IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

CRIMINAL DIVISION
State Of lrlinois, )
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Plaintiff,
v.
Annabel K. Melongo
Defendant,
Amended Petition To Have Mr. Podlasek Recused And To Appoint Special Prosecutor
NOW comes ANNABEL K. ME LONGO, ProSe, and petitions this Court to appoint a special prosecutor
for the following reasons:
1. On July 1Oth, 2013, defendant filed a civil right case naming, among others, Mr. Pod Iasek, Mrs.
Anita Alvarez, Mrs. Julie Gunnigle and Investigator Kate O'hara, all employed by the Cook County State
Attorney during the events that gave rise to the complaint.
2. Mr. Podlasek is currently prosecuting defendant in the above captioned case. This creates an
inherent conflict of interest in that he's the prosecutor in the present case and a defendant in the civil right
case. Attached exhibit A. As stated in People v. White, 365111.499, 6 N.E.2d 1015(1937), "Trials courts
should be reluctant to appoint as assistant state's attorney one who represents private interests in
pending civil litigation growing out of the same state of facts as is presented in the criminal case in which
he is appointed prosecutor. "
3. The pending civil litigation and the present criminal case are intertwined as followed:
1
On October 31
5
\ 2006, the defendant was charged with three counts of Computer
Tampering alleging remotely deleting files, mostly financial , belonging to Save-A-
Life Foundation Inc. , a now defunct non-for-profit organization with ties to the
Illinois Attorney General and the Cook County State Attorney Office.
The investigation that led to these charges was conducted by Mr. Kyle French of
the Illinois Attorney General Office, Mr. Randy Roberts, Executive Assistant to Cook
County State Attorney and Mr. William Martin, detective at the Schiller Park Police.
On January 10th, 2007, the charges against the defendant were dismissed for lack
of evidence.
On or about July of 2008, when the defendant ordered the January 1Oth, 2007,
transcript, to her surprise, not only the date of the hearing, but its content were
tampered with. The transcript stated that the dismissal was no longer due to lack of
evidence but rather, due to a superseded indictment not corroborated by any court
record. When defendant called the court report, Mrs. Annemary Tabor, to inquire,
2
the court reporter hung up after telling the defendant that the transcript was a
faithful representation of the proceedings.
On January 17th, 2007, the defendant was indicted in 2600 California Ave. Chicago,
IL, on the same charge.
On May 28th, 2008, a new indictment on the same charges superseded the January
2007 indictment. The arraignment's date was set for June 18th, 2008.
Upon realizing that she wasn't arraigned in the present case on June 18th, 2008,
the defendant ordered various court records to confirm this. Indeed, the docket, the
judge's half sheets and notes and the court call sheet showed no arraignment.
On December 4th , 2010, when the defendant received the arraignment's transcript
from Mrs. Laurel Laudin, the court reporter, the transcript showed an arraignment.
The defendant as a result, called Mrs. Laudin who told her that she was properly
arraigned. When the defendant threatened to file a complaint, Mrs. Laudin hung
up.
On December 10th, 2009, Mrs. Pamela Taylor, the court reporter assistant
administrator and supposedly Mrs. Laudin's supervisor, called the defendant and
forbade her to ever call Mrs. Laudin. Irritated, the defendant hung up.
Minutes later, Mrs. Pamela Taylor call back and left a voicemail wherein she
reiterated that Mrs. Laudin shouldn't be contacted. Mrs. Taylor made herself
available for any discussion related to the tampered court transcript.
Later that day, using the phone number prescribed in the voicemail , the defendant
called Mrs. Taylor to discuss the facts surrounding the tampered court transcript.
The defendant recorded that conversation.
On December 15th , 2009 and December 16th, 2009, subsequent phone
conversations on the tampered court transcript between the defendant and Mrs.
Taylor continued. The defendant recorded said conversations as well .
On December 17th, 2009, the defendant transcribed and posted the recordings on
her website, the illinoiscorruption.net. Additionally, she added a note on that
website stating that her actions were protected by 720 ILCS 5/14-3(i), an
exemption permitting recording to prove a crime.
On or about March 2010, and continuing thereafter, Mrs. Kate O'Hara, Mrs. Julie
Gunnigle and Mr. Robert Podlasek opened an investigation and issued subpoenas
to GoDaddy, Yahoo and financial institutions to find out the owner and email
activities of the illinoiscorruption.net website.
On April 13th, 2010, Mrs. Pamela Taylor filed a criminal complaint against the
defendant alleging violation of the Illinois Eavesdropping statute. That same day,
Mr. Podlasek, Mrs. Gunnigle and Mrs. Kate O'hara obtained a search and arrest
warrant for the charges of eavesdropping, 1 OCR080901 , the defendant spent more
that 20 months in jail because of her excessive bond, 500,000 D, later reduced to
300,000 D.
On July 26th, 2010, Mr. Podlasek switched election to the eavesdropping case.
Exactly two years later, July 26th, 2012, Judge Goebel officially dismissed the
eavesdropping case and on July 1Oth, 2013, defendant filed a civil right case based
on the eavesdropping case.
On two occasions, the defendant has tried to subpoena the audio-tapes of the
dismissal of her case in Rolling Meadows and the arraignment. Her assigned
judges never granted her an order to do so. In the event the defendant
successfully subpoena these tapes in federal court and confirm the fact that her
case was dismissed for lack of evidence and that there was no arraignment in the
present case, there will be a significant embarrassment for the Cook County State
attorney's office to have prosecuted the defendant in the eavesdropping case for
telling the truth and to have benefited and condoned the tampering of court
reports.
4. Apart from the conflict interest mentioned in paragraphs 2-3, the state attorney office also has a
per se conflict of interest in this case in that the complainant witness, Mrs. Carol Spizzirri , was a personal
friend of Mr. Dick Devine, the state attorney in charge, Attached Exhibit B. Furthermore, in 2009, Mrs.
Carol Spizzirri was also engaged in a computer stacking project with Anita Alvarez's office to create
computer laws in Illinois, Exhibit C. The present case is a computer tampering case which will benefit the
state attorney office's and Mrs. Carol Spizzirri in the event the defendant is found guilty. For this reason,
while the People of the State of Illinois would be well served by a truthful and objective prosecution of
defendant, State's Attorney Anita Alvarez would not be. This constitutes a per se conflict of interest under
Illinois law, People v. Spreitzer, 123111.2d 1, 525 N.E.2d 30, 34-35(1988) .
WHEREFORE, the defendant is requesting the appointment of a special prosecutor given that
the Cook Cook State Attorney Office is now an interested party in the present criminal case.
Atty. No.: 99500
Attorney For: Annabel K. Melongo
Address: P.O. Box 5658
City/State/Zip: Chicago. IL 60680
Telephone: 312-415-6632
3
[Exhibit A ___ _
IN THE UNITED STATES DISTRICT COURT ';S ;E-,r"'" """ .,.
FOR THE NORTHERN DISTRICT OF ILLINOIS /, ,_ .:..._ ---" .'_ .
