Chicago Justice Project Lawsuit

E-Notice
2018-CH-06576
CALENDAR: 10
To: Matthew Vincent Topic
matt@loevy.com
NOTICE OF ELECTRONIC FILING

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
CHICAGO JUSTICE PROJECT vs. CHICAGO POLICE DEPARTMENT
The transmission was received on 05/22/2018 at 1:42 PM and was ACCEPTED with
the Clerk of the Circuit Court of Cook County on 05/22/2018 at 2:11 PM.
CHANCERY_ACTION_COVER_SHEET (CHANCERY DIVISION)
COMPLAINT
Filer's Email: matt@loevy.com

Filer's Fax: (312) 243-5902
Notice Date: 5/22/2018 2:11:48 PM
Total Pages: 50
DOROTHY BROWN
CLERK OF THE CIRCUIT COURT
COOK COUNTY
RICHARD J. DALEY CENTER, ROOM 1001
CHICAGO, IL 60602
(312) 603-5031
courtclerk@cookcountycourt.com
Chancery Division Civil Cover Sheet - General Chancery Section (Rev. 12/30/15) CCCH 0623
IN THE CIRCUIT CIVIL COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, COUNTY DIVISION
CHICAGO JUSTICE PROJECT

Plantiff
ELECTRONICALLY FILED
v. 5/22/2018 1:42 PM
No. 2018-CH-06576
CALENDAR: 10
CHICAGO POLICE DEPARTMENT CIRCUIT COURT OF
Defendant COOK COUNTY, ILLINOIS
CHANCERY DIVISION
CLERK DOROTHY BROWN
CHANCERY DIVISION CIVIL COVER SHEET

GENERAL CHANCERY SECTION
A Chancery Division Civil Cover Sheet - General Chancery Section shall be fi led with the initial complaint in all
actions fi led in the General Chancery Section of Chancery Division. The information contained herein is for administra-
tive purposes only. Please check the box in front of the appropriate category which best characterizes your action being
filed.
0005 Administrative Review
0001 Class Action
0002 Declaratory Judgment
0004 Injunction
0007 General Chancery 0019 Partition

0010 Accounting 0020 Quiet Title
0011 Arbitration 0021 Quo Warranto
0012 Certiorari 0022 Redemption Rights
0013 Dissolution of Corporation 0023 Reformation of a Contract
0014 Dissolution of Partnership 0024 Rescission of a Contract
0015 Equitable Lien 0025 Specific Performance
0016 Interpleader 0026 Trust Construction
0017 Mandamus 0027 Foreign Transcript
0018 Ne Exeat 0085 Petition to Register Foreign Judgment
Other (specify)
By: /s MATTHEW VINCENT TOPIC
Atty. No.: 41295 Pro Se 99500 Pro Se Only: I have read and agree to the terms of the
Name: LOEVY & LOEVY Clerk's Office Electronic Notice Policy and choose to opt
Atty. for: CHICAGO JUSTICE PROJECT in to electronic notice from the Clerk’s office for this caseat
this email address:
Address: 311 N ABERDEEN 3FL
City/State/Zip: CHICAGO, IL 60607
Telephone: (312) 243-5900
Primary Email Address:
matt@loevy.com
Secondary Email Address(es):
joshb@loevy.com
foia@loevy.com
DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

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CIRCUIT COURT OF
COOK COUNTY, ILLINOIS
CHANCERY DIVISION
COUNTY DEPARTMENT, CHANCERY DIVISION CLERK DOROTHY BROWN
CHICAGO JUSTICE PROJECT, )

