Page 1

IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

JASON GONZALES, )
)
)
Plaintiff, )
)
) No. 2016 C 7915
-vs- )
)
MICHAEL J. MADIGAN, FRIENDS )
OF MICHAEL J. MADIGAN, 13TH )
WARD DEMOCRATIC ORGANIZATION )
SHAW DECREMER, SILVANA )
TABARES, RAY HANANIA, )
JOE BARBOZA and GRASIELA )
RODRIGUEZ, )
)
Defendants. )

This is the discovery deposition of

MICHAEL J. MADIGAN, called as a witness by the
Plaintiff herein, pursuant to the provisions of the
Federal Rules of Civil Procedure pertaining to the
taking of depositions before Kimberly E. Causley,
Certified Shorthand Reporter, of the State of Illinois,
pertaining to the taking of depositions at 151 North
Franklin Street, commencing on September 13, 2018, at
the hour of 11:00 a.m., pursuant to notice and the
agreement of Counsel.
- - o o OO o o - -
 Michael J. Madigan
September 13, 2018
Page 2 Page 4
1 A P P E A R A N C E S: 1
2 ANTHONY J. PERAICA & ASSOCIATES, LTD. 2 INDEX
5130 South Archer Avenue
3 Chicago, Illinois 60632 3
(773) 735-7100 4
4 Email: Www.peraica.com 5 WITNESS
5 BY: MR. ANTHONY J. PERAICA 6 MICHAEL J. MADIGAN
6 Appeared on behalf of the Plaintiff; 7
7
HINSHAW & CULBERTSON 8
8 151 North Franklin Street - Suite 2500 9 DIRECT EXAMINATION BY: PAGE
Chicago,Illinois 60606 Mr. Anthony Peraica..................5
9 (312) 704-3000 10
Email: Avaught@hinshawlaw.com CROSS-EXAMINATION BY:
10
BY: MR. ADAM VAUGHT 11 Mr. Michael Kasper.................240
11 12 REDIRECT EXAMINATION BY:
Appeared on behalf of Michael J. Madigan; Mr. Anthony Peraica.................247
12 13
13 FLETCHER, TOPOL & O'BRIEN 14
151 North Franklin - Suite 2500
14 Chicago, Illinois 60601 - - o o OO o o - -
(312) 704-3191 15
15 Email: Mjkasper@mac.com 16
16 BY: MR. MICHAEL J. KASPER 17
17 Appeared on behalf of Friends of EXHIBITS MARKED FOR IDENTIFICATION
Michael J. Madigan, 13th Ward Democratic
18 Organization; 18
19 EXHIBIT NO. 1.........................61
LAW OFFICE OF SCOTT B. ERDMAN 19 EXHIBIT NO. 2........................133
20 8 South Michigan Avenue - Suite 3500 EXHIBIT NO. 3........................183
Chicago, Illinois 60603 20
21 (312) 263-5700
Email: scotterdman@erdmanlawoffices.com 21
22 22
BY: MR. SCOTT B. ERDMAN - - o o OO o o - -
23 23
Appeared on behalf of Grasiela Rodriguez; 24
24

Page 3 Page 5
1 - Continued- 1 THE VIDEOGRAPHER: This is Nick Paige
2 2 with Advance Video Solutions, Incorporated; 615
3 A P P E A R A N C E S: 3 Berkshire Court, Schaumburg, Illinois. I am the
4
5 DEL GALDO LAW GROUP, LLC 4 operator of this camera.
1441 South Harlem Avenue 5 This videotaped deposition of
6 Berwyn, Illinois 60402 6 Michael J. Madigan is being taken on behalf of the
(708) 222-7000 7 Plaintiff at 151 North Franklin Street, Chicago,
7 Email: sullivan@dlglawgroup.com
8 Illinois on September 13, 2018, approximately
8
9 BY: MR. SEAN SULLIVAN 9 11:06 a.m. as indicate
10 Appeared on behalf of Shaw Decremer. 10 d on the video screen
11 11 This case is captioned Jason Gonzales
12 RICHARD J. PRENDERGAST, LTD. 12 v. Michael J. Madigan, et al.
111 West Washington Street - Suite 1100
13 Chicago, Illinois 60602 13 At this time will all the attorneys
(312)641-0881 14 please identify themselves for the video record.
14 Email: Rprendergast@rjpltd.com 15 MR. PERAICA: Yes. For the record, Anthony
15 16 Peraica P-e-r-a-i-c-a representing Plaintiff, Jason
16 BY: DEIRDRE A. CLOSE
17 Gonzales, who is present at this deposition sitting to
17 Appeared on behalf of Silvana Tabares.
18 18 my left.
19 19 And if I could just go around the
20 ALSO PRESENT: Jason Gonzales (Plaintiff) 20 table to attorneys introduce themselves for the record
21 21 and whom they represent, please.
22 - - o o OO o o - -
23 22 MR. NALLY: Good morning, James P. Nally
24 23 N-a-l-l-y on behalf of Joe Barboza.
25 24 MR. ERDMAN: Scott B. Erdman E-r-d-m-a-n on

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 Michael J. Madigan
September 13, 2018
Page 6 Page 8
1 behalf of Defendant Grasiela Rodriguez. 1 Q I just want to go over some very basic
2 MR. SULLIVAN: Sean Sullivan 2 rules so that we can have a clear record both video and
3 S-u-l-l-i-v-a-n on behalf of the Defendant Shaw 3 written record.
4 Decremer. 4 Please allow me to finish my question
5 MS. CLOSE: Deidre Close C-l-o-s-e on 5 before you begin to answer. If for any reason you do
6 behalf of Silvana Tabares. 6 not understand a question that I'm asking, please let
7 MR. VAUGHT: Adam Vaught V as in Victor 7 me know and I'll try to repeat it, rephrase, break it
8 a-u-g-h-t on behalf of Mr. Madigan. 8 down into component parts.
9 MR. KASPER: And Michael Kasper K-a-s-p-e-r 9 If there are any objections pending,
10 for Defendant Madigan. 10 please allow us to make the record, all attorneys
11 THE VIDEOGRAPHER: And would the court 11 regarding the objections before you begin to answer.
12 reporter identify herself and swear-in the witness. 12 If at any point you need to take a
13 COURT REPORTER: Kim Causley with Causley 13 break to consult with your counsel, to take a bathroom
14 Court Reporting. 14 break or for any reason, all I ask is that you answer
15 Would you please raise your right 15 the question that is pending on the floor -- on the
16 hand? 16 table, and then we can take a break after that.
17 17 question and can answer it, please do so audibly using
18 18 words rather than body shrugs, head nods, mm-hmm,
19 (WHEREUPON, the witness was 19 uh-huh, or any other gestures, it does not make a clear
20 first duly sworn.) 20 record so we want to avoid that.
21 21 Is that understood?
22 22 A I think so.
23 23 Q Thank you.
24 24 Have you reviewed any documents in

Page 7 Page 9
1 MICHAEL J. MADIGAN, 1 preparation for your deposition today?
2 called as a witness herein, having been first duly 2 A I read the deposition of Alderman Quinn and
3 sworn, was examined and testified as follows: 3 the deposition of Tim Mapes.
4 4 Q Any other depositions that you read?
5 5 A No.
6 DIRECT EXAMINATION 6 Q Did you look at any of the pleadings or
7 7 motions?
8 BY MR. PERAICA: 8 A I've read pleadings, yes.
9 Q Can you please state your full name for the 9 Q Did you read the Second Amended Complaint
10 record and spell your last name? 10 that the Plaintiff filed?
11 A Michael J. Madigan M-a-d-i-g-a-n. 11 A Not that I recall.
12 Q Mr. Madigan, as you heard, I represent 12 Q Did you read any of the orders entered by
13 Jason Gonzales, Plaintiff in this case. You and I have 13 Judge Knelly recently in this case or at any point?
14 met before. Good to see you this morning. 14 A Not that I remember.
15 I want to state for the record that 15 Q Beside the two depositions that you
16 this deposition is being taken pursuant to the 16 indicated you went over, did you look at any
17 applicable Federal Code of Civil Procedure, Federal 17 documentation related to the allegations in this case?
18 Rules and the Local Rules of the Northern District of 18 A Not that I remember, no.
19 Illinois including the court order that the judge in 19 Q I'm about talking about any literature, any
20 this case Judge Knelly, entered a protective order 20 financial records, donor records, organizational
21 which was entered yesterday. 21 records, any records that were obtained during
22 Sir, have you given a deposition 22 discovery of this case?
23 before?
23 A Not that I remember.
24 A No.
24 Q I assume you met with your counsel prior

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 Michael J. Madigan
September 13, 2018
Page 10 Page 12
1 to? 1 Representative, any of your Fundraising Committees,
2 A Yes. 2 does Mr. Kasper serve in any other role regarding
3 Q Okay. Besides your attorneys, have you 3 those?
4 spoken to anyone in advance of this deposition? 4 A Not to the best -- the answer is no. To
5 A I spoke to my wife. 5 the best of my knowledge, the is answer no.
6 Q Anyone else? 6 Q I'm just going to go through these names
7 A I may have spoken to some of my children. 7 regarding the attorneys who are working on this case
8 Q Did you talk to any of the other Defendants 8 and the Law Firm of Hinshaw & Culbertson.
9 in this case before your deposition today? 9 Adam Vaught, do you know Mr. Vaught?
10 A No. 10 A I do.
11 Q Did you talk to any of the circulators or 11 Q Do you know him only in relation to this
12 notaries that were involved in the various petitions 12 case or do you know him in any other way?
13 here? 13 A I know him in relation to this case. He's
14 A No. 14 also the husband of a woman who served as Counsel to
15 Q Did you talk any of your donors in advance 15 the Speaker.
16 of this deposition? 16 Q And her name is?
17 A No. 17 A Heather.
18 Q So your family and your counsel would be 18 Q Full name?
19 the only people you spoke with, is that correct? 19 A Vaught.
20 A To the best of my memory. 20 Q Okay. Do you social with Mr. Vaught and
21 Q Okay. With respect to the attorneys who 21 his wife outside of the usual political gatherings?
22 are present in this room, I just want to establish your 22 A No.
23 relationship, if any, to the attorneys. 23 Q Do you know an attorney at Hinshaw
24 You're represented by Michael Kasper, 24 Culbertson by the name of Vince Rizzo?

Page 11 Page 13
1 and also by Hinshaw & Culbertson Law Firm, is that 1 A No.
2 correct? 2 Q Do you know an attorney working on your
3 A I'm represented by Kasper. And you're here 3 case at Hinshaw & Culbertson by the name of Carson
4 on behalf of Hinshaw? 4 Griffis?
5 MR. VAUGHT: Well, on behalf of you but 5 A No.
6 Hinshaw the firm is. 6 Q Do you know an attorney by the name of
7 THE WITNESS: So the answer is yes. 7 Gretchen Sperry?
8 BY MR. PERAICA: 8 A No.
9 Q Okay. Does your attorney Michael Kasper 9 Q Do you know an attorney by the name of
10 serve in any other political function or any other 10 J. Williams Roberts who works at Hinshaw & Culbertson?
11 function with you individually or you in any elected or 11 A I know Mr. Roberts.
12 appointed capacity? 12 Q How do you know Mr. Roberts?
13 A Well, Mr. Kasper is the General Counsel of 13 A Mr. Roberts is an attorney who's
14 the Democratic Party of Illinois. 14 represented me in different matters. At one time he
15 Q I would ask you to please keep your voice 15 was the United States Attorney for the Central District
16 loud so we can have, again, a clear record. 16 of Illinois, prior to that he was the State's Attorney
17 So he's General Counsel for the 17 of Sangamon County. At one time he was the Inspector
18 Democratic Party of Illinois? 18 General of the Legislative Ethics Commission.
19 A The answer is yes. 19 Q Is he still serving in any of those
20 Q Does he serve in any other function? 20 functions?
21 A Not that I recall. 21 A He's no longer the Inspector General.
22 Q Any financial function at all, Mr. Kasper, 22 Q Is he with the State of Illinois in any
23 that is related to the Party, your role on the 23 function?
24 Central -- State Central Committee, Committeeman, State 24 A To the best of my knowledge, no.

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 Michael J. Madigan
September 13, 2018
Page 14 Page 16
1 Q And what case did he represent you on or 1 who is here today.
2 in, Mr. Roberts, that is? 2 Do you know moving on to Richard J.
3 A Those were matters that involved the United 3 Prendergast, do you know him?
4 States Attorney's Office. 4 A Yes, I do.
5 Q Were those civil in nature or criminal in 5 Q And you know that he is the attorney for
6 nature? 6 Miss Tabares, Representative Tabares?
7 A They were not civil. 7 A Yes.
8 Q Are those matters over, completed, 8 Q How long have you known Mr. Prendergast?
9 finished? 9 A Many years.
10 A Yes, they are. 10 Q Multiple decades?
11 Q How about the attorney by the name of 11 A Yes.
12 Robert Shannon S-h-a-n-n-o-n also employed at Hinshaw & 12 Q He has ever represented you in any
13 Culbertson? 13 capacity?
14 A I believe I met him once. 14 A Yes.
15 Q And was that in relation to this case? 15 Q How so?
16 A Yes. 16 A In a matter before the Legislative
17 Q Do you know Mr. Shannon in any other 17 Inspector General.
18 capacity? 18 Q Is that the same case that Mr. Roberts
19 A No. 19 worked on?
20 Q Are you familiar with the Law Firm of 20 A To the best of my knowledge, no.
21 Del Galdo Law Offices? 21 Q So it was a different matter?
22 A Yes. 22 A Again, to the best of my knowledge, yes.
23 Q Do you know Michael Del Galdo, the 23 Q And how long ago was that?
24 principal at that firm? 24 A Approximately three to four, five years

Page 15 Page 17
1 A Yes, I do. 1 ago.
2 Q And how do you know Mr. Del Galdo? 2 Q Is he representing you currently in any
3 A As the practicing attorney many times in 3 official or private capacity?
4 the western suburbs and the southwestern suburbs. 4 A To the best of my knowledge, no.
5 Q Have you or you in any of your capacities 5 Q Was that the only case that he represented
6 ever been represented by Michael Del Galdo or Del Galdo 6 you, the one dealing with the Inspector General
7 Law Office? 7 investigation three or four years ago?
8 A To the best of my knowledge, no. 8 A Well, again, at this time my answer would
9 Q Do you work with Mr. Del Galdo on any 9 be that was the only case, but there may be items that
10 issues regarding the Town of Cicero whether they're in 10 I'm forgetting.
11 political sense or governmental sense? 11 Q Okay. Do you know of an attorney at
12 A The answer is no. 12 Mr. Prendergast's Office by the name of Deirdre
13 Q Do you know another attorney at the Del 13 Close?
14 Galdo Law Firm by the name of Cynthia Grandfield? 14 A No.
15 A No. 15 Q Do you know attorney at the same
16 Q Do you -- at the same law firm, these are 16 Prendergast Office by the name of Michael Laden?
17 the same name -- these are different names from the 17 A I believe I do.
18 same firm. 18 Q How do you know Mr. Laden?
19 Joseph Giambrone, do you know him? 19 A I believe that Mr. Layden was an attorney
20 A No.
20 involved in one aspect of legislative redistricting
21 Q Do you know attorney at Del Galdo Law
21 several years ago.
22 Office by the name of K. Austin Zimmer?
22 Q So it was that last redistricting that took
23 place?
23 A No.
24 A I don't recall whether it was the last or
24 Q Do you know -- well, you met Mr. Sullivan

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 Michael J. Madigan
September 13, 2018
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1 the one before that. 1 campaigns?
2 Q Did he represent you individually or in 2 A To the best of my knowledge, no.
3 your capacity as a State official? 3 Q Are you familiar with the Law Firm Burke
4 A I don't remember. 4 Law?
5 Q Do you know an attorney by the name of 5 A Burke Law?
6 Michael Kreloff? 6 Q Yeah, J. Stalin in particular from that
7 A Yes, I do. 7 firm.
8 Q How do you know Mr. Kreloff? 8 A No.
9 A Well, Mr. Kreloff is active in Democratic 9 Q Mr. Madigan, just a routine question, have
10 politics. At one time he was a Township -- Democratic 10 you ever been charged with any crime involving fraud or
11 Township Committeeman in the northern suburbs, that's 11 dishonesty or perjury or anything dealing with lack of
12 how I would know him. 12 truthfulness?
13 Q Do you know Mr. Kreloff in his capacity as 13 A No.
14 an attorney? 14 Q Are you taking any medications that would
15 A I know he's an attorney. 15 impair your ability to hear, understand, and answer
16 Q Has he -- has Mr. Kreloff ever represented 16 questions today?
17 you in any capacity individually or in your official -- 17 A No.
18 A To the best of my knowledge, no. 18 Q And you do understand you're under oath,
19 Q Please allow me to finish my question. 19 correct?
20 A Yes, I will. 20 A I do.
21 Q Did Mr. Kreloff ever represent you in any 21 Q Are you currently involved in any other
22 official capacity? 22 lawsuit beside this one, civil lawsuit?
23 A Again, to the best of my knowledge, no. 23 A There's a matter filed by a former employee
24 Q Do you know an attorney by the name of 24 of our political committees.

Page 19 Page 21
1 Scott Erdman, who is present here today? 1 Q And who would that be?
2 A Only since I met him in this room today. 2 A Her name is Hampton.
3 Q Do you know that he represents Grasiela 3 Q Elena Hampton?
4 Rodriguez? 4 A So you know her?
5 A Well, you're telling me, so I'll accept it. 5 Q I read the paper.
6 Q Have you ever done business with 6 A Right, and it's at the EEOC.
7 Mr. Erdman in any capacity? 7 Q And who is representing you in that matter?
8 A To the best of my knowledge, no. 8 A Tony, I don't know the name of the law firm
9 Q Have you done any business with Mr. Erdman 9 today. It's a major law firm that does Employment Law.
10 when he was an employee of Cook County? 10 I don't know the name of the law firm.
11 A To the best of my knowledge, no. 11 Q I would ask that that information be
12 Q Do you know attorney James Nally who is 12 provided.
13 here on behalf of Joe Barboza? 13 A Sure.
14 A I know the name, and I think I've met him 14 Q Any other lawsuits besides the matter
15 for the first time today. 15 pending before EEOC brought by Elena Hampton?
16 Q Has Mr. Nally ever done work for you 16 A Not to my -- to the best of my knowledge,
17 individually in anyway? 17 no.
18 A To the best of my knowledge, no. 18 Q Have you been involved either as a
19 Q Did Mr. Nally ever represent any of the 19 Plaintiff or a Defendant in any lawsuits from
20 committees you're involved in? 20 April 2015 up until present day that were concluded
21 A To the best of my knowledge, no. 21 where you were either a Plaintiff or a Defendant?
22 Q Did Mr. Nally represent you in any 22 A To the best of my knowledge just the ones
23 political capacity for yourself as a candidate or 23 that we talked about.
24 anybody else that you support in the political 24 Q No others?

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 Michael J. Madigan
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1 A Again, to the best of my knowledge, no. 1 A Yes.
2 Q Okay. Your middle initial J. stands for 2 Q Andrew Madigan?
3 Joseph? 3 A Yes.
4 A Yes. 4 Q All right. Have you had or adopted any
5 Q And how old are you now? 5 other children?
6 A 76. 6 A No.
7 Q And what is your date of birth? 7 Q Now, Lisa Madigan is still currently the
8 A April 1942. 8 Attorney General?
9 Q What is your marital status? 9 A Yes, she is.
10 A Married. 10 Q Of the State of Illinois.
11 Q What is your wife's name? 11 What about Tiffany Madigan, where is
12 A Shirley. 12 she employed?
13 Q Is she known as Shirley Madigan? 13 MR. VAUGHT: Tony, I'm objecting. We're
14 A Yes, she is. 14 getting past -- we're getting in -- you know, the
15 Q What was your wife's maiden last name? 15 protective order says not to get into the family other
16 MR. VAUGHT: Tony, I'm going to raise an 16 than into the Attorney General any involvement
17 objection. The protective order says we're not going 17 regarding the 2016 primary. There's no need for the
18 to get into families. 18 background.
19 MR. PERAICA: It is just background 19 MR. PERAICA: Well, it has to do with State
20 information. I'm not getting into that otherwise. 20 acts and the positions that the deponent holds. So I
21 MR. VAUGHT: Okay. 21 don't intend to spend a lot of time on this, but
22 THE WITNESS: Romago. 22 briefly, I think as a result of the Counts in the
23 23 Amended Complaint that were sustained, I'm able to ask
24 BY MR. PERAICA: 24 those questions.

Page 23 Page 25
1 Q How do you spell that? 1 MR. VAUGHT: Well, yesterday the Court
2 A You're going to cause a problem for me if I 2 entered an order that said the scope of the deposition
3 can't spell my wife's maiden name. 3 shall be restricted as follows: 2(c) "Counsel for
4 Q I won't tell her. 4 Plaintiff shall not question Defendant Madigan about
5 MR. VAUGHT: And I'll instruct him not to 5 his family members with the exception of questions
6 answer. 6 regarding any actions by Attorney General Lisa Madigan
7 THE WITNESS: Obviously, it's a French name 7 or her office directly related to the 2016 Democratic
8 so there's o-u-x on the end so like Romagoux 8 Primary Election in the 22nd District of the Illinois
9 R-o-m-a-g-o-u-x. 9 House of Representative Grasiela Rodriguez or Joe
10 BY MR. PERAICA: 10 Barboza and their respective families."
11 Q Thank you. 11 MR. PERAICA: Well, so that I can make my
12 Do you and your wife have children as 12 record. Are you going to instruct the witness not to
13 a result of the marriage? 13 answer if I ask him about the background of Tiffany
14 A Yes, we do. 14 Madigan's employment?
15 Q And how many children do you have? 15 MR. VAUGHT: I don't see how it's relevant,
16 A We have a total of four children. The 16 and it's outside the scope of the deposition and the
17 first child was conceived in a prior marriage that my 17 order that was entered by the Court yesterday that you
18 wife was involved in, and the last three were conceived 18 agreed -- this is an agreed order.
19 by both her and I. 19 MR. PERAICA: So the answer is yes?
20 Q So the four children would be Lisa Madigan? 20 MR. VAUGHT: Yes.
21 A Yes. 21 MR. PERAICA: Are you going to object to
22 Q Tiffany Madigan? 22 eliciting information from the deponent regarding
23 A Yes. 23 Jordan Matyas M-a-t-y-a-s, a husband of Tiffany Madigan
24 Q Nicole Madigan? 24 who is employed as Chief of Staff of Regional

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Page 26 Page 28
1 Transportation Authority? 1 MR. VAUGHT: It's an order you agreed to.
2 MR. VAUGHT: Yes, if that's involved 2 MR. PERAICA: The record has been made.
3 with -- I mean, Tony, this is an order entered by the 3 THE WITNESS: We promise not to ask
4 Court that you agreed to. 4 questions about your family, too.
5 MR. PERAICA: And you will likely instruct 5 MR. PERAICA: You could.
6 Mr. Madigan not to answer that question either then, is 6 BY MR. PERAICA:
7 that correct? 7 Q What is your current address where you
8 MR. VAUGHT: I'm saying that you're not 8 live?
9 allowed to ask the question. 9 A 6400 South Keeler.
10 MR. PERAICA: Okay. Well, for the record, 10 Q How do you spell the street?
11 I do believe that that does not fall under the language 11 A K-e-e-l-e-r.
12 of the agreed order that was entered yesterday, 12 Q And what is the zip code there?
13 protective order that is. 13 A 60629.
14 But for the record, I will just 14 Q Who resides with you at that address?
15 state, and we can have the Court to deal with this 15 A My wife.
16 issue that the questions that I would elicit here would 16 Q Anybody else?
17 deal with work done by the husband of one of the 17 A No.
18 children of Mike Madigan, that is Tiffany Madigan who 18 Q How long have you lived at that address?
19 is married to Lobbyist Jordan Matyas who also in 19 A Since October of 1977.
20 addition to lobbying State Government is a Chief of 20 Q 48 years?
21 Staff for the RTA or Regional Transportation Authority 21 A Is that the count?
22 a State agency, so. 22 Q Almost.
23 MR. VAUGHT: Spouses of children are 23 A Okay.
24 considered family members. At least my in-laws take 24 Q Have you owned any other homes or

Page 27 Page 29
1 that position. 1 residences in Cook County?
2 MR. PERAICA: Mine don't. 2 A I own the residence at -- my wife and I own
3 MR. KASPER: I'm with you, Tony. 3 the residence at 6406 South Keeler?
4 BY MR. PERAICA: 4 Q Is that a single-family home as well?
5 Q Is your daughter Nicole Madigan employed as 5 A Yes, it is.
6 well? 6 Q And who lives there?
7 MR. VAUGHT: Tony, the same objection. 7 A Nobody.
8 MR. PERAICA: So you're instructing him not 8 Q It's vacant?
9 to answer? 9 A It's vacant.
10 MR. VAUGHT: I'm saying the Court doesn't 10 Q Did you own real estate in Ravenswood
11 allow you to ask the question. 11 neighborhood of Chicago sometime in the past?
12 MR. PERAICA: Okay. 12 A To the best of my knowledge, no.
13 BY MR. PERAICA: 13 Q Did you or your wife sell any property in
14 Q Finally, Andrew Madigan, he's your son, 14 Ravenswood, in particular, to Shaw Decremer and his
15 correct? 15 wife?
16 A Yes. 16 A The answer is no.
17 Q Is Andrew Madigan employed with Mesirow 17 Q Where did you graduate elementary school?
18 Financial? 18 A Saint Adrian.
19 MR. VAUGHT: Tony, same objection. 19 Q And where did you go to high school?
20 MR. PERAICA: Are you instructing him not 20 A St. Ignatius.
21 to answer that question? 21 Q Did you graduate?
22 MR. VAUGHT: I'm saying you don't get to 22 Q Yes, I did.
23 ask the question. 23 A What year was that in?
24 MR. PERAICA: Okay. All right. 24 A 1960.

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1 Q After St. Ignatius High School, where did 1 A To the best of my knowledge, the answer is
2 you go to college? 2 no.
3 A Notre Dame. 3 Q Do you belong to any church or parish?
4 Q When did you graduate? 4 A No.
5 A '64, June of '64. 5 Q Were you a member in the past of
6 Q What did degree did you obtain? 6 St. Mary Star of the Sea?
7 A Bachelors of Arts BA. 7 A No.
8 Q And after graduating from Notre Dame, did 8 Q Were you a regular attendee at any
9 you go further in school? 9 particular church?
10 A The Loyola Law School. 10 A Once upon a time St. Adrian.
11 Q When did you graduate from Loyola Law 11 And let me amend that, for a time I
12 School? 12 would be a regular attendee at St. Nicholas of
13 A June of '67. 13 Tolentine.
14 Q Have you had any other education besides 14 Q These are all churches in Chicago around
15 that? Did you study or take seminars, obtain any 15 the area you live in?
16 certificates or diplomas post-graduating from law 16 A Southwest side of Chicago.
17 school at Loyola? 17 Q Now, in the past after you graduated from
18 A I have done CLE training. 18 Loyola Law School, did you go to work as an attorney?
19 Q Okay. Anything other than that? 19 A Yes, I did.
20 A Not that I recall. 20 Q And where did you work?
21 Q Do you belong to any clubs? 21 A At the Illinois Commerce Commission.
22 A Yes. 22 Q What did you do there?
23 Q Which ones? 23 A I was a hearing examiner.
24 A I belong to the Union League Club of 24 Q Just approximately how long were you there?

Page 31 Page 33
1 Chicago. I also belong to the Beverly Country Club. 1 A Approximately from sometime in late 1967
2 Q How long have you been a member Union 2 until sometime in 1969.
3 League Club of Chicago? 3 Q Was that a full-time or part-time position?
4 A Approximately 10 years. 4 A Full-time job.
5 Q How long have you been a member of Beverly 5 Q And after you left the job that you had
6 Country Club? 6 with Illinois Commerce Commission, did you go to work
7 A Approximately 10 to 15 years. 7 somewhere else?
8 Q Are you a member of the Lake Shore Club? 8 A City of Chicago Law Department.
9 A The Lake Shore Club no longer exists. 9 Q From when to when was that approximately?
10 Q Were you a member in the past? 10 A From sometime in 1969 until approximately
11 A Yes, I was. 11 December of '69.
12 Q When did it cease to exist? 12 Q And when you worked as an Assistant
13 A Tony, I think it was 30 years ago that was 13 Corporation Counsel for the City of Chicago during that
14 shut down. 14 time, what were your responsibilities, what did you do?
15 Q Do you belong to any legal professional 15 A I worked with the Liquor Control
16 associations or organizations? 16 Commissioner to analyze and review police reports and
17 A State Bar Association, Chicago Bar 17 prepare a summary report for the Liquor Commissioner.
18 Association. 18 Q After you left the City of Chicago as an
19 Q Any others? 19 Assistant Corporation Counsel in December of '69, where
20 A To the best of my knowledge, no. 20 did you go to work then?
21 Q Were you ever a member or an honorary 21 A The Illinois Constitutional Convention.
22 member of the Women's Bar Association? 22 Q And how long did that position last?
23 A I may have been a member for a short time. 23 A From December of '69 until approximately
24 Q You're no longer involved with them?
24 September of 1970.

