [Marisol?s former business partner] holding back with you in terms of the, ah, the landlord and dealing with him, or something? She wanted.to .. . Marisol Solis confirmed; ?Yeahs Yeah, shew? SOLIS asked: ?Was it? Did she do that?" Marisol Solis said: ?No, not yet. We literally just settled today, and we just, I wanted to get my money from her and that?s what happened today, finally, and settled.? SOLIS said: ?Well, [settlement] check:before:you do anything because it might bounce Marisol Solis said: ?Ah, no. I did. I cashed it today.? SOLIS said: ?Drop, I mean drop it off in the bank.? Marisol Solis said: ?Yeah, I did that today.? SOLIS said: ?Alright, then, ah, okayy so understand this to be SOLIS directing Marisol Solis to pretend 62 Case: 1:16?mc?00261 Document #1 1?1 Filed: 05/27/16 Page 18 of 39 PagelD #:88 that she was unaware of SOLIS taking retaliatory action against Marisol Solis?s former business partners], let?s start doing'work.? Marisol Solis said: ?Um, alright. What else . . . have you? What has Fred said to you?? SOLIS said: ?Nothing. That he?s gonna return his call and he?s gonna rent it for a year.? Marisol Solis said: ?Okay. So then?? SOLIS said: ?Just tell, just tell [first name of Marisol?s attorney] to deal with.him? Don?t, you don?t get involved with him.? Marisol Solis said: ?Okay, okay. I?ll call everybody tomorrow morning, then." SOLIS said: ?Alright, Mijo. Thank you.? 107. On or about August 13, 2015, at approximately 5:04 p.m. (Session #16595), SOLIS received an incoming call on Target Phone 2 fromIWarisol Solis. Duringt?uaoall, SOLISproperty. Although LATSKO remained willing to rent the property, it appears that Marisol Solis was unable to commit to running a dance studio from the property in question in a timely fashion. Specifically, on or about September 11, 2015, at approximately 5:39 p.mJ (Session #18645), SOLIS placed.an outgoing call on.Target Phone 2 to Marisol Solis. During the call, Marisol Solis reported that her former business partner had entered into another lease for the subject property: don't know the last time you.spoke with.Fred but um I found out that in September or for starting September if not a little sooner that Peter did um reneW'his lease with [Marisol?s former business partner] and 1 don?t know the details of how much or this SOLISscoldedNMrisolSolis for being indecisive about her business decisions: ?Th, that it?s a criticism of you, Mija, is that you gotta be more definitive 1 mean and and that's something that [Marisol?s former business partner] does have is even if she?s bullshitting well I?m gonna do that and that?s what I'nlgonna.do you know .. . and.and.and?you.have so many more advantages than [Marisol's former business partner] because Juan would have got in it as an investor I would 64 Case: 1:16?mc?00261 Document #2 1?1 Filed: 05/27/16 Page 20 of 39 PageID #:90 of probably Fred but you gotta pull the plug you know you . just, ?Well maybe I shouldn't be, bad, it's bad.karma and this this and.that,? what the hell are you talking about? . .. Later, Marisol Solis expressed her doubt that Fred was interested in renting the property for her. SOLIS assured her that if she had been prepared to run the dance studio business, LATSKO would have rented the property, and the landlord would have rented the property in order to gain favor with SOLIS: ?If um, Fred would have done it for you, right, but the other player in this is the owner of the property . Now, the theeowner?of the property'would.have droppedq dropped this thing whether it he has other properties that are in my ward that he's interested in doing stuff for, and at some point, he might be call calling me to to do some stuff so, on_two levels, one, is he could probably get somebody else to come to that place and maybe even pay more than what [Marisol?s former business partnerJ's paying with less headache alright, and number two, he would do it because it somehow it's like a, a, an indirect favor that I you know, um.? Case: Document #2 1?1 Filed: 05/27/16 Page 21 of 39 PagelD #:91 b. SOLIS Plans to Involve LATSKO in a Potential City Development Project and the Zoning Committee Approves Development Projects. 109. On or about June 26, 2015, at approximately 10:51 a.m. (Session #13874), SOLIS received.an.incoming call During the call, SOLIS asked HYNES to relay a message to LATSKO regarding a recommendation SOLIS made regarding an ordinance that was favorable to interests. SOLIS said: ?I_met with Judy Remember her?? HYNES said: ?Yeah, yeah SOLIS said: ?She?s the new commissioner for buildings and I really like her.? ?Yeah, I I I mentioned that to her'and then she brought up, remember you asked me to look into the ordinance she was writing?? HYNES said: ?Yeah,right. Right,yeah you have any?? and I said: ?Cause they did the Kehoe project in my ward.? HYNES said: ?Right." SOLIS said: ?And I said, and she said: ?Well,iIanritingt??rsbut,1?L we shouler I says: ?None. We need revenue.'? HYNES said: ?Right, right." SOLIS said: ?And she liked my response, you.know, and she goes: ?Yeah, okay, well then that?s how we?re going to do it? and says: ?The only person that would be against it: is Andrew Mooney [the commissioner of the City?s Planning and Development Commission].? I says: ?Fuck:Andrew?Mooneyy? you.know?? HYNES said; ?Ha ha. Good, good, good." SOLIS said: ?Yeah, so tell, tell we had, we had a really good meeting and it will go, it will help him out 66 Case: 1:16wmc-00261 Document 1-1 Filed: 05/27/16 Page 22 of 39 PagelD #:92 with the property that he owns.? HYNES said: Okay. Perfect. Perfect. Perfect. Perfect." 110. On or about August 12, 2015, at approximately 2:57 p.m. (Session #16417), SOLIS received an incoming call on Target Phone 2 who was using telephone number (787) BIO-8005.22 During the call, SOLIS advised HYNES that he wished to meet with HYNES and LATSKO. Specifically, SOLIS indicated he wanted to meet with HYNES: ?Well, when.you get in, cause I got an interesting proposal that I want you to look overn Maybe you and Fred HYNES said: ?Okay.? SOLIS added: think I told you about it. The one where you, um, you. would. trade off, uh, river PMD [planned manufacturing district] property, um, for, uh, maybe, more inland property that, and then put commercial residential in that river PMD propertyx And there?s a formula for how the city gets the money, the industrial then gets credit, um, the guy came in to see me today. I?Ulgonna set up alneeting with David Reifman.[the new Commissioner of the Department of Planning and Development]. I?d like to talk to you and Fred about it first. believe SOLIS is inviting LATSKO and HYNES to meet with him to discuss a potential development project that will require a zoning adjustment for property that is currently 22 During the course of the investigation, interceptions over Target Phone 2 revealed two telephone numbers for BRIAN HYNES, namely, (787) 510?8005 and (312) 952?8067. According to publicly available information, area code 787 is an area code associated with Puerto Rico, while area code 312 is an area code associated with Chicago, Illinois. Based on the content and context of the intercepted conversations, HYNES used telephone number (787) 5310?8008 when he was located in Puerto Rico. Accordingly, I believe that SOLIS, who was located in Illinois at the time of the conversation described above, caused the transmission of an interstate wire communication in connection with his conversation with HYNES. 67 Case: 1:16-mc-00261 Document 1-1 Filed: 05/27/16 Page 23 of 39 PagelD #:93 zoned for industrial use HYNES said: ?Yeah, no, we?d love to talk about that. Yeah, ah, ah, again hoping tomorrow. Uh, and this is very exciting.? HYNES added laterw knoijredenuiI spoke before. [Ibelieve HYNES is telling SOLIS that both HYNES and LATSKO want to become involved in a project involving the City of Chicago.] SOLIS said: ?Alright, alright. Let?s talk later." 111. On or about August 13, 2015, at approximately 11:21 a.m. (Session #16529), SOLIS placed an outgoing call on Target Phone 2 to LATSKO. During the call, SOLIS made arrangements to meet LATSKO. Specifically, SOLIS left a voicemail message for LATSKO, in which he asked LATSKO if LATSKO was available for dinner. SOLIS added that if HYNES returned from Puerto Rico, all three of them could meet. SOLIS noted: want to show you something that you might find interesting.? 112. On or about August 14, 2015, at approximately 5:55 p.m. (Session #16678), SOLIS received an incoming call on Target Phone 2 During the call, SOLIS discussed.assisting LATSKO in identifying business opportunities within his ward? Specifically, SOLIS said: ?Yeah, and then the other issue, um, Fred brought up yesterday; He ah, he was trying to ah, you know, you know, he was asking me what I?m.going to do, if I'm going to run again [stand in another election], blah, blah, blahi .And then he says, why don?t you get into real estate. I says, well, I don?t know. And then, um, then_he was saying youtnight be interested.in.getting into som?, 68 Case: 1:16-mc-0026l Document #1 1?1 Filed: 05/27/16 Page 24 of 39 PageID #:94 the real estate. And I said, well, I, I'll help Brian if he wants to do that, whatever I should do. But that?s another?" HYNES interjected: have no, I have no interest in getting into real estate . I might, well, we can sit down and talk about it, if it Works, it works.? SOLIS said; ?Yeah? So, he was interested in my ward and_I told him, um, when you get back, maybe he, you, I, and staff member} can.drive through my"ward, and.I?oan show you where I think things are going to be, you know, developing and popping.? HYNES said: ?And, and that?s a great ide~, I mean, you know, the thing about Fred, just so you know, ye?q ye?, yeah, he?s, he has been.paying attention.to things, and so, when I talked.to him about a week ago, he was like livid. He, he was reading about all these properties all these guys are buying and [unintelligible] Well, everywhere. And he hasn?t bought anything. So, he?s sitting on hundreds of millions in cash and he hasn? bought anything. So yeah, so he, he, he wants to start doing stuff. So, tha?, tha?, that%sperfecttimingv?thl?nt? [IbelieveHYNESadvisedSOLISthat LATSKO was ready to make a substantial investment in.a real estate project and that idea to take steps to assist such an investment was a good idea.) SOLIS said: ?Yeah. .Alright, well then.ah, I?ll~? HYNES said: ?Perfect.? SOLIS said: ??talk;when you get back." 113. had business before the City Council and the Zoning, Landmarks Building Standards Committee, which SOLIS Chairs. For example: 69 . . ass. 1.16 W: 00261 Document 1-1 Filed: 05/27/16 Page 25 of 39 PagelD #"95 0 LATSKO was listed as the manager of entities that sought rezoning of 1149 North State Street so that a 25 story building could be built atop the property. The rezoning request was recommended.to pass by the Zoning Committee on:January 23, 2014, andypassed.the City Council on February 5, 2014. According to records publicly available on the website of the Office'of the City Clerk, SOLIS moved for and voted in favor of this zoning change. 