1
' 0
EASTERN DIVISION
ANNABEL K. MELONGO,
Plaintiff
v 1. 13-cv-04924
Judge Joh
ROBERT PODLASEK Assistant State Attorne). Magistr.ate nJ F Grady
JULIE GUNNIGLE Assistant State Attorney. Udg
KATE O'HARA (STAR NO. 423) Cook County lnvestigallll, e Sheila M_ Fin
JAMES DILLON (STAR NO. I 068) Cook County Sherrilf. negan
ANTONIO RUBI NO (STA R NO. 5043) Cook County Sherriff
Investigator. RICH LESIAK (STAR NO. 5000) Cvok
County Sheniff Investigator. UNKNOWN COOK COUNTY JURY TRIAL DEMANDED
SHERIFF OFFICERS. Dr. S. MARKOS Director
Forensic Clinical Sen ices. MARILYN FILISHIO OITtcial
Court Reponers administrator, PAMELA TAYLOR Official
Court Repot1er Assistant Administrator. LAUREL L/\UDIN
Official Coun Reporter. KYLE FRENCH Assistant At1orney
General. AMBER HAQQANI Computer Forensic Expert .
LISA MADIGAN Illinois Attomey General.
ANITA ALVAREZ Cook Count: State Attorne:.
TOM DART Cook Count: Sherriff. COOK COUNTY.
Defendants .
COMPLAINT
"'''
Plaintiff Annabel K. Me Iongo. ProSe, complains of defendants ROBERT PODLASEK Assistant State
Attorne;. JULIE GUNNIGLE Assistant State Attorney, KATE o HARA (STAR NO. -123) Cook County
Ill\ estigator. SERGEANT JAMES DILLON (STAR NO. I 068) Cook Count: Sherriff. ANTONIO
RUBINO (STAR NO. 5043) Cook Count;. Sherriff lmestigator. RICH LESIAK (STAR NO. 5000) Cook
County Shwiff Investigator. UNKNOWN COOK COUNTY SHERJFF OFFICERS. Dr. MATTHEWS.
MARKOS Director Forensic Clinical Services. MARILYN A. FILISHIO Official Court Reporters
Administrator, PAMELA TAYLOR Official Cour1 Reporter Assistant Administrator. LAUREL LAUDfN
Officiat Court Reporter, KYLF FRENCH Assistant Attorney General. AMBFR HAQQANI Computer
Forensic Exper1. LISA MADIGAN Illinoi s Attorney General. ANITA ALVAREZ Cook County State
Anome). TOM J. DART Cook County Sherriff: COOK COUNTY as foiiO\\S:
INTRODUCTION
I. In Januar) of 20 I 0 and continuing thereafter. the above Defendants engaged in conspirac: to
cause Plaintiff Annabel K. Melon go to be charged of six counts of eavesdropping and to spend
more than 20 months of unlawful incarceration at the Cook Count) Jail.
Defendants conspiracy included a v .. iII ful disregard of a statu tor: exemption. 720 I LCS 5/ 1-1--3( i ).
and the conscious usc of a statute. 720 ILCS 5/ 14-2. lacking a cr iminal mental state.
3. As a direct consequence to Defendants' actions. Plaintiff endured extraordinar:- hardships and
undement incalculable loss, pain and humiliation for which shes nO\\ seeking redress.
JURlSDICTION AND VENUE
-1-. This action is brought pursuant to -1-2 U .S.C. 1983 to redress the deprivation under color of
law of Plaintiff"s rights as secured by the United States Constitution as v .. ell as deprivation of
rights under state Ia\\ .
5. This Coun has jurisdiction pursuant to 28 U.S. C. ~ 1331. 1367. Venue is proper under 28
U.S.C. ~ 1391(b). The parties reside in this judicial district. and the events gi\ing rise to the
claims asserted herein occurred in this judicial district.
THE PARTIES
6. Plaintiff ANNABEL K. MELONGO. 40, is from Cameroon. West Africa. and came to the
United States on a student \isa. She's a resident of Cook Count) . Illinoi s.
7. At all times relevant hereto. Defendams Robert Podlasek and Julie Gunnigle \\ere attorne)S
licensed to practice law in the State of Illinois and duly appointed Cook Count y Assistant
State's Attorneys .
8. At all times relevant hereto. Kate o !-lara (Star No. 43) ''as an investigator employed b) Cook
Count) State Anorne; office.
9. At all times relevant hereto. Sgt. James Dillon (Star No. 1068). Investigator Antonio Rubino
(Star No. 50-1-3). lmestigator Rich Lesiak (Star No. 5000) and the unkno,vn Cook Count:
sheriff officers were duly appointed members ol'the Cook County Sheniff Police Department.
I 0. At all times relevant hereto. Mrs. Pamela Tayl or and Mrs. Laurel Laud in were Official Court
Reporters employed b: the Official Court Reporters and paid by the Stare or Illinois.
II. At all rimes rele\ant herero. Mr. K: le French \\as an attome:- I icensed to practice Ia\\ in the
State of Illinois and a duly appointed Assistant Illinois Attorney General.
12. At all times rele\ant hereto. Mrs. Amber Haqqani \\aS a computer forensic expert employed b)
the Illinois Anome) General.
2
13. At all times relevant hereto, Dr. MatthewS. Markos was the director of Forensic Clinical
Services wbich provide comprehensive and diagnostic clinical services to the court and related
agencies under the court's jurisdiction. The agency employs psychiatric, psychological and
social service methods in the delivery of clinical services and submits clinical opinions and
recommendations to the court .
14. Each ofthe above defendants (paragraphs 7-13) is sued in his individual capacity.
15. At all times relevant hereto. Mrs. Marilyn A. Filishio was the administrator of the Official
Court Reporters with duties to oversee the recording of certain cour1 proceedings verbatim
either through the taking of stenographic notes or by an electronic recording system approved
by the Illinois Supreme Court. In her capacity, she ensures that all transcripts prepared as the
official record of court proceedings are prepared pursuant to applicable Illinois Supreme Com1
rules. This suit is brought against Mrs. Filishio in her individual and official capacity.
16. At all times relevant hereto, Defendant Lisa Madigan was the Attorney General of the State of
Illinois. In that capacity. she "consult[s] with and advise[s] the several state's attorneys in
matters relating to the duties of their office; and when, in [her] judgment. the interest of the
people of the state requires it. [ s ]he shall attend the trial of any party accused of crime, and
assist in the prosecution. " 15 ILCS 205/4. This suit is brought against Attorney General
Madigan in her individual and official capacity.
17. At all times relevant hereto, Defendant Anita Alvarez was the State Attorney responsible for
enforcing criminal laws within Cook County. This suit is brought against State Attorney
Alvarez in her individual and official capacity.
18. At all times relevant hereto, Defendant Tom J. Dart was the Cook County Sheriff responsible
for patrolling unincorporated areas of Cook County as well as assisting suburban police
departments with police operations including, but not limited to, detective and evidence
services, narcotics interdiction. bomb detection and disposal, vice operations. gang crimes
investigation, hostage, barricade and terrorist incidents . This suit is brought against Cook
County Sheriff Dart in his individual and official capacity.
