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dc-3409940Court UnsealedDeposition

Guevara Deposition Juan Johnson

Date
January 24, 2017
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Court Unsealed
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dc-3409940
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55
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REYNALDO GUEVARA Condcnsclt TM JOHNSON v GUEVARA IN THE UNITED STATES DIStRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION 1 3 JUAN JOKNSON, ) ) Plciintiff, ) vs. No. ) RE¥NALDO GUEVARA dnd <he c;ITY OF CHICAGO, ' OS c 1042 "· X Exam;lnation by: Mr. Gardiner 6 ) ) 7 ) Defendants. Reynaldo Guevara 5 ) 7. Witness: 3 4 ) I N D 2 ) B 9 10 11 The deposition of REl'NALDO_ GUEVARA, 12 . by the Plaintitt tor examination 10 called 11 notice 13 and pur£

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REYNALDO GUEVARA Condcnsclt TM JOHNSON v GUEVARA IN THE UNITED STATES DIStRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION 1 3 JUAN JOKNSON, ) ) Plciintiff, ) vs. No. ) RE¥NALDO GUEVARA dnd <he c;ITY OF CHICAGO, ' OS c 1042 X Exam;lnation by: Mr. Gardiner 6 ) ) 7 ) Defendants. Reynaldo Guevara 5 ) 7. Witness: 3 4 ) I N D 2 ) B 9 10 11 The deposition of REl'NALDO_ GUEVARA, 12 . by the Plaintitt tor examination 10 called 11 notice 13 and pur£udr.t to the Federal Rules of civil 12 14 Proceduz:e for the United States District Courts 13 15 pertaining to the taking ·.of depositions-,' takEm 14 16 before Cynthia A. Sink.cvicz, Certified sho.tthand 15 17 Reporter and NOtary 'public within and for "the 16 18 County of Cook and 17 19 53 West Jackson 20 ·Illinois,· on the fllinois, at E X II I B I T S Number 79 19 Suite 950, Chicago, 19 of Ma-rch 2007. 21 20 22 21 23 22 23 24 1 2 . GARDINER.KOCH & WEISBERG, by MR. THOMAS G. DANIEL J. 222 North LaSalle Street, Suite 200 Chic-dgo, Illinois 60601 1312) 726-1180 un behalf of the plaintiff; LTD., 11 550 12. Itasca, Illinois 60143 (630). 735-3300 on behalf' of defendants. . (Witness sworn.). 2 REYNALDO GUEVARA, 3 STOHR JAME.S G. SOTOS " ASSOCIATES, MS. ELIZABETH A. EKL I called as a witness herein, having been first duly 4 sworn, was examined arid testifiea as follows: GARDINER "53 West Jdckson B6ulevard, Suite 950 Chicago, Il-l.inois 60604 1312) 362-0000 .:andLAW OFFICE OF DANIEL J. STOHR, by I0 Page 4 2 APPEARANCES: 5 EXAMINATION 6 BY 7 MR. GARDINER: 8 9 by 10 Devon, suite 150 11 12 13 14 13 15 14 16 15" 17 16 IB 17 19 18 20 19 21 20 21 23 22 24 23 24 STENO · JR-JJAMERICAN 044681 ' Could you please state your name. A. Reynaldo Guevara. That's G-u-e-v-a-r-a. Q. Mr. Guevara, could you K:ll us your educational background. A. I have an Associate's Degree. Q. Where did you receive that from? A. Governor State. Q. Okay. And what is it in? A. Just in general. Q. All right. And when did you receive that degree? A. Oh, Jesus. A long time ago. I can't even you the day-- it's been so long-- because it was correspondence. Q. Okay. Could you tell us your employinent prior to the Chicago Police Department. A. Prior to the PoliceDepartment I was a Q. .. Page· I - Page 4 REYNALDO GUEVARA CondenseltTM JOHNSON v. GUEVARA Page 5 refrigeration, heating and air-conditioning serviceman .. _, Q. When was that? A. Way back when, too. Q. You're not sure of the year? A. (Shaking head.) Q. Okay. THE REPORTER:. Was that a "no"? THE WITNESS: No. I don't remember the year, but it was just before I went on the Force. MS. EKL: If we could, just for a second, Ray, because the court reporter is taking it down, it's important for you to say "yes" or "no." THE WITNESS: Yeah, I understand. BY MR. GARDINER: Q. You've testified before; right'? A. Yes, I have. Q. And you understand that the court reporter needs to take down whatever you say and you need to orally elicit the answer; right? A. Right: Q. Okay, If there are any questions you don't please let me know and I'll rephrase them. Okay? 1 .2 3 4 5 6 7 8 9 10 11 12 13 14 15 .16 17 18 •- 19 20 21 22 23 24 Page 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19" 20 21 22 23 24 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19. 20 21 22 23 24 All right. Otherwise, I'll presume that you understand the question. A. Yes. ·· Q. All right. So you said you worked as a heating and air-conditioning man? A. Correct. Q. Okay. Was that before or after you were in the Air Force? A. After. Q. Okay. Ai1d you were in the Air Force for, what, about a year? A. Right. Correct Q. And you were discharged because of a medical condition -A: Yes, I was. Q. -- related to your eye? ·· A. Generally, yeah. Q. Okay. And that was a favorable discharge, right, from the military? A. Correct. Q. What responsibilities did you have in the military? A. I was actually administrative. A. 1 Q. 2 STENO (312) 236-1414 JR-JJAMERICAN 044682 A.· Actually, Page 8 'i; {' .·.·-.. Page 6 2 And what did you administer? nothing, to be honestwith you really, Q. You just had an administrative position, but you didn't have an assignment to do.anything? A. Correct. I was still going through basic training. Q. Okay. And then they discharged you after thattime? A. Correct. Q. And then you became a heating air-condilioning man? A. That's correct. <._>. And then afterthat you becatrle a police officer? A: Correct Q. All right. Are you retired from the Police Department. now? A.· Yes, I am. Q. What was the date of your retirement? A. June 15 of last year. Q. And what have you done since June 15th of 2006? . c A. I work part-time for the Chicago Park Q. 3 4 6 7 8 9 !0 11 12 13 14 15 16 17 18 19 20 21 22 23 ·. 24 District. - Q. And what do you do for them? A. Security. Q. Where do you do security? · A All over. . Q, How did you obtain position as a person doing security for the Chicago Park District? A. I applied for it. Q. And when you say "all over," all over the City you do security? A. All over the North R<:;giQJ!. Q. And how many hours a week do you work? A. 25 hours a week Q. Do you have any other current ernployinent? A. No, I do not. Q. Do you work days or nights? A. It varies. Q. And how many years did you have with the Police Department at the time that you retired? A. 32 years. Q. Now I want to direct your attention to the time that you joined the Police Department. So that would havebeen in 1974? A. '73. a Page 5 - Page 8 REYNALDO GUEVARA CondcnscltTM . ·· Page 9 Okay. And did you have training atthat time( A. Yes, I did. Q. And what training did you have? A.