BEFORE THE BOARD OF FIRE AND POLICE COMMISSIONERS

OF THE VILLAGE OF OAK BROOK, ILLINOIS

IN THE MATTER OF CHARGES )

AGAINST OFFICER ) No.
STEPHEN PETERSON )

STATEMENT OF CHARGES

NOW COMES Thomas Sheahan, Chief of Police of the Village of Oak Brook,

Illinois, and makes the following statement of charges against Officer Stephen Peterson,

of the Oak Brook Police Department. Police Chief Thomas Sheahan (hereinafter “Chief

Sheahan”) requests that the Board of Fire and Police Commissioners of the Village of

Oak Brook (hereinafter “Board”) set a hearing date on said charges and to take

appropriate action in accordance with the provisions of 65 ILCS 5/10-2.1-17 and the rules

and regulations of the Board of Fire and Police Commissioners of the Village of Oak

Brook.

Jurisdiction

1. Chief Sheahan at all times relevant to the bringing of these charges was

and is the duly appointed Chief of Police for the Village of Oak Brook.

2. Officer Stephen Peterson (hereinafter “Officer Peterson”) is a duly

appointed and qualified member of the Village of Oak Brook Police Department

(hereinafter “Department”).

3. At all times mentioned herein the Board was in existence and acting under

the authority of 65 ILCS 5/10-2.1-1, et seq., and its own Rules and Regulations.

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 Statement of Facts

Background on Disappearance of Stacy Peterson

4. On October 20, 2007, Officer Peterson’s wife, Teresa Peterson, had a

conversation with Stacy Peterson, the wife of Officer Peterson’s father, Drew Peterson, at

Drew and Stacy’s home. During this conversation, Stacy Peterson told Teresa Peterson

that she wanted out of her marriage to Drew Peterson.

5. Nine days later, on Monday, October 29, 2007, at approximately 9:00

a.m., Officer Peterson received a telephone call at his home from Drew Peterson. During

that telephone call, Drew Peterson told Officer Peterson that Drew Peterson’s wife, Stacy

Peterson, had called him the night before and told him that she had left him for another

man, gone on vacation, and would deal with Drew Peterson when she got home. Drew

Peterson also told Officer Peterson during that telephone call that Stacy Peterson had

taken with her $25,000 and the title to the couple’s home.1

6. At approximately 9:00 p.m. on October 29, 2007, Drew Peterson again

called Officer Peterson at home and stated that Stacy Peterson still had not returned home

and that Stacy’s family had filed a missing person report with the police.

7. On Tuesday, October 30, 2007, at approximately 7:00 a.m. or 7:30 a.m.,

Drew Peterson called Officer Peterson and told him that local news outlets were running

a news story about Stacy Peterson’s disappearance. During that same telephone call,

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Attached as Exhibit 1 is the Illinois State Police Report outlining the activities of Officer
Peterson immediately after the disappearance of Stacy Peterson. During his internal
interrogation Officer Peterson affirmed the accuracy of the facts in the Illinois State
Police Report, with one exception. Officer Peterson stated that he last saw Stacy
Peterson when he and his wife visited Drew and Stacy’s home on October 20, 2007, not
October 27, 2007, as indicated in an Illinois State Police report. This error was noted in a
subsequent Illinois State Police report.
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Drew Peterson told Officer Peterson that he was going to bring some of his guns to

Officer Peterson’s home.

8. At approximately 7:30 a.m. that same day, October 30, 2007, Drew

Peterson arrived at Officer Peterson’s home with three firearms contained in two separate

gun cases: a Colt AR-15 .223-caliber rifle, an Ithasa 12-gauge shotgun, and a Magnum

Research .22-caliber rifle.

9. The AR-15 rifle had an 11.5 inch barrel, 4.5 inches shorter than the

standard barrel length of 16 inches on that model weapon used by the Oak Brook Police

Department.

10. Officer Peterson is familiar with the AR-15 model weapon because he

typically keeps such a weapon in an Oak Brook Police Department patrol car. Officer

Peterson is trained and qualified by the Department in the use of the AR-15 rifle.