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1 Q What were your responsibilities in that 1 among lawyers in terms of cost sharing, so I wouldn't
2 position? 2 remember today what the structure or the arrangement
3 A I was a delegate to the convention. 3 was.
4 Q Was that a paid or unpaid position? 4 Q But the Firm of Madigan & Getzendanner has
5 A Compensated position. 5 been around since what year?
6 Q Was it considered full time or part time? 6 A I don't recall exactly when it became
7 A For me it was full time. 7 Madigan & Getzendanner.
8 Q And were you compensated by the State of 8 Q It's been a while?
9 Illinois? 9 A It's been a while.
10 A Yes. 10 Q Okay. Your father, was he also named
11 Q So during that period from December of '69 11 Michael Madigan?
12 to September of 1970, you were a convention delegate 12 A Yes.
13 working on the drafting of the Illinois State 13 Q Did he have a different middle initial?
14 Constitution? 14 A It was Michael J. Madigan.
15 A Yes. 15 Q Michael J. Okay.
16 Q After that employment ended in September of 16 Do you have any siblings?
17 1970, where did you go to work then? 17 A Yes.
18 A The Illinois House of Representatives. 18 Q How many?
19 Q When were you first sworn-in? 19 A One.
20 A January of '71. 20 Q What is the name?
21 Q And you have been serving in that capacity 21 A Marita M-a-r-i-t-a.
22 until the present time? 22 Q Last name?
23 A Yes. 23 A McGivney McGiveney M-c capital G-i-v-n-e-y.
24 Q You're also a principal in the Law Firm of 24 Q And how old is your sister?

Page 35 Page 37
1 Madigan & Getzendanner, is that correct? 1 A She is 71.
2 A The answer is yes. 2 Q Are both your mother and father deceased?
3 Q And how long have you worked in that 3 A Yes.
4 capacity as a principal at that law firm? 4 Q I know your father was involved in
5 MR. VAUGHT: Okay. Tony, I'm going to 5 politics, was your mother involved in politics as well
6 object here. The scope of deposition says, "The scope 6 when she was alive?
7 shall be restricted as follows: (b) Counsel for 7 A No.
8 Plaintiff shall not question Defendant Madigan 8 Q Your wife Shirley, is she involved with any
9 regarding his law practice." 9 committees that you were working with or control?
10 MR. PERAICA: I'm not. I'm just asking for 10 A She's the Chair of the Illinois Arts
11 a diagraphical background information from when to when 11 Council, which is a State agency appointed by the
12 was the deponent principal in Madigan & Getzendanner, 12 Governor.
13 that's all. 13 Q And the appropriation for the Illinois Arts
14 MR. VAUGHT: Then we're going to move on? 14 Council comes from the State taxpayers?
15 MR. PERAICA: Yeah. 15 A From the Illinois Legislature.
16 THE WITNESS: Tony, I started my law firm 16 Q Right, as part of the State budget?
17 in, I believe, 1972. And thereafter, why I was 17 A Yes.
18 associated with multiple lawyers and eventually it 18 Q Is your wife Shirley involved in any other
19 became Madigan & Getzendanner, but I'm not certain of 19 way in any of the governmental work or State agency
20 the date that it became Madigan & Getzendanner. 20 work or any board memberships in any other way besides
21 BY MR. PERAICA: 21 Illinois Arts Council?
22 Q Were you an equity partner or owner since 22 A Governmentally it you would be restricted
23 1972 in whatever formation or names were used? 23 to the Arts Council. Now, she'sinvolved with other
24 A For one period it was a loose arrangement 24 arts organizations such as the Erikson Institute. I

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1 believe she's a board member there. 1 geographically close than others that are not
2 Q Any others? 2 geographically close, but I wouldn't describe any of
3 A There may be more, but I don't remember 3 these relationships as anything other than knowing that
4 them right now. 4 these people are involved with politics and from time
5 Q Is your wife still a Trustee at Loyola 5 to time why you may interact with them.
6 University? 6 Q All right. Do you have a close working
7 MR. VAUGHT: Tony, I'm going object. I 7 relationship with the Committeemen of the adjacent Ward
8 mean, this is again getting into family. We've already 8 Alderman Ed Burke who is also a Committeeman?
9 discussed this. It's not relevant. 9 A Correct. I would not describe it as a
10 MR. PERAICA: You're right. 10 close working relationship.
11 MR. VAUGHT: It's prohibited by the 11 Q You backed Ed Burke in the past when he ran
12 protective order. Let's just move on. 12 for State's Attorney it was back in the 80s, did you
13 BY MR. PERAICA: 13 not?
14 Q One more question on that point. 14 A I did.
15 Is Shirley Madigan involved as a 15 Q And he backed you when you ran for various
16 Director for After School Matters, Inc.? 16 offices, did you not?
17 A Tony, she may be, but I don't remember 17 A He supported me for State Representative.
18 right now. 18 Q Right. Do you and Committeeman Alderman Ed
19 Q Okay. That's fair. 19 Burke work closely on any races in the Primary or
20 I want to focus next group of 20 General Election generally?
21 questions on the political functions that you serve in 21 A Again, I wouldn't say closely.
22 both within the Democratic Party and in the leadership 22 Q Particularly in the months leading up to
23 position of the Party structure. 23 the filing for the March 2016 primary, so I'm talking
24 Are you a Democratic Committeeman of 24 from April of 2015 through about April of 2016, have

Page 39 Page 41
1 the 13th Ward? 1 you worked with Committeeman or Alderman Ed Burke on
2 A Yes. 2 any of the races in that cycle?
3 Q And how long have you been a Democratic 3 A To the best of my knowledge, maybe, that's
4 Committeeman of the 13th Ward? 4 what I can remember today.
5 A Since July of 1969. 5 Q Well, it's not that long ago, so I'm asking
6 Q And you are currently serving a deposition? 6 you if you recall having any conversations, for
7 A Yes. 7 example, with Alderman Ed Burke related to the March
8 Q As a Committeeman of the 13th Ward, do you 8 2016 primary when you were running yourself?
9 participate in the City of Chicago Democratic Party 9 A Not that I remember.
10 work? 10 Q Did you ask Committeeman Alderman Ed Burke
11 A With the -- the City element of the Cook 11 to provide any assistance in anyway to you or your
12 County Democratic Party? 12 campaign in that March 2016 primary?
13 Q Yes. 13 A I presumed that I asked for his support.
14 A The answer is yes. 14 Q Is it your practice to ask all
15 Q Do you have a close relationship with all 15 Committeemen, Democratic Committeemen, who are
16 50 Ward Democratic Committeemen across the City of 16 contained within the 22nd House Representative District
17 Chicago or do you just focus on your local area where 17 to assist you?
18 you're at? 18 A In the ordinary course I would do that.
19 A I'm like you, I try to make friends 19 Q But you don't recall any particular
20 everywhere but not with great success. 20 meetings or conversations with Alderman Ed Burke?
21 Q All right. Do you have a close working 21 A I do not remember.
22 relationship with the Ward Committeemen surrounding 22 Q Did you ask Alderman Ed Burke or in his
23 13th Ward is my question? 23 capacity as a Committeeman Ed Burke to send any
24 A Obviously, you spend more time with those 24 literature out either on your -- on your behalf first

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1 in that March 2016 primary? 1 of the 13th Ward?
2 A Not that I remember. 2 A In the 13th Ward why -- what we attempt to
3 Q Did you ask him to ask Alderman Ed Burke to 3 do is to persuade and encourage governments,
4 send any literature on behalf of any other candidates 4 governmental bodies to provide an appropriate level of
5 for or against in that March 2016 primary? 5 service to the people that live in the 13th Ward. And
6 A Not that I remember. 6 so citizens of the 13th Ward will come to our office
7 Q Are you aware that Alderman Ed Burke sent a 7 and ask for assistance in terms of their interaction
8 piece in support of Grasiela Rodriguez, one of your 8 with governments, and we attempt to help them.
9 primary opponents in the March 2016 primary? 9 Q Isn't that role of an Alderman of the Ward?
10 A I'm not aware of that. 10 A In part, but it's also a role that the 13th
11 Q Was your understanding or belief that 11 Ward Organization performs.
12 Alderman Ed Burke was supporting your re-election as a 12 Q The committeeman position is a party
13 member of the House of Representatives from the 22nd 13 position, an unpaid position, correct?
14 District in that March 2016 primary? 14 A Yes.
15 A The answer would be yes. 15 Q And generally speaking you get no budget or
16 Q According to my math, 1969 you would have 16 money for any staff from anybody from the party, for
17 been about what 27-years old when you were elected by 17 example?
18 your fellow precinct captains as a Committeeman of the 18 A Yes.
19 13th Ward? 19 Q So you have to generate and produce moneys
20 A About that age. 20 for the 13th Ward Democratic Organization, correct?
21 Q And you have served in that capacity almost 21 A Yes.
22 50 years, correct? 22 Q And you have to then use that money to
23 A Yes. 23 support the Democratic Party activities in that Ward on
24 Q So can you tell me how do you define the 24 behalf of yourself as a Democratic elected official or

Page 43 Page 45
1 role of a Democratic Committeeman of a Ward in the City 1 others who are running in that ward, correct?
2 of Chicago? 2 A Yes.
3 A My view of the responsibility of the Ward 3 Q And you would also then from that same
4 Committeeman is to work on behalf of Democratic 4 fundraising for the 13th Ward Democratic Organization
5 candidates in the general election; to distribute their 5 pay any staff people if you deem them appropriate to be
6 literature; to prepare a sample ballot, and to 6 hired?
7 distribute the sample ballot. 7 A Yes.
8 In the Primary Election why everybody 8 Q With all the other responsibilities that
9 is a Democratic or claim to be a Democratic and you 9 you have in your various roles, why would you want to
10 pick someone that you would support in the Primary 10 continue as a committeeman for 50 years?
11 Election. 11 A It's a good question.
12 Q And those would be activities related to 12 Q Have you figured out the answer? I'm
13 before or at election time. 13 curious.
14 What about when you're between 14 A My stock answer is to tell people that I'm
15 elections, what is the duty or role of a Democratic 15 rather peculiar.
16 Committeeman? 16 Q You're passionate about that position,
17 A My view would be to participate in the 17 right?
18 affairs of the Democratic Party, the ongoing affairs of 18 A You want an answer to that?
19 the Democratic Party, activities of the Democratic 19 Q Yes.
20 Party formulating issue positions of the Democratic 20 A I'm not sure I'm passionate, but I still
21 Party that might become determinative issues in the 21 perform the duties.
22 general election. 22 Q All the duties that you enumerated earlier
23 Q In your role as the 13th Ward Committeeman, 23 which overlap with the Alderman's Office, are those the
24 are you able to offer any services to the constituents 24 only duties that you as a committeeman would be

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1 involved in or are there others? 1 neighboring committeeman Alderman Ed Burke, correct?
2 A Well, in general you stay abreast of 2 A I believe answer is yes.
3 Democratic Party positions, Democratic Party issues, 3 Q Chicago Tribune wrote in the past that
4 and to the best of your ability you think in terms of 4 during the last decade and a half that some 25 lawyers
5 future elections and working to provide support for 5 that you recommended were appointed or elected to the
6 those Democratic Party positions. 6 bench in Cook County?
7 Q Did you have anyone on the payroll as a 7 A That I recommended?
8 staff person or a contractor being paid by the 13th 8 Q Yes, it's a 15-year span.
9 Ward Regular Democratic Organization between April of 9 A And who did I give the recommendations to?
10 '15 and April of 2016? 10 Q Chief Judge or whoever is in charge of the
11 A I don't remember. 11 appointment process, Supreme Court possibly.
12 Q Would that be reflected if anyone was hired 12 A Are you talking about appointments by the
13 on any disclosure forms that you would file for the 13 Court or are you talking about the Democratic
14 organization? 14 Committee?
15 A The answer is yes. 15 Q Appointments.
16 Q As a 13th Ward Committeeman in the City of 16 A Okay. So you shifted over to a
17 Chicago, you are also part of the Cook County 17 different --
18 Democratic Organization which encompasses 50 Wards in 18 Q Right.
19 this City and the townships in suburban Cook County, is 19 A And you're talking about people appointed
20 that correct? 20 by the Supreme Court?
21 A The answer is yes. 21 Q Yes.
22 Q Do you participate in that role as a 13th 22 A I don't remember -- I don't remember who
23 Ward Democratic Committeeman in the Cook County 23 would have been appointed by the Court in my
24 Democratic Party activities? 24 recommendation.

Page 47 Page 49
1 A The answer is yes. 1 Q As far as the election of judges, do you
2 Q Does that include slating activity as well? 2 participate in the process of electing Democratic
3 A The answer is yes. 3 judges in Cook County?
4 Q Do you have any leadership role in either 4 A To the extent that those judges appear on
5 the Chicago Democratic Party or the Cook County 5 the 13th Ward sample ballot.
6 Democratic Party leadership structure? 6 Q Then you do?
7 A The answer is no. 7 A The answer is yes.
8 Q Are you in charge of any of the screening 8 Q Do you also participate as a Committeeman
9 committees? 9 in the filling of vacancies when an elected official
10 A The answer is no. 10 either retires, dies, or quits midterm and the vacancy
11 Q In particular, do you get involved with the 11 has to be filled?
12 judicial slating by the Chicago or Cook County 12 A Can you give me some examples.
13 Democratic Party? 13 Q For example, if the Alderman were to leave
14 A The answer is no. 14 in the 13th Ward you, as a Committeeman, would have a
15 Q Have you done so in the past? 15 voice in terms of who the replacement would be until
16 A Well, Tony, the full answer to your 16 the next special election or regular election, is that
17 question is that I don't serve as a Member of the 17 correct?
18 Committee on the Judiciary. I do not participate 18 MR. KASPER: Objection. I think you're
19 actively with that committee. There have been 19 going beyond the scope of the witness' knowledge.
20 instances where I supported individual candidates for 20 MR. PERAICA: If he knows.
21 judgeships and as I did that they were appearing before 21 BY MR. PERAICA:
22 that committee. 22 Q Do you know?
23 Q And the Judicial Evaluation Committee of 23 A Can you restate the question?
24 the Cook County Democratic Party is chaired by your 24 Q If an elected official whether Municipal,

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1 County or State leaves midterm, would the role that you 1 Q And do you pay for that space that you
2 hold as a 13th Ward Democratic Committeeman come into 2 occupy from one of the funds that you control or how?
3 play in picking a replacement, a temporary replacement? 3 A It's from my personal money.
4 A If you focus just on the office of the 4 Q Who owns that building currently?
5 Alderman, I would make a recommendation to the Mayor. 5 A The Balzekas Museum.
6 It's the Mayor's appointment. 6 Q Right. Is it a non-for-profit corporation?
7 Q Right. 7 A I really don't know, but I presume it is.
8 A I would make a recommendation to the Mayor. 8 Q But you pay money from personal funds for
9 The Mayor may accept it or not accept it. 9 the rent, who do you pay it to?
10 Q Right. And what about if it's a State 10 A We write a check to the Balzekas Museum.
11 Representative, for example, would you play a role as a 11 Q Okay. And how much do you pay for rent as
12 Democratic Committeeman in replacing a person who left 12 13th Ward Committeeman?
13 for some reason in midterm? 13 A I don't recall.
14 A If part of the Legislative District were in 14 Q Who handles the payments for you?
15 the 13th Ward, why I would have a vote. 15 A The check is prepared for me.
16 Q Right. 16 Q By whom?
17 A I would vote. 17 MR. KASPER: I think that's beyond the
18 Q Yes. And if a State Senator were to quit 18 scope of this dep.
19 midterm that encompasses the 13th Ward, you would have 19 MR. PERAICA: He can say that.
20 a -- 20 BY MR. PERAICA:
21 A I would have a vote. 21 Q Is it?
22 Q Okay. So have you voted as such in these 22 A Well, I think it is yes.
23 special occasions, rare and infrequent occasions when 23 Q You don't know?
24 there was a vacancy? 24 A Oh, I know who prepares the check for me.

Page 51 Page 53
1 A Not that I remember, but I may have. 1 Q Well, who is it?
2 Q Okay. Do you have a 13th Ward Committeeman 2 A It's a woman that works in my law office.
3 office, physical office? 3 Q What's her name?
4 A Yes, I do. 4 A Marsha.
5 Q Where is that at? 5 Q Last name?
6 A 6500 South Pulaski. 6 A Thomas.
7 Q Is that on the second floor? 7 Q Do you -- does she prepare the checks and
8 A You've been there. The answer is yes. 8 you sign them --
9 Q And which part of the multiple offices and 9 A Yes.
10 cubicles is dedicated to the work as 13th Ward 10 Q -- or does she use a stamp?
11 Committeeman? 11 A No, no, I sign the checks.
12 A I think the answer to your question would 12 Q All right. And you never looked what the
13 be that the space that I occupy is on the northside of 13 amount is that you pay in rent?
14 the suite. It faces 64th Street -- excuse me -- 65th 14 A Oh, I've looked at it, but I don't remember
15 Street. 15 at this time.
16 Q Right. So you're talking about the extreme 16 Q Do you have any employees who work for you
17 north end of the -- 17 as a Committeeman of the 13th Ward?
18 A Suite. 18 A I don't remember.
19 Q -- building? 19 Q You don't remember?
20 A Building. 20 A Your question is 13th Ward, so I presume
21 Q The suite? 21 you're referring to the banking account maintained by
22 A Correct. 22 the 13th Ward.
23 Q On the second floor? 23 Q Yes. I'm asking whether you as a 13th Ward
24 A Second floor. 24 Democratic Committeeman have any staff that you pay for

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1 their services? 1 the work as a 13th Ward Committeeman on average?
2 A Today I don't remember if we do today. We 2 A As needed.
3 may have in the past. 3 Q At the height of the Primary Election
4 Q How about between April of 2015 and April 4 campaign, what would be your involvement as a
5 of 2016? 5 committeeman at that time?
6 A Same answer. I don't remember, but we may 6 A Again, as needed.
7 have. 7 Q How many precinct captains do you have as a
8 Q Do you know how many people you have on 8 13th Ward Committeeman?
9 staff as a Democratic Committeeman of the 13th Ward? 9 A Today I believe there are about 55
10 A No. 10 precincts in the 13th Ward.
11 Q And do you know how those individuals, if 11 Q I thought there were 48 myself, but is
12 you do have them, would get paid and from where? 12 that -- you don't know or?
13 A Well, there would be a payroll check 13 A Your count -- your number may be correct.
14 written for them. 14 Q But in terms of precinct captains you
15 Q And would Marsha Thomas handle that as 15 estimate about 55?
16 well? 16 A Whatever the number of precincts then that
17 A No. 17 would be the number of precinct captains.
18 Q Who handles that? 18 Q So if there are 48 precincts you --
19 A The checks at the 13th Ward are prepared by 19 A 48 captains.
20 Sue Carpentier. 20 Q What is the extent of your interaction with
21 Q Sue Carpenter? 21 the precinct captains of the 13th Ward Democratic
22 A Carpentier. 22 Party, how often do you meet with them?
23 Q Carpentier. 23 A A minimal amount of time.
24 A Yeah. 24 Q Do you have someone who coordinates that on

Page 55 Page 57
1 Q And where does she work? 1 a more regular basis with the precinct captains?
2 A At 6500 South Pulaski. 2 A Alderman Quinn.
3 Q And what is her function there? 3 Q Anybody else other than Alderman Quinn who
4 A She writes the checks to pay the bills. 4 interacts with the precinct captains on a regular
5 Q For the 13th Ward Democratic Organization? 5 basis?
6 A Yes. 6 A Well, today there's a man named Moe Zahdan
7 Q Any others? 7 who works with Alderman Quinn.
8 A No, just the bills that come in for the 8 Q He's the, I believe, what Chief of Staff
9 13th Ward Organization. The bills that are going to be 9 or --
10 paid by the 13th Ward Democratic Organization. 10 A No.
11 Q Is this the same account that Marsha Thomas 11 Q -- Superintendent?
12 uses to pay the rent? 12 A He's the Ward Superintendent.
13 A No. 13 Q So Moe Zahdan is the Ward Superintendent of
14 Q That's a separate account? 14 the 13th Ward also assists Alderman Quinn and you to
15 A Well, you recall I told you that I use my 15 work with the precinct captains throughout the year but
16 personal money to pay for my space. 16 especially during and leading up to election?
17 Q All right. 17 A The answer is yes.
18 A That's the check that's prepared by Marsh 18 Q Do you join the committeeman to go
19 Thomas. 19 door-to-door in any outreach efforts to the
20 Q When you say "personal money," is that 20 constituents?
21 money coming from Madigan & Getzendanner Law Firm or is 21 A No.
22 it from your personal checking or savings account? 22 Q Have you done that during the 2016 primary
23 A Personal account. 23 cycle?
24 Q How many hours a week do you dedicate to 24 A No.

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1 Q Did you go door-to-door at all -- 1 BY MR. PERAICA:
2 A No. 2 Q So he acted in that role even though he
3 Q -- during that time? 3 didn't have the official designation as such?
4 A No. 4 A The answer is yes.
5 Q What is your interaction typically with the 5 Q Did Alderman Marty Quinn as a coordinator
6 13th Ward Alderman Marty Quinn? 6 for your re-election campaign in March of 2016 have any
7 A We meet and talk sometimes everyday, 7 assistants that worked with him in that regard that you
8 sometimes everyday. 8 know of?
9 Q Other than talking to each other, do you do 9 A Not that I recall today.
10 anything else? 10 Q For example, like Moe Zahdan?
11 A Can you rephrase the question? 11 A He may have been. He may have been.
12 Q Do you delegate any other responsibilities 12 Q Any others that you would be able to
13 or functions to Alderman Quinn as a Ward Committeeman? 13 identify?
14 A Well, not that I can remember now. We -- 14 A Not that I can recall.
15 we meet, we talk, we work through issues and problems. 15 Q So, again, in your opinion and based on
16 Q And when you say "issues and problems," are 16 your knowledge and years of service as a Democratic
17 you talking about constituents' issues and problems? 17 Ward Committeeman for almost 50 years, how did the
18 A Both that and campaign issues and problems. 18 offices of the 13th Ward Alderman, in this case,
19 Q And what role does Marty Quinn, Alderman 19 Marty Quinn now, Frank Olivo before him, and your role
20 Quinn, play in any campaign issues? 20 as a 22nd District Democratic Representative, how did
21 A Well, depending upon the campaign he may be 21 they interact?
22 involved in the campaign he may not be. If he's 22 A We would maintain a joint service office so
23 involved in the campaign, why he'll be involved in the 23 we would combine our resources to provide constituent
24 campaign. 24 service to both 13th Ward and 22nd District.

Page 59 Page 61
1 Q Was Marty Quinn, Alderman Quinn, involved 1 Q And can you elaborate on that, what type of
2 in your re-election campaign in March of 2016? 2 typical activity would that involve?
3 A Yes. 3 A It's generally being responsive to requests
4 Q In what role? 4 from citizens of the area, whatever a citizen might
5 A Just as an advisor, as a coordinator. 5 wish to talk to us about.
6 Q Was the Alderman Marty Quinn your campaign 6 MR. PERAICA: Let's label this as
7 manager? 7 Exhibit -- you got them out?
8 A There was no designated campaign manager. 8 MR. VAUGHT: Is this the snow plowing?
9 Q Did Marty Quinn act in that role? 9 MR. PERAICA: Hm?
10 A Marty Quinn acted as an advisor and as a 10 MR. VAUGHT: Is this the snow plow?
11 coordinator, that's what he did. 11 MR. PERAICA: No, I'm going to save that,
12 Q Coordinator of the campaign? 12 though.
13 A Coordinator of the campaign. 13 MR. VAUGHT: You're going to save it.
14 Q That would be a campaign manager? 14
15 MR. VAUGHT: Objection. That's been asked 15 (WHEREUPON, said document was
16 and answered. He said there was no -- 16 so marked as Madigan Deposition
17 BY MR. PERAICA: 17 Exhibit No. 1, for identification.)
18 Q Is that true?
18
19 MR. VAUGHT: He said there was no campaign
19 BY MR. PERAICA:
20 manager, then he said he was a coordinator.
20 Q I marked this as Madigan Deposition
21 Exhibit No. 1, would you take a look at this?
21 MR. PERAICA: I heard what he said.
22 A Sure.
22 THE WITNESS: There was no campaign
23
23 manager. What Marty did would be the type of things
24 (Document tendered)
24 that would be done by a campaign manager.

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1 BY MR. PERAICA: 1 question was what arrangement. So maybe I suggest,
2 Q Have you had a chance to look at it? 2 Mr. Peraica, why don't you just you reask the question
3 A I have. 3 so it's accurate as to what you're actually asking.
4 Q At the bottom of this, which is a snapshot 4 MR. PERAICA: That's fair. Let me rephrase
5 from the website that is maintained by you and Alderman 5 the question.
6 Quinn it says, "Paid for by the 13th Ward Democratic 6 BY MR. PERAICA:
7 Organization" at the bottom. 7 Q And please if you don't understand what I'm
8 Do you see that? 8 asking, which may happen again, please let me know, and
9 A I do. 9 I'll try to rephrase it.
10 Q So is this creation and design and 10 Looking at this Madigan Exhibit 1
11 maintenance of this website maintained by the 13th Ward 11 paid for by the 13th Ward Democratic Organization, my
12 Democratic Organization? 12 question is what work do you as a Democratic
13 A I don't know the answer to that question. 13 Committeeman do at these two locations in conjunction
14 Q Do you recall paying for the creation of 14 with Alderman Quinn?
15 this website? 15 A Can you state it again?
16 A I do not remember. 16 Q Yeah, what work do you do as a committeeman
17 Q Do you recall discussing with Alderman 17 at 6500 South Pulaski and 6014 South Central with
18 Quinn the creation of this website? 18 Alderman Quinn?
19 A I do not remember. 19 A Well, for one thing I've never been inside
20 Q Have you met with any web designers to talk 20 the office at 6014 South Central. I've never been
21 about what should be contained in terms of text or 21 inside the office.
22 pictures on this website? 22 Q Who pays the rent for that office?
23 A I do not remember. 23 A Today I don't know. I'd have to go back
24 Q It lists here at the top where it says 24 and ask.

Page 63 Page 65
1 "Welcome to the Madigan-Quinn Website" two offices, 1 Q Have you personally ever paid rent for 6014
2 correct? 2 South Central?
3 A Correct. 3 A I don't remember.
4 Q And one is that you mentioned before 6500 4 Q Do you recall if the Democratic
5 South Pulaski, and the other is 6014 South Central, is 5 Organization of the 13th Ward paid rent at that
6 that correct? 6 location?
7 A That's correct. 7 A I don't remember.
8 Q What is the arrangement that you and 8 Q Do you remember if the State of Illinois on
9 Alderman Quinn have regarding the work done at these 9 behalf of you as a State Representative of the 22nd
10 two offices by the 13th Ward Democratic Organization? 10 District paid rent at that office?
11 A Can you restate the question? 11 A I don't remember.
12 MR. PERAICA: Can you read the question, 12 Q Did the State of Illinois pay any rent at
13 please? 13 6500 South Pulaski?
14 14 A The answer is that the State of Illinois
15 (WHEREUPON: The question was 15 pays for some space at 6500 South Pulaski.
16 read as follows: "Q What is 16 Q And what space particularly is paid for by
17 the arrangement that you and 17 the State of Illinois at 6500 South Pulaski?
18 Alderman Quinn have regarding
18 A I wouldn't remember. If it's not, I have
19 the work done at these two
19 to back and ask.
20 offices by the 13th Ward
20 Q And who would be the person making that
21 designation in terms of what areas are for what
21 Democratic Organization?"?)
22
22 purpose?
23 A Alderman Quinn.
23 MR. SULLIVAN: I think the court reporter
24 Q And not you?
24 has incorrectly restated the question. I think the

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1 A Correct. 1 A The answer is no.
2 Q So you've never been at 6014 South Central? 2 Q Do you have any office as a State Central
3 A I've never been inside the office. I've 3 Committeeman?
4 driven past it, but I've never been inside the office. 4 A No.
5 Q This is your service office? 5 Q Do you have anything to do with the design,
6 A It is. 6 launch, content of this website that's before you
7 Q But you've never been there? 7 Madigan Exhibit 1?
8 A I've never been there. 8 A The answer is no.
9 Q Did you ever assign a person that you paid 9 Q Is this done solely by Alderman Quinn and
10 to be there? 10 his staff?
11 A I don't remember. 11 A I wouldn't know.
12 Q Was Elena Hampton ever assigned to work at 12 Q As a 22nd District Representative, do you
13 this office? 13 have a joint arrangement like you have here with you
14 A I don't remember. 14 and Alderman Quinn with any of the other Aldermen who
15 Q Did you in any of your multiple capacities 15 are part of the 22nd House District?
16 or in your control of these various funds that you 16 A State it again.
17 control allocate any moneys for any expense, payroll, 17 Q Do you have an arrangement with any other
18 rent, utilities, anything in relation to 6014 South 18 elected official who is part of your 22nd House
19 Central? 19 District that you represent?
20 A I don't remember. 20 A An arrangement related to office -- sharing
21 Q But you do remember 6500 South Pulaski? 21 of office space?
22 A Yes. 22 Q Sharing of office space.
23 Q And you do pay a percentage of the usage 23 A The answer is no.
24 there? 24 Q Creation of a website as the one here?

