John J. Flood   Bio & Jim McGough (Biography)
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<PRE>
                                                                    1
         1              IN THE UNITED STATES DISTRICT COURT
                       FOR THE NORTHERN DISTRICT OF ILLINOIS
         2                       EASTERN DIVISION
         3     MOTHER and FATHER on their own   )
               behalf and as guardian of the    )
         4     estate of their son, JOHNNY DOE, )
               or R.G., a minor,                )
         5                                      )
                             Plaintiffs,        )
         6                                      )
                      vs.                       )   No. 99 C 3259
         7                                      )
               JAMES CASSIDY #20207, ALLEN      )   Judge Lefkow
         8     NATHANIEL #20443, SGT. STANLEY   )
               ZABORAC #1139, SGT. DANIEL       )
         9     BRANNIGAN #1469, COMMANDING      )
               YOUTH LT. K. BROWN #202, DET.    )
        10     PAUL JACKSON #20932, YOUTH INV.  )
               VINCENT JAMES #40321, YOUTH INV. )
        11     ANTHONY POWELL #40060, SGT.      )
               NELSON #1931, DET. DOLORES MYLES )
        12     #20242, DET. SAMUEL BROWN #20826,)
               DET. DEVON ANDERSON #5114,       )
        13     COMMANDER DANIEL GIBSON, YOUTH   )
               INV. CHARLES BOWEN #40225, and   )
        14     the CITY OF CHICAGO,             )
                                                )
        15                   Defendants.        )
        16            The deposition of TERRY G. HILLARD, pursuant
        17     to notice and pursuant to the Federal Rules of Civil
        18     Procedure for the United States District Courts
        19     pertaining to the taking of depositions, taken before
        20     Carmella T. Fagan, C.S.R., R.P.R., Notary Public
        21     within and for the County of Cook and State of
        22     Illinois, at 3510 South Michigan Avenue, Fifth Floor,
        23     in the City of Chicago, Cook County, Illinois,
        24     commencing at 1:10 p.m. on the 17th day of May, 2001.

                           


                                                                    2
         1                    There were present during the taking
         2     of this deposition the following counsel:
         3
                              THE PEOPLES LAW OFFICE,
         4                    (1180 North Milwaukee Avenue
                               Chicago, Illinois  60622)
         5                    BY:  MR. G. FLINT TAYLOR
                                   On behalf of the Plaintiffs;
         6
                              THE PEOPLES LAW OFFICE,
         7                    (1180 North Milwaukee Avenue
                               Chicago, Illinois  60622)
         8                    BY:  MS. JAN SUSLER
                                   On behalf of the Plaintiffs;
         9
                              SHEFSKY & FROELICH,
        10                    (444 North Michigan Avenue
                               Chicago, Illinois  60611)
        11                    BY:  MR. MICHAEL SHEEHAN
                                   On behalf of the City of Chicago;
        12
                              SHEFSKY & FROELICH,
        13                    (444 North Michigan Avenue
                               Chicago, Illinois  60611)
        14                    BY:  MR. BRIAN L. CROWE
                                   On behalf of the City of Chicago;
        15
                              ASSISTANT CORPORATION COUNSEL,
        16                    (Individual Defense Litigation
                               Division
        17                     30 North LaSalle Street
                               Room 900
        18                     Chicago, Illinois  60602)
                              BY:  MS. EILEEN E. ROSEN
        19                         On behalf of the
                                   Individual Defendants.
        20
                              CITY OF CHICAGO, DEPARTMENT OF POLICE,
        21                    (General Counsel to the Superintendent
                               3510 South Michigan Avenue
        22                     Chicago, Illinois  60653
                              BY:  MS. KAREN A. ROWAN
        23                         On behalf of Terry G. Hillard.
        24

                           


                                                                    3
         1                           I N D E X
         2     WITNESS:                                   PAGE
         3     TERRY G. HILLARD
         4         Examination by Mr. Taylor:                4
         5
         6
         7                        E X H I B I T S
         8
                      Plaintiffs' No. 298                   22
         9            Plaintiffs' No. 299                   42
                      Plaintiffs' No. 300                  107
        10            Plaintiffs' No. 301                  140
                      Plaintiffs' No. 302                  146
        11            Plaintiffs' No. 303                  146
                      Plaintiffs' No. 304                  149
        12            Plaintiffs' No. 305                  171
                      Plaintiffs' No. 306                  184
        13            Plaintiffs' No. 307                  219
                      Plaintiffs' No. 308                  227
        14
        15
        16
                                CERTIFIED QUESTIONS
        17
                      None.
        18
        19
        20
        21
        22
        23
        24

                           


                                                                    4
         1                        (Witness sworn.)
         2                       TERRY G. HILLARD,
         3            called as a witness herein, having been first
         4     duly sworn, was examined and testified as follows:
         5                          EXAMINATION
         6     BY MR. TAYLOR:
         7   Q   Okay.  Could you state your name and
         8     spell your last name for the record,
         9   A   Terry G. Hillard, H-i-l-l-a-r-d.
        10   Q   Superintendent Hillard, are you the
        11     superintendent of police of the Chicago Police
        12     Department?
        13   A   Yes, sir.
        14   Q   And for how long have you held that
        15     post?
        16   A   Approximately three years and two
        17     months.
        18   Q   Okay.  So that would be approximately
        19     March, February or March, of --
        20   A   February the 18th, 1998, is when I was
        21     promoted by the mayor.
        22   Q   Okay.  How long have you been with the
        23     Chicago Police Department?
        24   A   I'm in my 34th year now.

                           


                                                                    5
         1   Q   Okay.  Prior to becoming the
         2     superintendent, were you the chief of detectives?
         3   A   Yes, sir.
         4   Q   Okay.  How long did you hold that
         5     post?
         6   A   As I remember, it was close to
         7     probably about 25, 26 months, somewhere right in
         8     there.
         9   Q   Okay.  Did you have deputy chiefs
        10     working for you?
        11   A   Yes, I did.
        12   Q   Was one of those deputy chiefs Richard
        13     Frangella?
        14   A   Yes, sir.
        15   Q   Which field group was he in charge of?
        16     Do you recall?
        17   A   His name is John Frangella.
        18   Q   I'm sorry.  Do you remember which
        19     field group he was in charge of?
        20   A   As I remember, he was in Field Group
        21     A, the south side.
        22   Q   Now, who was in charge of Field Group
        23     B under your command?
        24   A   As I remember, I believe Deputy Chief

                           


                                                                    6
         1     Maurer, I believe.
         2   Q   That's M-a-u-r-e-r?
         3   A   Yes.
         4   Q   All right.  Now, did you answer to a
         5     deputy superintendent as chief of detectives?
         6   A   Yes, sir.
         7   Q   And who did you answer to?
         8   A   Deputy Superintendent Michael Malone.
         9   Q   He was the deputy in charge of what
        10     services, Inspectional?
        11   A   Bureau of Investigative Services.
        12   Q   Investigative.  I'm sorry.  He, in
        13     turn, answered to the superintendent; is that right?
        14   A   Yes, sir.
        15   Q   At that time was Rodriguez the
        16     superintendent?
        17   A   Matt Rodriguez.  Yes, sir.
        18   Q   Now, prior to the 26 months or so that
        19     you spent as chief of detectives, where were you
        20     assigned?
        21   A   Prior to that I was the deputy chief
        22     of Area 2 Patrol Division, south side.
        23   Q   How long did you hold that post?
        24   A   It was close to a little over two

                           


                                                                    7
         1     years, I think.
         2   Q   Now, did you answer to a deputy
         3     superintendent in that post as well?
         4   A   I really answered to the chief of
         5     Patrol.  That was my immediate supervisor, the chief
         6     of Patrol, at that time.
         7   Q   And who was he?
         8   A   It was John Cadigan.
         9   Q   What year did you become a Chicago
        10     police officer?
        11   A   11 March 1968.
        12   Q   And did you for a while after that
        13     assume patrol -- did you go to the academy?
        14   A   Yes, sir.
        15   Q   How long were you in the academy?
        16   A   You're talking about a long time ago.
        17     I think I was probably in there close to about 13, 14
        18     weeks.
        19   Q   Okay.
        20   A   An approximation.  I don't know exact.
        21   Q   What was your educational background
        22     prior to coming to the police department?
        23   A   I had a high school education.
        24   Q   What high school did you graduate

                           


                                                                    8
         1     from?
         2   A   Wendell Phillips High School.
         3   Q   Here in Chicago?
         4   A   Here in Chicago.
         5   Q   After you came out of the academy,
         6     were you assigned to a particular police district?
         7   A   Yes, sir.
         8   Q   Did you have particular duties at that
         9     district?
        10   A   Yes, sir.
        11   Q   For how long and to what district were
        12     you assigned?
        13   A   I went to the 18th District.  That was
        14     the old Chicago Avenue District, and I spent
        15     approximately about seven, eight months there.
        16   Q   Did you move to other districts as a
        17     patrol officer?
        18   A   From there I went to what we called
        19     the Task Force, South Side Task Force, at 91st and
        20     Cottage Grove.
        21   Q   Did that have different investigative
        22     functions than a patrol officer?
        23   A   I was -- it was in Patrol.  I was
        24     still in Patrol.

                           


                                                                    9
         1   Q   How long did you stay at the Task
         2     Force?
         3   A   I would say approximately a little
         4     over two years.
         5   Q   All right.  Then where were you
         6     assigned?
         7   A   Then I went to -- I got, as I remember
         8     -- and this is not verbatim now.  As I remember, I
         9     got assigned to the 7th District and then back to
        10     Task Force.  Then I went to the 2nd District --
        11   Q   Okay.
        12   A   -- and then went to bodyguard detail
        13     with Daddio Daley.
        14   Q   Okay.  What year was that that you
        15     went to bodyguard detail?
        16   A   It was in the early '70s.  I can only
        17     tell you that.
        18   Q   Did at some point you make sergeant?
        19   A   Yes, sir.
        20   Q   And when was that?
        21   A   Uh, that was in the early part of the
        22     '80s, I believe it was, 1980, '81.
        23   Q   Have you ever been a detective?
        24   A   No, sir.

                           


                                                                   10
         1   Q   So when you made sergeant, were you
         2     then assigned to a patrol district?
         3   A   No, sir.
         4   Q   Where were you assigned?
         5   A   I was on the dignitary protection
         6     security detail for Mayor Jane Byrne.
         7   Q   And then did you continue to be on
         8     that detail with Mayor Washington for a while?
         9   A   When Mayor Washington came in, I left
        10     for a period of time, but I was brought back.
        11   Q   Was that during the time that you went
        12     to the FBI for a while or were detailed to the FBI?
        13   A   Yes, sir.
        14   Q   At some point did you conclude your
        15     duties as being on the detail for Mayor Washington?
        16   A   Yes, sir.
        17   Q   What year was that?
        18   A   It was -- I left, going to the FBI
        19     academy, in July of 1984 and went there for
        20     approximately three months.  It was almost three
        21     months.  And when I came back, I was assigned to the
        22     9th District.
        23   Q   As a sergeant?
        24   A   Yes, sir.

                           


                                                                   11
         1   Q   And how long did you stay at the 9th
         2     District?
         3   A   Probably about three days.
         4   Q   Okay.  And then where were you
         5     assigned?
         6   A   I went back to the Intelligence
         7     Section.
         8   Q   You worked as a sergeant in the
         9     Intelligence Division?
        10   A   Yes, sir.
        11   Q   And for how long did you stay there?
        12   A   Approximately six and a half years.
        13   Q   And had you been at the Intelligence
        14     Division prior to that?
        15   A   Just for the little time between when
        16     I had left Mayor Byrne's detail and when I went back
        17     to Mayor Washington's detail.
        18   Q   Okay.  So for the six and a half years
        19     that you were at the Intelligence Division, that was
        20     in the late '80s?  Is that when that was?
        21   A   Yes, sir.
        22   Q   Did you have a particular assignment?
        23     Did you work organized crime or some other aspect,
        24     generally speaking, in the Intelligence Division?

                           


                                                                   12
         1   A   Yes, sir.
         2   Q   What did you work?
         3   A   First I started out and I started
         4     working organized crime and moved from organized
         5     crime to working terrorism.
         6   Q   Okay.  Did at some point you leave the
         7     Intelligence Division?
         8   A   When I got promoted to lieutenant.
         9   Q   What year was that?
        10   A   That was about 1990, '91, somewhere in
        11     there.
        12   Q   Okay.  Upon leaving and becoming a
        13     lieutenant, where were you assigned?
        14   A   I went to Gang Crimes South at 51st
        15     and Wentworth as a watch commander.
        16   Q   All right.  Were there any particular
        17     youth gangs that you specialized in with regard to
        18     your work at Gang Crimes?
        19   A   No, sir.
        20   Q   You dealt with all investigations as
        21     to any gangs that were in Gang Crimes South?  Was it
        22     Gang Crimes South at that point?
        23   A   It was Gang Crimes South.  I was a
        24     watch commander in charge of the afternoon watch.

                           


                                                                   13
         1   Q   And for how long did you stay at Gang
         2     Crimes South?
         3   A   Approximately four and a half months.
         4   Q   From there where were you assigned?
         5   A   I was assigned to the Narcotics
         6     Division over at 35th Street.
         7   Q   That was, what, in 1991?
         8   A   It was about 1991.  Yes, sir.
         9   Q   Were you a watch commander or a
        10     commander?
        11   A   I was commanding officer of what we
        12     call the Special Investigations.  It was long-term
        13     investigations, narcotics investigations.
        14   Q   And for how long did you remain at
        15     that location as the lieutenant?
        16   A   I think about four, five months.
        17   Q   And from where -- to where were you
        18     assigned after that?
        19   A   Right after that I was promoted to
        20     commander of the 6th District, Gresham District.
        21   Q   Were you still a lieutenant or had you
        22     made captain?
        23   A   No, I was still a lieutenant.
        24   Q   Are you a captain now?

                           


                                                                   14
         1   A   No, sir.
         2   Q   I'm sorry.  You said you were sent to
         3     the Gresham District?
         4   A   The 6th District.  Yes, sir.
         5   Q   As the commanding officer?
         6   A   No, as commander.
         7   Q   Commander.  Okay.  And that was in '91
         8     or '92?
         9   A   That was in '91.
        10   Q   How long did you remain the commander
        11     of the 6th District?
        12   A   I would say probably 25, 26 months.
        13   Q   Was the next assignment to the
        14     Detective Division or did you have an assignment in
        15     between?
        16   A   No.  The next assignment was to the
        17     deputy chief of Area 2 Patrol.
        18   Q   From there you then went to the
        19     Detective Division as the chief of detectives?
        20   A   Yes, sir.
        21   Q   Now, in your training as a Chicago
        22     police officer did you have training to become a
        23     sergeant?
        24   A   Yes, sir.

                           


                                                                   15
         1   Q   Did you also have training to become a
         2     lieutenant?
         3   A   Yes, sir.
         4   Q   In any of your training could you tell
         5     us did you have any training in the questioning of
         6     suspects and witnesses?
         7   A   Me personally?
         8   Q   Yes, you personally.
         9   A   No, sir.
        10   Q   And, I would take it, specifically
        11     then you had no training in questioning of juveniles;
        12     is that right?
        13   A   That's right, sir.
        14   Q   Were you familiar with the procedures
        15     within the Chicago Police Department with regard to
        16     questioning of suspects and witnesses?
        17   A   What do you mean?
        18            MR. CROWE:  At what period of time?
        19            MR. TAYLOR:  Well, at any period of time.
        20            THE WITNESS:  Now, when you say "familiar,"
        21     can you be a little more specific?
        22     BY MR. TAYLOR:
        23   Q   Well, were you conversant or did you
        24     know what the procedures were within the police

                           


                                                                   16
         1     department for questioning juveniles?
         2   A   No, sir.
         3   Q   All right.  Do you now?
         4   A   To some degree.  Yes, sir.
         5   Q   Okay.  And when did you first become
         6     familiar with those procedures to the degree you are
         7     now familiar?
         8   A   Probably after the Ryan Harris
         9     incident.
        10   Q   Okay.  So --
        11            MR. CROWE:  I'm sorry.  Could you read that
        12     last answer back.
        13                        (Record read.)
        14                    Thanks.
        15     BY MR. TAYLOR:
        16   Q   Now, were you appointed to the -- to
        17     be chief of detectives by Matt Rodriguez?
        18   A   Yes, sir.
        19   Q   Did you request that assignment or was
        20     that something that just came in the normal course of
        21     business?
        22   A   No, I did not request it.
        23   Q   Okay.  Could you give us the closest
        24     that you can remember the date that you were assigned

                           


                                                                   17
         1     as chief of detectives?
         2   A   As I remember, I think it was
         3     somewhere, like, in April of '95.  I know it was in
         4     1995.  I think it was during the month of April or
         5     May, one of those two months.  An exact date I
         6     couldn't tell you.
         7   Q   In your duties as a patrol officer and
         8     as a sergeant and later as a lieutenant, did you have
         9     experience in questioning witnesses and suspects?
        10   A   When you say questioning suspects,
        11     can -- tell me exactly what you mean when you say
        12     questioning suspects, you know, when -- if I'm
        13     filling out a case report or arrest report, you're
        14     not talking about -- are you talking about that or
        15     what?
        16   Q   Well, no.  I see what you're saying.
        17     I mean substantive questioning about a crime, let's
        18     say, questioning them about if they were a witness or
        19     if -- what information they knew about a crime that
        20     you were investigating.
        21   A   I have --
        22            MR. CROWE:  I'll just object as to whether
        23     Mr. Taylor is talking about whether they are in
        24     custody or not in custody.

                           


                                                                   18
         1            MR. TAYLOR:  Right now it's a general question
         2     covering all circumstances.
         3            THE WITNESS:  Well, I've questioned, you know,
         4     individuals, whether it was in custody or whether it
         5     was out of custody, you know.
         6     BY MR. TAYLOR:
         7   Q   Had you had an occasion to question
         8     juveniles, whether they were in custody or out of
         9     custody?
        10   A   Not to my recollection, no.
        11   Q   So, I take it, then you hadn't had any
        12     experience in questioning little children of the ages
        13     similar to the ones that were arrested originally in
        14     this case, the Ryan Harris case.
        15   A   Who?  Me personally?
        16   Q   You personally.  Yes, sir.
        17   A   No, sir.
        18   Q   Now, in 19 -- did you say -- I'm
        19     sorry.  I didn't hear your answer in terms of -- did
        20     you say 1997 when you came to the Detective Division
        21     or did you say 1996?
        22   A   I said 1995.
        23   Q   I guess I really didn't hear you at
        24     all, did I.  In 1995 when you came to the Detective

                           


                                                                   19
         1     Division as the chief, was it your duty to appoint
         2     the personnel under your command or were they
         3     assigned to you?
         4   A   It all depends on what personnel
         5     you're talking about.
         6   Q   Specifically the deputy chiefs.
         7   A   No, sir.  That came from the
         8     superintendent of police.
         9   Q   Did you have a staff?
        10   A   Yes, I had a staff.
        11   Q   And did you have a lieutenant on your
        12     staff?
        13   A   Yes, I did.
        14   Q   And who was that lieutenant?
        15   A   At that time it was Lieutenant James
        16     Malloy.
        17   Q   Did he remain with you during the time
        18     that you were at the Detective Division?
        19   A   Yes, sir.
        20   Q   Did you have any kind of chief of
        21     staff or administrative assistant that handled some
        22     of your work?
        23   A   No.
        24   Q   Would Malloy have been the equivalent

                           


                                                                   20
         1     of your chief of staff or administrative assistant?
         2   A   He would have been the equivalent of
         3     my administrative assistant.
         4   Q   Did you have any sergeants or others
         5     that worked on your direct staff?
         6   A   Yes, sir.
         7   Q   And who worked with you as a sergeant?
         8   A   Sergeant Marjorie O'Day, Sergeant Paul
         9     Carroll, and Sergeant Padgurskas, Charles Padgurskas.
        10   Q   Anyone else that was on your direct
        11     staff other than the persons you've named for me?
        12   A   At one time Sergeant Jack Ridges
        13     worked out of the Detective Division once we
        14     initiated Cold Case Central and Homicide Squad.
        15   Q   What year was that?
        16   A   That had to be the last year that I
        17     was there as chief of detectives.
        18   Q   That would have been '98 or --
        19   A   I believe in '97.
        20   Q   Was there a time period between the
        21     time that you became superintendent in early 1998 and
        22     the time that you left as deputy -- excuse me -- as
        23     chief of detectives, or did you move right from chief
        24     of detectives to being the superintendent?

                           


                                                                   21
         1   A   Well, there was a time period in the
         2     sense that I was selected by the mayor and I had to
         3     be approved before the city council.
         4                    I still worked out of the office of
         5     the chief of detectives.  I didn't move into the
         6     superintendent's office until I was confirmed by the
         7     city council.
         8   Q   How long a period of time are we
         9     talking about?
        10   A   Probably talking about a couple of
        11     months, I believe.
        12   Q   All right.  So would it be fair to say
        13     that you worked in the Detective -- as chief of
        14     detectives right up until the end of '97 and perhaps
        15     a little bit into the beginning of '98?
        16   A   Well, I was still the chief of
        17     detectives for the full year of '97 because I wasn't
        18     appointed to superintendent until 18 February 1998.
        19   Q   Okay.  Now, was one of the things that
        20     was done at the Detective Division to do reports and
        21     analyses concerning crime patterns?
        22   A   That was one of the small units we had
        23     there, yes, sir.
        24   Q   Okay.  Was there a crime -- what was

                           


                                                                   22
         1     the name of that unit?
         2   A   Analytical Unit.
         3   Q   Okay.
         4            MR. CROWE:  This is when he was chief of
         5     detectives.
         6            MS. ROSEN:  Right.  Right.
         7     BY MR. TAYLOR:
         8   Q   And who was the head of the Analytical
         9     Unit while you were chief?
        10   A   At that time, as I remember, Sergeant
        11     Paul Carroll.
        12   Q   Now, I want to show you what I'm going
        13     to have marked here as Plaintiffs' Exhibit 298.
        14                        (Exhibit marked and tendered to
        15                         witness.)
        16                    Do you recognize the kind of document
        17     that Plaintiffs' Exhibit 298 is?
        18   A   Yes, sir.
        19   Q   What is it?
        20   A   This is an aggravated criminal sexual
        21     assault.  It's what we call a crime pattern.
        22   Q   All right.  Was this issued by the
        23     unit that you testified that Officer Carroll was in
        24     charge of?

                           


                                                                   23
         1   A   Yes, sir.
         2   Q   And I notice at the bottom, is that
         3     your signature or is that someone else that --
         4   A   No, sir, I don't write that good.
         5   Q   So someone else was signing it in your
         6     stead?
         7   A   Yes, sir.
         8   Q   Now, when a crime analysis pattern is
         9     issued, is it normally issued with the signature of
        10     the chief or someone acting in his stead?
        11   A   Yes, sir.
        12   Q   And do you recognize who may have
        13     signed your name on this one?
        14   A   Well, that could have been Sergeant
        15     Paul Carroll, it could have been Lieutenant Malloy.
        16   Q   Either of them were authorized --
        17   A   Yes.
        18   Q   -- to sign your name?  Okay.  Around
        19     the time that this particular crime pattern was
        20     issued, were you aware of this particular crime
        21     pattern?
        22   A   You know, it doesn't bring back any --
        23     ring any bells or anything like that.
        24   Q   Would you, from time to time, as chief

                           


                                                                   24
         1     of detectives review crime analysis pattern reports
         2     that were issued?
         3   A   From time to time, yes.
         4   Q   And under what circumstances would you
         5     review those?
         6   A   Well, it depends on the crime, you
         7     know.  If there was an inordinate amount of bank
         8     robberies, an inordinate amount of criminal sexual
         9     assaults, an inordinate amount of people, like, we
        10     had female streetwalkers dying in a particular
        11     neighborhood, that would be brought to my attention.
        12   Q   Okay.  But you don't know whether this
        13     crime pattern, this particular crime pattern, was
        14     called to your attention or not while you were chief
        15     of detectives?
        16   A   I can't say yes or no on that,
        17     Counsel.
        18   Q   Okay.  From this report it had a
        19     fairly wide distribution; is that right?
        20   A   Yeah, it should have.  Well, if you
        21     look at it, the 2nd and the 7th District --
        22   Q   Okay.
        23   A   -- are the two districts, but most of
        24     the -- if you look over on the left-hand side, a lot

                           


                                                                   25
         1     of the specialized units got it.
         2                    The Special Operations Section
         3     received it, the Special Functions Section, and the
         4     district Tactical and also the field units.
         5   Q   And then Area 1, various portions of
         6     Area 1 got it?
         7   A   Right.
         8   Q   Which, of course, covers both the 2nd
         9     and the 7th District; is that right?
        10   A   Yes.  And --
        11   Q   At --
        12            MR. CROWE:  I'm sorry.  Have you finished your
        13     answer?
        14            THE WITNESS:  No.
        15     BY MR. TAYLOR:
        16   Q   I'm sorry.
        17   A   And then over on the right-hand side,
        18     all the units from Organized Crime and really from
        19     the Detective Division, especially those units that
        20     encompass organized crime and prostitution, that was
        21     on there.
        22   Q   Okay.  At whose initiation would a
        23     crime analysis pattern be issued?
        24   A   Well, the analyst who works out of

                           


                                                                   26
         1     this unit would take and review all those particular
         2     case reports for that respective crime that he was in
         3     charge of.
         4                    This is from a sexual assault case, so
         5     the individual who was in charge of criminal sexual
         6     assault cases, or whether it be a robbery case or
         7     whether it be a burglary case, those different
         8     analysts, whoever it is, he would come up with the
         9     analysis and then submit it to a sergeant.
        10   Q   Okay.  And was there, while you were
        11     at the Detective Division as its chief, were there
        12     computerized systems for looking for crime patterns?
        13   A   Well, when you say, "computerized
        14     systems," I need to know what you're talking about.
        15   Q   Well, let me ask you.  Are you
        16     familiar with a system called ICAM?
        17   A   Yeah.  But ICAM, as I remember, ICAM
        18     hadn't came in during this time --
        19   Q   Okay.
        20   A   -- as I remember.
        21   Q   All right.  Do you remember when it
        22     did come in?
        23   A   I think ICAM came in right when I
        24     became superintendent, not too long after I became

                           


                                                                   27
         1     superintendent, the best of my recollection.
         2                    You know, I can check on that for you.
         3     But, you know, I think 1997, 18 February 1997, I
         4     don't think ICAM was operational then.
         5   Q   Was there any other way to use
         6     computerized data to search for crime patterns while
         7     you were chief of detectives?
         8   A   Well, as I remember, the majority of
         9     this was done manually, those detectives sitting down
        10     and going through those particular case reports from
        11     their respective Area of assignment and reading them
        12     verbally and manually.
        13   Q   Okay.  Would this be done by the
        14     detectives at headquarters in the Crime Analysis Unit
        15     or would this be out in the Areas that it would be
        16     done?
        17   A   Well, detectives at headquarters, but
        18     also you had detectives out in the field who would go
        19     over the case reports also.
        20   Q   Okay.  Were crime analysis patterns
        21     done in homicides and sexual assault cases, robbery
        22     cases, all those different kinds of cases?
        23   A   If there was a pattern.
        24   Q   To look for one?

                           


                                                                   28
         1   A   Yeah.
         2   Q   Could a request come from an Area to
         3     have the Crime Analysis Unit look for a pattern if
         4     someone out in the district or the Area wanted to see
         5     if there was such a pattern?
         6   A   Yes, sir.
         7   Q   Okay.  Did that happen while you were
         8     chief of detectives periodically?
         9   A   I'm quite sure it did.
        10   Q   All right.  Now, when you came to be
        11     the superintendent, you had various deputy
        12     superintendents on your command staff; is that right?
        13   A   Yes, sir.
        14   Q   Were those selections made by you or
        15     were they appointments made by someone else?
        16   A   Well, when I became superintendent, I
        17     only made one appointment.
        18   Q   And what appointment did you make?
        19   A   That was Deputy Superintendent Jeannie
        20     Clark.
        21   Q   What was her title that you appointed
        22     her to?
        23   A   I think I appointed her to deputy
        24     superintendent of Staff Services, I believe.

                           


                                                                   29
         1   Q   And the others you kept in place from
         2     the previous administration; is that right?
         3   A   Yes, sir.
         4   Q   So who was the first deputy
         5     superintendent?
         6   A   John Townsend.
         7   Q   Okay.  Who else other than Townsend
         8     and Clark were deputy superintendents when you --
         9   A   Deputy Superintendent Mike Malone,
        10     Bureau of Investigative Services; Deputy
        11     Superintendent James Whigham, Bureau of Technical
        12     Services; and Deputy Superintendent of Administrative
        13     Services, Harris, John Harris.
        14   Q   Anyone else?  Does that cover all of
        15     them?
        16   A   That should be five of them.
        17   Q   Okay.  Did you have a practice while
        18     you were superintendent to have daily briefings or
        19     daily meetings with your command staff?
        20   A   I had tried to have what we call a
        21     morning staff meeting.  Every morning I would try,
        22     you know, but sometimes I'm not able to.
        23   Q   All right.  If you were out of town or
        24     otherwise busy, you might not have one?