0 LATSND was listed the manager of 2a limited liability company that filed EH1 application to establish a day care center at 1154 West Belmont Avenue. Zoning Committee recommended that the zoning change be approved on December 9, 2014, and.the measure passed.the City Council on December 10, 2014 . 0 LATSKO was the project developer for a 98 unit residential building at 1201 North Clark Street. This development was approvedln/the City Council.on or about January 21, 2015. According to records publicly available on the website of the Office of the City Clerk, SOLIS moved for and voted in favor of this zoning change. Calls to Solicit.Monetary Contributions fronLMultiple Individuals and Entities with Official Business Pending Before Him and His Agreement to Take Official Action Benefitting Certain of These Contributors. 114. As discussed.in greater detail below, SOLIS has actively solicited.monetary contributions in calls over Target Phone 2 that repeatedly coincided with.SOLIS?s promises in these'very same calls to take official action.that benefits these financial contributors. As further described below, SOLIS called.numerous individuals over Target Phone 2 seeking monetary contributions in connection.with a fundraiser that was held on September 10, 2015, an event which he referred.to as the ?Taste of the 25th.Ward.?23 The individuals from 23 Although the name of this event implies it may be a neighborhood festival, the interceptions detailed.herein reflect that this event 70 Case: Document 1-1 Filed: 05/27/16 Page 26 of 39 PageID #296 whoaxSOLIS sought contributions were typically associated with.real estate development companies?entities that had business before SOLIS in.his official capacity as the Chairman.of the City'Council?s Zoning Committee or were likely to appear before him?as opposed to constituents from within his own Ward who do not regularly have business before him in his official capacity on the Zoning Committee. In addition, with respect to certain of these contributors, SOLIS agreed to take official action for them at or near the time they pledgecltheir financial support. Indeed? to steer legal business to one contributor, an attorney, in return for the attorney?s pledge to raise money for September 10, 2015 fundraiser. i. Real Estate Attorney VICTOR REYES 115. On or about August 4, 2015, at approximately 11 25 a.m. (Session #15719), SOLIS received an incoming call on Target Phone 2 from VICTOR REYES. 2? During the call, SOLIS asked REYES for a campaign contribution, and REYES in return asked SOLIS to send him business. Specifically, SOLIS said: ?Alright, here, here, here, the, this is the other reason I called. September 10th, Taste of the 25th Ward. Can you raise me some money please?? REYES responded, ?Yeah Danny, can.I ever, can I, are you ever gonna send me?? SOLIS was designed to be a fundraiser for SOLIS. 24 According to the internet website, REYES is the majority owner of ReyesKurson, a boutique lobbying and. legal practice firm. According to news reports, REYES was a political advisor to former mayor Richard M. Daley and the founder and chairman of the now defunct Hispanic Democratic Organization. 71 Case: 1:16?mc?00261 Document 1~1 Filed: 05/27/16 Page 27 of 39 PageID #:97 interrupted: ?Tell me, tell, well, look, look. The big one you?re ,35 talking about, is the 63 acres [the Roosevelt Road project] REYES continued; ?How ?bout anything?lknv?bout.anything, Danny?i?nv?bout anything? Not just the big one. How about one fucking thing. You know, [1st Ward Alderman Proco ?Joe?] Moreno sends me business, um . SOLIS said: will, I will?? REYES said: ?[22nd Ward Alderman Ricardo Munoz] Rick Munoz sends me business.? SOLIS said: will send.you business this month.? Hibelieve SOLIS promisedtx>direct individuals with business before the City to REYES as clients in return for financial support.] REYES continued: ?You haven't sent me any. I don?t know why." SOLIS said: ?You got it.? REYES asked: ?Are you sending it all to Brian SOLIS responded; ?No, he.doesnft do that kind of shit.? REYES said: ?I?m just kidding you buddy. Fucki" SOLIS said: ?People that do that are a lot?yeah, yeah.? REYES said: ?But here?s, but here's, but Danny, I?m telling you, I gave you, I, every month, every, at least once a month, they?re not, they?re small matters but at least once a month George is sending me something. Um, Male, Maldonado has sent me three clients for shit in the 26th Ward in just the last three months. The Chairman of the fucking Zoning Committee hasn?t sent 25 The Roosevelt Road project is a multi?million dollar development project that concernseaGB acre parcel.of land.ownedinrNadhnn.Auchi, a client of associate, BRIAN HYNES. Publicly available information reflects that this parcel was purchased in 2005 for approximately $131 million. Interceptions over Target Phone 2 (including session #16250) reflect that the mayor of Chicago, Rahm Emmanuel, considers this parcel of property to be one of the most valuable pieces of property in the country. 72 ase. 1.16 mc 00261 Document 1-1 Filed: 05/27/16 Page 28 of 39 PageID #?98 me one." SOLIS said: ?You?ve made your point, you?ve, I, you?ve, made your point absolutely right. ll get to you this month, I promise you. That?s a promise.? REYES said: ?Okay. Alright. What?s today? Today?s August 4th." SOLIS said: ?Yeah." REYES continued: nqrevent, I'll_get you more business than.what, what you raise.? believe SOLIS was telling REYES that he would generate business revenue for REYES that would exceed the total amount REYES contributeritc>SOLIS for his fundraiser-] REYES said: ?I?nxfocusing on September 10th brother." SOLIS said: ?Alright. .Alright Vic." 116. According to Illinois State Board.of Elections records, Reyes 25ttLWard.Regular Democratic $1,000 on April 8, 2014, and $1,500 on September 21, 2015. The Roosevelt Group, a government relations firm for which REYES is a co?founder according to its website, also to the 25tr1Ward.Regular Democratic Organization on.or about September 21, 2015 . ii. Real Estate Broker 117. On or about August 7, 2015, at approximately 2:09 p.m. (Session #16001), SOLIS received.an incoming call on Target Phone 2 from a real estate broker.26 During the call, SOLIS solicited a donation from the real estate broker, who provided SOLIS a donation 26 Publicly available information_reflects that the real estate broker Operates a Chicago based real estate brokerage business. Case: Document #2 1?1 Filed: 05/27/16 Page 29 of 39 PagelD #:99 larger than requested and then reminded SOLIS that he was in need of SOLIS?scofficial assistance. Specifically, SOLIS referencedlais fundraiser, and said: ?You?ve been.a good supporter of mine in the past and I?m hoping I might be able to count on you again. The real estate broker asked: ?How much you need?" SOLIS said: ?Ah, if you could raise me $1,500, that would be fantastic.? The real estate broker said: Itcannot. Danny; I?nrvery very sorryn I cannot give you fifteen hundred but I can give you two thousand SOLIS said: well thank you very much. You're the best!" The real estate broker said: ?No, don?t be silly. You've, you?ve been.great for the city. You?ve been great for me. I?m still trying to get my sign permit.27 I think:we're at the five yard line and.I know you?ve been in the background helping me. I still have a little bit of ways to gobut,e?r?? T?narealestatetmokersaid: ?Danny, do me a favor. Give me your address where I can send you a check right now." SOLIS said: ?You know what? Let me give you my assistant cause she?s got all that. Hold on." The real estate broker said: ?My pleasure to help you anytime.? 118. According to Illinois State Board of Elections records, the real estate broker contributed $500 to Citizens for Danny Solis cu10ecemberi?9,2014, amd$l,000cn1February6, 2015. T?nerealestate 2'7 According to publicly available records, an order was filed for a permit for a sign at a particular address in Chicago associated with the real.estateabroker. Ck:August.27, 2015, the<3rder was introduced to the Committee on Zoning, Landmarks and Building Standards, which recommended to pass the order. On September 24, 2015, SOLIS motioned to pass the order before the City Council, which approved the order. 74 Case: 1:16?mc?00261 Document #1 1?1 Filed: 05/27/16 Page 30 of 39 PagelD #2100 broker contributed $2,000 to the 25th Ward Regular Democratic Organization on or about August 17, 2015. The Pizzuti Companies 119. On or about August 13, 2015, at approximately 10:49 a.m. (Session #16511), SOLIS placed an outgoing call on Target Phone 2 to a legislative aide, who was using a telephone located within City Hall office (Subject Location 1). During the call, SOLIS asked about ani update concerning 51 development project associated. with. The Pizzuti Companies and. MICHAEL CHIVINI.28 Specifically, SOLIS said: ?(first name of legislative aide redacted], what?s the story with Mike Chivini and the Pizzuti Company? Where are we at with that, cause I?m gonna call him right now.? The legislative aide said: ?We?re working on that, we're supporting them, um, SOLIS interrupted the conversation.to take another call. 120. On or about August 13, 2015, at approximately 10:57 a.m. (Session #16516), SOLIS placed an outgoing call on Target Phone 2 to a legislative aide, who was using a telephone located within SOLIS's City Hall office (Subject Location 1). During the call, SOLIS received additional information concerning The Pizzuti Companies? Specificallyy the legislative 28 Records maintained.by the City of Chicago reflect that on or about July 30, 2014, Pizzuti Development, LLC submitted an application to amend Chicago?s Zoning Ordinance to permit the development of residential and commercial space at 1061 West Van Buren. According to the website for The Pizzuti Companies, MICHAEL A. CHIVINI is an executive vice president and leads the company's development operations in Chicago, Indianapolis, and Columbus. 