11. When Drew Peterson arrived at Officer Peterson’s home with the three

guns, he told Officer Peterson that he knew the police would be looking at his house and

he did not want anything to happen to these particular guns because they were his

“favorites.” Drew Peterson further told Officer Peterson that the story of Stacy’s

disappearance would be all over the news.

12. After opening the two gun cases and looking at the weapons, Officer

Peterson concealed the weapons, contained in two separate gun cases, in the closet of a

spare bedroom of his home.

13. Officer Peterson admitted in his internal interrogation that he did not

possess Drew Peterson’s guns for any purpose related to his law enforcement duties as a

police officer for the Village of Oak Brook.

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 14. Officer Peterson did not alert any law enforcement authorities, including

the Illinois State Police or Chief Sheahan, or any other supervisor at the Oak Brook

Police Department, that he and Drew Peterson had concealed three guns, including an

AR-15 with an 11.5 inch barrel, in his home in order to prevent law enforcement from

discovering those guns during a search of Drew Peterson home in connection with Stacy

Peterson’s disappearance. Instead, Officer Peterson willingly concealed his father’s guns

in a spare bedroom of his home and alerted no one to their location.

15. Later that same day, October 30, 2007, Drew Peterson called Officer

Peterson and told Officer Peterson to come to his home.

16. At approximately 2:00 p.m. that day, October 30, 2007, Officer Peterson

arrived at Drew Peterson’s home where Drew Peterson was present with his two young

children. While Officer Peterson was present at Drew Peterson’s home, Drew Peterson

told Officer Peterson that he wanted Officer Peterson to take all four of his children in

case of his arrest. Drew Peterson gave Officer Peterson the telephone numbers of two

lawyers to call if he were arrested, as well as personal financial information regarding his

bank accounts, trust funds, etc. Drew Peterson also gave Officer Peterson three checks

totaling $236,800, including a $225,000 check drawn on a home equity line of credit

Drew Peterson had established on his home. The $225,000 check was dated October 29,

2007. Drew Peterson told Officer Peterson that he wanted Officer Peterson to have this

money to assist him in caring for Drew Peterson’s children and also so that no one else

could access it. Drew Peterson told Officer Peterson not to deposit the checks until Drew

Peterson instructed him to do so. After accepting these checks from Drew Peterson,

Officer Peterson went home.

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 17. After receiving checks totaling $236,800 from his father, Officer Peterson

still did not alert law enforcement authorities to the fact that he had concealed three of his

father’s guns, including an AR-15 with an 11.5 inch barrel, in his home in order to

prevent law enforcement from discovering those guns during a search of Drew Peterson’s

home in connection with Stacy Peterson’s disappearance.

18. By Thursday, November 1, 2007, there was intense media coverage of

Stacy Peterson’s disappearance and it was widely speculated in the news media that

Drew Peterson was a suspect in Stacy’s disappearance.

19. On November 1, 2007, the Illinois State Police executed a search warrant

at Drew Peterson’s home in connection with their investigation of Stacy Peterson’s

disappearance. During this search, Drew Peterson called Officer Peterson and told him to

pick up Drew’s children at the home of Drew’s neighbor. After receiving this phone call

from Drew Peterson during the search of Drew’s home, Officer Peterson still did not alert

law enforcement authorities to the fact that he had concealed three of his father’s guns in

his home in order to prevent law enforcement from discovering them during their search

of Drew Peterson’s home.

20. During the search of Drew Peterson’s home, members of the Illinois State

Police located four unloaded magazines for the AR-15 that Officer Peterson had

concealed in his home on October 30, 2007. A State’s Attorney Investigator asked Drew

Peterson where the AR-15 was located and Drew Peterson responded, “I knew you guys

were coming and I took it to my son’s house Tuesday.”

21. Also on November 1, 2007, the day his father’s home was searched by the

Illinois State Police, Officer Peterson attempted to deposit the three checks Drew

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Peterson had given to him on October 30, 2007. The two checks for smaller amounts

were honored but the $225,000 check drawn on Drew Peterson’s home equity line of

credit was not honored because the line of credit had a maximum amount of $220,000.