19. Defendant Cook County is a County in the state of Illinois which employs or employed Mr.
Robert Podlasek. Mrs . Julie Gunnigle, Mrs. Kate oHare. Dr. Matthew Markos and Mrs. Anita
Alvarez.
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ALLEGATIONS OF FACT
A. FACTS
20. On October 3 L 2006, Plaintiff was charged with three counts of Computer tampering alleging
remotely deleting files. mostl:;. financial. belonging to Sme-A-Life Foundation Inc .. a ncn\
defunct non-for-profit organization with ties to the Illinois Attorney General and the Cook
County State Attomey Office.
21. The investigation that led to these charges ''as conducted by Mr. Kyle French of the Illinois
Attomey General Office. Mr. Randy Roberts. Executive Assistant to Cook County State
Attorney and Mr. William Martin. detective at the Schiller Park Police.
22. On November 15. 2006. upon being inf01med of the charges against her. Plaintiff surrendered to a judge
in the Rolling Meadows Courthouse. She was later released on an !-Bond.
23. On January 10.2007. the charges against Plaintiff were dismissed for lack of evidence.
2-L On or about Jul:;. of 2008. \\hen Plaintiff ordered the January I 0 . .2007. transcript. to her surprise. not
only the date of the hearing. but its content were tampered with. The transcript stated that the dismissal
was no longer due to lack of e\ idence but rather. due to a superseded indictment not corroborated ~
any court record. When Plaintiff called the court reporter. Mrs. Annemary Tabor. to inquire, the court
reporter hung up after telling Plaintiff that the transcript \\as a faithful representation of the
proceedings.
25. On January 17. 2007. Plaintiff was indicted in 2600 California Ave .. Chicago. IL. on the same computer
tampering charges and her Rolling Meado'' s !-Bond was transferred.
26. On Ma) 28. 2008. a new indictment on the same charges superseded the January 2007 indictment. The
arraignment's date was set for June 18'
11
, 2008.
27. Upon realizing that she wasn't arraigned on June 18'
11
2008. Plaintiff ordered \arious court records to
con finn this. Indeed. the docket. the judge s half sheets and notes and the court call sheet sho'' ed no
arraignment.
:28. On December 4'
11
20 I 0. when Plaintifr received the arraignment's transcript from Mrs. Laurel Laud in,
the transcript showed an arraignment. Plaintiff as a result. called Mrs. Laurel Laudin. Mrs. Laudin told
Plaintiffthat she was properly arraigned. When Plaintiflthreatened to file a complaint. Mrs . Laudin
hung up.
29. On December I 0. 2009. Mrs. Pamela Taylor. an assistant administrator at the Official Court Reporters
and supposedly Mrs. Laudins supervisor, called Plaintiff and forbade her to ever call Mrs. Laudin.
Irritated. Plaintiff hung up.
4
30. Minutes later. Mrs. Pamela Taylor called back Plaintiff and left a voicemail wherein Mrs. Taylor
reiterated that 1\tlrs. Laudin shouldn't be contacted. 1\tlrs. Taylor made herself available for any
discussion related to the tampered court transcript.
31. Later that da). using the phone number prescribed in the , oicemail. Plaintiff called Mrs. Taylor.
Unconstrained. Mrs. Taylor answered Plaintiffs questions and discussed the facts surrounding the
tampered court transcript. Plaintiff recorded that conversation.
32. On December 15, 2009, and December 16, 2009. subsequent phone conversations on the tampered
court transcript bet\\een Plaintiff and 1\tlrs. Taylor continued. Plaintiff recorded said con' ersations as
well.
33. On December 17'
11
2009. Plaintiff transcribed and posted the recordings on her \Vebsite. the
i!/inoiscorruJJfion.ner. Additionally, she added a note on that stating that her actions were
protected by 720 ILCS 5/ 1-t-3( i ), an exemption perm ining recording to pro\e a crime. The
illinoiscorruprion.nel "ebsite a chronological description of Plaintiffs computer tampering case
1

34. On December 18. 2009. using rhe internet' s links of the recorded conversations on the
il/inoiscormprion.net website. Plaintiff contacted an FBI agent.
35. On Januar: 8'
11
2010. while ProSe. Plaintiff filed an amended motion to dismiss the charges of
computer tampering. The grounds of her motion \Vere perjured statements of the state's'' itness.
Detective William Martin of Schiller Park Police. and prosecutorialmisconduct of the state prosecutor,
Mr. Robert Podlasek. .
36. On or about January IS. 2010. Amber Haqqani. a computer forensic expe11 \\Orking under the direction
of Mr. Kyle French. captured the il/inoiscorruplionner website. Subsequent captures ''ere used as
evidence at Plaintiff's eavesdropping trial.
37. On or about March 2010. and continuing thereafter. 1\tlrs. Kate O'Hara. Mrs. Julie Gunnigle and 1\tlr.
Robert Pod Iasek opened an investigation and issued subpoenas to Go Daddy. Yahoo and financial
institutions to find out the 0\\'11er and the email acti\ ities of the illinoi.lcmTUJ}[ionnel \\ebsite.
38. On March 3r". 2010, Plaintiffv .. as scheduled to argue her motion to dismiss the computer tampering
charges. HO\\ever. 1\tlr. Kyle French. Mr. Robert Podlasek and Mrs. Julie Gunnigle mO\ed to request a
psychological evaluation ("BCX") on Plaintiff to determine her fitness to stand trial and to represent
herself
39. On April 13. 20 I 0. at around II.OOam. Plaintiff submitted to the BCX and Dr. Markos posed as the
psychological examiner. During the examination session. unknown Cook County sheriff officers
1
The illinoiscorrvption.net website has since evolved into portraying events of the eavesdropping case, its appeal at the Illinois Supreme Court
and the present Civil Right case. At the time of Plaintiff's arrest on the eavesdropping charges. the website averaged 5,000 hi t s. It was used or
referenced by many media outlets.
5
knocked at the door and Dr. Markos left the room for a short period. When he came back, the
interrogation shifted from a psychological angle to the illinoiscorruption.net website. Dr. Markos
wanted to know its owner, the author of the posts and the meaning of the word "SURPRISE" on the
March 3'd, 20 I 0, entry of the website. Plaintiff avoided the self-incriminatory questions the best she
could. Afterward. Dr. Markos ended the session. As Plaintiff was stepping out of her psychological
evaluation, she was arrested by unknown Cook County Sherriff Officers. Her Miranda Rights were
never read and the charges against Plaintiff never stated. in handcuffs, was immediately taken
to Cook County Central Intelligence Unit ('"CIU'') for fw1her processing.
40. Once at C!U. Sgt. James Dillon, Investigator Rich Lesiak and investigator Antonio Rubino also tried to
extract self-incriminatory statements from Plaintiff regarding the illinoiscorruption.nel website.