75 Case: 1:16-mC-00261 Document 1-1 Filed: 05/27/16 Page 31 of 39 aide said: ?Yeah, everything?s moving forward with Chivini, they worked everything out with planning [the Planning Department] so that?sgonnagxr Allthat'sreallygoingcniis,1mm allthat'sreally going on is CDOT [the Chicago Department of Transportation] and CDOT is, um, working with them.? Later, the legislative aide added: ?So, but we haven?t held up anything at all and they haven?t asked us for anything recently SOLIS said: ?Okay, good.? 121. On or about August 17, 2015, at approximately 3:40 p.m. (Session #16913), SOLIS received an incoming call on Target Phone 2 CHIVINI. During the call, SOLIS solicited.monetary contributions andl?jsassociates, and.agreedtxaprovide a letter of support to CHIVINI at request. Specifically, SOLIS said: am working, making phone calls for my annual fundraiser, um, next month. . .. I'm hoping, uh, you.can help out, and maybe with some of the people you do business with. You know, subcontractors, contractors, etc.? CHIVINI said: ?You know what Danny? By tine way, iI mean, II actually, tun candidly, we?ve CHIVINI weabsolutelywill. IUifact,lialreadyhavethec?wck for uh, we actually were gonna go to 1,500 dollars this year." company was going to contribute $1,500 to SOLIS said: ?Mm~hmm.? CHIVINI said: ?Um, so, I?ve got the check, and.uh, I was just gonna go ahead.and get that over to, I think, uh, Zach.? SOLIS said: ?Right, Zach.?29 CHIVINI said: ?Yeah, sure, yeah, no 29 I believe ?Zach? is Zach Martin. According to Martin?s Linked?In 76 Case: 1:16?mc?00261 Document #2 1-1 Filed: 05/27/16 Page 32 of 39 PagelD #1102 problem. Yeahq we?ll.get, I?vezgot thencheck.? appreciate if you.could raise me a little bit more from some of the people that you have. You know, some of the contacts that you have.? CHIVINI said: ?Okay.? SOLIS said: ?I?d appreciate it. Okay? If you could try to raise like 5,000 that?d be fantastic.? CHIVINI said: ?Yeah, you know what Danny? I?ll go ahead and I?ll make some phone calls. We? ll do everything that we can. SOLIS said: appreciate it. CHIVINI said: ?Uh, but I can assure you certainly that our check will probably be over there with Zach this week.? SOLIS said: ?Alright.? CHIVINI then said: ?Okay, and.then uh, hey, by the way, I'd be remiss if I didn?t say I spoke to [first name of SOLIS legislative aide] this morning, and uh, she was just kind of confirming that the same information that we were getting that the folks at DPD [the City's Department of Planning and Development], we?ve come to an agreement on the, on the zoning with them.? SOLIS said: ?Mm?hmm. CHIVINI said: ?And so I think we? re good with them. And then, um, um, Bill Higgins, I think, or I forgot the gentleman?s name, but Steve Prowsh [phonetic] and there?s another gentleman over at CDOT [Chicago Department of Transportation] got back to us last week and.they let us know that, uh, they have nozmare comments on our site plan, um, and we?ve done, I think, I wanna say profile and the website for New Chicago Consulting, LLC, Martin is employed by New Chicago Consulting, LLC, as a Finance Associate. Based on calls intercepted over Target Phone 2 Martin assisted SOLIS with soliciting campaign contributions, including for the Taste of the 25? Ward. Case: Document #1 1?1 Filed: 05/27/16 Page 33 of 39 PagelD #1103 four out of the five things that the Related30 folks had asked us to do. And I don? know that we? re ever really gonna be able to completely satisfy those guys, but the CDOT folks, uhm, and you guys will have to confirm, I think, they feel comfortable with what it is that we want to do by way of the relocation.? SOLIS said: ?Yeah, I got the same message.? CHIVINI said: ?Oh, you did? Okay.? SOLIS said: ?Yeahs I mean, I got it last week, actually, that the CDOT people were okay. So, yeah, I anticipate this thing will get done, and we? ll just put the other stuff aside in terms of Related. Cause I think they?ve got too many other issues that they? ll never be happy with.? CHIVINI said: ?Yeah, I think [first name of SOLIS legislative aide] told me last time around we had shot you guys some drafts of just two quick letters to both DPI) and CDOT. So I know that Ed Cuss [phonetic] is sending those over to her. And she said that she would put those on your letterhead and talk to you about signing those, you know, whenever you get back into the office . understand this to mean CHIVINI had provided staff member with two letters of support CHIVINI wanted SOLIS to send in support of his proj ect.] SOLIS said: ?Okay, no problem.? understand this to mean SOLIS agreed to provide letters of support to CHIVINI in connection with hispendimgdevelopmentproject.] ifwecould go that route, that would be great then. Okay." SOLIS said: ?Okay. 30 Based on the investigation to date and news reports, I believe ?Related folks" is in reference to Related Midwest, a real estate developer that is working with Nadhmi Auchi and General Mediterranean Holding to develop the 63?acre Roosevelt Road property referenced above. 78 Case: 1:16?mc?00261 Document 1-1 Filed: 05/27/16 Page 34 of'39 PagelD #2104 Alright Mike. Thank you for returning my call . And if you can help out with some of your associates, that would be helpful.? CHIVINI said: ?We?ll certainly do everything we can, Danny; And, uh, try to get some time off this week." SOLIS said: ?Alright, thank you." 122. According to Illinois State Board.of Election records, on September 21, 2015, The Pizzuti,Companie51nadeea$1,500 contribution to the 25th Ward Regular Democratic Organization. The same day, ?Pizzuti 1033 a limited.liability company'associated with The Pizzuti Companies, also made a $500 contribution to the 25th Ward Regular Democratic Organization. iv. TSAPARAS and the Nobu Project 123. On July 29, 2015, a hotel development project involving the Nobu Hotel (?the Nobu.project?) went before the City Council and was passed. Details for the City Council meeting indicate that the project was passed on a motion by SOLIS. SOLIS is also recorded as voting in favor of the project. 124. On or about August 4, 2015, at approximately 11:56 a.m. (Session #15733), SOLIS placed an outgoing call on Target Phone 2 to SPIRO TSAPARAS, the Chief Excutive Officer of Centaur Construction.31 During the call, SOLIS and TSAPARAS discussed the Nobu project, SOLIS ?xrexmonetary'contributionj and 31 Publicly available documents on the internet reflect that TSAPARAS is the CEO of Centaur Construction. Centaur Construction maintains a website at Several news reports published on the internet state that Centaur Construction owns land in Chicago that will be developed into a hotel and restaurant. These reports also state that Nobu?Hospitality Group is involved with.the project. For example, Crain's Chicago Business published a story on the internet dated June 11, 2014, noting Centaur Construction?s ownership of the property and Nobu?s involvement with the property. a} 10 Case: Document#: 1-1 Filed: 05/27/16 Page 35 0f 39 PagelD #1105 SOLIS agreed to assist brother~in_law in finding a job with the City; Specifically, SOLIS said: ?Hi Spiro. How ya doin?? This is Danny Solis.? TSAPARAS said: ?Hello Danny, how are you?? SOLIS said: ?I'm good, I?m good, uh, how?s it going with the, uh, hotel [the Nobu project]?? TSAPARAS said: ?Uh, it was good to see you the other day there. I had never, uh, seen that process go through and I was feeling proud of you. Uh, pretty cool. It? uh it? a really [sic] thing. I didn?t know exactly what that means to have that position, and.uh, it was good to see you.in action. I was like, yup, that?s Danny." believe TSAPARAS was indicating that he was present at the Zoning Committee hearing on July 22, 2015, when the NobutmtjexK1wasconsidered SOLISsaidx WIWnsurprised3mnihaven?t been,th that you do." TSAPARAS said: ?Never. Never. Nope, it?s always the attorneys andt?uaarchitectsemuisocmr andi?i,nmaast?uedevelopment manager is never in. This is the first time that I have ownership of something of that caliber. Uh, previously I never did? I was always the service provider, and uh, now it?s one, I'm kind of one of the first times I?m breaking into the ownership aspect of it.? SOLIS said: ?Well that?s great, that?s, congratulations on that. I ?Yeah, it?s the first big one like that. Uh, I was there and I was like ooh, wow, that?s cool. This Ilnean.it's really fantastic. It?s wonderful.? SOLIS said; ?Well, it?s, it?s been.reallyg?xxithe last three or four years because development in the City is starting to 80 Case: 1:16?mc?OO261 Document 1-1 Filed: 05/27/16 Page 36 of 39 PageID #2106 pick up. So we've been really busy in the committee, but, ah, I?m so glad to see you too there at the event because it means that you finally got that, uh, hotel underway.? TSAPARAS said: ?Yeah, yeah, it?s uh, it?s like half of what it was but at least it?s being done and at least still is, it can make sense and that Nobu said okay. So, that was good.? SOLIS said: ?Good, good. Anyway Spiro, the reason I?m calling is I?m having my annual Taste of the 25th Ward [fundraiser] in September. I?m hoping you might be able to help out . TSAPARAS said: will definitely be there. As always.? believe TSAPARAS meant that he would support SOLIS said: ?Good, good. Alright, I?mgonna email you. TSAPARAS said: ?If I?mnot there I will, I will, I will send my, ah, my support, but ah, I always try to be there. Last year I couldn? t, but I did send my support . SOLIS said: know, I know. . . . I very much appreciate it. . . As the call continued, TSAPARAS said: ?Danny, since I got you on the phone, and I don?t want to bother yon otherwise, were you able to look at all at that job position for my brother-in?law? Like I told you, super~qualified. He has a He? worked in the corporate world, large corporate world, in Whirlpool, and Walgreens?? SOLIS said: ?Yeah, you know what, Saul, gave, gave me the information, uh, I?ve got his resume and I think there?s other opportunities as the mayor is naming new commissioners for different departments. I?m gonna give it not only to the one that you told me about but I?m also going to open it up to the other commissioners as I meet with them. Especially ones that are under my committee [the Zoning Committee] 81 Case: 1:16?mc?00261 Document#: 1?1 Filed: 05/27/16 Page 37 of 