· Police training, basic training, police procedures. Q, _And how long was the training that you had? .. A. I think about nine, ten weeks. I don't remember exactly. Q:· Okay. Did you have training relating to lineup procedures? A. Yes, afterwards I did. Q. So after the basic training you had that? A. No. Q. When did you have lineup procedure training? A. When I went to detective school. Q. Okay. And.how about interrogation training, did you have that? A. Yes. Q. \Vhen .did you have that? A. During and after I went to detective school. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 11 I don't understand that question. 2 · ·'" Q."'Ratl'you acquired knowledge about gangs 3 prior to becoming a Gang Crime specialist? 4 A. I still don't understand. 5 Q. All right. Before you became a Gang Crime 6 specialist did you have knowkdge about gangs? . 7 A. Yes, I did. 8 Q. Okay. What knowledge did you have about · 9 gangs? 10 A From the street. I grew up in the City of 11 ·chicago and-the streets basically were the gangs. 12 Q. And what gangs were you knowledgeable 13 about at the time that you became a Gang Crime 14 ··. specialist? 15 A I was knowledgeable about the Cobras; I 16 was knowledgeable about the Disciples; I was · 17 knowledgeable about the Latin Kings; I was 18 · knowledgeable about the Latin Eagles; I was 19· knowledgeable about the Latin Dragons and so-forth. 20 Q. Okay. You were knowledgeable about all 21 gangs that were at a particular location in the 22 City? 2-J. A Yeah. Mainly in the Humboldt Park area. 24 Q. Okay. And you gained that experience and 1 Q. 1 Page 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q. Okay. Now, youofiginally started'·a:s a beat Officer? A. Correct. Q. All right. And what was your assignment? A Atfirst I was assigned to the 17th District, and from there I went to -- I believe it was the 23r:d District, and from there I believe I went to 13 and then I went to Gang Crimes. Q. Do you know when you went to Gang Crimes? A. No, I don't remember. Q. Were you a detective before or after you went to Gang Crimes? A. After. Q. Okay. So you started in Garrg Crimes as justa regular police officer? A No, I was a Gang Crime specialist. Q. Okay. How did you get to become a.Gang Crime A. Oh. You had an interview -- you had to have an interview with a commander at that time, and your knowledge on gangs. Q. Okay. Had you acquired knowledge on gangs p[iortothc time you_became a Gang Crime· specialist? ST,ENO. (312) 236-1414 JR-JJAMERICAN 044683 JOHNSON v. GUEVARA A Page 12 1 that knowledge relating to thdse gangs because of 2 serving as an officer in that area? 3 A. Plus, I grew up in the area, 4 Q. Okay. And you were aware before becoming 5 a Gang Crime specialist about what gang rivalries 6 there were? 7 MS. EKL: Objection. Form of the 8 question. 9 THE WITNESS: I don't understand the 10 question. 11 12 BY MR. GARDINER: Q. Okay. From your knowledge of gangs, sonie gangs don't get along with other gangs; right? A True. 15 "' Q. You were aware of that information when 16 you .became -17 A. Yes, I )8 Q. Okay. So you became a Gang Crime 19 specialist and then what responsibilities did you 20 have that were different from your prior 21 responsibilities as a beat officer? A As a Gang Crime specialist I had to · 22 23 follow up on gangs, the members, what they do, 24 where they hang around at, their girlfriends 13 14' Page 9 -Page 12 REYNALDO GUEVARA · Condenselt l'M Page 13 ·.are, who they hang around with, who do they rival 2 _. :wjtq, whQ are they .allied with and .SO fortl}. _ 3 Q. So how would you get that information? 4 A. Through them. 5 Q. So by talking to the gang members? 6 A. True. . .. 7 . Q. Okay. And _why would the gang members give:; 8 you that information? 9 MS. EKL: objection. Fonn of the 10 question. II THE WITNESS: They always do regardless. 12 BY MR. GARDINER: 13 Q. Okay. But my question is, why? 14 MS. EKL: same objection. 15 THE WITNESS: You would have to ask them. 16 Because they talk. 17 BY MR. GARDINER: 18 you" were the person that asked them; 19 right? 20 A. Yes. 21 MS. EKL: objection. Argumentative. 22 BY MR. GARDINER: 23 Q. And they would talk to you. Is there a 24 reason you felt that they were willing to talk to I JOHNSON v. GUEVARA Page 15 1 . 2 3 4 5 6 7 8 9 10 1.1 12 13" 14 15 16 17 18 19 20 21 22 23 24 would frequently talk to me. Q. Okay. And with those-confidentia,l. , informants did you develop files on those people or not? A As a Gang Crime spe<;ialist you are supposed to make synoptic reports, and in those reports you would have to. put downwhat you have learned from them. Q. Okay. And would you put down the source of the information that you learned from them, too? A Y would put down the information that they gave you. Q. Okay. But would you put down who gave you · that inforination in the report? .. A No. Q. Okay. And what would you do with those reports? A They wete submitted to the office. Q. To the office of... '? . A. To the Department, Gang Crimes office. Q. Okay. Would you take pictures of gang members as well? A Only when they were arrested. Q. You wouldn't take pictures of gang members cO Page 16 1 you as opposed to any other person'? A. Basically they talk to anyone really. 2 3 3 Q. Okay. Audas a Gang Crime.specialistand 4 4 officer for 32 years, do you have any 5 feeling or belief as to why they would talk to ., 6. ·-1anyone? 6 7 A I believe they would talk to anybody just 7 8 to show off who they are. 8 9 Q. Okay. So you would talk to the gang 9 10 members and get infonnation from them? 10 II II A True. .12 12 . Q. And would you need to do anything to 13 obtain that information from them? 13 14 .