However, Plaintiff wouldn't answer any question and referred all inquiries to her lawyer, Mr. Nick
Albukerk. Two U.S Marshalls also came and asked the same self-incriminatory questions. Plaintiff.
again, wouldn' t answer and referred the U.S. Marshalls to her lawyer. Later that day, she finally leamed
that she was charged of eavesdropping. After being processed, she was transferred to Maywood Jail
where she spent the night.
41. On April 13'
11
, 20 l 0. Mrs. Pamela Taylor filed a criminal complaint against Plaintiff alleging violation of
the Illinois Eavesdropping statute. Worth noting, the complaint was never signed or sworn.
42. On April 13'
11
20 l 0, Investigator Kate 0' Hara successfully obtained a search warrant and an anest
warrant for the charges of eavesdropping against Plaintiff. Judge James Linn signed both warrants.
43. On April 14, 2010, Plaintiff initial bond was set to $30,000 at the bond court.
44. On April20'
11
, 2010, Judge Mary Brosnahan. upon Mr. Robert Podlasek and Julie Gunnigle request. set
Plaintiff' s additional bond to $500,000D for violation of !-Bond conditions.
45. On April27
111
, 2010, Plaintiff was indicted with three counts of recording phone conversations with Mrs.
Pamela Taylor. 720 !LCS 511 4-2(a)( I), and three counts of publishing said conversations on the
illinoiscorruption.net website, 720 ILCS 5/14-2(a)(3). At the indictment, Mrs. Julie Gunnigle was the
state attorney and Mrs. Kate O'Hara was the state's witness.
46. On May 5
11
', 20 I 0, Judge Brosnahan. upon Plaintiff's motion, reduced the bond to $300,000D.
Plaintiff' s final bond became $330.000D. Not being able to post it, Plaintiff remained incarcerated at
the Cook County Jail for more than a year and half.
4 7. On July 26
111
20 I 0, Plaintiff. through her lawyer, was scheduled to argue her motion to dismiss the
computer tampering charges. However, Mr. Pod Iasek and Mrs. Julie Gunnigle switched election to the
Eavesdropping charges.
6
48. On December 13
111
, 20 I 0, Plaintiffs first motion to dismiss the eavesdropping charges was denied by
Judge Brosnahan. The basis of the motion was the statutory exemption under 720 ILCS 5/ 14-J( i).
49. On January It". 201 L Plaintiff's trial on the Eavesdropping charges commenced.
50. On January 13, 20 II, Mrs. Pamela Taylor, testifying for the state, stated that she willingly patticipated
in the conversations. Mrs. Laud in, also testifying for the state, stated that she deleted the audiotape of
the arraignment ' s hearing to preserve memory in her computer. The FBI agent, Dana DePooter,
testifying for the defense, acknowledged receiving an email complaint from Plaintiff regarding the
tampered court transcript.
51 . On January 14
111
, 20 II , Judge Brosnahan, with a jury hung at 7-5. declared a mistrial.
52. On April II '
11
20 II. Judge Steven J. Goebel replaced Judge Mary Brosnahan by order of Chief Judge
Timothy C. Evans .
53. On or about August of20 II , Plaintiff fired her lawyer. Mr. Nick Albukerk, and became, again. ProSe.
54. On August 3 I", 20 ll. Plaintiff. with the help of her friend, filed a motion for standby counsel or
electronic monitoring given that the maximum time allowed for her incarceration was up on October
14'h.2011.
55. On September 14'
11
, 2011. Mr. Robe11 Pod Iasek requested that Plaintiff's eavesdropping legal file
2
be
handed to him in order to redact social security and credit card numbers. Judge Joyce, presiding for
Judge Goebel. upon Plaintiff' s objection, refused to make such a ruling.
56. On September 15'
11
, 2011. Judge David K. Frankland of Sangamon County declared the Eavesdropping
law unconstitutional in People 1: Allison. No. 2009-CF-50.
57. On September 20
111
, 2011 , Mr. Robert Podlasek renewed his request in front of Judge Goebel to acquire
Plaintiffs eavesdropping legal file. Plaintiff objected anew but Judge Goebel overruled and handed
Plaintiff's eavesdropping file to Mr. Podlasek with instructions that third parties social security and
credit card numbers be redacted. However, Mr. Podlasek used the opportunity to remove documents
from Plaintiffs eavesdropping file and ignored Judge Goebel's orders. For instance, Mr. Podlasek
removed police reports and various discovery documents pertaining to the eavesdropping case and left
credit card and social security numbers un-redacted.
58. On September 20'
11
, 20 II. and continuing thereafter, Judge Goebel ' s signed various court orders
allowing Plaintiff to make phone calls to her family oversea. The orders were ignored by Cook County
Jail's administration, although the calls were at the expenses of Plaintiff.
2
Mr. Pod Iasek requested both the computer tampering and eavesdropping legal files. For the sake of this case, Plaintiff limits Mr. Pod Iasek' s
request to that of the eavesdropping file.
7
59. On October 5'
11
, 10 II, during argument on Plaintiffs electronic monitoring motion, Plaintiff told Judge
Goebel that any incarceration at the Cook County Jail past October 14'
11
, 2010, would be
unconstitutional.
60. On October 13'
11
, 20 II , Judge Goebel granted Plaintiff"s motion for electronic monitoring and restricted
Plaintiff to movements pre-approved by either the court or the electronic monitoring program.
61. On October 20'h, 20 II , Plaintiff was released from Cook County Jail and transferred to the electronic
monitoring program. This occurred a week after the lawful detention had expired.
62. On November I 0'
11
, 2011, Mr. Robert Pod Iasek motioned the court to revoke Plaintiff's bond stating that
Plaintiff made an unauthorized movement to her former lawyer and stole her own legal file while at that
lawyer's office. Plaintiff requested leave to reply. Although said request was granted and Plaintiffv,as
given the opportunity to respond within four days, Mr. Podlasek. dissatisfied by the Judge's decision.
called the electronic monitoring program and requested that Plaintiff be put in custody right away.
Unknown Cook County officers anested Plaintiff without a judge's order or probable cause. Plaintiff
vvas sent back to jail.
63. On November 14'
11
2011, Judge Goebel reinstated Plaintiff's bond after reviewing all evidence. That
same day. while still in jail, Plaintiff filed her already typed motion to dismiss the eavesdropping
charges on grounds of unconstitutionality.
64. On November 23'd, 2011 , Plaintiff was released from the Cook County jail and transferred back to the
electronic monitoring program. Plaintiff spent more than 6 months on house arrest. She was released
from the electronic monitoring program on June 20'
11
, 2012.
65. On November 30'\ 2011 , Plaintiff filed an amended motion to dismiss the eavesdropping charges
against her.
66. On February 14'
11
, 2012. Mr. Robert Pod Iasek filed his response to Plaintiff's amended motion to
dismiss.
67. On March 2"ct, 2012. Judge Stanley Sacks of Cook County declared the Eavesdropping statute
unconstitutional in People v. Dre>v. I OCR00046.