39 PagelD #2107 for example, um, um, uh, Judy who?s now the commissioner of, um, uh, buildings. I?m also gonna give it to her. And ll do the same thing with uh, the other, uh, historical landmarks and uh, and zoning. And as you know, um, they're gonna replace, uh, which I?m very?incidentally, privately between you and ImI?m very happy about Andy Mooney [Commissioner of the Department of Planning and Development] resigning.? TSAPARAS said: ?Yeah, I, I heard it and there was always talk about, uh, there was talk about combining the Zoning and the Building Department under one commission." SOLIS said: ?You know what if that happened under Judy that would be great. But, I, I don?t think that?s gonna happen. If it is, she would be the perfect one for it cause everybody has such high regard for her." TSAPARAS said: ?Yeah, she, she?s great. I met her once and she?s fantastic . SOLIS said: ?You know, we've had really good meetings, she?s connecting with me on a lot of ideas that I?ve got for development. And I?m really happy about her. But I still have uh, your brother?in?law?s resume, I, I?ll continue to work on it and, and I?ll let you know.? believe SOLIS indicated he would attempt to help relative find a suitable job with the City.) 125. According to public filings made by Citizens for Daniel Solis with the Illinois State Board of Elections, on or about December 18, 2014, TSAPARAS made a $5,000 contribution to Citizens for Daniel Solis. On September 11, 2012, Tsaparas made a $1,500 contribution to the 25th Ward Regular Democratic Organization. On March 23, 2012 Tsaparas made a $500 contribution to the 25th Ward Regular Democratic 82 Case: Document #2 1-1 Filed: 05/27/16 Page 38 of 39 PageID #:108 Organization. On March 30, 2013, September 23, 2013, and October 7, 2013, Tsaparas made $5,000 contributions on each date to the 25th Ward Regular Democratic Organization. v. McHugh Construction 126. On.September 27, 2014, at approximately'4z04 p.m. {Call SOLIS made an outgoing call on Target Phone 2 to JUAN GAYTAN. In this call SOLIS and GAYTAN discussed a construction project being undertaken by McHugh Construction.32 Specifically, GAYTAN asked SOLIS what the ?Mayor?s people? had about that from McHugh_Construction about that hotel and stuff.? SOLIS replied.that ?they" wanted him to ?hold it" [the approval process for McHugh Construction?s hotel project] because ?they want to helpxnecnu:with the woman that?s running against me.? GAYTAN replied: ?These people [McHugh Construction] really want to help you. . . . . These guys really want to help you, they?re tired.of all this 8.8., and I told 32 Based on records maintained by the City of Chicago, I believe this project concerned the development of hotel and.data center'byIWoHugh Construction that required a zoning change to the land to be used for the project before it could move forward. On or about May 1, 2014, McHugh Construction agreed to pay $12 million to the United States and the State of Illinois to resolve allegations of disadvantaged business enterprise fraud.in connection with specific United.States Department of Transportation and Illinois Department of Transportation funded.projects. McHugh Construction also agreed to the appointment of a monitor for a period_of three years and to take other remedial action in order to prevent the company from being barred frowxentry into futureigovernment contracts. Basedmake, uh, uhm, something clear to you, cause I think you might have misunderstood. . .. I would, if, uhnn I think you could, uh, do very well in the role I was telling you in terms of being a consultant, 97 Case: 1:16-mc-00261 Document #2 1-2 Filed: 05/27/16 Page 14 of 26 PageID #:123 uh, for some these investors that are coming from China.? The prospective consultant said: ?Yep.? SOLIS continued: ?But I would never get.any'compensaticulfor'that, The prospectiveaconsultant said; ?Okay.? SOLIS continued: ?Because you, I, think when you questioned is this legal?,' I, you know, absolutely, uh, it probably would.not be legal, but even if it was legal and, it would.be unethical.? The prospective consultant said: ?Okay." SOLIS continued.to note that get compensation.for stuff I do that may be connected in Washington, but not in Chicago.? The prospective consultant asked SOLIS what the ?next step" was, and SOLIS replied: ?Well, you know what? Uh, you mentioned [name redacted}. That?s, The'other'possibility'is maybe, uh, uh, maybe it could also be my sister, Patti Or Brian or a combination thereof." SOLIS suggested ?a might.help,? because more experience of any of the players we? re talking about: me, Patti, uh [name redacted]. Because he?s been doing this for a long time. He no longer does it. He?s no, no longer a consultant. He was a lobbyist in Springfield? He don?t, he doesn't do that anymore- He doesn?t do that in Chicago. He has his own.business where he's done veryr well." The jprospective consultant said: ?Sure." SOLIS continued: ?The only reason that the?guy?fronlLondon, uh, hired him, is, is, at my insistence, because I need an attorney I can trust, and, um, that is representing him [enchil?? The prospective consultant said: ?Okay." SOLIS said: ?Which, which is the same Case: 1:16?mc?00261 Document 1-2 Filed: 05/27/16 Page 15 of 26 PagelD #2124 reason I?d be interested.in you, uh, becoming a, uhm, consultant or lobbyist.? I believe SOLIS suggested. directing work. to the the prospective consultant with the impression that SOLIS would illegally benefit from this activity. Moreover, I believe claim that he would not do anything illegal is pretextual not only because the prospective consultant was left with the impression that SOLIS was proposing something illegal, but also because, among other things, of prior interceptions inmwhich SOLIS acknowledged.that his former girlfriend.was hired.by individuals to ?buy" influence with SOLIS, despite denial of knowledge of such.activity to and Businessman 144. On or about June 26, 2015, at approximately 10:51 a.m. (Session #13874), SOLIS received an incoming call on Target Phone 2 from HYNES. During the call, SOLIS told HYNES about a recent conversation.he had with.a zoning attorney regarding the Vacant Lot involving and Businessman 2. SOLIS informed HYNES that he told the zoning attorney, who represents Businessman 2, that everything needed.tC)be done legally due to the involvement of former girlfriend with the project. Specifically, SOLIS said: ?Speaking of developments, [name of zoning attorney] came into to see me this About the Canal and Cermak property that. .remember [Businessman.2] wanted?? HYNES said: ?Yeah, yeah, 39 In a subsequent conversation with the prospective consultant (Session #12357), SOLIS discussed her becoming an employee for the City of Chicago. Case: 1:16?mc?0026l Document#: 1?2 Filed: 05/27/16 Page 16 of 26 PagelD #:125 yeah, right.? SOLIS said: ?And then [first name of former girlfriend] tried tx) give ii: over tx; her~ boyfriend?" HYNES responded, ?Right.? SOLIS said; ?And.ah, so now they?re, he?s back in the picture on it. HYNES interjected, ?Who is? The boyfriend or [Businessman . . . Who is [the zoning attorney] representing?? SOLIS indicatedlnawas representing BusinessmanZL HYNES said: Okay. Fine. Good." SOLIS continued, ?And.so, um, I told [first name of zoning attorney] the history of it and you know what, and I told [first name of zoning attorney], you know what, [first name of zoning attorney]? Because of this history, I want to make sure everything is on the up and up [done legallytold him that I was gonna talk to some people in the city and I was going to talk to you because I want to make sure that if I go ahead and do this, it?s the, it?s the right thing to do and that none of [csai], he was involved, involved in both, with both sides. Well, he was with [first name of former girlfriend] and.her friends when_they tried to recruit to get investors from China to take it away from [Businessman 2] and now when he couldn?t raise it, now he?s involved with [Businessman But when was involved with [first name of former girlfriend] and her friends, I had not, you know, I wasn't supporting it. I think [first name of former girlfriend] was just counting that I was going to be able to do it, ah, even though we weren?t together or whatever. I don?t just, it looks, it sounds fishy and.I?H1not sure 100 Case: 1:16-mC-00261 Document 1?2 Filed: 05/27/16 Page 17 of 26 PageID #2126 I should go along with it and that? why I wanted to talk to you about it." HYNES said: ?Okay. No, definitely.? SOLIS said: ?So, anyway [first name of zoning attorney] will talk to you about it.? HYNES said: ?Okay. Yeah, I'll be back on Tuesday.? 145. I believe that the various statements referenced above regarding claims that ?[elverything has to be legal;? that he would not do anything illegal; that everything in connection with for a number of reasons. First, SOLIS appears to want to distance himself from any connection to his former girlfriend, particularly in light of Businessman 2?s disclosure to SOLIS that Businessman 2 Lot. As expressed by SOLIS to HYNES, SOLIS understood that the payment was to buy access to SOLIS, and SOLIS no longer trusts his former girlfriend. Moreover, these statements occurred while, among other things: SOLIS promised to take official action in return for the retention of MADIGAN's firm by Businessman 1; (ii) information_provided by that BusinessmaILZ gave SOLIS two cash payments in exchange for support of Businessman 2?s SOLIS received_while taking official actions for the benefit of the individuals providing him the benefits; and (iv) the connections SOLIS made between his requests and receipt of campaign contributions of the contributors. 