                           


                                                                   30
         1   A   Right.
         2   Q   But would you say normally you would
         3     have one each day?
         4   A   I would try.
         5   Q   Did you come in around 8:30 in the
         6     morning?
         7   A   Usually I would come in about 8:00,
         8     8:15.
         9   Q   And would that be the first thing you
        10     would do that morning if you had one, have a
        11     briefing, or would you --
        12   A   It was usually held between 9:00 and
        13     9:15.
        14   Q   And for how long did you schedule the
        15     meetings?  In other words, how long were they in
        16     terms of time?
        17   A   The meetings go anywhere from -- it
        18     all depends on what the participants have to discuss,
        19     you know.  But it would go anywhere from 15 minutes
        20     to 30, 35, 40 minutes.
        21   Q   Would the deputy superintendents each
        22     report on significant business in cases that they
        23     were involved in to you each morning?
        24   A   Out of their respective bureau, yes,

                           


                                                                   31
         1     sir.
         2   Q   And other than the deputy
         3     superintendents who attended the meeting along with
         4     you, these briefings along with you, who else
         5     normally attended, if anyone?
         6   A   Well, the deputy superintendent, the
         7     secretary, the press secretary; the administrator
         8     from OPS, the assistant deputy superintendent of IAD,
         9     the general counsel.
        10   Q   Did you have an administrative
        11     assistant?
        12   A   And my administrative assistant, yes,
        13     sir.
        14   Q   When you came in, did you appoint an
        15     administrative assistant or did you assume the one
        16     that was already there?
        17   A   I assumed the one that was already
        18     there.
        19   Q   Who was that?
        20   A   That was Commander Gerald Mahnke.
        21   Q   Is he still your administrative
        22     assistant?
        23   A   No, sir.  He's commander of Area 5
        24     Detective Division.

                           


                                                                   32
         1   Q   Okay.  When was he replaced?
         2   A   Approximately two years ago.
         3   Q   All right.  So he would have been your
         4     administrative assistant during the Ryan Harris case?
         5   A   I believe so, yes, sir.
         6   Q   Okay.  Who was he replaced by?
         7   A   Um, Commander Joseph Gandurski.
         8   Q   Is he still your administrative
         9     assistant?
        10   A   Yes, sir.
        11   Q   And you said legal counsel would
        12     normally attend these briefings?
        13   A   Yes, sir.
        14   Q   Did you assume legal counsel from
        15     Deputy -- excuse me -- Superintendent Rodriguez?
        16   A   Uh, for a couple of months.
        17   Q   Was that Zoufal?
        18   A   Yes, sir.
        19   Q   Then did you replace Zoufal or was he
        20     replaced with another counsel?
        21   A   Yes, sir.
        22   Q   Was that Needham that replaced him?
        23   A   Yes, sir.
        24   Q   At some point Needham was appointed to

                           


                                                                   33
         1     another position within your administration, was he
         2     not?
         3   A   I appointed him to chief of staff.
         4   Q   Okay.  Does he hold that position now?
         5   A   Yes, sir.
         6   Q   When did you appoint him to that
         7     position?
         8   A   Um, I believe it was almost a year
         9     ago.
        10   Q   Do you now have legal counsel?
        11   A   Yes, sir.
        12   Q   Is she present today?
        13   A   That's her down on the end, Ms. Karen
        14     Rowan.
        15   Q   All right.  Very good.  And she took
        16     Needham's place; is that right?
        17   A   Yes, sir.
        18   Q   Now, you say that -- who was your
        19     chief of staff when you became superintendent?
        20   A   There was no chief of staff then.
        21   Q   Okay.  Did you create that position?
        22   A   Yes, sir.
        23   Q   You created that position about a year
        24     ago?

                           


                                                                   34
         1   A   Yes, sir.
         2   Q   All right.  Does the chief of staff
         3     have a different role than the administrative
         4     assistant did prior to you creating the chief of
         5     staff?
         6   A   Say that again.
         7   Q   What does the chief of staff do?
         8   A   The chief of staff, what's his job
         9     now?
        10   Q   Um-hum.
        11   A   His job is to handle those tasks that
        12     I don't have the time to handle when it comes down to
        13     interacting with certain elected officials, when it
        14     comes down to attending meetings down at city hall
        15     that I don't have -- you know, that my time won't
        16     allow me to be two places at one time, and to help me
        17     out that way.
        18   Q   Okay.  Was that one of the tasks that
        19     the administrative assistant performed before you
        20     created the chief of staff?
        21   A   No, sir.
        22   Q   Okay.  What did and does the
        23     administrative assistant do?
        24   A   Administrative assistant handles all

                           


                                                                   35
         1     the invitations, you know, he oversees all the
         2     invitations that the superintendent receives in order
         3     to appear before certain community groups, certain
         4     political groups, certain faith-based organizations,
         5     to help and oversee my scheduling, to ensure that
         6     when I have to travel outside the city, along with
         7     his staff, see that contact is made with persons
         8     outside the city so that when I get there, things are
         9     set up for me to proceed without any disruption, to
        10     take and review those public speeches that I have to
        11     present, things such as that, and really to run the
        12     superintendent's office, oversee the running of the
        13     superintendent's office.
        14   Q   Now, while you were chief of
        15     detectives, did you have any dealings with Commander
        16     Dan Gibson who became the commander of Area 1 around
        17     the time of the Ryan Harris case?
        18   A   When you say, "dealings," what do you
        19     mean?
        20   Q   Did you know Dan Gibson while you were
        21     chief of detectives?
        22   A   Yeah, I knew Dan Gibson when I was
        23     chief of detectives.  Yes, sir.
        24   Q   Did you work -- did he work for you or

                           


                                                                   36
         1     with you on any cases?
         2   A   No, sir.
         3   Q   Did you know Lieutenant Cornfield
         4     while you were chief of detectives?
         5   A   Yes, I did.
         6   Q   What was Cornfield's -- how did you
         7     happen to know Cornfield?  In what context did you
         8     know him?
         9   A   He was the administrative assistant to
        10     Deputy Superintendent Mike Malone when I was chief of
        11     detectives.
        12   Q   And did you know -- let me ask you
        13     this.  Did you know Detective Allen Nathaniel prior
        14     to the Ryan Harris case?
        15   A   No, sir.
        16   Q   Did you know Detective James Cassidy
        17     prior to the Ryan Harris case?
        18   A   No, sir.
        19   Q   Did you know Sergeant Stanley Zaborac
        20     prior to the Ryan Harris case?
        21   A   Yes, sir.
        22   Q   All right.  And in what context did
        23     you know him?
        24   A   Stan Zaborac used to be a Tac sergeant

                           


                                                                   37
         1     for the commander of the 2nd District.
         2   Q   While you were there?
         3   A   No, while -- I'm going back a couple
         4     years now, but I knew that he was a Tac sergeant down
         5     there, you know.
         6   Q   Did you have any dealings with him?
         7     Did you work with him on any cases?
         8   A   I never worked with him on any cases
         9     or anything like that, but, you know, I knew him.  I
        10     knew that he was a good Tac sergeant, ran a good
        11     team, a good police officer.
        12   Q   So you thought he was a good officer
        13     from what you had heard about him?
        14   A   Well, that's what I thought and that's
        15     what I felt and I still think that today.
        16   Q   Okay.  Did you know Sergeant Daniel
        17     Brannigan prior --
        18   A   Yes, sir.
        19   Q   -- to the Ryan Harris case?  How did
        20     you happen to know him?
        21   A   I used to work with Dan Brannigan,
        22     Sergeant Brannigan, when I was a patrolman in Gang
        23     Crimes South.
        24   Q   He was a patrolman and you were the

                           


                                                                   38
         1     watch commander there?
         2   A   No, this goes back even further than
         3     that.  This is gang investigations when we first got
         4     started out on 91st Street.
         5   Q   What year was that?
         6   A   About 1974.
         7   Q   So this is before you made sergeant?
         8   A   Yeah, this was before I made sergeant.
         9   Q   Did you work with him as a partner?
        10   A   No, no.  We worked on the same shift,
        11     third watch, the same office.
        12   Q   Did you do any investigations with
        13     him?
        14   A   No.
        15   Q   Did you work on cases with him?
        16   A   No, sir.
        17   Q   But you knew him because he was on the
        18     same watch with you?
        19   A   Yes, sir.
        20   Q   All right.  And did you have any
        21     opinion of him as a police officer?
        22   A   Yes, sir.
        23   Q   And what was that?
        24   A   A very good police officer, very

                           


                                                                   39
         1     motivated.
         2   Q   Okay.  Did you know with regard to
         3     either Brannigan or Zaborac their disciplinary
         4     backgrounds, what, if any, disciplinary allegations
         5     they had had against them?
         6   A   No, sir.
         7   Q   Have you ever investigated that?
         8   A   No, sir.
         9   Q   Okay.
        10   A   Can we back up here?
        11            MR. CROWE:  Sure.
        12            THE WITNESS:  Now, when you asked me if I had
        13     worked with Dan Brannigan when I was a patrolman and
        14     I said no cases or anything like that, but he did
        15     work for me when I became a lieutenant.
        16     BY MR. TAYLOR:
        17   Q   That was the next thing I was going to
        18     ask you.
        19   A   Okay.  I just didn't want that to slip
        20     through the cracks, you know.
        21   Q   When you became a lieutenant and went
        22     back to Gang Crimes, he was still there, right?
        23   A   Yes, sir.
        24   Q   At that time was he a sergeant or was

                           


                                                                   40
         1     he still a --
         2   A   He was a sergeant.  As I remember, he
         3     was a sergeant.
         4   Q   So he worked for you at that time?
         5   A   Yes, sir.
         6   Q   Again, did you supervise his work?
         7   A   To a certain extent.  He was -- during
         8     that time I was there, he was sort of, like, detailed
         9     to -- he was detailed to Alcohol, Tobacco, and
        10     Firearms, too.  So the majority of the time, he spent
        11     the majority of his time over at Alcohol, Tobacco,
        12     and Firearms.
        13   Q   So you didn't supervise him on a
        14     day-to-day basis?
        15   A   No, sir.
        16   Q   But you did know -- he was working out
        17     of your office but detailed somewhere else the
        18     majority of the time?
        19   A   Yes, sir.
        20   Q   And did you supervise any
        21     investigations that he did?
        22   A   No.
        23   Q   Did you continue to have the same
        24     opinion of him as a police officer while you were a

                           


                                                                   41
         1     lieutenant at Gang Crimes?
         2   A   I still have the same opinion of him.
         3     He's a dynamite police officer.
         4   Q   A what?
         5   A   He's a dynamite police officer.
         6   Q   Oh, okay.  Were you aware that he was
         7     involved in the arrest of Andrew Wilson in the Andrew
         8     Wilson case?
         9   A   As I remember vaguely, you know, there
        10     was a lot of folks involved in the arrest of the --
        11     the Wilson Brothers, you're talking about?
        12   Q   Right, right.
        13   A   There was a number of police officers.
        14     I don't know if -- what percentage or what part he
        15     played in it, but I know there was a number of police
        16     officers involved in that.
        17   Q   Did you know that he was involved?
        18   A   Not -- you know, I couldn't say
        19     verbatim that I knew that he particularly was
        20     involved.  I know there was a lot of folks that
        21     worked on that case.
        22   Q   Okay.  Now, did you know any of the
        23     other detectives that were involved in the -- well,
        24     let me ask you specifically rather than ask you

                           


                                                                   42
         1     generally.  Did you know Devon Anderson?
         2   A   No, sir.
         3   Q   And Sam Brown --
         4   A   No, sir.
         5   Q   -- Samuel Brown?  Paul Jackson?
         6   A   No, sir.
         7   Q   Now, I want to ask you about July and
         8     August of 1998.  In order to perhaps help in terms of
         9     days you were working and when you were working, we
        10     have the A&A sheets.
        11                    I'm going to mark that as an exhibit
        12     and let you have that in front of you so that if you
        13     need to -- let's mark this as 299.  This is in case
        14     you need to look at it to see if you were working or
        15     when you were working on a particular day.
        16                        (Exhibit marked and tendered to
        17                         witness.)
        18                    Do you recognize these to be generally
        19     what's called the A&A sheets that record the daily
        20     attendance of all officers from -- apparently from
        21     the superintendent on down --
        22   A   Yes, sir.
        23   Q   -- all the way to beat patrolmen; is
        24     that right?

                           


                                                                   43
         1   A   Yes, sir.
         2   Q   These start on the 28th of July and
         3     they go up until the 15th of August and then there
         4     are several in early September; the 3rd, 4th, and
         5     5th.  So as we go through your testimony, we can
         6     refer to this as necessary to see when and what hours
         7     you were working.
         8                    Looking at the first day, which is the
         9     28th, it indicates that you were on duty; is that
        10     right?
        11   A   Yes, sir.
        12   Q   And that the -- it appears to be that
        13     the normal hours that you worked that day were from
        14     8:30 to 4:30; is that right?
        15   A   You know, I just got to -- I'm not
        16     being facetious or anything like that, and I see what
        17     the sheets say.  But I don't think since -- I know
        18     for a fact since I've had this job I have not left
        19     this job at 4:30 in the afternoon.
        20   Q   Well, I notice from the sheets that if
        21     you look at the next day, it says, "3 HR AO, 28 July
        22     98, 1630 to 1930."  Would normally they enter your
        23     overtime the next day on the next sheet?  Is that the
        24     way that --

                           


                                                                   44
         1   A   Well, really it's not overtime.  They
         2     just put the time that we work because the exempt
         3     ranks, you know, we don't receive overtime.
         4   Q   Okay.  Well, looking at this sheet in
         5     the column that says, "Absence, Explanation of Comp
         6     Time Worked," it has, "3 HR AO, 27 July 98, 1630 to
         7     1930."  Do you see that?
         8   A   Yes.
         9   Q   Now, would that indicate that on the
        10     27th of July you worked -- well, we won't call it
        11     over -- for lack of a better word -- extra hours?
        12   A   Right.  I stayed here until about
        13     7:30.
        14   Q   You stayed until 1930 hours, which is,
        15     what, 7:30 in the evening?
        16   A   Yes, sir.
        17   Q   Okay.  Was that your general practice
        18     to at least work three or four hours beyond the bell
        19     on the days you were in?
        20   A   Well, not only during the week, but on
        21     the weekend, too.
        22   Q   Okay.  What is "AO"?  Do you know what
        23     that stands for?  "HR," I would assume, is hours.  Do
        24     you know what "AO" stands for?

                           


                                                                   45
         1   A   I have no idea.
         2   Q   Okay.  So this would indicate that on
         3     the 27th of July, that being the day that Ryan Harris
         4     was reported missing, you were working and you worked
         5     your normal or fairly normal 11, 12-hour day; is that
         6     right?
         7   A   Yes, sir.
         8   Q   Was it called to your attention while
         9     she was missing but before her body was found that,
        10     in fact, Ryan Harris -- that there was a girl missing
        11     in Englewood that turned out to be Ryan Harris?
        12   A   You know, if I was to be appraised of
        13     that, it would probably have been at the morning
        14     meeting.
        15   Q   So it wouldn't have been until the
        16     morning of the 28th?
        17   A   Yeah.
        18   Q   And if you were appraised of that,
        19     would that have come most likely through Deputy
        20     Superintendent Malone who is in charge of the
        21     Detective Division, among other parts of the
        22     department?
        23   A   Yes, sir.
        24   Q   Do you have a recollection of Deputy

                           


                                                                   46
         1     Superintendent Malone informing you of the missing
         2     person or child in Englewood that turned out to be
         3     Ryan Harris on the 28th, informing you on the 28th?
         4   A   Normally when we had the normal
         5     meeting, we would start with the first deputy who
         6     used to sit in the seat to the right of me.  He would
         7     give his report.
         8                    Then the deputy superintendent of the
         9     Bureau of Investigative Services would give his
        10     report, and he would go down and start with the
        11     Detective Division first, telling, you know, what
        12     outstanding cases that they had.
        13                    If there was a young child missing,
        14     you know, he would bring that up; female, black, age
        15     11, 12 years old, missing from such-and-such a
        16     location, and then he would go on to the next case.
        17   Q   Now, in the summer of '98 were you
        18     aware of there being a series of unsolved cases
        19     having to do with children in the Englewood area?
        20            MR. CROWE:  Object to the form of the
        21     question.
        22            THE WITNESS:  I'm not aware of children, you
        23     know.  I'm aware of --
        24            MR. CROWE:  Do you mean sexual abuse of

                           


                                                                   47
         1     children, missing children?
         2     BY MR. TAYLOR:
         3   Q   Okay.  Well, were you aware of any
         4     particular pattern of crimes against children, or
         5     young girls, I should say, in July of 1998 when the
         6     Ryan Harris case arose?
         7   A   Not to my recollection, you know.  I
         8     can't say that I recall it, not to my recollection.
         9   Q   Do you remember there being any
        10     particular community protest or community concern
        11     that was articulated to you from Englewood about
        12     unsolved crimes in that community?
        13            MR. CROWE:  Before the Ryan Harris case?
        14            MR. TAYLOR:  Yes, during -- in July of '98.
        15            THE WITNESS:  Well, I spent a great deal of
        16     time at community meetings over there in Englewood
        17     talking about the deaths of some of the ladies who
        18     plied their trades on the street, and going over and
        19     trying to galvanize that community, tell them what we
        20     were trying to do and we needed their help.
        21   Q   So those were the prostitute murders
        22     that were unsolved at that time?
        23   A   Well, we had a -- we had a number of
        24     them, you know.

                           


                                                                   48
         1   Q   And so you were at community meetings
         2     along with people from Area 1 to discuss with the
         3     community those crimes and other crimes that were --
         4     that the community chose to raise to you; is that
         5     right?
         6   A   As I remember, you know, I spent a
         7     significant amount of time over in Englewood going to
         8     community meetings and talking about the problems
         9     that we had in Englewood.
        10   Q   Was one of the problems that was
        11     raised with you the fact that there were a series of
        12     unsolved sexual assaults against young girls, girls
        13     of, say, the ages of ten to 15, in that area?
        14   A   As I remember, Mr. Taylor, this was
        15     having to do with the murders of the prostitutes.
        16   Q   Okay.  So you don't recall the issues
        17     beyond the prostitute issue?
        18   A   No, sir.
        19   Q   But you were attending a series of
        20     meetings in the summer of '98 in Englewood at which
        21     concerns about sexual assaults and homicides in that
        22     community were being discussed.  Is that fair to say?
        23   A   When it comes down to homicides of the
        24     streetwalkers.

                           


                                                                   49
         1   Q   Right.  Was there a sexual component
         2     to those crimes?  In other words, were the
         3     streetwalkers being --
         4   A   All of them had a sexual component,
         5     you know, when it comes down to the homicides of
         6     streetwalkers in Englewood.
         7   Q   Right.  But, I mean, there was a
         8     sexual assault aspect to those cases as well; is that
         9     right?
        10   A   Well, they had engaged in sexual
        11     activity, yes, sir.
        12   Q   Okay.  And was your -- did you
        13     articulate a concern to the Englewood community about
        14     these crimes when you went to these meetings?
        15            MR. CROWE:  Object to the form of the
        16     question.
        17            THE WITNESS:  Can you be more specific?
        18     BY MR. TAYLOR:
        19   Q   What I'm asking you is did you
        20     reassure the community that the police department was
        21     doing everything it could to try to solve the crimes
        22     that were unsolved in the community?
        23   A   Well, not only did we do that, but we
        24     asked for the input, you know, telling folks that

                           


                                                                   50
         1     this was just not a Chicago Police Department
         2     problem.  This was an entire community problem, that
         3     they had to work with us, you know, if there's
         4     someone out there who either saw or knew what's going
         5     on.
         6                    So they needed to work not only with
         7     the Chicago Police Department, but with their
         8     respective district commander and Area detective
         9     commander.
        10   Q   Okay.  Did you receive cooperation
        11     from the community?
        12   A   Uh, I think we did to a certain
        13     extent.
        14   Q   Okay.  Are there any records of the
        15     meetings that you had with the Englewood community?
        16   A   Well, I think if it's not on my
        17     schedule, the folks that I met with over in
        18     Englewood, you know, certain groups over there who I
        19     met with, they should have it.
        20            MR. CROWE:  You're talking about Chicago
        21     Police Department records?
        22            MR. TAYLOR:  Right.
        23            THE WITNESS:  Okay.  I would have to get the
        24     schedule.

                           


                                                                   51
         1     BY MR. TAYLOR:
         2   Q   Was there some kind of official
         3     schedule that was kept of your appointments that
         4     would reflect when you met with the Englewood
         5     community in the summer of '98?
         6   A   I would have to see if we could ferret
         7     that out because you have to realize that first year
         8     being in this job I did not have an official
         9     scheduler.
        10                    That didn't happen until almost until
        11     1999, when we really started documenting things, you
        12     know, the different meetings that we were supposed to
        13     attend and things such as that.
        14   Q   Now, do you have a specific
        15     recollection of the Ryan Harris -- of it being called
        16     to your attention that Ryan Harris was missing?
        17   A   It was brought to my attention by
        18     Deputy Malone.
        19   Q   That would have been on the morning of
        20     the 28th?
        21   A   It would probably have been the day
        22     after.  If it wasn't on a Saturday or Sunday, if it
        23     was during a weekday and I attended the morning
        24     meeting, you know, Deputy Malone would have brought

                           


                                                                   52
         1     it to my attention.
         2   Q   Okay.  And what did he tell you?
         3   A   Well, I can't specifically say what he
         4     told me.  I can say truthfully to tell you that he
         5     would state that we have -- if she was a 12,
         6     13-year-old, female black, from such-and-such a
         7     location, missing, and saying that if we had a plan
         8     into effect and what was being done to try and locate
         9     this young girl.
        10   Q   Did you subsequently -- were you
        11     subsequently informed of the fact that her body had
        12     been found?
        13   A   Um, Mike Malone would have informed
        14     me.
        15   Q   Okay.  Do you have a memory of that?
        16   A   Vaguely.
        17   Q   Okay.  And what did he tell you with
        18     regard to the discovery of her body?
        19   A   Well, you know, this is not verbatim.
        20     This is just going on being, like, an approximation.
        21     He would probably have informed me that the missing
        22     female black that he had reported on prior to that
        23     time had been found and that she was -- she had been
        24     murdered or that she was dead, you know.

                           


                                                                   53
         1   Q   Did he at that time tell you any of
         2     the details concerning the body or how it was found,
         3     in what condition it was in?
         4   A   No, no.  That's one of the things -- I
         5     never got off into specifics.  I never get off into
         6     specifics.  That's not my job.
         7   Q   Did he tell you that it appeared that
         8     the girl had been sexually assaulted?
         9            MR. CROWE:  Object to the form of the question
        10     given the witness's last answer.
        11            THE WITNESS:  He didn't tell me specifics,
        12     Mr. Taylor.
        13     BY MR. TAYLOR:
        14   Q   Not even that specific?
        15   A   No.
        16   Q   Okay.  Did you give him -- let me ask
        17     you this.  Were there any notes kept at these daily
        18     briefings?
        19   A   No, sir.
        20   Q   And there was no recording of it by
        21     tape or a reporter or anything like that?
        22   A   No, sir.
        23   Q   Okay.  After you learned that the Ryan
        24     Harris girl had been found murdered, did you give any

                           


                                                                   54
         1     instructions to Malone or anyone else in your chain
         2     of command concerning the case?
         3   A   Well, you know, I don't think I would
         4     have to give instructions.  Mike Malone was a -- one
         5     hell of a detective, you know, in the Detective
         6     Division when he was in his younger days.
         7                    And now here he is, the deputy
         8     superintendent of the Bureau of Investigative
         9     Services.  Mike knew what had to be done.
        10   Q   So in that sense you relied on Malone
        11     to make sure that whatever was necessary to do with
        12     regard to the investigation would be done; is that
        13     right?
        14   A   Well, not only Mike Malone, but the
        15     entire Detective Division.
        16   Q   Okay.  Did you receive daily updates
        17     with regard to the investigation of the Ryan Harris
        18     case after the body was found?
        19   A   Now, when you say, "daily updates" --
        20   Q   Let me put it this way.  Was it a
        21     topic of the briefing each day, your morning briefing
        22     I'm talking about now, after the body was found?
        23   A   Mike Malone would come in and he would
        24     tell us that, you know, they were still moving ahead

                           


                                                                   55
         1     and trying to locate, identify who the perpetrator
         2     was or perpetrators were of this incident.
         3            MR. CROWE:  Excuse me.  I don't think he
         4     understands your question.  Your question is every
         5     day was this discussed?  I don't think he understands
         6     that.
         7            MR. TAYLOR:  But he's telling us generally
         8     what Malone would say.
         9            MR. CROWE:  Yeah, he's talking generally, and
        10     I think you're asking him every day was this
        11     discussed.
        12            THE WITNESS:  No, no, not every day, you know,
        13     because the incident had happened and then it was in
        14     the detectives' hands.
        15     BY MR. TAYLOR:
        16   Q   Did Malone give you periodic updates
        17     during the first week or two of the investigation?
        18   A   Not periodic updates.  When he had
        19     something to give me, he would give it to me, you
        20     know.  I think he would come in and inform me or tell
        21     me, you know, where they were at.  But it wasn't
        22     every day.
        23   Q   But it was -- at some point during the
        24     first couple of weeks you received updates from

                           


                                                                   56
         1     Malone concerning the case; isn't that right?
         2   A   Uh, yes.
         3   Q   Did he update you with regard to what
         4     the medical examiner had found in the autopsy of Ryan
         5     Harris?
         6   A   No, sir.
         7   Q   Did you receive any information
         8     concerning the nature of the injuries that Ryan
         9     Harris had suffered from Malone or anyone else?
        10   A   Not from Malone or from any of the
        11     detectives.  You know, all you have to do is read the
        12     newspaper.
        13   Q   Had you read reports in the newspaper
        14     about some details with regard to the murder of Ryan
        15     Harris?
        16   A   Well, you read the newspaper and then
        17     you have to be very cautious on what you read in the
        18     newspaper, you know.
        19   Q   Sure.  But you're saying that there
        20     were some -- there were some details with regard to
        21     the injuries to Ryan Harris that you saw in the
        22     newspaper?
        23   A   Yes, sir.
        24   Q   And did you learn from the newspapers

                           


                                                                   57
         1     that she had suffered head injuries, blunt trauma
         2     head injuries?
         3   A   The only thing I remember reading was
         4     blunt trauma.
         5   Q   Okay.  Did you learn anything either
         6     from the briefings or the newspapers concerning
         7     whether she had skull fractures?
         8   A   No, sir.
         9   Q   Did you learn anything from either the
        10     newspapers or the briefings in the first week or two
        11     of the investigation with regard to whether she had
        12     any injury to her brain, such as bruising or bleeding
        13     or that kind of thing?
        14   A   No, sir.
        15   Q   All right.  Did you learn about any
        16     other injuries to her other than the fact that she
        17     had blunt trauma?
        18   A   No, sir.
        19   Q   Okay.  Did you learn anything with
        20     regard to whether she had been sexually assaulted,
        21     whether there was any evidence of sexual assault,
        22     either from the newspaper or from your briefings?
        23   A   No, sir.
        24   Q   Okay.  Did you learn anything either

                           


                                                                   58
         1     from the newspapers or from your briefings about
         2     whether she had been suffocated by having a piece of
         3     clothing shoved into her mouth?
         4   A   No, sir.
         5   Q   Did you learn anything about
         6     whether -- what the nature of the weapon was that the
         7     investigation had identified as a potential murder
         8     weapon?
         9   A   The only thing that I remember is
        10     something about a rock.
        11   Q   Okay.  Now, was it a rock or a brick?
        12   A   No, it was a rock.
        13   Q   Now, was it prior to or subsequent to
        14     the arrest of the little boys in this case that you
        15     learned that there was a rock that was a potential
        16     murder weapon, according to the police?
        17   A   This was after.
        18   Q   The boys were arrested?
        19   A   Were arrested.
        20   Q   Okay.
        21            MR. CROWE:  I think all the questions
        22     Mr. Taylor is asking dealt with before the boys were
        23     arrested.
        24     BY MR. TAYLOR:

                           


                                                                   59
         1   Q   Yes, that's right.  That's why I
         2     clarified it with you, because I thought you might be
         3     talking about afterward.
         4                    So before the little boys were
         5     arrested you had no information as to what, if any,
         6     murder weapon the investigation had identified as a
         7     possible --
         8   A   No, I'm sorry.
         9   Q   Okay.  Had you learned anything prior
        10     to the arrest of the little boys with regard to the
        11     location of where her body was found?
        12   A   The only thing that I can say is
        13     remembering what Malone said, that the body was
        14     located and it was in Englewood.  That's it.  The
        15     location, the specific location, I had no knowledge
        16     of that.
        17   Q   So in terms of what address or even
        18     how the body was found in terms of on her back or on
        19     her side or on her front, you didn't know any of
        20     that?
        21   A   No, sir.
        22   Q   Was there -- you say you saw it in the
        23     newspapers.  Did you also see it on TV?
        24   A   Well, I have to truthfully tell you,

                           


                                                                   60
         1     Mr. Taylor, during that time I was getting beat up
         2     and I didn't watch very much TV, especially the news.
         3   Q   Now, you're saying, "beat up."  You
         4     mean by the media?
         5   A   By the media and by some of the
         6     activists in this city.
         7   Q   Now, are you talking about, again,
         8     after the little boys were arrested or before?
         9   A   After the little boys was arrested and
        10     really --
        11            MR. CROWE:  His question is before --
        12            THE WITNESS:  Before --
        13            MR. CROWE:  -- the boys were arrested.
        14            THE WITNESS:  Before I was taking my lumps and
        15     hits from the newspaper -- from the TV.  So I don't
        16     do a lot of watching of TV.
        17     BY MR. TAYLOR:
        18   Q   Were some of the lumps you were taking
        19     because the Ryan Harris case was not being solved or
        20     hadn't been solved over the next couple of weeks?
        21   A   Well, that and a number of other
        22     things.
        23   Q   What were the other things other than
        24     the Ryan Harris case?