Drew Peterson realized his mistake when he spoke with Officer Peterson on November 1,

2007, just after Officer Peterson attempted to deposit the check, and he corrected the

mistake shortly thereafter by providing Officer Peterson a second check for $215,000 on

the home equity line of credit. This second check cleared and the funds were deposited

in Officer Peterson’s personal checking account sometime during the week of November

4, 2007.

22. On Friday, November 2, 2007, at approximately noon or 12:30 p.m., Drew

Peterson drove to Officer Peterson’s home on his motorcycle. While at Officer

Peterson’s home, Drew drafted a will in which he bequeathed his entire estate to Officer

Peterson, signed the title of his motorcycle over to Officer Peterson, and ate lunch. At

approximately 1:45 p.m. that same day, Officer Peterson drove Drew Peterson back to

Drew’s home.

Officer Peterson’s Contact with the Illinois State Police

23. During the morning of November 2, 2007, Illinois State Police arrived at

Officer Peterson’s home to question Officer Peterson about the circumstances under

which he came to possess Drew Peterson’s guns. After answering the door for

investigators, Officer Peterson told them that Drew Peterson had given him the guns

because he expected to be arrested and did not want police to take those particular guns.

Officer Peterson then told the investigators that he did not want to discuss the matter any

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further at his home and he agreed to meet with investigators later that day at the

Bolingbrook Police Department.

24. Despite these statements to investigators on November 2, 2007, at his

interrogation Officer Peterson refused to admit that he had knowledge on November 2,

2007, that Drew Peterson was a suspect in Stacy Peterson’s disappearance:

Q: You understood at some point that week that there was speculation
that your father was involved in the disappearance of Stacy
Peterson, correct?

A: I would say generally based on the fact that they had a search
warrant of his house it could have gone either way. It could have
been they suspected him or they wanted to see what she left
behind. I don’t know.

25. At approximately 3:10 p.m. that same day, November 2, 2007, Officer

Peterson was interviewed by Illinois State Police Special Agent Hardy and Sergeant

Lawson at the Bolingbrook Police Department while Officer Peterson was there turning

over his father’s three guns to the Illinois State Police. During the interview, Officer

Peterson admitted that he concealed three weapons for his father at his home on October

30, 2007, because Drew Peterson expected police to be looking at his house and Drew

did not want anything to happen to his “favorite” guns. Officer Peterson failed to

mention during this interview that on the same day he accepted the guns, October 30,

2007, his father had also given him $236,800 in checks which Officer Peterson had

attempted to deposit the day before, on November 1, 2007.

Officer Peterson’s Failure to Disclose Facts to the Department

26. Officer Peterson never disclosed to Chief Sheahan, or any other supervisor

at the Oak Brook Police Department, that this November 2, 2007, interview even

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occurred, much less the statements he made during that interview. Specifically, Officer

Peterson never disclosed to Chief Sheahan, or any other supervisor at the Oak Brook

Police Department, that he had concealed three of Drew Peterson’s guns in his home so

that they would not be discovered by law enforcement authorities during a search of

Drew Peterson’s home, that he had been interviewed by the Illinois State Police in

connection with Stacy Peterson’s disappearance, or that the Illinois State Police had taken

possession of Drew Peterson’s guns from Officer Peterson.

Officer Peterson’s Grand Jury Testimony

27. On November 29, 2007, Officer Peterson testified before a Will County

grand jury investigating Stacy Peterson’s disappearance. During his testimony, Officer

Peterson testified about concealing three of his father’s guns on October 30, 2007,

accepting $236,800 in checks from Drew Peterson on October 30, 2007, and Drew

Peterson’s visit to his home on November 2, 2007, during which he signed over the title

of his motorcycle to Officer Peterson, told Officer Peterson to raise his children if

anything happened to him, and drafted a will bequeathing his entire estate to Officer

Peterson.