101 Case: 0261 Document #1 12 Filed: 05/27/16 Page 18 of 26 PageID #?127 G. The Subject Premises ?146. With regard to Subject Location 1, Subject Location 2, Subject Location 3, Subject Location 4, Subject Location 5, and Target Phone 2 and based.on.my training and experience in fraud and public corruption.investigations, I believe that public officials, such as SOLIS, maintain various records, in both paper and electronic format, within their offices, places of business, residences, and telephones, including the following: a. Campaign financial records including financial donations, records, reports, ledgers and receipts; b. Information related to fundraising activities including advertisements, photographs, invitations, letters or records of contributors and/or attendees at fundraising events; c. Lists, actual campaign. contributors including, but not limited. to, contributors witlipotential.matters before the Chicago<2ity'Council or a representative body or committee thereof; d. Calendars, schedules and communications of staff members; e. Letters have appeared or may likely appear before the Chicago City Council or a representative body or committee thereof, including the Zoning Committee, as well as actions taken on these matters; 102 Case: 1:16?mc?00261 Document #2 1-2 Filed: 05/27/16 Page 19 of 26 PagelD #2128 f. Credit card statements, bills, payment records/ledgers or receipts; 9. Employee payment records, to include IRS reporting documents such as forms 1099 or h. proof of occupancy, such asausutility'and telephone bills, mail envelopes, or addressed correspondence, which in turn demonstrates possession, control and. association. with other evidence relevant to the investigation; i. Computers, electronic devices and removable media storage devices which_may contain information related to the above items. i. Subject Location 1 147. As further described in Attachment.A~1, Subject Location 1 is City Hall office. On March 8, 2016, visited office at at Subject Location 1 at the direction of the FBI. was equipped with concealed video and audio recorders. According to and as observed on the video, Subject Location 1 is behind a door that states ?Committee on Zoning.? Subject Location.l bears name and office number, 304. According to and as observed on the video, entered Subject Location 1 and spoke with a legislative aide and an unknown woman, who were located inside Subject Location 1. 148. As discussed herein, SOLIS is the Chairman of the City Council?s Zoning, Landmarks Building Standards Committee. Furthermore, SOLIS has agreed to take official action on multiple 103 Case: 1:16?mc?00261 Document #2 1?2 Filed: 05/27/16 Page 20 of 26 PagelD #:129 and elsewhere. Owing to his chairmanship of the Zoning Committee, and his participation in the affairs of the City Council, it is reasonable to believe that SOLIS maintains within his City Hall office documents relating to development projects that will be heard and have been heard by the Zoning Committee including those projects with.respect to those projects on.which.he has agreed to take or has taken<3fficial action.on is itself proof of his participation.in the Subject Offenses under investigation. 149. Based on their use of telephones located within Subject Location asaxreviewc?fpublic records,]ihave identified City of Chicago employees whO?workansa.part of staff within Subject Location 1. .As noted on multiple occasions herein, SOLIS has maintained contact with these employees (including his legislative aides) for the purpose of obtaining information of his office and to obtain information about his schedule. 150. In addition, based on intercepted conversations, including the intercepted conversation.set forth in paragraph 134, I believe a legislative aide prepared, maintained and/or received lists of individuals and entities for whom SOLIS wished to receive a monetary contribution from, as well as the official action that It.isthereforereasonable to believe that copies of these lists, as well as information 104 Case: 1:16?mc?00261 Document #2 1-2 Filed: 05/27/16 Page 21 of 26 PagelD #:130 on SOLIS, and official action taken.or to be taken on their behalf will be found within Subject Location 1. 151. Additionally, as set forth above, legislative aides to SOLIS have includingt?uaWater Commissioner, and. handled requests from individuals, such. as CALDERO. It is therefore reasonable to believe that information relating to these requests will be found.within Subject Location 1. ii. Subject Location 2 152. As further described in Attachment B?l, Subject Location 25tt1Ward.constituent service?office. website ward25.com, 25th.Ward.constituent service office is located at 1800 South Blue Island. During recent surveillance on 2016, however; surveillancebelieve expenses incurred by the organization in the carrying on of its political activities. This information is relevant to this investigation, because these records will tend to establish what are permissible expenditures (and the reasons for those permissible expenditures) as opposed to the personal expenses of SOLIS and PERALES that have been paid through the use of organization funds. Subject Location 3 156. As further described.in.Attachment C?l, Subject Location 3>is personal residence. The residence is number ?522" affixed to the wall adjacent to the door. According to utility records received on or about April 19, 2016, SOLIS is identified as time resident c?f record ikn: Subject Location 3. According to Illinois Secretary of State records, Subject Location 3 is identified.as SOLIS's residence. On.April 25 and 26, 2016, as well as May 11, 2016, surveillance observed the vehicle registered to SOLIS parked in the front turnaround area of the building in which Subject Location 3 is located. 157. individualSInaintain within.their residences, to include books, records, journals or other records of original entry; ledgers and other records of assets, liabilities, or capital account balances; records of income or expenses including invoices and receipts; records of 107 Case: 1:16-mC-00261 Document 1-2 Filed: 05/27/16 Page 24 of 26 PageID #2133 lessors or lessee; records of receipts or disbursements; accounting information; (9) bank statements, check registers, or canceled checks; duplicate deposit tickets; bank account reconciliations; passbooks, certificates of deposit, money orders, or cashier?s or official checks; records of payroll or employee earnings; (1) records of bartering activity such as exchanges of property or services; financial statements or copiesc?ftaxreturns;and hm records/ledgers or receipts. 158. to the investigation of the Subject Offenses for multiple reasons. Among them are the following. First, as noted earlier in the affidavit, thus far no evidence has been found to demonstrate that SOLIS has paid for the benefits lavished upon him by others. Records documenting expenditures SOLIS ha81nade will allow investigators to determine what items and services SOLIS has paid for, and will also paid for. Establishing the extent of payments SOLIS has made, and for what items and services, will establish what items and services he has not paid for are connectedtxianillicitpurpose. personal finances would tend to show his inability to pay for many of the benefits he has received, such as the use of multi?million dollar farm. Third, because individuals typically maintain documents relating to their finances at home, it is reasonable to believe that SOLIS would maintain documents relating 108 Case: Document #2 1?2 Filed: 05/27/16 Page 25 of 26 PagelD #2134 to any loans he received from GARY FEARS, referenced above in footnote 17, at his residence in the event such documents exist. Such documents would demonstrate the terms of the loan and any payments that have been made with respect to the loan. In addition, documents tending to show a lack of formality or memorialization concerning the terms of the loan would tend to demonstrate that this loan was Eburth,because individuals typically maintain records concerning their personal expenses at home, it is expected that these documents will be found at Subject Location 3, and that these documents will confirm that certain expenditures made by SOLIS using his debit card associated with the 25th Ward Regular Democratic Organization (such as, for example, school tuition expenses) are in fact personal expenses. Finally, it is reasonable to believe that SOLIS will also maintain in his residence documents relating to economic and other benefits as the individuals identified herein who have provided him with benefits. iv. Subject Location 4 159. As further described.in.Attachment D?l, Subject Location In his Statement of Financial Interests that he filed with.the City of Chicago on May 2, 2016, SOLIS identified Subject Location 4 as the residence of his wife. On April 25, 2016 at approximately 9:12 on.April.26, onhkurll, 2016, 109 Case: Document #2 1-2 Filed: 05/27/16 Page 26 of 26 PagelD #:135 at approximately 9:05 on May 12, 2016, at approximately 8:55 on May 17, 2016 at approximately 9:00 on May 25, 2016 at approximately 2016 at approximately 8 :28 the parking garage at Subject Location 4 . FBI surveillance observed SOLIS as the driver of this vehicle on April 25, 2016 and May 11, 2016, and on_other occasions was not able togmositively'identify?the driver. .Although.surveillance was unable to determine the driver of these other occasions, no one else other than SOLIS has been observed. driving this "vehicle during surveillance. With. the exception of May 12, May 17 and May 25, FBI surveillance observed the vehicle proceed to Subject Location 3. Based on intercepted conversations in July and August of 2015, SOLIS and his wife were working to resolve marital issues and had begun living together again after a period.of separations At the same time, SOLIS continues to maintain his residence at Subject Location 3. 160. individuals maintain documents regarding their personal finances, loans, and expenditures within their residences. As noted above, the Ward Credit Card Account has been used for expenditures that appear to be associated with family, to include school and payments for cookware and children?s clothing. Because Location 4, there will be documents confirming that certain 110 Case: 1:16?mC?00261 Document 12 Filed: 05/27/16 Page 26 of 26 PagelD #:135 at approximately 9:05 on May 12, 2016, at approximately 8:55 on May 17, 2016 at approximately 9:00 a on May 25, 2016 at approximately 8 :14 a.m. and on May 26, 2016 at approximately 8:28 the parking garage at Subject Location 4. FBI surveillance observed SOLIS as the driver of this vehicle on April 25, 2016 and May 11, 2016, driver- .Although surveillance was unable to determine the driver of these other occasions, no one else other than SOLIS has been observed. driving this 'vehicle during surveillance. With the exception of May 12, May 17 and May 25, FBI surveillance observed the vehicle proceed to Subject Location 3. Based on intercepted conversations in July and August of 2015, SOLIS and his wife were after a.period.of separation? At the same time, SOLIS continues to maintain his residence at Subject Location 3. 