                           


                                                                   61
         1   A   People just -- it seemed as if some of
         2     my residents didn't think that I was running the
         3     police department like it should have been ran.
         4   Q   Are there any specific examples you
         5     can give us about how you were getting beat up other
         6     than the Ryan Harris case?
         7   A   The only thing is every time that I
         8     watched TV, it was something negative about Terry
         9     Hillard and the Chicago Police Department, you know.
        10   Q   I see.
        11   A   And being a new superintendent at that
        12     time, you know, it wore on me for a while.
        13   Q   Okay.  So you didn't watch the TV or
        14     the newspapers too closely in those weeks, the week
        15     or two between the time that Ryan Harris was found
        16     and the time that the little boys were arrested,
        17     because there was a lot of negative publicity against
        18     you and the police department because of that case
        19     and other things as well.  Is that fair to say?
        20   A   Um-hum.  That's true.
        21   Q   Okay.  Did you have -- however, did
        22     someone in News Affairs or your administrative
        23     assistant or someone keep you generally informed of
        24     what was going on in the media so that you knew what

                           


                                                                   62
         1     kind of criticism was coming down so you could
         2     respond to it, from time to time?
         3   A   Well, we got what we call press
         4     releases, press briefings, that we clip out of the
         5     newspaper, you know, to sort of give us a short
         6     synopsis of what's happening; the Tribune, Sun-Times,
         7     Defender, such as that.
         8   Q   Would you look at those clippings?
         9   A   From time to time, you know.
        10   Q   So -- by the way, would someone from
        11     News Affairs be at your daily briefings?
        12   A   Yes, sir.  I said that.
        13   Q   Who was that at the time?
        14   A   At that time it was Pat Camden.
        15   Q   Was he director of News Affairs?
        16   A   He was the acting director.
        17   Q   Is he director now?
        18   A   He's the deputy director.
        19   Q   Okay.  Who is the director now?
        20   A   Dave Baylis.
        21   Q   At that time he was the acting
        22     director --
        23   A   Right.
        24   Q   -- so he was number one in command of

                           


                                                                   63
         1     News Affairs; is that right?
         2   A   Yes, sir.
         3   Q   That's part of your staff, right?
         4   A   Yes, sir.
         5   Q   When News Affairs issued information,
         6     it would be with your either expressed or tacit
         7     approval; is that right?
         8   A   No, sir.
         9   Q   All right.
        10   A   Let's back up here.  News Affairs
        11     operates and they don't have to -- when they get
        12     ready to go and have a press release or something
        13     like that, they don't have to get the approval of the
        14     superintendent.
        15                    That's the reason I hired them.  They
        16     are supposed to be the pros, you know.  They're
        17     supposed to do what's in the best interest of this
        18     police department.
        19   Q   But they do speak for you and your
        20     department, right?
        21   A   They speak for the department, yes,
        22     sir.
        23   Q   In that sense you delegated the
        24     authority or some of the authority to speak for the

                           


                                                                   64
         1     department --
         2   A   Right.
         3   Q   -- to News Affairs, right?
         4   A   Right.
         5   Q   And if you are in disagreement with
         6     something that they say, do you then call it to their
         7     attention?
         8   A   Oh, yes.  Definitely.
         9   Q   Have you done that, from time to time,
        10     since you've been the superintendent?
        11   A   Well, a couple of times, but it hasn't
        12     been that many times, you know.  It's just like any
        13     organization, you know.
        14   Q   So if there was something you didn't
        15     agree with, you would call Camden or whoever in and
        16     ask him why he did that and perhaps even put out a
        17     release that might counteract what he said?
        18            MR. CROWE:  Object to the form of the question
        19     in that there's no foundation for it.
        20            THE WITNESS:  Well, if they put out something
        21     that I didn't agree with, I would bring them in and,
        22     you know, give me the reason why this was done, you
        23     know.
        24                    But what you have to realize is I

                           


                                                                   65
         1     might disagree with it, but he might have a reason
         2     why it needed to go out, you know.  They're the pros
         3     at this, not Terry Hillard.
         4     BY MR. TAYLOR:
         5   Q   Is he a civilian or does he have a
         6     rank within the department?
         7   A   He used to be a sworn.  He's a
         8     civilian now.
         9   Q   But he used to be a Chicago police
        10     officer?
        11   A   Yes.
        12   Q   What rank did he attain?
        13   A   He was a patrolman, but he was the
        14     deputy press secretary for almost 11 years.
        15   Q   Okay.  As a patrolman?
        16   A   As a patrolman.  And he was never paid
        17     for it.
        18   Q   You mean he volunteered?
        19            MR. CROWE:  There was no question pending.
        20            THE WITNESS:  Yeah, okay.
        21     BY MR. TAYLOR:
        22   Q   So he's loyal to the department, is
        23     what you're saying.
        24   A   No, he's loyal to this city.

                           


                                                                   66
         1   Q   Okay.  And to the department?
         2   A   And the citizens of this city.
         3   Q   Okay.  Now, did you at some point --
         4     strike that.
         5                    Are you aware, even though you weren't
         6     watching the press that closely during the 12 or 13
         7     days between the time that Ryan Harris' body was
         8     found and the time that the little boys were charged
         9     in this case, were you aware that it was receiving a
        10     lot of attention both in the city in general and
        11     specifically in Englewood?
        12   A   Yes, sir.
        13   Q   And would it be fair to say that it
        14     was a significant case here in the city?
        15            MR. CROWE:  Object to the form of the
        16     question.
        17            THE WITNESS:  When you say, "significant,"
        18     what --
        19     BY MR. TAYLOR:
        20   Q   An important case.
        21   A   Well, Mr. Taylor, I think all of them
        22     are important really.  All of them are important.
        23     But, you know, this case happened to come out of
        24     Englewood, and Englewood being the neighborhood that

                           


                                                                   67
         1     it is, it seems like it gets -- a lot of time it
         2     doesn't get its just due.  This is an important case.
         3     It's like a lot of the cases that we have in
         4     Englewood.
         5   Q   Did it have an added importance
         6     because it was a little girl that was victimized in
         7     the case?
         8   A   Well, it's -- when there's a child,
         9     it's always got that level, you know, the feeling
        10     that you have to solve it.
        11   Q   Um-hum.  During that week or two that
        12     there were periodic briefings that included this case
        13     in the press that you weren't following that closely
        14     but did get some information from, was there any
        15     discussion with -- between you and any persons on
        16     your staff, whether it be Malone or anyone else,
        17     about looking to see whether the Harris case fit into
        18     a pattern in Englewood concerning assaults of little
        19     girls or young girls?
        20            MR. CROWE:  Object to the form of the
        21     question.  That assumes that there was a pattern.
        22            THE WITNESS:  Kindly rephrase that for me,
        23     would you?
        24     BY MR. TAYLOR:

                           


                                                                   68
         1   Q   Okay.  What I'm asking you is did you
         2     have any discussions with Malone or with anyone else
         3     during the first couple of weeks before the little
         4     boys were arrested concerning whether there might be
         5     a pattern that could be located with regard to the
         6     Harris case and other cases in Englewood in which
         7     young girls had been attacked?
         8   A   I think --
         9            MR. CROWE:  Object to the form of the
        10     question.
        11                    You may answer.
        12            THE WITNESS:  I had not been micromanaging.
        13     You know, that's not my style.
        14     BY MR. TAYLOR:
        15   Q   So you left that up to your
        16     subordinates?
        17   A   I left that up to Deputy Malone, the
        18     chief of detectives, the commander of the Detective
        19     Division, the lieutenant of Violent Crimes, and the
        20     sergeant of that Detective Division out in Area 1.
        21   Q   Did it occur to you during that
        22     couple-week period before the little boys were
        23     arrested, given the facts that you had and the
        24     experience you did as the chief of detectives, that

                           


                                                                   69
         1     this would be a case to look at with regard to a
         2     potential pattern in the Englewood community?
         3   A   When you say with the experience that
         4     I had as the chief of -- I was chief of detectives,
         5     but that don't mean that I was qualified to go out
         6     and investigate, you know, homicides and rapes
         7     because I had never been a detective.  You're going
         8     to have to be a little more specific.
         9   Q   Okay.
        10   A   I appreciate that.
        11   Q   Well, let me restate the question.
        12     Given your knowledge of the workings of the Detective
        13     Division that you gleaned from being the chief of
        14     it --
        15   A   Um-hum.
        16   Q   -- did it occur to you that it would
        17     be an appropriate investigative technique to look at
        18     the Harris case in light of whether it fit into a
        19     preexisting pattern of attacks on young girls in the
        20     Englewood community?
        21            MR. CROWE:  Object to the form of the multiple
        22     questions.
        23     BY MR. TAYLOR:
        24   Q   You can answer.

                           


                                                                   70
         1            MR. CROWE:  If you understand the question.
         2     If you don't, you don't.
         3            THE WITNESS:  Can we do one at a time?
         4            MR. TAYLOR:  Okay.  Well, why don't you read
         5     the question back and we'll see where it is.
         6                        (Record read.)
         7            MR. CROWE:  I assume that means if he knows,
         8     given what his last answer was before that.
         9            MR. TAYLOR:  Yeah, yeah.
        10            MR. CROWE:  Okay.
        11            THE WITNESS:  But I don't think there's
        12     anything out there that say that they didn't look at
        13     all the options and look and see about the patterns.
        14     BY MR. TAYLOR:
        15   Q   I'm sorry if I'm not clear with my
        16     question.  I'm not asking whether they may or may not
        17     have done that.  I'm asking whether it occurred to
        18     you that that would be something that should be done.
        19   A   No.
        20   Q   Okay.
        21   A   And I say no for a reason.  It is
        22     because I wanted -- you know, that was Malone's job,
        23     the chief of detectives' job, the commander's job,
        24     and the lieutenant and the sergeant's job, you know,

                           


                                                                   71
         1     to decide what strategies, what programs, and what
         2     initiatives to go forward with to investigate this
         3     case.
         4   Q   But would you not, in briefings and
         5     other conversations with subordinates, if you felt
         6     there was an appropriate suggestion or directive to
         7     make with regard to a case, you would make it,
         8     wouldn't you?
         9   A   No.  And you know the reason why?
        10     I've learned over these last -- since I was chief of
        11     detectives, that when people of the stature of the
        12     superintendent speak, people want to take it as
        13     gospel, you know, and there's nothing by being the
        14     superintendent of police to say that I know what I'm
        15     talking about when it comes down to investigating
        16     cases.
        17                    We need to let those detectives and
        18     those folks in the Detective Division who have been
        19     tasked with this mission carry out their job.  We got
        20     one of the best Detective Divisions this country, bar
        21     none, and I think that what they do and how they do
        22     their job is very credible, and I just don't think
        23     that we need to micromanage from this chair right
        24     here trying to tell these folks how, when, what, and

                           


                                                                   72
         1     how to do their jobs.
         2   Q   But it would be fair to say, would it
         3     not, that as the superintendent the buck stops with
         4     you?
         5   A   The buck always stops --
         6            MR. CROWE:  Object to the form of the
         7     question.
         8     BY MR. TAYLOR:
         9   Q   You started to answer.
        10   A   The buck always stops here.
        11   Q   Right.  So it wouldn't be
        12     micromanaging, would it, to intervene if you thought
        13     that there was something wrong that was being done by
        14     subordinates in the name of the Chicago Police
        15     Department?
        16            MR. CROWE:  Object to the form of the
        17     question.  I don't see whether the buck stops here
        18     has anything to do with micromanaging.
        19                    You may answer if you understand the
        20     question.
        21            THE WITNESS:  When you say something is being
        22     done wrong, you know --
        23     BY MR. TAYLOR:
        24   Q   Um-hum.

                           


                                                                   73
         1   A   -- no one has proven or shown us
         2     anything, that anything has been done wrong.
         3   Q   No, I'm not talking --
         4   A   That's what you said, Mr. Taylor.
         5   Q   I'm not -- don't -- I'm not talking
         6     about anything specific now.  I'm asking you if, in
         7     fact, it were called to your attention that something
         8     needed to be fixed within the department, you
         9     wouldn't stand back, but rather you would act,
        10     wouldn't you?
        11   A   I would --
        12            MR. CROWE:  I would object to the form of that
        13     question.
        14            THE WITNESS:  I would bring that respective
        15     commander -- not commander -- but deputy
        16     superintendent in and ask him, you know, can you tell
        17     me about this, like I do my press officer.  Tell me
        18     about this situation.
        19     BY MR. TAYLOR:
        20   Q   Okay.  If, in fact, they told you
        21     things that appeared to you to be something that
        22     needed to be corrected, you would correct it, would
        23     you not, as the chief officer of the police
        24     department?

                           


                                                                   74
         1   A   Well, I think since these three years
         2     and two months that I've been here, I don't have to
         3     tell my folks what to correct.  They are coming to me
         4     and telling me how they corrected it, and they are a
         5     lot more proactive than I am, you know.
         6   Q   So you haven't had to act in any
         7     particular circumstance to correct any problems
         8     within the department?
         9            MR. CROWE:  Object to the form of the
        10     question.
        11            MS. ROSEN:  Object to the form.
        12            THE WITNESS:  You know, I can truthfully say
        13     that we have a very dynamite staff here, people who
        14     are very proactive and do their job the way it needs
        15     to be done.
        16                    To say that I micromanage, I will
        17     never, ever micromanage.  That's the reason we have
        18     the levels; the deputy superintendent, the chief of
        19     detectives, the commanders, the Violent Crimes
        20     lieutenant, and those sergeants in the Detective
        21     Division.
        22                    You're talking about three, four, five
        23     levels.  I'm quite sure that it -- before it reaches
        24     me it's going to get solved.

                           


                                                                   75
         1     BY MR. TAYLOR:
         2   Q   Okay.  Now, during those two weeks
         3     from the time that Ryan Harris' body was found on
         4     July 28th until the 9th of August, which was the date
         5     that these little boys were arrested here, did you
         6     attend any community meetings in Englewood in which
         7     the Ryan Harris case was a topic of discussion?
         8   A   I think there's a possibility that I
         9     did.
        10   Q   Okay.  Do you remember who attended
        11     the meeting?
        12            MR. CROWE:  Who from the community or who from
        13     the police department?
        14            MR. TAYLOR:  Well, whoever he remembers.
        15            THE WITNESS:  I think there's a possibility
        16     of -- I would have to see if Commander Ford --
        17     BY MR. TAYLOR:
        18   Q   That's the 7th District commander?
        19   A   I don't know who the commander was,
        20     the commander from the 7th District was, at that
        21     time.
        22   Q   I believe it was Ford.
        23   A   Yeah.  I would have to see if he
        24     attended with me.

                           


                                                                   76
         1   Q   Okay.  Would it have been at the 2nd
         2     District or would it have been out in the community?
         3   A   Well, the 2nd District is not in the
         4     7th District.  The 2nd District is at 51st and
         5     Wentworth.  The 7th District is at 61st and Racine.
         6   Q   I'm sorry.  I meant the 7th District.
         7   A   It's a possibility it could have been
         8     out in the neighborhood or it could have been at one
         9     of the churches.
        10   Q   Do you have a memory of where it was?
        11   A   No.
        12   Q   Did people articulate at this meeting
        13     concerns about the fact that the Ryan Harris case had
        14     not been solved?
        15   A   Yeah.  Yes, they did.
        16   Q   Okay.  And did you assure them as
        17     superintendent that everything was being done that
        18     could be done with regard to the investigation?
        19   A   I told them that as the Chicago Police
        20     Department that we were moving as fast and as
        21     thoroughly as we could in trying to solve this case.
        22   Q   Now, in the -- do you remember who
        23     from the community was present?
        24   A   Not right offhand, no.

                           


                                                                   77
         1   Q   Would it be fair to say that it had
         2     become a heater case in the community?
         3            MR. CROWE:  Object to the form of the
         4     question.
         5            THE WITNESS:  Well, that term that you used,
         6     that's a media term, a heater case, you know.  I
         7     guess I truthfully have to say in some sense, yes.
         8     BY MR. TAYLOR:
         9   Q   Okay.  During those first two weeks
        10     before the little boys were charged, was it called to
        11     your attention by Malone or anyone else that there
        12     were certain suspects that were being looked at with
        13     regard to the case?
        14            MR. CROWE:  This was before the arrest?
        15            MR. TAYLOR:  Right.
        16            THE WITNESS:  I don't remember that.
        17     BY MR. TAYLOR:
        18   Q   Do you remember whether you were
        19     informed that there were certain adult suspects that
        20     were being considered in the case?  Again, I'm
        21     talking about in the first two weeks.
        22   A   I don't remember him coming up with
        23     any specifics, specific adults.  No.
        24   Q   Now, did you have 24 -- did persons,

                           


                                                                   78
         1     such as Malone, have 24-hour access to you in the
         2     sense that they could reach you at any time of the
         3     day or night if there was an emergency or some
         4     significant information they needed to get to you?
         5            MR. CROWE:  Object to the form of the question
         6     and the prefatory remark "such as."
         7            THE WITNESS:  Almost half the Chicago Police
         8     Department got 24-hour access to me.
         9     BY MR. TAYLOR:
        10   Q   That's through your home number and
        11     your pager?
        12   A   Yes, sir, and through Operations
        13     command.
        14   Q   So you would say you're a very
        15     accessible superintendent?
        16   A   Yes, sir.
        17   Q   Would you get calls from Malone and
        18     others in the chain of command, from time to time, to
        19     discuss matters that they felt were significant?
        20   A   Usually if it came out of -- whatever
        21     bureau it came out of, that deputy superintendent
        22     would reach out for me and call me if he wanted to
        23     contact me.
        24   Q   Now, this A&A sheet indicates that on

                           


                                                                   79
         1     the 8th of August, which was a Saturday, that you
         2     were off, but that if you look at the 9th, it appears
         3     that you nonetheless worked from 11:00 to 4:00; is
         4     that right, if you look at the two sheets together?
         5   A   If you go back to the 8th of August,
         6     you'll look at 1630 to 1930 hours.
         7   Q   Right.  Actually, that's in reference
         8     to the 7th of August, isn't it?
         9   A   Okay.
        10   Q   Okay.  So the next date would be --
        11   A   The 9th of August.
        12   Q   -- the 9th.  Right.  But it says, "4
        13     HR, 11 to 15."  So is that -- do you know whether you
        14     worked on the 9th from 11:00 to 4:00?
        15            MS. ROSEN:  Three.
        16            THE WITNESS:  11:00 to 3:00.  That's 1500
        17     hours.
        18     BY MR. TAYLOR:
        19   Q   Oh, I'm sorry.
        20   A   If it's on here, I was.
        21   Q   Okay.  Let's look at the next day
        22     which says, "4 HR, 9 August 98, 1000 hours to 1400
        23     hours."  Do you see that?
        24   A   Um-hum.

                           


                                                                   80
         1   Q   So that would -- I guess I'm making
         2     the assumption that the entry on the 9th would be in
         3     reference to what you did on the 8th, which would be
         4     working 11:00 to 3:00, and then on the 10th is a
         5     reference to what you did on the 9th, which would be
         6     from 10:00 to 2:00.  Do you think that's a fair
         7     interpretation of those sheets?
         8   A   I guess that's a fair interpretation.
         9     I'm not a timekeeper.
        10   Q   Right.  But would you normally work
        11     three, four hours in the middle of the day on
        12     Saturday and Sunday, your off-day?
        13   A   If I didn't have a drug march or a
        14     gang march or some kind of community march or rally,
        15     then I would come down to the office and work.
        16   Q   Okay.  Now, on the 8th and 9th of
        17     August were you working in your office or do you know
        18     if you were out in the community?
        19   A   Well, I could have been in the office
        20     or I could have been outside, you know.  It all
        21     depends.
        22   Q   Now, on the 9th of August did you
        23     receive any communication from Deputy Superintendent
        24     Malone concerning the Ryan Harris case?

                           


                                                                   81
         1   A   The 9th of August?  What day is that?
         2   Q   That's a Sunday.
         3   A   That's a Sunday?  To my recollection,
         4     if I did receive some communication from Mike Malone,
         5     it might have been later on in the night.
         6   Q   It would have been on the night of the
         7     9th, Sunday night?
         8   A   Yeah, if he would have called me.
         9   Q   Would it have been at your home or --
        10   A   Yes, sir.
        11   Q   Okay.  And what do you remember about
        12     that call?
        13   A   Well, like I said, if he was going to
        14     call me, he would call me at night.  As far as the
        15     conversation, you know, you got to realize that I
        16     talk to 40, 50, sometimes a hundred people a day.  I
        17     don't remember all these conversations, especially
        18     going back almost what, two, three years.
        19   Q   Well, do you remember Malone calling
        20     you at home and telling you that two little boys had
        21     been arrested for the murder of Ryan Harris?
        22   A   At what -- I don't know if he said
        23     arrested or if they are talking to two little boys.
        24     I don't know which one he said.

                           


                                                                   82
         1   Q   So did he tell you the ages of the
         2     little boys?
         3   A   It's a possibility that he did.
         4   Q   Do the ages seven and eight sound
         5     about right?
         6   A   Yes, sir.
         7   Q   And did it surprise you or shock you
         8     when you heard this from Malone, that they were
         9     talking to or they were charging little boys, two
        10     little boys, that young with the murder of Ryan
        11     Harris?
        12   A   You know, when you say shocked, not
        13     particularly shocked.  You know, I was concerned
        14     because it seems as if during this day and age, and
        15     especially back then, that offenders were getting
        16     younger and younger and younger.
        17   Q   Okay.  So you were concerned when he
        18     told you that they either were talking to or were
        19     arresting the seven and eight-year-old little boys
        20     for the murder of Ryan Harris?
        21   A   I think, like I said, it's possible,
        22     as I remember, that he said they were talking to
        23     them.
        24   Q   Okay.  Did he tell you what they --

                           


                                                                   83
         1     what the nature of the talking to them was; in other
         2     words, what they were talking to them about?
         3   A   No, no.
         4   Q   Did he tell you that they were talking
         5     to them as suspects in the Ryan Harris case?
         6   A   No, sir.
         7   Q   But you knew enough to be -- what was
         8     the word you used -- concerned about such young kids
         9     being involved in a case like this, right?
        10   A   Right.
        11   Q   So you knew that they were somehow
        12     being connected to the murder of Ryan Harris as
        13     potential suspects, didn't you?
        14   A   Well, he said, as I remember -- as I
        15     remember, you know, he said that they were talking to
        16     them.  He never said anything, as I remember, and
        17     you're going back a few years, you know, but I don't
        18     know anything about suspects or arresting or anything
        19     like that.
        20   Q   Okay.  When he called you, though, it
        21     was a -- did you ask him any questions about what the
        22     details of what they were talking to the children
        23     were with regard to the murder of Ryan Harris?
        24   A   No.

                           


                                                                   84
         1   Q   Okay.  Did he tell you that evening
         2     that the parents or the grandparents of the children
         3     were there when they were talking to these kids?
         4   A   No, sir.
         5   Q   Did you ask him?
         6   A   No, sir, and I'll tell you the reason
         7     why is because I always --
         8            MR. CROWE:  There's no question pending.
         9            THE WITNESS:  Okay.
        10            MR. CROWE:  He didn't ask you why.
        11            THE WITNESS:  Okay.
        12            MR. TAYLOR:  All right.  Well, I will.  We're
        13     all interested here.
        14     BY MR. TAYLOR:
        15   Q   Why did you not?
        16   A   I don't talk over telephones, you
        17     know.
        18   Q   So you didn't want to go into a lot of
        19     detail over the telephone.  Is that fair to say?
        20   A   Well, I don't go into details over the
        21     telephone.  You know, it's -- I don't micromanage.
        22   Q   Why don't you go into detail over the
        23     telephone?  Is there a particular reason?
        24   A   I don't trust telephones.

                           


                                                                   85
         1   Q   Okay.  Did you ask Malone who the
         2     detectives were who were talking to these kids or
         3     questioning these kids?
         4   A   No, sir.
         5   Q   Did you know where it was occurring?
         6     Did you know it was occurring at Area 1?
         7   A   If it was occurring -- just me knowing
         8     -- being a chief of detectives, knowing it was
         9     probably occurring in Area 1 because that's where the
        10     crime happened, in Area 1.
        11   Q   Right.  Did you -- after getting the
        12     call from Malone, did you either go to Area 1 or make
        13     a call down to Area 1 to find out any more
        14     information?
        15   A   No, sir.
        16   Q   Did you know at that time that
        17     Brannigan and Zaborac were working at Area 1?
        18            MR. CROWE:  You mean during the telephone
        19     call?
        20            MR. TAYLOR:  Yeah, at that time.
        21     BY MR. TAYLOR:
        22   Q   Were you aware that they were
        23     supervisors at Area 1?
        24   A   That they were supervisors in the

                           


                                                                   86
         1     Detective Division at Area 1.
         2   Q   Yes.  You knew that?
         3   A   Yeah, I knew that they was assigned to
         4     Area 1.
         5   Q   Okay.  Did you know whether they were
         6     involved in the questioning of the little boys that
         7     Malone was telling you about?
         8   A   No, sir.
         9   Q   When Malone called, did he tell you
        10     the names of the little boys?
        11   A   No, sir.
        12   Q   Did you ask him?
        13   A   No, sir.
        14   Q   And did you ask him whether the little
        15     boys' parents or guardians were present in the Area
        16     anywhere?  Not necessarily that they were present
        17     during the questioning, but were they present there
        18     or not?
        19   A   No, sir.
        20            MS. ROSEN:  Can we take a quick break?
        21            MR. TAYLOR:  Sure.  I was just about to.
        22                        (Brief recess.)
        23     BY MR. TAYLOR:
        24   Q   In this phone conversation with Malone

                           


                                                                   87
         1     on the evening of the 9th, did you ask him whether
         2     they were going to arrest the little boys?
         3   A   No, sir.
         4   Q   Okay.  And he didn't tell you whether
         5     they were or not; is that right?
         6   A   No, sir.
         7   Q   Did you subsequently that evening
         8     either get another call from Malone or make a call to
         9     him to find out whether, in fact, they had arrested
        10     or charged the little boys --
        11   A   No.
        12   Q   -- with the murder of Ryan Harris?
        13   A   No, sir.
        14   Q   Did anyone call you, Ivanjack or
        15     anyone else, to tell you that?
        16   A   Not that I remember, no, sir.
        17   Q   Okay.  And the reason that you didn't
        18     follow up was because the -- you felt that you didn't
        19     want to micromanage this particular case; is that
        20     right?
        21            MR. CROWE:  Object to the form of the
        22     question.
        23     BY MR. TAYLOR:
        24   Q   Is that right?

                           


                                                                   88
         1   A   Yes, sir.
         2   Q   Okay.  Did you learn either later that
         3     night or the next morning that, in fact, these little
         4     boys that Malone told you about had been charged with
         5     the murder of Ryan Harris?
         6            MR. CROWE:  Object to the form of the
         7     question.  Charged or arrested?
         8            MR. TAYLOR:  What was my --
         9            MR. CROWE:  You said charged.
        10     BY MR. TAYLOR:
        11   Q   Did you learn that they had been
        12     arrested for the murder of Ryan Harris?
        13   A   I believe it was the next morning at
        14     the morning meeting, as I remember.
        15   Q   Okay.  Did you hear it on the news
        16     media prior to the morning meeting or was the first
        17     that you actually heard that they had been arrested
        18     was when you got to the morning meeting?
        19   A   I believe when I got to the morning
        20     meeting.
        21   Q   When you talked to Malone, did you
        22     discuss the possibility of arresting the children
        23     for -- let me make this clear.
        24                    When you talked to Malone on the

                           


                                                                   89
         1     evening of the 9th via the phone, did you discuss
         2     with him the possibility of arresting the children?
         3   A   No, sir.
         4   Q   All right.  Did you discuss whether
         5     to -- what to charge the children with if they were
         6     arrested?
         7   A   No, sir.
         8            MR. CROWE:  I'll object to the form of the
         9     question.  It's not his responsibility to charge.
        10     It's the state's attorney's responsibility.
        11     BY MR. TAYLOR:
        12   Q   Did you discuss what offense these
        13     children would be arrested for if they were arrested?
        14   A   No, sir.
        15   Q   Now, at the briefing on the morning of
        16     the 10th, that would have been around 9:00 o'clock in
        17     the morning if that was your normal time of having
        18     the briefing?
        19   A   Was that a Monday morning or --
        20   Q   Right.  That would be the 10th.
        21   A   The 10th.  About 9:00 o'clock we
        22     probably had -- between 9:00 and 9:10 we would have
        23     had the morning meeting.
        24   Q   Just one more question in terms of

                           


                                                                   90
         1     that conversation on the 9th with Malone.  Subsequent
         2     to the conversation with Malone in which he told you
         3     they had the little boys at Area 1 in connection with
         4     the Ryan Harris case, did you do any follow-up
         5     whatsoever with regard to the information that Malone
         6     gave you?
         7   A   No, sir.
         8   Q   On the 10th at the early morning
         9     briefing, who besides yourself and Malone was
        10     present?
        11   A   Well, it would be the normal -- it
        12     should have been the normal staff who would be there;
        13     the first deputy, Deputy Malone, Jeannie Clark, the
        14     superintendent's assistant, um, the acting press
        15     secretary, the general counsel, the ADS from the
        16     Internal Affairs Division, the administrator from
        17     OPS, the deputy superintendent of Administrative
        18     Services who is John Harris, and the deputy
        19     superintendent of Technical Services who would be Jim
        20     Whigham.
        21   Q   Was that during the time that there
        22     wasn't -- that Gayle Shines had left the OPS and
        23     before Callie Baird had taken over?  Was it at that
        24     period that --

                           


                                                                   91
         1   A   You know, I think Gayle Shines was --
         2     this was in '98.  Gayle Shines might have still been
         3     here.
         4   Q   Do you remember who from OPS was
         5     there, if anyone?
         6   A   No, sir.
         7   Q   Okay.
         8   A   No, sir.
         9   Q   Now, who was the deputy superintendent
        10     in charge of the IAD at that time?  Was that Mike
        11     Hoke or Risley?
        12   A   As I remember, it was either -- I
        13     believe it was Mike Hoke at the time.
        14   Q   Okay.  Now, at the briefing on the
        15     10th did you ask Malone questions about the -- well,
        16     let me ask you this.
        17                    How did it come up that the little
        18     boys had been arrested for the murder of Ryan Harris
        19     at this briefing on the 10th?
        20   A   As I remember, we would go around the
        21     room and the first deputy would give his report, and
        22     then Malone, he gave his report and stated that the
        23     two little boys had been, I believe, arrested, as I
        24     remember.