28. On December 13, 2007, Officer Peterson again testified before a grand

jury investigating the disappearance of Stacy Peterson. During his testimony he again

recounted concealing Drew Peterson’s guns in his home and accepting a $220,000 check

from Drew Peterson, both shortly after Stacy Peterson’s disappearance.

Officer Peterson’s Participation in the Drew Peterson’s Gun Charge Prosecution

29. In the spring of 2010, the Will County State’s Attorney’s Office

(hereinafter “SAO”) contacted the Department and informed the Department that Officer

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Peterson was under subpoena to testify at a hearing in the prosecution of Drew Peterson

for violating 720 ILCS 5/24-1(a)(7)(ii) (Unlawful Use of a Weapon) due to Drew’s

possession of the AR-15 rifle which had a barrel length less than the statutory minimum

of 16 inches.

30. This spring 2010 communication from the SAO led to an investigation

where Chief Sheahan learned the details of how Officer Peterson had concealed Drew

Peterson’s guns in his home during the week immediately following Stacy Peterson’s

disappearance and during the Illinois State Police search of Drew Peterson’s home, that

Officer Peterson never notified the Illinois State Police that he possessed these weapons

until they contacted him, that the Illinois State Police had taken possession of those guns

from Officer Peterson, and that one of the guns Officer Peterson had concealed was a

rifle with a barrel length less than 16 inches in violation of Illinois law.

31. Officer Peterson never notified Chief Sheahan, or any other supervisor at

the Department, that he had possessed the AR-15 rifle in the days following Stacy

Peterson’s disappearance, even after he was made aware that Drew Peterson was being

prosecuted by the SAO for possessing that same weapon and, therefore, that his own

conduct may have violated the law.

32. On August 23, 2010, Officer Peterson testified before the Circuit Court of

Will County during a preliminary hearing in Drew Peterson’s prosecution for violating

720 ILCS 5/24-1(a)(7)(ii). During his testimony, Officer Peterson recounted for the

Court that on October 30, 2007, Drew Peterson brought three guns to his home enclosed

in two gun cases because those were Drew Peterson’s “favorite” guns and he did not

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want anything to happen to them. Officer Peterson further testified that he looked at and

kept the guns in his home.

Investigation and Interrogation of Officer Peterson

33. On October 5, 2010, Officer Peterson was interrogated at the Oak Brook

Village Hall in connection with these charges.

34. During the interrogation, Officer Peterson was questioned about why he

failed to disclose during his November 2, 2007, interview by the Illinois State Police that

Drew Peterson had given him $236,800 in checks just three days prior, on October 30,

2007. Officer Peterson responded that he “didn’t think it was relevant.”

35. Officer Peterson also testified during the interrogation that he accepted his

father’s weapons on October 30, 2007, strictly in his personal capacity and that he had no

expectation or understanding that he would utilize those weapons in his capacity as a law

enforcement officer.

36. During the October 5, 2010, interrogation, Officer Peterson stated that he

has discussed the nature and substance of the Chief’s investigation of Officer Peterson’s

conduct with numerous family members and co-workers, including Drew Peterson, his

wife, mother, siblings, and friends including several fellow officers of the Oak Brook

Police Department , and a former member of the Oak Brook Police Department.

37. Officer Peterson testified during the interrogation that he is aware of a

Department General Order prohibiting him from discussing an internal investigation with

any other person, that he does not believe he is excused from complying with that

General Order, and that he intentionally violated it because he “believe[s] that everybody

should know what’s going on here.”

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 38. During the interrogation, Officer Peterson also testified that the statements

he made during his interviews with the Illinois State Police, the recording of his

statements in Illinois State Police reports, and the transcripts of his testimony before the

grand jury in 2007 and the Circuit Court of Will County in 2010, are all accurate.

Officer Peterson’s Disciplinary History

39. Officer Peterson has a long history of disciplinary issues as an Oak Brook

Police Officer. His disciplinary record exhibits a disregard for the Rules and Regulations

of the Department.

40. On April 15, 2005, Officer Peterson received a one day suspension

without pay for sending a mobile data terminal (“MDT”) message from a Department

patrol car to another patrol car inquiring about the physical appearance of a female

civilian.