160. As discussed above, based on my training and experience, individuals maintain documents regarding their personal finances, loans, and expenditures within their residences. As noted above, the Ward Credit Card Account has been used for expenditures that appear to be associated with family, to include school and.payments for cookware and.children's clothing. Because SOLIS's Location 4, there will be documents confirming that certain 110 Case: Document 1-3 Filed: 05/27/16 Page 1 of 43 PagelD #1136 Organziation are, in fact, personal expenditures. Additionally, Subject Location 4, which suggests that financial documents, including the apartment lease and.other records, will be located.at this location. For example, (M1 or about March 26, 2015, at on Target Phone 2 to a representative of the property developer behind The Roosevelt Collection, where Subject Location 4 is located. During the call, the representative informed SOLIS that a two bedroom, two bathroom apartment may become available in July. SOLIS informed the representative that he was looking to rent right now and may purchase a property as an investment later. SOLIS also said that he had a unit in River City (Subject Location 3). In another intercepted call on or about June 19, 2015, at approximately 2:41 p.m. (Call #13375), SOLIS placed an outgoing call on Target Phone 2 to ?Roxy" at the Roosevelt Collection. During the call, Roxy informed SOLIS that she had received his application, proof of ofaniapartment att?uaRoosevelt.Collectiond Duringt?uscall, SOLIS informed Roxy that he would_arrange to have his bank automatically transfer rent for the apartment on a certain day. v. Subject Location 5 161. As described:u1AttachmentIldq Subject Location.55?3the business premises of the Copper Tan and Spa, where SOLIS received 111 3 Case: Document 1?3 Filed: 05/27/16 Page 2 of 43 PagelD #:137 prostitution services, as described above in paragraphs 69 through 75, 88 and 89. Based on surveillance and news reports related to a Chicago Police Department raid on the Copper Tan and Spa, which occurred on or about July 31, 2013, Subject Location 5 has video surveillance equipment, which may provide evidence of 5 visit, the method of payment for visit, and the identities of the individuals who provided services to SOLIS and his companions. 162. at the business accepts most credit cards. Based on my training and experience, I know that businesses that accept credit of credit card.transactions in order to receive payment frowlthe lender for the services rendered. Such businesses often maintain other financial records, including receipts, checks, bank and savings and loan records of deposit, statements and other bank records, credit card statements, money of deposit, loan records, customer account information, amd income and expense summaries. 163. Additionally; businesses often_maintain appointment books, calendars, client lists, details of services rendered, that.a client utilizes, and other records of client visits, services rendered and contact information. All the foregoing information will constitute evidence of visits by SOLIS and his companions to this location. 112 Case: Document 1-3 Filed: 05/27/16 Page 3 of 43 PageID #1138 vi. Target Phone 2 164. As further?described:h1Attachment F?l, Target.Phone:2is and text messages discussed above regarding the Subject Offenses. 165. Based upon rm; training anni experience, ll know that information stored within a cellular phone may provide crucial evidence of the ?who, what, why, when, where, and how? of the criminal conduct under investigation, thus enabling the United States to establish and prove each element or alternatively, to exclude the innocent fronxfurther suspicion? In.my training and.experience, the information stored_within.a cell phone can indicate who has used or controlled the cell phone. This ?user attribution? evidence is analogous to the search for ?indicia of occupancy" while executing a search.warrant at a residence. In.this case, establishing use of Target Phone 2 will, among other things, establish.his voice identification in wire interceptions made over Target Phone 2. In (and the data associated with.the foregoing, such as date and time) may indicate who used or controlled the cell phone at a relevant time. Further, such stored electronic data can show and.when the cell phone and.its Such.?timeline" information allows investigators to understand the chronological context of cell phone access, use, and events relating to the crime 113 Case: 1:16-mC-00261 Document 1-3 Filed: 05/27/16 Page 4 of 43 PagelD #:139 under?investigationd This ?timeline? inculpate or exculpate the cell phone account owner. 166. Cellular phones may contain relevant evidence of the Subject Offenses, including text messages made or received from Target Phone 2 that are located in the memory of Target Phone 2, which messages may provide information regarding the identities of, and the methods and means of operation and communication used by, the located in the memory of Target Phone 2 may contain images of participants involved in the Subject Offenses. Moreover, digital photographs stored in Target Phone 2 may contain images of SOLIS, associates (including persons involved in or knowledgeable about the Subject Offenses), places frequented.by SOLIS leading up to and during the Subject Offenses, and locations and instrumentalities used in committing the Subject Offenses. 167. In additionq based.on my training and experience, I know that information stored withhn a cell phone may indicate the geographic location.of the cell phone and user at a particular time (e location integrated.into an image or video sent via email or text message to include both metadata and the physical location displayed in an image or video). Stored electronic data may also provide relevant insight into the cell phone owner?s state of mind as it relates to the offense under investigation. For example, information in the cell phone may indicate the owner?s motive and intent to commit a crime communications relating to the 114 Case: 1:16?mc?00261 Document 1?3 Filed: 05/27/16 Page 5 of 43 PagelD #:140 crime), or consciousness of guilt (e deleting communications in an effort to conceal them from law enforcement). Unless this data is itself orknrajprograntthat deletes or over?writes the data contained within the cell phone, such data will remain stored within the cell phone indefinitely. 168. Through experience as 21 law enforcement officer and through the experience of other law enforcement officers as conveyed tt>me, I have learned that individuals involved in criminal offenses commonly use cellular telephones as a means to cemmunicate. As detailed above, SOLIS used Target Phone 2 to communicate with a number of individuals regarding and.in connection.to the Subject Offenses. numbers and names or nicknames of fellow conspirators on their telephones and the telephones also reflect recent call history. Finally, individuals often use text messaging and digital on cellular telephones. Because, as explained above, Target Phone 2 is associated with SOLIS, because there was telephonic and because, in my experience and in the experience of other agents, defendants use telephones to contact co-conspirators, there is probable cause to believe Target Phone 2, described further in Attachment F?l, contains evidence of the Subject Offenses. vii. Specifics Regarding Searches of Computer Systems. 115 Case: 1:16?mc?00261 Document 1?3 Filed: 05/27/16 Page 6 of 43 PagelD #:141 169. Based upon my training and experience, and the training and experience of specially trained computer personnel whom.I have consulted, searches of evidence from computers commonly require agents to download or copy information.from the computers and their components, items (computer hardware, computer software, and, computer related. documentation) in; be processed later by a qualified computer expert in a laboratory or other controlled.environment. This is almost always true because of the following: a. Computer storage devices can store the equivalent of thousands of pages of information. Especially when the user wants file names. This requires searching authorities to examine all the stored.data.to determine whether it is included in the warrant. This sorting process can take days or weeks, depending on the volume of data stored, and it would be generally impossible to accomplish this kind of data search on site. b. Searching computer systems for criminal evidence is a highly technical process requiring expert skill and a properly controlled environment. The vast array of computer hardware and software available requires even computer experts to specialize in some systems and.applications, so it is difficult to know before a search which expert should analyze the system and its data. The search of a computer system is an exacting scientific procedure which is designed to protect the integrity of the evidence and to recover even 116 Case: Document #2 1-3 Filed: 05/27/16 Page 7 of 43 PagelD #:142 hidden, erased? compressed? or Since computer evidence is extremely vulnerable to tampering or destruction (whiCh may be caused by malicious code or normal activities of an operating system), the controlled environment of a laboratory is essential to its complete and accurate analysis. 170. In order to fully retrieve data from a computer system, the analyst needs all storage media as well as the computer. The analyst needs all the system software (operating systems or interfaces, and hardware drivers) and any applications software which may have been.used to create the data (whether stored.on hard disk drives or on external media). 171. In order tc>gain.access to data fronta'computer systenxand to fully analyze that data, an analyst may need to have access to the following information.or equipment: passwords, keys, and other access devices that may be necessary to access the computer equipment; documents or other items demonstrating the presence or absence of computer software that would allow others to control the items, and presence or absence of security software designed to detect such malicious software; documents or other items demonstrating the attachment of other computer hardware or that are designed to eliminate data. 172. Inadditnmr and Internet connection interface may be instrumentalities of the 117 Case: 1:16mmc-00261 Document 1?3 Filed: 05/27/16 Page 8 of 43 PagelD #:143 or were used to carry out criminal activity. Procedures To Be Followed In Searching Computers and Electronic Storage Devices. 