·• A. No. · 14 15 Q. Was there any benefit you would have to 15 16 16 give to gang meinbers to obtain information from 17 17 . them? 18 18 A No. 19 19 Q. Did you have. confidential informants as a 20 20 Gang Crime specialist? 21 21 A. Yes. 22 Q. All right. And what types of confidential 22 . 23 23 · infonnants did you have?. 24 A. Members that belong to the same gang who 24 1 2 STENO (312) 236-1414 JR-JJAMERICAN 044684 on the street? A. No. Q. And youwouldn't ask gang members to step forward.so you could take a picture and keep it in · yollrfi1e'? A. No . Q. So when you had certain -- there were books of gangmembers; right'? A Correct. Q. And you would maintain those books or were they maintained at the Area at which you were assigned? A. They were at the Area. Q. Were those books only of people that'had been arrested? A. Notnecessarily. Q. So how would people that were not arrested get in the gang picture books'? A. They volunteer, I gl\ess. Q. So gang members would volunteer to be in a book that would be used to allow people to pick out potential defendants? A. Thcy.volunteer to get into their own·gang books. Page 13- Page 16 REYNALDO GUEVARA Condenselt rM Page 17 Page 19 4 And wh'at was the reason for that? MS, E{(L: Objection. Calls for speculation: THE WITNESS: I have I)O idea. 5 BY MR. GARDINER: 6 So these gang books would have more tha11 6 just people 'that were arrested; right? 7 A.. That's true. 8 Q. It would have more than people that were 9 convicted; right? 10 ·A. Yes. 11 Q. All right. A..nd you would-- \vould You ·· 12 ever take pictures that would be included in these 13 14,; Gang Crime books or would it always be. people at the lockup or the picture taking places? 15 Q. Confidential informants. A. No. I would take pictures of the people 16 A. Correct. 17 Q. Okay. There's a-- well, let me ask you. that 1 have arrested. Gang Book descriptions Q. Woul&you carry a camera with you? 18 After you became a Gang Critne specialist · 19 what did,you do next? A. No. Q. So where would you take pictures of the 20 A. We just investigate gang incid.ents. . people thai you arrested? 21 Q. Would you investigate homicides as a Gang A. At the.Area . 22 Crime specialist? Q. So when they would come in after your 23 A. I would help with the detectives on the arrest you would take a picture of them? 24 investigations of the homicides if they were Q. 1 2 3 . JOHNSON v. GUEVARA 1 2 3 4 5 Q. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 . 22 23 24 .·. Page 18 1 2 3 4 c5 6 7 8 9 10 11 .12 13 14 15 16 17 18 19 20 21 22 23, 24 A. correct. Would you take Polaroid pictures? Yes. Q. Would .you write the name of the person that-·you were taking a picture· of ?n the PolarOid : picture? A. No, on the back. Q. Okay. And what would you do with the pictures then after you took them? A. They would be filed. Q. And that would be filed at the Area? A Right. Q. Now you mentioned that there were reports relating to· confidential infonmints and that you didn't indicate who the confidential infonnant was on thereports that you filed; right?. A. Right. Q. On those confidential infonnant reports how would you go back and know what source gave you the infonnation? A. I would know. Q. You would just remember? A. Yes. Q. And was that true throughout the 30 years 1 Q. 2 A. 3 STENO (312) 236-1414 JR-JJAMERICAN 044685 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 that you were an officer? A Well, at .one point in timel stopped working with the gangs. Q. Okay. When was that? A. When I became a dick assigned to homicide investigations only. Q. When was that? A. 1990I believe it was. Q: Okay. But between the time of roughly -was it 19- -- well, between the time you were assigned as a Gang Ctin1c specialist in 1990, you would have these reports, but you wouldn't keep any names on them; right? A.. Of the ... ? Page 20 gang-related. Q. All right. So you would help another officer who was a detective handling homicides? A. Correct. Q. All right. Ana then you became a detective at some point; right? A. Yes. Q. And that was before 1989; right? A. After 1989. Q. Oh. After '89 ·you became a detective? A. Correct. Q. Okay. So as ofSeptember ofl989, you weren't a detective and you wo1,Ild assist on homicides; is that right? .' A. That's correct. Q. So how were you assigned to work on a homicide case? A. Depending on the gang that was involved with it. Q. Who would assign you? A. We would be assigned by a sergeant of the Gang. Crime Unit. Q. I sec. Okay. And then therR were particular gangs that Page I 7 .:. Page 20 REYNALDO GUEVARA 1 2 3 4 5 6 7 8 9 10 11 l2 13 · 14 15 16 17 18 19 20 21· 22 23 24 Condenselt TM Page 21 Page 23 1 Not everybody you would do but, you know ... you were more knowledgeable about and you- would be 2. Q. Well; I understand that thatwas the goal, ··· assignc:;d to .. 3 but I'm interested in what they taught you. How A. Yes. Q. And what gangs were the gangs that you 4 would you approach someone? How would you gain were more knowledgeable about around the time of 5 their confidence? 6 MS. EKL: JUst for clarification, Counsel, 1989? A..Iwas knowledgeable about gangs that .7 are you asking how-- specifically howJhcy trained .8 him to approach people? were in the area of Humboldt Park. Q .. Okay. And Latin Kings would be one of 9 MR. GARDINER: Yes. Right. those gangs; right? 10 MS. EKL: Okay. '11 THE·wrrNESS: It's-- I'mean; thcyjust A Latin Kings would be; the Urtknowns would 12 tell, you -know, when you approach somebody, be; Disciples.; Cobras. Q. Okay. The Latin-type gangs, would that 13 a suspect or smnebody you are talking encompass your knowlt:dge or would· it expand beYond 14 · to, a member of anything; witnesses in. there, you 15 approach them, ask them their name, what they do that? 16 and so forth, and just keep on talking with them, .MS. EKL: objection. Form of the 17 talking about anything they want to talk about. question. THE WITNESS: It expand beyond that. _ 18. BY MR. GARDINER: 19 Q. Okay. Ana that would be how you would do BY MR, GARDINER: Q. Okay. So you said that during the -- once 20 interviews of suspected murderers, too? 21 A Of anybody. - _, you became a detective there was trainirigthat you 22 Q. And you mentioned you had training received in connection with interrogating people; right? 