41. On May 15, 2007, Officer Peterson received a one day suspension without

pay for failing to interact with a member of the public, specifically, a Village of Oak

Brook Trustee, in a manner consistent with the ordinary rules of good conduct and

behavior at the Village Hall while Officer Peterson was off-duty.

42. On May 27, 2008, the Board imposed upon Officer Peterson an eight day

suspension, without pay, for violating Department rules and regulations when he drove a

Department patrol car to the Will County grand jury proceedings to testify on November

29, 2007, and December 13, 2007. With regard to the December 13, 2007, incident,

Officer Peterson had told his immediate supervisor that he was traveling “to court,” but

failed to disclose that the court was in Will County and that the proceedings related to

Officer Peterson’s personal business. The Board found that Officer Peterson’s conduct

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constituted “disingenuous avoidance of the truth prompted by [Officer Peterson’s]

personal agenda or an arrogant disregard for the Orders and Rules and Regulations of the

Police Department.” The eight day suspension was later reduced on administrative

review.

43. Less than six months later, on November 19, 2008, the Board imposed

upon Officer Peterson a twenty-five day suspension, without pay, for violating a

Department General Order and the Illinois Administrative Code when he made

unauthorized LEADS inquiries for personal purposes on fourteen separate occasions.

The Board found that Officer Peterson had run multiple unauthorized LEADS inquiries

on his wife, his friend, his personal vehicle, the personal vehicles of other Oak Brook

police officers, the vehicle used by Deputy Chief Larson, and the vehicle used by the Oak

Brook Village Manager. The Board found “absolutely no credibility in [Officer

Peterson’s] testimony regarding his inability to recollect” running these unauthorized

LEADS inquiries. The twenty-five day suspension was later reduced by agreement

between the Board and Officer Peterson after a ruling by the Circuit Court of DuPage

County remanded the penalty phase of the hearing back to the Board.

Charge 1: Obstruction of and Failure to Disclose Facts to Law Enforcement

Officials (Violation of Illinois Law and Oak Brook Police Department
Rules and Regulations)

44. Chief Sheahan realleges and incorporates by reference paragraphs 1

through 43 of this Statement of Charges.

45. At all relevant times there was in effect an Illinois statute, 720 ILCS 5/31-

1(a), that states as follows:

A person who knowingly resists or obstructs the performance by one

known to the person to be a peace officer, firefighter, or correctional

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 institution employee of any authorized act within his official capacity
commits a Class A misdemeanor.

46. At all relevant times there was in effect within the Department Rule 1.14

that states as follows:

Officers and members shall not interfere with cases being handled by
other officers and members of the Department or by any other
governmental agency unless: (a) Ordered to intervene by a superior
officer, or, (b) The intervening officer and member believes, based upon
information available to him that a manifest injustice would result from
failure to take immediate action.

47. At all relevant times there was in effect within the Department Rule 7.2

that states as follows:

The integrity of a member must be above reproach. Members shall be

truthful.

48. At all relevant times there was in effect within the Department Rule 7.3

which states as follows:

No person has the right to violate the law. When an officer exceeds
his/her authority by unreasonable conduct, he/she violates the sanctity of
the law which he/she is sworn to uphold. All members shall respect and
uphold the law.

49. At all relevant times there was in effect within the Department Rule 14.11

that states as follows:

Members shall conduct themselves in a manner that will foster the greatest
harmony and cooperation between each other and between divisions and
sections of the Department and other governmental departments and
agencies.

50. At all relevant times there was in effect within the Department Rule 14.25

that states as follows:

Members shall report, in writing, to the Chief of Police, through the

Investigations Supervisor, all information in their possession regarding
persons and places suspected of being involved or connected with

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 violations of federal, state, county or municipal laws and ordinances
relating to criminal matters or vice operations. Such reports shall be
submitted before the conclusion of the tour of duty during which the
member received the information or at the first opportunity in cases where
the information was received while the member was off duty.

51. At all relevant times there was in effect within the Department Rule 15.20

that states as follows:

Department personnel shall avoid actions which give the appearance of

impropriety. Activities on or off duty engaged in by Department members
which indicate instability of character or personality shall subject the
officer to disciplinary action.