68. On March 6'
11
, 2012, Mr. Robert Podlasek motioned the court to have Plaintiff's bond revoked alleging
that Plaintiff forged Dorothy Brown ' s signature and issued unauthorized subpoenas. Judge Goebel put
the case on recall and asked Plaintiff to present evidence against the forgery charges and to bring the
responses to the unauthorized subpoenas. After hearing both arguments, Judge Goebel found no forgery
and confiscated the subpoenas responses tendered by Plaintiff.
69. On March 19'h, 2012. Plaintiff argued her amended motion to dismiss and to declare the Eavesdropping
statute unconstitutional .
8
70. On May 8'
11
2012. the Lnited States Court Of Appeals for the Seventh Circuit in ACUJ r . . Nr.
11-1286. ruled that the Illinois Eavesdropping statute violates substantive First Amendment and Due
Process Rights .
71. On June 19th, 201:2. Judge Goebel heard arguments on the new A CU../ ,._ Almre::s ruling. After the
arguments '"ere o\er. Judge Goebel dismissed Plaintiffs eavesdropping case but omitted to do so
according to Illinois Supreme Court Rule 18. This rule prescribes ho" an Illinoi s Court ought to declare
a statute unconstitutional.
72. On June 25'
11
2012. Plaintiff motioned up her case to request an amended order in compliance'' ith
Illinois Supreme Cour1 Rule 18. Judge Goebel granted Plaintiff's motion.
73. On July 26' ". 2012. Judge Goebel officially dismissed Plaintiff"s eavesdropping charges in a manner
indicative of her innocence.
B. The Malicious Prosecution
74. Mrs. Laurel Laud in deleted the audio-tape of the proceedings\\ hich \\aS crucial e\ idence in Plaintiffs
criminal case. Moreover. although Plaintiff made serious allegations of cour1 transcripts being tampered
at the Official Court Reporters and there was tangible evidence to that effect, neither Mrs. Lisa Madigan
nor Mrs . Anita Alvarez nor Mrs. Marilyn Filishio opened an investigation into the matter. Instead Mrs.
Madigan investigated Plaintiffs ea\ esdropping case as early as Januar; 20 I 0 and Mrs. Alvarez's
investigation foiiO\ved in March of 201 0: which investigations led to the un la\\ful arrest. incarceration
and prosecution of Plaintiff.
75. Theres a huge discrepancy between Cook County Sheriff Police's documents and those presented by
the Cook County State Attorney. Apparent!). Plaintiff was arrested because she supposedly threatened a
public official using the \\Ord --sURPRISE" on her website. The psychological e\aluation \\aS less
about Plaintiff"s mental state but rather getting self-incriminatory statements using the influence of Dr.
Markos. When that failed. Sgt. James Dillon, Investigators Antonio Rubino and Rich Lesial-.. and t\-\ 0
U.S. Marshalls continued the same I ine of questioning when Plaintiff \\as transferred to CI U. lt"s only
when they couldn t get the desired ansv.-ers that the charges \\ere S\\ itched to eavesdropping. Mrs.
Pamela Ta) lor helped in this by filing a criminal complaint that \-\US ne\cr signed or S\\Orn.
9
76. After Plaintifffired her lawyer. she needed to call her famil)' to hire a ne\\ HO\\ever, though the
Cook County Jail once granted a similar request. the jail administration completely ignored Judge
Goebel's orders to let Plaintiff make oversea phone calls.
77. Mr. Robert Podlasek violated Plaintiff's and privileges \\hen he acquired
Plaintiffs eavesdropping legal tile on the basis of a Supreme Court Rule that never existed. Mr.
Pod Iasek also violated Plaintiff's Due Process Rights\\ hen he removed and redacted information he
wasn't supposed to in Plaintiff's eavesdropping file. Finally. Mr. Podlasek unlawfully asked Cook
County Sherriff to arrest Plaintiff in November of 20 II although he didn't have probable cause and
there \\aS no pending arrest warrant against Plaintiff.
78. On September 15'
11
, 20 II . Judge David K. Frankland of Sangamon County declared the Eavesdropping
law unconstitutional. On March 2"d. 2012. Judge Stanley Sacks of Cook County made a similar ruling.
On May 8'
11
2012. the Seventh District Court of Appeals ruled that the Eavesdropping law violated
substantive First and Due Process Rights. Hov.ever. neither Mrs. Lisa Madigan nor Mrs. Anita Al varez
nor Mr. Robert Podlasek moved to dismiss PlaintitT's eavesdropping case based on these rulings.
79. There have been numerous citing of employees at City Hall and at Chicago Tribune who did what
Pia inti IT accused of namely. recording phone con\'ersations without the consent of all patties.
However. neither Mrs. Madigan nor Mrs. Alvarez nor Mr. Dart nor Mr. Pod Iasek ever opened an
investigation into the allegations. let alone prosecute City Hall's emplo: ees or Tribune s Reporters.
C. Plaintiff's Damages
80. Plaintiff has suffered enormous injury as a direct and proximate result of the misconduct of
Defendants alleged in the preceding paragraphs. Plaintiff spent more than 20 months in jail and
about 6 months on house arTest for a crime of which she was completely innocent. Following
her wrongful arrest. incarceration and house confinement. Plaintiff was separated from her
family and friends. lost all proper!) and important academic and legal documents.
81. Plaintiff was wrongly condemned by individuals she came in contact with, which caused
Plaintiff great anguish. shame and humiliation. Plaintiff's incarceration was lonely and arduous.
Given the unfamiliar settings. she suffered dail) rejecti ons. humiliations and indignities.
10
82. In addition to these emotions, Plaintiff was deprived of the opportunity to further pursue her
education and to live as a free citizen. Plaintiff also has an arrest record on the charges.
83 . Following her release from jail, Plaintiff has struggled to forget the humiliations and hardships
while in custody. She suffers constantly from the feeling that life s opportunities have been
stolen from her and has constant nightmares of being arrested and going back to jail on bogus
charges.
84. Plaintiff must also live with lasting psychological damage caused by Defendants, who used a
variety of traumatizing and coercive tactics to extract confessions from her in an attempt to use
her words and website as self-incriminatory statements.
D. Policies and Practices
85. Defendants violated Plaintiff's Constitutional rights and otherwise injured her as a proximate of
their adherence to the following policies and practices:
a. The Illinois Attomey General, Mrs. Lisa Madigan, The Cook County State
Prosecutor, Mrs. Anita Alvarez, the Cook County Sherriff, Mr. Tom J. Dart. showed a
deliberate indifference to training their personnel in the light of the Eavesdropping
statute; specifically its lack of a criminal mental state and its statutory exemption under
720 ILCS 51l4-3(i) didn ' t stop Mr. Dart's employees from arresting and incarcerating
eavesdropping detainees, didn't stop Mrs. Alvarez's prosecutors from prosecuting at least
three individuals and didn't stop Mrs. Madigan ' s employees from assisting and
investigating eavesdropping cases.
b. That deficiency in training caused the Plaintiff' s unlawful arrest, incarceration
and prosecution. Furthermore, the unknown Cook County Sheriff Officers also showed
training' s deficient in November of 20 II , when they arrested Plaintiff without probable
cause and an arrest warrant.
c. Moreover, Mrs. Madigan and Mrs. Alvarez demonstrated a tacit acceptance
and/or authorization of this unconstitutional statute. Mrs. Madigan assisted the state
prosecutors in People v. 1\tfelongo and in People v Allison. Additionally, although the
Allison's Court declared the eavesdropping statute unconstitutional on First and
Fourteenth Amendments grounds, neither Mrs. Madigan nor Mrs. Alvarez moved to
dismiss the still pending People': Drew and People }: Melongo's cases.
d. The Official Court Reporters' policy and practice permitting court reporters to
delete audio-tape of court proceedings even if such tapings constitute crucial evidence in
detennining the accuracy of transcripts greatly injured Plaintiff.