23 relating to lineup procedures once you became -24 once you were in Gang Crimes; right? A. Yes. Page 2'2 Q. Could you describe the training that you 1 2 received. A. Bow to approach people, what to ask them. Q.. .Okay .. How were you to approach people? 4 A Different gain their confidence. 5 Q. Okay. So the training that you received 6 7 on interrogation was Jhat gain their 8 confidence by doing what? 9 A. Chatting with ther.n, talking, you know, and 10 BS'ing with them, I would say. II Q. Okay. So it was being friendly? 12 A Correct 13 Q. And was there any training to you relating 14 to interrogation about not being friendly? 15 · MS. EKL: objection. Form of the 16 question. 17 -niE WITNESS: It's just the training. 18 Regardless whether it's friendly or unfriendly, you 19 ·know, it's basically the same. 20 BY MR. GARDINER: 21 · Q. And what is the-- tell me what is same. 22 What is the training that you had? 23 "':· Again, how to a,pptoach people, how to. talk 24 to them, and to gain their trust and confidence. 2 3 3 1 JOHNSON v. GUEVARA STENO JR-JJAMERICAN 044686 4 5 6 7 8 9 10 11 12 13 14 15 16 i7 18 19 20 21 22 23 24 P:,1ge 24 A. Yes. Q. All right: Could you tell us what the training was relating to lineup procedures. · A. A lineup training consisted of how to pick the people-- they're fillers in the lineup -based on race, based on age, height and weight. you bring them in abel you let the suspect pick their spot. You don't tell him, You stand here or. you stand there.. You have him pick his spot. And then from there, after the lineup, you would have to get somebody to come and take a photo of the lineup. And then you make your lineup reports and move on. Q. Was there training regarding the number of people that should be in a lineup? A. Yes, there is. Depending on the case, type of the case. Q. So for a homicide case ... ? A For a homicide, no less than five. Q. Okay. And were there rules pertaining to how. many suspects could be in a lineup? A. No. Q. So a lineup could -- if there were five suspects in a murqer, you could have all five in · Page 21 - Page 24 REYNALDO GUEVARA Condenselt TM Page 25 · the same. lineup? I 2 2 A. No. No. CoiUI11on sense will tell you if you got five suspects for a lineup, you are going 3 3 4 4 to get five other people or four other people. Q. Okay. And if you have two suspects for a 5 .5 6 murder, how many suspects would be in the lineup? 6 A. You can get three, you can get four, 7 7 8 8 .. \Vhatever you. can find. Q. Well, I'mjust saying-- what I'm 9 9 10 10 saying -- I'm drawing a distinction between 11 suspects in the case and I guess what you would 11 12 ·call the fillers; right? i2 13 13 A. Right. 14 · · Q. If you in whicn two people 14 15 were suspected of murder in the course of your 15 16 investigation, how many of the suspects would you. 16 17 put in the lineup and how many of the fillers would 17 18 18 you put in? 19 19 A. If there's two, usually we put either 20 three,four or f.ive, as long as there's five 20 21 participants in the lineup. 21 22 .. Q. But you could have two suspects in the 22 23 23 same lineup? 24 24 A. Yes. Page 27 BY MR. GARDINER: 1 .. JOHNSON v. GUEVARA Q; But after all your years of experience you don't have an idea on why somebody would voJunteer to be in the lineup? A. No . MS. EKL: Argumentative. THE. WITNESS: No.. So you would be able to go out on the street and get some volunteers for a lineup whenever you needed to? · ·· A. Yes. Q. Now, did you also learn about photo array presentations in your training? · A. Yes. Q. Could you tell us how a photo·array i's · done. A. A photo array is basically done thesame way as a lineup. The only difference is it's just photos. Q. So.yo4,.w:o.uld pull a number of photos depending on the type of case? A. Correct. Q. So for a murder case it would be at least Q. Page 26 Q. Okay> And then you follow the other procedures that you mentioned with the 3 documentation? 4 A. Correct. .5 • Q. And how does a person view the lineup 6 under the rules as you were trained? 7 A. It's a mirror. There's two rooms; 8 one room is where you put the suspects in and the 9 fillers; the other room is where the witness will I o view the lineup from. II Q. And how do you obtain the fillers? -12 A. The first step you take is you go to the · 13 lockup and see if there's anyone fitting the 14 description; how many they got there_. If you don't · 15 find any in the lockup, then you go.out on the 16 street and you ask people to fill in. 17 Q. To fill in as volunteers? 18 A. Yes: 19 Q. So why would someone volunteerto be in 20 the lineup? 21 MS. EKL,: objection. Calls for 22 . s_peculation. 23 THE_ WITNESS: They do-it all the time. 1 24 have no idea, but they do. - BY MR. GARDINER: Page 28 1 I five? 2 2 A. At least five, six; it all depends many. Q. All right. And then you would show that -- you would show those pictures to the victim? A. You would show those pictures to the · witnesses. Q. Okay. And you would try to meet the same -- the same criteria as you mentioned for a live lineup, which would be that there should be similarity between the traits of the people in the photo array and the suspect? That's correct. Q. Now how about showing picture books of gang members, would you do that sometimes? A. All the time. Q. All right. Who would you show those to? A To,the witi1esses. Q. And would you show entire books' to witnesses? A. I would give them a book, let them go ·. through the book.. · Q. How many people would be in one of your .. AMERICAN STENO (312) 236-1414 JR-JJ 044687 3 4 5 6 7 8 9 10 11 . 12 ·u A: 14 15 16 17 1.8 19 20 21 22 23 24 b Page 25 - Page 28 JOHNSON v. GUEVARA 31 I 2 3 4 5 6 7 8 9 10 II 12 Page 29 1 Q. All right. And you would bring -gang books? 2 sometimes would you use those picture books that A .. Anywhere from 20 to.