                           


                                                                   92
         1   Q   For the murder of Ryan Harris?
         2   A   Uh, yes.
         3   Q   And were you at all surprised or
         4     shocked at that point?
         5   A   Like I said earlier, not shocked, just
         6     concerned, you know.
         7   Q   And were you concerned because of the
         8     young ages of the little boys?
         9   A   I was concerned because of the young
        10     ages of the little boys, yes, sir.
        11   Q   And did Malone tell you anything
        12     beyond the fact that the little boys had been
        13     arrested for the murder of Ryan Harris?
        14   A   He probably mentioned their names, you
        15     know, and that's all that I remember because, as I
        16     remember, he didn't say that much at the morning
        17     meeting.
        18   Q   Okay.  Did he discuss with you what
        19     the bases for the arrests were?
        20   A   No, not him.  No.
        21   Q   Okay.  Did someone at this meeting
        22     tell you any details about the bases for the arrests
        23     of the two little boys?
        24   A   No, sir.

                           


                                                                   93
         1   Q   So at -- and did you inquire of Malone
         2     what the bases of the arrests were?
         3            MR. CROWE:  You mean at that particular
         4     meeting?
         5            MR. TAYLOR:  Yeah, I'm talking now about the
         6     morning of the 10th.
         7            THE WITNESS:  Not at that particular meeting,
         8     no
         9     BY MR. TAYLOR:
        10   Q   Again, was this because you didn't
        11     want to micromanage the case at that point?
        12   A   Well, I just felt that the Detective
        13     Division, they could handle the situation.
        14   Q   Well, had you ever heard of children
        15     this young being arrested for murder?
        16   A   Not children this young, but children,
        17     you know, young offenders, you know, that committed
        18     some very heinous crimes.
        19   Q   But you're talking about children
        20     nine, ten, 11 years old, that area?
        21   A   Yes, sir.
        22   Q   So these kids were younger than that,
        23     right?
        24   A   Yes, sir.

                           


                                                                   94
         1   Q   And did it -- did you question in your
         2     own mind whether children this young could commit the
         3     heinous murder that you knew that the Ryan Harris
         4     case was?
         5            MR. CROWE:  Object to the form of the
         6     question.
         7     BY MR. TAYLOR:
         8   Q   Or that the Ryan Harris murder was?
         9   A   No, I didn't question it.  No.
        10   Q   Okay.  Did either Malone or Camden
        11     discuss at this meeting that they were planning to
        12     have a press conference at Area 1 to discuss the
        13     details of the evidence that they said supported the
        14     arrest of the children?
        15   A   I don't remember that being discussed
        16     at that morning meeting, no, sir.
        17   Q   Did anyone inform you that such a
        18     press conference was going to be conducted at Area 1
        19     on the 10th?
        20   A   I think I found out after.
        21   Q   So it wasn't -- you were not consulted
        22     about whether to have that press conference; is that
        23     right?
        24   A   No, and I have -- no, sir.

                           


                                                                   95
         1   Q   Okay.  After you were informed that
         2     such a press conference took place, did you consider
         3     it to be an appropriate thing to do?
         4   A   Well, yes, it was an appropriate thing
         5     to do.  Why not.
         6   Q   Did you ever see the press conference
         7     itself?
         8   A   I can't particularly say I did.  You
         9     know, I heard about it.
        10   Q   Did you ever see a transcript of what
        11     was said at that press conference?
        12   A   No, sir.
        13   Q   But you generally heard the substance
        14     of what was discussed by these officers and Sergeant
        15     Zaborac at the press conference?
        16            MS. ROSEN:  Objection.  Foundation.
        17            THE WITNESS:  Say that again.
        18     BY MR. TAYLOR:
        19   Q   But you did generally hear what the
        20     substance was of what Sergeant Zaborac said at this
        21     press conference?
        22            MR. CROWE:  Object to the lack of foundation.
        23     You mean did he hear it?
        24            MR. TAYLOR:  Right.

                           


                                                                   96
         1            THE WITNESS:  I understand that he made a
         2     statement, and one of his statements was that an
         3     eight and a seven-year-old had been arrested for the
         4     murder of Ryan Harris.
         5     BY MR. TAYLOR:
         6   Q   And did you understand that he
         7     discussed some of the evidence that he said supported
         8     that arrest?
         9   A   No, I didn't hear that because I
        10     didn't watch the press conference.
        11   Q   Would that be appropriate for him to
        12     discuss evidence?
        13            MR. CROWE:  Object to the form of the
        14     question.
        15            THE WITNESS:  Well, I can't answer that, you
        16     know.  You would have to ask that detective or
        17     sergeant or Lieutenant Zaborac on that, you know,
        18     because he was the acting lieutenant at that
        19     particular time.
        20     BY MR. TAYLOR:
        21   Q   Have you ever directed there be any
        22     investigation into the conducting of the press
        23     conference on the 10th?
        24   A   Have I ever --

                           


                                                                   97
         1   Q   Yes.
         2   A   -- directed that what?
         3   Q   That there be an internal
         4     investigation as to the appropriateness of the press
         5     conference and what was said there.
         6   A   No, sir.
         7   Q   All right.  Are there certain
         8     regulations that need to be followed with regard to
         9     the holding of -- in terms of the department's
        10     supplying of information to the media?
        11   A   Yes, sir.
        12   Q   And if you violate those regulations,
        13     then you could be subject to internal discipline; is
        14     that right?
        15   A   Yes, sir.
        16   Q   But nothing that you knew of with
        17     regard to the holding of that press conference
        18     warranted any internal investigation into whether any
        19     departmental rules or regulations had been violated;
        20     is that right?
        21            MR. CROWE:  Objection to the form of the
        22     question.  He already said he doesn't know everything
        23     that was said at the press conference.
        24            THE WITNESS:  I don't know everything that was

                           


                                                                   98
         1     said at the press conference because I didn't view
         2     that tape of that press conference.
         3     BY MR. TAYLOR:
         4   Q   I understand that.  But from what you
         5     did know of the press conference, you didn't feel it
         6     necessary to have any investigation, internal
         7     investigation, done in order to determine whether it
         8     was appropriate in light of the rules and regulations
         9     of the police department.  Is that fair to say?
        10   A   Yes, sir.
        11   Q   All right.  When did you first hear
        12     that Zaborac had held a press conference?
        13   A   It was probably about an hour after it
        14     occurred.
        15   Q   And who told you?
        16   A   More than likely, Pat Camden probably
        17     told me.
        18   Q   What did he say to you?
        19   A   That a press conference was held and
        20     Stan Zaborac, uh, gave the press conference.
        21   Q   Were you aware that Zaborac had told
        22     the press that they were certain that they had
        23     arrested the right people?
        24   A   No, sir.

                           


                                                                   99
         1   Q   No?
         2   A   No.
         3   Q   Okay.  Did you start to get inquiries
         4     from the press concerning the arrest of the little
         5     boys on the 10th?
         6   A   Well, me, per se, no, sir.
         7   Q   Did your office?
         8   A   Yeah, more than likely the press
         9     office did.
        10   Q   Okay.  And did you give any statement
        11     to the press office to issue on behalf of yourself or
        12     the superintendent's office with regard to the
        13     arrests on the 10th?  I'm talking about on the 10th.
        14   A   The 10th was Monday?
        15   Q   Monday, the day after the boys were
        16     arrested at Area 1.
        17   A   I don't know.  You know, I don't
        18     remember if it was on the 10th or what.  I know
        19     following the arrests, you know, there was a number
        20     of press conferences held.  What date it was, I can't
        21     truthfully say.
        22   Q   Okay.  Well, did you make any public
        23     appearances on the 10th, that being the day, that
        24     Monday, the 10th?

                           


                                                                  100
         1   A   I couldn't say, Mr. Taylor.
         2   Q   Okay.
         3   A   I don't know if I had any public
         4     appearances that day or not.
         5   Q   Do you remember fielding any questions
         6     from the media with regard to the arrest of the
         7     little boys on the 10th?
         8   A   Not to my recollection.  I just -- I
         9     couldn't say.
        10   Q   Did you quickly learn that it was a
        11     major, major news item, the fact that such little
        12     boys had been charged for such a serious murder?
        13            MS. ROSEN:  Objection.  Form.
        14            THE WITNESS:  I knew that it was a major news
        15     item, you know.
        16     BY MR. TAYLOR:
        17   Q   You knew that from the beginning?
        18   A   Well, I knew that it was a major,
        19     major news item, you know, because Ryan Harris,
        20     whatever happened in the Ryan Harris case was going
        21     to be major.
        22   Q   But did you quickly learn that because
        23     such young boys had been charged with such a serious
        24     crime that it made it an even more major news item

                           


                                                                  101
         1     than it would have been otherwise?
         2   A   Yes, sir.
         3            MS. ROSEN:  Objection.  Form.
         4     BY MR. TAYLOR:
         5   Q   And were you concerned for the -- I
         6     take it, you were concerned for the family of Ryan
         7     Harris; is that right?
         8            MR. CROWE:  Objection.  Foundation.
         9            THE WITNESS:  When you say, "concerned" --
        10     BY MR. TAYLOR:
        11   Q   Well, you were concerned about what
        12     they had gone through and held sympathy for them?
        13   A   Well, not only for Ryan Harris, but
        14     for the entire community, the entire city, you know.
        15   Q   Were you also concerned about these
        16     two little boys and what it might do to them to be
        17     charged with such a serious crime?
        18            MR. CROWE:  Object to the form of the
        19     question.
        20            THE WITNESS:  You're always concerned about
        21     kids.  You know, whether they're the victims or
        22     offenders, you're always concerned about kids.
        23     BY MR. TAYLOR:
        24   Q   And did you have any question in your

                           


                                                                  102
         1     mind as to whether kids this young could form an
         2     intent to murder a young girl?
         3            MR. CROWE:  Object to the form of the
         4     question.
         5            THE WITNESS:  No, sir.
         6     BY MR. TAYLOR:
         7   Q   That wasn't a question in your mind?
         8   A   Um-um.
         9   Q   Was that discussed at the briefing on
        10     the 10th?
        11   A   No, sir.
        12   Q   All right.  When Malone mentioned --
        13     briefed you and told you the fact that the little
        14     boys had -- their names and that they had been
        15     arrested for the murder of Ryan Harris, did you ask
        16     him any questions about the arrests or about the
        17     case?
        18   A   I think --
        19            MR. CROWE:  I'm sorry.  At the morning
        20     meeting?
        21            MR. TAYLOR:  Yes, at the morning meeting on
        22     the 10th.
        23            THE WITNESS:  I think one of the things that I
        24     asked Mike is -- I believe I asked him one question

                           


                                                                  103
         1     and I asked him -- I forget what it was now, but I
         2     think I might have asked him one question.
         3     BY MR. TAYLOR:
         4   Q   Do you remember without -- anything
         5     about the question, generally what it was about?
         6   A   No, no.
         7   Q   Okay.
         8   A   I think I might have asked one
         9     question.
        10   Q   Do you remember his answer without
        11     remembering the question?
        12   A   No.
        13   Q   Did anyone else at the briefing ask
        14     Malone any questions about the arrest of the little
        15     boys in the Ryan Harris case at this briefing on the
        16     10th?
        17   A   You know, one or two of the deputies
        18     might have had a question or two.  What they were, I
        19     don't know.
        20   Q   All right.  Did you -- and you don't
        21     remember either if there were questions, what they
        22     were and what the responses were by Malone?
        23   A   No, sir.
        24   Q   Okay.  Now, did you at some point on

                           


                                                                  104
         1     the 10th or the 11th decide that you wanted to hear
         2     more detail about the circumstances of the arrests of
         3     the little boys?
         4   A   I believe it was on the 11th.  I think
         5     that was Tuesday.
         6   Q   Was this while you were -- was there a
         7     CAPS conference, a Community Policing conference,
         8     that was going on at the Hyatt --
         9   A   Yes, sir.
        10   Q   -- in Chicago?
        11   A   Yes, sir.
        12   Q   And were you speaking at that
        13     conference on the 11th?
        14   A   Yes, sir.
        15   Q   Were you then conducting your morning
        16     briefings at the Hyatt on the 11th, your command
        17     briefing at the Hyatt on the 11th, rather than at
        18     your offices?
        19   A   Yes, sir.
        20   Q   Now, let me ask you and go back for a
        21     minute to the briefing on the 10th.  Was the briefing
        22     on the 10th at your normal office or was that also
        23     downtown at the hotel?
        24   A   As I remember, I think it was at my

                           


                                                                  105
         1     office at 11th and State.
         2   Q   So the first briefing we're talking
         3     about, which was on the 10th, Monday the 10th, was at
         4     your office, but the next day you were at the CAPS
         5     conference so that your briefing was there; is that
         6     right?
         7   A   Yes, sir.
         8   Q   Did you make a determination on the
         9     11th to have some of the people who were more
        10     familiar with the arrest of the children to come in
        11     and appear at your briefing?
        12   A   Yes, sir.
        13   Q   Okay.  Do you know -- and why did you
        14     do that?
        15   A   What do you mean why did I do that?
        16   Q   Why did you decide that you needed
        17     more information concerning the arrest of the
        18     children?
        19   A   I wanted the supervisors that -- I
        20     wanted the Violent Crimes lieutenant and the sergeant
        21     who was in charge of the case to come down and give
        22     us a briefing and give us a little update and show us
        23     where they were.
        24   Q   Did you want to question them to

                           


                                                                  106
         1     determine whether they had made the right decision in
         2     arresting these little boys?
         3   A   No, sir, I didn't want to question
         4     them.  I just wanted them to come down and give us an
         5     update before we started our CAPS conference because
         6     I was due to give a major speech at 12:00 o'clock and
         7     after that was going to be press availability.
         8   Q   So you wanted -- you knew that the
         9     press was going to ask you some questions about the
        10     Ryan Harris case?  You anticipated that?
        11   A   Yes, sir.
        12   Q   And you wanted the people who had more
        13     information about the Ryan Harris arrest to brief you
        14     so that you would be more able to answer any
        15     questions that the press might have.  Is that fair to
        16     say?
        17   A   Well, not so much as answer all the
        18     questions the press was going to put towards me, but
        19     so I would have some knowledge, some brief knowledge,
        20     not an in-depth briefing of what this case was about.
        21   Q   Did you intend to review whether, in
        22     fact, the detectives and the sergeants involved in
        23     the arrest of the children for the Ryan Harris murder
        24     had, in fact, made the right decision or not?

                           


                                                                  107
         1   A   Did I intend to review it?
         2   Q   Yes.  Was that one of the purposes --
         3   A   No, sir.
         4   Q   -- of the briefing?
         5   A   Categorically, no.
         6   Q   You at that point were not doing any
         7     kind of review of the propriety of the arrests when
         8     you brought the people from Area 1 down on the 11th
         9     to speak to you at your briefing; is that right?
        10   A   Right, sir.
        11   Q   All right.  Now, I want to mark this
        12     300.
        13                        (Exhibit marked and tendered to
        14                         witness.)
        15                    Now, this is a Xeroxed copy of the
        16     front-page article of the Chicago Tribune that
        17     appeared on the morning of Tuesday, August 11th.
        18                    Do you remember generally seeing the
        19     newspapers on the 11th and a headline similar to
        20     this, "Police Say Suspects Not Too Small To Kill"?
        21            MS. ROSEN:  Objection.  Form.
        22            THE WITNESS:  You know, I can't say that I saw
        23     this because Tuesday was a big day for us, probably
        24     the biggest day the Chicago Police Department ever

                           


                                                                  108
         1     had in a long time, you know, and we were not in our
         2     regular meeting that day.  So I don't know if news
         3     clips were brought over that day.  I don't remember.
         4     BY MR. TAYLOR:
         5   Q   Well, do you remember seeing the paper
         6     either in the news boxes or laying on somebody's desk
         7     or something with the headline, the banner headline,
         8     "Police Say Suspects Not Too Small To Kill"?
         9   A   Like I said before, Mr. Taylor, I
        10     can't remember if I saw this.
        11   Q   You don't remember whether you saw
        12     this or not.  Okay.  I want to call your attention to
        13     the third page of this exhibit, and particularly I
        14     want to call your attention to the final column
        15     there.
        16                    About halfway down the paragraph --
        17     halfway down the column it says, "On Monday morning."
        18     Do you see that paragraph that I'm calling your
        19     attention to?
        20   A   Um-hum.
        21            MR. CROWE:  Let me get with you too, Flint.
        22     Oh, I see it.  Okay.  Thanks.
        23     BY MR. TAYLOR:
        24   Q   "On Monday morning Sabrina Harris, the

                           


                                                                  109
         1     victim's mother, appeared in juvenile court in hope
         2     of seeing the two boys.  She expressed doubt that
         3     such small boys could have overpowered her daughter.
         4     'She had two sisters, one seven and one eight, and
         5     she could run circles around them,' Harris said.
         6     'She was a tomboy.  She was strong.'"
         7                    Do you remember reading that
         8     information on or about Tuesday, the 11th?
         9            MR. CROWE:  I'll object to the form of the
        10     question.  He said he didn't see this article.
        11            THE WITNESS:  I don't remember seeing this.
        12     BY MR. TAYLOR:
        13   Q   Okay.  Do you remember having that
        14     information called to your attention in some form?
        15   A   Probably somewhere down the line, you
        16     know.
        17   Q   Do you remember when it was first
        18     called to your attention?
        19   A   Well, I couldn't really say, you know.
        20   Q   Did you become aware in the first few
        21     days after the little boys were arrested that, in
        22     fact, the case had become not only -- had a lot of
        23     notoriety locally, but it had notoriety nationally
        24     and even internationally?

                           


                                                                  110
         1   A   Yes, sir.
         2   Q   And did you realize that there was a
         3     whole lot of attention being paid to the case and
         4     particularly to the fact of -- that such little boys
         5     were being charged with such a serious crime?
         6            MR. CROWE:  Object to the form of the
         7     question.
         8            THE WITNESS:  Yes, sir.
         9     BY MR. TAYLOR:
        10   Q   Okay.  Did that cause you to want to
        11     take a closer look at the case?
        12            MS. ROSEN:  Objection.  Form.
        13            THE WITNESS:  No, sir.
        14     BY MR. TAYLOR:
        15   Q   So would it be fair to say that you
        16     didn't pay any more attention to this case than to
        17     any other serious murder case that would arise in the
        18     community?
        19   A   I never said that.
        20   Q   Did you pay more attention to it than
        21     the normal murder case that arose in the city?
        22            MS. ROSEN:  Objection.  Form.
        23            MR. CROWE:  I'll object to the form, too,
        24     because what's the normal murder case?

                           


                                                                  111
         1            THE WITNESS:  I paid attention to it.
         2     BY MR. TAYLOR:
         3   Q   Okay.  Now, when you summoned the
         4     sergeants to come down to speak to the briefing on
         5     the 11th, who did you ask to do that?
         6   A   I believe that I would probably have
         7     gone through Deputy Malone.
         8   Q   Okay.  Did you know who the persons
         9     were that he was going to bring down to talk to you
        10     about the case?
        11   A   Not until after they came in the room.
        12   Q   So you didn't request -- did you make
        13     any specific request with regard to who you wanted to
        14     come down?
        15   A   No.
        16   Q   You just said you wanted someone who
        17     knew about the case?
        18   A   The Violent Crimes lieutenant and the
        19     sergeant who was in charge of the case.
        20   Q   That's what you asked for?
        21   A   Yes.
        22   Q   And the acting Violent Crimes
        23     lieutenant turned out to be Stan Zaborac --
        24   A   Yes, sir.

                           


                                                                  112
         1   Q   -- who you knew?
         2   A   Yes.
         3   Q   And the supervising sergeant turned
         4     out to be Brannigan --
         5   A   Yes.
         6   Q   -- who you also knew, right?
         7   A   Yes, sir.
         8   Q   About what time did they arrive at
         9     this briefing?
        10   A   It was in the morning.  I would say
        11     probably about 9:00 or 10:00 o'clock, somewhere
        12     around about that time.
        13   Q   Again, was it at the Hyatt Regency?
        14     Is that where it was?
        15   A   Yes, sir.
        16   Q   And you had a conference room there
        17     where you held your briefing?
        18   A   Yes, sir.
        19   Q   Who was present that day?
        20   A   The normal people who would normally
        21     sit in on the morning meeting.
        22   Q   So, again, we have the deputy
        23     superintendents?
        24   A   Yeah.

                           


                                                                  113
         1   Q   And the first deputy, Townsend?
         2   A   Yes, sir.
         3   Q   And we have Camden?  Was he there?
         4   A   Yes, sir.
         5   Q   And Needham, the lawyer?
         6   A   Yes, sir.
         7   Q   And whoever was there from OPS?
         8   A   Yes, sir.
         9   Q   And Mike Hoke, if he was the assistant
        10     superintendent for IAD?
        11   A   Assistant deputy superintendent.
        12   Q   Okay.  Anyone else who was present?
        13   A   Well, the other deputy
        14     superintendents; Deputy Superintendent Whigham,
        15     Deputy Superintendent John Harris, Deputy
        16     Superintendent Jean Clark; naturally, Deputy
        17     Superintendent Mike Malone, First Deputy
        18     Superintendent John Townsend, and the commander at
        19     that particular time for the superintendent, my
        20     administrative assistant.  You know, those would be
        21     the people who would there be.
        22   Q   That would be Meinke?
        23   A   M-a-h-n-k-e, I think.
        24   Q   Okay.  I suppose we can get it right

                           


                                                                  114
         1     off of here.  M-a-h-n-k-e, according to the sheets
         2     here.  Those are the same people who were present the
         3     day before on the 10th at the briefing?
         4   A   Yes, sir.
         5   Q   Now, at this briefing on the 11th was
         6     Chief of Detectives Ivanjack also there?
         7   A   It's a possibility that he could have
         8     been.  It's a very good possibility that he could
         9     have been there.
        10   Q   Now, were there any notes or
        11     recordings being taken of this particular briefing?
        12   A   No, sir.
        13   Q   And when these -- Zaborac and
        14     Brannigan then entered the room, did they then -- why
        15     don't you tell us what happened at this meeting.
        16   A   Well, what would happen is we
        17     conducted our meeting, and then after the meeting was
        18     over we asked -- the deputy superintendent asked the
        19     two sergeants to come in to explain to us, told the
        20     rest of the body who they were, and asked them to
        21     give them a short synopsis of what occurred.
        22   Q   Okay.  Now, you say that you -- the
        23     rest of the meeting had gone on before the sergeants
        24     had been brought in?

                           


                                                                  115
         1   A   Yes, sir.
         2   Q   Had you discussed the Ryan Harris case
         3     at all outside of their presence at the briefing on
         4     the 11th before you brought them in?
         5   A   Not that I remember.
         6   Q   Did you discuss with any of the
         7     people, whether it be Townsend or Needham or Malone,
         8     what questions to ask these sergeants about the Ryan
         9     Harris case prior to their coming into the meeting?
        10            MR. CROWE:  I'm sorry.  The questions of
        11     Needham in the presence of all the other people,
        12     right, so as to distinguish it from any private
        13     conversation he had with Needham within the
        14     attorney-client privilege?
        15            MR. TAYLOR:  Right.  Well, this is -- I'm
        16     talking about at the briefing.
        17            MR. CROWE:  Okay.
        18     BY MR. TAYLOR:
        19   Q   At the briefing prior to the sergeants
        20     coming in, did you have any discussions with any of
        21     the participants in the briefing about what you were
        22     going to ask the sergeants about the case?
        23   A   No, I didn't have to discuss or have
        24     to tell folks what questions I ask.  These guys are a

                           


                                                                  116
         1     lot more experienced than Terry Hillard was at that
         2     particular time, so if they had questions to ask,
         3     they would ask them, you know.
         4   Q   But you were the only one who had
         5     previously been the chief of detectives of all the
         6     people sitting there, right?
         7            MR. CROWE:  Objection.  Argumentative, and to
         8     the form of the question.
         9            THE WITNESS:  No, I don't think so.
        10     BY MR. TAYLOR:
        11   Q   Well, was there anyone else that had
        12     commanded the Detective Division directly as the
        13     chief of detectives other than yourself that was at
        14     the briefing?
        15   A   I thought Jack Townsend was the chief
        16     of detectives at one time.  I don't know, you know.
        17     But being chief of detectives, that -- you know, just
        18     because you was chief of detectives doesn't mean that
        19     you -- that, you know, you were the Bible.
        20   Q   The Bible?
        21   A   Yeah, you know.
        22   Q   Uh-huh.  So you were counting on --
        23     even though you called the meeting, you were counting
        24     on others to ask the appropriate questions of these

                           


                                                                  117
         1     sergeants with regard to the Ryan Harris case at the
         2     briefing.  Is that fair to say?
         3            MR. CROWE:  Object to the form of the question
         4     as to what he was counting on.
         5            THE WITNESS:  I wasn't counting on them.
         6     BY MR. TAYLOR:
         7   Q   Relying on them.
         8   A   No, I wanted the sergeants to come in
         9     and give the body a short briefing on what had
        10     occurred, you know.  I wasn't counting on anybody to
        11     ask anything.  If they had questions to ask, they
        12     would ask.
        13   Q   Had you any questions?  Had you
        14     formulated any specific questions you wanted to ask
        15     them?
        16   A   I think the one thing that I asked is
        17     how do we know that these young kids are involved.
        18   Q   That's a question that you actually
        19     asked?
        20   A   Yeah.
        21   Q   All right.  Now, was that the first
        22     question that they were actually asked?
        23   A   I don't remember whether it was the
        24     first question, second question.

                           


                                                                  118
         1   Q   Did you ask them to bring any reports
         2     for you or the others in the briefing to review?
         3   A   I don't remember asking anybody to
         4     bring in reports.
         5   Q   Did they, in fact, bring any reports
         6     to the briefing on the 11th for you all to review?
         7   A   As I remember, as the sergeants came
         8     in, they had folders in their hand.  I don't remember
         9     them giving them to anybody to review because we
        10     didn't have that much time to review anything.
        11   Q   Okay.  How long did the portion of the
        12     briefing that the sergeants were present for, how
        13     long did that take?
        14   A   Probably no more than ten, 15 minutes,
        15     as I remember.  Ten, 15 minutes at the most.
        16   Q   Who did most of the talking?
        17   A   I think Lieutenant Zaborac, Stan
        18     Zaborac.
        19   Q   Okay.  And you say you asked them the
        20     question how do we know these boys did it?  Is that
        21     right?
        22   A   Um-hum.
        23   Q   Did I repeat that correctly?
        24   A   How do we know that they were

                           


                                                                  119
         1     involved.
         2   Q   All right.  And you asked that
         3     question because you wanted to have information to
         4     respond to the press later on in the day?
         5            MS. ROSEN:  Objection.  Form.
         6            THE WITNESS:  No, no.
         7     BY MR. TAYLOR:
         8   Q   Why did you ask that particular
         9     question?
        10   A   I asked that question because I felt
        11     that was a question to ask coming from me, how do we
        12     know they are involved.
        13   Q   And you thought it was appropriate
        14     conning from you?
        15   A   Yes.
        16   Q   Why did you think it was appropriate
        17     coming from you?
        18   A   Because I wanted to know, you know,
        19     how did we know that they were involved.
        20   Q   Did you have any question in your own
        21     mind about whether the children might have actually
        22     been involved?
        23   A   No.  I wanted to hear it from the two
        24     sergeants.

                           


                                                                  120
         1   Q   What did they say or what -- did
         2     Zaborac respond to your question?
         3   A   As I remember, Zaborac responded to my
         4     question.
         5   Q   Okay.  And what did he say?
         6   A   They had certain knowledge, certain
         7     facts about the body, that only anybody who had been
         8     near or around this particular incident knew about,
         9     and that was it.
        10   Q   That was his response?
        11   A   That was his response.
        12   Q   That they knew things that only people
        13     who had been around the body would have known?
        14   A   Yeah.
        15   Q   "They," meaning the kids, right?
        16   A   Yes.
        17   Q   Did he tell you or did you ask him any
        18     more detail about what knowledge that Zaborac said
        19     these kids had that only --
        20   A   No, I did not.
        21   Q   Did someone else?
        22   A   Not that I remember.  No one else.
        23   Q   All right.  And what else did --
        24     strike that.