11
e. Plaintiff's injury amounted to present a defense lacking the crucial evidence that
\\as the audio-tape of the challenged transcript. Moreover, the lack of that crucial
evidence caused Plaintiffs unlawful arrest, incarceration and prosecution.
f. By enforcing such a policy and practice. Mrs. Filishio tacitly authorized violating
Plaintiffs Due Process Rights.
86. The abo\'e-described widespread practices and policies. so well-settled as to constitute defciclo
policies at the Illinois Attorney General Office. at the Official Court Reporters. at the Cook
County Sheriff and at the Cook County State Attorney Office during the time period at issue.
existed and thrived because Cook county. Cook County Sheriff. the Ofticial Court Reporters
and the Illinois Attorney General failed to address them.
COUNT I
42 U.S.C. 1983 - Due Process, Fourteenth Amendment
8 7. PlaintitT repeats and re-al leges paragraphs I through 86 as if fully se1 forth herein.
88. As described more fully above, all of the individual Defendants. while acting individually,
jointly and in conspiracy. as well as under color of law and within the scope of their
employment. deprived Plaintiff of her constitutional right to a fair trial.
89. ln the manner described more fully above. Defendants used a statute that lacks a criminal
mental state. deliberately ignored a statutory exemption. fabricated false reports. deleted
evidence and \ iolated Plaintiffs \\ ork-product and anorne: -client pri,i leges. thereby
misleading and misdirecting the criminal prosecution of Plaintiff. Absent these misconducts, the
prosecution of Plaintiff could not and would not have been pursued.
90. As a result ofthis deprivation of her constitutional right to a fair trial. Plaintiff suffered injuries.
including. but not limited to. emotional distress. as is more fully alleged abo,e.
91. The misconduct described in this Count was objectively unreasonable and was undenaken
intentionally with ~ i llful indifference to Pia inti trs constitutional rights.
92. The misconducts described in this Count \vas undenaken pursuant to the policies and practices
of the Illinois Attorney General prosecutors and forensic experts. Cook County SheniffOfficers
and investigators. Cook County State Attorney prosecutors and investigators. Official Court
Reporters and ''as tacitly ratified by policy-makers for Cook County. Cook County Sheniff. the
Official Court Reporters and the Illinois Anorney General with final policymaking authorities.
12
COUNT II
42 U.S.C. 1983- Conspiracy
93. Plaintiff repeats and re-a !leges paragraphs I through 92 as if fully set forth herein.
94. The individual Defendants reached an agreement amongst themselves to falsely charge Plaintiff
with eavesdropping and to deprive Plaintiff of her Constitutional rights. as described above.
95 . Each individual Defendant conspired. and continues to conspire. to use a statute lacking a
criminal mental state and to ignore a statutory exemption which. if considered. would have led
to Plaintiffs more timely dismissal of the false criminal charges as described above.
96. In this manner. the Defendants. acting in concert with other unknown co-conspirators. have
conspired by concerted action to accomplish an unlawful purpose by an unlawful means.
97. In furtherance of the conspiracy. each of the co-conspirators committed overt acts and was an
otherwise willful participant in joint acti\' it:;..
98. As a direct and proximate result of Detendams actions. Plaintiff's rights were violated. She
suffered injuries. including. but not limited to, emotional distress. as is more fully alleged
above.
99. The misconduct described in this Count was undertaken with malice. willfulness and reckless
indifference to Plaintiff's rights.
I 00. The misconducts described in this Count \\aS undertaken pursuant to the policies and
practices of the Illinois Attorney Genera I prosecutors and forensic expe11s. Cook County
Sherriff Officers and investigators. Cook Count) State Attorney prosecutors and investigators.
Official Court Reporters and was tacitly ratified by policy-makers tor Cook County, Cook
County Sheniff. the Official Court Repor1ers and the Illinois Attorney General with final
pol icymaking authorities.
COUNT III
42 U.S.C. 1983- Equal Protection, Fourteenth Amendment
l 0 I. Plaintiff repeats and re-al leges paragraphs I through I 00 as if fully set forth herein.
I 02. As described more fully above. City Hall's employees and Chicago Tribune's reporters recorded
phone conversations without the consent of all parties. However neither the Illinois Attorney General.
nor the Cook County State Attomey. nor the County Sherriff investigated. arrested. incarcerated or
prosecuted said individuals.
l 03. Defendants Lisa Madigan. Anita Al\arez. Robert Pod Iasek. Julie Gunnigle. Investigator Kate
o Hara. Tom J. Dart. Sgt. James Di lion. Investigators Antonio Rubino and Rich Lesiak as well as the
!3
unknown Cook County Sheniff singled out Plaintiff and unlawfully arrested, incarcerated and
prosecuted Plaintiff whereby violating Plaintiff' s Equal protection Rights based on deep-seated
animosity and vindictiveness stemming from the computer tampering case; in which Plaintiff turned
down three plea agreements, had a pending motion to dismiss based on unlawful acts of Mr. Kyle
French and Mr. Podlasek and created a highly-visited website, illinoiscorruption.net, depicting her
wrongful prosecution.
104. The misconduct described in this Count was undertaken with malice, willfulness and
reckless indifference to Plaintiff's rights.
I 05. As a direct and proximate result of these Defendants ' actions, Plaintiff' s rights were
violated. She suffered injuries, including, but not limited to, emotional distress, as is more fully
alleged above.
COUNT IV
42 U.S.C. 1983- Unreasonable Seizure, Fourth Amendment
106. Plaintiff repeats and re-alleges paragraphs l through 105 as if fully set forth herein.
107. As described more fully above, in April of 2010, Sgt. James Dillon, Investigators Antonio
Rubino, Rich Lesiak, Kate O' Hara and the unknown Cook County Sherriff officers unreasonably seized
Plaintiff in violation of the Fourth Amendment of the United States Constitution. In November of 2011 .
unknown Cook County SherTiffOfticers. following Mr. Podlaseks orders also unreasonable seized
Plaintiff in violation of the Fourth Amendment of the United States Constitution.
108. The misconduct described in this Count was undertaken with malice, willfulness and
reckless indifference to Plaintiff's rights.
109. As a direct and proximate result of these Defendants' actions, Plaintiff's rights were
violated. She suffered injuries, including, but not limited to, emotional distress, as is more fully
alleged above.