Page 67 Page 69
1 MR. VAUGHT: Can you define -- 1 A I don't remember. To the best of my
2 MR. KASPER: Yeah, who's you, Tony? 2 knowledge, no.
3 MR. PERAICA: Pardon me? 3 Q Engagement in joint activities for
4 MR. KASPER: Who's you? 4 constituent services, any other Aldermen --
5 MR. VAUGHT: Who's you? 5 A Not that I remember.
6 BY MR. PERAICA: 6 Q So Alderman Quinn would be the only one
7 Q You as the State Central -- pardon me. 7 that you have --
8 As the Ward Committeeman of the 13th 8 A To the best of my knowledge, the answer is
9 Ward. 9 yes.
10 MR. KASPER: Well, he's already testified 10 Q How do you distinguish the role as a
11 that he pays personally some money. 11 Democratic Committeeman of 13th Ward from your role as
12 MR. PERAICA: Okay. So that's him. 12 a Third Congressional District State Central
13 MR. KASPER: Yeah, that's the you you're 13 Committeeman, Democratic State Central Committeeman?
14 talking about from his personal -- from his personal 14 A As a local Ward Committeeman, my focus is
15 account? 15 on local issues, local activities.
16 MR. PERAICA: Yeah. 16 As a member of the State Committee,
17 MR. KASPER: Objection; asked and answered. 17 my focus is on State issues.
18 BY MR. PERAICA: 18 Q And what are your functions within the
19 Q And you have the State of Illinois pay for 19 Democratic Party as the Third District State Central
20 a certain square footage of the second floor office 20 Committeeman, what are your responsibilities?
21 space at 6500 South Pulaski? 21 A My responsibility would be to be a member
22 A The answer is yes. 22 of the State Central Committee of the Democratic Party.
23 Q Do you have an office as a State Central 23 If there were votes taken with the State Committee, I
24 Committeeman in that same 6500 South Pulaski location? 24 would be expected to participate in the votes.

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1 Q Do you? 1 joining you in this race in the Third Congressional
2 A Yes, I do. 2 District for State Central Committeeman that she
3 Q Do you also serve in addition to Third 3 contribute funds?
4 Congressional District Democratic State Central 4 A I believe the answer is no.
5 Committeeman, do you also serve as a Chairman of the 5 Q As a member of the State Central Committee
6 Democratic Party? 6 and as a Chairman of the Democratic Party, do you get
7 A Yes, I do. 7 to elect the Executive Director of the Democratic
8 Q And how are you elected in that role? 8 Party?
9 A By other members of the State Committee. 9 A Historically, the Chair is appointed the
10 Q And there are two from every Congressional 10 Executive Director.
11 District? 11 Q And who appoints the Executive Director?
12 A Yes. 12 A As I said, historically the chair --
13 Q And who is your running mate in the Third 13 Q Right.
14 Congressional District as a State Central Democratic 14 A -- appointed the Executive Director.
15 Committeeman? 15 Q That would be you?
16 A Silvana Tabares. 16 A Yes.
17 Q Who is in the past been a member of the 17 Q In April 2015 through April of 2016, who
18 Illinois House of Representatives? 18 was the Chairman of the Democratic -- who was the
19 A The answer is yes. 19 Executive Director of the Democratic Party?
20 Q And currently serves as an Alderman of the 20 A Tim Mapes.
21 adjacent to the 23rd Ward? 21 Q Who was also your Chief of Staff as a
22 A The answer is yes. 22 Speaker of the House?
23 Q Which is also part of your 22nd District, 23 A Yes.
24 parts of it at least -- 24 Q And in that same period April of 2015

Page 71 Page 73
1 A The answer is yes. 1 through April of 2016, you were the Chairman of the
2 Q 23rd Ward, correct? 2 Democratic Party of the State of Illinois, correct?
3 A The answer is yes. 3 A Yes.
4 Q Did you have anything to do with her, 4 Q You were the Third Congressional District
5 meaning, Silvana Tabares, being placed as a running 5 Committeeman?
6 mate with you for the Third Congressional District 6 A Yes.
7 State Central Committeeman? 7 Q You were there 13th Ward Committeeman?
8 A Yes, I did. 8 A Yes.
9 Q How so? 9 Q You were the 22nd District House of
10 A I met with her and suggested that she might 10 Representative member?
11 want to run for the office, and she agreed to do it. 11 A Yes.
12 Q Have you met or interviewed any other 12 Q You were Speaker of the House?
13 potential candidates? 13 A Yes.
14 A No. 14 Q What would be the purpose of running for
15 Q She was the only one? 15 Third Congressional District State Central Committeeman
16 A Yes. 16 with all the other responsibilities that you have?
17 Q You asked her and she said yes? 17 A My purpose would be to become a member of
18 A The answer is yes. 18 the State Committee so I'm active in Illinois
19 Q Did you pay for that campaign for you and 19 Democratic politics, and I would have a choice to be a
20 Silvana Tabares to run as candidates in the Third 20 member of the State Committee or not be a member of the
21 Congressional District for State Central Committeeman? 21 State Committee. Given my level of interest in
22 A I believe we ran a joint campaign which was 22 Democratic politics in Illinois why I chose to attempt
23 paid for probably by Friends of Michael J. Madigan. 23 to become a member of the State Committee.
24 Q Did you ask Silvana Tabares as part of her 24 Q And what benefits do you get from that

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1 role? 1 and nomination for the office of Lieutenant Governor,
2 A Can you -- 2 and the State Committee met and vote for Shelia Simon
3 Q What benefit would you obtain from serving 3 to become Quinn's running mate for Lieutenant Governor.
4 in that role? 4 Q Would that be the only circumstance?
5 A Well, you'd be actively involved in the 5 A To the best of my knowledge that's the only
6 deliberations of the State Committee. 6 time that the State Committee would be replacing
7 Q Any other benefits or roles? 7 people.
8 A You get to meet and talk to a lot of 8 Q Looking, again, at the Madigan Exhibit 1.
9 people. 9 It says here under "Bringing Government To You" that
10 Q Do you go statewide and campaign on behalf 10 any information would be directed to Quinn Service
11 of other individuals? 11 Office, and there are two numbers given here.
12 A No. 12 Is this the Alderman Quinn Aldermanic
13 Q You don't even go out and meet your own 13 Service Office that's being referred to --
14 constituents in the 13th Ward you said? 14 A Where does it state "Bringing Government To
15 A I meet them all the time. I met one this 15 You"? Where does that state that?
16 morning coming into the building. 16 Q Right here. It's a headline.
17 Q Are you able to offer any services as a 17 A Gotcha. Okay.
18 Third Congressional District Democratic Committeeman to 18 And the question again?
19 anyone? 19 Q Two paragraphs down there's an information
20 A Well, you can offer the service of 20 given about where the constituents or any interested
21 representing Democratic people and Democratic voters at 21 party was looking at this website would call for
22 the level of the State Committee. 22 services, and there's a Madigan-Quinn service office
23 Q You also get to appointment the vacancies 23 and two numbers are given.
24 as a member of the Third Congressional District, if 24 A And the question is?

Page 75 Page 77
1 someone, for example, a congressman were to leave you 1 Q That's for the two locations, one on
2 would have a say in the replacement? 2 Central, and one on Pulaski, correct?
3 A No. 3 A 8000 is Pulaski and 1313 is Central.
4 Q Not as a Committeeman? 4 Q But you said you don't have anybody at the
5 A In the case of the Congress, it's a special 5 Central office that you can remember, right?
6 election. 6 A I don't think I said that.
7 Q But to fill a vacancy? 7 Q Do you?
8 A For what office? 8 A Do I know what? What's your question?
9 Q For Congress, for example. 9 Q Do you have anyone that you place there to
10 A It's a special election. 10 work there on your behalf on Central Avenue?
11 Q All right. What about for any other 11 A I know the name of one woman that works
12 office, let's put aside congress? 12 there that's Jen Solski.
13 A Well, the only time that the State 13 Q Is she being paid by 13th Ward Democratic
14 Committee fills vacancies is where there's a vacancy in 14 Organization?
15 nomination between primary and the general election. 15 A I don't know the answer to that question.
16 Q Right. So, for example, when Judy 16 Q All right. Do you want to take a short
17 Barr-Topinka was elected Treasurer or Comptroller, I 17 break? Are you okay?
18 forget which now, and died before she took office, 18 A I'm great.
19 would the Central Committee -- 19 Q All right. Good. Let's go on then.
20 A No, no, no. The better example would be 20 A So thankful to spend so much time with you.
21 in the case of Pat Quinn and the Primary Election where 21 THE VIDEOGRAPHER: Counsel, I was going to
22 Quinn was nominated and -- for the office of Lieutenant 22 ask you to change the tape.
23 Governor, one individual won the Primary Election and 23 MR. PERAICA: Go ahead. 10 minutes.
24 then resigned the candidacy. So there was a vacancy 24 THE VIDEOGRAPHER: Well, I was going to ask

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1 you in 10 minutes to change the tape. 1 today there you are Democratic candidates for State
2 MR. PERAICA: Do you want to go on for the 2 Offices, and we're working with them to help them get
3 next 10 minutes or do you want to stop it now? It's up 3 elected. In addition, we work with candidates for the
4 to you. 4 Illinois House, candidates for the Illinois Senate,
5 THE VIDEOGRAPHER: It's up to you. 5 candidates for the United States Congress.
6 MR. PERAICA: All right. Let's go for 10 6 Q Any others?
7 minutes, and then we'll take a break if that's okay 7 A Not that I can remember at this time.
8 with everyone? 8 Q What about the administrative duties, those
9 MR. SULLIVAN: Absolutely fine with me. 9 would be political functions, but do you have any
10 MR. PERAICA: Thank you, sir. 10 administrative responsibilities as a Chairman of the
11 BY MR. PERAICA: 11 Democratic -- State of Illinois Democratic Party?
12 Q So you don't have this kind of a joint 12 A To the extent that you are coordinating
13 arrangement with, for example, Bedford Park or Burbank 13 campaigns, working with other campaigns to the extent
14 or Chicago Ridge or any other municipalities in the 14 that you're required to file reports disclosure
15 Third Congressional District, do you? 15 reports.
16 A The answer is yes. 16 Q Who would do that for you as Chairman of
17 Q Which ones? 17 the State Democratic Party?
18 A No, you're correct. You said I don't have 18 A Historically, Tim Mapes would do that.
19 that arrangement. The answer is I do not have the 19 Q Now, Tim Mapes has --
20 arrangement. 20 A Resigned.
21 Q Thank you. 21 Q Resigned and retired?
22 When were you elected the Chairman of 22 A Resigned.
23 the Democratic Party of Illinois? 23 Q Resigned.
24 A Tony, I don't remember the exact date. 24 Did you force Tim Mapes to resign?

Page 79 Page 81
1 You could probably understand -- 1 A I told him to submit his resignation.
2 Q I have information that it was in 1998, 2 Q And he did?
3 would that be about right? 3 A He did.
4 A Right. 4 Q And you accepted it?
5 Q So about 20 years now? 5 A I did.
6 A Maybe more than 20 years. It's one of 6 Q So who is the Executive Director of the
7 those situations where you have so much fun you forget 7 Illinois Democratic Party now?
8 things. 8 A There's a interim Executive Director named
9 Q Yeah. Okay. We talked about your role as 9 Christian Mitchell. He's a State Representative.
10 a 13th Ward Democratic Committeeman. We talked bit 10 Q Did he replace Tim Mapes?
11 about your role as a Third Congressional District State 11 A He became the interim Executive Director.
12 Central Committeeman. We talked a little bit about the 12 Q And you appointed former -- is he still a
13 role that you're in as Chairman of the Democratic Party 13 State Representative?
14 of Illinois, and I just want to ask you about that in 14 A Yes.
15 particular. 15 Q So he's serving as a State Representative
16 Besides what you already said about 16 and as interim Executive Director of the Illinois
17 naming an Executive Director or appointing an Executive 17 Democratic Party?
18 Director and participating in the filling of vacancies
18 A Yes.
19 at the State level that you talked about, what other
19 Q Why is this an interim rather than a full
20 role or position do you play or occupy as the Chairman
20 appointment as an Executive Director?
21 of the Democratic Party of Illinois?
21 A It's just a result of the circumstances
22 that existed when he was appointed as the interim
22 A You work with any Illinois Democratic which
23 Executive Director.
23 is to get involved with the Democratic Party of
24 Q When you were elected Chairman of the
24 Illinois. You work with different candidates and so

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1 Democratic Party of Illinois, did you relocate the 1 A Upon recommendation of Alderman Quinn.
2 headquarters of the Party from Chicago to Springfield? 2 Q Does anyone else provide advice and consent
3 A I wouldn't say that I relocated the 3 or is it just Alderman Quinn?
4 headquarters. The Democratic Party of Illinois 4 A We're like you we listen to everybody.
5 maintains an office in Springfield, and it maintains an 5 Q Okay. But ultimately the call is yours as
6 office in Chicago. 6 to who would be in that position as a precinct captain?
7 Q Where is the office in Chicago for the 7 A Well, under the statute.
8 Illinois State Democratic Party? 8 Q Yeah. So you can remove someone at will if
9 A 111 West Washington. 9 you wanted to as a Democratic precinct captain?
10 Q And where is the office for the State Party 10 A The answer is yes.
11 in Springfield? 11 Q Other than you and Alderman Quinn is anyone
12 A It's at the intersection of Veterans 12 else -- well, you said Moe Zahdan would assist, other
13 Parkway and Monroe. 13 than the three of you is anyone else working on a
14 Q Besides you as the Chairman of the 14 regular basis to interact with the captains or
15 Democratic Party and your appointed interim Executive 15 administer the 13th Ward Regular Democratic
16 Director Representative of Christian Mitchell, are 16 Organization?
17 there any other individuals who serve in administrative 17 MR. KASPER: Excuse me. Tony, are you
18 functions at State of Illinois Democratic Party? 18 talking about now?
19 A Yes, there's a Mary Morrisey who is the 19 MR. PERAICA: I'm talking about the period
20 Chief Operating Officer, and there's an Emily Wurth 20 during April of 2015 through April of 2016.
21 W-u-r-t-h who is the Chief Finance Officer. 21 MR. KASPER: So all this -- we'll just
22 Q Any others? 22 assume that all this line of questioning is --
23 A There are other employees there, but the 23 MR. PERAICA: Yes.
24 names I've given you would be the main people. 24 MR. KASPER: -- confined to that window of

Page 83 Page 85
1 Q How many employees are there total at the 1 time?
2 both Chicago and the Springfield offices? 2 MR. PERAICA: Correct.
3 A I don't know the answer to the question, 3 THE WITNESS: Restate the question.
4 and it fluctuates so during campaigns there's more. 4 BY MR. PERAICA:
5 When you're not in a campaign season there's less. 5 Q Other than yourself, Alderman Marty Quinn,
6 Q Okay. Going to the 13th Ward Democratic 6 Moe Zahdan, who is the Ward Superintendent and Chief of
7 Organization, is there a membership requirement for 7 Staff to Quinn, anyone else working with the precinct
8 acceptance as a member of the 13th Ward Democratic 8 captains of the 13th Ward Democratic Organization on a
9 Organization? 9 regular basis?
10 A Well, we would hope that they're Democrats. 10 A During that time period that you set out?
11 Q Anything else? 11 Q Yes.
12 A There is -- the answer is no. 12 A Kevin Quinn.
13 Q So there's no membership fee or anything of 13 Q And what was Kevin Quinn's role?
14 that sort that one would have to pay? 14 A To work with and interact with the precinct
15 A The answer is yes. There is no membership 15 captains.
16 fee. 16 Q Was he a precinct captain coordinator as
17 Q Does one have to by necessity serve as a 17 one would be normally called?
18 precinct captain or assistant precinct captain or is 18 A The answer is yes.
19 that optional? 19 Q And is Kevin Quinn still with your 13th
20 A That's optional. That's a decision to be 20 Ward Democratic Organization?
21 made by the individual. 21 A No.
22 Q And the final call as to who would be the 22 Q What happened there?
23 precinct captain in any precinct in the 13th Ward is 23 A He was terminated.
24 made by you as Committeeman?
24 Q By?

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1 A Me. 1 Quinn being a close associate and assistant in terms of
2 Q And that was your unilateral decision? 2 the work of the organization and Kevin Quinn who is
3 A Yes. 3 Marty Quinn's brother, is that correct?
4 Q And why did you terminate him? 4 A That's correct.
5 A Because of wrongdoing on his part. 5 Q Being a precinct captain coordinator, would
6 Q And the wrongdoing would be what? 6 any other individuals besides them -- besides you and
7 MR. KASPER: Objection. 7 Marty and Kevin Quinn who worked as coordinators or
8 MR. VAUGHT: I will object this is outside 8 leaders of the 13th Ward Democratic Organization?
9 of the scope. This was post April 2016. It's not 9 A During that period of time?
10 relevant to this lawsuit. 10 Q Correct.
11 BY MR. PERAICA: 11 A Those are the two that I would know of.
12 Q Well, did it have to do with his work on 12 Q Does Moe Zahdan have a particular role
13 the political front for you as a Committeeman? 13 within the 13th Ward Democratic Organization either
14 A The answer to that question is no. 14 loosely assigned or a structure?
15 Q Did it have to do with his outside 15 A He would work with Alderman Quinn in terms
16 activities outside of the 13th Ward Democratic 16 of coordinating activities of Members of the Ward
17 Organization? 17 Organization.
18 MR. KASPER: Objection. 18 Q So who -- since you don't deal with the
19 MR. PERAICA: Yes. 19 precinct captains directly, who would report to you as
20 MR. KASPER: That by itself proves that 20 to any concerns that they would have?
21 it's outside the scope of the deposition. 21 A Alderman Quinn.
22 MR. PERAICA: During that period. 22 Q Does Moe Zahdan report to Alderman Quinn
23 MR. KASPER: This is not covered by the 23 who then reports to you or does Moe Zahdan report
24 scope of the deposition. 24 directly to you?

Page 87 Page 89
1 MR. PERAICA: What paragraph are you 1 A Moe does not report directly to me.
2 referring to? 2 Q So he would go through Alderman Marty
3 MR. VAUGHT: 2(d). 3 Quinn?
4 MR. PERAICA: Well, let's take a break, if 4 A That's correct.
5 we may at this point, and we'll come back with that 5 Q Does Kevin Quinn report directly to you or
6 question. 6 does he go through his brother Marty Quinn?
7 THE VIDEOGRAPHER: This is the end of Tape 7 A Kevin Quinn has been terminated.
8 1. We're off the record at 12:32. 8 Q I know while he worked.
9 9 A He would have reported to his brother.
10 (WHEREUPON, a break was had.) 10 Q Marty Quinn?
11 11 A Yes.
12 MR. PERAICA: Back on the record. 12 Q As I was looking at the D-2s for payment
13 THE VIDEOGRAPHER: Tape 2 back on the 13 made to the political workers and operatives, there was
14 record at 12:51. 14 a distinction between a merit pay and a bonus pay, are
15 15 you familiar with that?
16 (WHEREUPON, the deposition of 16 A I'm familiar with payments made to people
17 Michael J. Madigan was 17 for political work without regard to the adjective that
18 resumed.) 18 you used.
19 19 Q So did the 13th Ward Democratic
20 BY MR. PERAICA: 20 Organization pay precinct captains bonus money for
21 Q Mr. Madigan, we were talking about the 21 political work?
22 structure that you had at the 13th Ward Democratic 22 A The answer is yes.
23 Organization at 6500 South Pulaski, and you mentioned 23 Q And what would be the criteria to qualify
24 in addition to yourself as Committeeman, Alderman Marty 24 for receiving a bonus pay?

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1 A That would be a recommendation by Alderman 1 A I'm the named beneficiary on the title, and
2 Quinn. 2 I make spending decisions.
3 Q And that's the only basis that you would 3 Q Are you the chairman of that committee?
4 have to determine whether to give someone a bonus or 4 A I'm not sure of the legal titles associated
5 not? 5 with the committee.
6 A The recommendation of Alderman Quinn. 6 Q Is it fair to say that no moneys get spent
7 Q What would Alderman Quinn use as a 7 from Friends of Michael J. Madigan Committee unless you
8 criteria, is there some certain test that would have to 8 approve it?
9 be met? 9 A The answer is yes.
10 A I wouldn't have the answer to that. 10 Q Is this strictly a vehicle for donations or
11 Q All right. What about the merit pay, do 11 is there an organizational structure in this committee?
12 you know -- 12 A This committee would be for spending
13 A I think the merit pay and the bonus pay are 13 purposes.
14 the same. 14 Q So does it have an office as such?
15 Q I saw throughout the D-2's verbiage used, 15 A No.
16 you know, best efforts, does that relate to being able 16 Q Does it have any staff, Friends of
17 to, if you know, does that relate to their best efforts 17 Michael J. Madigan Committee, does it have any staff?
18 on -- in that particular reporting cycle when that D-2 18 A Not on a formal basis.
19 was filed or is that simply that you didn't have an 19 Q As needed part time?
20 address for that person and couldn't locate it or do 20 A That's a good way to say it.
21 you know what that means? 21 Q Do you have any independent contractors
22 A I have no idea what it means. 22 that work for the committee?
23 Q Are the moneys that the 13th Ward 23 A Well, we may.
24 Democratic Organization raises spent outside of the 24 Q Again, as needed during elections?

Page 91 Page 93
1 13th Ward? 1 A As needed, sure.
2 A They could be. 2 Q Besides yourself as the person with sole
3 Q So that would be your discretion? 3 discretion for expenditure of funds from Friends of
4 A The answer is yes. 4 Michael J. Madigan, does anyone else have any either
5 Q In other words, you can go to any area of 5 reporting function or any other function besides
6 the 22nd District that you represent and spend money 6 yourself?
7 from the 13th Ward Democratic Organization? 7 A In terms of preparing the disclosure
8 A The answer is yes. 8 reports?
9 Q Committee called Friends of Michael J. 9 Q Yes.
10 Madigan, are you familiar with that? 10 A Well, Emily Wurth who's been mentioned
11 A Yes, I am. 11 already would do that.
12 Q And do you know when was that committee 12 Q She would be the Chief Financial Officer of
13 formed approximately? 13 sorts?
14 A Tony, I have no idea. 14 A That's a fair characterization.
15 Q Has it been in existence for a decade or 15 Q Other than Emily Wurth and yourself, anyone
16 two? 16 else?
17 A It's been existence for multiple years. 17 A At one time Tim Mapes.
18 Q Is it still in existence? 18 Q What was Tim Mapes' role before he resigned
19 A Yes it is. 19 with respect to Friends of Michael J. Madigan?
20 Q Was it in existence during the period 20 A He would have been the significant manager
21 leading up to the March 2016 Primary? 21 of that account.
22 A The answer is yes. 22 Q Would Tim Mapes have to during his tenure
23 Q And what role do you play in that
23 with Friends of Michael J. Madigan get your permission
24 committee?
24 for expenditure of funds from that committee?

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1 A More or less, more or less. 1 Friends of Michael J. Madigan only donated money to
2 Q Did you as a matter of practice or policy 2 Democratic candidates at Stale level or below?
3 have any limits up to which he could spend without 3 A Well, as a general rule it supports
4 checking with you and over a certain amount he would 4 Democrats. There may be some Republicans that receive
5 have to check with you? 5 support from that committee. I wouldn't remember at
6 A The answer is no, but he would bring to me 6 this time.
7 significant on spending. 7 Q I couldn't find any, but...
8 Q All right. Anyone else involved during the 8 A You didn't get any checks?
9 existence of that committee besides yourself, Emily 9 Q No.
10 Wurth, Tim Mapes? 10 Do you inform donors or potential
11 A Not that I can remember. 11 donors that funds that are donated to Friends of
12 Q Any reporting in terms of expenditures of 12 Michael J. Madigan may be used for other than your
13 Friends of Michael J. Madigan Committee where the terms 13 various offices that you run for?
14 of merit and bonus are used in the description of 14 A The answer is no.
15 payment to individuals who did work on behalf of the 15 Q Do you inform donors or potential donors
16 committee, would your answer be the same as it was 16 that you will provide funding for Democratic or other
17 before that those would be interchangeable? 17 candidates down the ballot who have nothing to do with
18 A Yes. 18 your district or your ward where you serve as a
19 Q Yes? 19 Democratic Committeeman, meaning, their even outside of
20 A Yes. 20 Cook County?
21 Q Besides supporting your election 21 MR. KASPER: Objection, Tony. I think this
22 efforts -- well, let me strike that question. 22 is beyond the scope of the deposition.
23 Did the Friends of Michael J. Madigan 23 Again, in Paragraph 2(d) "Plaintiff
24 support your re-election activities in the 22nd House 24 shall not question Defendant Madigan regarding the

Page 95 Page 97
1 District? 1 current structure, actions and\or operations of any
2 A The answer is yes. 2 political organizations."
3 Q Did the Friends of Michael J. Madigan 3 MR. PERAICA: Okay. You're right.
4 support your activities for election as a Third 4 BY MR. PERAICA:
5 Congressional District State Central Committeeman? 5 Q So looking at the period of April 2015
6 A I believe the answer is yes. 6 through April of 2016, did Friends of Michael J.
7 Q Did the Friends of Michael J. Madigan 7 Madigan Committee financially support candidates during
8 Committee support your efforts as a State Party 8 that election cycle other than yourself?
9 Chairman? 9 A I don't remember, but I would presume that
10 A Yes. 10 it did.
11 Q Did you also from this Friends of Michael 11 Q Are there any other political organizations
12 J. Madigan Committee support candidacies of other 12 that you belong to other than what we have discussed so
13 individuals? 13 far?
14 A The answer is yes. 14 A Organizations?
15 Q Would that be at the State and Local level 15 Q Political organizations.
16 Congressional level or all of the levels? 16 A Political organizations?
17 A It would not be -- that particular 17 Q Right.
18 committee would not be supportive of Congressional 18 A What did we talk about the 13th Ward
19 candidates because that's a blended committee. For the 19 Organization and --
20 Congressional candidates you need, as you know, Federal 20 Q 13th Ward, Third District, State Democratic
21 hard money. But that committee would be involved with 21 Party, any other political organizations?
22 candidates for State office, candidates for the 22 A I don't think so. I think it's 13th Ward
23 legislature. 23 Democratic Organization, Cook County Central Committee,
24 Q And is it fair to say that that committee, 24 State Central Committee.