)
Plaintiff, )
)
v. )
)
CHICAGO POLICE DEPARTMENT, )
)
Defendant. )
COMPLAINT
NOW COMES Plaintiff, CHICAGO JUSTICE PROJECT by its undersigned attorneys,
LOEVY & LOEVY, and brings this suit to overturn Defendant CHICAGO POLICE
DEPARTMENT’s refusal, in willful violation of the Illinois Freedom of Information Act, to
produce records related to various CPD reports and CPD data. In support of its Complaint, CJP
states as follows:
INTRODUCTION
1. Pursuant to the fundamental philosophy of the American constitutional form of
government, it is the public policy of the State of Illinois that all persons are entitled to full and
complete information regarding the affairs of government and the official acts and policies of
those who represent them as public officials and public employees consistent with the terms of
the Illinois Freedom of Information Act (“FOIA”). 5 ILCS 140/1.
2. Restraints on access to information, to the extent permitted by FOIA, are limited
exceptions to the principle that the people of this state have a right to full disclosure of
information relating to the decisions, policies, procedures, rules, standards, and other aspects of
government activity that affect the conduct of government and the lives of the people. 5 ILCS
140/1.
3. All public records of a public body are presumed to be open to inspection or
copying. Any public body that asserts that a record is exempt from disclosure has the burden of
proving by clear and convincing evidence that it is exempt. 5 ILCS 140/3.
4. Under FOIA Section 11(h), “except as to causes the court considers to be of
greater importance, proceedings arising under [FOIA] shall take precedence on the docket over
all other causes and be assigned for hearing and trial at the earliest practicable date and expedited
in every way.”
PARTIES
5. Plaintiff CHICAGO JUSTICE PROJECT is the FOIA requester in this case.

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6. Defendant CPD is a public body located in Cook County, Illinois.
JUNE 14 REQUEST (ARREST DATA)
7. On June 14, 2017, CJP requested individual arrest data for every arrest made by
CPD from 1999-2016. Group Exhibit A.
8. On June 20, 2017, CPD denied the request stating that under Section 3(g) the
burden of production outweighed the public interest in disclosure. Group Exhibit A.
9. The burden of compliance does not outweigh the public interest in disclosure.
MAY 25 REQUEST (BROMWICH REPORT)
10. On May 25, 2017, CJP requested Michael Bromwich’s report on CPD training
completed in 2016 and “all invoices, cancelled checks, contracts, work orders, and any other
financial documents that in any way are related to” Bromwich’s work for CPD. Group Exhibit
B.
11. On June 9, 2017, CPD denied the request stating that the Bromwich report is
-2-
exempt under Section 7(1)(m) because the record was prepared at the request of an attorney.
CPD stated that it does not maintain the records responsive to the remainder of the request.
Group Exhibit B.
SEPTEMBER 26 REQUEST (COMPREHENSIVE ANALYSIS)
12. On September 26, 2016, CJP requested the comprehensive analysis that CPD
official referenced in a September 21, 2016, briefing with alderman at City Hall. CJP also
requested all records that CPD maintains regarding staffing or allocation of CPD resources from
January 1, 2011, to September 26, 2016. Ex. C.
13. On October 4, 2016, CPD took a five day extension. Ex. D.
14. Despite follow up communications from CJP, CPD never responded and never
produced any responsive records. Ex. E.

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JANUARY 20 REQUEST (CRIME INCIDENT DATA)
15. On January 20, 2017, CJP requested “case level crime incident data for all crime
incidents including homicides from 1980-2016 including data related to how the incident is
originally coded as it enters the CPD and the final incident classification.” Ex. F.
16. On January 27, 2017, CPD took a five day extension. Ex. G.
17. On February 3, 2017, CPD denied the request stating that it would need to create
an algorithm to gather the responsive data and this constituted creating a new record. CPD also
stated that under Section 3(g) the burden of production outweighed the public interest in
disclosure. Ex. H.
18. On February 18, 2017, CJP narrowed the request to the time period 1999-2016.
Ex. I.
19. CPD did not respond to the narrowed request and did not produce responsive
-3-
records.
FEBRUARY 17 REQUEST (DV DATABASE)
20. On February 17, 2017, CJP requested “the database records related to domestic
violence that were provided to ABC Chicago News and are reported on in this news report: [url
to report].” Group Exhibit J.
21. CPD never responded to the request or produced any responsive records. Group
Exhibit J.
DECEMBER 19 REQUEST (EMAILS)
22. On December 19, 2017, CJP requested emails (from seven listed
positions/individuals) related to Superintendent Eddie Johnson’s announcement on September,