52. At all relevant times Article 18 of the Department Rules and Regulations

listed the actions that will subject a member to discipline. Those actions include:

18.2 “Violation of any federal, state, county or municipal ordinance.”

18.19 “Failure to maintain an impartial attitude toward persons coming to

the attention of the police.”

18.36 “Violation of Department rules and regulations.”

18.39 “Any act which brings or tends to bring the individual or the
Department into disrepute.”

18.40 “Any other act or omission contrary to good order and discipline of
the department.”

53. Officer Peterson violated 720 ILCS 5/31-1(a) and Department Rules 7.2,

7.3, 14.11, 14.25, 15.20, 18.2, 18.19, 18.36, 18.39, and 18.40 when he failed to alert law

enforcement authorities, including the Oak Brook Police Department, that Drew Peterson

was taking steps to conceal his guns, when he concealed Drew Peterson’s guns in his

home with the specific intention of preventing law enforcement authorities from

discovering them during a search of Drew Peterson’s home, and when he failed to

disclose to law enforcement authorities, including the Department, that Drew Peterson

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had given him checks totaling $236,800 the day after Stacy Peterson was reported

missing.

54. The foregoing conduct of Officer Peterson constitutes a clear violation of

Illinois law and the Department Rules and Regulations. As such, Officer Peterson’s

conduct constitutes some substantial shortcoming which renders his continuance and

employment in some way detrimental to the discipline and efficiency of the public

service and something which the law and sound public opinion recognize as good cause

for him to no longer occupy his position.

Charge 2: Possession of Unlawful Weapon

(Violation of Illinois Law, Oak Brook Police Department General Order, and Oak
Brook Police Department Rules and Regulations)

55. Chief Sheahan realleges and incorporates by reference paragraphs 1

through 43 of this Statement of Charges.

56. At all relevant times there was in effect an Illinois statute, 720 ILCS 5/24-

1(a)(7)(ii), that states as follows:

A person commits the offense of unlawful use of weapons when he

knowingly sells, manufactures, purchases, possesses or carries any rifle
having one or more barrels less than 16 inches in length or a shotgun
having one or more barrels less than 18 inches in length or any weapon
made from a rifle or shotgun, whether by alteration, modification, or
otherwise, if such weapon as modified has an overall length of less than 26
inches.

57. Under 720 ILCS 5/24-2(c)(1), peace officers in the performance of their

official duties are exempted from the prohibitions of 720 ILCS 5/24(1)(a)(7)(ii).

58. At all relevant times there was in effect within the Department General

Order 96-0030 that states in part:

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 All duty weapons and magazines will be issued by the Oak Brook Police
Department…. Off Duty firearms are limited to handguns and must be
approved by the Range Master.

59. At all relevant times there was in effect within the Department Rule 7.3

which states as follows:

No person has the right to violate the law. When an officer exceeds
his/her authority by unreasonable conduct, he/she violates the sanctity of
the law which he/she is sworn to uphold. All members shall respect and
uphold the law.

60. At all relevant times there was in effect within the Department 15.20 that

states as follows:

Department personnel shall avoid actions which give the appearance of

impropriety. Activities on or off duty engaged in by Department members
which indicate instability of character or personality shall subject the
officer to disciplinary action.

61. At all relevant times Article 18 of the Department Rules and Regulations

listed the actions that will subject a member to discipline. Those actions include:

18.2 “Violation of any federal, state, county or municipal ordinance.”

18.36 “Violation of Department rules and regulations.”

18.39 “Any act which brings or tends to bring the individual or the
Department into disrepute.”

18.40 “Any other act or omission contrary to good order and discipline of
the department.”

62. Officer Peterson violated 720 ILCS 5/24-1(a)(7)(ii), G.O. 96-0030, and

Department Rules 7.3, 15.20, 18.2, 18.36, 18.39, and 18.40 when he intentionally

concealed in his home a Colt AR-15 with a barrel 4.5 inches shorter than the statutory

minimum of 16 inches for no purpose related to his law enforcement duties, and then

failed to notify Chief Sheahan, or any other supervisor at the Oak Brook Police

Department, that he possessed this weapon.