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1 Q Are you a member of any national political 1 Alderman who is paid by the City of Chicago, you have
2 committees? 2 his Ward Superintendent present at your office at
3 A I'm a member of the Democratic National 3 6500 South Pulaski paid for by the taxpayers of the
4 Committee because the Chair of the State Party is 4 City of Chicago, how do you distinguish their, and how
5 automatically a member of the DNC. 5 do they segregate their political functions from their
6 Q Do you serve on any particular committee or 6 governmental functions?
7 are you a member at large or what's the -- 7 A In the case of Moe Zahdan, he would only be
8 A At the DNC? 8 at the political offices at 6500 South Pulaski when
9 Q Yes. 9 he's not on the City payroll, so he would come there
10 A I'm simply a member. 10 after work.
11 Q How often do you participate in meetings at 11 In the case of the alderman, he's an
12 the DNC, Democratic National Committee? 12 elected official, and he apportions his time as he
13 A Very seldom. 13 deems best.
14 Q Is it once every two years with the 14 Q You would agree that one is not to use
15 congressional elections or less than that or? 15 government resources for political purposes, right?
16 A It might be more than that. 16 A The answer is yes.
17 Q More than that. Annually? 17 Q So in the apportionment of time whether for
18 A As a general rule, I don't attend their 18 yourself or these other individuals that work closely
19 meetings. 19 with you, do you enforce that segregation between the
20 Q Are you in any leadership position there at 20 governmental and political work?
21 the DNC, just asking? 21 A That's a rule that we operate under. Let
22 A Well, do you think they do that for me if I 22 me speak for myself. All right? So I have certain
23 don't go to their meetings? 23 obligations as a State Representative, as the Speaker,
24 Q It happens, yes. 24 and I fulfill those obligations. I give whatever time

Page 99 Page 101

1 A The answer is no. 1 is needed to fulfill those obligations. In addition, I
2 Q Can you tell me what your practice is or 2 do some political things, some campaign things.
3 what your philosophy is with respect to the distinction 3 Q But not at the same time?
4 between these political functions that you hold that 4 A Correct.
5 we've talked about, the 13th Ward level as a 5 Q So looking at the second floor of 6500
6 committeeman, the Third Congressional level as a 6 South Pulaski, you said your office being the most
7 committeeman, State Party, National Democratic Party, 7 northern office, it's at the north end of the building
8 these are the governmental roles that you have as the 8 known as the Balzekas Museum of Lithuanian Culture
9 member from the 22nd District Speaker of the House 9 going south from your office, that office that you are
10 State of Illinois. 10 in you said you pay out of your own personal funds?
11 A Sure. 11 A Yes.
12 Q How do you -- what is your philosophy on 12 Q And then the outside support staff that's
13 keeping those separate? 13 right outside of your office, who pays for that?
14 A Well, you understand that there are certain 14 A That's a blend.
15 legal requirements on separation and that's what I 15 Q Blend of who?
16 would abide by. I'm an active member of the Democratic 16 A City of Chicago and State of Illinois.
17 Party and the Democratic Party has certain issue 17 Q So it's paid for by the taxpayers of the
18 positions that its an adopted. I would become an
18 City or the State for that support staff outside of
19 advocate for those positions before the government, but
19 your office?
20 I'm not going to engage in any inappropriate or illegal
20 A As they work on City issues or State
21 issues, and then general constituent service issues,
21 activity in terms of blending. I'm not going to do
22 the answer is yes.
22 that.
23 Q And then Alderman Quinn has his office?
23 Q So, for example, when you have, you know,
24 A Yes.
24 in your role as a 13th Ward Committeeman you have the

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1 Q Are there any other elected officials who 1 conversion date than a later one.
2 have that office? 2 Q So I'm asking you as a matter of policy
3 A No. 3 since you're the guy who sets policy there, is it a
4 Q Just the two of you? 4 month before the Primary Election, is it three months
5 A Yes. 5 before, six months before, when?
6 Q And then Alderman Quinn's support staff 6 A I don't have the exact answer for you. I
7 Moe Zahdan has his office there? 7 can go back and check our records.
8 A Well, Moe occupies one of the offices that 8 Q If you would.
9 you're referring to in the southern part of the suite. 9 A We would. But let me repeat, we're going
10 Q Okay. 10 to exercise caution. If we're going to err on the side
11 A When he's there. 11 of caution, they have a longer date rather than a
12 Q Right. 12 shorter date.
13 A Now, again, he's only there when he 13 Q Are the telephones outside of your office
14 finishes his work with the City. 14 at the northern end of the Balzekas building at
15 Q Right. And is that paid for by the City, 15 6500 South Pulaski, are those outside phones paid for
16 that office or is it paid for by someone else? 16 by you or the taxpayers?
17 A Well, in certain times it's paid for either 17 A For the telephones in the office, when
18 by the City or the State. When we get into a heavy 18 we're not in campaign season some are paid for by the
19 political season, it's paid for with campaign money. 19 City of Chicago, some are paid for by the State of
20 Q So how do you actually keep track of what 20 Illinois. There's a line in my office that I pay for
21 it is being used for on any particular day? 21 personally. Once we get to campaign season everything
22 A We operate with a great deal of caution so 22 is converted to campaign payments.
23 when it gets -- when we're moving into the busy 23 Q When I questioned Alderman Silvana Tabares,
24 political campaign season, all the payments are done 24 who I believe at that time was still State

Page 103 Page 105

1 with political money. 1 Representative Silvana Tabares, she said that she made
2 Q From where, Friends of Michael J. Madigan? 2 phone calls in support of your candidacy in weeks
3 A Probably Friends of Michael J. Madigan. I 3 leading up to the March 2016 election from the phones
4 say it that way because I'm not certain on the account, 4 right outside of your office there at 6500 South
5 but in all likelihood Friends of Michael J. Madigan. 5 Pulaski.
6 Q So do you keep a log where you have by day, 6 MS. CLOSE: I would object to the
7 by hour what purpose it's being used for that -- 7 characterization of Miss Tabares' testimony.
8 A No, we just -- we reach a concern date and 8 BY MR. PERAICA:
9 everything is converted. 9 Q Well, the transcript will show exactly what
10 Q When would that date be normally? 10 the testimony was, but that's my recollection and those
11 A It would be a date, this year it would have 11 were my notes.
12 been sometime July, August. 12 So I'm asking you would the phones
13 Q Let's take the period in question here from 13 right outside of your office be used for calling
14 April of 2015 through April of 2016. 14 potential voters leading up to the primary in March of
15 A Yeah. 15 2016?
16 Q Looking at the March 2016 Primary Election, 16 A Only if they're paid for with campaign
17 when would you convert during that time period to 17 money.
18 political payments being used or campaign funds being 18 Q So if it was paid for with campaign money,
19 used rather than taxpayer paying for that support 19 that money would be coming out of the Michael J. --
20 staff? 20 Friends of Michael J. Madigan Committee fund?
21 A I don't remember the exact date today, but 21 A In all likelihood.
22 as I said, we would operate with great caution. And so 22 Q Are there any other funds that that money
23 in terms of selecting the date for the conversion we'd 23 would come from?
24 err on the side of caution. Let's use an earlier 24 A Well, it could be from the 13th Ward

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1 Organization account. 1 ongoing basis?
2 Q Okay. Any others? 2 A It would be people on our -- our campaign
3 A It could be the House Democratic Majority 3 staff.
4 account. 4 Q So would that be the person who is acting
5 Q Any others? 5 as the campaign manager Alderman Marty Quinn?
6 A It could be the Democratic Party of 6 A I don't know the answer to that question in
7 Illinois. In all likelihood, it's Friends of Michael 7 terms -- are you referring to the design of brochures?
8 J. Madigan. 8 Q Yeah, who would design it?
9 Q Okay. You were elected to the House of 9 A Yeah, it would have been somebody on our
10 Representatives you testified earlier in 1970, correct? 10 staff. I don't know the name of the person would have
11 A Yes. 11 done it during that time period.
12 Q How many wards do you cover within the 22nd 12 Q So is this your staff in Springfield or in
13 District? 13 Chicago?
14 A Today? 14 A In all likelihood in Springfield.
15 Q Yeah. 15 Q Who would be the staff people that would do
16 A There's either three or four wards. 16 that kind of work?
17 There's 23, 14, 13 and maybe 18. 17 MR. KASPER: Objection. He's already
18 Q Was that the case in -- 18 answered he doesn't know the name twice.
19 A 1970? 19 BY MR. PERAICA:
20 Q No. Was that the case in June -- Pardon 20 Q If you know. You don't?
21 me. 21 A I don't know the name of the person that
22 Was that the case in April of 2015 22 design the brochures.
23 through April 2016, those four wards would be included? 23 Q But you do know it was done in-house?
24 A To the best of my knowledge, the answer is 24 A I don't know that. So the people in-house

Page 107 Page 109

1 yes. And there's two precincts in Burbank. 1 might of had a contract with an outside vendor.
2 Q What is your salary as the Member of the 2 Q Your duties as a Representative of the 22nd
3 House? 3 District, do you view that as a full-time or a
4 A You're going to embarrass me again, because 4 part-time position?
5 I don't know the exact amount. I don't know exactly 5 A With me I give all -- I give whatever time
6 what it is. 6 is needed to my duties as a State Representative and as
7 Q You don't rely on it, huh? 7 the Speaker of the House.
8 Do you get additional stipend or 8 Q So it could go 40 hours a week or more?
9 payment as the Speaker of the House? 9 A Much more.
10 A I do. 10 Q As a Speaker of the House, do you have sole
11 Q How much is that? 11 discretion as to committee appointments?
12 A And I don't know what that amount is 12 A I have to give you a complicated answer,
13 either. 13 convoluted answer, right? Under the rules of the House
14 Q Do you have any additional staff beyond 14 the appointments of the committee are done, I believe,
15 being a Member of the House, Speaker any additional 15 by adoption of a resolution. And then in terms of the
16 payments from taxpayers for anything related to your 16 appointments -- you better go back and ask the question
17 function as a Speaker or as a Member of the House? 17 again.
18 A The answer is no. 18 Q Well, I understand there are rules of the
19 Q In the March 2016 primary, you had numerous 19 House, and I have them here. But the rules are rather
20 mailings that went out, is that correct? 20 vague and broad in many instances.
21 A The answer is yes. 21 So among all of the other duties here
22 Q And who designed those pieces for you? 22 is the ability to name Chairman or appoint Members of
23 A I don't know. I don't know. 23 the House, the Chairman as Members of the Committees?
24 Q Do you have someone that you use on an 24 A Yeah, Tony, my memory is coming back.

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1 So, I believe, that the names of the 1 MR. PERAICA: (Continuing) -- and the tape
2 committees are done by the adoption of a resolution. 2 can be edited as necessary.
3 Q Right. 3 BY MR. PERAICA:
4 A And then I appoint the chair, and I appoint 4 Q Other than appointing members of the
5 the Members of the Committee. 5 committee and naming of the Chairman of various
6 Q And you do that in the exercise of a sole 6 committees, what other discretionary authority do you
7 discretion as Speaker of the House? 7 have as it relates to the Members of the Democratic
8 A Yes. 8 Caucus in the House of Representatives?
9 Q So if you don't want to name someone to a 9 MR. KASPER: We're going to renew our
10 committee, they don't sit on the committee? 10 objection. This is beyond the scope of Section 2(a),
11 A That's correct. 11 Tony. Unless you have a demonstrable relationship to
12 Q And if you don't name someone a Chairman of 12 the support of the candidate -- any candidate in the
13 the Committee, they're not a Chairman of the Committee? 13 2016 Primary Election or Larry Dominick.
14 A The answer is yes. 14 MR. PERAICA: Well, I'm relating it to the
15 Q And by having someone named as a Chairman 15 period in question as stated in the Paragraph D(1) --
16 in your exercise, sole exercise of discretion, that 16 D(i) rather.
17 person he or she would get an additional stipend as a 17 MR. VAUGHT: But, Tony, we're talking 2(a).
18 Chairman of the Committee? 18 2(a) says, "Counsel for Plaintiff shall not question
19 A The answer is yes. 19 Defendant Madigan regarding any present or past
20 Q So if the salaries of State Representatives 20 legislative work or electoral strategies other than in
21 are 68,000 or so currently, correct? 21 A(i) 2(i) and 3(i) have specific things you can ask
22 A The answer is yes. 22 about.
23 Q The member that would be named as a 23 On D(1) we're talking about a
24 Chairman of the Committee by you would get an 24 specific time frame but that's all with political

Page 111 Page 113

1 additional stipend of about $10,000? 1 committees. So you've now moved to the legislature
2 A The answer is yes. 2 where we're not talking -- there's no time limitation.
3 Q Do you also control all of the hiring and 3 MR. PERAICA: The question that I'm
4 firing of the support staff for the Democratic Members 4 referring to is covered under 2(a) double ii dealing
5 of the House? 5 with Silvana Tabares, Daniel Lipinski, Larry Dominick
6 A The answer is yes. 6 prior to or during the 2016 Primary Election, that's
7 Q Do the -- 7 what I'm talking about.
8 MR. KASPER: I object to this line of 8 MR. VAUGHT: So you're asking Mr. Madigan
9 questioning under 2(a) "Counsel for Plaintiff shall not 9 whether he hired Larry Dominick, Daniel Lipinski or
10 question Defendant Madigan regarding it past or present 10 Silvana Tabares as staff of the --
11 legislative work or the hiring of staff." 11 MR. PERAICA: No, I'm not asking him about
12 MR. PERAICA: Well, we're dealing with the 12 that.
13 period in question here, which is an exception to the 13 MR. VAUGHT: Well, that was the question
14 rule. 14 you asked about staff.
15 MR. KASPER: Not under 2(a). 15 MR. PERAICA: No, I was asking about the
16 MR. VAUGHT: It's not -- 16 committees.
17 MR. KASPER: It's under 2(a). 17 MR. VAUGHT: Okay.
18 MR. VAUGHT: In 2(a) there's not an 18 MR. PERAICA: And his authority --
19 exception to the time. 19 MR. KASPER: We didn't object to that. We
20 MR. KASPER: Right. That's what I mean. 20 got that part.
21 MR. PERAICA: Well, you can make your 21 MR. VAUGHT: You can ask about that.
22 objection. I'm going to go forward, and we'll let the 22 MR. KASPER: What about -- what's the staff
23 judge rule on those if appropriate -- 23 hiring got to do with it?
24 MR. VAUGHT: He already has. 24 MR. PERAICA: It's got to do with the

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1 exercise of discretion by the Speaker of the House, 1 MR. VAUGHT: Okay. Then ask about Silvana
2 which is the deponent. 2 Tabares.
3 MR. VAUGHT: Who is -- that's legislative 3 MR. KASPER: Yeah.
4 work. 4 MR. PERAICA: That's what I'm getting to.
5 MR. PERAICA: I'm not talking about 5 MR. KASPER: Fine.
6 legislative work. I'm talking about political work. 6 BY MR. PERAICA:
7 I'm talking about people who get hired for a position 7 Q So you're familiar with Silvana Tabares,
8 because they did political work, not that they're doing 8 obviously, correct?
9 it at the same time that they're doing State function, 9 A The answer is yes.
10 separately. 10 Q And she currently serves as the Alderman of
11 MR. VAUGHT: You said there's a clear line 11 the 23rd Ward, which is part of your 22nd District at
12 of demarcation on those. And besides the protective 12 least portion of it, right?
13 order says that the legislative work is not subject to 13 A Yes.
14 the scope of this deposition. 14 Q And she was your running mate in the Third
15 MR. PERAICA: I forgot my question even so 15 Congressional District State Central Committeeman race?
16 if we can get the summary of it, please? 16 A Yes.
17 17 Q Did Silvana Tabares work on your campaign
18 18 for re-election as a 22nd District Representative in
19 19 the March 2016 primary?
20 20 A The answer is yes.
21 21 Q Did she make phone calls on your behalf?
22 22 A I don't remember that, but she may have.
23 23 Q Did she sit outside of your office right
24 24 where you sit at the second floor at 6500 South

Page 115 Page 117

1 (WHEREUPON, the record was 1 Pulaski?
2 read as follows: "Q Other 2 A I don't remember that, but she may have.
3 than appointing members of the 3 Q Did she go door-to-door and advocate on
4 committee and naming of the 4 your behalf?
5 Chairman of various 5 A I don't remember that, but she may have.
6 committees, what other 6 Q Did she go out and work precincts on your
7 discretionary authority do you 7 behalf?
8 have as it relates to the 8 A I don't remember, but she may have.
9 Members of the Democratic 9 Q And after the March 2016 primary, both you
10 Caucus in the House of 10 and Silvana Tabares were elected as Democratic nominees
11 Representatives?") 11 for your respective districts, right?
12 12 A For the House?
13 MR. KASPER: Yeah. 13 Q Yes.
14 MR. PERAICA: And you're pointing to what 14 A The answer is yes.
15 2(a)? 15 Q And both of you were elected in the
16 MR. KASPER: Yeah, 2(A) "Counsel for 16 November 2016 General Election out of your respective
17 Plaintiff shall not question Defendant Madigan 17 Districts?
18 regarding any present or past legislative work." 18 A The answer is yes.
19 You're talking about hiring people on 19 Q And did you name Silvana Tabares a Chairman
20 the staff of the Democratic Caucus of the State office 20 of the Election Committee upon her being sworn-in in, I
21 of the House of Representatives. 21 believe, January of 2017?
22 MR. PERAICA: Right. And my questions are 22 A The answer is yes.
23 going to be relating to 2(a)(ii), particularly, Silvana 23 Q Is it a chairmanship of a committee -- does
24 Tabares.
24 the chairmanship of that committee entitle her and any

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1 other Representative that you name as a chairperson to 1 to Springfield with them and work in the Capitol
2 that $10,000 additional stipend? 2 building.
3 A The answer is yes. 3 Q I see. And the budget appropriation for
4 Q Was it your practice and the exercise of 4 the Members of the House to run their District
5 your discretion as a Speaker of the House to name 5 Constituent Office or offices would be expended by the
6 freshman members to chairmanships? 6 member without any input from the Speaker, correct?
7 A The answer is no. 7 MR. KASPER: Objection. This is again
8 Q How long was Silvana Tabares in the House 8 "shall not question Defendant Madigan regarding past or
9 as a member before she got appointed as a Chairman? 9 present legislative work." You're asking about the
10 A Four years. 10 appropriation, Tony.
11 Q Other than the appointment of chairman in 11 MR. PERAICA: Well, I'm asking about the
12 your role as a Speaker of the House of 12 funding not the appropriation.
13 Representative -- Representatives in the State of 13 MR. KASPER: Well, it's --
14 Illinois, are there any other positions that you can in 14 MR. PERAICA: So skip the budget. I'll
15 the exercise of your discretion appoint members to that 15 rephrase the question.
16 would be providing for an additional payment beyond 16 MR. KASPER: Okay.
17 their regular State Representative salary? 17 BY MR. PERAICA:
18 A People get elected to the House and they 18 Q Do the Members of the House get to spend
19 get the basic salary. And then some are appointed 19 their own money for their local service office in
20 committee chairs, and they get a stipend for that. 20 anyway that they see fit, within rules, obviously?
21 Others are appointed as members of what's called the 21 A Okay. That's the important point to
22 Leadership Team, they get a stipend for that. The rule 22 understand; that they get A District office account and
23 is that people only get one stipend. So if you're the 23 they submit vouchers to what's called the Fiscal
24 member of the leadership and you're also the chair of a 24 Office, and there's a review process in the Fiscal

Page 119 Page 121

1 committee you only get one stipend. 1 Office which is designed to determine there may be some
2 Q But are there any other positions beyond 2 inappropriate attempt at spending.
3 being a member of the Leadership Team working with you 3 Q Does the newly elected House Majority of
4 as a Speaker or being a Chairman of a particular 4 any Party set their own rules every two years?
5 committee working with you as a Speaker, are there any 5 A They have the ability to do that.
6 other positions where additional payment would be made? 6 Q So do you every two years revisit the rules
7 A To the best of my knowledge, no. 7 of the body for amendments?
8 Q Do you have separate staffs for your role 8 A The answer is yes.
9 as the Speaker of the House vis-a-vis your role as a 9 Q And Majority has to support and vote in
10 Member of the House from the 22nd District, do you have 10 favor of any change in rules, right?
11 separate staffs? 11 A The answer is yes.
12 A I think the answer to the question would be 12 Q That also involves the creation of any
13 that there are staffers that work on a payroll that's 13 committees existing or new committees, correct?
14 under my jurisdiction. Then every State Representative 14 A The answer is yes.
15 and every Senator has what's called a District Office 15 Q Does the -- at the initial presentation of
16 account, and they can use that District Office account 16 the House rules each member have the ability to offer
17 to hire workers. They control that spending, I don't. 17 amendments or changes?
18 Q So just that I understand then the support 18 A The answer is yes.
19 staffer for yourself as a Member of the House and other 19 Q In terms of the selective path that a bill
20 house members in Springfield would be determined by the 20 would have to go through, is that covered by the rules?
21 Speaker, is that true? 21 MR. KASPER: Objection.
22 A I think answer is yes. Now understand that 22 MR. VAUGHT: Objection. We're getting into
23 an individual member might use their District Office 23 schoolhouse rock here.
24 account to hire someone and that person would come down 24 MR. KASPER: Exactly.

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1 MR. VAUGHT: This is 2(a) -- 1 MR. KASPER: Objection. Tony, this is
2 MR. PERAICA: Okay. I'll withdraw the 2 legislative action. This is not permitted by the
3 question. 3 protective order.
4 BY MR. PERAICA: 4 MR. PERAICA: I'm trying to get to the
5 Q As a Speaker of the House, are you involved 5 Special Assistant.
6 in the redistricting? 6 MR. VAUGHT: Who is it?
7 MR. KASPER: Objection. Same, legislative 7 MR. KASPER: Yeah, I don't --
8 action. Redistricting is legislative action under the 8 THE WITNESS: Yeah, Tony, I think I've
9 Illinois Constitution. 9 answered your question. I don't know of anybody that I
10 BY MR. PERAICA: 10 consider to be a Special Assistant.
11 Q Did you have anything to do with the 11 BY MR. PERAICA:
12 boundaries of your 22nd House District? 12 Q Well, do you have someone who keeps your
13 MR. VAUGHT: Objection. 13 schedule?
14 MR. KASPER: Objection. Same, legislative 14 A I do that.
15 action. 15 Q You do that personally?
16 BY MR. PERAICA: 16 A Yes.
17 Q Who is your special assistant to you as a 17 Q No one assists you in that regard?
18 House Speaker? 18 A I do the schedule. It's maintained in a
19 A Special assistant? 19 computer by my secretary in Springfield.
20 Q Yes, do you have a person with the title 20 Q We asked for a production of that schedule
21 Special Assistant to the House Speaker? 21 for the period in question and it wasn't produced.
22 A Not that I remember. Do you have a name 22 MR. KASPER: We objected.
23 you want to ask about? 23 MR. PERAICA: Yeah.
24 Q Well, you said that Tim Mapes was your 24 MR. VAUGHT: You never followed up.

Page 123 Page 125

1 Chief of Staff? 1 MR. PERAICA: We did send a letter.
2 A Yes. 2 MR. VAUGHT: I don't believe I got a 37-2
3 Q Who is your Chief of Staff now? 3 letter. If you want to follow-up on that you can.
4 A Jessica Basham. 4 MR. PERAICA: We will. So we're asking for
5 Q How do you spell that? 5 the production of those either digital or in hard copy
6 A B-a-s-h-a-m. 6 records for the period in question of April 2015 to
7 Q Is there anyone else other than Chief of 7 April of 2016.
8 Staff that you would have working with you as a Speaker 8 BY MR. PERAICA:
9 of the House? 9 Q Who is the secretary that would have
10 A I think the best answer I can give you is 10 access to your schedule?
11 to say that I have a process to review bills and 11 A Mika Baugher.
12 amendments and the participants would be the Chief of 12 Q Michael Bauer?
13 Staff, the Director of the Research Unit. 13 A Mika.
14 Q Who's that? 14 Q Mika.
15 A That was Jessica Basham. It's now Mark 15 A M-i-k-a B-a-u-g-h-e-r.
16 Jarmer J-a-r-m-e-r and the Director of the Issue 16 Q Was Mika Baugher your assistant for
17 Development Unit whose name today is Craig Willert 17 scheduling in that period that we're talking about
18 W-i-l-l-e-r-t.
18 April of 2015 through April of 2016?
19 Q Were these people in these positions
19 A I don't remember, because she's recently
20 during --
20 been appointed to that position.
21 Q Do you know who was there before her?
21 A I'm not finished.
22 A Joanne Sullivan.
22 Q I'm sorry. Go ahead.
23 Q Is Joanne Sullivan still with your staff in
23 A Counsel to the Speaker would participate.
24 some other capacity?
24 Q Who would that be?

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1 A She's retired. 1 A The House Democratic Caucus is a term
2 Q Are you familiar with the Illinois House 2 that's used to describe the Democratic Members of the
3 Democratic Majority Political Action Committee? 3 House.
4 A You think that's the committee that I refer 4 Q Right.
5 to as the House Democratic Majority? 5 A And we do Caucus meets. We meet among
6 Q Yes. 6 ourselves, and they're called Caucus Meetings.
7 A I'm familiar with it. 7 Q Right.
8 Q What is your role with that committee? 8 A That's the extent of the House Democratic
9 A I don't know my legal title with the 9 Caucus.
10 committee, but it's a fundraising committee that 10 Q My question is, does the Illinois
11 supports candidates either House Democratic candidates. 11 Democratic Caucus whether, you know, formally organized
12 Q And do you have sole discretion for 12 or informally do any fundraising themselves?
13 expenditures of funds from that committee? 13 A No.
14 A Yes. 14 Q Did you review your petitions before they
15 Q Does anyone else have that kind of 15 were filed?
16 authority or discretion? 16 A No.
17 A No. 17 Q In -- let me finish my question.
18 Q Does anyone else other than you involved 18 Did you review your petitions before
19 with the House Democratic Majority Committee? 19 they were filed in November of 2015?
20 A Can you state the question again? 20 A No.
21 Q Is anyone else other than you involved with 21 Q Is that your usual practice?
22 the Illinois House Democratic Majority Political Action 22 A Yes.
23 Committee, that's how it's listed in the disclosures? 23 Q And why would you not review them to make
24 A So what does involved mean? 24 sure that they were done correctly?

Page 127 Page 129

1 Q Meaning, do they have any function other 1 A Because they would have been reviewed by
2 than what you said being the person who has final 2 someone else.
3 authority to expend moneys, who else is involved in 3 Q And who would that be?
4 reporting, does anyone else get involved in any other 4 A For one Marty Quinn.
5 way? 5 Q And who else?
6 A The names I gave you previously Emily Wurth 6 A I don't remember.
7 would prepare the Disclosure Reports. 7 Q So you would rely entirely on Marty Quinn
8 Q Anybody else? 8 to make sure those petitions were properly designed,
9 A On a formal basis in terms of accepting 9 circulated, signed, notarized, packaged, and gotten
10 receipts and documenting expenditures -- 10 ready for submission to the State Board of Election?
11 Q Right. 11 A And he would have worked with others.
12 A -- it's Emily Wurth. 12 Q To your knowledge who else would Marty
13 Q Is there anyone on an informal basis who 13 Quinn work with?
14 would be involved besides you and Emily Wurth? 14 A I don't remember.
15 A Not that I can remember. 15 Q Was there someone like Mr. Kasper who would
16 Q You're familiar with the Illinois House 16 review as an attorney or any other lawyer?
17 Democratic Caucus? 17 A Mr. Kasper may have been one of the people.
18 A Yes. 18 Q Okay. Anyone else who would within the
19 Q Does it have a separate Fundraising 19 usual course of events review your package to make sure
20 Committee? 20 That it's --
21 A No. 21 A Not that I would remember.
22 Q So that would be funded through the House 22 Q Okay. I want to show you those two pages
23 Democratic Majority Committee if any member of the 23 here. One is a Statement of Candidacy for re-election
24 Caucus needed financial assistance? 24 in the 22nd District in March of 2016, and the other is

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September 13, 2018
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1 a Loyalty Oath. 1 A I don't remember.
2 Take at a look at these first two 2 Q Was Shaw Decremer a member of the 13th Ward
3 pages. 3 Democratic Organization?
4 A Yeah, that's my signature. 4 A Not to my knowledge.
5 Q That was my question. 5 Q Did he have an office or a space at 6500
6 So looking at the first page of this 6 South Pulaski, second floor?
7 nominating petition set which is entitled Nomination -- 7 A Not to my knowledge.
8 pardon -- it's titled "Statement of Candidacy." It 8 Q Was he ever there?
9 contains your signature down here? 9 A He may have been in that space.
10 A Yes. 10 Q Well, did he have you sign these documents
11 Q Did you sign that in front of a Notary? 11 Statement of Candidacy and Loyalty Oath on
12 A The answer would be yes. 12 November 14, 2015 in the office at 6500 South Pulaski?
13 Q And the Notary was Shaw Decremer? 13 MR. KASPER: Objection. He already stated
14 A That's the name that's on there. 14 he doesn't remember signing it.
15 Q And then looking at the second page of this 15
16 petition packet document titled "Loyalty Oath." 16 BY MR. PERAICA:
17 Do you see that? 17 Q If you remember, that's a specific
18 A Yes, I do. 18 question.
19 Q And it contains a signature here at the 19 A No, I don't remember.
20 bottom, whose signature is that? 20 Q Do you remember Shaw Decremer coming to
21 A That's my signature. 21 your house to have you sign these?
22 Q Did you sign this document in front of Shaw 22 A No, I don't remember that.
23 Decremer? 23 Q Was Shaw Decremer ever at your house?
24 A That's how the document reads. 24 A Not to my knowledge.