}OO. 3 you would make yourself and show people those Q. And where were those Gang Crime books 4 picture books? kept? A. At the office of Gang Crimes. 5 A. Yes. Q. Could you take the books out of the office Q. So those weren't really the official 6 of Gang Crimes and go out on -the street and show 7 picture books of the. Area, they were more the8 . Guevara picture books? people? A. The only way you could take those books 9 A: Right. out is if the State's Attorney's Office will Q. And you would put those together based on 10 11 , the particular investigation that you were doing? subpoena them, and then there will be one officer 12 A. No. . be together basecr·on the -· that will bring #.:i!1 there. < Q. But you couldn't take a Gang Crimes'· · ' 13 gangs. _ picture book of gang members out in the field? : 14 Q. So did you havea set ofpicture books for 15 the Spanish Cobras that were the Guevara picture A. No. 16 books? Q. All right. Could you remove picture!:) from 17 A We would have individual photos of them. the gang picture book and take those -- take five 18 Sometimes they take two photos. One goes into the pictures out in· the field?_ 19 book, and whoever the officer is keeps the other A. Nope. 20 one and that's how they build up. Q. So you couldn't do a photo array outside 21 Q. So you would have your own book of Spanish of the area at which you worked? 22 Cobras right?A. Qh, yes; you could. · ·A I would have some pictures of them. 23 Q. Okay. Q. And you would have your own book of 24 A. Did I ever do it? No. 13 14 15 16 17 18 19 20 21 22 23 24 c ) ,,.., .: '•' - - Page 30 1 2 3 4 5 6 7 8 cj' 10 . 11 12 13 14 15 16 17 18 19 ./ 20 21 22 23 24 --- Okay. So detectives and officers couid · take pictures out, but you never would follow that procedure? A Not of the not out of the books. Q. Would you take other pictures out to the field to show people? A Yes. You can look in boxes to sec if you they're at, and, yes, find any you can take them. Q. So pictures that are outside the book; is that what you are talking about? A. That's correct '· · · Q. So there would be other pictures outside the book at the Area? You+could gather those and bring those-out to the field? A. There were boxes of them. Q. Okay. Hut yoi.1 could do that? A You· could do that, yes. Q. You wouldn't ever bring those books out? A Not the books. Q. And you wouldn't-- would you ever make your own ljttle book based on the other pictures that were in boxes? A Ycs, I had. 1 2 Q. (312) 236-1414 JR-JJAMERICANSTENO 044688 Page 32 3 4 5 6 7 i\ 8 9 /10 "- 11 , 12 0 13 14 \ 15 ...l..fi_ 17 18 19 20 21 22 23 24 Latin Kings, for instance? A Latin Kings, Spanish Eagles, you know, Latjn Eagles, all of them. Yeah, 1 would havesome. Q. All nght. Why is it that you retired \ from the Police Department? \ A Because I was going to get kicked out if didn't. _ ·· · t Q. And why were you going to get kicked out I A Because of the age. Q. And what -- is there an age limitation then? ·· A Yes, there is. Q. All right. And what is the age limitation? A The af!e is fi1 Q. Was there any other reason that you left the Police Department? A No. Q. You haven't had any criminal convictions yourself, have you? · A No. Q_. Did anyone within the Police Department encourage you to retire for reasons other than your Page 29 - Page 32 REYNALDO GUEVARA . 1 age? CondenseltrM Page35 1 No. 2 2 A .. 3 Q. Do you know a person named Juan Johnson?. 3 4 A. .Juan 4 5 Q. Uh-huh. Johnson? 5 Yes. 7 Q. How do you know that person? 8 A. I, knew him from the street. He's a gang 9 member from the Spanish Cobras -- from the Cobras. 10 Q. When did you first know Juan Johnson? II · A. I knew Juan Johnson whet1 he first 12 started -- when they first started hanging around 13 on the streets over there. 14 Q. So how old do you think he was?· 15 A. He was young, yery young. 16 Q. A teenager or younger than that? 17 A. Yes, teenager. 18 Q. )3-, 14-year-old? 19 A. Probably. You know, !couldn't tell you 20 their age. 21 Q. And what -- prior to September 9, 1989, 22 what knowledge did you have of.Juan Johnson other 23 than that he was a gang member? 24 A. That he was a dope dealer. 6 JOHNSON v. GUEVARA PageJ3 ·· 6 A. 7 8 9 10 11 12 13 · 14 15 16. 17 is19 20 21 22 23 24 ·the time? A. They never move. They always do it in the same spot. Q. Did you ever arrest him? A. I can't tell you exactly that I did or not because I don't remember if I did arrest him prior to that. Q. Okay. You may have, but you are. not sure? A. May have. Q. Whywould you not have arrested him if you knew he was selling drugs there? ' A. Selling and proving it, they are two different things. Q. So even though you wouldobserve him selling drugs, you felt that you couldn't prove cases against him? A. Yeah. Q. He would be the person actm1lly selling . the drugs, though, when you would observe him? A He would be one of them. Q. All right. Did you ever do an undercover buy with Juan Johnson? A. Never did a buy. Q. Was there a reason that you never did an Page 34 Page 36 1 Q. And what dope did he sell? 1 2 A Dope. 2 3 4 5 6 7 8 9 1o 11 12. 13 14 15 16 17 18 19 20 21 22 23 24 Q. And do you know what particular drugs he sold? A He sold all kinds of them. Q. So he sold marijuana? A He sold marijuana, sold coke, sold -whatever he would sell. · Q. And do you know what-- what years did you observe him selling drugs? A. In the years that I had been a police officer, I've knownJuanJohnson and his brother· and other guys that were sitting around there standing on the comer selling their little bags. Q. Okay. How many. years did you see Juan Johnson on the corner selling bags before 1989? A. Oh, I couldn't tell you. Many years. . Q, }Je was -- if I tell you.:-- I think he was 19 or so in 1989. So how many years do you think you had seen him selling drugs? A Figure at least four or five years, around there, something like that. I don't know exactly. · Q. bid he sell the drugs at the same area all .AMERICAN STENO (312) 236-.1414 JR-JJ 044689 3 .4 ·· 5 6 7 8 9 10 11 12 13 ·undercover buy with him? A. I never did a buy. In fact, l never did a buy in the Police Department in my career. Q. All right. But you could have facilitated an undercover buy; right? A. Yes, but not with them. They knew me. Q. All right. But you could have had another officer come in and do a buy undercover; right? A. Yeah. Q. Why didn't you do that with Juan Johnson? A. Never did it. I have no idea, but I never did it. " Q. You don't know why you didn't do it? No. Never did it. 15 Q. And did you do it with any-body at the· 16 location at which you would sec Juan Johnson l7 selling drugs? 