                           


                                                                  121
         1                    What other questions were asked other
         2     than the question that you asked?
         3   A   Well, as I remember, there was a
         4     couple other questions asked of those two sergeants.
         5     The specifics of them, I couldn't tell you.  I don't
         6     remember.  But I know there was a couple people asked
         7     them a couple other questions and that was it.
         8   Q   Did Townsend ask them anything?
         9   A   I couldn't tell you that.
        10   Q   Did Malone ask them anything?
        11   A   You would have to ask Malone.  I don't
        12     know.
        13   Q   You don't remember?
        14   A   I don't remember.
        15   Q   Other than them saying that there was
        16     information that these kids had that only persons who
        17     had been involved with the body would have, what
        18     other information did the sergeants say during this
        19     meeting?
        20   A   That was it as far as they told about
        21     the two kids, their age, um, told about Ryan Harris,
        22     that they had not been able to locate the bicycle,
        23     that they had certain evidence over at the forensic
        24     laboratory that was waiting to be analyzed and

                           


                                                                  122
         1     processed, and that they were going to continue with
         2     their canvassing and try to interview people from
         3     that respective neighborhood.
         4   Q   Did they tell you what evidence that
         5     they had over at the forensic laboratory that they
         6     were waiting on to be analyzed?
         7   A   No, sir.
         8   Q   Did you know at that time that there
         9     were panties that had been found in the mouth of Ryan
        10     Harris?
        11   A   No, sir.
        12   Q   Did they tell you that in the -- so
        13     they didn't mention that in the briefing?
        14   A   No, sir.  No.
        15   Q   Did you know whether those panties had
        16     been tested to see if there was semen on them?
        17   A   No, sir.
        18            MR. CROWE:  On the 11th?
        19            MR. TAYLOR:  Yeah, I'm talking now about on
        20     the 11th.
        21            THE WITNESS:  No.
        22     BY MR. TAYLOR:
        23   Q   Did you or anyone else ask these
        24     sergeants anything about the physical evidence; in

                           


                                                                  123
         1     other words, any details about what physical evidence
         2     that they were waiting for tests on?
         3   A   No, sir, I didn't ask.
         4   Q   Did anyone else?
         5   A   I don't know.  After the meeting, you
         6     know, somebody might have had some private
         7     conversation with them, but, you know, publicly, I
         8     don't remember anybody asking, you know.  I know I
         9     didn't ask.
        10   Q   Did they talk about what the murder
        11     weapon was or what their investigation showed the
        12     murder weapon was?
        13   A   Well, one -- I believe it was
        14     Brannigan stated that it seemed as though she had
        15     been involved in an altercation and somebody had
        16     threw a rock and that was it.
        17   Q   Did he say whether there was any
        18     evidence to connect the boys to the rock that was
        19     thrown at her?
        20   A   From what I remember, he said that
        21     these kids was involved with a group of kids who had
        22     thrown a rock or rocks at Ryan Harris.
        23   Q   Okay.  And you knew from your previous
        24     knowledge of the case that she had had a blunt trauma
                           


                                                                  124
         1     to the head?
         2   A   That's what I had seen.
         3   Q   Okay.  And did they, Brannigan or
         4     Zaborac, tell you that the blunt trauma to the head
         5     had been caused by the thrown rock?
         6   A   No.
         7   Q   Did you make that --
         8   A   No, no.
         9   Q   -- connection in your head?
        10   A   That's the connection that I had made.
        11   Q   You made that connection.  Did you ask
        12     any questions about whether the medical evidence
        13     supported the fact that a thrown rock could have
        14     caused the blunt trauma to the head?
        15   A   No, I didn't ask any questions.
        16   Q   So from what -- the impression --
        17     strike that.
        18                    So from what you understood from what
        19     was being told to you at the briefing was that the
        20     little boys had been involved with a group of boys
        21     that threw a rock or rocks at Ryan Harris and that
        22     caused her death by the blunt trauma to the head?
        23   A   Well, that was my approximation.
        24     That's what I assumed.

                           


                                                                  125
         1   Q   Okay.  From what you heard?
         2   A   Yeah, from what I heard.
         3   Q   And given your experience as an
         4     investigator and police officer for 30 or 34 years,
         5     did it occur to you whether a thrown rock by a
         6     seven-year-old or an eight-year-old could possibly
         7     inflict a blunt trauma to an 11-year-old girl
         8     sufficient to kill her?
         9            MR. CROWE:  Objection to the form of the
        10     question.
        11            THE WITNESS:  Well, I had no idea on how large
        12     the rock was, you know, who threw it, you know.
        13     BY MR. TAYLOR:
        14   Q   Did you make any inquiry about that?
        15   A   No.
        16   Q   Did anyone else?
        17   A   I know I didn't --
        18   Q   Well, you didn't --
        19   A   -- but as far as anybody else, I can't
        20     speak for anybody else.
        21   Q   Okay.  Did they say anything to you
        22     about any injury to Ryan Harris' vagina or hymen or
        23     sexual organs?
        24            MR. CROWE:  Object to the form of the

                           


                                                                  126
         1     question, the nebulous "they."
         2     BY MR. TAYLOR:
         3   Q   "They," meaning either of the
         4     sergeants.
         5   A   Brannigan and Zaborac, no.
         6   Q   Right.
         7   A   No, not to me, no, sir.
         8   Q   Were you aware on the 11th when you
         9     were participating in this briefing with Zaborac and
        10     Brannigan that there had been, according to the
        11     medical examiner, an injury to the vagina of Ryan
        12     Harris?
        13   A   Not that day, no, sir.
        14   Q   You learned that subsequently?
        15   A   Subsequently, later on.
        16   Q   After the charges were dropped against
        17     the boys?
        18   A   Yes, sir.
        19   Q   Now, did they say anything about the
        20     girl having suffered any suffocation as part of her
        21     injury -- "they," meaning Brannigan or Zaborac -- at
        22     the briefing?
        23   A   No.  As I remember, they really didn't
        24     get off into details, specifics such as that, as I

                           


                                                                  127
         1     remember.
         2   Q   Okay.  How about any leaves being
         3     placed in the girl's nose or the girl's mouth or any
         4     other part of her body?  Did they say anything about
         5     any evidence concerning leaves at this briefing?
         6   A   I remember something about some
         7     leaves, yeah.
         8   Q   What do you remember about leaves?
         9   A   Uh, that some leaves or leaves was
        10     found in her nostrils or something like that.
        11   Q   Okay.  Did they say who placed those
        12     leaves in the nostrils?
        13   A   No, sir.
        14   Q   They did not?
        15   A   No.
        16   Q   Did they say anything about the body
        17     having been moved at any time?
        18   A   No.
        19   Q   Did they say anything about there
        20     being any marks on the body, drag marks or any other
        21     kind of abrasions or marks on the body?
        22   A   I don't think -- as I remember, not at
        23     that briefing, no.
        24   Q   Did you learn that sometime

                           


                                                                  128
         1     subsequent?
         2   A   I learned it subsequently, later on
         3     down the line.
         4   Q   How long?  How much later down the
         5     line?
         6   A   I would say probably right after the
         7     charges had been dropped.
         8   Q   Okay.  Now, from this briefing did you
         9     learn that the children had, according to the police,
        10     made statements?
        11            MR. CROWE:  I'll object to the form of the
        12     question because he's already answered that they made
        13     statements knowing things that only those who would
        14     be involved knew.  He's answered that.
        15            MR. TAYLOR:  No, I don't think so.  But you
        16     can --
        17            MR. CROWE:  Oh, all right.  Okay.  Then I'll
        18     withdraw the objection.
        19            THE WITNESS:  What was the question?
        20            MR. TAYLOR:  Can you read it back, please.
        21                        (Record read.)
        22            THE WITNESS:  I think I learned further down
        23     the line that the children had made statements
        24     pertaining to that, you know.

                           


                                                                  129
         1     BY MR. TAYLOR:
         2   Q   When did you first learn that the
         3     children had made statements pertaining to it?
         4   A   Let me back up here.
         5   Q   Sure.
         6   A   When Stan Zaborac -- when I made the
         7     question, you know, how do we know they were
         8     involved, I think I said, and they said they knew
         9     things about the body that only people who had been
        10     in and around the body, that incident, that only
        11     somebody who had been around that incident would know
        12     about.
        13   Q   Okay.  So you took -- at the time did
        14     you take that to mean that the children made some
        15     statements?
        16   A   Yeah, because they were talking to
        17     them.
        18   Q   But you didn't find out any of the
        19     details of what the statements consisted of at that
        20     time?
        21   A   No.
        22   Q   Did they tell you what circumstances
        23     the statements were given in?
        24   A   What do you mean?

                           


                                                                  130
         1   Q   Well, in terms of who was present,
         2     that kind of thing.
         3            MR. CROWE:  You're talking about the 11th?
         4            MR. TAYLOR:  Yeah, the briefing on the 11th.
         5            THE WITNESS:  Can you repeat that for me?
         6                        (Record read.)
         7                    Okay.  I assumed that the detectives
         8     and the Youth officers were present.
         9     BY MR. TAYLOR:
        10   Q   Okay.  But did they tell you that?
        11   A   No.
        12   Q   So you made an assumption that --
        13   A   Yes.
        14   Q   Did they tell you whether the parents
        15     or the grandparents were present when these
        16     statements or statement were given by the little
        17     boys?
        18   A   No.
        19   Q   Did you ask?
        20   A   No.
        21   Q   Did anyone else ask?
        22   A   Not that I remember.
        23   Q   All right.  Did Zaborac or Brannigan
        24     say anything about the ability of either of these

                           


                                                                  131
         1     children to speak coherently?
         2            MS. ROSEN:  Objection.  Form.
         3            MR. CROWE:  Well, I don't think he's --
         4                    I thought you hadn't finished your
         5     question.
         6            MR. TAYLOR:  No, I did.
         7            MR. CROWE:  Oh, okay.
         8            THE WITNESS:  No.
         9     BY MR. TAYLOR:
        10   Q   And did either of them tell you that
        11     the littlest boy, the seven-year-old, had a speech
        12     impediment?
        13   A   No, no.
        14   Q   Did they tell you in any way how the
        15     statements were given?  In other words, were they
        16     question and answer, were they narrative form, were
        17     they some combination of both?  Was that --
        18   A   No, sir.
        19   Q   -- told to you?
        20   A   No, sir.
        21   Q   Did you ask any questions to determine
        22     how the statements were given?
        23   A   No, sir.
        24   Q   Did anyone else in your presence?

                           


                                                                  132
         1   A   At that briefing?
         2   Q   Yeah, at that briefing.
         3   A   Not that I remember.
         4   Q   Okay.  And did you have any concerns
         5     at that time about whether such little kids could
         6     give statements which were either -- were credible?
         7            MS. ROSEN:  Objection.  Form, foundation.
         8     BY MR. TAYLOR:
         9   Q   Let me ask a different question.  Did
        10     you have any concerns that such little kids could be
        11     easily intimidated or -- intimidated into giving
        12     statements that wouldn't be accurate?
        13            MS. ROSEN:  Objection.  Foundation.
        14            MR. CROWE:  Object to the form of the
        15     question.
        16            THE WITNESS:  You know, I can't answer that
        17     because I wasn't there.  I don't know if they were
        18     intimidated.
        19     BY MR. TAYLOR:
        20   Q   I know.  I'm not asking you that.  I'm
        21     asking you as you sat there listening to the briefing
        22     and knew that some kind of statements had been given,
        23     according to the police, did you have any concerns in
        24     your mind as to whether these statements were --

                           


                                                                  133
         1     could have been the product of coercion or
         2     intimidation?
         3            MS. ROSEN:  Objection.  Foundation.
         4            MR. CROWE:  I'll object to the form of the
         5     question.
         6            THE WITNESS:  I wish I could answer that.  The
         7     only thing I can tell you is that, you know, you're
         8     always concerned when you have young folks involved
         9     in situations such as this.  But to say that, you
        10     know, this is -- this was a new avenue.
        11     BY MR. TAYLOR:
        12   Q   This was what?
        13   A   A new avenue, not only for this
        14     department, but all across the country with young,
        15     youthful offenders, suspects such as this.
        16   Q   Well, were you aware of any ways that
        17     the police department had in place to deal with the
        18     questioning of young children in order to assure that
        19     they were not intimidated or coerced into giving
        20     statements that were not true?
        21            MS. ROSEN:  Object to the form.
        22            MR. CROWE:  I'll object to the form, too.
        23            THE WITNESS:  I believe that's what the Youth
        24     officers' role is to play.

                           


                                                                  134
         1     BY MR. TAYLOR:
         2   Q   The youth officers' role is to make
         3     sure that they are not intimidated?
         4   A   And look out for the -- not only the
         5     well-being of those youthful offenders, youthful
         6     suspects, of the people being questioned, but to act
         7     as an advocate for those young folks.
         8   Q   Did you ask any questions of any of --
         9     either of the sergeants at the briefing on the 11th
        10     as to whether there was any element of intimidation
        11     or coercion or anything like that with regard to the
        12     children?
        13   A   No, sir.
        14   Q   Did anyone else?
        15   A   Not that I remember, no, sir.
        16   Q   Similarly, was it a concern of yours
        17     that such young children could be easily suggestible
        18     in terms of whether they had been asked leading
        19     questions or had information suggested to them that
        20     they might, in order to please the police, repeat
        21     things that they really didn't have any knowledge of?
        22                    Was that a concern that you had at the
        23     briefing on the 11th when considering what Zaborac
        24     and Brannigan were telling you?

                           


                                                                  135
         1            MR. CROWE:  Object to the form of the multiple
         2     questions and --
         3            MS. ROSEN:  Objection.  Foundation.
         4            MR. CROWE:  -- also the foundation and lack
         5     thereof.
         6            THE WITNESS:  Mr. Taylor, the only thing I can
         7     tell you is Dan Brannigan and Stan Zaborac are two
         8     very competent, very articulate, very kind
         9     individuals who I got a lot of confidence in and --
        10     BY MR. TAYLOR:
        11   Q   But to answer my question, was it or
        12     was it not a concern?
        13            MR. CROWE:  Have you finished your answer?
        14            THE WITNESS:  People I got a lot of confidence
        15     in.  And anyone who suggests that they were coerced
        16     and intimidated, even young offenders or old
        17     offenders, you know, I just take issue with that.
        18     BY MR. TAYLOR:
        19   Q   Well, what I'm asking you is
        20     whether -- I think my question was about the
        21     suggestibility of young children and whether it was a
        22     concern of yours that children of these tender ages
        23     could have things suggested to them through
        24     questioning that they might repeat and that, in fact,

                           


                                                                  136
         1     they didn't have the knowledge that they said they
         2     had.
         3            MS. ROSEN:  Objection.  Foundation.
         4            MR. CROWE:  I'll object to the form of the
         5     question because it's been asked and answered.  He
         6     said it wasn't a concern because of the confidence he
         7     had in his officers.
         8            MR. TAYLOR:  Is that a -- well, why don't we
         9     hear it from him.
        10            THE WITNESS:  Yeah.  You know, I really do
        11     believe that these two individuals, you know, would
        12     not allow anything like that to happen.
        13     BY MR. TAYLOR:
        14   Q   Did you know whether Zaborac and
        15     Brannigan had done the questioning themselves or
        16     whether the questioning was done by other officers?
        17   A   No, I don't know.
        18   Q   So, I take it, then you didn't ask any
        19     questions nor were any questions asked concerning
        20     whether the information that the children had said
        21     was suggested to them during the questioning in one
        22     form or another?
        23   A   No, sir.
        24   Q   Now, at some point was it -- strike

                           


                                                                  137
         1     that.
         2                    Was anyone, did anyone draw any
         3     conclusions in this briefing as to whether the
         4     officers who had arrested the children had acted
         5     properly?
         6   A   I think that, you know, when they got
         7     through with that briefing, we felt that they had
         8     acted properly.
         9   Q   Okay.  And did you -- did anyone
        10     articulate that in the meeting, yourself or any of
        11     the deputy superintendents or anyone else, legal
        12     counsel or anyone else, articulate that they had,
        13     according to what they had told you, what Zaborac and
        14     Brannigan had told you, that they had acted
        15     appropriately?
        16   A   I think that, uh, it was seen and
        17     agreed upon that they acted properly.  We had no
        18     reservations about it.
        19   Q   And did you say that to each other or
        20     are you just making that assumption?
        21   A   No, no one said anything differently.
        22   Q   Okay.  So there wasn't anything said,
        23     but because nobody raised any concerns or said that
        24     they had a problem with it, you're assuming that

                           


                                                                  138
         1     everybody thought that they had acted properly?
         2   A   No red flags or anything like that
         3     went up, you know.  They finished their briefing, we
         4     said thank you, and as they were walking out, I
         5     guess, maybe one or two deputy superintendents might
         6     have said something to them on the side, you know,
         7     privately, and that was it.
         8   Q   Did you yourself ever say to them that
         9     they had acted properly, in your opinion?
        10   A   Well, it wasn't -- no.  No, I didn't.
        11   Q   Did Needham or any of the deputy
        12     superintendents say to them, you acted properly?
        13   A   I don't remember that being said.
        14   Q   Okay.  All right.  So you say this
        15     took, what, ten, 15 minutes?
        16   A   I think about probably ten, 15
        17     minutes.
        18   Q   And after that sometime later in the
        19     day you had a press conference or -- was it a press
        20     conference?
        21   A   I don't think it was so much that as
        22     it was press availability.
        23   Q   So the press was attending your speech
        24     at the CAPS conference?

                           


                                                                  139
         1   A   Right.
         2   Q   And afterwards they then asked you
         3     questions?
         4   A   As I remember, yes, sir.
         5   Q   Okay.  And were at least some of the
         6     questions, if not most of them, directed toward the
         7     arrest of the little boys in the Ryan Harris case?
         8   A   Yes, sir.
         9            MS. ROSEN:  Objection.  Form.
        10     BY MR. TAYLOR:
        11   Q   Was there an unusually large number of
        12     press there that day?
        13            MS. ROSEN:  Objection.  Form.
        14            MR. CROWE:  Yeah, I'll object to form, too.
        15            THE WITNESS:  Well, it would be for a number
        16     of reasons because we had over six, 700 people from
        17     across the world attending our CAPS conference, for
        18     one thing, and the press had been invited.
        19                    And then the next thing, you know,
        20     this case surely was at the top of the list with the
        21     media.
        22     BY MR. TAYLOR:
        23   Q   Okay.  Would you say that the main
        24     focus of the media at this press conference or --

                           


                                                                  140
         1     that happened after your speech was the Ryan Harris
         2     case and the arrest of the children?
         3   A   Well, I don't think the main focus,
         4     no, was -- you know, they were also to attend and to
         5     report on the Community Alternative Policing Strategy
         6     conference.
         7   Q   But what I'm asking you is in terms of
         8     the questions directed at you, was it primarily
         9     questions about the Ryan Harris case?
        10   A   There was a number of questions about
        11     the Ryan Harris case, yeah.
        12   Q   Now, I want to show you what I'm going
        13     to mark as Plaintiffs' Exhibit 301, which is a
        14     transcription of certain remarks attributed to you in
        15     various TV clips that we have.
        16                        (Exhibit marked and tendered to
        17                         witness.)
        18                    You don't need to look at all of this
        19     right now.  I'm going to call your attention to
        20     certain remarks here and ask you whether you made
        21     these comments.
        22                    I'm looking now at page 1 of this
        23     document and it says, "WMAQ, Hillard," and then it
        24     says, "Number 1, 8/11/98, 6:00 p.m., 10:00 p.m.

                           


                                                                  141
         1     news," and it has a quote attributed to you.
         2                    "Two to three weeks ago it was the
         3     press coming to me and asking me, when are you going
         4     to solve this case, when are you going to solve this
         5     case.  Now that it's solved, then we, on the other
         6     hand, well, you got the wrong folks.  It's tragic
         7     that a seven and eight-year-old can be involved in an
         8     incident such as this, but it happens."
         9                    Did you give this statement at this
        10     CAPS conference which was reflected in this
        11     transcription of the channel 5 news of the 6:00
        12     o'clock news in this document?
        13   A   I don't know if it was given at -- to
        14     the conference itself.  It was probably --
        15   Q   It was --
        16   A   It was probably --
        17   Q   -- in your remarks to the press after
        18     the conference?
        19   A   Yes, yes
        20   Q   And is this accurate?
        21   A   I would assume it is.
        22   Q   Okay.
        23   A   You know, I don't know.  I would
        24     assume it is.

                           


                                                                  142
         1   Q   I'm looking on page 3, and it's WFLD,
         2     which is channel 32, their 9:00 o'clock news, and it
         3     has the commentator saying, "Prosecution and police
         4     commissioner defend the investigation and murder
         5     charge," and then it quotes you, basically the same
         6     quote again that you -- so, I would take it, that was
         7     a quote that you gave and that was used by multiple
         8     media outlets here in the City of Chicago; is that
         9     right?
        10            MS. ROSEN:  Object to form.
        11            MR. SHEEHAN:  Do you understand the question?
        12            THE WITNESS:  No.
        13            MR. CROWE:  Why don't you read it back.
        14                        (Record read.)
        15            THE WITNESS:  I assume it was, yes.
        16     BY MR. TAYLOR:
        17   Q   Okay.  And, again, your conclusion
        18     that the case was solved was based on the information
        19     you had received from Malone on the 9th and the 10th
        20     and also the briefing you had on the 11th.  Is that
        21     the basis for your comments here as reflected on the
        22     11th?
        23   A   Yes, sir.
        24   Q   Anything else other than those items?

                           


                                                                  143
         1   A   No, sir.
         2   Q   All right.  Now, did you have another
         3     occasion to talk to the press on the 12th of August?
         4            MR. CROWE:  Do you have something here that
         5     shows that?
         6            MR. TAYLOR:  Yeah.
         7            MR. CROWE:  Which one?
         8            MR. TAYLOR:  Well, I'm looking at a couple of
         9     quotes that are --
        10            MR. CROWE:  Can I show this to him?
        11            MR. TAYLOR:  Yeah.
        12            MR. CROWE:  The bottom of the page.
        13     BY MR. TAYLOR:
        14   Q   They're both on WFLD, their 9:00
        15     o'clock, and WLS on 9:00 o'clock, and they both quote
        16     you as saying, "This is the United States of America.
        17     People can say what they want to say, but the letter
        18     of the law was followed in this case."  They both
        19     have you saying that.
        20            MS. ROSEN:  Objection.  Form.  Your own
        21     document isn't clear that WFLD actually said that at
        22     9:00 p.m. on August 12th.  There's a question mark
        23     next to that.  I don't know what that question mark
        24     means because it's your document.

                           


                                                                  144
         1            MR. TAYLOR:  I think that's a typo.
         2     BY MR. TAYLOR:
         3   Q   Do you remember giving a similar quote
         4     to that in response to criticism that -- about how
         5     you were handling the Harris case, that the letter of
         6     the law was followed in this case?
         7   A   Yeah, I assume that I said that.
         8   Q   Okay.  Again, did you draw that
         9     conclusion based on your briefing from Brannigan and
        10     Zaborac on the 11th?
        11   A   On the 11th?
        12   Q   Yes.
        13   A   Yes.
        14   Q   Is that right?
        15   A   Yes.
        16   Q   Well, did all of this come --
        17            MR. CROWE:  I'll object now.  Before you said
        18     what Malone had said to him and what Malone had said
        19     again and then what the sergeants had said and what
        20     everybody else said at the briefing and then what he
        21     knew about the quality of the officers involved.  So
        22     all of that --
        23            MR. TAYLOR:  No, I never said that.
        24            MR. CROWE:  -- formed a factual basis.

                           


                                                                  145
         1            MR. TAYLOR:  Well, wait a minute.  You're just
         2     giving him an answer.
         3            MS. SUSLER:  Yes.  Nice testimony.
         4            MR. TAYLOR:  I never asked that, but you can
         5     note your objection.  That's fine.
         6            MR. SHEEHAN:  Wait one second.
         7                        (Whereupon there was an
         8                         off-the-record discussion held
         9                         between defendants' counsel.)
        10     BY MR. TAYLOR:
        11   Q   Um, did you have -- I guess my
        12     question is did you have a second conversation with
        13     the news media, that one being on the 12th rather
        14     than the 11th, or is this quote about they following
        15     the letter of the law, was that given on the 11th and
        16     just used on the 12th?
        17   A   That's a possibility, that it could
        18     have been given on the 11th and used on the 12th, you
        19     know --
        20   Q   Okay.
        21   A   -- because the 12th was -- I don't
        22     know.
        23   Q   Now, I want to show you what I'm going
        24     to mark as Plaintiffs' Exhibit 302 and -- well, first

                           


                                                                  146
         1     let me show you 301.  Let me mark this as 302.  I'm
         2     sorry.
         3                        (Exhibit marked and tendered to
         4                         witness.)
         5                    Now, this is a front-page article on
         6     the 12th of August of the Chicago Tribune, "Fight
         7     Looms Over Boys' Confessions."  Did you see this
         8     particular news article on or about the 12th of
         9     August?
        10   A   I don't remember.  More than likely I
        11     did.
        12   Q   Okay.  Let me mark this as 303, which
        13     is the 13th of August.
        14                        (Exhibit marked and tendered to
        15                         witness.)
        16                    Again, this is a Thursday, the 13th of
        17     August, Chicago Tribune article, front-page article.
        18     Did you see this on or about the 13th?
        19   A   I probably saw it, yeah.
        20   Q   Okay.  Now, did you feel, given your
        21     experience as a police officer, that it would have
        22     taken a certain kind of child to be that young and to
        23     have committed the kind of murder that the Ryan
        24     Harris case was or --

                           


                                                                  147
         1            MS. ROSEN:  Objection.
         2     BY MR. TAYLOR:
         3   Q   -- did you have any opinion as to
         4     that?
         5            MS. ROSEN:  Form, calls for speculation.
         6     Foundation.
         7            MR. CROWE:  Join in the objection.
         8            THE WITNESS:  I can't answer that.  I have no
         9     opinion of it.
        10     BY MR. TAYLOR:
        11   Q   Okay.  Did the fact that it appeared
        12     that these children had parents who loved them and
        13     were concerned for them, did that have any impact on
        14     you as to questioning whether, in fact, these
        15     children could have committed the crime?
        16            MR. CROWE:  I'll object to --
        17            MS. ROSEN:  Objection.  Form --
        18            MR. CROWE:  -- the form of the question.
        19            MS. ROSEN:  -- calls for speculation.
        20            THE WITNESS:  No, sir.
        21     BY MR. TAYLOR:
        22   Q   Okay.  Now, I want to look again at
        23     the August 12th article that you say you most likely
        24     saw.

                           


                                                                  148
         1   A   Which exhibit is that?
         2   Q   That's 302, I believe.
         3            MR. CROWE:  August 12th, Chicago Tribune.
         4            THE WITNESS:  Okay.
         5     BY MR. TAYLOR:
         6   Q   Now, looking at the last column of the
         7     first page and the first column of the second page,
         8     it has a quote.  "'The question is simply whether the
         9     individual understands that he is obligated to tell
        10     the truth and can distinguish reality from fantasy,'
        11     said Ronald Allen, a professor of criminal and
        12     constitutional law at Northwestern University.
        13                    "Another question concerns whether a
        14     confession from a juvenile is coerced or is otherwise
        15     unreliable because the child is frightened or
        16     confused by the police interrogation.  'Children can
        17     be made to say virtually anything, including
        18     fantasizing magical rituals, baby killing, black
        19     magic,' Allen said.  'We've seen many cases in which
        20     children fantasize the most astounding things that
        21     never happened.  There is tremendous concern about
        22     children's vulnerability to suggestion, and we've
        23     found that suggestion can occur in very, very subtle
        24     ways.'"

                           


                                                                  149
         1                    Do you remember that particular quote
         2     or seeing it at the time you saw this newspaper?
         3   A   I remember that -- I don't remember
         4     that particular quote, you know.  I'm quite sure that
         5     if -- that I have read these news clips, but as far
         6     as remembering, per se, I can't say that.
         7            MR. TAYLOR:  Then looking at the -- do I have
         8     a 304 yet?
         9            MS. REPORTER:  No.
        10            MR. TAYLOR:  Want to take another real short
        11     break?
        12                        (Brief recess.)
        13                        (Exhibit marked and tendered to
        14                         witness.)
        15     BY MR. TAYLOR:
        16   Q   Now, I've marked this is 304, which is
        17     another front-page article of the Tribune, this one
        18     Friday the 14th.  I take it you also would have seen
        19     this article around that time?
        20   A   I probably did, Mr. Taylor.
        21   Q   I want to call your attention to the
        22     fourth paragraph on the front page, and it says, "One
        23     expert says the seven-year-old, described by police
        24     as the aggressor in the slaying and the one who

                           


                                                                  150
         1     authorities say gave the most detailed statement
         2     implicating himself and his friend in the crime, has
         3     significant speech problems both in understanding and
         4     in articulation.  Dr. Louis Kraus also said the boy
         5     was virtually nonverbal unless his mother was present
         6     during the interview."  Do you remember learning that
         7     information?
         8   A   Yes.
         9   Q   I'm sorry?
        10   A   From the newspaper, yes.
        11   Q   Okay.  Now, given the fact that the
        12     statement by Allen in the article on the 12th about
        13     children can be made to say anything, and also the
        14     testimony here as recounted concerning the expert who
        15     said that the seven-year-old was virtually nonverbal
        16     unless his mother was present, did you at that point
        17     do anything to further investigate the circumstances
        18     of the statements that Zaborac and Brannigan had told
        19     you these children had made?
        20            MS. ROSEN:  Object to foundation.
        21            MR. CROWE:  Yeah.  I'll object to the form and
        22     as to the foundation as to why these particular
        23     articles should cause any kind of conduct
        24     unprofessional on a police professional's part.