Page 131 Page 133

1 Q Were both of these documents signed by you 1 Q Does the organization maintain a list of
2 in front of Shaw Decremer on November 14, 2015? 2 Notary, people who have a commission as a Notary Public
3 A That's how the document reads. 3 in the 13th Ward Regular Democratic Organization?
4 Q Well, you have no recollection? 4 A I do not know of a formal list of Notary
5 A Correct. 5 Publics, no.
6 Q Do you remember signing these at all? 6 Q I want to show you what I will mark as
7 A No. 7 Madigan Exhibit 2. Madigan Deposition Exhibit 2.
8 Q How do you know Shaw Decremer? 8
9 A At one time he was one of our staffers, 9 (WHEREUPON, said document was
10 today he's a lobbyist. 10 so marked as Madigan Deposition
11 Q When you say "Shaw Decremer was one of your 11 Exhibit No. 2, for identification.)
12 staffers," can you be more specific? 12
13 A No, because I don't remember which unit he 13 BY MR. PERAICA:
14 worked with or the timeline that he worked for us. I 14 Q Can you please take a look at what we
15 just know that at one time he was one of our staffers. 15 marked as Madigan Exhibit 2?
16 Q Okay. And he was a staffer for you in your 16 A Ready.
17 role as Speaker of the House? 17 Q This is again a printout of a website paid
18 A Well, he would have been a staffer for one 18 for by the 13th Ward Regular Democratic Organization
19 of those units that I set out for you. 19 titled "Madigan-Quinn Website." It has the two offices
20 Q One of the units that you control and 20 at 6500 South Pulaski and 6014 South Central, and it
21 monitor and supervise as a Speaker of the House? 21 lists here a 13th Ward Constituent Service, again,
22 A That's correct. 22 numbers, and then a list of services provided.
23 Q And he was with you for about 10 years or 23 Do you see that?
24 more? 24 A I do.

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September 13, 2018
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1 Q And do you see there in the middle where it 1 the Secretary of State?
2 says that among the various services provided like 2 A Yeah.
3 abandoned vehicle removal, garbage carts, block 3 Q So your memory is that the 13th Ward
4 parties, garage sale permits, graffiti removal, there's 4 Regular Democratic Organization pays that?
5 Notary Public parenthesis (free) end of parenthesis. 5 MR. KASPER: No, he said his memory was
6 Do you see that? 6 vague that they might.
7 A I do. 7 MR. PERAICA: Okay.
8 Q So who provides this service to the 8 THE WITNESS: It's vague, Tony.
9 constituents at the 13th Ward Regular Democratic 9 BY MR. PERAICA:
10 Organization? 10 Q All right.
11 A I don't know. 11 A But, you know, in terms of this there are
12 Q Well, Shaw Decremer provided it to you, did 12 people who work in the office 6500 Pulaski they're
13 you pay him for the service? 13 Notary Publics.
14 A To notarize that document? 14 Q Mm-hmm.
15 Q Yes. 15 A And if someone walks in there and is asked
16 A The answer is no. 16 could you notarize a document, that's a service that
17 Q If a constituents came into the office on 17 would be provided.
18 the second floor at 6500 South Pulaski and wanted a 18 Q I understand that.
19 document notarized, would you be able to assist them? 19 A You know.
20 A I could do it personally. 20 Q My question is who is paying for that
21 Q Are you a Notary? 21 Notary to get the commission or to maintain the
22 A I'm a Notary. 22 commission?
23 Q All right. And how many other people are 23 MR. KASPER: And his answer twice was his
24 Notary there? 24 memory vague, but the Ward Organization might pay for

Page 135 Page 137

1 A I don't know the answer to that question. 1 it.
2 Q My point is, does the 13th Ward Regular 2 BY MR. PERAICA:
3 Democratic Organization pay for either getting or 3 Q Is that your answer?
4 maintaining the commission as notary for its members to 4 A That's the answer.
5 be used during election cycles or for any other reason 5 Q Okay. Thank you.
6 that a constituent may request? 6 Looking at the list of services that
7 A My memory is vague, but it may be that the 7 are provided to the 13th Ward constituents on this
8 Ward Organization pays whatever fees have to be paid 8 joint Madigan-Quinn Website, can you point among the
9 for someone to become a Notary. 9 menu of services provided any State services that would
10 Q Right. You're a Notary yourself? 10 be provided through any State agency or for any State
11 A I am. 11 function? These seem to be all local or aldermanic
12 Q So you know there's a fee associated 12 services.
13 with -- 13 A Circuit Breaker Benefits Access Program,
14 A Yeah, mm-hmm. 14 that's a State administered program.
15 Q You have to get a Surety Bond, right? 15 Q Any others?
16 A Yeah, yeah. 16 A That's the only one that I recognize.
17 Q All that cost money, correct? 17 Q And by providing this service a member of
18 A Correct. 18 the staff would just give or help a constituent fill
19 Q And then after your commission expires you 19 out a form that then gets processed through the usual
20 have to renew it? 20 required channels?
21 A Yeah. 21 A Sure.
22 Q You have to pay a fee again, correct? 22 Q Is that true?
23 A Yeah. 23 A To the best of my knowledge, yes.
24 Q For both the a Surety Bond and renewal with 24 Q I mean, you wouldn't individually deal with

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 Michael J. Madigan
September 13, 2018
Page 138 Page 140
1 these types of things yourself, would you? 1 relations person, who would decides that?
2 A Ordinarily the answer would be no. 2 A I don't know that we had a person
3 Q As a possessor of a Notary seal and a 3 designated public relations person.
4 person who has Commission as a Notary Public, do you in 4 Q Well, who would do your press releases or
5 a usual course of events notarize documents for others? 5 any press communication?
6 A As needed, as needed if called upon. 6 A I don't remember who would do it for the
7 Q When was the last time you did it? 7 campaign.
8 A I don't remember. 8 Q Would Marty Quinn do that or would he make
9 Q In your March 2016 Primary, you said that 9 a decision about that?
10 Kevin Quinn was the coordinator of the precinct 10 A He might be involved in the decision,
11 captains of the 13th Ward Regular Democratic 11 that's not normally something he does.
12 Organization. 12 Q What about literature, who would decide
13 Was there anyone who was assigned to 13 about the content, would you have input on that?
14 coordinate volunteers in your campaign or was it Kevin 14 A No.
15 Quinn who did that as well? 15 Q Who would?
16 A I don't remember. 16 A And I don't remember who would have done
17 Q Did you make a determination as to who 17 that.
18 would work on your campaign personally? 18 Q Would Marty Quinn as a campaign coordinator
19 A I don't remember. 19 work on that?
20 Q Did you delegate to others as to who would 20 A He may have.
21 be hired or involved in your re-election campaign in 21 Q And would that include all aspects in terms
22 March of 2016? 22 of design, content, distribution?
23 A To a certain extent. 23 A The answer is yes.
24 Q And who did you delegate to? 24 Q Did you have any attorney review it for

Page 139 Page 141

1 A Well, the main person would be Marty Quinn. 1 legal ramifications, you know, like Michael Kasper or
2 Q And then did you leave it up to Marty Quinn 2 any other lawyer?
3 to decide as to who he would involve in your 3 A Yeah, not that I remember. It may have
4 re-election effort? 4 been Kasper.
5 A The answer is yes. 5 Q In terms of the authorization for payment
6 Q Would Marty Quinn and Kevin Quinn then work 6 of these expenditures for design, content,
7 with the precinct captains and volunteers on a 7 distribution, would you make decisions about payment of
8 day-to-day basis? 8 those items or would that be Kevin Quinn or Marty
9 A The answer is yes. 9 Quinn?
10 Q Would they report to you as necessary if 10 A It would not be me, and I don't remember
11 there were any issues? 11 who it would be.
12 A The answer is yes. 12 Q But as a campaign coordinator Marty Quinn
13 Q Both of them or just Marty Quinn? 13 may have some input?
14 A Mainly Marty Quinn, maybe every once in a 14 A He may have been involved.
15 while Kevin Quinn. 15 Q Did you have a regular printer that you
16 Q And in terms of the decision as to who 16 worked with?
17 would do polling, would you make that decision or would 17 A In that campaign, I don't remember.
18 you delegate that to Marty Quinn? 18 Q Did you have a separate campaign office for
19 A It would be Marty Quinn. 19 your 22nd District re-election in May of 2016?
20 Q In terms of naming pole watchers or 20 A Not that I remember.
21 precinct election day workers inside or out, who would 21 Q So whatever was done was done out of the
22 make that determination? 22 6500 South Pulaski, second floor?
23 A Marty Quinn. 23 A To the best of my memory that's the case.
24 Q What about who would be the public 24 Q Did you do anything from the other location

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 Michael J. Madigan
September 13, 2018
Page 142 Page 144
1 at 6014 South Central? 1 MR. SULLIVAN: You know what come on, Tony.
2 A Not that I remember. 2 He said he doesn't recall.
3 Q Did you ever have a campaign office for any 3 BY MR. PERAICA:
4 of your races separate and apart from 6500 South 4 Q Did you have Sunday telephone conferences
5 Pulaski? 5 in relation to your campaign?
6 A I don't remember that. 6 A The answer is yes.
7 Q Is it true that the circulation of the 7 Q When did you begin to have those telephone
8 petitions for March 2016 primary cycle begin sometime 8 conference on Sundays?
9 at the end of September, I believe? 9 A I don't remember.
10 A That sounds correct. 10 Q Was it before the filing date in November
11 Q When did you first learn about the other 11 of 2015?
12 candidates in your 22ndDistrict Democratic Primary 12 A I don't remember but it probably was.
13 Race? 13 Q Was it in September of 2015 leading up to
14 A Sometime before the filing. 14 November filing date?
15 Q Well, the filing was at the end of November 15 A I don't remember.
16 of 2015, was that the first time you found out about 16 Q It was sometimes in the second half of
17 it? 17 2015?
18 A No, we knew that there were other 18 A I just don't remember.
19 candidates that wanted to file in the Democratic 19 Q But was it in the second half of 2015?
20 Primary Election. 20 A I don't remember.
21 Q How did you learn that? 21 Q Is there anything that you remember about
22 A Just by word-of-mouth. 22 when you had these Sunday teleconferences begin?
23 Q Who told you about that? 23 A Yes, they were on Sunday mornings.
24 A I don't recall. 24 Q But besides that you have no recollection

Page 143 Page 145

1 Q When did you learn that other candidates 1 of the time frame?
2 may be running in the March 2016 Primary? 2 A It would have been around all these
3 MR. KASPER: Objection. He already said he 3 campaign activities.
4 did not recall. 4 Q And who would originate these
5 BY MR. PERAICA: 5 teleconferences on Sunday mornings?
6 Q I thought you said it was shortly before 6 A I don't remember.
7 the filing date? 7 Q Did you call from your house or were you at
8 A Well, it was certainly before the filing. 8 the office?
9 Q Isn't it true that you also knew about 9 A I was at 6500 South Pulaski.
10 potential, other potential candidates, well before the 10 Q Would these other participants call into
11 November 2015 filing date? 11 the office then and join in?
12 A I don't recall when I learned that there 12 A Some would be at the office and some would
13 were others that wanted to file in the primary. 13 call in.
14 Q Well, you said you heard through the 14 Q All right. Who other than yourself
15 grapevine that other candidates were gearing up, did 15 participated in these Sunday morning teleconferences?
16 you learn that in July of 2015? 16 A I don't remember.
17 A I don't remember. 17 Q Was Marty Quinn part of the conference?
18 Q Did you learn about it in August of 2015? 18 A Marty Quinn was.
19 A I don't remember. 19 Q Was Will Cousineau part of the
20 Q September of 2015? 20 teleconference?
21 A I don't remember. 21 A He was part of the calls.
22 Q October of 2015? 22 Q And who -- what was his function at that
23 A I don't remember. 23 time at the end of 2015 -- second half 2015?
24 Q So it was November of 2015 when you recall? 24 A He was a campaign supporter.

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September 13, 2018
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1 Q What else? 1 A Yes, we did.
2 A Campaign supporter. 2 Q Did you talk about Joe Barboza?
3 Q Did he -- 3 A We did.
4 A He worked on the campaign. 4 Q Did all of you discuss and talk about
5 Q Did he work for the State of Illinois in 5 Grasiela Rodriguez?
6 anyway? 6 A Yes, we did.
7 A Not at that time. 7 Q And what decisions, if any, were made
8 Q Did he work after? 8 regarding the strategy towards these other candidates,
9 A The answer is yes. 9 if you recall?
10 Q Where did he work at at the State? 10 A Our basic strategy was to identify the
11 A He worked in -- he worked in the Speaker's 11 people that are going to vote for me and identify them
12 Office. He was the head of the Issues Development 12 and get them voted, that was our basic strategy.
13 Unit. 13 Q Well, that's every campaign strategy.
14 Q So Will Cousineau -- you have that spelling 14 A Yes.
15 I believe, right, was he on a leave of absence at the 15 Q Did you look at the demographic back --
16 time? 16 breakdown of the population in the 22nd District?
17 A Our practice is that when we get into 17 A That was not a consideration in the conduct
18 campaign season people take a leave of absence from the 18 of the campaign.
19 State Government. 19 Q Were you aware that the District was in
20 Q Did Tim Mapes participate in this 20 excess of 70 percent Hispanic in Primary of March 2016?
21 teleconference? 21 A I've never heard that it was 70 percent.
22 A Yes, he did. 22 At the time of drafting, it was about 60 percent.
23 Q Did Steve Brown your press person 23 Q When you say at the time of drafting,
24 participate? 24 you're referring to redistricting?

Page 147 Page 149

1 A At times he would. 1 A Yes.
2 Q How long would these last? 2 Q And that would have been in 2010, six years
3 A About two hours. 3 before, correct?
4 Q And what would be the topics of discussions 4 A Probably 2011.
5 typically? 5 Q '11. And would you agree that the District
6 A The status of campaigns that we would be 6 has progressively trended more and more Hispanic over
7 involved in. 7 the years?
8 Q Does that include your re-election campaign 8 A Yes.
9 as well? 9 Q So were you concerned about having a
10 A Yes, it would. 10 Hispanic opponent Jason Gonzales?
11 Q Was there any discussion of Jason Gonzales 11 A No.
12 that you recall during these telephone conferences? 12 Q Why not?
13 A Well, he was one of the opponents in the 13 A Because I know of my own knowledge that I
14 22nd District. 14 have widespread support among Hispanic people in the
15 Q So did you discuss Jason Gonzales? 15 District.
16 A To some extent, yes. 16 Q So you were not concerned?
17 Q Did these telephone discussions on Sunday 17 A About what?
18 mornings among these individuals including yourself 18 Q About a Hispanic candidate running against
19 continue all the way up to and including election day? 19 you in the primary?
20 A Not on election day but close to the 20 A I was concerned about Bruce Rauner, that's
21 election day. 21 what I was concerned with.
22 Q Did -- in addition to Jason Gonzales as one 22 Q I'm not asking you about Bruce Rauner. I'm
23 of the opponents, did you or any of the other
23 asking you about Jason Gonzales.
24 participants talk about the other two opponents?
24 A No, you asked me what I was concerned with.

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 Michael J. Madigan
September 13, 2018
Page 150 Page 152
1 I'm telling you. I was concerned with all the money 1 Sunday for -- this went on for months, I believe,
2 that Bruce Rauner was going to bring into the election, 2 right?
3 that's what I was concerned with. 3 A I don't remember.
4 Q So were you concerned that the money that 4 Q Well, you said you started at least in
5 Bruce Rauner was going to bring into the 22nd District 5 November of 2015, right?
6 election where you were running for re-election would 6 A I don't think I said that.
7 be brought in on behalf of Jason Gonzales? 7 Q No, you don't remember when you started?
8 A Yes. 8 A I think I said I don't remember.
9 Q So what were you going to do about that? 9 Q All right. Well, when the petitions were
10 A We were going to make sure that the voters 10 filed and you knew who the candidates were, did you
11 in the District knew that Bruce Rauner was on the scene 11 then have these meetings going forward all the way
12 and that he was supporting Jason Gonzales because Bruce 12 through March of 2016?
13 Rauner is not a popular person in the 22nd District. 13 A I just don't remember the schedule of the
14 Q As part of your re-election strategy that 14 meetings.
15 you developed with these other individuals Marty Quinn, 15 Q And you do remember as you stated that in
16 Will Cousineau, Tim Mapes, Steve Brown, yourself, did 16 addition to Jason Gonzales the names of Joe Barboza and
17 you discuss bringing in other Hispanic candidates into 17 Grasiela Rodriguez came up?
18 the 22nd District Primary Race? 18 A Well, they were candidates then.
19 A The answer is no. 19 Q Right. You knew that right after November
20 Q There were two other primary District -- 20 filing date?
21 22nd District Hispanic candidates in that race other 21 A We did.
22 than Jason Gonzales, right? 22 Q And did you discuss before the filing date
23 A The answer is yes. 23 before November 29th or 30th of 2015, whenever the
24 Q Did you have anything to do with those 24 filing deadline was, did you discuss with these other

Page 151 Page 153

1 candidates getting on the ballot? 1 members of your telephone discussion group potential
2 A We learned about those candidates, again, 2 other candidates since you felt that it would be
3 by word-of-mouth, and we made a judgment that was 3 helpful to have other candidates in the 22nd District
4 advantageous to me that there would be multiple 4 Race?
5 candidates in the Democratic Primary. My judgment was 5 A We discussed our knowledge that there would
6 at the beginning that not every participant in the 6 be multiple candidates in the Primary Election.
7 Democratic Primary was going to vote for me and the 7 Q Did you reach out to any of your political
8 statistic proved that out. 8 allies to try to get additional candidates onto the
9 So when we learned that there were 9 22nd District Primary Ballot?
10 others that were contemplating candidacies, we thought 10 A I don't remember that.
11 that would be helpful to my campaign. It would be 11 Q Is it possible that you did?
12 advantageous to my campaign. 12 A No.
13 Q So you realized that it would be to your 13 Q So you're certain that you didn't?
14 political advantage on election day March of 2016 to 14 A I don't remember.
15 have additional Hispanic candidates besides Jason 15 Q Oh, you don't remember.
16 Gonzales on the ballot? 16 Did you discuss, for example,
17 A Not Hispanic, just multiple candidates. 17 reaching out to Mike Del Galdo to try to get a
18 And so you study election returns, I study returns, and 18 candidate from Cicero or somewhere else to run for the
19 you know that in my case for certain not every 19 22nd District Primary?
20 applicant for a ballot in the Democratic Primary is 20 A I don't remember that.
21 going to vote for me. And, therefore, in a Primary 21 Q Did you reach out to Larry Dominick?
22 Election it's advantageous to me to have multiple 22 A I don't remember that.
23 candidates. 23 Q Did you reach out to Dan Lipinski?
24 Q During these two-hour discussions every 24 A I don't remember that.

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September 13, 2018
Page 154 Page 156
1 Q Did you reach out to Dan Lipinski's Chief 1 Plaintiff Jason Gonzales."
2 of Staff Jerry Hurckes and ask for assistance in 2 Did you give that answer to that
3 getting other people on the ballot? 3 question?
4 A I don't remember that. 4 A That's how the document reads. Now, again,
5 Q Did you talk to Charlie Hernandez? 5 I may have had a conversation with Charlie Hernandez
6 A I don't remember that. 6 talking about the election. I didn't ask Hernandez to
7 Q You don't? 7 do anything.
8 A No. 8 Q No part of the 22nd District is in Cicero,
9 Q These are your Answers to -- actually, 9 is it?
10 Friends of Michael J. Madigan Answers to Plaintiff's 10 A That's correct.
11 Interrogatories Page 3, Counsel. 11 Q So why would you talk to Charlie Hernandez
12 A Can you restate your question? 12 about your campaign?
13 Q Did you talk to Charlie Hernandez about 13 A He would have been the one that would of
14 getting a candidate on the ballot in the 22nd District 14 initiated the conversation with me.
15 Race? 15 Q Did Charlie Hernandez recommend Joe Barboza
16 A I don't remember that. Now, did I talk 16 as his friend and acquaintance to run in the 22nd
17 about Hernandez about the election. We had 17 District to you?
18 conversations about the election. I don't remember 18 A I have no memory.
19 asking him to go find a candidate. 19 Q What did you talk to Mr. Hernandez about?
20 Q Okay. May I have that? 20 A I don't recall exactly what I talked to him
21 Did you provide Answers to these 21 about, but it's certainly conceivable that he would of
22 Interrogatory questions to you and to these committees 22 said to me, well, you know, I know Barboza, Barboza
23 that you control to your attorney? 23 knows Gonzales.
24 A I participated in preparing those Answers. 24 Q So to the best of your recollection Charlie

Page 155 Page 157

1 Q So in this Answer to Question No. 2, you
2 stated and just to remind you what the question was --
3 MR. VAUGHT: To be clear, Friends of
4 Madigan is stating. He's not stating.
5 MR. PERAICA: Well, you said that --
6 MR. VAUGHT: He said he participated.
7 MR. PERAICA: No, I understand.
8 MR. VAUGHT: But he did not recall.
9 BY MR. PERAICA:
10 Q The Question No. 2 in these Interrogatories
11 to you and to the committee that you control stated "To
12 identify every individual with knowledge or facts
13 pertaining to the allegations in the Complaint and/or
14 whom you believe may have discoverable knowledge,
15 information or data regarding this matter and with
16 respect to each person so identify, describe in detail
17 facts possessed by each such person and identity all
18 documents -- and identify all documents that relate to
19 your Answer to this Interrogatory."
20 The person that you name here Charles
21 Hernandez stated "Mr. Hernandez and Madigan had a
22 conversation, date unknown, during which Hernandez
23 advised Madigan that he was friendly with Defendant Joe
24 Barboza and that Mr. Barboza was also friendly with
1 Hernandez was the one who initiated this conversation
2 with you about Joe Barboza?
3 A I really don't have any memory of the
4 conversation. I know Charlie Hernandez, he's a
5 talkative person, and so I presume you've had
6 conversations with him, and he's the type of
7 personality that he'll take the lead in a conversation.
8 Q Well, again, I'm reading your question --
9 your answer to this question. And your answer to this
10 question was that "Mr. Hernandez and Madigan had a
11 conversation date unknown during which Hernandez
12 advised Madigan that he was friendly with Joe Barboza
13 and that Barboza was also friendly with Plaintiff Jason
14 Gonzales."
15 MR. KASPER: Is there a question?
16 BY MR. PERAICA:
17 Q Is that your answer?
18 MR. KASPER: He's already stated that he
19 has no memory of the conversation twice.
20 BY MR. PERAICA:
21 Q Well, then how did you remember that you
22 had this conversation if you have no memory of it?
23 MR. Vaught: Objection. This Friends of
24 Michael J. Madigan's Interrogatory responses. He said

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September 13, 2018
Page 158 Page 160
1 he participated in the Answer and knows. He didn't say 1 there in response to that Interrogatory Question you
2 he answered everything. So you are saying "you" 2 have no knowledge of anything else?
3 referring to an entity. 3 A I think you and I are talking on two
4 MR. PERAICA: The same question was 4 separate tracks here.
5 answered in the same way in his Individual answers 5 Q Please put me on the right track then.
6 bottom of Page 3. 6 A Well, there's one statement that talks
7 MR. VAUGHT: Okay. Why did you start with 7 about information given -- being given to me by
8 this one? 8 Hernandez. There's another track where you're asking
9 MR. PERAICA: Because I can start with 9 did I ask Hernandez to go and find a candidate, and the
10 anyone I want. 10 answer to that is no.
11 MR. VAUGHT: You can, but regardless the 11 Q Did you have anything to do with the
12 question has been asked and answered. He doesn't 12 recruitment of Grasiela Rodriguez to run in the 22nd
13 remember. 13 District March '16 Primary?
14 BY MR. PERAICA: 14 A The answer is no.
15 Q So my question, Mr. Madigan, is you 15 Q Did you know anything about Jason Gonzales
16 remembered at least that you had a conversation with 16 before he became interested in running in that 22nd
17 Charlie Hernandez, is that correct? 17 District Race?
18 A In that conversation would have been what? 18 A No.
19 Q In which, even though you don't remember 19 Q Did you know that he had an office in the
20 exact date, date unknown, Charlie Hernandez advised you 20 22nd District?
21 that he knew and was friendly with Joe Barboza, you 21 A No.
22 remember that, right? 22 Q Did you have anything to do with the no
23 A I do. 23 parking signs being put in front of his office?
24 Q And that Barboza was also friendly with 24 A I don't even know where the office was, and

Page 159 Page 161

1 Jason Gonzales? 1 the answer is no.
2 A I remember that as part of that document. 2 Q Well, Alderman Marty Quinn certainly knew
3 Q And did you provide that answer when this 3 because he would be the one who would have to make
4 document was being responded to? 4 those requests to the City Streets and Sanitation.
5 A That's how the document reads. 5 MR. KASPER: Is there a question?
6 Q So it is your answer then, correct? Here's 6 MR. SULLIVAN: I'm going to object. That's
7 your personal Answer to the Interrogatory. It's at the 7 not a question. Now you're testifying on the record.
8 bottom of that page. 8 BY MR. PERAICA:
9 A I see that. I see that. And so Hernandez 9 Q You've been involved in local aldermanic
10 volunteers to me that he knows Barboza, Barboza knows 10 business for a long time, isn't that true?
11 Gonzales. I think this all started when you were 11 A I've never served as an Alderman.
12 asking did I ask Hernandez to ask Barboza to run, the 12 Q I know you haven't served, but Alderman who
13 answer is no. 13 have served as Aldermanof the 13th Ward served with
14 Q Did you ask Charlie Hernandez to ask 14 you in that same location where you are at daily?
15 Barboza to run in the 22nd District? 15 A The answer is yes.
16 A No. 16 Q So if someone comes in and there are Ward
17 Q Did you ask Charlie Hernandez's wife, Lisa 17 issues you would by osmosis learn about it, if not,
18 Hernandez, Elizabeth Hernandez, to ask Joe Barboza to 18 directly being told about it, right?
19 run? 19 A The answer is yes.
20 A No. 20 Q And you didn't know anything about the --
21 Q Did you ask anybody to solicit Joe Barboza 21 about the request to have the City of Chicago put no
22 to enter that 22nd District Democratic Primary? 22 parking signs in front of the office run by the Jason
23 A No. 23 Gonzales campaign, is that your testimony?
24 Q So even though your answer is as it reads 24 A That's my testimony.

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1 Could you give me the address of that 1 A I don't remember.
2 office? 2 Q Was this a topic of discussion between you
3 MR. PERAICA: What was the address? 3 and other members of the teleconference every Sunday?
4 MR. GONZALES: The address I believe was 4 A It was a topic of discussion. It may not
5 4849 South Pulaski, if I recall. 5 have been every Sunday.
6 BY MR. PERAICA: 6 Q But you did -- you do recall discussing
7 Q 4849 South Pulaski. 7 that?
8 A I don't think that's in the 13th Ward. 8 A Yes.
9 MR. KASPER: It's not in the 13th Ward. 9 Q Was that brought up by one of the
10 BY MR. PERAICA: 10 participants in this two-hour Sunday teleconference?
11 Q I said 22nd District, but I'll withdraw 11 A Again, I don't recall specifically, but it
12 that question. 12 was discussed.
13 A Okay. Good. You know you have to have a 13 Q Was the Jason's -- Jason Gonzales'
14 few laughs, Tony. 14 background discussed in terms of his past history?
15 Q Of course. 15 A Yes, it was.
16 Do you know Julia Larkin? 16 Q And did you talk to these other
17 A Only by name. 17 participants about that?
18 Q How do you know her? 18 A Yes, we did.
19 A I believe that she may have been a staffer 19 Q Did you discuss obtaining records from the
20 in Springfield at one time. 20 Prison Review Board during these phone conferences?
21 Q Do you ask Julia Larkin to do a background 21 A I don't recall a specific discussion about
22 search on Jason Gonzales? 22 that, but I know now that records were obtained from
23 A No. 23 the Prison Review Board.
24 Q Did you ask Julia Larkin to obtain records 24 Q Did you direct someone to do that?