18 A. No. 19, Q. And you don'tknow of any reason why you 20 wouldn't have done that? 21 A. No. 22 Q. What location would you see Juan Johnson · 23 · selling drugs at? 24 A. He. would be -- actually, he would be. on 14 A. Page 33 - Page 36 REYNALDO GUEVARA .. JOHNSON v. GUEVARA CondenseltrM Pagc37 1 Campbell, Artesian,'fromNorth Avenue toLe Moyne .2 · 'lnd back, back and. forth from that area. They!re 3 . always there. Always in front of the restaurant 4 there. Evie's I believe was the name of it. 5 Q. How do you know what drugs he was selling? 6 A. I don't. I'm just saying they were 7 dealing all kinds of dope. 8 Q. Now you're presuming he sold all types of 9 dope-10 A. Right. ll· · Q. --but you don't know what he was actually ' 12 selling? A. I don't know because I never got any from 13 t4 him. Q. And what do you know about Juan Johnson 15 16, . other than that he sold drugs. at various locations? A. That he was a member of the Spanish 17 18 Cobras. Q. And do· you know what positions he had 19 20 within the Spanish Cobras? A. At that time, he was up. I don't know 21 22 what -- the exact position that. he carried, but he 23 was up. Q. How did you know that? 24 Page 39 ' A. He would talk to me. J don't think he ever did gave me any infonnation. · 3 Q. Okay. And the brother that you are " 4 talking about is Henry Johnson; right? 5 A. Corre.ct. 6 Q. Would you speak with him as well? 1 2 7 8 9 10 11 12 13 14 15 16 17 19 20 21 22 23 24 A. Yes .._ Q. All right. And would he tell you information? A. I don't think either one of them have ever given me any information regarding anything. Q: All right. Now, while they were there you said there were other guys with them; right? A. Yes. - · Q. Could you tell us the names of the other people that you would see? A. No. Q. Is that because you can't remember them? A. That's right. I can't remember them. --Q. Did you know their names at the time? A. Basically by their nicknames is what I would say. Q. And do you remember the nicknames of the peoplethat would be with the Johnson brothers? Page 40 From the gangbangers. Q. Just the people that you would speak to on 2 3 the street? A. Yeah. They're members. They're all 4 . 5 . ·members. Q. And they would tell you that Juan 6 7 Johnson -8 A. They would say who is the higher-up. 9 Q. Before September 9th ofl989, how many 10 times did you have a conversation with Juan ·:. 11 Johnson? -12. .. A: Oh, 1 can't answer that.- l·used to have 13 conversations with him and his brother a lot of 14 times. Every time I drove by he's standing on the 15 corner I pulled over and talked to him. 16 Q. And he would be selling drugs on the 17- corner? 18 A. Whether at that particular time if he was 19 _ selling or not, have no idea. .. 20 Q. Okay. But you would pull over and talk to 21 him about what? 22 A. Just chat with him. 23 Q. And .he would talkto you and 'give you 24 infonnation? 1 . A. STENO- (312) 236-1414JR-JJAMERICAN 044690 right now I don't. 2 Q. Did you ever warn Juan Johnson about his 3 involvementwith the gang? 4 MS. EKL: objection. · Form of the 5 question . Q, THE WITNESS: I don't think so. 1 A. 7 BY MR. GARDINER: 8 Did you ever tell Juan Johnson that he would be dead or in jail by the time he was 21? A. I don't think I ever did tell him that. I don't think so. " Q. Did 'ydu ever tell Jiiah Johnson tinltiehe;, would spend time in prison? A: No; Q. Did you have a concern about the Spanish Cobras more than any other gang? A. No.· I treated them all alike. Q. Andhow did you treat them? A. The same way. Q. And how was that? A. I talked to them. If they messed up, they would go to jail. And just as simple as that. Q. Would you make drug arrests when you were in the Gang Crimes Unit? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q. Page 37- Page 40 REYNALDO GUEVARA CondenseIt ™ Page 41 1 Oh, I have. 2 Q. You have? A. Yes, I have. 3 Q. And how many drug arrests would you make 4 in, say -- say 1989? 5 A. Probably none. 6 Q. And why was that? 7 A. I don't remember how many drug arrests 8 that I ever made in my 32 years. 9 Q. Do you have a general idea of how many 10 arrests you would have made over the years before 11 12 1989? .. A. No, I do not. 13 Q. Do you know whether you would have made i4 more than 20 drug arrests during the years prior to 15 16 1989?. A. No, I do not. 17 Q. It could have been less than that? 18 19 A. It c;ould have been less; it could have 20 been more. I have no idea. Q. Do you know a person named Jose Negron? 21 ·A. Jose Negron? 22 23 Q. Yes. 24 A. I don't recall. A. I 2. 3 4 5 6 7 8 9 10 11 12 13 . 14 15 16 17 18 19 20 21 22 23 24 Page 42 Do you know a g6es by Blankito or Blanko? A Yeah, I know Blankito. Q. All right. What is his name? A. Gee, I don't know right now. I dori't think it's Jose though. Q. His last name is Negron? A I think so. Q. Oka)< How do you know him? A. From the street. He was a gangbanger, too. · Q.·What gang was hewith?·· ·· A Oh; I don't remember right now what gimg he was with; but he was a·Folks -- he was with the Folks. Q. You don't know if he was a Spanish Cobra or not? A. He could have been a Spanish Cobra. He could have been a Campbell Boy. He could. been a Disciple; I don't know. But I know he was a gangbanger. Q. Okay. And you know that from word o? the street? A. Yes. .. Q. 2 3 4 5 6 7 8 ·9 10 11 . 12 13 14 15 16 17 18 19 2o ···. 