21, 2016, that CPD would hire 1,000 more police officers. Group Exhibit K.
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23. On December 20, 2017, CPD responded that it needed complete names despite
the fact that CJP had listed the exact positions it requested emails from. Group Exhibit K.
24. CPD never produced the responsive records. Group Exhibit K.
SEPTEMBER 11 REQUEST (HIRES & ACADEMY)
25. On September 11, 2017, CJP requested records related to the number of people
CPD hired and the number of people that went through CPD’s academy. Group Exhibit L.
26. On September 11, 2017, CPD took a five day extension. Group Exhibit L.
27. CPD never produced the responsive records.
JUNE 23 REQUEST (OEMC CALL FOR SERVICE DATA)
28. On June 23, 2017, CJP requested “all call level police call for service data
originally created by the Office of Emergency Management and Communications, but
maintained by the Chicago Police Department for the years 1999-2016.” Ex. M.
-4-
29. On June 30, 2017, CPD responded stating that it does not possess records
responsive to the request. Ex. N.
APRIL 10 REQUEST (STAFFING)
30. On April 10, 2017, CJP requested records related to staffing by district for
January 1st of each year for the years 2000-2017. Ex. O.
31. After additional correspondence, on May 2, 2017, CPD responded that it only
possessed responsive data going back to 2008. Ex. P.
32. On May 24, 2017, CPD produced responsive records for 2008-2017, but not
2000-2007 stating that it did not possess the responsive records for 2000-2007. Ex. Q.
FEBRUARY 24 REQUEST (IAD DATA)

33. On February 24, 2018, CJP requested various records related to digital complaint
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data received by Internal Affairs Division from 2000-2017. Ex. R.
34. After additional correspondence, on April 5, 2018, CPD responded largely
denying the request and stating that under Section 3(g) the burden of production outweighed the
public interest in disclosure for part of the request. CPD stated that it did not possess some of the
other records requested and it produced a small portion of responsive records. Ex. S.
35. The burden of compliance does not outweigh the public interest in disclosure.
-5-
COUNT I – JUNE 14 WILLFUL VIOLATION OF FOIA
36. The above paragraphs are incorporated by reference.
37. CPD is a public body under FOIA.
38. The records sought in the FOIA request are non-exempt public records of CPD.
39. CPD has willfully and intentionally violated FOIA by refusing to produce the
requested records.
COUNT II – MAY 25 WILLFUL VIOLATION OF FOIA
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requested records.
COUNT III – SEPTEMBER 26 WILLFUL VIOLATION OF FOIA
requested records.
COUNT IV – JANUARY 20 WILLFUL VIOLATION OF FOIA
-6-
requested records.
COUNT V – FEBRUARY 17 WILLFUL VIOLATION OF FOIA
requested records.
COUNT VI – DECEMBER 19 WILLFUL VIOLATION OF FOIA

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requested records.
COUNT VII – SEPTEMBER 11 WILLFUL VIOLATION OF FOIA
requested records.
COUNT VIII – JUNE 23 WILLFUL VIOLATION OF FOIA
-7-
requested records.
COUNT IX – APRIL 10 WILLFUL VIOLATION OF FOIA
requested records.
COUNT XI – FEBRUARY 24 WILLFUL VIOLATION OF FOIA


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requested records.
WHEREFORE, CJP asks that the Court:
i. in accordance with FOIA Section 11(f), afford this case precedence on the Court’s
docket except as to causes the Court considers to be of greater importance, assign
this case for hearing and trial at the earliest practicable date, and expedite this
case in every way;
ii. declare that CPD has violated FOIA;
iii. order CPD to produce the requested records;
iv. enjoin CPD from withholding non-exempt public records under FOIA;
v. order CPD to pay civil penalties;
-8-
vi. award Plaintiff reasonable attorneys’ fees and costs;
vii. award such other relief the Court considers appropriate.
RESPECTFULLY SUBMITTED,
/s/ Joshua Hart Burday
____________________________
Attorneys for Plaintiff

