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?