173. The warrant not authorize the ?seizure" of computers and related media within the meaning of Rule 41(c) of the Federal Rules of Criminal Procedure. Rather the warrant sought by this Application will authorize the removal of computers and.related1nediasn3that they may be searched.ineasecure environment. Where practicable, however, agents will image the computers and related media on?site. 174. With.respect to the search of any computers or electronic storage devices seized from the locations identified.in.Attachment A?l, B?l, C?l, D?l, Eel, and F?l hereto, the search procedure of electronic data contained in any such computer may include the following techniques (the liSt, and the government may use other procedures that, like those listed.below, minimize the review of information not within the list of items to be seized as set forth herein): a. examination of all of the data contained in such computer hardware, computer software, and/orlnemory'storageidevices to determine whether that data falls within the items to be seized as set forth herein; 118 Case: Document 1-3 Filed: 05/27/16 Page 9 of 43 PageID #:144 b. the list of items to be seized as set forth herein (any data that is and. unreadable will not. be returned 'unless law enforcement personnel have determined that the data is not (1) an instrumentality of the Cifenses, (2) a fruit of the criminal activity, CH contraband, UH evidence of the offenses specified above); c. surveying various file directories and the individual files they contain to determine whether they include data falling within the list of items to be seized as set forth herein; d. opening or reading portions of files in order to determine whether'their contents fall within the items to be seized as set forth herein; e. scanning storage areas to discover data falling within the list of items to be seized as set forth herein, to possibly recover any such recently deleted data, and to search for and recover deliberately hidden files falling within the list of items to be seized; and/or f. performing key word searches through all storage media to determine whether occurrences of language contained in such storage areas exist that are likely to appear in the evidence described in Attachments A-2, E-2, and g. Any computer systems and electronic storage devices removed.from the premises during the search will be returned to the 119 Case: 1:16?mC?00261 Document 1?3 Filed: 05/27/16 Page 10 of 43 PageID #2145 premises within a reasonable period of time not to exceed 30 days, or unless otherwise ordered by the Court. IV. CONCLUSION 175. and fruits of the Subject Offenses are located within the Subject Premises. By this affidavit and application, I request that the Court issue a search warrant authorizing the search of the Subject Premises for the items described.in.Attachments Bw2, C-2, and FURTHER AFFIANT SAYETH NOT. - Steven D. Noldin Special Agent Federal Bureau of Investigation Sworn to before me and subscribed in my presence this 27th day of May, 2016 1 W??w u. ed St es Magistrate Judge 120 Case: Document #1 1?3 Filed: 05/27/16 Page 11 of 43 PagelD #:146 {Bil?y?il?i?l H. :B?iaiw?gww51:. w. . . 'i Case: lle?mc-OOZBI Document #2 1-3 Filed: 05/27/16 Page 12 of 43 PagelD #:147 {le??ELLEil?e ?53:5. a it? ?11?z?litwe: Nd: fins: iiowl?ilnri 2. Information related to fundraising activities inchiding advertisements, photographs, invitations, letters or records of contributors and/or attendees at fundraising events; 3. Lists, spreadsheets or other records of potential or actual campaign contributors including, but not limited to, contributors with potential matters before the Chicago City Council or a representative body or committee thereof; 4. Calendars, schedules and communications of staff members; 5. Letters and correspondence concerning matters which have appeared or may likely appear before the Chicago City Council or a representative body or committee thereof, including the Zoning Committee, actions Daniel Solis has taken on those matters, as well as benefits received by Daniel Solis from any other party; 8, {lfiedit card statements bills, payment records/lodgijers or ts; titer! A I 32*: i r; 511,; . ii?? I, ii 1 ?i .2 2:21;: - Case: Document 1?3 Filed: 05/27/16 Page 13 of 43 PageID #2148 33. 0232:1133??nin {g occt?mancy of the 531.1 hject Prez'nises (described 3.531%: 3 e07 . :3 3.71313; ?n ma in agei?in .: b.3003? 1?3. 5 33.33., 1: 11h, it}. LU an?; cwinpum?. *thliplubrlb m: titili?i. a. Passwords, keys, and other access devices that ma 3 be necessar to access the com Juter ui )rnent. I 1). Documents or other items demonstrating the presence or absence of computer software that would allow others to control the items, and presence or absence of security software designed to detect such malicious software. Documents or other items demonstrating the attachment of other computer hardware or storage media. d. Counter forensic programs and associated data that are designed to eliminate data. 11. Items in the paragraphs above that are stored. in computer media, including media capable of being re All. 17:? a {such as external and internal Niki :31} ll. kl}; .. . than; and ?m 11-3 i Case: 1:16?mc?00261 Document 1?3 Filed: 05/27/16 Page 14 of 43 PagelD #:149 1 '3 P..- 1 4 73.21 {521638 CW Case: 1:16-mc-00261 Document #2 1?3 Filed: 05/27/16 Page 15 of 43 PagelD #:150 35; 32.1153 ?:is}: 1. -: Ul'. "stunt-s1 {33.1 has .. :muS-ct i 3 2x0. iUiil? c1533 z: struts: n. iron; the premises described in Attachment may include the foliawarine? techniques (the tollowina" is a nonexclusive list, and the government may use other procedures that, like those listed below, minimize the review of inibrmation not within the list of items to be seized as set forth herein): a. examination of all the data contained in such computer hardware, computer software, and/or memory storage devices to determine whether that data falls within the items to be seized as set forth in Attachment b. searching for and attempting to recover any deleted, hidden, or data to determine whether that data falls within the list of items to be seized as set forth in Attachment (any data that is and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4) otherwise unlawfully possessed, or (5) evidence of the offenses specified abovek c. surveying file directories and the individual files they contain to determine whether they include data falling Within the list of items to be seized as set forth in Attachment and i enemas: or reading-j portions of files, and performing hey word searches of in ?nder to. i [ermine i?ir?i ?75 41 ti.23Case: Document 1-3 Filed: 05/27/16 Page 16 of 43 PageID #:151 {71? .- ?1 $42 5 A. Case: Document 1-3 Filed: 05/27/16 Page 17 of 43 PagelD #:152 B1 13:13:81?) 03:: 59.21.131111311.? BE SEA (1:111:10 I- .1 . . ?143 v?Limit {??rv'iw *7 (111-.: 1.1-1.1. UH i .2 :1 1.1.: (in s:2. 1111:2311. 1: The {4:1221'511132 f? r. . ?3 H. 11:11.: 131m: 21:11:12.1 :51: E5: 31%1?112graph: A {6:51.4an W. urmmw - um ?1 utuh?w .m ?km? ?annmqam Mum? m?mm a wrlumrunn 14$1111..Ea? . 1" Case: 1 :16?mc- 00261 Document 1?3 Filed 05/27/16 Page 18 of 43 PagelD 153 Case: Document #2 1-3 Filed: 05/27/16 Page 19 of 43 PageiD #:154 1113MB TO BE SEIZELD 'flg?fi?i 2131a?? ?czcei?ftlt-i 5-1; 5:2 (bins tie - till?? rises aria Ll met ?you sin.? i. eca?synis: to lundraisnig activities including advortisemc-nti-s, photographs, invitations, letters or records of contributors and/or attendees at fundraising events; 3 Lists, spreadsheets or other records of potential or actual campaign contributors including, but not limited to, contributors with potential matters before the Chicago City Council or a representative body or committee thereof; 4. Calendars, schedules and communications of staff members; 5. Letters and correspondence concerning matters which have appeared or may likely appear before the Chicago City Council or a representative body or committee thereof, including the Zoning Committee, actions Solis has taken on those matters, as well as benefits received by Daniel Solis from any other party; (3. Credit card. statements, bills, payment records/ledgers or receipts; 133mm: to include reporting dmoments such a" i ?t i . Case: Document #1 1?3 Filed: 05/27/16 Page 20 of 43 PagelD #:155 ?02213312222233 eon. occupancy 0f the all} 1:21object 3.33.2emises in 222 23.22; .2222" telephone; 232.2312; envelopes, 2222 2303232723232 .32} 2132.332522;3.12: 41,2. 2 22.2 . - 3.32 2.22:333213222- "24.22:; 2:22:32 222313125 {With 1:3} 222?.? ?6 Him? 2 2. 2 . 2 ignite-2? 21.2. 5 l? 32:21.2: :3 3.2.2.2.: 23> 1.2 Beg/s, and. other access device :23 that may be necessary to access the computer equipment. Documents or other items demonstrating the presence or absence of computer software that would allow others to control the items, and presence or absence of security software designed to detect such malicious software. C. Documents or other items demonstrating the attachment of other computer hardware or storage media. 01. Counter forensic programs and associated data that are designed to eliminate data. 11. Items in the paragraphs above that are stored in computer media, including media capable of being read by a computer (a uch as external and internal hard driecs. 1115311101337 sticks. and thumb drier} and el .lmi 2 . ecti?nmc 2.1.f :2 r3222)?. 22 a Case: 1:16-mC-00261 Document #2 1-3 Filed: 05/27/16 Page 21 of 43 PagelD #2156 .1: aura. my. magnem. 1m 131,1..iees or data {such <_:elhidn_1? teiomhcmes; :71 m3 r3467by; ,ceimi}. 134: Fungi! {theta Ls: Karla}; {.1165 Case: 1:16-mc-00261 Document 13 Filed: 05/27/16 Page 22 of 43 PageID #1157 AQDENDUM TO ATTA 3? if 1.112s 1.12133. 1.1.1.1193. ef. 11?h .2) {in} oi? the Federal Roles of P11icednre. 11:11.: . 77.213". 32!. 5.7.31.? f} 1.15351} nu. 01,535 nil?! .1 Li?il?. ?33 {til 4.391111%: 3.17. "-3.3332133131 l3. 3 1 Hm. 11.1911 If. .21 1.1.: ale 3: Hahn 211,633 :33. l} 3 1 9 Jib-5 i . 1 i . 3,33." 3 . 3 1. 3: 1:13: til. 1111:: :131.111.113.1311; $111: 23:12.1. 1.1.1.112 1:213 1.21.1311? 