Matthew Topic
Joshua Burday
LOEVY & LOEVY
311 North Aberdeen, 3rd Floor

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Chicago, IL 60607
2018-CH-06576
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312-243-5900
matt@loevy.com
joshb@loevy.com
Atty. No. 41295
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Group Exhibit B
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Exhibit C
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Exhibit D
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Exhibit E
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Exhibit I
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Group Exhibit J
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Group Exhibit K
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From: Tracy Siska tsiska@chicagojustice.org
Subject: Chicago Justice Project FOIA 9/11/17
Date: September 11, 2017 at 11:05 AM
To: Chicago Police Department, Dept: Records & Inquiry foia@chicagopolice.org
Please provide the following records in accordance with the Illinois Freedom of Information Act.
A. "Please provide aggregate totals for the following categories broken down by month for every month since 1/1/16 - through
8/31/17. Please further break down the data by the race and gender of the individuals.
1. Number of officers hired by the Chicago Police Department
2. Number of cadets entering the Chicago Police Department academy
3. Number of cadets graduating from the Chicago Police Department academy
4. Number of officers retiring from the Chicago Police Department
5. Number of officers that left the employ of the Chicago Police Department for any reason besides retirement
B. For every entrance exam given by the Chicago Police Department from 1/1/16 - 8/31/17 please detail the following aggregate
totals: Please further break down the data by the race and gender of the individuals.
1. Number of individuals that applied to take the exam
2. Number of individuals that completed the exam
3. Number of individuals that passed the exam

4. Number of individuals that attempted each qualifying test, i.e. the psychological exam, POWER test, etc…., and the number of
5/22/2018 1:42 PM
individuals that both failed and passed the exam.

2018-CH-06576
PAGE 29 of 49
Please fulfill this request in the 5 working days mandated by Illinois Law. If you have any question please respond to this email. When
fulfilling this request please reply to this email and send the material in digital format.
Tracy Siska
------------
Tracy Siska | Executive Director
Chicago Justice Project | 53 W. Jackson Blvd., Suite 1205 | Chicago, IL 60604
Ph. (312) 971-6745 |
tsiska@chicagojustice.org | www.chicagojustice.org |
Twitter: CJPJustProj
Group Exhibit L
From: FOIA foia@chicagopolice.org
Subject: RE: Chicago Justice Project FOIA 9/11/17- Extension Notice FOIA # P428461
Date: September 11, 2017 at 11:48 AM
To: Tracy Siska tsiska@chicagojustice.org
Extension Notice FOIA # P428461
The Chicago Police Department received your Freedom of Information Act Request on September 11,
2017. Under the Freedom of Information Act, a public body may extend the time to respond to a FOIA request
by up to 5 business days for a limited number of reasons. Pursuant to Section 5 ILCS 140/3(e) of the Act,
the CPD is extending the time to respond to your request by 5 business days from the original due date for the
following reason(s):
() The requested records are stored in whole or in part at other locations

other than the office having charge of the requested records;
() The requested records require the collection of a substantial

number of specified records;
(X) The request is couched in categorical terms and requires an

extensive search for the records responsive to it;
() The requested records have not been located in the course of

routine search and additional efforts are being made to locate
them;
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() The requested records require examination and evaluation by personnel

PAGE 30 of 49
having the necessary competence and discretion to determine if they are

exempt from disclosure or should be revealed only with appropriate
deletions;
(X) The request for records cannot be complied by the public body within the
time limits prescribed by the Freedom of Information Act, 5 ILCS 140/3(c),
without unduly burdening or interfering with the operations of the public
body;
(X ) There is a need for consultation, which shall be conducted with all practicable
speed, with another public body or among two or more components of any
public body having a substantial interest in the determination or in the
subject matter of the request.
Chicago Police Department

FOIA Section
This message is intended only for the use of the individual or entity to which it is addressed, and may contain information that is PRIVILEGED,
CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient, or the
employee or agent responsible for delivering that message to the intended recipient, you are hereby notified that any dissemination, distribution or
copying of this document is strictly prohibited.
From: Tracy Siska [tsiska@chicagojustice.org]

Sent: Monday, September 11, 2017 11:05 AM
To: FOIA
A. "Please provide aggregate totals for the following categories broken down by month for every month since 1/1/16 - through 8/31/17. Please
further break down the data by the race and gender of the individuals.
B. For every entrance exam given by the Chicago Police Department from 1/1/16 - 8/31/17 please detail the following aggregate totals: Please
4. Number of individuals that attempted each qualifying test, i.e. the psychological exam, POWER test, etc…., and the number of individuals that
both failed and passed the exam.
Please fulfill this request in the 5 working days mandated by Illinois Law. If you have any question please respond to this email. When fulfilling this
request please reply to this email and send the material in digital format.
Tracy Siska
------------
5/22/2018 1:42 PM
2018-CH-06576
Ph. (312) 971-6745 |