21 22 · 23 24 STENO (312) 236-1414 JR-JJAMERICAN 044691 t 2 3 4 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24 JOHNSON v. GUEVARA Page 43 Did you have a relationship with his mother? A. No, I didn't. Q. Did you kno.w his mother? A. Yes, I did. Q. And what is his mother's name? . A I have no idea what his name is right now .. Q.. And how did you know his mother? A. From the street. Q. Did you ever spend time at the place tnat his mother lived at? A No, I did hot. Q .. Did you any involvement in raising Mr. Negron? A. No, I did not. Q. Did you have any involvement in any case involving Mr. Negron? . . A That I can recall? Maybe I havo, but I don't remember. Q. And you had no involvement in his plea of guilty to acriminal case? A. No, I don't-- or, no, I didn't. Q. Mr. Negron is currently serving a Q. Page 44 substantial sentence in Pennsylvania. Were you aware of that before today? A. Nope. Q. Were you involved in any serious offense -- or arrest of an offense in which Mr. Negron was arrested? A. I don't recall I ever been involved in any with him. Q. You've never been-- have you-ever told Juan Johnson or anyone else that you were upset with the Spanish Cobras because they were ruining the ·life of Mr. Negron? A. No, sir. Q. Have you everblamed the SparilshCobras for Mr. Negron being involved in criminal activity? A. No, sir. Q. Now, prior tci September 9, 1989, you mentioned that you !)ad numerous conversations with Juan Johnson; right? A Not just one, every gangbanger on the street. Q. I understand, but my question is limited to Juan Johnson. Prior to September 9th of ,1989 you had had _ ··Page 41 -Page 44 REYNALDO GUEVARA 1 2. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 CondenseIt rM Page 45 Page 47 ntm1erous conversations with him over the years; 1 Q. Okay.· Soyou don't know what gang Hector right?· 2 · Franco was in in 1989? . A. I'm sure I did, yeah. 3 A. No. Could have been the Eagles. I have Q. Are there any particular conversations . 4 no idea. I don'tremember. that you can recall and tell us about that you had 5 Q. Did you have conversations with him prior with Juan Johnson prior to September 9, 1989? 6 to September 9', 1989? A. No. .7 A. I believe I talked to all ofthose guys on . Q. And the nature of .your were 8 occasions. the kind of conversations youmentioned before, 9 Q. And when you would talk to them, that was which was, how are you doing, what's going on, 10 just to get infonnation? things like that; right? 11 A To see what was going yes. A. Correct. 12 Q. Vv11at would you do with the infom1ation? Q. You didn't have-- prior to September 9, 13 A. I would keep it to myself., Unless it was. 1989, you didn't have anysubstantiveconversation 14 real, real important, put' it on asyti6ptic with Juan J ohuson about crime; is that right? 15 report. Q. Okay. And those synoptic reports were· · 16 17 turned in then to your Area? have any substantive conversation· with Henry 18 . A. Correct. Johnson about crime;is that right?. .. 19 . Q. But would you use the information to deal 20 with crimes? A. That's correct. I don't think so. Q. Can you tell us any conversation that you 21 A. Sure. It was used -- it was based on had with Henry Johnson prior to SepteiUber 9, 1989? ·22 cnmes, sure; A. No. 23 Q. So you would talk to these gang members to Q. Do you know a person named Hector Franco? 24 obtain information for what purpose? on, Page46 1 2 3 4 5 6 7 8. 9 10 11 . 12 13 14 15 16 17 18 19 20 21 22 23 24 JOHNSON v. GUEVARA Now. I know that yeah, I know Hector · Franco now. . . . Q. Did you know that person. prior to September 9, 1989'? A. Sure. Q. How did you know him? A. He was a gangbanger, too. Q. What gang was he a member of? A. On,Tcari't remember. I don't remember what gang he was in, but he was in he could have been an . Eagle -- I mean, I have no idea -- but at . that time they werc·all together; the Cobras; the Disciples, they were all together. They were all ·the same ally. Q. Were the Disciples part of the Folks? A. Yes. Q. So the Latin Kings and the Spanish Cobras were together, they were allies; is that what you're saying? A. No, noUhe Latin Kings. Q. Oh. I'm sorry. The Latin Eagles and the Spanish Cobras were allies? A. Yes. A. . . . . STENO (312) 236-1414 JR-JJAMERICAN 044692 Page 48 To gaintheir knowledge: as to what they . I . . 2 are doing and what they are about and what's going 3 . on or what's going to happen. 4 Q. And then what would ybu do if you found 5 out what's go'ing to happen? 6 A. Well, I would keep my eyes open for one. 7 Q. Okay. And would you intervene and go to 8 another crime -- another gang and say, I 9 understand this is going to happen, I'm on to you? 10 A No. 11 Q. Okay. What would you do.if you were told '12 something was going to happei1'? 13 A Obviously, I would wait till it happen. 14 Q. And then you would make arrest or · · 15 attempt to make an arrest? 16' A Then I would investigate as to who did it. 17 Q. So if a gang member were to say that L8 somebody was going to be violated or somebody was 19 . going to be killed, what would you do with that 20 ·. infonnation? 21 : A. Well, first of all, they will not tell me 22 who is going to be violated. 23 "Q. Okay. 24 A. That information, they Wol}ld never give it 1 A. Page 45 - Page 48 REYNALDO GUEVARA Condenselt ™ JOHNSON v. GUEVARA ·Page 49 Page 51 1 cJ out. 2 : Q .. 3 you? 4 If there's made, it was going 4 5 to be known by me after it was already made. . Q. Okay. And if-you had information that a 6 murder wasgoingto take place, what wouldyou do 7 . . . 8 with.that information? A. Oh, I would try to prevent it. Sure. 9 Q. So you can't recall any specific 10 conversations ·you had with Hector Franco, but you 11 probably had conversations with him; right? 12 13 · A. Correct. 14 Q. And you probably had co·nversa'tioris witlt •. 15 him before September 9th of 19 89; right? 16 . A. Probably .. Q. Do you know a person named Pedro Cordero?. ... . 17 A. If I'm not mistaken-I think that's one 18 . . of. the guys .that Lan:ested, ifl'm'not mistaken .....· 19 Q. Did you know him prior to September 9, 26' 21 1989? A. I don't think.so, no. 22 Q. All right. His nickname was Stony. Does 23 that ring a bell for you? 24 Okay, What information would they give 2 3 A. 5 6 7 .. 