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 63. Officer Peterson also violated 720 ILCS 5/24-1(a)(7)(ii), G.O. 96-0030,

and Department Rules 7.3, 15.20, 18.2, 18.36, 18.39, and 18.40 when he failed to notify

Chief Sheahan, or any other supervisor at the Oak Brook Police Department, that he

possessed the Colt AR-15 in the days following Stacy Peterson’s disappearance, even

after he became aware that the Will County State’s Attorney’s Office was prosecuting

Drew Peterson for possessing this same weapon.

64. The exemption contained in 720 ILCS 5/24-2(c)(1) does not apply to

Officer Peterson’s conduct because he expressly admitted that he possessed Drew

Peterson’s Colt AR-15 rifle for no purpose related to his law enforcement duties.

65. The foregoing conduct of Officer Peterson constitutes a clear violation of

Illinois law and the Department Rules and Regulations. As such, Officer Peterson’s

conduct constitutes some substantial shortcoming which renders his continuance and

employment in some way detrimental to the discipline and efficiency of the public

service and something which the law and sound public opinion recognize as good cause

for him to no longer occupy his position.

Charge 3: Failure to Keep Internal Investigation Confidential

(Violation of Oak Brook Police Department General Order)

66. Chief Sheahan realleges and incorporates by reference paragraphs 1

through 43 of this Statement of Charges.

67. At all relevant times there was in effect within the Department General

Order 96-0036 that states in part:

Section III(F)(5). Investigations of a complaint against a department

member should be conducted in a manner that best reveals the facts while
preserving the rights and dignity of all persons involved and maintaining
the confidential nature of the investigation.

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 68. At all relevant times there was in effect within the Department Rule 6.6

which states as follows:

Members shall not discuss or impart confidential information to anyone

except those for whom it is intended, or as directed by their supervisors, or
under due process of law.

69. At all relevant times there was in effect within the Department Rule 6.7

which states as follows:

Members shall not make known to any person the contents of any
confidential directive or order which they receive, unless so required by
the nature of the order.

70. At all relevant times Article 18 of the Department Rules and Regulations

listed the actions that will subject a member to discipline. Those actions include:

18.30 “Unauthorized dissemination or release of any information

concerning essential police matters to the press, public or others.”

18.36 “Violation of Department rules and regulations.”

71. Officer Peterson violated G.O. 96-0036, and Department Rules 6.6, 6.7,

18.30, and 18.36 when he, with full knowledge that he was violating G.O. 96-0036,

deliberately discussed the nature and substance of the Chief’s investigation of his conduct

with numerous family members and co-workers, including Drew Peterson, his wife,

mother, siblings, and friends including several fellow officers of the Oak Brook Police

Department, and a former member of the Oak Brook Police Department.

72. The foregoing conduct of Officer Peterson constitutes a clear violation of

Illinois law and the Department Rules and Regulations. As such, Officer Peterson’s

conduct constitutes some substantial shortcoming which renders his continuance and

employment in some way detrimental to the discipline and efficiency of the public

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service and something which the law and sound public opinion recognize as good cause

for him to no longer occupy his position.

Prayer for Relief

WHEREFORE, Chief Sheahan respectfully requests that a hearing be held before

the Board of Fire and Police Commissioners of the Village of Oak Brook, Illinois, and

that the Board terminate Officer Stephen Peterson’s employment as a police officer of the

Village of Oak Brook, Illinois, in accordance with its authority under its own Rules and

Regulations and Section 10-2.1-17 of the Illinois Municipal Code, 65 ILCS 5/10-2.1-17.

____________________________________
Thomas Sheahan, Chief of Police
Village of Oak Brook

October 18, 2010

CHARLES E. HERVAS
KATHLEEN MCNAMARA
HERVAS, CONDON & BERSANI, P.C.
333 WEST PIERCE ROAD, STE. 195
ITASCA, IL 60143
630-773-4774

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