                           


                                                                  151
         1                    But you may answer the question.
         2            THE WITNESS:  No, sir.
         3     BY MR. TAYLOR:
         4   Q   Did you make any effort to get any of
         5     the reports or testimony from the juvenile court
         6     to -- from the experts to determine whether, in fact,
         7     these children could have made the statements that
         8     the officers were saying they made?
         9   A   No, sir.
        10   Q   Okay.  Did you have any concern
        11     whatsoever with regard to the statements as a result
        12     of any of the testimony in court or any of the
        13     newspaper articles on any of the experts' statements
        14     about little children in general, and particularly
        15     these little children, with regard to giving
        16     statements?
        17   A   No, sir.
        18            MS. ROSEN:  Objection.  Compound, foundation.
        19                    Oh, now you're asking questions, too?
        20            MS. SUSLER:  I'm talking to my co-counsel, if
        21     you don't mind.
        22            MR. TAYLOR:  It's okay.  He answered.
        23            MS. ROSEN:  Well, I need to still make my
        24     objection.  So my objection is compound, foundation

                           


                                                                  152
         1     as to what the testimony was and as to how it's been
         2     recounted in the media.
         3            MR. CROWE:  And I will join in the objection
         4     and move that the answer be stricken.
         5     BY MR. TAYLOR:
         6   Q   Now, did you at any time -- other than
         7     what you were reading in the newspapers, did you
         8     receive any additional information from the time of
         9     the briefing on the 11th up and until you learned
        10     about the semen on the panties of Ryan Harris?
        11            MS. ROSEN:  Objection.  Form.
        12            MR. CROWE:  Join in the objection.
        13            THE WITNESS:  Can I answer?
        14            MS. ROSEN:  Yeah.
        15            THE WITNESS:  I think, as I remember, after
        16     reading everything in the newspaper, you know, Malone
        17     and I might have had a conversation about where we
        18     were at, you know, how were we doing on the
        19     investigation.
        20     BY MR. TAYLOR:
        21   Q   All right.  Did you at any time
        22     question whether the arrest and the prosecution of
        23     these children should go forward at any time after
        24     the 11th of August and before the semen was found on

                           


                                                                  153
         1     the panties?
         2   A   Well, the arrests had taken place and
         3     the prosecution was up to the state's attorney.  No,
         4     sir.
         5   Q   Okay.  So as the chief police officer
         6     of the City of Chicago, you made no effort to speak
         7     to the state's attorney as to stopping the
         8     prosecutions or asking them to reconsider the
         9     prosecutions that your officers had initiated; is
        10     that right?
        11            MR. CROWE:  Object to the form of the question
        12     and --
        13            MS. ROSEN:  Object to form.
        14            MR. CROWE:  -- the verbal negative nature and
        15     argumentative nature.
        16            MS. ROSEN:  Foundation, as to -- object to the
        17     officers initiated the prosecution.
        18            THE WITNESS:  No, sir.
        19     BY MR. TAYLOR:
        20   Q   Okay.  Now, you say you had a
        21     conversation with Malone sometime in August after
        22     these newspaper articles --
        23   A   Um-hum.
        24   Q   -- is that right?

                           


                                                                  154
         1   A   Yes, sir.
         2   Q   What was the substance of your
         3     conversation with Malone?
         4   A   Just asked him how were we doing on
         5     the case.
         6   Q   Did you have any -- did you ask him
         7     any specific questions that these articles or that
         8     anything -- other information that you had raised in
         9     your mind concerning the propriety of the arrests or
        10     the prosecution?
        11   A   No, sir.
        12   Q   What did Malone tell you when you
        13     asked him how are we doing?
        14   A   From what I remember, Mike said we was
        15     doing okay, you know, that our detectives were still
        16     confident that we had the right individuals.
        17   Q   All right.  Did he tell you why they
        18     were confident?
        19   A   No.
        20   Q   Did you ask him why they were --
        21   A   No.
        22   Q   -- still confident?
        23   A   No, no.
        24   Q   Was this at one of the briefings in

                           


                                                                  155
         1     August subsequent to --
         2   A   No, this was just with Malone and I.
         3   Q   And do you recall the circumstances of
         4     it in terms of where it was and when it was?
         5   A   Well, most likely it was probably in
         6     my office.
         7   Q   Was it -- how long after the briefing
         8     that Zaborac and Brannigan attended was this
         9     particular briefing?
        10   A   It was probably a week, week and a
        11     half later, you know, as I remember.
        12   Q   And did you have any other
        13     conversations with Malone in which you asked how
        14     things were going other than this one and putting it
        15     in a time frame between the 11th of August and the
        16     time that you discovered that the -- or you were
        17     informed that there were semen found on the panties?
        18   A   You know, I'm more than certain that
        19     Malone would give me a little update every now and
        20     then, you know, after I talked to him about asking
        21     him how we were doing.
        22   Q   Did Malone at any time tell you that
        23     the medical examiner's report said that the blow to
        24     Ryan Harris' head which caused her death could not

                           


                                                                  156
         1     have been caused by a thrown rock?
         2   A   I forget who told me that.  I don't
         3     know what specific person told me that, but later on
         4     down the line I found that out.
         5   Q   Was it before or after the charges
         6     were dropped against the children?
         7   A   It was after the charges were dropped.
         8   Q   Was it Lieutenant Cornfield who told
         9     you that?
        10   A   I said I don't know.  I forget who the
        11     specific person was who told me.
        12   Q   But you don't remember -- strike that.
        13                    You were not told that in the briefing
        14     on the 11th; is that right, by Zaborac or Brannigan
        15     or anyone else?
        16   A   No, sir, not that I remember.
        17   Q   Was that a significant piece of
        18     evidence in your mind when you were told that?
        19            MS. ROSEN:  Objection.  Form, foundation.
        20            MR. CROWE:  Object to the form of the
        21     question.
        22            THE WITNESS:  Can I ask you a question?
        23     Significant how?
        24     BY MR. TAYLOR:

                           


                                                                  157
         1   Q   Well, did it seem like it was an
         2     important piece of evidence to know?
         3            MR. CROWE:  I'm objecting to the question
         4     because charges had been dropped at that point.
         5            MR. TAYLOR:  Right.  I know when he said he
         6     learned it.  Right.
         7            MR. CROWE:  Do you understand his question?
         8     If you can, you can certainly answer it.
         9            THE WITNESS:  No, no, no.  I need you to --
        10     BY MR. TAYLOR:
        11   Q   Did it appear significant to you that
        12     the medical examiner's findings at the time were
        13     inconsistent with the statements of the boys with
        14     regard to how the head injury was caused to Ryan
        15     Harris?
        16            MS. ROSEN:  Objection.  Form, foundation as to
        17     the fact that it was inconsistent.
        18            THE WITNESS:  I don't know if it was
        19     significant.  You know, it was brought to my
        20     attention.
        21     BY MR. TAYLOR:
        22   Q   Well, it was brought to your
        23     attention?
        24   A   It was brought to my attention that

                           


                                                                  158
         1     the rock didn't cause the death.
         2   Q   Okay.  Wasn't that an important piece
         3     of information?
         4            MS. ROSEN:  Objection.  Form, foundation.
         5     Vague.
         6            THE WITNESS:  Important piece of information
         7     concerning the death of Ryan Harris?
         8     BY MR. TAYLOR:
         9   Q   Right.
        10   A   Yeah, I guess it was.  Yes.
        11   Q   Did you ever make inquiry as to why
        12     you weren't told that information when you were -- at
        13     the briefing on the 11th by Zaborac and Brannigan?
        14   A   No.
        15   Q   Now, did you ever make any inquiry as
        16     to why they didn't tell you that at any time?
        17   A   No, I didn't.
        18   Q   Now, did you learn either on the 10th
        19     from Malone or on the 11th from Brannigan or Zaborac
        20     that the children were being held in Hartgrove
        21     Psychiatric Hospital, a children's psychiatric
        22     hospital?
        23   A   You know, I don't know if that was
        24     told to me on the 10th or the 11th.  You know, I

                           


                                                                  159
         1     remember somebody was saying that, you know, they
         2     were going to try to get them into Hartgrove.
         3   Q   So did Malone tell you that on the
         4     9th, on the evening of the 9th?
         5   A   No, it couldn't have been on the 9th.
         6     The 9th was a Sunday.  Am I correct?
         7     BY MR. TAYLOR:
         8   Q   Um-hum.
         9   A   No, it might have been Monday.
        10   Q   Were you ever informed that -- did you
        11     know that there had to be consent for them to be
        12     placed in Hartgrove Hospital, consent of the parents?
        13            MS. ROSEN:  Objection.
        14            THE WITNESS:  No, I didn't know that.
        15     BY MR. TAYLOR:
        16   Q   Did you ever learn that, in fact,
        17     there was a misrepresentation made by the Youth
        18     officers, or at least one Youth officer, in the case
        19     to the parents that the children would be taken by
        20     DCFS if they didn't consent to them being placed in
        21     Hartgrove Hospital?  Did you ever hear that?
        22            MS. ROSEN:  Objection.  Foundation.
        23            MR. CROWE:  Object to the form of the
        24     question.  Assumes facts not in evidence.

                           


                                                                  160
         1            MR. TAYLOR:  No, it's admitted.
         2            MR. SHEEHAN:  Where?
         3            MS. ROSEN:  Objection.  Foundation.
         4            MR. TAYLOR:  Bowen.
         5            MS. ROSEN:  It is not admitted.
         6            MR. TAYLOR:  Bowen and Bartek.
         7            MS. ROSEN:  It is not admitted.
         8            MS. SUSLER:  Let's not argue about it.
         9            MS. ROSEN:  Well, I don't want him to
        10     represent to the superintendent that something is
        11     admitted when it's not admitted.
        12            MS. SUSLER:  You made your objection.
        13            THE WITNESS:  I didn't know that, Mr. Taylor.
        14     BY MR. TAYLOR:
        15   Q   If, in fact, a misrepresentation had
        16     been made to obtain consent in this case, would that
        17     be appropriate to be investigated internally?
        18            MR. CROWE:  Object to the form of the
        19     question.
        20            THE WITNESS:  If that was the case?
        21     BY MR. TAYLOR:
        22   Q   Yes.
        23   A   Yes, sir.
        24   Q   Has any such investigation been made

                           


                                                                  161
         1     at your behest?
         2   A   No, sir.
         3   Q   Do you know whether there has been
         4     such an investigation?
         5   A   I don't know.  This is the first time
         6     that I'm hearing about this.
         7   Q   But that would be misconduct if that
         8     were done, would it not --
         9            MR. CROWE:  Object to the form.
        10     BY MR. TAYLOR:
        11   Q   -- if, in fact, it happened?  If, in
        12     fact, it happened, it would be misconduct, wouldn't
        13     it?
        14            MR. CROWE:  Object to the form of the
        15     question.
        16            THE WITNESS:  Well, I don't know if it would
        17     be misconduct or it was a mistake or what.  I don't
        18     know.  I mean, I would have to wait until we make an
        19     investigation.
        20     BY MR. TAYLOR:
        21   Q   If it were intentionally done rather
        22     than a mistake, it would be misconduct; isn't that
        23     right?
        24            MS. ROSEN:  Objection.  Foundation.

                           


                                                                  162
         1            THE WITNESS:  Yes, sir.
         2     BY MR. TAYLOR:
         3   Q   Similarly, if, in fact, there were
         4     misrepresentations made in police reports about the
         5     circumstances of the questioning of these little
         6     boys, that would be misconduct as well, wouldn't it?
         7            MS. ROSEN:  Objection.  Foundation.
         8            MR. CROWE:  Object to the form of the
         9     question.
        10            THE WITNESS:  Yes, sir.
        11     BY MR. TAYLOR:
        12   Q   And have you -- at your behest has
        13     there been any investigation into whether there were
        14     any misrepresentations made by the detectives who
        15     investigated this Ryan Harris case as to the
        16     circumstances of the statements of the children in
        17     this case?
        18            MS. ROSEN:  Object to foundation.
        19            MR. CROWE:  Object to the form of the
        20     question.
        21            THE WITNESS:  Not at my behest.
        22     BY MR. TAYLOR:
        23   Q   Do you know whether there has been?
        24   A   No.

                           


                                                                  163
         1   Q   Now, at some point in August of '98
         2     did you have a meeting with Eugene Pincham and his
         3     associate, Andre Grant, about this case?
         4   A   I had a meeting with Eugene Pincham.
         5   Q   Do you remember whether Andre Grant
         6     was with him or not?
         7   A   As I remember, Andre Grant was not
         8     with him.
         9   Q   Okay.  Where was the meeting?
        10   A   It was held in the superintendent's
        11     office at 1121 South State Street, room 400.
        12   Q   Okay.  Was this sometime after the
        13     briefing but before the semen was found?
        14   A   I don't know the exact time line.  I
        15     don't remember the exact time line, you know.
        16   Q   Do you remember whether it was before
        17     the semen had been found on the body?
        18   A   I just said I don't know the exact
        19     time line.
        20   Q   Okay.  At whose request was this
        21     meeting?
        22   A   As I remember, it was Judge Pincham's,
        23     Eugene Pincham.
        24   Q   Did you know Judge Pincham prior to

                           


                                                                  164
         1     this?
         2   A   Yes, I did.
         3   Q   Had you had dealings with him?
         4   A   When you say, "dealings," what --
         5   Q   Well, let me ask you this.
         6            MR. CROWE:  Thank you.  I object to the form
         7     of the question.
         8     BY MR. TAYLOR:
         9   Q   Did you know of Mr. Pincham's
        10     reputation within the legal community?
        11   A   Yeah, I knew of his reputation within
        12     the legal community.
        13   Q   What was his reputation?
        14   A   That he was a former appellate court
        15     judge, a former circuit judge, you know.
        16   Q   And did you have respect for
        17     Mr. Pincham?
        18   A   Yes.
        19   Q   And when Mr. Pincham came, did he tell
        20     you what the content of the meeting that he wanted to
        21     have with you was?
        22   A   No.  He called me and I spoke to him
        23     and he asked if he could come down and talk to me.
        24   Q   All right.  And you agreed?

                           


                                                                  165
         1   A   Yes.
         2   Q   And when he came down, what did he
         3     talk to you about?
         4   A   Well, he came in and it started out
         5     mostly about my blackness, that I'm a black man, I
         6     was a black man before I was a police officer, before
         7     I was the superintendent, and that I needed to step
         8     up to the plate and do what was right.
         9                    And I told him not only am I a black
        10     man, I'm a man.  I'm a father, I'm a son, I'm a
        11     brother, and I'm a police officer, and I have done
        12     nothing wrong, and that I was -- I thought I was
        13     leading this department in the best way that I knew
        14     how.
        15                    He mentioned that these two little
        16     babies had been wronged, and me being a black man, I
        17     needed to step up to the plate and go forward and do
        18     what needed to be done.  We said a couple other
        19     things.
        20                    Mr. Pincham gave me, as I remember, a
        21     sealed envelope.  I took it, I thanked him.  He got
        22     up and he left and that was it.
        23   Q   All right.  So did he describe to you
        24     in any detail how he said these little babies had

                           


                                                                  166
         1     been wronged?
         2   A   No.  You know, this was an open
         3     investigation and at no time would I ever discuss an
         4     open investigation with anybody.
         5   Q   He has stated that at the end of the
         6     conversation he got up and you had tears in your
         7     eyes.  Is that an accurate representation by him?
         8   A   Well, I can truthfully say that I did
         9     not have tears in my eyes, you know.
        10   Q   You can or you can't?
        11   A   I can.  I can --
        12   Q   All right.
        13   A   -- as a 57-year-old black man, bar
        14     anything else, say I did not have tears in my eyes,
        15     you know.
        16   Q   Were you at all emotionally affected
        17     by what Mr. Pincham had to say?
        18   A   Emotionally?
        19   Q   Um-hum.
        20   A   Uh, I listened to him.  I listened to
        21     him as the superintendent of the Chicago Police
        22     Department.
        23   Q   Did he tell you what was in the
        24     envelope that was sealed?

                           


                                                                  167
         1   A   No, sir.
         2   Q   Was it one of these manila envelopes,
         3     a yellow envelope?
         4   A   It was, like, a -- those manila, those
         5     kind of brown manila envelopes, you know, that was
         6     sealed.
         7   Q   I thought I might have one here.
         8   A   Brown, white, one of them.  You know,
         9     one of the two.
        10   Q   Did you at some point review the
        11     materials that he gave you?
        12   A   No, I didn't.
        13   Q   Why?
        14   A   Because I have a habit since I've been
        15     superintendent that -- I'm given a number of sealed
        16     envelopes and sealed containers and I never, never
        17     open them.
        18                    They have confidential, secret,
        19     personal, and I take it out and I give to a staff
        20     member.
        21   Q   And who did you give this particular
        22     envelope to?
        23   A   I went out and I don't remember if I
        24     gave it to Commander Mahnke or I gave it to one of my

                           


                                                                  168
         1     -- one of the secretaries out there.
         2   Q   Did they ever report back to you on
         3     what the content of the envelope was?
         4   A   No.
         5   Q   Did Pincham tell you that it contained
         6     police reports and other reports having to do with
         7     this case?
         8   A   No, never.
         9   Q   So you -- he did not describe to you
        10     what it was that he wanted you to look at beyond
        11     saying, here, take this envelope?
        12   A   Yeah.  Well, here's an envelope, you
        13     need to look at it.  And, like I said, I never review
        14     any material that comes in a sealed envelope, sealed
        15     containers, anything like that.
        16                    I take it and I give it to my staff
        17     and they will forward it to the respective person who
        18     needs to look at that, you know.
        19   Q   Did you have an occasion to request of
        20     either Brannigan or Zaborac or Malone or anyone else
        21     any of the reports in this case?
        22   A   I don't remember requesting any
        23     reports, you know, right offhand.  It's a possibility
        24     that I saw some reports, you know.  But as far as

                           


                                                                  169
         1     requesting the reports from this case, I don't
         2     remember.  Maybe I did.  I -- you know, I can't say.
         3   Q   All right.  Did you ever see the crime
         4     photos in the case?
         5   A   The crime photos from the crime scene?
         6   Q   Um-hum.
         7   A   No, sir.
         8   Q   Did you ever request to see them?
         9   A   No, sir.
        10   Q   Did you ever see the medical
        11     examiner's report in this case?
        12   A   Not that I remember, no, sir.
        13   Q   Did you ever see the supplementary
        14     report that the detectives who questioned the little
        15     boys wrote in this case?
        16            MS. ROSEN:  Objection.  Foundation.
        17            THE WITNESS:  I can't say that I did, no.
        18     BY MR. TAYLOR:
        19   Q   Now, after Pincham left, did you make
        20     any effort to do anything to familiarize yourself
        21     further with any aspects of the case in order to
        22     determine whether Pincham was, in fact, right, that
        23     these little babies had been wrongfully treated by
        24     your department?

                           


                                                                  170
         1   A   Well, I think, as I remember, Malone
         2     and I, we might have had a conversation, saying,
         3     Mike, where are we with this, you know, with what's
         4     happening in the newspapers and Judge Pincham coming
         5     down.  Where are we.
         6                    He said we were -- he said detectives
         7     still stuck by their story, you know, stuck by what
         8     they did was proper and correct and lawful.
         9   Q   Okay.  Is this the same conversation
        10     with Malone that you told us earlier or is this a
        11     subsequent one?
        12   A   This was probably a different
        13     conversation that I had with him, you know.
        14   Q   Did Pincham suggest to you any other
        15     potential suspects in the case?
        16   A   No, sir.
        17   Q   Okay.  Did you ever make any calls to
        18     any -- to a Sergeant McMahon and ask him to check
        19     into someone who might be a suspect in the case?
        20   A   Sergeant McMahon?
        21   Q   Right.
        22   A   No, sir.
        23   Q   You don't remember that?
        24   A   No, I don't remember that.  No.

                           


                                                                  171
         1   Q   Okay.  Let me show you what I'm going
         2     to have marked as 305, I believe.  This is another
         3     front-page Chicago Tribune article, this one dated
         4     later on in the month of August, Sunday, August 30th.
         5     It's entitled, "How Cops Got Boys To Talk."
         6                        (Exhibit marked and tendered to
         7                         witness.)
         8                    Did you see that article around the
         9     time that it came out, Sunday, the 30th of August?
        10   A   I probably did.
        11   Q   This particular article details
        12     information in police reports, particularly the
        13     police report that documented the questioning of the
        14     little boys; isn't that right?
        15            MS. ROSEN:  Do you want him to read the
        16     whole --
        17     BY MR. TAYLOR:
        18   Q   Well, you can take a look at it and
        19     see if you agree with that interpretation of mine.
        20   A   Yes, that's what it says.
        21   Q   Okay.  Oh, by the way, let me go back
        22     a moment to the meeting, the briefing on the 11th.
        23                    Did Zaborac or Brannigan tell you
        24     whether they had at any point given any kind of

                           


                                                                  172
         1     Miranda warnings to either of the children that were
         2     being questioned?
         3   A   No, sir.
         4   Q   Did you ask?
         5   A   No, sir.
         6   Q   Did anyone else ask?
         7   A   Not that I remember.
         8   Q   Did you have any concern at that time
         9     that children of this young age might not understand
        10     what Miranda warnings were?
        11   A   It --
        12            MS. ROSEN:  Objection.  Form, foundation.
        13            THE WITNESS:  It didn't -- just didn't
        14     register to me.
        15     BY MR. TAYLOR:
        16   Q   Okay.  One way or the other?
        17   A   Yeah.
        18   Q   Okay.  Now, in reading this article, I
        19     want to call your attention to the bottom of the last
        20     column.
        21   A   Which page are you on?
        22   Q   I'm on the second page of the exhibit.
        23   A   The middle column?
        24   Q   No, the second to the last column.

                           


                                                                  173
         1     I'm sorry.
         2   A   Okay.
         3   Q   It says, "Police called Dr. Mitra
         4     Kalelkar, who performed the autopsy on Ryan, and she
         5     reported to them that a thrown rock would not have
         6     caused the skull fracture the girl suffered."  Do you
         7     see that in the article?
         8   A   Um-hum.
         9   Q   Do you remember having read that
        10     around the 30th of August?
        11   A   Maybe I did, you know.  I can't be
        12     positive, you know.
        13   Q   Would this be the first time that you
        14     had heard about this aspect of the medical examiner's
        15     report, that being that a thrown rock could not have
        16     caused the injury to Ryan Harris' head?
        17            MS. ROSEN:  Objection.  Form, foundation.
        18            MR. CROWE:  Object to the form of the
        19     question.
        20            THE WITNESS:  I have to ask a question.  Was
        21     this after the charges had been dropped against them?
        22     BY MR. TAYLOR:
        23   Q   This is a few days before.
        24   A   A few days before.

                           


                                                                  174
         1            MR. CROWE:  What's the question?  Did he see
         2     that paragraph?  Is that the question?
         3                        (Record read.)
         4            THE WITNESS:  I thought the first time that I
         5     had heard about it was after the charges had been
         6     dropped.
         7     BY MR. TAYLOR:
         8   Q   Okay.  Now, in this article it
         9     indicates that -- let me see if I can find it quickly
        10     here.
        11                    Did you learn from this article that
        12     the -- when the seven-year-old gave his statements to
        13     the police, that his grandmother was not present,
        14     neither his mother nor his grandmother was present?
        15   A   No, I didn't learn that from this
        16     article.  I didn't know anything about it.  I didn't
        17     know if they was present or not.
        18   Q   Did you ever learn that the
        19     grandparent or parents were not present when the
        20     seven-year-old gave his statement or is the first
        21     time you're learning that today when I'm mentioning
        22     it?
        23   A   I thought they were, you know -- that
        24     the grandparents was present.

                           


                                                                  175
         1   Q   By "present," I mean present in the
         2     room when he was giving the statement, not present in
         3     the building.
         4   A   From what I understand, they were
         5     outside the room, sitting right outside the room with
         6     the door open.
         7   Q   Did you understand that she was -- so
         8     then you did understand that she wasn't in the room
         9     where he was being questioned?
        10   A   Yes, sir.
        11   Q   You thought she was sitting outside
        12     the room somewhere?
        13   A   I thought she was sitting right
        14     outside the room.
        15   Q   By "right outside," you mean, like,
        16     within a couple of feet or something?
        17   A   Yes.
        18   Q   So you didn't know that, in fact,
        19     according to the police, she was sitting across the
        20     office in another room?
        21   A   No, sir.
        22   Q   Okay.  When I mentioned that to you
        23     now is the first time you've heard that?
        24   A   That she was sitting across the room

                           


                                                                  176
         1     in another room?
         2   Q   Right.
         3   A   Yes, sir.
         4   Q   Where did you learn the information
         5     that she was sitting right outside the door where the
         6     boy was being questioned?
         7   A   I think that was told to me probably
         8     by either Malone or the chief of detectives.
         9   Q   Okay.  Was this before or after semen
        10     was found on the panties?
        11   A   I believe it was after the semen was
        12     found.  That's when I got really a rundown.
        13   Q   Now, did you on or about the 3rd of
        14     September receive information from Malone that the
        15     crime lab, the Illinois state crime lab, had found
        16     semen on the panties of Ryan Harris?
        17   A   Yes, sir.
        18   Q   And was it Malone that told you that?
        19   A   Yes, sir.
        20   Q   And was it at a briefing or did he
        21     come, just come to your office and tell you?
        22   A   As I remember, he came to the office
        23     and told me.
        24   Q   Was that because it was a very

                           


                                                                  177
         1     significant piece of evidence?
         2            MS. ROSEN:  Objection.  Calls for speculation.
         3            THE WITNESS:  Yes, sir.
         4     BY MR. TAYLOR:
         5   Q   Okay.  Did you at that point -- you
         6     had mentioned earlier that you had had some
         7     information that there was some -- I think you said
         8     at the briefing that there was some testing being
         9     done.  Is that the way you said it?
        10   A   Analysis.
        11   Q   At the crime lab, right?
        12   A   Yes, sir.
        13   Q   But at that point they didn't tell you
        14     that the analysis that was being done or waiting to
        15     be done was the testing of the panties, did they?
        16   A   They didn't tell me what material was
        17     being tested.
        18   Q   Was Malone upset by this information?
        19   A   I don't know if he was upset.  He came
        20     and reported what he had found, you know.  As far as
        21     being upset, you know, you would have to ask him
        22     that.
        23   Q   When you got this information, what
        24     did you do with it?  Well, what did you do?  I

                           


                                                                  178
         1     shouldn't say "with it."  What did you do?
         2   A   I asked him what does this mean.
         3   Q   And what did he say?
         4   A   He said that there's a great
         5     possibility that young boys of this age could not
         6     deposit -- what is it -- semen or sperm or whatever
         7     it is.
         8   Q   Um-hum.
         9   A   You know, and that he was going to
        10     have me call the state's attorney and inform the
        11     state's attorney and hold a meeting.
        12   Q   I didn't hear the last thing.
        13   A   They would have to hold a meeting.
        14   Q   Hold a meeting to determine whether to
        15     drop the charges against the children?
        16   A   Yes, sir.
        17   Q   And did you and Malone discuss whether
        18     you thought it would be appropriate for the charges
        19     to be dropped at that time against the children?
        20   A   That was up to him, whoever he
        21     designated to go to the state's attorney's office and
        22     talk to the assistant state's attorney.
        23   Q   Okay.  Did you and he discuss what
        24     your view or position was with regard to whether the

                           


                                                                  179
         1     case should be dropped based on this significant new
         2     information?
         3            MS. ROSEN:  Objection.
         4            THE WITNESS:  No, we had to wait for the
         5     state's attorney.
         6     BY MR. TAYLOR:
         7   Q   Well, did you have a recommendation to
         8     the state's attorney as to whether the case should be
         9     dropped or not?
        10   A   No.  We waited for the state's
        11     attorney to give us some information, some advice on
        12     what needed to be done.
        13   Q   So, in other words, you didn't have a
        14     position as to whether the charges should be dropped
        15     based on this new evidence?
        16   A   That's the state's attorney's job.
        17   Q   Not yours.
        18   A   Right.
        19   Q   All right.  Did you have a personal
        20     opinion as to whether the charges should be dropped
        21     at that time or not?
        22            MR. CROWE:  Object to the form --
        23            THE WITNESS:  No.
        24            MR. CROWE:  -- of the question.

                           


                                                                  180
         1            THE WITNESS:  No, sir.
         2     BY MR. TAYLOR:
         3   Q   So you had no feeling one way or the
         4     other as to whether the arrest and prosecution of the
         5     children should continue or should be terminated; is
         6     that right?
         7            MR. CROWE:  Object to the form of the
         8     question.
         9            THE WITNESS:  That needed to be left up to the
        10     prosecutors, to the state's attorney.
        11     BY MR. TAYLOR:
        12   Q   Did you attend the meeting with the
        13     prosecutors?
        14   A   No, sir.
        15   Q   Do you know who did?
        16   A   No, no.
        17   Q   Either Malone or someone he designated
        18     from the police department attended the meeting?
        19   A   From the -- probably from the
        20     Detective Division.  Right.
        21   Q   Okay.  And when was that meeting held?
        22     Was it held the same day that you received the
        23     information about the semen?
        24            MR. CROWE:  I'm going to object to the

                           


                                                                  181
         1     question.  There is no way to show that he knew when
         2     the meeting was held.
         3            THE WITNESS:  You know, I don't know when it
         4     was held, but I know, you know, that they held a
         5     meeting and it was determined that the charges were
         6     going to be dropped.
         7     BY MR. TAYLOR:
         8   Q   Did someone inform you that the
         9     decision had been made that the charges would be
        10     dropped?
        11   A   Malone informed me.
        12   Q   Did he inform you the same day that he
        13     informed you that semen had been found on the
        14     panties?
        15   A   I don't remember the time line, you
        16     know.  I don't know if we got that information early
        17     in the morning or late in the afternoon, you know, so
        18     I couldn't say.  But he did inform me, you know.
        19   Q   Okay.  As a result of the information
        20     that you received that the charges were going to be
        21     dismissed, did you prepare a press release or have a
        22     press release prepared for your reading?
        23   A   As I remember, the press office did
        24     prepare a press release.

                           


                                                                  182
         1   Q   And do you know what position the
         2     police department either through Malone or someone
         3     from Area 2 -- Area 1 -- took at the meeting with the
         4     state's attorney as to whether the charges should be
         5     dropped?
         6   A   Well, I would assume that they took
         7     the same stance that the state's attorney did.
         8   Q   That they should have been dropped?
         9   A   Yeah, I would assume that.
        10   Q   Did you know that?
        11   A   Well, I don't know that.
        12   Q   Would that have been your position?
        13            MS. ROSEN:  Objection.  Asked and answered.
        14            MR. CROWE:  Object to the form of the
        15     question.
        16            THE WITNESS:  That's -- you go by what your
        17     lawyers tell you.  If the prosecutor said the charges
        18     need to be dropped, then you go with it.
        19     BY MR. TAYLOR:
        20   Q   Prior to learning that the semen had
        21     been found on the panties, at any time had you had
        22     any communication with the state's attorney's office
        23     with regard to this case?
        24   A   Not to my recollection, no.