COUNTY
42 U.S.C. 1983- False Arrest And Imprisonment, Fourth Amendment
II 0. Plaintiff repeats and re-al leges paragraphs l through 109 as if fully set forth herein.
Ill . As described more fully above. Mr. Robert Podlasek, Mrs. Julie Gunnigle. Mrs. Kate O'Hara, Mr.
Tom Dart, Sgt. James Dillon, Investigators Antonio Rubino, Rich Lesiak. and the unknown Cook
County Sherriff officers arrested and caused the confinement of Plaintiff without probable cause in
violation of the Fourth Amendment ofthe United States Constitution.
112. As described more fully above, Plaintiff stayed at the Cook County Jail for more than 20 months,
remained an additional week in jail past her maximum lawful detention, was re-incarcerated for about 2
14
weeks in November of 2011 following an arrest without probable cause and warrant and was confined
for more than six months at her house under electronic monitoring.
113. The misconduct described in this Count was unde1taken with malice, willfulness and
reckless indifference to Plaintiff's rights. The above Defendants acted with the intention to
confine Plaintiff within fixed boundaries, the above Defendants' actions directly or indirectly
resulted in Plaintiffs confinement, Plaintiff was aware of the confinement.
114. As a direct and proximate result of the above Defendants ' actions, rights were
violated. She suffered injuries, including. but not limited to, emotional distress. as is more fully
alleged above.
COUNT VI
42 U.S.C. 1983 - Free Speech, First Amendment
115. Plaintiff repeats and re-a !leges paragraphs 1 through I 14 as if fully set forth herein.
116. As described more fully above, the Defendants, while acting individually, jointly and in
conspiracy, as well as under color of law and within the scope of their employment. deprived
Plaintiff of her constitutional right to free speech by prosecuting Plaintiff based on what she
posted on the il/inoiscorrup!ion.neT website.
117. The misconduct described in this Count was undertaken with malice, willfulness and
reckless indifference to Plaintiff's rights.
118. As a direct and proximate result of Defendants actions, Plaintiff's rights were violated.
She suffered injuries. including, but not limited to, emotional distress, as is more fully alleged
above.
COUNT VII
42 U.S.C. 1983- Freedom of Press, First Amendment
119. Plaintiff repeats and re-a lieges paragraphs I through 118 as iffully set forth herein.
120. As described more fully above, the Defendants, while acting individually, jointly and in
conspiracy. as well as under color of law and within the scope of their employment, deprived
Plaintiff of her constitutional right to freedom of press by targeting Plaintiff and the
i//inoiscorruption.nel website.
121. The misconduct described in this Count was undertaken with malice, willfulness and
reckless indifference to Plaintiffs rights.
122. As a direct and proximate result of Defendants' actions, Plaintiff's rights were violated.
She suffered injuries. including, but not limited to, emotional distress. as is more fully alleged
above.
15
COUNT VIII
.n U.S.C. 1983- Petition Right, First Amendment
123. Plaintiff repeats andre-all eges paragraphs l through 122 as if fully set forth herein.
12-+. As described more fully abO\'e. the Defendants. ''bile acting indiYiduall). jointly and in
conspiraC). as well as under color of Ia\\ and within the scope of their employment. depri,ed
Plaintiff of her constitutional right to petition the government for redress of grievances given
that evidence obtained from eavesdropping can't be used in any court proceedings.
125. The misconduct described in t h i ~ Count was undertaken'' ith malice.'' illfulness and
reckless indifference to Plaintiff's rights.
126. As a direct and pro:-;irnate result of the Defendants" actions. Plaintiff's rights were
violated. She suffered injuries, including. but not limited to. emotional distress. as is more u l l ~
alleged abo\'e.
COUNTVllll
State Law Claim - Malicious Prosecution
127. Plaintiff repeats and re-al leges paragraphs 1 through 126 as iffully set forth herein.
128. As described more fully above, Defendants caused Plaintiff to be subjected to judicial
proceedings for'' hich there was no probable cause. These judici al proceedings \\ere instituted
and continued maliciously. resulting in injury. and all such proceedings \\ere terminated in
Plaintifls favor in a manner indicative of innocence.
129. Defendants also accused Plaintiff to be the perpetrator of criminal acti\ ities kno'' ing
those accusations to be without probable cause given that Plainti tl ''as charged '' ith a statute
that lacl-;s a criminal mental state and that she was exempted from prosecution because her
recordings were made to prove a crime against her.
130. Mrs. Pamela Ta) lor. Mrs. Laurel Laud in. Mr. K: le French. Mrs. Amber Haqqani. Mr.
Rober1 Podlasek. Mrs. Julie Gunnigle and Investigator Kate oHara actions were aimed at
silencing Plaintiff by sending her to jail. Sgt. James Dillon. investigators Antonio Rubino and
Rich Lesiak and the unkno"" n Cook County Sherriff Officers later made statements about
Plaintitrs alleged culpability\\ ith the knowledge that such statements \vere unfounded and
false. The Defendants in this count also fabricated evidence, withheld exculpatory information.
deleted crucial e\ ide nee and violated Pia inti If's "ork-product and an orne) -c I ienr privileges.
131. The misconduct described in this Count "as undertaken "ith mal ice. willfulness and
reckless indifference to Plaintiff's rights.
16
132. As a direct and proximate result of the above Defendants actions. Plaintiff"s rights v.ere
violated. She suffered injuries, including. but not limited to, emotional distress. as is more full:
alleged above.
COUNT X
State Law Claim- Civil Conspiracy
133. Plaintitfrepeats andre-alleges paragraphs I through 132 as iffully set forth herein.
13-1. As described more fully above. the Defendants. acting in concert with other unknm\ n co-
conspira!Ors. ha,e conspired b) concerted action to accomplish anunla,,ful purpose b;.
unlawful means.
135. In furtherance of the conspiracy. each of the co-conspirators committed overt acts and
\\as an othemise willful panicipant in joint activity.
136. The misconduct described in t i ~ Count ''as undertaken'' ith malice.\\ illfulness and
reckless indi lference to Plaintiff's rights.
137. As a proximate result of the Defendants conspiracy. Plaintiff's rights were violated. She
suffered injuries, including. but not limited to. emotional distress. as is more fully alleged
above.
COUNT XI
State Law Claim- Intentional Infliction of Emotional Distress
13 8. Pia inti fl repeats and re-a lieges paragraphs I through 13 7 as i r full) set forth herein.
139. The acts and conduct of Defendants as set forth above \\ere extreme and outrageous. Defendants
intended to cause or were in reckless disregard of the probabilit) that their conduct would cause severe
emotional distress to Plaintiff: as is more fu ll y alleged above.
140. The Defendants actions and conduct did directly and proximately cause severe emotional
distress to Plaintiff. and thereby constituted intentional infliction of emotional distress.
1-+!. The 111 isconduct described in this Count v..as undertaken with mal ice. "i llfulness and
reckless indifference to Plaintiff's rights.