15:31:31 1:11.131: it: 11.11311113335;s aletintilia-gd in Attachment may 1.1.1113} ode the r-a - 1 trite-l3sinner?; 1.1.ine 1231101111113; is list, 2.131 the 1:11:13 1.1 se other procedures that, like those listed below, minimize the review of information not Within the list oi? items to be seized as set forth. herein): a. examination of all the data contained in such computer computer software, and/or memory storage devices to determine Whether that data falls within the items to be seized as set forth in Attachment b. searching for and attempting to recover any deleted, hidden, or data to determine Whether that data falls within the list of items to be seized as set forth in Attachment 13?2 (any data that is and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4) otherwise unlawfully possessed, or (5) evidence of the offenses specified above? c. surveying ?le directories and the individual files they contain to determine whether they include data falling Within the list of items to be seized as set forth in Attachment and d. opening or reading portions of ?les, and performing key word searches of files, in order to determine whether their contents fall within the items to be seized set forth in Attachmont 8-Case: Document 1-3 Filed: 05/27/16 Page 23 of 43 PagelD #:158 Cm]; 0F PREMISES TO BE SEARCHED .3 7-335 I 'l I rum; Mn}. ?15 .z?ii; Ham? n. 1.11.314. [Whine-i {in 7:4 {?itti??Li-J 'aai'?'?4i'1in "Bliigdillg-f as: {335.425n? 411:?. "$5312 .2: And wad: mm ?2322;?, 3:3 zii?xed the adj?d.ae135ii to {z :311fTa?mm3. zentranue ilt'f?r U135: 172,3 :8 a th panel entrance door with a silver calmed door knocking device attached. Case: 1116-mc?00261 Document 1?3 Filed: 05/27/16 Page 24 of 43 PagelD #:159 LIST Fill? lil?li?il?y?fm TO BE SEIZED 1? I 1 13 ?11 lg; ilfg leans um. i 1'1 di ii 1:331:11 . i .17 cl 1de 51. Books, records, journals or other records of original b. Ledgei?s and other records of 2-issets, liabilities, or capital account. balances; (2. Records of income or expenses including invoices and receipts; d. records or lessee; 0. records of receipts or disbursements; f. accounting information; g. bank Statements, check registers, or canceled checks; h. duplicate deposit tickets; i. bank account reconciliations; j. liuissl?iooks, certi?cz'ites of deposit, money orders, 01' 322.141.1143 .2 Case: DocUment 1?3 Filed: 05/27/16 Page 25 of 43 PageID #:160 . .bartering; ecuVita: seen of we. {:12 i2 '1 211.. i; gm-fi is 12v ?nial Hire-iv :1 lip: {hires}. Esslirr tree: 2mg; {stinky we 271:? 2315331123542. bills; or Decoii?iente (:chiigiaiicji? of the Subject Premises (iilescrilu-wf. in Cal), such as utility and telephone bills. mail envelopes, or addressed correspondence_: and 4. Computers, electronic devices and removable media storage devices which may contain informa?iticm related to the above items. 5. With respect to any computer equipment or other electronic devices: a. Passwords, keys, and other access devices that may be necessary to access the computer equipment. 1). Documents or other items demonstrating the presence or absence of computer software that would allow others to control the items, and presence or absence of security software designed to detect such malicious software. er? Hi? shirt?! 2.3.121 (lliaLll??EL?Wi Case: 1:16-mc-00261 Document #1 1-3 Filed: 05/27/16 Page 26 of 43 PagelD #:161 d. programs and aSW?Nj?i?dted data-1 111m 1: are {ii-Eeigz?ned in {jaliillhh?sifa} ?21 {1:31. JJ'=ug 4n. :52: 13?gi?rizini3a s?g??Vf; iluuii L?vyizwi ?Ri 3i??ir?ii.1 hevd drhar; ?nauhfy and :hw?rnui? (Searicxear Hm? sepalj?e oi zl'atm?yiaia'zg; {USP}tljy'ihgf, or itmnenxiuing electronic or magnetic {:mnputer impulses; data (such as (:elhllar telephones and PDAS), Shall be searched in accordance with the attached Addendum. Case: Document#: 1?3 Filed: 05/27/16 Page 27 of 43 PagelD #2162 YQMAILA LIMEMAQ l1'211's'222227221: 2'2; l-ti'de of the Rules of(1322222221221 this the :22 211""! 212,222.22 32222222.? .2272 the 3.2.2. 2. l7 iiui?i'f 3.13 it}: 15.5" '33? ii)? 1.12:. awn-2.2 22 23222.2. a ate-272i he 2'21? ?2 ?l?he aimed and eieeti23222:: 13:22:21 the pijeinhises do5-2::2Til52e2l. :22 Attachment 212.223" inehale the 22212222222: (the following is a. list, and ties: genie2722.22.22:at 22?2222: uzsxe (1'2t?1liei? procedures that, like those listed below, minimize the review of 22122212122222.2021 not within the list of items to be seized as set forth herein): a. examination of all the data contained in such computer hardware, computer software, and/or memory storage devices to determine Whether that data falls Within the items to be seized as set forth in Attachment b. searching for and attempting to recover any deleted, hidden, or data to determine whether that data falls Within the list of items to be seized as set forth in Attachment (3-2 (any data that is and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4) otherwise unlawfully possessed, or (5) evidence of the offenses specified above); (3. surveying file directories and the individual files they contain to determine Whether they include data falling Within the list of items to be seized as set forth in Attachment 02; and d. opening or reading portions of files, and key word searches of files, in order to determine whether their contents fall within the 7 . 22-2 . V. .. 1 -22 .210, 126:22222 2.22 he as .2202. 10?: l. 11 111 L. Case: Document 1-3 Filed: 05/27/16 Page 28 of 43 PagelD #:163 37513131+1W?itii undid Wm?d?h (24.11%.erband m: gm 315511 12331-9 in {3i (?fl??fh i e, herwiee ()rdpm? by; Hm (?our . Case: 1216-1110-00261 Document 1~3 Filed: 05/27/16 Page 29 of 43 PagelD #:164 ?v9: 9 Case: 1:16?mc?00261 Document #2 13 Filed: 05/27/16 Page 30 of 43 PagelD #2165 1.13155 TO BE SLEEIZEIElli; ii?ili 11 i 2n almi- 3. Books. records, journals or oiher records of original b. Ledger?s and other records of assets, liabilities, or capital account balances; c. Records of income or expenses including invoices and receipts; d. records of lessors or lessee; e. records of receipts or disbursements; f. accounting information, including trial balances or work sheets adjusting, reclassi?ving, closing, or reversing entries; g. bank statements, check registers, or canceled checks; h. duplicate deposit tickets; in bank, account reconciliations: cl ii iftunsj? ?cilia i Case: Document 1-3 Filed: 05/27/16 Page 31 of 43 PagelD #:166 l. of bartering activity such as exchanges of 2 it ?l~twfl?3 a: ti} i 2 3.2.7223 :as: 22::2 .2 2 2 l2}? 1322222232, we: {2252221 any 2:22.172 57:12:23 med tetaenraan2:23.. hills, peg-Tintint or Documente eccupancy of the Subject Premises (deriscrihed in Attachment such as utility and telephone bills, mail envelopes. or addressed and Computers, electronic devices and removable media storage devices which may contain information related to the above items. 5 With respect to any computer equipment or other electronic devices: a. Passwords, keys, and other access devices that may be necessary to access the computer equipment. I). Documents or other items demonstrating the presence or absence of computer software that would allow others to control the items. and presence or absence of security software designed to detect such malicious softw: re. l? 2 2:17thz:=r itemx? t1 ?i 3 Case: 1:16?mc?00261 Document 1-3 Filed: 05/27/16 Page 32 of 43 PagelD #2167 d. {703.313.3333} {70130333393113 pmgcamc and 3.13.1333 (hail 3.5331321311?11cd 313:3 311333121. 31:3233333 3.33 11.333.33.31 3'3 31333.33: 13/373333 133313 9 133? 331-34331 =51 1113313333933 3.43.13 3 313-3331.: 33.3% b.3333?? J. 4 1.3., 31m3.3343331111133331: electronic magnetic computer 11111311133933 01' data (such as cc} ?3.1333. 3.31.: 1313131113333 331 11111335.; 3131,13. 1,1. 31:31.3.1113. 1.213133333131g; 170 3* 11331133131333. 332.1131. 3.3133113}? 3733333311233}. 11131"? C) 1' inlay and PDAS), Shall be searched in accordance with the attached (1310 11 (l . . 1? Case: Document 1-3 Filed: 05/27/16 Page 33 of 43 PagelD #:168 ADDENDUM TO ATTACHMENT 1:93;} :31 Rule of the Farleral Rule; of this 3? ar?ta "331thrr?3?3w 3L3 elm:aggjri: media 135:3?? . a? 3 anal ihar 33a3111 lala? 31331 333.? . 3 . 3.1.1.33. +1.1 1.1a3.311.133-..31 . 1,33 3, ., 3 . . l?i?-H 1 i=1? ?Jr. 11:3 . '5 J. .515?: 333 37:337i33ar (if 1313733113 {initugilly stored 2-31'1d eiezfif'r1113in :313'1'31'311 ail-aedira. 133.113 31 he preigruiscrz-Z: glarsaasrilred. in attachniaent U31 1113 include H3 g-g, 1 {the l?aisllowing: is a list, and the grairvejrninient 1132-1}; 1.13.333 othn-ri- 1aroaxethan-13s that, like those listed below, minimize the review of information not within the list of items to be seized as set forth herein): a. examination of all the data contained in such computer hardware. computer software, and/or memory storage devices to determine Whether that data falls Within the items to be seized as set forth in Attachment b. searching for and attempting to recover any deleted, hidden, or data to determine Whether that data falls Within the list of items to be seized as set forth in Attachment (any data that is and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4) otherwise unlawfully possessed, or (5) evidence of the offenses specified above); c. surveying file directories and the individual files they contain to determine Whether they include data falling Within the list of items to be seized as set forth in Attachment and (1. opening er reading portions of files, and performing~ key word searches of files, in order to determine Whether their contents. fall Within the to be 13:13:13.3 ail as 3330*. forth in Attachniiziant 3. bi ill?. ?11. 1:1 . 11.3.32?: 11Case: Document 1?3 Filed: 05/27/16 Page 34 of 43 PageID #2169 stmrage mediz-z {:(mtains or mt nfcrinm. mm 12111933 ofhwwim by the Case: Document 1?3 Filed: 05/27/16 Page 35 of 43 PagelD #:170 i 1 :iwzg Case: 1:16-mc-00261 Document #2 1-3 Filed: 05/27/16 Page 36 of 43 PagelD #:171 I lz TO Eli? finl?ueriti? .i?rnmises era" ., if} uiilfl?i??lit?i i and his}: {to include Emilierto CslilerriVideo surveillance equipment and recordings; 2. Financial records, including receipts, checks, bank and savings and loan records of deposit, statements and other bank records, credit card statements, money orders, cashier?s checks, passbooks, cancelled checks, certificates of deposit, loan records, customer account information, and income and expense summaries. 3. Appointment books, calendars, client lists, details of services rendered, the names of masseuses that a client utilizes, and other records of client Visits, services rendered and contact information; and 4. Computers, electronic devices and removable media storage devices which may contain information related to the above items. Case: Document 1-3 Filed: 05/27/16 Page 37 of 43 PagelD #:172 ?23: ?2 911.32% i {5?21} 2,218? 2f the lili=d2i