                           


                                                                  183
         1   Q   Had you spoken with State's Attorney
         2     Devine at any time from the time that the children
         3     were arrested up and until the time that the semen
         4     was found on the panties?
         5   A   Not to my recollection.
         6   Q   Okay.  Do you know whether Deputy
         7     Superintendent Malone spoke with either Devine or one
         8     of his top assistants?
         9   A   I couldn't answer that for Deputy
        10     Malone.
        11   Q   Do you know Assistant State's Attorney
        12     Erickson?
        13   A   David Erickson?
        14   Q   Yes.
        15   A   Yes.
        16   Q   Did you have any communication with
        17     Erickson at any time from the time the children were
        18     arrested in this case until the semen was found on
        19     the panties?
        20   A   Not to my recollection.
        21   Q   And do you know Cathy Ryan?
        22   A   Yes.
        23   Q   And did you have any communication
        24     with Cathy Ryan about this case and specifically

                           


                                                                  184
         1     whether the charges should be dropped against these
         2     children?
         3   A   Did I?
         4   Q   Yes.
         5   A   No, not to my recollection.
         6   Q   Was her opinion or position with
         7     regard to whether these charges should be dropped or
         8     not ever communicated to you?
         9   A   No.
        10   Q   Now, the state's attorney did decide
        11     to drop the charges and they were dropped the next
        12     day; is that right?
        13   A   If that's the time line.
        14   Q   Okay.  Well, sometime very soon after
        15     the discovery the charges were dropped against the
        16     little boys, were they not?
        17   A   Yes, sir.
        18   Q   And you say that you -- that a news
        19     release was issued over your name; is that right?
        20   A   Yes, sir.
        21            MR. TAYLOR:  Okay.  Let's mark this as 306, I
        22     believe; is that right?
        23            MS. REPORTER:  Yes.
        24                        (Exhibit marked and tendered to

                           


                                                                  185
         1                         witness.)
         2     BY MR. TAYLOR:
         3   Q   Calling your attention to Plaintiffs'
         4     Exhibit 306, does this appear to be a press release
         5     dated the 4th of September of 1998 in which it is a
         6     statement of yourself concerning the Ryan Harris
         7     case?
         8   A   Yes, sir.
         9   Q   Did you hold a press conference either
        10     on behalf of the police department or together with
        11     the state's attorney's office on the 4th of September
        12     concerning a dismissal of the Ryan Harris charges?
        13   A   I don't know if this is the one from
        14     when I came downstairs right after this was -- a
        15     statement that I read, or this is one from the --
        16     with the state's attorney.
        17            MR. CROWE:  The date.
        18            THE WITNESS:  Yeah, I'm looking at the date.
        19     BY MR. TAYLOR:
        20   Q   Okay.  But this is a statement that
        21     you read; is that right?
        22   A   Yes, sir.
        23   Q   Is it a statement that you -- that you
        24     wrote?

                           


                                                                  186
         1   A   No, sir.
         2   Q   Someone wrote it for you?
         3   A   Yes, sir.
         4   Q   Who wrote it for you?
         5   A   Uh, the press office.
         6   Q   Camden?
         7   A   Probably Camden or one of his people
         8     back there in the press office.
         9   Q   Okay.  But it did articulate your
        10     position with regard to the recent developments in
        11     the Ryan Harris case; is that right?
        12   A   Yes, sir.
        13   Q   And did you discuss the content of the
        14     statement before he wrote it with him?
        15   A   Well, not necessarily so.  They write
        16     it and I read it.
        17   Q   You read it.  And if you agree with it
        18     when you read it --
        19   A   Yeah, yeah.
        20   Q   -- you give it publicly, and --
        21   A   Yeah.
        22   Q   -- if not, you make any changes that
        23     you feel appropriate; is that right?
        24   A   Yes, sir.

                           


                                                                  187
         1   Q   Now, in the second paragraph you state
         2     in this statement that you understood that children
         3     of the ages of the suspects, meaning the little boys
         4     in this case, would be incapable of being the source
         5     of the semen; is that right?
         6   A   Yes, sir.
         7   Q   Was that the information that Malone
         8     had passed on to you?
         9   A   Yes, sir.
        10   Q   And you then say that this case has
        11     been extraordinary from its inception; is that right?
        12   A   Yes, sir.
        13   Q   And, I take it, you were referring
        14     there to the ages of the children, the notoriety that
        15     it was getting in the community and around the world,
        16     and the age of the victim and all those kinds of
        17     things.  Is that what made it an extraordinary case?
        18            MS. ROSEN:  Objection.  Form.
        19            THE WITNESS:  Yes, sir.
        20     BY MR. TAYLOR:
        21   Q   Is there anything else that I omitted
        22     that went into the fact that it was an extraordinary
        23     case from its inception?
        24            MR. CROWE:  Well, I'll object to the form of

                           


                                                                  188
         1     the question as it was a statement made back in
         2     September 4th of '98.
         3                    There could have been a lot of things
         4     that went into it other than what you said, even
         5     though what you said is pretty good things to make it
         6     extraordinary.
         7            THE WITNESS:  That's it.
         8     BY MR. TAYLOR:
         9   Q   Anything else?
        10   A   No, sir.
        11   Q   Okay.  And then you say that it
        12     remains a tragedy within a tragedy.  Is one of the
        13     tragedies the senseless killing of a young girl?  Is
        14     that one of tragedies that's referred to --
        15   A   Yes, sir.
        16   Q   -- in this statement?  And is the
        17     other tragedy the fact that these little boys were
        18     arrested for it?
        19   A   Well, the other tragedy is that the
        20     pain and grief that that community had gone through,
        21     that these two young boys who had knowledge of
        22     something that happened, you know, around Ryan
        23     Harris' demise, and it's a tragedy that two young
        24     boys like this are being involved with something like

                           


                                                                  189
         1     this.
         2   Q   Okay.  So you were still at this point
         3     articulating that you felt that these boys were
         4     involved in the murder of Ryan Harris?
         5   A   They had, uh, certain information that
         6     we were not privy to.
         7   Q   So are you saying that you still felt
         8     that they were involved in the murder of Ryan Harris
         9     or that they had information about the murder of Ryan
        10     Harris?
        11   A   Well, there was certain facts that
        12     they had of only somebody who was intimately
        13     involved, you know, in the death of Ryan Harris.
        14   Q   Well, the police also had those facts,
        15     didn't they?
        16   A   Yes, sir.
        17   Q   And the media had those facts, too,
        18     didn't they?
        19            MS. ROSEN:  Objection.  Foundation.
        20            MR. CROWE:  Object to "the media."
        21            THE WITNESS:  I don't know what the media had.
        22     BY MR. TAYLOR:
        23   Q   But I want to be precise now.  Were
        24     you saying that the fact that these children,

                           


                                                                  190
         1     according to the police, had information that only
         2     they and people who were intimately involved with the
         3     case would have known, that led you to conclude that
         4     the children were involved in the murder; in other
         5     words --
         6            MR. CROWE:  Objection.
         7     BY MR. TAYLOR:
         8   Q   -- participated in the murder, or
         9     simply that they were witnesses --
        10            MR. CROWE:  Object to the form.
        11     BY MR. TAYLOR:
        12   Q   -- to the murder?
        13            MR. CROWE:  Object to the form of the question
        14     as asked and answered.
        15            THE WITNESS:  And the only thing that I can
        16     relate to you is what was told to me, that they had
        17     certain facts pertaining to this incident, you know.
        18     BY MR. TAYLOR:
        19   Q   Was it related to you that the facts
        20     that they had could have been obtained by someone who
        21     saw the body?
        22            MS. ROSEN:  Objection.  Foundation.
        23            MR. CROWE:  Join in the objection.
        24            THE WITNESS:  It's possible.

                           


                                                                  191
         1     BY MR. TAYLOR:
         2   Q   So it wasn't -- so there were more
         3     alternatives other than just that the children were
         4     intimately involved in some way in the murder in
         5     order to have this information, right?
         6            MR. CROWE:  Object to the form of the
         7     question.
         8            THE WITNESS:  Say that again now.
         9     BY MR. TAYLOR:
        10   Q   Well, the children could have gotten
        11     this information from questions asked to them by the
        12     police, couldn't they?
        13            MS. ROSEN:  Objection.  Foundation.
        14            MR. CROWE:  Join in that objection, and object
        15     to the form of the question.
        16            THE WITNESS:  Yes, sir.
        17     BY MR. TAYLOR:
        18   Q   And they also could have gotten this
        19     information from persons who had seen the body before
        20     the police came and recounted it to them.  That's
        21     another way; isn't that right?
        22            MS. ROSEN:  Objection.  Foundation.
        23            MR. CROWE:  Join in that objection.
        24            THE WITNESS:  Yes, sir.

                           


                                                                  192
         1     BY MR. TAYLOR:
         2   Q   And they could have gotten the
         3     information from having witnessed part of the crime;
         4     is that right?
         5            MS. ROSEN:  Objection.  Foundation.
         6            THE WITNESS:  Yes, sir.
         7     BY MR. TAYLOR:
         8   Q   And they also could have gotten the
         9     information by themselves having seen the body at
        10     some point after the girl had been killed; isn't that
        11     right?
        12            MS. ROSEN:  Objection.  Foundation.
        13            THE WITNESS:  Yes, sir.
        14     BY MR. TAYLOR:
        15   Q   Now, were these all possibilities that
        16     you considered when you made your statement about the
        17     children?
        18            MR. CROWE:  Object to that question because it
        19     certainly doesn't exclude all other possibilities.
        20            THE WITNESS:  Would you repeat that last one
        21     for me, ma'am?
        22                        (Record read.)
        23                    I don't know if, uh, all those were
        24     considered when we made the statement.

                           


                                                                  193
         1     BY MR. TAYLOR:
         2   Q   Okay.  Now, on the second page of this
         3     statement it says, "Allegations of misconduct on the
         4     part of the detectives have been made.  There has
         5     been no -- I repeat -- no misconduct," in bold, "on
         6     the part of any member of the Chicago Police
         7     Department, nor would I condone any such actions
         8     concerning this or any other case."
         9                    Now, you read that particular
        10     statement; is that right?
        11   A   Yes, sir.
        12   Q   And that was broadcast widely in the
        13     news media, right?
        14   A   Yes, sir.
        15   Q   On what did you base your conclusion
        16     that no misconduct had been -- there had been no
        17     misconduct on the part of any member of the Chicago
        18     Police Department?
        19   A   No allegations of misconduct was
        20     brought to me by anybody about these detectives.
        21   Q   Well, Mr. Pincham had brought you some
        22     allegations, hadn't he?
        23            MS. ROSEN:  Objection.  Foundation.
        24            MR. CROWE:  Join in that objection.

                           


                                                                  194
         1            THE WITNESS:  I'm telling you the conversation
         2     I had with Mr. Pincham --
         3     BY MR. TAYLOR:
         4   Q   Right.
         5   A   -- and Mr. Pincham did not bring me
         6     allegations.
         7   Q   Well, he told you -- he gave some
         8     evidence he said supported the fact that your
         9     officers had treated these babies wrong; isn't that
        10     right?
        11            MS. ROSEN:  Objection.  Foundation.
        12            THE WITNESS:  Mr. Pincham gave me an envelope,
        13     a sealed envelope, which I have no idea what was in
        14     it.
        15                    You said there was police reports.
        16     Police reports are reviewed and audited by the
        17     commanding officer and by the supervisor.  If there
        18     had been misconduct, it was incumbent upon the
        19     sergeant, the lieutenant, or the commander, those
        20     deputy chiefs, to initiate a complaint register
        21     number.
        22     BY MR. TAYLOR:
        23   Q   Well, at the time that Malone came and
        24     told you about the semen being found on the panties,

                           


                                                                  195
         1     did you have any discussion about why this took the
         2     period of time it took to come to make this finding?
         3                    In other words, we're now almost six
         4     weeks from the finding of the body before the semen
         5     is found.  Did you have any discussion with him about
         6     that?
         7   A   Mr. Taylor, I don't think I need to
         8     ask Deputy Superintendent Malone that.  We should ask
         9     the forensic lab from the Illinois state police
        10     because they are the ones who analyze and do those
        11     tests, not the police department.  We don't have a
        12     lab.  That's the Illinois state police lab.
        13   Q   But shouldn't you have also looked
        14     into what, if any, role the police department had in
        15     the failure of that testing?
        16            MS. ROSEN:  Objection.  Form, foundation as to
        17     a failure to do any testing.  The testing was
        18     complete.
        19            MR. CROWE:  Object to -- join in that
        20     objection.
        21     BY MR. TAYLOR:
        22   Q   A failure to do it in a more timely
        23     fashion.
        24            MS. ROSEN:  Objection.  Form, foundation.

                           


                                                                  196
         1     There's nothing in the record to indicate that it
         2     wasn't done in a timely fashion.
         3            MR. CROWE:  Join in that objection.
         4            THE WITNESS:  You know, as I said before, the
         5     police department does no testing on -- when it come
         6     down to things such as this.  That goes to the
         7     forensic lab, over to the Illinois state police, and
         8     it's incumbent upon them to answer that question.
         9     BY MR. TAYLOR:
        10   Q   Well, you were familiar with the fact
        11     that the police department was the one who would
        12     gather the evidence; isn't that right?
        13   A   Um-hum.
        14   Q   Yes?
        15   A   Yes, sir.
        16   Q   And they would be the ones who would
        17     also make the evidence available to the crime lab,
        18     right?
        19   A   Yes, sir.
        20   Q   And they would also then make requests
        21     of the crime lab in terms of what tests should be
        22     done --
        23   A   Yes, sir.
        24   Q   -- isn't that right?

                           


                                                                  197
         1   A   Yes, sir.
         2   Q   And they also could make requests to
         3     have certain evidence tested in a more expedited
         4     manner; in other words, ask for rush testing on
         5     certain evidence; isn't that right?
         6   A   Yes, sir.
         7   Q   So those were -- and they also could
         8     make an inquiry if, in fact, testing was not being
         9     done in a timely manner to request of the persons who
        10     were doing the testing to do that testing in a more
        11     timely manner, couldn't they?
        12   A   Yes, sir.
        13   Q   Now, did you make any inquiry to find
        14     out whether the police department had done any of
        15     those things with regard to the panties?
        16   A   Did I make any inquiries?  No, sir.
        17   Q   Did you cause any investigation,
        18     internal investigation, to be done to find out what,
        19     if any, role the police department had in the fact
        20     that the finding of semen on the panties was six
        21     weeks after the killing of Ryan Harris?
        22            MS. ROSEN:  Objection.  Foundation.
        23            THE WITNESS:  From what I understand is that
        24     this went through the process, "this" being -- and

                           


                                                                  198
         1     you said it earlier, a heater case, a high-profile
         2     case.  Those cases, the majority of the time, take
         3     precedence over other cases, and that analysis went
         4     forward.
         5                    Now, how long it takes them to analyze
         6     and evaluate evidence over at the Illinois state
         7     police crime lab, I have no idea.
         8     BY MR. TAYLOR:
         9   Q   Now, in making your statement that
        10     there no misconduct on the part of any member of the
        11     Chicago Police Department, that there was none, had
        12     you at that time seen any reports that indicated how
        13     the questioning took place?
        14   A   Had I seen --
        15   Q   Yes.  Had you seen the supplementary
        16     report, any of the GPRs, any of the evidence,
        17     documentary evidence, in the case with regard to the
        18     questioning of the children?
        19   A   I don't know if that would be in a GPR
        20     or a supplementary, no.
        21   Q   But you hadn't seen them in any
        22     regard, had you?
        23   A   No.
        24   Q   And had you talked to any of the

                           


                                                                  199
         1     detectives or seen any investigation with regard to
         2     whether -- the circumstances of the questioning of
         3     the children?
         4   A   No, sir.
         5   Q   For instance, did you know at that
         6     time whether the grandmother had not been permitted
         7     to be present in the room when the child was
         8     questioned?
         9            MS. ROSEN:  Objection.  Foundation.
        10            MR. CROWE:  Object to the form of the
        11     question.
        12            THE WITNESS:  I think you informed me of that
        13     about 30 minutes ago.
        14     BY MR. TAYLOR:
        15   Q   So what, if any, investigation did you
        16     do prior to making the statement that you did on the
        17     4th of September that no misconduct on the part of
        18     any member of the Chicago Police Department had
        19     occurred?
        20   A   I did no investigation.  Those
        21     sergeants, lieutenants, and the commander and deputy
        22     chief, chief of detectives, and deputy superintendent
        23     of the Bureau of Investigative Services, that was
        24     incumbent upon them.

                           


                                                                  200
         1                    If they found there had been
         2     misconduct, they would have informed me.  I was not
         3     informed that there was any misconduct.
         4   Q   Was there, to your knowledge, any
         5     internal investigation by the IAD that was underway
         6     with regard to any of the actions of the police or
         7     the police department in this case?
         8   A   I'm not aware of it.  It's a
         9     possibility that an internal investigation could have
        10     been initiated, but I don't get informed of all the
        11     complaint register numbers that's initiated in the
        12     Chicago Police Department.
        13   Q   Did you make any attempt to find out
        14     in this very extraordinary case whether there had
        15     been any investigation, internal investigation, about
        16     any misconduct before making the statement that there
        17     was none?
        18            MR. CROWE:  Object to the form.
        19            MS. ROSEN:  Objection.  Form.
        20            THE WITNESS:  No, because I would like to
        21     reiterate that I don't micromanage.  This is a
        22     department of 13,500 police officers, you know, and
        23     for me to micromanage -- doing my job is hard enough.
        24                    To try and do all of those folks' jobs

                           


                                                                  201
         1     who are subordinate to me, who come under me, you
         2     know, it would be impossible.  That's the reason that
         3     I give them the jobs and they are supposed to do it.
         4     BY MR. TAYLOR:
         5   Q   Okay.  Did you within a day or two of
         6     issuing this statement go to Area 1 and request a
         7     meeting with the detectives who had taken the
         8     statements from the children?
         9   A   No.  I went to Area 1 not to meet the
        10     detectives who had taken the statements from the
        11     children, but I went to talk to all the detectives in
        12     Area 1.
        13   Q   And?
        14   A   And to tell them that they still had
        15     my support, that I thought they were one hell of a
        16     group of detectives.  And I not only do this -- I did
        17     that for those detectives.
        18                    I go around the city and talk to our
        19     police officers and tell them what I think about
        20     them, how I think they're doing, you know, and that
        21     you cannot really let what's being said in the media
        22     really get you down.  You got to continue to do your
        23     job, continue to do your mission, carry out your
        24     mission and your task.

                           


                                                                  202
         1                    So by me going out and talking to
         2     those detectives, that was something that I do on a
         3     regular basis since I've been superintendent of
         4     police.
         5   Q   But you did it, talked to them, in
         6     light of the dismissal of the case that they had
         7     brought and the arrests that they had made in this
         8     case; isn't that right?
         9            MS. ROSEN:  Objection.  Form.
        10            MR. CROWE:  Object to the form of the
        11     question.
        12            THE WITNESS:  No, I did it to go out there and
        13     tell them you still got the support of the Chicago
        14     Police Department and the superintendent of the
        15     Chicago Police Department.
        16                    When you make a -- you just have to
        17     understand that's my makeup.  That's the way I
        18     operate, going out and talking to these detectives
        19     and police officers on a regular basis.  I do that.
        20     This wasn't in light of this case being dropped
        21     against the two boys.  I would have done it anyway.
        22     BY MR. TAYLOR:
        23   Q   But you went the next day after the
        24     case was dropped, wasn't it?

                           


                                                                  203
         1   A   I assume it was.
         2   Q   Okay.  And Brannigan and Zaborac were
         3     at the meeting, right?
         4   A   I believe they were.
         5   Q   And the detectives who took the
         6     statements from the children were also there, weren't
         7     they?
         8   A   I think it were probably a good 13 or
         9     14 detectives at the meeting.
        10   Q   And you had requested that the
        11     detectives who had been involved in the Ryan Harris
        12     investigation and the arrest of the children be there
        13     so you could speak to them, hadn't you?
        14   A   I requested all the detectives in Area
        15     1 who had worked on this case to be there so I could
        16     come and talk to them.
        17   Q   And you wanted to then commend them
        18     for their work on the case, didn't you?
        19   A   Yes, I did.
        20   Q   And when you had them all in the room,
        21     you didn't ask them any questions about any of the
        22     details of the investigation, did you?
        23   A   No, sir.
        24   Q   Specifically, you didn't ask the ones

                           


                                                                  204
         1     who took the statements any details about whether the
         2     methods they used in taking the statements were
         3     appropriate or not, did you?
         4            MR. CROWE:  Object to the form of the
         5     question.
         6            THE WITNESS:  No, sir.
         7     BY MR. TAYLOR:
         8   Q   And you didn't ask them anything about
         9     the semen evidence and why -- what the circumstances
        10     were of getting the semen evidence to the crime lab,
        11     did you?
        12   A   No, sir.
        13   Q   Could you tell me exactly what you
        14     said to them.
        15   A   Well, the best of my recollection, I
        16     said what I normally say to our police officers, you
        17     know, that they do a very stressful, very dangerous
        18     job.
        19                    A lot of time their job goes -- it's
        20     not rewarding and people -- they don't get enough
        21     thanks for it, that they should be proud to be
        22     Chicago police officers, and that with all the
        23     criticism and all the hits, negative hits, that we
        24     take from the news media, whether it be print, radio,

                           


                                                                  205
         1     or TV, that they have a task, they have a sworn oath
         2     that they must uphold, you know, and you got to
         3     continue to do your job.
         4                    Do your job, be professional, be fair,
         5     and be constitutional and right, you know, and try
         6     and treat people with dignity and with respect.
         7   Q   Now, after the charges were dropped --
         8     let's look again at the plaintiffs' exhibit that has
         9     the statements.
        10   A   Which --
        11   Q   I forget what the number is on it, but
        12     it has to do with the TV statements.
        13   A   301?
        14   Q   301.  Thank you.  I want to look now
        15     at statements that are attributed to you on the 4th
        16     of September.
        17                    It says -- it has you saying that --
        18     this is WMAQ on page 1.  "We have to go where the
        19     facts take you.  The facts took us to these young
        20     boys and it still does.  What is to say that they are
        21     wrong?"  Did you make that statement?
        22   A   I guess I did.
        23   Q   Okay.  Then it says that Hillard
        24     continues, "Well, you know, there is semen in the

                           


                                                                  206
         1     underwear, but that does not mean that these two
         2     young men were not involved."  Did you make that
         3     statement as well?
         4   A   Yes, sir.
         5   Q   Getting back to what you meant here by
         6     "involved," did you mean that they were -- that you
         7     were saying that they still were -- you still felt
         8     they were involved in the murder itself?
         9   A   Well, going back to what my two
        10     sergeants tell us, that the facts that these young
        11     boys knew pertaining to this incident, that they had
        12     to know something other than, uh -- because they were
        13     around the body, around Ryan Harris, when she was
        14     killed or after she was killed.  They had to know
        15     something.
        16   Q   Okay.  But what I'm asking you is are
        17     you saying that they were -- there's a difference
        18     between being a witness to something and being
        19     involved in the commission of a crime; isn't that
        20     right?
        21   A   That's true.
        22   Q   All right.  You and I could be sitting
        23     here and Mr. Sheehan could kill Ms. Rosen and we
        24     might know things that others might not know about

                           


                                                                  207
         1     that, but we wouldn't be involved in that crime,
         2     would we?
         3   A   That's true.
         4   Q   So what I'm asking you is when you
         5     used this term that these young men were -- meaning
         6     these kids, you still thought they were involved, did
         7     you mean it still meant they were involved in the
         8     actual murder or that they knew things?
         9                    Were you simply trying to say that
        10     they may have known things about the murder and were
        11     witnesses to the murder or witnesses to the body
        12     after the murder?  Do you --
        13            MS. ROSEN:  Objection.
        14     BY MR. TAYLOR:
        15   Q   -- understand what I'm asking you?
        16            MS. ROSEN:  Objection.  Form.
        17            THE WITNESS:  Yeah, I understand.
        18     BY MR. TAYLOR:
        19   Q   Which would it be?
        20            MS. ROSEN:  Objection.  Form.
        21            MR. CROWE:  I object to form, too, that it had
        22     to be one or the other.
        23            THE WITNESS:  At this particular time I wish I
        24     could say.  You know, I just don't remember at this

                           


                                                                  208
         1     particular time.
         2     BY MR. TAYLOR:
         3   Q   All right.  But you would agree with
         4     me there's quite a bit of difference in saying that
         5     someone is involved in a murder and saying someone is
         6     a witness to a murder; isn't that right?
         7   A   Yes.
         8   Q   But you can't tell me which you meant?
         9     As you sit here now, you can't tell me which you
        10     meant?
        11            MS. ROSEN:  Objection.  Form, asked and
        12     answered.
        13            THE WITNESS:  Not at this particular time, no,
        14     sir.
        15     BY MR. TAYLOR:
        16   Q   Now, the next page has a quote from
        17     the 9th of September at 4:30 p.m., which is, again,
        18     from WMAQ, and it says, "Commentator:  'Last week
        19     Terry Hillard said that the evidence still leads to
        20     the two young boys.  This week he's saying nothing.
        21     Reporters caught up with Hillard when he was locked
        22     out of his car.'"
        23                    There is a quote from you, "When I get
        24     something, I'll give it to you, you know.  I don't

                           


                                                                  209
         1     have anything right now."  Do you remember that
         2     particular report?
         3   A   Yeah, vaguely.  Yes.
         4   Q   Okay.  And, again, they're saying here
         5     that you said that the evidence still leads to the
         6     two young boys.  Now, that's based on your statement
         7     on the 4th, right?
         8            MS. ROSEN:  Objection.  Form --
         9            MR. CROWE:  I'll object to --
        10            MS. ROSEN:  -- foundation.  Calls for
        11     speculation as to what the commentator meant.
        12            MR. CROWE:  Plus, this is the commentator
        13     saying that.
        14     BY MR. TAYLOR:
        15   Q   Was it your view even after the case
        16     was dismissed against the kids that the evidence
        17     still led to them?
        18   A   Well, it was our view, the Chicago
        19     Police Department's view, that these two young boys
        20     still had intimate knowledge on what happened to Ryan
        21     Harris.
        22   Q   So, again, we're at the point of
        23     whether it was witness knowledge or participant
        24     knowledge, right?

                           


                                                                  210
         1   A   And that's something that --
         2   Q   You don't know at this point?
         3   A   Don't know.  Yeah.
         4   Q   So did you consider the boys to still
         5     be suspects in the case after the case was dismissed
         6     against them?
         7   A   Well, whether I considered it, it was
         8     up to the Detective Division to consider it, and they
         9     was the ones that was investigating it.
        10   Q   Did you understand them to consider
        11     the children to still be suspects or to be possible
        12     witness or what?
        13   A   Well, uh, I guess with the semen there
        14     was no longer -- they were no longer suspects.
        15   Q   So the Detective Division considered
        16     them to be potential witnesses at that point, not
        17     suspects; is that right?
        18            MR. CROWE:  Object to the form of that
        19     question.
        20            MS. ROSEN:  Objection.  Form.
        21            MR. CROWE:  He doesn't know.
        22            THE WITNESS:  I don't know.
        23     BY MR. TAYLOR:
        24   Q   Well, did you ever find out from them?

                           


                                                                  211
         1   A   No, I didn't.
         2   Q   Now, did you at some point just
         3     subsequent to the dismissal of the case have an
         4     occasion to make a request of Sergeant Ridges to
         5     obtain the file in the Ryan Harris case?
         6   A   As I remember, I asked, uh -- I asked
         7     either Ivanjack or Malone to ask Ridges to look at
         8     it.
         9   Q   Did Ridges get you certain parts of
        10     the file?
        11   A   He didn't get me -- I don't remember
        12     him getting me certain parts of the file.  I think I
        13     asked him to look at it.
        14   Q   You asked who to look at it?
        15   A   Sergeant Ridges.
        16   Q   So you asked Ridges to look at it for
        17     you?
        18   A   Yes.
        19   Q   So he didn't then get you the file
        20     himself.  He looked at it for you; is that right?
        21   A   That's how I remember it, you know.
        22   Q   What did you ask him to look at the
        23     file for?
        24   A   Well, Jack Ridges, when it came down

                           


                                                                  212
         1     to serial killers and when it came down to
         2     investigating patterns of homicides, he's a very good
         3     homicide detective, and he had a very small, very
         4     capable, competent group down in the chief of
         5     detectives' headquarters that was very good.  Let a
         6     fresh set of eyes look at it.
         7   Q   So you were asking Ridges to look at
         8     it to see if there were any patterns that it would
         9     fit into in terms of homicides and sexual assaults
        10     and --
        11   A   No, I just asked him to look at the
        12     file, him and his folks to look at it, you know.  I
        13     think that was through Malone or through Ivanjack
        14     that we asked him to do that.
        15   Q   And did he do that for you?
        16   A   I believe he did.
        17   Q   And what did he -- did you get any
        18     report back on --
        19   A   No.
        20   Q   -- what his investigation led to?
        21   A   No, no.
        22   Q   Was it about this time that you
        23     started to learn that there was a suspect in the case
        24     by the name of Floyd Durr?

                           


                                                                  213
         1   A   Probably not too long after that.
         2   Q   And who informed you of that?
         3   A   More than likely it would probably
         4     have been Malone, maybe Ivanjack.  One of the two.
         5   Q   Were you informed that there was a
         6     task force looking into the -- investigating to find
         7     out who committed the crime after the case was
         8     dismissed against the children?
         9   A   Yes, sir.
        10   Q   Were you also informed they had
        11     arrived at Durr through DNA testing and admissions
        12     that he had made, among other things?
        13   A   Yes, sir.
        14   Q   Did you also learn that there was
        15     evidence in the case that witnesses had seen him with
        16     Ryan Harris in the evening hours just prior to --
        17     well, in the evening hours of the 27th, the day she
        18     disappeared?
        19   A   Yes, sir.
        20   Q   And did you learn that at least one of
        21     those witnesses had picked Durr out of a lineup?
        22   A   Picked her out of a lineup?
        23   Q   Picked Durr out of a lineup.  I'm
        24     sorry.  Floyd Durr.