PAGE 31 of 49
Subject: Re: Chicago Justice Project FOIA 9/11/17- Extension Notice FOIA # P428461
Date: September 30, 2017 at 4:18 PM
To: FOIA foia@chicagopolice.org
Can you please let me know the status of our FOIA request?
Tracy Siska
------------
Chicago Justice Project | 9 W. Washington, Suite 400 | Chicago, IL 60604 | Ph. (312) 971-6745 |
On Sep 11, 2017, at 11:46 AM, FOIA <foia@chicagopolice.org> wrote:
The Chicago Police Department received your Freedom of Information Act Request on September 11, 2017.
Under the Freedom of Information Act, a public body may extend the time to respond to a FOIA request by up
to 5 business days for a limited number of reasons. Pursuant to Section 5 ILCS 140/3(e) of the Act, the CPD
is extending the time to respond to your request by 5 business days from the original due date for the
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them;
() The requested records require examination and evaluation by personnel

having the necessary competence and discretion to determine if they are
exempt from disclosure or should be revealed only with appropriate
deletions;
time limits prescribed by the Freedom of Information Act,5 ILCS 140/3(c),
body;
(X ) There is a need for consultation, which shall be conducted with all practicable
speed, with another public body or among two or more components of
any public body having a substantial interest in the determination or in the
subject matter of the request.

FOIA Section

employee or agent responsible for delivering that message to the intended recipient, you are hereby notified that any dissemination, distribution
or copying of this document is strictly prohibited.

To: FOIA
5/22/2018 1:42 PM
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PAGE 33 of 49
4. Number of individuals that attempted each qualifying test, i.e. the psychological exam, POWER test, etc…., and the number of individuals that
both failed and passed the exam.
Please fulfill this request in the 5 working days mandated by Illinois Law. If you have any question please respond to this email. When fulfilling this
request please reply to this email and send the material in digital format.
Tracy Siska
------------
Ph. (312) 971-6745 |
Date: October 10, 2017 at 10:38 AM
To: FOIA foia@chicagopolice.org
Can you please provide me with an update on my FOIA request?
Tracy
------------
On Sep 30, 2017, at 4:18 PM, Tracy Siska <tsiska@chicagojustice.org> wrote:
Can you please let me know the status of our FOIA request?
Tracy Siska
------------

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The Chicago Police Department received your Freedom of Information Act Request on September 11, 2017.
Under the Freedom of Information Act, a public body may extend the time to respond to a FOIA request by
up to 5 business days for a limited number of reasons. Pursuant to Section 5 ILCS 140/3(e) of the Act, the
CPD is extending the time to respond to your request by 5 business days from the original due date for the




them;
() The requested records require examination and evaluation by

personnel having the necessary competence and discretion to
determine if they are exempt from disclosure or should be revealed
only with appropriate deletions;
time limits prescribed by the Freedom of Information Act,5 ILCS 140/3(c),
body;
(X ) There is a need for consultation, which shall be conducted with all

practicable speed, with another public body or among two or more
components of any public body having a substantial interest in the
determination or in the subject matter of the request.

FOIA Section


To: FOIA

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4. Number of individuals that attempted each qualifying test, i.e. the psychological exam, POWER test, etc…., and the number of individuals
that both failed and passed the exam.
Please fulfill this request in the 5 working days mandated by Illinois Law. If you have any question please respond to this email. When fulfilling
this request please reply to this email and send the material in digital format.
Tracy Siska
------------
Ph. (312) 971-6745 |
5/22/2018 1:42 PM
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From: Karr, Landon P. Landon.Karr@chicagopolice.org
Subject: FW: Follow-up - P428461 FW: Chicago Justice Project FOIA 9/11/17- Extension Notice FOIA # P428461
Date: October 10, 2017 at 2:11 PM
To: tsiska@chicagojustice.org
Mr. Siska,
Apologies for the delay in getting this material together. As easy as it may seem, it is simply not a set of records that is maintained regularly by
CPD. I'm still trying to see what I can do to piece together some of this from a variety of different places within this department.
Again, apologies. I will be in touch once I have a better answer for you.
Landon
From: FOIA
Sent: Tuesday, October 10, 2017 1:31 PM
To: Karr, Landon P.
Subject: Follow-up - P428461 FW: Chicago Justice Project FOIA 9/11/17- Extension Notice FOIA # P428461
employee or agent responsible for delivering that message to the intended recipient, you are hereby notified that any dissemination, distribution or
copying of this document is strictly prohibited.