142. As a proximate result of the Defendants' actions. Plaintiffs rights \\'ere violated. She
suffered injuries. including. but not limited to, emotional distress. as is more fully alleged
above.
COUNT XII
State Law Claim - Consumer Fraud and DeceptiYe Business Practices
1-+3. Plaintillrepeats andre-alleges paragraphs I through l-+2 as if fully set forth herein.
17
144. The Official Cowt Reporters otlice tampered v.ith Plaintitl's transcript and deceived and misled
Pia inti ff by conceal in g. veiling and misrepresenting the facts of the merchandise.
145. Mrs. Laurel Laudin. acting as an employee of the Official Court Reporters Office. deleted the
original audio-tape of the transcript to conceal and suppress the tacts of the purchased merchandise.
Mrs. Pamela Taylor. acting as an assistant administrator of the Omcial Court Reporters office. stood b)
Mrs. Laurel Laudin's actions.
146. The misconduct described in this Count \\aS undertaken malice. willfulness and
reckless indifference to Plaintiffs rights.
147. As a proximate result of the Official Court Reporters Offices actions. Plaintiff's rights
were violated. She suffered injuries. including. but not limited to. emotional distress. as is more
fully alleged abo\ e.
COUNT XIII
State Law Claim -Breach Of Fiduciary Duty
148. Plaintitfrepeats andre-alleges paragraphs I through 147 as if fully set forth herein.
149. As described more fully abO\ e. Dr. Markos and Plaintiff had a doctor-patient relationship during
and after the psychological evaluation. However. Dr. Markos used the ps:vchological examination as a
mean to help the state prosecutors in Plaintiff's ongoing criminal irl\'estigation. In doing so. Dr. Markos
abused Plaintiff's trust and violated the doctor-patient privilege he had \\ ith her.
150. The misconduct described in this Count was undertaken with malice. willfulness and
indifference to Plaintiff's rights.
151. As a proximate result of Dr. Markos actions. Plaintiffs rights \\ere \iolated. She suflered
injuries. including. but not limited to. emotional distress, as is more fully alleged above.
COUNT XIV
State Law Claim- RespondeAt Superior
152. Plaintiff repeats andre-alleges paragraphs I through 151 as if fully set for1h herein.
153. At all times relevant hereto. Defendants \vere members or agents of either the Illinois
Attorne: General. or Cook Count). or the Cook Count) Sherriff or the Official Court Reporters.
ithin the scope of their employment and under color of Ia\\ .
!54. Defendants Illinois Attorney General Otlice. Cook County. Cook County Sherriff and the
Official Coun Reporters are liable as principals for all torts committed by their agents.
COUNT XV
State Law Claim- Indemnification
155. Plaintiff repeats andre-alleges paragraphs I through 15-1 as if full: set forth herein.
18
Donald Peters
From:
Sent :
To:
Cc:
Subject :
Importance
Caro Sptzzlr't ::sor::.z n' sal' :rgj
V'!eC"esda, .1 <J:. i :>'lV"i <;, 2- PM
Brta" Sale'"10 ::lpet.:rs'Q :'lnl<crttt::al cc:>1
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RE Tha..,k
Exhibit 8
Dear Rr'idll drHI Don - UpdatP - Dct. ' -; IHI'' today - AllyG and SI,Jtt I'd ty (Dick Devin!' i,"
personal fl'itnd)- kt"eping closf L;.tJo.; CJ/1 progess- Plea<;o kt'"P t1ll tint:s availabl'
1,ill neec1 nd yolw audits Don ,v;.Jp could you for..,ar-rl IJ,:re I:J VillU' or Rob<?f'l our Ac 1 t >
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\JILL COi'-11:: HJ 11-1!'\!U. AND DO AtJIJITS AT NO COST!
THEY hllLL KLLP /\LL DOCS AS LVlDLNC! I'HOI'-1 THOSE AUDllS.So it ', to do nolltil ll:
ca J l po 1 l c P r 1 ,.q 1 r 1
Kind of 1Ikt ,1 '1-1-1 tor' t.llllfWI' ing.
Cvrol
Carol J Spiulrri
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SALF
Save A Life Foundation
Mav os 2006
\acirmal HeadquJutt"
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tPc"rtr.i>n< '" 0ur w!'b Stle nePO' afler dPa'' o! nJr !T Di'l'<ior :was. Robert Ha"
subcontractPd Annabel Metonqo to provide roolwor, support and mstntain m,r nard Rnd softw;;re
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verue:l 01' C0<'1pt.:t' and ex1t t:r to the dOOr Smce Ms. Melongo naa knowleOQe 10 ali our
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rnvesttga\lon wf. eli our fi1es. cata b!scs tl(;., nad oeen deleted Throughout the da) Ms
rJeo,go to :nP otilf,R t1mAs and phon eo tolalmg four 1trnes, wanitng to see only me from
Fnday through S"ndy mnrninn Mr Davos ;,nd vendors Tr.te Consulttng 11nd Critical Technology
SoiJt1ons worx.ed contmuar y 10 recover tha missing ccmpt.ter fdes unsuccessluily
"'av Jncl !Mf rererveo a d1sturbing e-mail fmm MPion:J" H"r -..rn;ul
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!56. Illinois Ia'" prO\ ides that pub! ic entities are directed to pa: any tort judgment from
compensatory damages for \\ hich employees are I iable within the scope of their employment
activities.
157. At all times rele,ant hereto. Mrs. Anita Al\arez. Dr. Marthe\\ Markos. Mr. Robert
Podia ek. Mrs. Julie Gunnigle and investigator Kate o Hare were employees of Cook County
who acted within the scope of their employment in committing the misconduct described
herein.
158. At all times rele\ant hereto. Mr. Tom J. Dart. Sgt. James Dillon. imestigators Antoni o
Rubio and Rich Lesiak and the unknO\vn Cook County Sherriff Officers were employees ofthe
Cook County Sherriff vvho acted v, ithin the scope of their employment in committing the
misconduct described herein.
159. At all times relevant hereto .. Mrs. Marilyn rilishio, Mrs. Pamela Taylor and Mrs. Laurel
Laudin were employees of the Ofticial Court Reporters who acted within the scope of their
employment in committing the misconduct described herein.
160. At all times relevant hereto. Mrs. Lisa Madigan. Mr. Kyle French and Mrs. Amber
Haqqani were employees of the Illinois Attorney General Office who acted within the scope of
their employment in committing the misconduct described herein.
WHEREFORE. Plaintiff Annabel K. Melon go respectfully requests that this Court enters judgment in
her favor and against Defendants. awarding compensatory damages for the injuries that she has suffered.
costs and reasonable attorneys fees. and puniti\'e damages against each of the indi' idual defendant:, in
their individual capacities: and lor such further and additional relief as this Court may deem appropriate
and just.
Plaintiff demands trial by jury.
Annabel K. Melongo
P.O Bo:-.. 5658
Chicago. IL 60680
312-415-6632
JURY DEMAND
19
Respectfully submined.
By: Annabel K. Melongo, ProSe.
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