                           


                                                                  214
         1   A   I believe that was brought to my
         2     attention.
         3   Q   And was it also brought to your
         4     attention that Durr's DNA connected him to a series
         5     of previous sexual assaults and physical assaults of
         6     young girls in the Englewood area?
         7            MS. ROSEN:  Objection.  Form.
         8            THE WITNESS:  Yes, sir.
         9     BY MR. TAYLOR:
        10   Q   And did you at any point have an
        11     occasion to determine why Durr had not been
        12     previously identified as a suspect in the Ryan Harris
        13     case?  Have you ever had occasion to do any
        14     investigation in that regard?
        15   A   Well, I didn't do an investigation.
        16     But from what I was told, that he was not a convicted
        17     sex offender and his DNA was not in the data, in the
        18     state's database.
        19   Q   Do you know whether any patterns were
        20     developed with regard to Durr's crimes prior to the
        21     murder of Ryan Harris?
        22   A   No, I don't know that specifically.
        23   Q   Did you know that, in fact, Durr had
        24     been connected to a pattern of assaults against young

                           


                                                                  215
         1     girls in Englewood prior to the murder of Ryan
         2     Harris?
         3   A   I don't --
         4            MS. ROSEN:  Objection.  Foundation.
         5            THE WITNESS:  I don't know that for a fact
         6     either.
         7     BY MR. TAYLOR:
         8   Q   Have you ever heard that?  Have you
         9     seen that in the paper?
        10   A   No.
        11   Q   Did you sometime in November of '98
        12     have an occasion to meet with the state's attorney
        13     about charging Floyd Durr with the Ryan Harris
        14     murder?
        15   A   I remember that, yes, sir.
        16   Q   Was that after the task force had
        17     informed you with information which led you to
        18     conclude that Durr had, in fact, committed the murder
        19     and sexual assault of Ryan Harris?
        20            MR. CROWE:  Object to the form of the
        21     question.
        22            MS. ROSEN:  Foundation.
        23            MR. CROWE:  And foundation.
        24            THE WITNESS:  No, I think they stated that the

                           


                                                                  216
         1     semen found on the panties was his DNA.
         2     BY MR. TAYLOR:
         3   Q   But you've also stated that you were
         4     informed about other evidence that implicated him in
         5     the murder of Ryan Harris; is that right?
         6   A   With the semen, yes.
         7   Q   I'm saying over and above the semen.
         8   A   Like what?
         9   Q   Like the witnesses who saw him with
        10     Ryan Harris, the statement that he made, the -- the
        11     other things we mentioned; the pattern of similar
        12     crimes that he was implicated in, among other things.
        13   A   Yes, sir.
        14            MR. CROWE:  Well, I have to object to that.
        15     That's all he was informed of.
        16            MR. TAYLOR:  Pardon me?
        17            MR. CROWE:  I said that's all he was informed
        18     of.
        19            MR. TAYLOR:  According to his testimony?
        20            MR. CROWE:  Well, according to what you've
        21     asked him here.  That doesn't mean that Floyd Durr
        22     had committed the murder.
        23                    It just means that these are things
        24     that he became aware of.  You keep saying that he

                           


                                                                  217
         1     committed the murder.  That's the objection.
         2     BY MR. TAYLOR:
         3   Q   Well, what I'm asking you is you said
         4     at some point in November you met with the state's
         5     attorney's office concerning charging Floyd Durr with
         6     the murder of Ryan Harris; isn't that right?
         7   A   It was charging Floyd Durr with the
         8     murder of Ryan Harris and other -- some other cases,
         9     as I remember.
        10   Q   Okay.  And did you recommend to the
        11     state's attorney that he be charged at that time with
        12     the murder of Ryan Harris?
        13   A   I made no recommendation whatsoever.
        14   Q   Was this after your detectives and
        15     your task force had determined that, in their
        16     opinion, Floyd Durr should be charged with the murder
        17     of Ryan Harris?
        18            MS. ROSEN:  Objection.  Foundation.
        19            THE WITNESS:  As I remember, I think so.
        20     BY MR. TAYLOR:
        21   Q   And did you concur with your task
        22     force's determination that there was sufficient
        23     evidence to charge Floyd Durr with the murder and
        24     assault of Ryan Harris?

                           


                                                                  218
         1   A   Well, the detectives said it was his
         2     DNA and he had to be on the scene.
         3   Q   So you did concur then?
         4   A   We went forward with it.
         5   Q   Okay.  At first did -- did the state's
         6     attorney agree with you that Floyd Durr should be
         7     charged?
         8            MS. ROSEN:  Objection.  Foundation,
         9     mischaracterizes his testimony.
        10            THE WITNESS:  You know, we went over there and
        11     the state's attorney told us what they were going to
        12     do.
        13     BY MR. TAYLOR:
        14   Q   And what did they tell you they were
        15     going to do?
        16   A   That they were going to proceed with
        17     Floyd Durr and charge him with criminal sexual
        18     assault and a number of other things and charge him
        19     with the Ryan Harris homicide.
        20   Q   Did you say "and charge him" or "not
        21     charge him"?
        22   A   I believe they said "and charge him."
        23   Q   Okay.
        24            MR. CROWE:  I want to say at this point it's

                           


                                                                  219
         1     about 20 after 5:00.  It's my understanding that this
         2     was a four-hour dep.  I would think that a half hour
         3     past 5:00 would include all the breaks that we took
         4     in this case.
         5                    So I think at 5:30 I would think it
         6     reasonable to call a recess.  I just wanted to
         7     forewarn you so that you weren't taken by surprise.
         8     I mean, maybe you're done in the next five minutes.
         9     I don't know.
        10            MR. TAYLOR:  Okay.  Well, I'll certainly try
        11     to get as far as I can.  I'm not too far from being
        12     done, but I don't know if I can get done in ten
        13     minutes or not.
        14                    I'm sure you'll be reasonable in terms
        15     of a few minutes here with regard to the four-hour
        16     limit if we can finish it today, wouldn't you be?
        17                    Okay.  I'll mark this as Plaintiffs'
        18     Exhibit 307.
        19                        (Exhibit marked and tendered to
        20                         witness.)
        21     BY MR. TAYLOR:
        22   Q   Now, let me ask you.  Did you at some
        23     point after you became aware of the arrest of the
        24     little boys learn that Detectives Nathaniel and

                           


                                                                  220
         1     Cassidy were the detectives who had taken the
         2     statements of the little boys?
         3   A   I became aware of that somewhere down
         4     the line, yes.
         5   Q   And did you also become aware at any
         6     point that Detective Nathaniel had a record of some
         7     35 IAD complains against him prior to this case?
         8   A   No.
         9   Q   And were you aware that, in fact,
        10     Detective Nathaniel had previously had a case of
        11     perjury and false reports sustained against him and
        12     charges presented to the police board for his
        13     separation?
        14            MS. ROSEN:  Where he was exonerated.
        15     BY MR. TAYLOR:
        16   Q   Where he was exonerated because the
        17     witness against him did not appear.
        18            MS. ROSEN:  Objection.  Foundation.  There was
        19     no evidence in the record that the reason he was
        20     exonerated was because the witness against him did
        21     not appear.
        22            THE WITNESS:  No, I'm not familiar with that.
        23     No, sir.
        24     BY MR. TAYLOR:

                           


                                                                  221
         1   Q   Okay.  Did you on or about September
         2     10th of '98 see this front-page story of the Tribune
         3     entitled, "Officer In Harris Case Coaxed Similar
         4     Confession In '94"?
         5   A   I think -- I believe I remember seeing
         6     this.
         7   Q   Okay.  And you knew when you saw this
         8     article that this was the same detective who was
         9     involved in taking the statement from the
        10     seven-year-old and eight-year-old in the Ryan Harris
        11     case; isn't that right?
        12   A   Well, after reading it, yes.
        13   Q   Okay.  And you knew that in the '94
        14     case it was a similar confession, that time from a
        15     ten-year-old; isn't that right?
        16            MS. ROSEN:  Objection.  Foundation, the
        17     confessions being similar.
        18            MR. CROWE:  Join in the objection.
        19            THE WITNESS:  Yes, sir.
        20     BY MR. TAYLOR:
        21   Q   And did you take any action to have
        22     any investigation done with regard to the similar
        23     case -- I'm sorry -- the '94 case of the ten-year-old
        24     and Cassidy's involvement in taking that statement?

                           


                                                                  222
         1   A   No, I did not.
         2   Q   And did you inquire to see whether, in
         3     fact, any investigation had been done?
         4   A   No, I did not.
         5   Q   Do you know whether, in fact, any
         6     investigation was ever opened and whether -- with
         7     regard to Cassidy's involvement in that case?
         8   A   I couldn't say.  I don't know.
         9   Q   Now, in the next few weeks after the
        10     dismissal of the cases against the little children,
        11     did you move to change any of the procedures and
        12     practices within the police department with regard to
        13     dealing with juveniles?
        14   A   Well, I think not only did I.  The
        15     Chicago Police Department, we did.
        16   Q   Okay.  Did you make changes to assure
        17     that juveniles' rights would be better protected with
        18     regard to questioning?
        19   A   Yes, sir.
        20   Q   And what specific changes did you make
        21     within the department rules and regulations with
        22     regard to the questioning of juveniles a few weeks
        23     after the case was dropped against the children?
        24   A   To ensure that a parent or guardian

                           


                                                                  223
         1     was present during any questioning of a juvenile
         2     under 12, that that six-hour rule for seeking charges
         3     against juveniles would go up to 24 hours, that --
         4   Q   Did you say the hours were changed
         5     from six hours to 24 hours?
         6   A   24 hours, yes.
         7   Q   Is that a waiting period or --
         8   A   Well, it's the time that you have to
         9     go through the process, you know, go through the
        10     mechanism to make sure that we get things correctly.
        11   Q   Okay.
        12   A   Then we instituted what we called the
        13     videotaping rooms in all the five detective Areas for
        14     adults and juveniles.  When it come down to
        15     homicides, it will not only be videotaped, but
        16     audiotaped, ensuring that command staff, when it came
        17     down to juveniles under 12 years old, that a deputy
        18     chief of that respective Area, whether it be the
        19     Detective Division or Patrol Division, to oversee
        20     investigations of cases such as this; that we would
        21     institute the sexual offenders data files on the
        22     Internet and have a visitation program not only in
        23     the Patrol Division, but in the Detective Division,
        24     to go out and try and ascertain where these

                           


                                                                  224
         1     registered sex offenders reside and if they are in
         2     the proper location where they're supposed to be.  If
         3     not, issue a warrant for them and try to actively and
         4     progressively go out and try to arrest them.
         5   Q   Okay.  This was all in response to the
         6     Ryan Harris case?
         7   A   Well, this -- not only for the Ryan
         8     Harris case.  We still had a couple of other cases
         9     that preceded the Ryan Harris case; Yummy Sandifer,
        10     you know, the Eric Morse case.  So, you know --
        11   Q   So it was cumulative that you --
        12   A   -- we need to look and see what folks
        13     were doing not only across the country, but what
        14     other police departments were doing because
        15     everybody's struggling with this issue when it come
        16     down to younger offenders, you know.
        17   Q   All right.  But the real trigger to
        18     these substantive changes that you made was the Ryan
        19     Harris case.
        20   A   The real trigger to this was Yummy
        21     Sandifer, Eric Morse, and Ryan Harris all together.
        22   Q   But the other two cases you mentioned
        23     had happened several years before the Ryan Harris
        24     case, hadn't they?

                           


                                                                  225
         1   A   Yes, they did.
         2   Q   And did you also talk to State's
         3     Attorney Devine about having Felony Review of
         4     juvenile cases?
         5   A   Yes, I forgot that.  Felony Review,
         6     uh, will review all cases when it come down to
         7     juveniles, when it come down to cases such as this.
         8                    And State's Attorney Devine started a
         9     juvenile competency commission to look at the
        10     problems when it come down to youthful offenders such
        11     as this, the problems that we're having not only in
        12     this city, but across the state.
        13   Q   Now, did you recently request that
        14     there be a reopening of the IAD investigation into
        15     the arrests of the two children in this case?
        16   A   I didn't.  It was probably done at the
        17     behest probably of the IAD.
        18   Q   Okay.
        19   A   The ADS.
        20   Q   Do you know why they were reopened at
        21     this time?
        22   A   No, I don't.
        23   Q   Did you have any input into that?
        24   A   No, I didn't.

                           


                                                                  226
         1   Q   Do you know what the status of those
         2     reopened investigations are?
         3   A   No, I don't.
         4   Q   Now, at some point in early -- in
         5     April of 1999 you appeared at a press conference with
         6     State's Attorney Devine to announce the indictment of
         7     Floyd Durr for the murder and sexual assault of Ryan
         8     Harris; is that right?
         9   A   Yes, sir.
        10   Q   Okay.  Now, did you both make
        11     statements at that press conference?
        12   A   As I remember, yes, sir.
        13   Q   Now, do you recall that among the
        14     statements that Richard Devine made was that the
        15     little boys in this case never should have been
        16     charged with the offense?
        17   A   I would have to see the press release,
        18     you know.
        19   Q   You don't remember that?
        20   A   No.
        21   Q   Do you remember saying that there were
        22     mistakes made in the investigation?
        23            MS. ROSEN:  Objection.  Foundation.
        24            MR. CROWE:  Instead of referring to him, show

                           


                                                                  227
         1     him the statement if you have it.
         2     BY MR. TAYLOR:
         3   Q   Well, I was asking if you would
         4     remember that.
         5   A   I would have to see the press release,
         6     Mr. Taylor.
         7   Q   Okay.
         8   A   I have two or three press releases a
         9     week.  I just can't remember them all, I'm telling
        10     you.
        11   Q   Okay.  Let me see if I can find the
        12     direct statements here to call your attention to.
        13                        (Brief pause.)
        14                    Okay.  Here.  I want to mark this as
        15     Plaintiffs' 307.
        16            MS. ROSEN:  308.
        17            MR. TAYLOR:  Okay, 308.  Thank you.
        18                        (Exhibit marked and tendered to
        19                         witness.)
        20     BY MR. TAYLOR:
        21   Q   This is a Sun-Times article of Friday,
        22     April 3rd, '99, and it has a picture of you and
        23     Devine at the press conference; is that right?
        24   A   Um-hum, yes.

                           


                                                                  228
         1   Q   Now, I want to call your attention to
         2     the second column here of the article.  It says,
         3     "'Charges should have never been brought against the
         4     boys,' Devine said.  'I regret that they were and I
         5     regret the pain that has been caused to the boys and
         6     their families.'"
         7                    Do you remember Devine saying that?
         8   A   Yes, sir.
         9   Q   Did you agree with his statement?
        10   A   That was his statement.
        11   Q   Well, I'm asking you did you agree
        12     with it?
        13   A   Well, not in particular.
        14   Q   Okay.  Did you feel that the children
        15     should never have been charged?
        16   A   Well, I feel that the Chicago Police
        17     Department and detectives acted properly.  They went
        18     with the facts they had in seeking charges.
        19   Q   Okay.  Then -- so, I guess, in that
        20     sense you don't agree with Devine; is that right?
        21            MR. CROWE:  Asked and answered.
        22     BY MR. TAYLOR:
        23   Q   Is that right?
        24   A   Yes, I'm saying that's his statement.

                           


                                                                  229
         1   Q   Then it goes on to attribute to you,
         2     Chicago Police Superintendent Terry Hillard, the --
         3     there was a bungled investigation and you're saying
         4     there were errors made in the handling of this case.
         5     Now, did you say there were errors made in the
         6     handling of this case?
         7   A   Well, as far as "bungled
         8     investigation," that's the news media.
         9   Q   Right.  But --
        10   A   The news media said it was bungled.
        11     You know, talking about errors made in the handling
        12     of this case, mistakes made, you know, I have a very
        13     unique way of explaining it.
        14                    When police officers make legitimate
        15     mistakes, whether it be on the job or in their own --
        16     well, you know, there is counseling, correction, and
        17     discipline.  On the other hand, if they get involved
        18     in brutality, excessive force, corruption, then we
        19     come after them.
        20                    Errors made in the handling of this
        21     case, you know, it might be semantics, but these
        22     detectives did a very credible job.  They went by the
        23     letter of the law at that particular time and they
        24     went by the rules and regulations of the Chicago

                           


                                                                  230
         1     Police Department.
         2   Q   But you did say that there were errors
         3     made in the handling of the case, right?
         4   A   That's what I said, yes.
         5   Q   What errors were you referring to when
         6     you made that statement?
         7   A   Since I just read it, I didn't write
         8     it, it always comes back to me that errors in the
         9     sense that this is the first time that the Chicago
        10     Police Department ever handled a case such as this
        11     with such young individuals, you know.
        12                    We really -- as a department, as an
        13     agency, you know, this is a new frontier, not only
        14     for us, but for everyone else, the judicial system,
        15     to figure out how you handle kids such as this.
        16   Q   What specific errors were you
        17     referring to?
        18   A   Well, one of the things that I think
        19     we needed to do, you know, if we had had the 24-hour
        20     rule instead of the six-hour rule.  Errors in that
        21     sense.
        22   Q   Let me stop you there, if I might.
        23     The 24-hour rule would have allowed further
        24     investigation and looking into the case.  Is that

                           


                                                                  231
         1     what you're saying?
         2   A   Yes.
         3   Q   All right.
         4   A   The next thing is that I think that
         5     instead of waiting, I should have went and had video
         6     and audiotaping probably for five months before this
         7     case even went into being.  This was on my part so I
         8     could see what our detectives went through.
         9   Q   So then you would have a record as to
        10     whether these kids had given these statements and
        11     under what circumstances they had given them; is that
        12     right, if they had?
        13            MS. ROSEN:  Objection.  Foundation.
        14     BY MR. TAYLOR:
        15   Q   Well, let me ask this.  You had been
        16     contemplating having a video system prior to this
        17     case, but hadn't moved to implement it.  Is that what
        18     you're saying?
        19   A   Yes, sir.
        20   Q   That's why you moved so promptly
        21     afterwards, right?
        22   A   Not only this case, but the other two
        23     cases that I talked about.
        24   Q   What about other errors other than the

                           


                                                                  232
         1     ones you've told us?
         2   A   I think that was it.
         3   Q   Okay.  Those are the major things you
         4     were thinking about?
         5   A   Yes.
         6   Q   Now, it refers in this article, I
         7     believe that it says -- I'm sorry.  Give me a moment
         8     here.  In one of these articles it says that you and
         9     Devine apologize to the families.  Is that an
        10     accurate statement?
        11            MR. CROWE:  I'll object to that.  There was no
        12     such --
        13            MS. ROSEN:  Objection.  Foundation.
        14            MR. CROWE:  I think there's an article that
        15     they apologize to the family of the victim.
        16            THE WITNESS:  I don't think there is one that
        17     says that, Mr. Taylor.  Yeah.  I don't remember
        18     apologizing to the family.
        19     BY MR. TAYLOR:
        20   Q   Is that something you would have done
        21     if the occasion arose?
        22   A   Well, I said time and time again if
        23     there was evidence, if facts came forward that would
        24     completely exonerate these two young boys from having

                           


                                                                  233
         1     anything to do with Ryan Harris' death, I have no
         2     problem with apologizing.
         3   Q   Are you saying that you don't feel
         4     that there's evidence now that completely exonerates
         5     these children from participation in the Ryan Harris
         6     murder given all you know to this point?
         7   A   From what I know, from what my -- our
         8     Detective Division have not been able to interview
         9     these young boys anymore.
        10   Q   Okay.
        11   A   You know, this investigation is still
        12     not complete.
        13   Q   So if, in fact, statements were given
        14     by these young boys, at that point would you feel
        15     that the investigation was complete and that
        16     apologies could be made to the families?
        17            MR. CROWE:  Object to the form of the
        18     question.
        19            THE WITNESS:  Well, that would be up to my
        20     detectives to tell me that the investigation is
        21     complete, not Terry Hillard, because I'm not
        22     investigating.
        23                    It's those detectives who are on the
        24     front line who need to tell me, Superintendent, this

                           


                                                                  234
         1     investigation is complete and we need to go forward.
         2     BY MR. TAYLOR:
         3   Q   Did you during the pendency of this
         4     case have occasion to talk to Mayor Daley about it?
         5   A   Why would I talk to the mayor about
         6     it?  No, sir.
         7   Q   You never spoke to the mayor about it?
         8   A   No, sir.  There are certain things
         9     that the mayor needs to know and certain things that
        10     the mayor need not know, especially coming from the
        11     superintendent.  If he wants to know about it, all he
        12     has to do is to pick up the Tribune and the
        13     Sun-Times.
        14   Q   Let me ask you this.  Did you see the
        15     statement by him that he would apologize to the
        16     families of the children?
        17            MS. ROSEN:  Objection.  Foundation.
        18            MR. CROWE:  And I'll object to the form of the
        19     question.
        20            THE WITNESS:  Well, that's the mayor.
        21     BY MR. TAYLOR:
        22   Q   Did you agree or disagree with his
        23     offer of an apology?
        24            MS. ROSEN:  Objection.  Form, foundation.

                           


                                                                  235
         1            THE WITNESS:  It's not for me to agree or to
         2     disagree.  The man is my boss.  He does what he wants
         3     to do when it come down to this and I have to go the
         4     way that I have to go, you know.
         5     BY MR. TAYLOR:
         6   Q   Would you agree with me that the
         7     families and these little children have suffered a
         8     great deal from their arrests and being branded as
         9     some of the youngest murderers in the history of the
        10     city?
        11            MS. ROSEN:  Objection.  Foundation.
        12            MR. CROWE:  And I'll object to that, what he
        13     may know or may not know.  He's not a doctor or a
        14     psychiatrist.
        15                    Now you're in an area which you really
        16     don't need to go into and to which he is not
        17     competent to testify.
        18            THE WITNESS:  The only thing I can say is that
        19     if there is sufficient facts and evidence brought
        20     before our detectives and they bring it to me and
        21     tell me that these kids have never been involved in
        22     it, I've said before I have no qualms whatsoever
        23     about apologizing.  But it has to be clear and
        24     precise and clear evidence that they were not

                           


                                                                  236
         1     involved.
         2     BY MR. TAYLOR:
         3   Q   And have you requested of your
         4     detectives to bring you that evidence?
         5   A   Well, it's not up to me to request the
         6     detectives to bring me the evidence.  You need to
         7     talk to the young men, the young boys.
         8   Q   So if, in fact, the young boys give
         9     statements that convince you that they were not
        10     involved in this murder, you would then have no
        11     qualms about apologizing to their families?
        12   A   No.
        13            MR. CROWE:  Object to the form of the
        14     question.
        15            MS. ROSEN:  Objection.  Relevance.
        16            THE WITNESS:  When you say "statements," you
        17     know, giving a statement does not preclude you from,
        18     you know, saying that you weren't involved.
        19                    I think, Mr. Taylor, they need to talk
        20     to these young boys and to bring this to some type of
        21     closure.
        22     BY MR. TAYLOR:
        23   Q   Okay.  Would you find it sufficient if
        24     they were examined by your lawyers at a deposition?

                           


                                                                  237
         1            MR. CROWE:  I object to this.  I think -- it's
         2     now 20 minutes to 6:00, and I think you're harassing
         3     the witness at this point.
         4            THE WITNESS:  The lawyers aren't the
         5     detectives.  These folks over here are not the
         6     detectives.  They're like me.  They haven't had
         7     interrogation and interview techniques.
         8     BY MR. TAYLOR:
         9   Q   So unless your detectives are able to
        10     question the children again, you would not feel that
        11     they could be completely exonerated from involvement
        12     in the murder of Ryan Harris; is that right?
        13   A   I think not just for my sake, but for
        14     the sake of Ryan Harris' family, for the sake of the
        15     community of Englewood, for the sake of this city, we
        16     need to bring this to a close.
        17   Q   Do you think that the conviction of
        18     Floyd Durr and the imposition of the death penalty as
        19     being sought by the state's attorney would bring
        20     sufficient closure to the family of Ryan Harris as to
        21     who murdered her?
        22            MR. CROWE:  Object to the form of the
        23     question.  There's no way he could know.
        24            THE WITNESS:  From what I understand, Mr. Durr

                           


                                                                  238
         1     has not confessed to this crime.
         2     BY MR. TAYLOR:
         3   Q   Well, the Chicago Police Department
         4     doesn't get confessions in every case that they
         5     convict people in, do they?
         6            MR. CROWE:  At this point I'm going to have to
         7     call this dep because I think you're just harassing
         8     the witness at this point, Mr. Taylor.  It is now 20
         9     minutes to 6:00.
        10            MR. TAYLOR:  Let me ask a couple more
        11     questions.
        12     BY MR. TAYLOR:
        13   Q   I want to call your attention to the
        14     last page of the quotes.
        15   A   Which one is that, 301?
        16   Q   Yes.  WLS has a quote attributed to
        17     you on the 22nd of April of '99.  It says, "Hillard,
        18     as of this time, says, 'I see no reason why there
        19     should be an internal investigation.'"  Do you see
        20     that?
        21   A   Which page is that?
        22   Q   It's the very last page.  It's a WLS
        23     quote.  If you look at --
        24   A   Oh, yes.

                           


                                                                  239
         1   Q   Did you make that statement that was
         2     carried on WLS?
         3   A   I assume I did.
         4   Q   All right.  And at that point even
         5     after Durr was charged you felt that there was no
         6     reason for an internal investigation to determine
         7     whether the police acted -- had committed any
         8     misconduct.  Is that fair to say?
         9   A   Yes, sir.
        10            MR. TAYLOR:  Okay.  Thank you, Superintendent.
        11            MR. CROWE:  Thank you.
        12            THE WITNESS:  You're welcome.
        13
        14                  FURTHER DEPONENT SAITH NOT
                                SIGNATURE RESERVED
        15
        16
        17
        18
        19
        20
        21
        22
        23
        24

                           


                                                                  240
         1              IN THE UNITED STATES DISTRICT COURT
                       FOR THE NORTHERN DISTRICT OF ILLINOIS
         2                       EASTERN DIVISION
         3     MOTHER and FATHER on their own   )
               behalf and as guardian of the    )
         4     estate of their son, JOHNNY DOE, )
               or R.G., a minor,                )
         5                                      )
                             Plaintiffs,        )
         6                                      )
                      vs.                       )   No. 99 C 3259
         7                                      )
               JAMES CASSIDY #20207, ALLEN      )   Judge Lefkow
         8     NATHANIEL #20443, SGT. STANLEY   )
               ZABORAC #1139, SGT. DANIEL       )
         9     BRANNIGAN #1469, COMMANDING      )
               YOUTH LT. K. BROWN #202, DET.    )
        10     PAUL JACKSON #20932, YOUTH INV.  )
               VINCENT JAMES #40321, YOUTH INV. )
        11     ANTHONY POWELL #40060, SGT.      )
               NELSON #1931, DET. DOLORES MYLES )
        12     #20242, DET. SAMUEL BROWN #20826,)
               DET. DEVON ANDERSON #5114,       )
        13     COMMANDER DANIEL GIBSON, YOUTH   )
               INV. CHARLES BOWEN #40225, and   )
        14     the CITY OF CHICAGO,             )
                                                )
        15                   Defendants.        )
                               WITNESS CERTIFICATION
        16            I hereby certify that I have read the
               foregoing transcript of my deposition, given at the
        17     time and place aforesaid, consisting of pages 1
               through 240; and I do again subscribe and make oath
        18     that the same is a true, correct, and complete
               transcript of my deposition so given.
        19            I have ____ not ____ submitted errata sheets.
        20            Signed:  _____________________________________
                                    TERRY G. HILLARD, Deponent
        21
               SUBSCRIBED AND SWORN TO
        22     before me this ____ day
               of _________A.D., 2001.
        23
               ___________________________
        24            NOTARY PUBLIC
 
                                                                  241
         1     STATE OF ILLINOIS)
                                )  SS:
         2     COUNTY OF C O O K)
         3
         4                   I, CARMELLA T. FAGAN, a Certified
         5     Shorthand Reporter and Notary Public within and for
         6     the County of Cook and State of Illinois, do hereby
         7     certify that heretofore, to-wit, on the 17th day of
         8     May, 2001, personally appeared before me at 3510
         9     South Michigan Avenue, Fifth Floor, Chicago,
        10     Illinois, TERRY G. HILLARD, a witness in a certain
        11     cause now pending and undetermined in said Court.
        12                   I further certify that the said TERRY
        13     G. HILLARD, was by me first duly sworn to testify the
        14     truth, the whole truth, and nothing but the truth in
        15     the cause aforesaid; that the testimony then given by
        16     said witness was reported stenographically by me, in
        17     the presence of said witness and afterwards reduced
        18     to typewriting via computer-aided transcription, and
        19     the foregoing is a true and correct transcript of the
        20     testimony so given by said witness as aforesaid.
        21                   The signature of the witness to the
        22     foregoing deposition was reserved by agreement of
        23     counsel for the respective parties.
        24                   I further certify that the taking of

                         


                                                                  242
         1     this deposition was pursuant to notice, and that
         2     there were appearances as heretofore noted.
         3                   I further certify that I am not counsel
         4     for nor in any way related to any of the parties to
         5     this suit, nor am I in any way interested in the
         6     outcome thereof.
         7                   In testimony whereof I have hereunto
         8     set my hand and affixed my notarial seal this ______
         9     day of __________, ______.
        10
        11                          ________________________________
        12                          Carmella T. Fagan, CSR, RPR
        13
        14                                 My notary expires:
        15                          ________________________________
</pre>

 

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