Page 163 Page 165

1 from the Prisoner Review Board? 1 A No.
2 A No. 2 Q Did you instruct one of the other
3 Q Did you ever meet Jason Gonzales before the 3 participants in this conversation to do that?
4 March 2016 Primary? 4 A No.
5 A No. 5 Q Did you discuss Joe Barboza as a
6 Q Did you ever meet Grasiela Rodriguez before 6 potentially Governor Rauner supported candidate?
7 March 2016 Primary? 7 A I don't recall.
8 A No. 8 Q Did you discuss Grasiela Rodriguez as
9 Q Did you meet Joe Barboza before the March 9 potentially having Governor Rauner's support?
10 2016 Primary? 10 A I don't remember.
11 A To the best of my knowledge, no. 11 Q Did you talk to Silvana Tabares about the
12 Q Why do hedge that answer? 12 Jason Gonzales campaign?
13 A Because I have been advised that he may 13 A Not that I remember.
14 have been at a social event and said hello to me. 14 Q How about Shaw Decremer, did you discuss
15 Q What social events? 15 Jason Gonzales with Shaw Decremer?
16 A I don't recall. 16 A Not that I remember.
17 Q Who decides on what endorsed candidates go 17 Q Did you discuss Jason Gonzales or his
18 on the 13th Ward sample ballot?
18 campaign with Ray Hanania?
19 A I do.
19 A Not that I remember.
20 Q Do you know who prepares the sample ballot
20 Q Do you know Ray Hanania?
21 A I know Ray Hanania. He's very fond of you.
21 for distribution?
22 Q And you know he's a Town of Cicero
22 A Marty Quinn.
23 spokesman?
23 Q Who told you about Governor Rauner possibly
24 A Well, you're telling me something I didn't
24 funding the campaign of Jason Gonzales?

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1 know. 1 A To the best of my knowledge, the answer is
2 Q Did you talk to Ray Hanania about writing 2 no.
3 any Op-Ed pieces about Jason Gonzales? 3 If it makes you feel any better, we
4 A No, I didn't talk to anyone. 4 could produce numerous articles by Hanania very
5 Q Did you instruct any of these other 5 negative on me, if you're interested in reading them.
6 individuals? 6 Q Did you help Ray Hanania when he ran for
7 A No. 7 the 10th Ward Alderman?
8 Q Did you request a criminal record of Jason 8 A No.
9 Gonzales? 9 Q No?
10 A No. 10 A No.
11 Q Did you instruct anybody else to get it for 11 10th Ward in Chicago?
12 you? 12 Q Yeah.
13 A No. 13 A When did that happen?
14 Q Did you see a criminal record, background 14 Q A long time ago.
15 records of Jason Gonzales? 15 MR. KASPER: Yeah, right.
16 A Not that I remember. 16 MR. PERAICA: He confirmed it, by the way.
17 Q Did you talk to Marty Quinn about that? 17 BY MR. PERAICA:
18 A About what? 18 Q Are you familiar with the Midway Baseball
19 Q About getting Jason Gonzales' background 19 Field?
20 or -- 20 A Yes.
21 A Not that I remember. 21 Q How do you know that Midway Baseball -- do
22 Q -- criminal history records? 22 you go there with your grandkids or do you visit there
23 A Not that I remember. 23 for political reasons or?
24 MR. PERAICA: Take 5 minutes. We have to 24 A I'm normally there on Opening Day.

Page 167 Page 169

1 change the tape. 1 Q And have you attended the Opening Day for
2 THE VIDEOGRAPHER: End of Tape 2, off the 2 the baseball season at Midway Baseball Field for the
3 record at 2:24. 3 last 30 years?
4 4 A No, not 30 years, but maybe 5 to 10.
5 (WHEREUPON, a break was had.) 5 Q Do you know that Joe Barboza is a coach of
6 6 several teams in that baseball league?
7 MR. PERAICA: Ready? 7 A I did not know that.
8 THE VIDEOGRAPHER: Beginning Tape 3. We're 8 Q Did you meet Joe Barboza at Midway Baseball
9 back on the record at 2:36. 9 Field?
10 10 A I don't remember that. If he's one of the
11 (WHEREUPON, the deposition of 11 participants, he may have said hello to me.
12 Michael J. Madigan was 12 Q Do you know a person by the name of Emilio
13 resumed.) 13 Cundari C-u-n-d-a-r-i?
14 14 A No.
15 BY MR. PERAICA: 15 Q Also known as Emo Cundari?
16 Q Back on record. Just to follow-up on the 16 A No.
17 Ray Hanania questions that I asked you earlier. 17 Q Do you know or have any interaction with
18 Was Ray Hanania ever engaged by 18 the firm, company called Robert R. Andreas
19 either you or any of your entities or committees as a 19 A-n-d-r-e-a-s Sons Construction Company?
20 public relations or a press person? 20 A No.
21 A The answer is no. 21 Q Do you know whether Joe Barboza ever worked
22 Q Did -- to your knowledge did Ray Hanania 22 at the 6014 South Central office, which was one of the
23 ever volunteer for any of your campaigns and in 23 two offices listed on your website with Marty Quinn?
24 particular for the March 2016 primary? 24 A The question again, did I know that Barboza

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Page 170 Page 172
1 worked there? The answer is no. 1 A I know Mike Thomson.
2 Q You know that from personal experience or? 2 Q Was he a Political Director of the 13th
3 A I just -- I have no knowledge of that, no 3 Ward Democratic Organization during that period between
4 memory of it. 4 April of 2015 to March of 2016?
5 Q Okay. Did -- do you recall Joe Barboza 5 A No.
6 ever asking you to intervene regarding an immigration 6 Q Who was?
7 problem for one of his relatives directly with you? 7 A There was no Political Director of the 13th
8 A The answer is no. 8 Ward Organization.
9 Now, Tony, I've learned for the first 9 Q That spot was vacant?
10 time today that he may be active around Midway 10 A There's never been a spot like that in the
11 Baseball. And I have been there for Opening Day and a 11 13th Ward.
12 lot of people talk to me, and I don't know their names 12 Q Well, was Mike Thomson working at 6500
13 and somebody may have started talking to me about an 13 South Pulaski during that time frame?
14 immigration problem, and I may have suggested well, why 14 A No.
15 don't you call 65th Street talk to somebody over there, 15 Q Was he in Springfield during that time?
16 but I don't remember any conversation like that with 16 A I presume that he was in Springfield
17 Barboza. 17 because he lives in Springfield.
18 Q Is there A representative from Congressman 18 Q Did Mike Thomson have any role in your
19 Lipinski's office in that 65th Street Central Avenue 19 March 2016 Primary Race?
20 office? 20 A He may have.
21 A We would just go to Lipinski's office on 21 Q What would he be responsible for?
22 Archer and whoever works on immigration problems, 22 A He would be working in the nature of an
23 that's who we would get involved with. 23 advisor or consultant.
24 Q But you personally don't recall Joe Barboza 24 Q What about Brian White?

Page 171 Page 173

1 approaching you bout an immigration issue with one of 1 A Brian White was not -- he was not involved
2 his relatives? 2 during this time period. Brian White was involved with
3 A I have no memory of that. 3 us years ago, but he's long gone.
4 Q Do you maintaina list of registered voters 4 Q Was he involved in any manner during that
5 for the 22nd District in your office? Is there a 5 time period from April of 2015 through April of 2016?
6 database where all the registered voters are kept? 6 A Not to my knowledge.
7 A To my knowledge, no. I presume that we 7 Q Former Alderman Frank Olivo, was he
8 have the ability to access the voter list. 8 involved in your March 2016 Primary?
9 Q Do you know who would be responsible for 9 A Not to my knowledge.
10 that task? 10 Q You said Will Cousineau was involved at
11 A Well, if I were to put a question in that 11 least in conversations that you had weekly?
12 area, I'd ask Marty Quinn. 12 A The answer is yes.
13 Q All these individuals that I'm going to ask 13 Q And did he have any other role besides
14 you about relate to their work, if any, in connection 14 those conversations that you had over the phone?
15 with your March 2016 Primary Race. 15 A To the best of my knowledge that would be
16 A People that work for me? 16 it.
17 Q These names that I'm going to mention and 17 Q How about Craig Willert W-i-l-l-e-r-t?
18 whether they were involved in your campaign all relate 18 A I don't have any memory of Willert being
19 to your March 2016 Primary Campaign. 19 involved, but Willert was involved with us at the time,
20 A Working for me or against me? 20 and he may have been doing things with Cousineau.
21 Q Let me get to them. 21 Q How about Nick Zaro Z-a-r-o?
22 A Okay. 22 A Nick is a member of the 13th Ward
23 Q The first one Mike Thomson, do you know 23 Organization.
24 Mike Thomson? 24 Q Was he a member during that period in

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1 question? 1 Q Do you know that he's employed at the
2 A To the best of my knowledge, yes. 2 Secretary of State as a Chief Deputy?
3 Q Did he work on your re-election campaign? 3 A No longer.
4 A I have no memory of that, but I presume he 4 Q Retired?
5 did. 5 A Yes.
6 Q Did Julie or Julia Larkin L-a-r-k-i-n have 6 Q Did you recommend him for that position?
7 any role in your re-election campaign in March of 2016? 7 A My memory is that I would have recommended
8 A I have no memory of that. 8 him for that job.
9 Q How about April Burgos B-u-r-g-o-s? 9 Q We got Jennifer Solski, whom I asked about
10 A April works at 6500 South Pulaski. She met 10 a moment ago here as a Ward Office Manager, but you
11 Jason at the polling place. 11 said that she was not a manager but handled the Central
12 Q Did she work on your re-election campaign? 12 Avenue office?
13 A To the best of my knowledge, no. 13 A Yeah, Tony, she may be the manager for that
14 Q Was she a pole watcher where she met Jason? 14 office. I told you I've never been inside of the
15 A She was trying vote, and Jason was trying 15 office. I know that she does Constituent Service, and
16 to get her vote. I can understand she's pretty. 16 she spends most of her time on Central.
17 Q How about Jennifer Solski S-o-l-s-k-i? 17 Q Do you know a person by the name of Erin
18 A I presume that she worked on my campaign. 18 E-r-i-n Foley F-o-l-e-y?
19 Q And what was April Burgos' responsibility 19 A Yes, I do.
20 at 6500 South Pulaski? 20 Q And how do you know her?
21 A Constituent Service. 21 A She's a member of the 13th Ward
22 Q Is Jennifer Solski employed at any of the 22 Organization.
23 offices? 23 Q Do you know if she's employed with the
24 A On Central. 24 Secretary of State?

Page 175 Page 177

1 Q And was she what an office manager there? 1 A I believe she is.
2 A Probably Constituent Service. 2 Q Did you recommend her for that position?
3 Q Do you know the name of -- do you know this 3 A I don't remember that I did, but I may
4 person by the name of Edward J. Tully? 4 have.
5 A Yes. 5 Q How about Henry Wisniewski
6 Q And how do you know him? 6 W-i-s-n-i-e-w-s-k-i?
7 A He's a member of 13th Ward Organization. 7 A He's a member of the Ward Organization.
8 Q Is he also employed at the Cook County? 8 Q Do you know that he works at Cook County
9 A Yes, he is. 9 Human Resource Department?
10 Q Did you have anything to do with his 10 A I don't think so.
11 employment there? 11 Q That's what we have him working at Cook
12 A My memory is that I recommended him for his 12 County.
13 current job. 13 Did you recommend him for that
14 Do you know where he works now? 14 position?
15 Q I do not. 15 A No, no.
16 A Somewhere in Cook County. 16 Q How about Danielle -- pardon me. Daniel J.
17 Q Right. 17 I'll spell the name it's H-u-i-c-o-c-h-e-a?
18 A Yeah.
18 A Huicochea.
19 Q And he was one of your circulators for your
19 Q Huicochea. Do you know him?
20 petitions, right? He was.
20 A I know him.
21 Q Is he a member of the 13th Ward?
21 A Okay.
22 A I think he's no longer with us.
22 Q Do you know a gentleman by the name of
23 Q Was he previously?
23 Thomas G. Siska S-i-s-k-a?
24 A Yes, he was.
24 A Yes.

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1 Q Was he there during the 2016 March Primary? 1 being employed at the City of Chicago?
2 A He may have been. 2 A Yeah, I have no memory of it, but I may
3 Q He also had a job with the State, former 3 have recommended him for the position.
4 State employee, do you know that? 4 Q How about Joseph A. Nasella, do you know
5 A I don't think so. 5 that gentleman?
6 Q That's what our information indicates. 6 A No, I don't know him.
7 Did you have anything to do with his 7 Q He was paid according to the D-2s by
8 employment, did you recommend him to anybody, if you 8 Friends of Michael J. Madigan for political work?
9 recall? 9 A Okay.
10 A Not that I remember. 10 Q You never met him, you don't recall?
11 Q How about Karen Cicero? 11 A To my knowledge I've never met him.
12 A I know Karen Cicero. 12 Q He was also a State employee as a
13 Q How do you know her? 13 legislative assistant to the Speaker of the House
14 A She's member of the Ward Organization. 14 Office.
15 Q Do you know that she's also a member of a 15 A Mm-hmm, mm-hmm.
16 Cicero Voter Alliance? 16 Q Do you -- you never met him in that
17 A You told me something I didn't know. 17 function?
18 Q Do you know that she donated money also to 18 A If he were to walk in the room, I wouldn't
19 Friends of Michael Madigan in 2014, 2016, Karen Cicero 19 recognize the guy.
20 I'm talking about? 20 Q I'm just asking if you remember that name
21 A You're telling me something I didn't know. 21 Joseph Nasella?
22 Q We talked about Moeen Zahdan previously. 22 A No, I don't know.
23 Do you know his brother Ziyadeh 23 Q Okay. He also worked in Cicero for Larry
24 Z-i-y-a-d-e-h Zahdan Z-a-h-d-a-n? 24 Dominick, never came across Joseph Nasella?

Page 179 Page 181

1 A It's easier just to call him ZZ. I know 1 MR. SULLIVAN: I'm going to object. He
2 him. 2 worked for the Town of Cicero. He didn't specifically
3 Q You don't know him? 3 work for Larry Dominick.
4 A I do. 4 MR. PERAICA: He worked for Public Works,
5 Q Is he a member of the 13th Ward? 5 yeah.
6 A He's a member. 6 MR. SULLIVAN: Yeah, he was an employee of
7 Q And he's the brother of the Ward 7 the Town of Cicero until he was fired for failing to
8 Superintendent in the 13th Ward, Moe? 8 appear on time at his workplace.
9 A The answer is yes. 9 MR. PERAICA: All right. We don't need
10 Q Did he work on your campaign in March of 10 that whole history, but thank you.
11 2016? 11 BY MR. PERAICA:
12 A I don't have any knowledge of that, but he 12 Q You have no knowledge of Joseph A. Nasella
13 probably did. 13 at all then?
14 Q Do you know Hugo Chavez? 14 A If the guy walked in the door, I wouldn't
15 A I know Hugo Chavez. 15 know him.
16 Q Not the former president of Columbia -- 16 Q Okay. How about Frank E. Glass G-l-a-s-s?
17 Venezuela, but Hugo C. Chavez I'm talking about? 17 A Yeah, I don't -- I wouldn't know him
18 A Yeah. 18 either.
19 Q Was he a member of the 13th Ward? 19 Q He was also on the payroll of Friends of
20 A The answer is yes. 20 Michael J. Madigan, was State contractual worker in
21 Q Is he still? 21 2016, you don't know anything about him?
22 A No. 22 A Again, Tony, if the guy were to walk in the
23 Q He was a City of Chicago employee perhaps 23 door, I wouldn't know him. Now, that doesn't -- okay,
24 still is, did you have anything to do with his position
24 he has that job. But, again, if he were to walk in the

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1 door, I wouldn't know the guy. 1 BY MR. PERIACA:
2 Q You deal with a lot of people? 2 Q Sir, can you please take a look at the
3 A Yeah, yeah. 3 document that I marked as Madigan Deposition Exhibit 3?
4 Q How about James Fernandez? 4 A Yeah.
5 A Yeah, I don't know him. 5 Q Do you recognize this document?
6 Q He was also paid by Friends of Michael J. 6 A Well, This is a personal service contract
7 Madigan in 2014, according to your disclosure forms and 7 between this gentleman that you're talking about and my
8 he was one of the circulators for Joe Barboza, you 8 office. And I told you I know who this gentleman is.
9 don't know James Fernandez at all? 9 I'm not quite sure what his duties are. Okay.
10 A Again, I wouldn't know him if he walked in 10 Q You hired him on behalf of the
11 the door. 11 Office as a State Representative in the House of
12 Q How about Derek Kucharski 12 Representatives.
13 K-u-c-h-a-r-s-k-i? 13 On the second page of this Exhibit 3,
14 A I have no knowledge of that gentleman. 14 this is your signature, is it?
15 Q He was paid by the 14th Ward. Do you 15 A Yes, it is.
16 recognize him as possibly a member of the 13th Ward? 16 Q It's a little different than your other
17 A No, he's not a member of the 13th Ward. 17 signatures but...
18 Kucharski was a famous name. 18 A Yeah, that's my signature.
19 Q Right. 19 Q And what looks to be a signature of Isidro
20 A You remember that, but I don't know who 20 Rosado?
21 this person is. 21 A Mm-hmm.
22 Q Okay. Do you know a person by the name of 22 Q Dated August 27, 2017.
23 John A. Nagel N-a-g-e-l? 23 A Mm-hmm.
24 A No. 24 Q Did you hire him as a contractor here to

Page 183 Page 185

1 Q Do you know Isidro Rosado? 1 perform work for one year?
2 A I know him. 2 A I signed the contract.
3 Q How do you know him, Isidro Rosado? 3 Q So you did hire him?
4 A He works around the 13th Ward. I'm not 4 A I signed the contract.
5 quite sure what he does, but he works around the 13th 5 Q Sob what did he do for you as a State
6 Ward. 6 Representative pursuant to this service contract?
7 Q Doing what to the best of your knowledge? 7 A Constituent Service work.
8 A Constituent Service. 8 Q In the Chicago office?
9 Q Is that for Alderman Marty Quinn or for 9 A Yes.
10 you? 10 Q Is he still in that position?
11 A I don't know the answer to that question. 11 A To the best of my knowledge, yes.
12 It's in response to a request to come into the office. 12 Q Do you see him around the office when you
13 Q Was he ever involved in your Speaker's 13 come in?
14 Office operation in Springfield or in Chicago? 14 A I saw him in the office a little bit ago.
15 A Not that I know of. I have no memory of 15 Q Was Isidro Rosado involved in your 2016
16 it. 16 Primary Campaign?
17 MR. PERAICA: I'm going to mark this as 17 A I have no memory of that.
18 Madigan Exhibit 3. 18 Q If I told you he was one of the
19 19 circulators, you would be surprised by that?
20 (WHEREUPON, said document was 20 A You're telling me something I didn't know.
21 so marked as Madigan Deposition 21 Q How about George Barrera B-a-r-r-e-r-a?
22 Exhibit No. 3, for identification.) 22 A I know George.
23 23 Q How do you know him?
24 (Document Tendered) 24 A He's a member of the Ward Organization.

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1 Q Do you know he works as a Policy Analyst 1 hard-working people with integrity. And if they are,
2 for the City of Chicago? 2 I'll recommend to a potential employer the best of my
3 A Not anymore. 3 knowledge and my experience with this person, this
4 Q Where is he working now? 4 would be a good worker for your office, a good worker
5 A Chicago Housing Authority. 5 for your business whatever it may be.
6 Q Did you have anything to do with his work 6 Q Is that a function that you enjoy doing?
7 either with the City of Chicago or CHA? 7 A No.
8 A I recommended him to the CHA. 8 Q Is that the least favorite part of your
9 Q And he was hired? 9 job?
10 A He was hired. 10 A That's a tough question. Give me some time
11 Q How about David W. Foley F-o-l-e-y? 11 to --
12 A I know him. 12 MR. KASPER: That calls for an opinion. I
13 Q How do you know him? 13 object.
14 A He's a member of the Ward Organization. 14 MR. SULLIVAN: Does that include giving
15 Q And do you know that he's employed at the 15 depositions?
16 Secretary of State as a Chief Deputy? 16 THE WITNESS: You haven't spent much time
17 A Yes. 17 in Springfield so that would be a whole new world for
18 Q Is he still there? 18 you.
19 A Yes. 19 BY MR. PERAICA:
20 Q Did you have anything to do with him being 20 Q We won't find out.
21 employed there? 21 Do you know a person by the name of
22 A I recommended him to the Secretary of 22 Collin Gruca G-r-u-c-a?
23 State. 23 A There's two Grucas.
24 Q Do you know that he was a circulator for 24 Q Kyle and --

Page 187 Page 189

1 you in that March 2016 Primary? 1 A Yeah, and I somewhat know them both. Here,
2 A You're telling me something that I didn't 2 again, if they were to walk in the door, I may not know
3 know. 3 who they are.
4 Q Do you know Susan Moran? 4 Q So you know Collin Gruca and Kyle Gruca?
5 A Yes. 5 A Mm-hmm.
6 Q How do you know her? 6 Q They're brothers?
7 A She's a member of the Ward Organization. 7 A Yes, hmm-hmm.
8 Q Is she employed with any unit of 8 Q And Collin Gruca is an Assistant State's
9 government? 9 Attorney in Cook County?
10 A She is. 10 A Yeah.
11 Q Where? 11 Q And did you recommend him for that job?
12 A I don't know. 12 A I have no memory of it. But, again, he
13 Q Did you recommend her for whatever position 13 would meet my test, and I would be willing to give him
14 she has with Local or County or State government? 14 a recommendation, but I don't have any memory of doing
15 A Either I did or I would recommend her. 15 it.
16 Q Is it your standard practice to recommend 16 Q Kyle Gruca's brother works for -- as an
17 precinct captains for positions in various levels of 17 assistant to Moody, one of the Moody brothers, you know
18 government? 18 the Moody brothers?
19 A You can understand that many people come to 19 A Yeah, I know him. Do you know him?
20 me asking for recommendations for employment, and I 20 Q Of course I do.
21 render recommendations for employment in both the 21 I believe this was while he was a
22 private and the public sector, I do it in both. But 22 commissioner for a brief time, I didn't think he ran --
23 there's a test that people have to meet. They have to 23 or maybe he still is.
24 be, to my knowledge, they have to be honest 24 A He's still a commissioner.

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1 Q He still is? 1 Q Do you know that James Dispensa also
2 A Right. 2 donates money to 13th Ward Organization?
3 Q So Kyle Gruca is employed with one of -- I 3 A You're telling me something I don't know.
4 can't remember -- 4 Q James Dispensa also donates to Friends of
5 A Ed. 5 Larry Dominick in Cicero, Cicero Voters Alliance?
6 Q Ed Moody at the Board of Commissioners Cook 6 A Mm-hmm.
7 County. Did you have anything to do with his position 7 Q Do you know that?
8 there? 8 A You're telling me something I didn't know.
9 A I have no memory of the recommendation. I 9 Q Do you know James Gleffe G-l-e-f-f-e?
10 would have given a recommendation based upon what I 10 A I do.
11 know about him. 11 Q How do you know James Gleffe?
12 Q And you said you know both Moody brothers, 12 A He's a member of the 13th Ward
13 what's the other gentleman? 13 Organization.
14 A Fred. 14 Q Do that he works for Cook County --
15 Q Fred, that's right. 15 A Recorder.
16 And both Fred -- let's take them one 16 Q Record of Deeds?
17 at a time. 17 A Yes.
18 Fred Moody, is he a member of the 18 Q Did you recommend him for that position?
19 13th Ward? 19 A I have no memory of that, but I would
20 A Yes. 20 recommend him.
21 Q Did you recommend him for his job? 21 Q Do you provide business cards paid for by
22 A My memory would be that I did. 22 the 13th Ward Democratic Organization to your precinct
23 Q I believe he's with the Clerk of the 23 captains?
24 Circuit Court? 24 A Yes.

Page 191 Page 193

1 A Clerk of the Circuit, but he's been there a 1 Q And for what purpose do you provide those,
2 long time, and he probably predated Dorothy Brown. 2 for constituent interaction?
3 Q I believe that to be true, but you would 3 A The purpose would be to use those cards in
4 have recommended -- 4 terms of interacting with the citizens of the area.
5 A I would recommend Fred Moody, because he 5 Q If one is no longer a member of the 13th
6 would meet my test. 6 Ward Democratic Organization, do you ask for those
7 Q What about Ed Moody? 7 cards to be returned?
8 A Well, he would meet my test, too. 8 A No.
9 Q Okay. What about James Dispensa 9 Q You said you saw some of the pleadings in
10 D-i-s-p-e-n-s-a, do you know him? 10 this case, correct?
11 A I believe there's two of them father and 11 A Yes.
12 son. 12 Q I may have asked this before, but did you
13 Q I'm just asking about James Dispensa? 13 have any conversation with any of the named Defendants
14 A I think father is Jim, too. 14 in this case along with you prior to this deposition?
15 Q Okay. Do you know them both? 15 A The answer is no.
16 A I know the father better than the son. I 16 Q Did you have an opportunity or did you talk
17 think I saw the son a couple of weeks ago. 17 to anybody who was deposed or scheduled for a
18 Q Are they both members of the 13th Ward? 18 deposition in this case either before or after they
19 A Either they are or they both were. 19 were deposed?
20 Q Do you know that James Dispensa, I don't 20 A About their deposition?
21 know if it's father or son, there's no middle initial 21 Q Yes.
22 or junior next to it, was one of the circulators for 22 A The answer is no.
23 your nominating petitions?
23 Q We discussed Alderman Edward Burke, Ed
24 A You're telling me something I didn't know.
24 Burke before, his brother Dan Burke ran for a

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Page 194 Page 196
1 re-election campaign for State Senate? 1 A For what?
2 A House. 2 Q Town President.
3 Q State House, beg your pardon. 3 A Again, I have no memory of that.
4 Did you support Dan Burke for 4 Q Did Larry Dominick ever send workers from
5 re-election -- 5 Cicero to help you out in your 22nd District Race?
6 MR. KASPER: Objection. When, what 6 A I have no memory of that.
7 timeline? 7 Q If a State Representative does not support
8 BY MR. PERAICA: 8 your legislative agenda, do you take measures to oppose
9 Q This was -- I think he ran in 2016 as well 9 them in the primary?
10 because every two years they would run, correct? 10 MR. KASPER: Objection. What --
11 A I don't think Dan Burke had an opponent in 11 THE WITNESS: I think I know where he wants
12 '16. He had one in the last election, which was '18 12 to go, but I'm prepared to --
13 Ortiz. 13 MR. KASPER: What is this --
14 Q That's true. But he would run every two 14 MR. PERAICA: Well, it's got to do with the
15 years just like you would? 15 use of State resources in either supporting or opposing
16 A Yes. 16 a member of the Democratic Caucus.
17 Q All right. Did you consider Ed Burke an 17 THE WITNESS: State resources or campaign
18 ally, still do? 18 resources?
19 A Sometimes yes, sometimes no. 19 MR. PERAICA: Campaign resources.
20 Q Was Ed Burke, the brother Dan Burke, a 20 THE WITNESS: Okay.
21 member of your Democratic Caucus? 21 MR. KASPER: Where in the protective order
22 A Yes. 22 does is contemplated?
23 Q Was he -- did he vote for you for Speaker? 23 MR. PERAICA: It isn't.
24 A Yes. 24 MR. KASPER: Where is it contemplated?