Sent: Tuesday, October 10, 2017 10:38 AM
To: FOIA
5/22/2018 1:42 PM
Can you please provide me with an update on my FOIA request?

2018-CH-06576
PAGE 37 of 49
Tracy
------------
The Chicago Police Department received your Freedom of Information Act Request on September 11,
2017. Under the Freedom of Information Act, a public body may extend the time to respond to
a FOIA request by up to 5 business days for a limited number of reasons. Pursuant to Section
5 ILCS 140/3(e) of the Act, the CPD is extending the time to respond to your request by 5 business days
from the original due date for the following reason(s):
()
The requested records are stored in whole or in part at other location
s other than the office having charge of the requested records;



routine search and additional efforts are being made to
locate them;
() The requested records require examination and evaluation by

personnel having the necessary competence and discretion to
determine if they are exempt from disclosure or should be revealed
only with appropriate deletions;
time limits
prescribed by the Freedom of Information Act,5 ILCS 140/3(c), without un
duly burdening or interfering with the operations of the public body;
(X
) There is a need for consultation, which shall be conducted with all pra
cticable speed, with another public body or among two or more
components of any public body having a substantial interest in the
determination or in the subject matter of the request.

FOIA Section
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To: FOIA
4. Number of individuals that attempted each qualifying test, i.e. the psychological exam, POWER test, etc…., and the number of individuals
that both failed and passed the exam.
Please fulfill this request in the 5 working days mandated by Illinois Law. If you have any question please respond to this email. When fulfilling
this request please reply to this email and send the material in digital format.
Tracy Siska
------------
Ph. (312) 971-6745 |
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Exhibit M PAGE 40 of 49
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Exhibit N
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Exhibit O
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Exhibit P
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Exhibit Q
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Exhibit R
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Exhibit S
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Summons - Alias Summons (12/31/15) CCG N001

No. 2018-CH-06576
v.
Defendant Address:
CHICAGO POLICE DEPARTMENT CHICAGO POLICE DEPARTMENT
3510 S MICHIGAN AVE
CHICAGO, IL 60653
SUMMONS ALIAS - SUMMONS

To each defendant:
YOU ARE SUMMONED and required to file an answer to the complaint in this case, a copy of which is hereto
attached, or otherwise file your appearance, and pay the required fee, in the Office of the Clerk of this Court at the
following location:
Richard J. Daley Center, 50 W. Washington, Room 802 ,Chicago, Illinois 60602
District 2 - Skokie District 3 - Rolling Meadows District 4 - Maywood
5600 Old Orchard Rd. 2121 Euclid 1500 Maybrook Ave.
Skokie, IL 60077 Rolling Meadows, IL 60008 Maywood, IL 60153
District 5 - Bridgeview District 6 - Markham Richard J. Daley Center
10220 S. 76th Ave. 16501 S. Kedzie Pkwy. 50 W. Washington, LL-01
Bridgeview, IL 60455 Markham, IL 60428 Chicago, IL 60602
You must file within 30 days after service of this Summons, not counting the day of service.
IF YOU FAIL TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE
RELIEF REQUESTED IN THE COMPLAINT.
To the officer:
This Summons must be returned by the officer or other person to whom it was given for service, with endorsement
of service and fees, if any, immediately after service. If service cannot be made, this Summons shall be returned so
endorsed. This Summons may not be served later than thirty (30) days after its date.
Witness: Tuesday, 22 May 2018

Atty. No.: 41295
Name: LOEVY & LOEVY
/s DOROTHY BROWN
Atty. for: CHICAGO JUSTICE PROJECT DOROTHY BROWN, Clerk of Court
Address: 311 N ABERDEEN 3FL
Date of Service:
City/State/Zip Code: CHICAGO, IL 60607
(To be inserted by officer on copy left with Defendant or other person)
Telephone: (312) 243-5900
Primary Email Address: matt@loevy.com
**Service by Facsimile Transmission will be accepted at:
Secondary Email Address(es):
joshb@loevy.com
(Area Code) (Facsimile Telephone Number)
DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