Page 195 Page 197

1 Q Did he support your initiatives, bills? 1 "The structure and actions of the Defendant political
2 A Generally, yes, not 100 percent. 2 organization between March 1st, 2015 and April 30th,
3 Q Would you consider former Congressman Bill 3 2016."
4 Lipinski your ally, political ally? 4 MR. PERAICA: Right.
5 A Sometimes yes, sometimes no. 5 MR. KASPER: So just in that time frame.
6 Q How about his son current Congressman Dan 6 MR. PERAICA: Mm-hmm.
7 Lipinski? 7 MR. KASPER: Okay.
8 A Same answer. 8 BY MR. PERAICA:
9 Q Not a consistent ally, political ally? 9 Q Did you understand my question?
10 A Well, Congressman -- current Congressman 10 A You better restated it.
11 Lipinski and I have some issue differences. That's the 11 Q So in March of 2016 Primary, were there
12 nature of the Democratic Party. 12 Members of the Democratic House of Representatives --
13 Q Right. But he's at the Federal level, 13 Democratic Members of the House of Representatives that
14 you're at that State level? 14 you opposed in that cycle?
15 A Correct. 15 A Yes.
16 Q Did you ask Dan Lipinski or any of his 16 Q Who were they?
17 supporters to assist you in the March primary 2016? 17 A Ken Dunkin.
18 A I have no memory of that. 18 Q Anybody else?
19 Q You helped Larry Dominick in his campaigns 19 A The best of my memory now is just Dunkin.
20 for Town President, for example, in 2013, do you send 20 Your question relates to City Members of the House?
21 workers to help him? 21 Q Correct.
22 A I have no memory of that. 22 A Yeah.
23 Q Did you ever help Larry Dominick in any of 23 Q And you opposed him and defeated him
24 his campaigns for Town President?
24 because he didn't cooperate in advancing your

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1 legislative agenda, right? 1 MR. VAUGHT: Objection; privileged.
2 A Well, he joined up with Governor Rauner. 2 MR. KASPER: Let's move on.
3 He was supporting the Governor's Agenda, and he was out 3 BY MR. PERAICA:
4 of sync with just about every other Democratic in the 4 Q As a Speaker of the House, you don't?
5 House. 5 MR. VAUGHT: Move on, Tony.
6 Q So you felt you were justified to spend the 6 We have a protective order and
7 time and money you spent on it to remove him? 7 privilege is a double whammy.
8 A We felt that given the votes that he took 8 BY MR. PERAICA:
9 for Rauner that we should stand against him we should 9 Q You have good lawyers here.
10 oppose him. 10 A Yeah.
11 11 Q Going back to the 6500 South Pulaski, you
12 Q Who is we, is that just you or? 12 said you had your private line that you pay for in your
13 A No, it was me and basic Democratic 13 office?
14 constituents, constituent groups such as Organized 14 A Yeah.
15 Labor. 15 Q How many lines do you have, if you know,
16 Q You get significant financial support from 16 coming into that office total?
17 Organized Labor, right? 17 A In the neighborhood of 10.
18 A Yes. 18 Q And you said that only you and Alderman
19 Q And I looked at the figures in 2016, would 19 Quinn and support staff share that space on the second
20 it be fair to say there was in excess of $5 million 20 floor at 6500 at South Pulaski, is that correct, in
21 combined? 21 terms of elected officials?
22 A I have no knowledge what the total amount 22 A There's two elected officials, correct.
23 of money would be but Organized Labor is supportive of 23 Q Do you have a Spanish speaking staff and
24 my political philosophy, my political beliefs and the 24 volunteers there?

Page 199 Page 201

1 positions I've adopted in the legislature. This is 1 A Yes.
2 where we get into Bruce Rauner in the around turn 2 Q In terms of the back office operation fax,
3 agenda, which is just designed to obliterate Organized 3 copiers, computers, who's that provided by?
4 Labor. 4 A Who pays the rent?
5 Q So in March of 2016 primary and months 5 Q Who pays for acquisition, servicing and
6 leading up to it, you had the support, financial 6 maintenance of those?
7 support, of Organized Labor, right? 7 A Like a Xerox machine?
8 A Yes. 8 Q Yes.
9 Q And you are a friend of Organized Labor? 9 A Friends of Madigan.
10 A And working people. 10 Q Are any of those pieces of equipment
11 Q Right. And as a Speaker of the House, you 11 purchased or paid for by the taxpayers?
12 have the ability to control and shape the Prevailing 12 A No.
13 Wage Act when it comes up for renewal, right? 13 Q What about the furniture?
14 MR. KASPER: Objection 2(a) 14 A No.
15 "Counsel for Plaintiff may not question Defendant 15 Q Who is that owned by?
16 Madigan regarding any present or past legislative 16 A Friends of Madigan.
17 work." 17 Q On the 6014 South Central Alderman Quinn
18 MR. VAUGHT: Further objection that would 18 indicated that the City pays for that office, is that
19 be subject to the legislative privileged. 19 your understanding?
20 BY MR. PERAICA: 20 A I'll take your word for it.
21 Q Well, do you have anything to do with that? 21 Q If the City of Chicago is paying for that
22 A With what? 22 as an Aldermanic service office, why would your name be
23 Q Prevailing Wage Act? 23 on the window?
24 MR. KASPER: Objection; same basis.
24 A Because Alderman Quinn and I operate a

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Page 202 Page 204
1 joint Constituent Service function. We've pooled our 1 Grasiela Rodriguez?
2 resources at 6500 Pulaski and on Central Avenue to 2 MR. SULLIVAN: Objection; that
3 maximize the quality of services provided to the people 3 mischaracterizes the evidence that's been produced in
4 in the area. 4 this case. You took Shaw Decremer's deposition, he
5 Q So the purchase of a graffiti blaster with 5 denied filing those petitions.
6 City funds as Alderman Quinn testified, that would have 6 MR. PERAICA: The clerk filed the
7 been because of the joint efforts the two of you have 7 petitions.
8 in servicing constituents? 8 MR. SULLIVAN: Right.
9 MR. KASPER: Objection. Alderman Quinn 9 MR. PERAICA: But he admitted bringing them
10 didn't testify to that. You're mischaracterizing his 10 to the counter and laying them on the counter.
11 testimony. 11 MR. SULLIVAN: No, he did not. He
12 BY MR. PERAICA: 12 testified that he may have brought them down in
13 Q Is your name on that graffiti blaster that 13 conjunction with 12 to 15 other filing petitions on an
14 was purchased by Alderman Quinn? 14 administrative run for multiple individuals.
15 A I believe it is. 15 MR. PERAICA: Okay.
16 Q We talked previously, Mr. Madigan, about 16 MR. SULLIVAN: He did not testify that he
17 Shaw Decremer and would you characterize him while he 17 filed those.
18 was with you down in Springfield as one of your top 18 MR. PERAICA: I can hear you perfectly.
19 aides? A No. 19 MR. SULLIVAN: I'm sorry.
20 Q How would you characterize him in the 20 MR. PERAICA: No reason to yell.
21 pecking order? 21 MR. SULLIVAN: Yeah, you know what you're
22 A He's somewhere in the line of authority. 22 right, Mr. Peraica, and I apologize for --
23 Q Did you have any discussions with Shaw 23 MR. PERAICA: So I appreciate you making
24 Decremer during the period in question, meaning, April 24 the record.

Page 203 Page 205

1 of 2015 through April of 2016 about Jason Gonzales? 1 MR. SULLIVAN: I know. I was just going to
2 A Not that I remember. 2 say if you have his transcript we can cite to it, but I
3 Q Did you have any conversation with Shaw 3 was at that deposition with him, and I know exactly
4 Decremer about Joe Barboza? 4 what he testified to.
5 A Not that I remember. 5 MR. PERAICA: Okay.
6 Q How about Grasiela Rodriguez? 6 BY MR. PERAICA:
7 A Not that I remember. 7 Q So my question is, did you know that Shaw
8 Q Did Shaw Decremer participate at anytime 8 Decremer was going to drive down with Joe Barboza and
9 during these Sunday morning hour, 2-hour 9 Grasiela Rodriguez's petitions and file them in
10 teleconferences between you and the other participants? 10 Springfield on the last day of filing?
11 MR. SULLIVAN: I'm going to object. You 11 MR. SULLIVAN: Again, I'm going to
12 haven't even laid a foundation that Shaw Decremer was 12 interject. That's a mischaracterization of the
13 even on the Speaker staff during the relevant time 13 evidence. That's -- your question is positing facts
14 frame. You know from taking his deposition he left the 14 that are not in evidence. That's a mischaracterization
15 Speaker staff somewhere around 2012. 15 of the testimony that was given by the Defendant in
16 BY MR. PERAICA: 16 this case, Shaw Decremer. You took his deposition, I
17 Q So do you recall during your conversations 17 was there, that is not what he testified to.
18 on Sunday mornings whether Shaw Decremer participated 18 MR. PERAICA: You stated your objection for
19 in any of those conversations on the phone? 19 the record and that's fine.
20 A I have no memory of that. 20 BY MR. PERAICA:
21 Q Were you aware that Shaw Decremer who 21 Q Do you understand my question or should I
22 worked with you for a decade or longer was going to 22 repeat it again?
23 file petitions for nomination as the 22nd State 23 A You should restate it.
24 Representative candidate for both Joe Barboza and 24 Q Did you know that Shaw Decremer took down

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Page 206 Page 208
1 petitions for Joe Barboza and for Grasiela Rodriguez to 1 Barboza and a set for Grasiela Rodriguez.
2 Springfield? 2 In Shaw Decremer's deposition taken
3 MR. KASPER: Wait. Objection. When? 3 previously he said that he drove them down to
4 MR. PERAICA: On November 30, 2015. 4 Springfield, did you know anything about that?
5 MR. KASPER: No, when are you asking if he 5 A No.
6 had that knowledge? 6 Q Did you instruct him to do it?
7 BY MR. PERAICA: 7 A No.
8 Q Anytime before November 30 of 2015, did you 8 Q Did you instruct anyone else to instruct
9 have any idea that Shaw Decremer was working on 9 Shaw Decremer to do this?
10 petitions for Joe Barboza and Grasiela Rodriguez? 10 A No.
11 A I had no -- 11 Q Did you have any knowledge about it?
12 MR. SULLIVAN: I'm sorry, Mr. Speaker. I 12 A None.
13 apologize. 13 Q Did you have any phone calls with Shaw
14 THE WITNESS: Go ahead. 14 Decremer on November 30 of 2015 before the filing
15 MR. SULLIVAN: But I have to interject an 15 deadline at 5:00 p.m. on that day, the last day for
16 objection now because that question is different. 16 filing?
17 Again, your terminology of working on petitions, I 17 A No.
18 object to that because there is absolutely no evidence 18 Q Did Shaw Decremer try to reach anyone that
19 that's been adduced to this point that Shaw Decremer 19 you are in touch with or who have perhaps communicated
20 worked on either petition that you cited in your 20 to you I heard from him today, meaning, November 30,
21 question. 21 2015?
22 MR. GONZALES: That's my own testimony. 22 A I have no knowledge of that.
23 MR. SULLIVAN: That's a different -- 23 Q Do you know why Shaw Decremer who's a State
24 MR. PERAICA: Please. 24 lobbyist now, as you testified, and who worked on your

Page 207 Page 209

1 MR. SULLIVAN: You never testified to that 1 staff for a decade or longer in the past would take
2 either. I was at your deposition, too. 2 petitions for your opponents in the primary of March of
3 MR. PERAICA: We're not going to get into 3 2016 to Springfield to file them?
4 an argument here. 4 MR. KASPER: Objection. How would he know
5 MR. SULLIVAN: I know but the question, 5 why somebody else was motivated to do something?
6 Mr. Peraica -- 6 BY MR. PERAICA:
7 MR. PERAICA: If you want to make an 7 Q No, I'm asking him do you know why, you, do
8 objection, make it, and let's move on so we can get 8 you know why somebody would do that?
9 home before 8:00 o'clock. 9 A No.
10 MR. SULLIVAN: I'm trying but your client 10 Q Does Shaw Decremer still lobby in
11 interjected. 11 Springfield?
12 All right. I've made my record. 12 A Well, I wouldn't know if he's still a
13 MR. VAUGHT: Certify it. 13 lobbyist. You could look up the list of lobbyists to
14 MR. PERAICA: Not with him here. 14 see if he's --
15 MR. SULLIVAN: Your question 15 Q He is.
16 mischaracterizes the evidence; it assumes facts not in 16 A He's still registered?
17 evidence that you posed to the deponent. 17 Q Yes, he is.
18 MR. KASPER: Why don't we go back -- well, 18 Have you seen him lately?
19 go ahead. 19 A No.
20 MR. PERAICA: Are you finished? 20 Q Have you seen him since March of 2016, Shaw
21 MR. SULLIVAN: Yes, sir. 21 Decremer that is?
22 BY MR. PERAICA: 22 A I presume that I've seen him since then. I
23 Q All right. Mr. Madigan, now regarding the 23 presume that I've seen him since then.
24 two sets of petitions, which I have here a set for Joe
24 Q Did he come to your office to lobby on any

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September 13, 2018
Page 210 Page 212
1 bill? 1 MR. KASPER: Objection. This protective
2 MR. KASPER: Objection. "Counsel for 2 order goes to 2(d) "The structure and actions of the
3 Plaintiff shall not question Defendant Madigan 3 Defendant political organizations between March 1, 2015
4 regarding any present or past legislative work." 4 and April 30, 2016."
5 BY MR. PERAICA: 5 You're asking him about 2009, that's
6 Q What did you -- in what context did you see 6 outside the scope.
7 Shaw Decremer after March of 2016 Primary? 7 BY MR. PERAICA:
8 A I don't remember. 8 Q Did you pay Shaw Decremer to do political
9 Q But you do remember seeing him? 9 work for you between April of 2015 and March -- and
10 A Well, my memory is that I may have seen 10 April of 2016?
11 him. So I may seen him socially in Springfield, you I 11 A I have no knowledge of that.
12 may have been at a social event, he's at the social 12 Q But if the Financial Disclosure Forms show
13 event. 13 that you did, then you wouldn't deny that, would you?
14 Q When did you hear that Joe Barboza and 14 A Well, the document speaks for itself.
15 Grasiela Rodriguez's petitions were filed? 15 Q Did Shaw Decremer also spearhead or manage
16 A I have no memory of that. 16 the campaign for Ken Dunkin's opponent in his State
17 Q Did you hear about that on November 30th 17 District?
18 the day they were filed from anybody? 18 A I have no memory of that.
19 A I have no memory of it. 19 Q You don't?
20 Q Did you hear about these two sets of 20 A I have no memory whether Decremer was
21 petitions for Joe Barboza and Grasiela Rodriguez being 21 involved against --
22 filed after November 30th when they were filed, did you 22 Q Well, he testified that he was.
23 hear about them in the next few days or weeks? 23 A Okay. Then I'll accept his testimony.
24 A Sometime after the end of filing I'm sure I 24 Q In fact, I believe a bonus was paid to him

Page 211 Page 213

1 was advised that multiple candidates had filed. 1 for a good job done?
2 Q Did you inquire then who filed these 2 A Well, it was a good thing to remove Ken
3 petitions? 3 Dunkin. Okay.
4 A No. 4 Q Shaw Decremer did not recall whether he
5 Q Were you told by anybody who filed these 5 paid for his Notary commission.
6 petitions for Joe Barboza and Grasiela Rodriguez? 6 So I'm going to ask you, do you
7 MR. KASPER: Told what? 7 recall if he was one of the notaries that the 13th Ward
8 BY MR. PERAICA: 8 Democratic Organization paid for to --
9 Q Were you told by anybody who filed these 9 MR. VAUGHT: I'm going to object, the four
10 two counter candidates to you for them in Springfield? 10 of us are going to object.
11 A No, I have no memory of that? 11 MR. PERAICA: If I can just finish the
12 Q Did you ever discuss these two nominating 12 question.
13 petition sets with Shaw Decremer at anytime after 13 BY MR. PERAICA:
14 November of 2015? 14 Q To either obtain or renew his Notary
15 A I have no memory of that. 15 Commission?
16 Q According to the D-2's filed for 16 MR. VAUGHT: I'm just going to object
17 expenditures by Michael J. -- Friends of Michael J. 17 because he never said the 13th Ward did. He said his
18 Madigan Committee, Decremer was on the payroll in 18 memory is vague the 13th Ward may have paid for
19 numerous years starting in about 2009, 2010 and 19 somebody, but he never said anybody did or that he knew
20 forward, is that your memory? 20 that anybody did.
21 A Well, I have no knowledge of that. I'll 21 BY MR. PERAICA:
22 take your word for it. 22 Q I exactly agree with you that's why I'm
23 Q Did you engage Shaw Decremer to work on 23 asking the person who knows, the Committeeman of the
24 behalf of Friends of Michael Madigan in 2009?
24 13th Ward Democratic Party who knows everything.

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1 So please tell us, if you know, if 1 you would know why it is, right?
2 you know, whether the organization paid to either 2 A I sign the checks for the 13th Ward
3 obtain a commission for Shaw Decremer as a Notary 3 Organization. I don't sign the checks for Friends of
4 Public or renew his commission as a Notary Public? 4 Madigan.
5 MR. SULLIVAN: And I have to interject 5 Q Who was that that signed the checks?
6 another objection because my recollection of Shaw 6 A It would have been Tim Mapes.
7 Decremer's testimony is that he said, I believe I paid 7 Q And after Tim Mapes left, who would it have
8 for my owns fees, that's my recollection. 8 been?
9 THE WITNESS: Tony, a good answer is that 9 A It probably is Mary Morrissey.
10 in terms of the 13th Ward paying for the Notary seals 10 Q Who?
11 it's for the precinct captains, for the precinct 11 A Probably Mary Morrissey.
12 captains. 12 Q Did you support Silvana Tabares when she
13 BY MR. PERAICA: 13 first ran for House?
14 Q Okay. 14 A No.
15 A Just as we pay for the business cards, we 15 Q Did you support someone else?
16 encourage them to become a Notary, and we pay for it. 16 A We didn't get involved in that District.
17 Q So was Decremer a -- 17 Q Did you talk to anybody at the City, for
18 A No. 18 example, the Mayor or Mayor's office staff about
19 Q -- member of the party? 19 Silvana Tabares being appointed 23rd Ward Alderman?
20 A He was not a member of the 13th Ward 20 A Yes.
21 Organization. 21 Q Who did you talk to there?
22 Q All right. But he was at the office there 22 A Rahm Emanuel.
23 on the second floor 6500 South Pulaski often, right? 23 Q Did you have anything to do after the
24 A Well, from time to time. 24 Primary March of 2016 with selection of staff at

Page 215 Page 217

1 Q I mean, you had him work on, according to 1 Silvana Tabares' Constituent Service Office?
2 the records again, of Michael Madigan, Friends of 2 A Me personally?
3 Michael Madigan on numerous campaigns over the years 3 Q Yes.
4 after he left State Government? 4 A No.
5 A Well, the document speaks for itself. 5 Q Did you instruct anyone else to do it?
6 Q Right. So you don't deny that there was 6 A No
7 interaction between you and Shaw Decremer after he left 7 Q Did you ask Silvana Tabares to hire Elena
8 State government? 8 Hampton at her service office?
9 A That's correct. 9 A No.
10 Q And you don't deny that he was involved at 10 Q Did you instruct anyone else to do it?
11 your request in some of these campaigns against the 11 A No.
12 people that you didn't want to support or oppose, in 12 Q Do you know Grasiela Rodriguez's husband
13 fact, like Ken Dunkin? 13 Mike Rodriguez?
14 A Well, it depends upon the campaigns. 14 A No.
15 Q Right. 15 Q Do you know that Mike C. Rodriguez, the
16 A So you're telling me something I really 16 husband of Grasiela Rodriguez, ran against you in 2012
17 didn't know that he was involved against Dunkin. As I 17 in the Democratic Primary for 22nd House District?
18 told you, that was a good thing to be against Dunkin. 18 A I know it now after the fact.
19 MR. KASPER: By you, are you referring to 19 Q But you didn't know it when?
20 him personally or the organization? 20 A Six months ago.
21 BY MR. PERAICA: 21 Q Did you know that in 2016 Primary the
22 Q Well, you said that you signed the checks, 22 house that Mike Rodriguez and Grasiela Rodriguez live
23 right? So if you saw Shaw Decremer's check or name on 23 in had a Mike Madigan sign in their front yard?
24 a check that you were signing coming across your desk 24 A I didn't know that.

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1 Q Did you have anything to do with Mike 1 MR. PERAICA: I don't have extras.
2 Rodriguez's campaign in 2012? 2 MR. VAUGHT: I just want to make a general
3 A No. 3 objection that this is not related anything left in the
4 Q In 2012 you had a Democratic Primary 4 lawsuit. So I assume you're going to get into stuff
5 opponent, right? 5 that was in the counts that were dismissed, but I'm not
6 A 2012 was another Republican invasion of the 6 going to instruct him not to answer.
7 Democratic Primary. 7 BY MR. PERAICA:
8 Q It seems to be a pattern, huh? 8 Q Have you seen these pieces of literature?
9 A Right. 9 A I'm seeing -- I have no memory of these
10 Q You had Michael Rodriguez running in that 10 from the time that they were distributed.
11 primary against you, right? 11 Q Do you know who designed and prepared
12 A Right. 12 these?
13 Q And you had Olivia Trejo run against you as 13 A No.
14 well, is that correct? 14 Q Do you know who paid for printing them?
15 A I believe that's correct. 15 A No.
16 Q And Terrence Goggin, do you know Terrence 16 Q Do you know who distributed them by mail or
17 Goggin? 17 any other means?
18 MR. KASPER: Objection. Tony, again, 18 A Not today, no.
19 you're way outside the March 1st, 2015 through 19 Q Okay. Were you aware of when these pieces
20 April 30th, 2016 parameter. 20 of literature, political literature, were printed that
21 MR. PERAICA: Well, this relates to the 21 Jason Gonzales was pardoned by Governor Quinn of his
22 relatives of Grasiela Rodriguez who was a candidate 22 criminal offenses?
23 to -- 23 A It's noted on the brochure.
24 MR. KASPER: Goggin is related to 24 Q Where?

Page 219 Page 221

1 Rodriguez? 1 A Right there.
2 MR. PERAICA: No, no, I said Mike Rodriguez 2 Q I can't see that. It must be my glasses,
3 I was asking about. 3 because I can't read it.
4 MR. KASPER: But you're asking about 4 So this is the disclaimer that you
5 activity from 2012. 5 argue would explain the whole story, right?
6 MR. PERAICA: He answered that question, so 6 A Yeah -- well, there's a disclaimer there.
7 I'm moving on. 7 Q You need a magnifying glass to see it, but,
8 MR. KASPER: All right. Let's move on. 8 yes.
9 BY MR. PERAICA: 9 MR. VAUGHT: Why don't we mark these?
10 Q I want to show you -- I'm not going to mark 10 MR. PERAICA: I'm not going use them as
11 these. I just want to show you a couple of -- three, 11 exhibits.
12 actually, pieces of campaign literature used during the 12 I'm just asking you --
13 March 2016 Primary. 13 MR. SULLIVAN: Well, I'm going to object to
14 Have you seen those? 14 that you are using them as exhibits. The deponent has
15 A Well, I'm seeing them now. 15 it, you've asked him multiple questions about it.
16 Q Have you seen them before? 16 We should have those copied --
17 A Not that I remember. 17 MS. CLOSE: We should have copies for us.
18 Q Let's take the one that you're looking at 18 MR. SULLIVAN: (Continuing) -- and they
19 in your hand right there. It says, "Neighborhood alert 19 should be marked as exhibits. You've had seven, eight,
20 be aware of Jason Gonzales criminal -- 20 nine questions to the deponent of that specific
21 A Record. 21 exhibit. It's clearly an exhibit now.
22 Q -- record!" On the other side -- 22 BY MR. PERAICA:
23 MR. KASPER: May I have a copy of that, 23 Q Mr. Madigan, you were aware of the pardon
24 Tony? 24 that Jason Gonzales was granted by Governor Quinn?

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1 A Yes, I was. 1 Q Would all of these pieces would have been
2 Q And you were aware of that prior to the 2 paid for production, distribution by Friends of Michael
3 filing date in March -- in November of 2015, right? 3 Madigan?
4 A I don't have any memory of that. I learned 4 A Again, I wouldn't have any knowledge of the
5 about his pardon early on. I was advised of it by one 5 payments. I just -- I'm not into that.
6 of his former lawyers. 6 Q Okay. And who would be the --
7 Q And that was before the petitions were even 7 A People that work for me and with me.
8 filed in November of 2015, right? 8 Q Did you ever instruct anyone not to send
9 A I don't recall the exact time frame. 9 these pieces to the potential voters' households?
10 Q Certainly, you were aware of the pardon 10 A Tony, again, my focus was to identify
11 prior to March of 2016, right? 11 people prepared to vote for me and get them voted.
12 A In all likelihood, yes. 12 Q I get that. But did you instruct anybody
13 Q Did you also instruct precinct captains to 13 these are just nasty, don't send them out, did you ever
14 inform voters of the 22nd District that Jason Gonzales 14 instruct anyone to do that
15 was a convicted felon? 15 A Have you seen the TV ads put on by Rauner
16 A I didn't have meetings like that with 16 against me, which were running through that period of
17 precinct captains. 17 time?
18 Q Did you say to your precinct captains or 18 Q I'm asking about these pieces here.
19 anyone, any potential voter that because of the 19 A No, no, I'm talking about the nastiness of
20 criminal background that Jason Gonzales would be unable 20 the campaign.
21 to serve? 21 Q Right.
22 A My strategy, as I said earlier, was to 22 A And the defamation that's been performed on
23 identify people who were prepared to vote for me and to 23 me and my family simply because we've got a Governor
24 get them voted, that was my strategy. 24 that thinks he's a dictator, and he was supporting

Page 223 Page 225

1 Q So did you communicate to anybody that 1 Gonzales. That's why Gonzales was there to advance the
2 Jason Gonzales would not be able to serve even if 2 Rauner agenda.
3 elected? 3 Q People have a right to support whomever
4 MR. VAUGHT: Objection. That's related to 4 they want to it's a democracy, right?
5 a count that was dismissed by the District Court. 5 A That's right, and I have that right, also.
6 You can answer. 6 Q Right. But it has to be true, the
7 MR. KASPER: Can you -- unable to, do you 7 information that's put out, right?
8 mean legally precluded? 8 A Those documents are true.
9 MR. PERAICA: Right. Not fit to serve, 9 Q With that disclaimer?
10 cannot serve. 10 A They're true.
11 MR. KASPER: I mean, unqualified or legally 11 Q Do you recall authorizing payment for
12 precluded? 12 production and distribution?
13 MR. PERAICA: Either one of those. 13 A The answer is no.
14 MR. VAUGHT: Well, why don't you ask one at 14 Q Did someone else pay for these pieces to be
15 a time. 15 distributed?
16 I guess the proper way to say it is 16 A I have no knowledge.
17 objection to form. 17 Q So you rely on the documents contained in
18 BY MR. PERAICA: 18 the Financial Disclosure forms, right?
19 Q Did you inform any potential voters that 19 A Document speaks for itself. The documents
20 Jason Gonzales would not be able to serve if elected? 20 speak for themselves.
21 A I have no memory of that. 21 Q Right.
22 Q Did you inform anybody that he would not be 22 A Right.
23 able to run for the office that he was running for? 23 Q Did you advise your precinct captains to
24 A I have no memory of that. 24 tell potential voters leading up to the election or on

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1 the day of election that Gonzales is a Rauner plant? 1 captains not to register Hispanics in the 22nd District
2 A I don't recall that explicit instruction. 2 leading up to the March 2016 Primary?
3 But like I said early on, we viewed this as a 3 A No, the answer is no. We do a very
4 Republican Rauner invasion of the Democratic Primary, 4 aggressive registration program. And our goal is to
5 and it had happened for a reason. The reason was in 5 identify voters that wish to participate in the
6 February of '15, I had a meeting with Rauner. Rauner 6 electoral process and in particular voters that want to
7 laid out his agenda, his turn-around agenda. I told 7 be Democratic voters, and then we register them.
8 him I wasn't going to support it so you know what he 8 Q Did you instruct anyone associated with
9 said to me? Well, if you don't support my agenda, I'm 9 your 2016 campaign to tell the Hispanic voters that if
10 just going to come after you and it was only a few 10 they didn't vote for you that they would have no one to
11 weeks later that they spent $1 million on downstate TV 11 protect them and they will be deported?
12 defaming me and now they're like over $30 million 12 A The answer is no. Who gave you that
13 defaming me. So if you're concerned about nastiness in 13 question? You must of got that from Larry Dominick.
14 politics, why don't you go over and talk to Bruce 14 MR. KASPER: Let's take 3 minutes, okay?
15 Rauner. 15 MR. PERAICA: Sure.
16 Q Well, didn't you do the same thing to Ken 16 THE VIDEOGRAPHER: Off the record at 3:47.
17 Dunkin when he didn't support your agenda? 17
18 A We spoke about the issues on Ken Dunkin and 18 (WHEREUPON, a break was had.)
19 his departure from the policies and the issues of the 19
20 Democratic Party. 20 THE VIDEOGRAPHER: Beginning Tape No. 4,
21 Q And you took him on and pulled him out of 21 back on the record at 3:56.
22 his seat, right? 22
23 A No, he was characterized by Juliana 23
24 Stratton as a sell-out. 24

Page 227 Page 229

1 Q I'm talking about you, not Juliana 1 (WHEREUPON, the deposition of
2 Stratton. 2 Mr. Michael J. Madigan was
3 A You don't like Juliana Stratton? 3 resumed.)
4 Q No, she's a wonderful woman I'm sure. I 4
5 never met her. 5 BY MR. PERAICA:
6 A Okay. 6 Q Back on the record.
7 Q But the point is you as the Speaker of the 7 Mr. Madigan, did you see any
8 House spent moneys from the Friends of Michael Madigan 8 subpoenas for State documentation that were issued by
9 fund and from other funds that you control to take Ken 9 Plaintiff's attorneys in this case, any?
10 Dunkin out? 10 A Not to my memory.
11 MR. VAUGHT: Objection. You said as 11 Q Did you discuss with anyone in any of your
12 Speaker of the House, and then you went to the 12 capacities about their response to a subpoena issued
13 political field that's State. 13 by the Plaintiffs in this case?
14 MR. PERAICA: Strike the Speaker of the 14 A No memory.
15 House. 15 Q Are you aware of any State of Illinois
16 BY MR. PERAICA: 16 personnel being subpoenaed in this case who are not
17 Q In your political function, you spent money 17 parties to the case, named parties?
18 to take Ken Dunkin out, defeat him? 18 A I have no knowledge of that.
19 A We opposed Ken Dunkin. 19 Q Did you have any discussions with your
20 Q Right. Do you have an email yet or no? 20 daughter, State's Attorney General Lisa Madigan, about
21 A No. 21 this 2016 Primary Race?
22 Q Then I'll skip that question. 22 A No.
23 A Okay. 23 Q Did you discuss with your daughter Lisa
24 Q Did you direct your staff and precinct 24 Madigan any of your opponents in the Democratic Primary

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1 Race in March of 2016? 1 Committee issued checks regularly to --
2 A No. 2 MR. KASPER: I don't think that's correct.
3 Q Did you discuss with your daughter about 3 MR. PERAICA: Based on my recollection.
4 obtaining any records regarding Jason Gonzales or his 4 MR. KASPER: It was the Democratic Party.
5 background with her? 5 MR. PERAICA: Was it the Democratic Party?
6 A No. 6 MR. KASPER: I think so not the committee.
7 Q Did you obtain any documents regarding any 7 BY MR. PERAICA:
8 of your opponents including Jason Gonzales through the 8 Q So you have no knowledge or memory of
9 Attorney General's Office? 9 Wilson & Kennedy, LTD.?
10 A No. 10 A That's correct.
11 Q Are you familiar with Power Play 11 Q There were numerous reimbursements by the
12 Properties, Inc.? 12 13th Ward Regular Democratic Organization and Friends
13 A No. 13 of Michael Madigan to Central Management Services, Inc.
14 Q Friends of Michael Madigan pay rent to this 14 Do you know what that would have been
15 corporation, Power Play Properties, Inc. in 2015, 2016, 15 for?
16 do you know what for? 16 A No.
17 A No. 17 MR. KASPER: Central Management Services,
18 Q Have you ever heard of them at all? 18 Inc., the corporation not the State Central Management
19 A No. 19 Services?
20 Q Are you familiar with Saw Bridge Studios? 20 BY MR. PERAICA:
21 A Somewhat. 21 Q Well, Central Management Services,
22 Q What do you know? 22 Incorporated, you're not familiar with that company?
23 A I think they're -- I think they're a 23 A No.
24 provider of gifts. 24 Q Okay. Are you familiar with Maria Trejo

Page 231 Page 233

1 Q Have you purchased gifts for donors or 1 T-r-e-j-o?
2 campaign workers through Saw Bridge Studios through 2 A No.
3 Michael Madigan -- Friends of Michael Madigan 3 Q She's shown to be a salaried employee of
4 Committee? 4 the 13th Ward Regular Democratic Organization?
5 A My understanding is that we've purchased 5 A What -- what kind of -- what's the amount
6 gifts from that company for supporters. 6 of the payments?
7 Q Supporters meaning? 7 Q I don't recall that at the moment.
8 A Political supporters. 8 A Well, if they're smaller payments, it may
9 Q Workers and donors or just workers? 9 be that she cleans the offices.
10 A It's a blend. 10 Q Is Maria Trejo related, if you know, to
11 Q What about the firm of Wilson & Kennedy, 11 Olivia Trejo who ran for 22nd District Representative
12 LTD.? 12 against you in 2012?
13 A Yeah, I don't have any knowledge of them. 13 A I have no knowledge.
14 Q Well, you paid them regularly in 2015 to 14 Q In the same period in question, have you
15 2016 monthly. 15 supported student applicants at the University of
16 A Yeah. 16 Illinois for admission for your political donors?
17 Q And you don't know what it's for? 17 MR. VAUGHT: Objection. That's outside the
18 A No, I don't. 18 scope. That's -- you're referring to legislative
19 MR. KASPER: You, when you say you? 19 scholarships and that would be legislative work.
20 MR. PERAICA: Pardon me? 20 BY MR. PERAICA:
21 MR. KASPER: You said you paid them, what 21 Q No, I'm just -- I'm not talking about
22 are you implying? 22 scholarships which you have a right to award as a State
23 BY MR. PERAICA: 23 Representative, correct, unless they did away with that
24 Q Meaning in -- Friends of Michael Madigan 24 I'm not sure.

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1 A They terminated it. 1 a factual causal relationship to the support of any
2 Q Terminated. Okay. 2 candidate in the 2016 Democratic Primary Election. The
3 But when prior to the termination of 3 house rules have they changed is completely outside the
4 this practice of giving each State Representative 4 scope. And for that matter, I imagine you can dig them
5 certain couple of whatever they were, two, three, five 5 up and print them off. The matter is public record.
6 scholarships through State Universities, have you 6 MR. PERAICA: I could. I could.
7 advocated on behalf of political donors? 7 Can we take a short break, please?
8 MR. VAUGHT: I'm going to object because 8 MR. KASPER: Yeah, sure.
9 that would be legislative work and that does not fit 9 THE VIDEOGRAPHER: Off the record at 4:08.
10 into 2(a)(i) through 3. 10
11 BY MR. PERAICA: 11 (WHEREUPON, a break was had.)
12 Q I'm not talking about his -- I'm not 12
13 talking about your particular scholarships that you 13 THE VIDEOGRAPHER: Back on the record at
14 would have to award. I'm talking generally outside of 14 4:15.
15 the ones that you had discretion as to whom to be award 15
16 those to, have you advocated on behalf of your 16 (WHEREUPON, the deposition of
17 political financial donors to get those? 17 Michael J. Madigan was
18 MR. NALLY: I would object. Are you going 18 resumed.)
19 to clarify, is this the term March 1st, 2015 through 19
20 April 30, 2016? 20 BY MR. PERAICA:
21 BY MR. PERAICA: 21 Q Mr. Madigan, you sent out the pieces that I
22 Q Yes, for the period in question. I began 22 showed you earlier regarding Jason Gonzales and his
23 with that, yes. I began my question with exactly that, 23 background to the constituents or you had your
24 Counsel. We're talking about that period of time April 24 committee send it for you, correct?

Page 235 Page 237

1 of 2015 to April of 2016? 1 MR. VAUGHT: Objection --
2 A The answer is no. 2 THE WITNESS: I have no knowledge of these
3 Q Did you at some point cease to do that or 3 documents that you've just provided me. I mean, I've
4 you've never done it? 4 read them, but I have no knowledge beyond that.
5 A I didn't do it during the period that 5 BY MR. PERAICA:
6 you're talking about. 6 Q And did you send any literature out against
7 Q Okay. All right. Have you lobbied the 7 the other two candidates Rodriguez and Barboza?
8 Metra on behalf of anyone during that period -- 8 A I have no knowledge of that.
9 A No. 9 Q Did you ever hire a private investigator to
10 Q -- to be hired at that agency? 10 look into the background of Jason Gonzales?
11 A No. 11 A Not to my knowledge.
12 Q How about RTA? 12 Q Did you instruct anyone else to hire a
13 A I have no memory on RTA. 13 private investigator or law enforcement person to look
14 Q How about Pace? 14 into the background of Jason Gonzales?
15 A No memory there. 15 A Not to my knowledge.
16 Q Have you ever lobbied anyone to get jobs? 16 Q Did you discuss with anyone accessing leads
17 A Not that I can recall. 17 information, which is a criminal database, to look into
18 Q Under the existing House rules as they were
18 the background of Jason Gonzales?
19 during that period of April 2015 through April of 2016,
19 A I have no knowledge of that.
20 have they changed substantially over the years or have
20 Q I know you said that you had no
21 conversation with Joe Barboza or Grasiela Rodriguez
21 they remained fairly constant, the rules?
22 directly at anytime, is that what you testified to
22 MR. VAUGHT: Objection. That's legislative
23 earlier?
23 work. The legislative work does not have a time period
24 A That's correct.
24 scope. You have to show that it's demonstrably having

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1 Q Did you discuss with any other individual 1 questions from me?
2 about rewarding Joe Barboza after the March primary in 2 MR. PERAICA: After we're done.
3 2016 with a job? 3 Other Counsel may have some questions
4 A The answer is no. 4 here. If you do, gentlemen, feel free.
5 Q Did you call on behalf of Joe Barboza any 5 MR. KASPER: Thank you.
6 individual to recommend Joe Barboza for a position? 6
7 A The answer is no. 7
8 Q How about the same questions as they relate 8
9 to Grasiela Rodriguez? 9 CROSS-EXAMINATION
10 A The answer is no. 10
11 Q Besides the group of people that you 11
12 discussed the March 2016 primary with on these regular 12 BY MR. KASPER:
13 telephone calls every Sunday leading up to the 13 Q Mr. Madigan, Mr. Peraica just asked you
14 election, did you have any other groups of individuals 14 some questions regarding Representative Silvana Tabares
15 that you worked with or discussed the election with 15 and her appointment to be the head of a committee, do
16 leading up to March 2016? 16 you recall that?
17 A Not to my knowledge. 17 A I do.
18 Q You admitted earlier in your 18 Q Do you recall when Representative Tabares
19 Interrogatories that you had conversations with Charlie 19 was appointed to head a committee?
20 Hernandez about Joe Barboza, is that correct? 20 A I don't remember the exact date, but I know
21 MR. VAUGHT: Objection. The Interrogatory 21 that it occurred after she had completed two terms in
22 says he had a conversation, not conversations. 22 the House.
23 BY MR. PERAICA: 23 Q And why was she appointed to become the
24 Q So you had one conversation with Charlie 24 head of a committee?

Page 239 Page 241

1 Hernandez regarding Joe Barboza, is that correct? 1 A We have a policy that before someone can be
2 A My memory is that in a social setting I had 2 appointed as the Chair of a Committee and get the
3 a conversation with Hernandez talking about Barboza and 3 stipend, they have to have completed two terms. They
4 talking about Gonzales, very short. 4 have to have been elected to three terms -- excuse
5 Q Was Charlie Hernandez the only person that 5 me -- appointed or elected to three terms. And then
6 you discussed Joe Barboza with in the Town of Cicero or 6 they enter an eligible class of people that can be
7 Cicero Township? 7 appointed as Chairs of Committees.
8 A I have no memory of that. 8 Q So her appointment to the Chair of a
9 Q Is there anyone else that you have memory 9 Committee was based on seniority?
10 of discussing Joe Barboza with? 10 A It's based on seniority, and it's important
11 A I have no memory today. 11 to understand that she was one of a class. I'm not
12 Q Is Silvana Tabares still the Chairman of 12 sure how many people were in that group, but there was
13 the Committee that you appointed her to the Election 13 a group of House Members who would had gotten to that
14 Committee? 14 point where they had either been elected to two terms
15 A She's no longer a member of the House. 15 and now they're beginning their third, which means
16 Q I see. And when she left the House to take 16 they'd be eligible to be appointed as a Committee
17 over the Aldermanic position, was she still a Chairman 17 Chairman.
18 of that Committee that you appointed her to before 18 Q And was Representative Tabares treated any
19 leaving the House? 19 differently than any other member of that class?
20 A At the time she left she was the Chair of 20 A No.
21 the Committee. 21 Q And has that been your practice
22 MR. PERAICA: I think those are all of the 22 historically?
23 questions that I have. 23 A The answer is yes.
24 THE WITNESS: You want to take some 24 Q Was Representative Tabares' appointment to

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1 that Committee Chairmanship conditioned in anyway upon 1 said Governor Rauner told you that he was going to
2 political work? 2 (quote) "go after you."
3 A The answer is no. 3 Do you recall that?
4 Q I'm sorry. Thank you. 4 A I do.
5 Mr. Madigan, Mr. Peraica asked you 5 Q What did you take that to mean?
6 some questions about your involvement in the 2016 6 A That he was going to employ the methods
7 Primary Election in your Representative District. 7 that we're now familiar with to discredit me, in
8 Do you recall those questions? 8 affect, defame me and my family name including my
9 A Yes, I do. 9 daughter the Attorney General.
10 Q Did you take any action personally to 10 Q Did you understand that to include
11 recruit any candidates to run in the Primary Election 11 supporting a primary opponent against you in the 2016
12 against you? 12 Election?
13 A The answer is no. 13 A I did, because we had a previous attemptat
14 Q Did you direct anyone who works for you or 14 Republican invasion of our primary in 2012.
15 who is associated with you to take any steps to recruit 15 Q Mr. Madigan, are you familiar Vince Cainkar
16 anyone to run in the Primary Election? 16 Vince Cainkar C-a-i-n-k-a-r the Stickney Township
17 A The answer is no. 17 Democratic Committeeman?
18 Q Are you aware of any actions hat anyone who 18 A Yes, I has.
19 works for you or who is associated with you took in 19 Q And are you familiar -- Mr. Peraica asked
20 furtherance of recruiting candidates to run against you 20 you some questions about Ed Burke the 14th Ward
21 in the Primary Election? 21 Democratic Committeeman?
22 A The answer is no. 22 A I know him.
23 Q Okay. And, Mr. Madigan, Mr. Peraica asked 23 Q And Michael Zalewski the 23rd Ward
24 you a number of questions regarding individuals. 24 Democratic Committeeman?

Page 243 Page 245

1 Do you recall those questions? 1 A I know him.
2 A I do. 2 Q And Derek Curtis is the 18th Ward
3 Q Members of the 13th Ward Organization -- 3 Democratic --
4 A Yes. 4 A Yes.
5 Q -- and other people? 5 Q -- Committeeman, do you know him?
6 A Yes. 6 A I know him.
7 Q And he asked you whether or not you made 7 Q And are those the committeemen that makeup
8 job recommendations for those people? 8 the 22nd Representative District?
9 A Yes. 9 A The answer is yes.
10 Q And you indicated that you had a test -- 10 Q And are there any others?
11 A Yes. 11 A To my knowledge, no.
12 Q Is that correct, do you recall that? 12 Q And were they the committeemen during the
13 A Yes. 13 time frame that Mr. Peraica has asked you about
14 Q Does that test ever involve doing political 14 March of 2015 through April 2016?
15 work for you or any of your political committee? 15 A Again, to the best of my knowledge, the
16 A The answer is no. 16 answer is yes.
17 Q Do you condition job recommendations upon 17 Q Did you ever have a conversation with
18 doing political work for you or your political 18 Mr. Cainkar regarding the eventuality of you losing the
19 committees? 19 Primary Election having the winner drop out and having
20 A The answer is no. 20 you get reappointed to the ballot?
21 Q Okay. At some point there was a 21 A The answer is no.
22 discussion, I'm not sure if there was a question 22 Q Did you ever have such a conversation with
23 from Mr. Peraica, but there was a discussion regarding 23 Alderman Burke?
24 Governor Rauner, and I wrote down that (quote) that you 24 A The answer is no.

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1 Q Did you ever have such a conversation with 1 BY MR. PERAICA:
2 Alderman Zalewski? 2 Q I said before November 20 -- November 30 of
3 A The answer is no. 3 2015 filing by these candidates who ran against you,
4 Q Did you ever have such a conversation with 4 you talked about it before, right?
5 Alderman Curtis? 5 A Counsel is correct. I don't recall when we
6 A The answer is no. 6 started the Sunday morning conference calls. There
7 Q Did you ever direct any of your employees 7 were Sunday morning conference calls. I don't know
8 or associates to have such a conversation? 8 when they started.
9 A The answer is no. 9 Q What I'm saying is that you discussed with
10 Q Are you aware of any such conversations 10 these individuals, regardless of when they started,
11 that ever took place between anyone? 11 prior to these petitions being filed by Barboza and
12 A The answer is no. 12 Rodriguez on November 30 of 2015, you and your
13 Q What would you have done had Mr. Barboza 13 participants on these conference calls talked about
14 won the Primary Election? 14 other candidates that you heard through the grapevine
15 A I would have supported him for election in 15 were running, right?
16 the General Election. 16 MR. VAUGHT: Same objection. He said he
17 Q What would you have done had Ms. Rodriguez 17 doesn't know when those calls began.
18 won the Primary Election? 18 MR. PERAICA: I'm not asking him when they
19 A I would of supported her as the Democratic 19 started or began.
20 nominee in the General Election. 20 MR. KASPER: But you're assuming they had
21 Q What would you have done had Mr. Gonzales 21 to of --
22 won the Primary Election? 22 MR. VAUGHT: But you're saying the calls --
23 A I would have supported him as the 23 MR. PERAICA: I'm saying before
24 Democratic nominee in the General Election. 24 November 30 of 2015.

Page 247 Page 249

1 MR. KASPER: Those are all the questions 1 MR. VAUGHT: You reference on these calls
2 that I have. 2 before November of '15?
3 3 MR. PERAICA: Yes.
4 4 MR. KASPER: He can't --
5 5 MR. VAUGHT: He said he doesn't know when
6 REDIRECT EXAMINATION 6 the calls began, right.
7 7 MR. KASPER: Right.
8 8 BY MR. PERAICA:
9 9 Q Well, anytime before November 30 of 2015,
10 BY MR. PERAICA: 10 do you recall having these conversations with your
11 Q Mr. Madigan, you stated earlier that the 11 advisors on the phone?
12 issue of other candidates possibly running in the 22nd 12 A Not at this time.
13 District March 2016 Primary came up well before filing 13 Q You don't?
14 the deadline in November of 2015, right? 14 A Not at this time.
15 A The answer is yes. 15 Q Is there anything that would refresh your
16 Q So you and your circle of advisors or 16 memory?
17 coordinators who had these Sunday morning 2-hour 17 A Just spending more time with you.
18 sessions to discuss the campaign talked about this 18 Q All right, maybe.
19 before the three candidates filed on the last day of 19 Do you have any records or documents?
20 November 13, 2015, right? 20 A No.
21 MR. VAUGHT: Objection. His testimony was 21 Q Did you diary these conversations on your
22 he doesn't remember when those calls began so you can't 22 schedule?
23 date it before the filing. 23 A No.
24 24 Q Were they conducted on your home phone

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1 number? 1 supporting Gonzales, of course we talked about that.
2 A No. 2 Q So you remember that?
3 Q Office number? 3 A Did you see the TV ads?
4 A I don't know. 4 Q Do you remember discussions you had?
5 Q You don't remember anything, right? 5 A Well, did you see the TV ads.
6 A Correct. 6 Q Please I'm --
7 Q Do you remember any conversations about 7 MR. KASPER: Just answer the question.
8 these three candidates after they filed their petitions 8 BY MR. PERAICA:
9 on November 30th, 2015? 9 Q You have to answer questions not ask
10 A Not today. 10 questions. That's what depositions are about.
11 Q Did you have conversations about three 11 So do you -- you remember talking
12 Hispanic candidates running against you after 12 about Jason Gonzales once you saw the money flowing
13 November 30 of 2015 with your circle of advisors? 13 into the 22nd District Race, did you?
14 A Well, not that I recall now. 14 A Yeah, sure.
15 Q Does that mean you didn't have any 15 Q It wasn't something you forgot, did you?
16 conversations? 16 A No.
17 A Well, after the filing, we knew who the 17 Q I mean, it was top on your mind, wasn't it?
18 candidates were. I testified earlier I knew and the 18 A It was.
19 election results proved that I had broad and deep 19 Q Yeah, so you focused on it, and you worked
20 support in the Hispanic community. 20 on it everyday?
21 Q My question is again after November 30th, 21 A Right.
22 2015, did you and your advisors discuss these 22 Q Because you wanted to defeat all three of
23 Hispanic -- three Hispanic candidates who were running 23 them, in particularly, Jason Gonzales?
24 in the March '16 Primary? 24 A We worked to identify our voters and get

Page 251 Page 253

1 A I have no memory at this time. 1 them voted. And our polling told us at the beginning
2 Q Do you remember having conversations 2 that I had over 65 percent support that's why I got on
3 regardless of the substance? 3 Election Day, because we identify our voters and we
4 A No. 4 re-voted them.
5 Q You don't? 5 Q Once you realized the kind of money that
6 A No. 6 was going to be spent in the 2016 District Race in
7 Q Do you remember having these telephone 7 March of 2016, you would have done anything necessary
8 conversations after November 30th, 2015 up to March of 8 to win that election, wouldn't you?
9 2016? 9 A We went to our voters. We communicated
10 A We had telephone conversations. 10 with our voters. We identified people prepared to
11 Q Every Sunday? 11 support Mike Madigan for retention, and we voted them.
12 A Once we started probably every Sunday, once 12 Q By destroying your opponent Jason Rauner?
13 we started. 13 A You got it right.
14 Q For 2 hours each Sunday? 14 Q Strike that.
15 A Yes. 15 MR. VAUGHT: We'll take judicial notice.
16 Q And you don't remember any of it at all? 16 MR. PERAICA: Strike that, that was a
17 A I don't remember -- I don't remember these 17 misstatement on my part.
18 items that you're attempting to question me on right 18 THE WITNESS: Yeah, right. But we won't
19 now. 19 file a lawsuit over it.
20 Q But if you knew that Jason Gonzales was 20 MR. PERAICA: We'll discuss that later.
21 going to be supported by Rauner millions that's not 21 BY MR. PERAICA:
22 something you would discuss with your advisors leading 22 Q But the point is that once you saw that the
23 up to the March 2016 Primary? 23 money was coming in to the candidate Jason Gonzales
24 A Well, now you're talking about Rauner 24 leading up to March 2016 primary, I mean, you knew what

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CAUSLEY COURT REPORTING
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 Michael J. Madigan
September 13, 2018
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1 was happening, if you had any doubts by that time you 1 A What did you mean regardless of where he
2 knew what was happening at that point, right? 2 came from, where does that mean?
3 A It was a fulfillment of Rauner's threat to 3 Q It doesn't matter what the source of money
4 me in February of '15 at the Governor's mansion. 4 was Rauner or somebody else, it doesn't matter?
5 Q And you knew that Rauner's candidate as you 5 A As I said earlier, once the voters in the
6 define Jason Gonzales -- 6 District realize that this was a choice between
7 A Yeah, Jason. 7 Mike Madigan and Governor Rauner's surrogate, they
8 Q -- was going to receive the kind of money 8 voted for Mike Madigan.
9 that Rauner and his supporters can produce, right? 9 Q Did you and your supporters in these --
10 A That's what happened. 10 your advisors rather in these telephone conference
11 Q So weren't you concerned about running 11 discuss recruiting to other Hispanic candidates?
12 against a Hispanic candidate, Jason Gonzales, in a 12 A No.
13 District that's 70, 80 percent Hispanic? 13 Q Never came up?
14 A As I said earlier, as proven by the 14 A The answer is no.
15 election results, I had broad and deep support among 15 Q Did you instruct any of the people who were
16 Hispanic voters. I live in a Hispanic neighborhood. I 16 involved in this process circulators, notarizers, Shaw
17 know my neighbors. I know how they feel about me. 17 Decremer filed them, anybody?
18 Q Didn't that realization that a Hispanic 18 MR. VAUGHT: Objection. This has all been
19 opponent, Jason Gonzales, with millions of dollars 19 asked and answered.
20 coming to his campaign is going to present a problem 20 MR. NALLY: I'll also object to this line
21 leading up to -- problem for you leading up to the 21 of questioning. I want to object to this line of
22 March 2016 Primary Election? 22 questioning beyond the scope of Mr. Kasper's
23 A The truth is that the expenditure of all 23 questioning.
24 the money by Rauner and Mr. Gonzales helped educate the 24 MR. PERAICA: It's dealing with the phone

Page 255 Page 257

1 people in the District as to what the choice was. The 1 calls.
2 choice was whether they're going to support Rauner or 2 BY MR. PERAICA:
3 whether they're going to support me, and they supported 3 Q You never discussed any of that, did you?
4 me. 4 A Discuss what?
5 Q Well, Rauner didn't run ads about Jason 5 Q With any of these individuals recruiting
6 Gonzales convicted felon, you know, unfit to run, can't 6 candidates --
7 serve if elected, you did that, right, or your 7 A My response is I don't have any memory of
8 supporters did that? 8 that today.
9 MR. KASPER: Objection. 9 MR. KASPER: He testified just a couple of
10 MR. VAUGHT: Asked and answered. 10 minutes ago he played no role in recruiting candidates.
11 MR. KASPER: There's no evidence of that. 11 MR. PERAICA: That's what I was following
12 BY MR. PERAICA: 12 up on.
13 Q Who produced those pieces of literature? 13 All right. Any other questions?
14 A I don't know. I don't remember. 14 MR. SULLIVAN: Are you done, Mr. Peraica?
15 Q They just fell out of the sky? 15 MR. PERAICA: I am.
16 MR. VAUGHT: Objection. 16 MR. KASPER: I am done.
17 MR. KASPER: Objection. 17 MR. PERAICA: Signature.
18 MR. VAUGHT: That's argumentative. 18 MR. KASPER: Reserve.
19 BY MR. PERAICA: 19 MR. PERAICA: Signature is reserved.
20 Q The -- once you realized that these were 20 Thank you, sir.
21 the dynamics that were taking place i.e. Hispanic 21 THE VIDEOGRAPHER: This deposition is off
22 opponent, lots of money behind the campaign regardless 22 the record at 4:39.
23 of where he came from, didn't you and your advisors 23 (DEPOSITION CONCLUDED)
24 talk about that during these meetings? 24 - - o o OO o o - -

65 (Pages 254 to 257)

CAUSLEY COURT REPORTING
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 Michael J. Madigan
September 13, 2018
Page 258 Page 260
1 IN THE UNITED STATES DISTRICT COURT 1 Witness my official signature and seal as Notary
NORTHERN DISTRICT OF ILLINOIS
2 EASTERN DIVISION 2 Public in and for Cook County, Illinois, on this 13th
3
4
3 day of October A.D., 2018
JASON GONZALES, ) 4
5 )
Plaintiff, ) 5
6 ) Kimberly E. Causley, C.S.R.
)
7 -vs- ) No. 2016 C 7915 6
)
8 ) 7
MICHAEL J. MADIGAN, et al., ) 8
9 )
Defendants. ) 9
10
11
10
I hereby certify that I have read the foregoing 11
12
transcript of my deposition given at the time and place 12
13 13
aforesaid, consisting of Pages 1 to 260 inclusive, and
14 14
I do make oath that with the corrections made the same
15 15
is a true, correct and complete transcript of my 16
16
deposition so given as aforesaid. 17
17
18
18
______________________________ 19
19 MICHAEL J. MADIGAN
20 20
21 21
SUBSCRIBED AND SWORN TO
22 before me this_________day 22
of____________________a.D., 2018.
23
23
___________________________ 24
24 Notary Public

Page 259
1 STATE OF ILLINOIS )
)
2 COUNTY OF C O O K )
3 I, Kimberly E. Causley, Certified Shorthand Reporter
4 and Notary Public in and for the County of Cook, State
5 of Illinois, do hereby certify that on the 13th day of
6 September at 11:00 p.m., the discovery deposition of,
7 MICHAEL J. MADIGAN, was taken before me, reported
8 stenographically and as thereafter reduced to
9 typewritten form under my direction and control.
10 The deposition was to be taken at 151 North
11 Franklin Street, Chicago, Illinois, and there were
12 present Counsel as previously set forth.
13 The said witness, MICHAEL J. MADIGAN, was first
14 duly sworn to tell the truth, the whole truth and
15 nothing but the truth, and was then examined upon oral
16 interrogatories.
17 I further certify that the foregoing is a true,
18 accurate and complete record of the questions asked of
19 and answers made by the said witness MICHAEL J.
20 MADIGAN, at the time and place herinabove referred to.
21 The undersigned is not interested in the within
22 case, nor of kin or Counsel to any of the parties.
23
24

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A 106:4 80:3 87:24 255:5 199:3 225:2 68:9,14

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103:4 106:1 26:20 70:3 252:3,5 198:1,3 64:18 65:23 allies 153:8

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allocate 47:1,3,7,10 137:3,4 219:6 181:8 apportion...

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46:15,21 136:23 158:5,12 appear 49:4 72:11 235:1,19,19

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245:14 asking 8:6 125:16 16:5 17:11 77:10 228:21

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259:18 124:5,10 15:13,21 2:20 3:5 207:18 169:5,8,21

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169:24 Baugher 125:2 142:9 137:23 board 37:20 204:9

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