Page 1 of 1
Chancery DIVISION
Litigant List
Printed on 05/22/2018
Case Number: 2018-CH-06576 Page 1 of 1
Plaintiffs
Plaintiffs Name Plaintiffs Address State Zip Unit #
CHICAGO JUSTICE
PROJECT
Total Plaintiffs: 1
Defendants
Defendant Name Defendant Address State Unit # Service By
CHICAGO POLICE 3510 S MICHIGAN AVE CHICAGO, IL 60653 Sheriff-Clerk
DEPARTMENT
Total Defendants: 1

Chicago Justice Project Lawsuit

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Chicago Justice Project Lawsuit

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E-Notice

NOTICE OF ELECTRONIC FILING

CHANCERY_ACTION_COVER_SHEET (CHANCERY DIVISION)

Filer's Email: matt@loevy.com

IN THE CIRCUIT CIVIL COURT OF COOK COUNTY, ILLINOIS

CHICAGO JUSTICE PROJECT

CHANCERY DIVISION CIVIL COVER SHEET

0007 General Chancery 0019 Partition

DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

CHICAGO JUSTICE PROJECT, )

NOW COMES Plaintiff, CHICAGO JUSTICE PROJECT by its undersigned attorneys,

DEPARTMENT’s refusal, in willful violation of the Illinois Freedom of Information Act, to

1. Pursuant to the fundamental philosophy of the American constitutional form of

the Illinois Freedom of Information Act (“FOIA”). 5 ILCS 140/1.

2. Restraints on access to information, to the extent permitted by FOIA, are limited

3. All public records of a public body are presumed to be open to inspection or

proving by clear and convincing evidence that it is exempt. 5 ILCS 140/3.

4. Under FOIA Section 11(h), “except as to causes the court considers to be of

5. Plaintiff CHICAGO JUSTICE PROJECT is the FOIA requester in this case.

6. Defendant CPD is a public body located in Cook County, Illinois.

JUNE 14 REQUEST (ARREST DATA)

CPD from 1999-2016. Group Exhibit A.

burden of production outweighed the public interest in disclosure. Group Exhibit A.

MAY 25 REQUEST (BROMWICH REPORT)

SEPTEMBER 26 REQUEST (COMPREHENSIVE ANALYSIS)

January 1, 2011, to September 26, 2016. Ex. C.

13. On October 4, 2016, CPD took a five day extension. Ex. D.

produced any responsive records. Ex. E.

JANUARY 20 REQUEST (CRIME INCIDENT DATA)

FEBRUARY 17 REQUEST (DV DATABASE)

to report].” Group Exhibit J.

DECEMBER 19 REQUEST (EMAILS)

positions/individuals) related to Superintendent Eddie Johnson’s announcement on September,

24. CPD never produced the responsive records. Group Exhibit K.

SEPTEMBER 11 REQUEST (HIRES & ACADEMY)

27. CPD never produced the responsive records.

JUNE 23 REQUEST (OEMC CALL FOR SERVICE DATA)

originally created by the Office of Emergency Management and Communications, but

responsive to the request. Ex. N.

APRIL 10 REQUEST (STAFFING)

January 1st of each year for the years 2000-2017. Ex. O.

possessed responsive data going back to 2008. Ex. P.

FEBRUARY 24 REQUEST (IAD DATA)

data received by Internal Affairs Division from 2000-2017. Ex. R.

34. After additional correspondence, on April 5, 2018, CPD responded largely

36. The above paragraphs are incorporated by reference.

37. CPD is a public body under FOIA.

COUNT II – MAY 25 WILLFUL VIOLATION OF FOIA

40. The above paragraphs are incorporated by reference.

41. CPD is a public body under FOIA.

COUNT III – SEPTEMBER 26 WILLFUL VIOLATION OF FOIA

44. The above paragraphs are incorporated by reference.

45. CPD is a public body under FOIA.

COUNT IV – JANUARY 20 WILLFUL VIOLATION OF FOIA

48. The above paragraphs are incorporated by reference.

49. CPD is a public body under FOIA.

COUNT V – FEBRUARY 17 WILLFUL VIOLATION OF FOIA

52. The above paragraphs are incorporated by reference.

53. CPD is a public body under FOIA.

COUNT VI – DECEMBER 19 WILLFUL VIOLATION OF FOIA

56. The above paragraphs are incorporated by reference.

57. CPD is a public body under FOIA.

COUNT VII – SEPTEMBER 11 WILLFUL VIOLATION OF FOIA

60. The above paragraphs are incorporated by reference.