8 9 10 11 12 13 14 15 16 17 18 !9 20 21 22 23. 24 ' Page 50 1 2 3 4 5 6 7 8 9 10 II . 12 13 14 15 16 17 18 19 20 21 22 23 24 A. No. Q. So you don't recall any conversations or knowledge that you would have had of Pedro Cordero before that time? A. No. Q. How about Samuel Perez, did you know him? A. Yes, I did. Q. He had a nickname? A. Yes. Q. What was his nickname? A. Spanky. . Q. How did you---·you knew him prior to September 9, 1989? .. A I knew was ·a little boy. Q. And how did you him? A. From the street. Q. And what could you tell us about Samuel Perez? A. That he. was agangbanger or he still is. I. have no idea if he still is or not. Q. Okay. What gang was he a member of? A I think he was an Eagle, if I'm not mistaken. Tthink he was an Eagle. Q. Did you have frequent contact with him? . STENO · (312) 236-1414 JR-JJAMERICAN 044693 1 2 3 4 5 6 7 8 9 10 II 12· 13 14 15 16 17 18 19 20 21 22 23 24 A I believe I arrested Spanky, too, ifl recalL I believe I had. · · .·· Q. Do you know what you arrested him for? A. No. I c11n't tell you-that because !don't remember.· Q .. Okay. Did you have conversations with him since he was a little boy?. A I had conversations with him often; you know, see him, talk to him, stop and talk to him just like every other gangbanger. Q. And you arrested' him one time you think? A. I'm saying I'm almost sure I arrested him. I don It know how many. times though. Q. dkay .. Was-- did he deal drugs? ' A. Yes, he did, too. Q. Do you know what drugs he dealt? A. No, I do not. Q. Did you ever arrest him for drug dealing? A.Tdon't remember ifl did oi.not. Q. All right. You said that he was a gang member. Do you know what position he had in the gang as of September of 1989? A. Well, Spanky was one of the leaders for Page 52 his section. Q. And how did you know that? A. From the gangs. · Q. From the word that you heard from talking to people? A. Correct. Q. Did he ever tell you that he was a gang leader? A. He might have. I don't remember. Q. Okay. He could have been a Spanish Cobra; right? A. Yes. · Q. Okay. As of 9, 1989, do you know if Sainuel Perez was considering moving to a different gang? A. No, I don't. Q. As of September Of 1989 did you know if there was any problems between Juan Johnson and Samuel Perez? A No. Q. As of September 1989, did you know what · degree of power Samuel Perez had within his gang? A. He·was a section leader. I believe he was a section. leader there. 'Page 49- Page 52 REYNALDO GUEVARA " - Condenselt TM ,. Page 53 So what would that mean, being a section leader? A. Meaning that he controls that area. Q. Do you know what area he controlled? A. Oh. I don't remember now; but, if I'm not mistaken, he was-- if I'm not mistaken, I don't rememberexactly, but I think it was probably Kostner -- Armitage and Kostner and some other areas. I couldn't tell you exactly. Q. Do you know how many people within the gang would have reported to Samuel Perez? A. No. Q. In the course of your dealings with Samuel Perez did you find him to be-honest with you'? A. No, he's a liar. Q. And why do you say that? A. Because from him I got a lot of infonnation that was nottrue. Q. So he would tell you things that were false? A. Yeah. Yeah. All of thein would. Q. Can you recall specific things that Samuel Perez told you that were false? A. No, not at this point. Q. .l 2 3 4 5 6 7 8 9 10 . 11 I2 13 14 15 16 17 18 19 20 21 22 23 24 -- " I 2 3 4 5 6 7 8 9 10 II 12. 13 14 15 16 . 17 18 19 20 21 22 . 23 24 . I ... 2 3 4 5 6 7 8 9 10 II 12 13 14 0 15 16 17 18 19 20 21 22 23 24 JOHNSON v. GUEVARA Page 55 Q. Do you know a· person named Edwin Gomez? _ A. I think he was one of the witnesses, too. I think he's also a gang member, a Latin Eagle, I _ he is. - Q. And did you speak with him before September 9th of 1989? A. Again, I spoke with most of them guys. Q. But you don't remember particular conversations with Edwin Gomez? · A. Nor do I remember particular days. Q. Excuse me? c A. Nor do I remember particular days: Q. All right. And Salvador Ortiz, did you know him? A. Yes. Q. How did you know him? A. From the same way. Q. And how long had you known Salvador Ortiz? A. Mo.st of these kids, I knew them since they were growing up. Q. And they would just grow up into the gangs? · A. They would grow up. Q. So you knew him since he was a little kid? Page 54· You just remember that he had given you false information? .. A. Yes. Q. Doyou have any idea what he gave you· false information about? A. Not right now I don't. . Q. Do you ever remember interviewing Samuel Perez in the course of an arrest or in the course of investigations? A. Oh, I might have talked to him in several cases. Q. Would you go to him for infonnation because he was a section leader? A: Yeah, mainlybccause he is a section leader. Q. And would he give information about his own gang members? A. I don't think he would. I don't-- he never gave me information abo11t his own gangs. Q. He would give you information about other gangs? A. About other gangs. Q. And how would he know that inforiwition? A. I have no idea. Q. STENO ·· (312)236-1414 JR-JJAMERICAN 044694 Page 56 i A. Since he was a little boy, yeah. 2 Q. And did you ever arrest Salvador Ortiz? 3 4 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 2A I don't remember right now if I had ever arrested hiin. "I. might have, and the.n again, I might not ·Q. Did he deal drugs? A. Ortiz, I don't think I ever -- l; personally, ever saw him dealing any drugs. answer that. Whether he was or Q. Okay. Have you had any contact with Salvador Ortiz since 1989? - · ·A. I haven't had any contact with any one of those guys. ·· · Q;. Okay.· And you can't recall any conversations with Salvador Ortiz; right? A. No. Q. How about Juan Michel Delgado, dO you · recall him? He's also known as Juanchi (phonetic). A. ·l know who you are talking about because he was also one of the witnesses, but that's-and, again, I had conversations with them prior on the street just like J did with any other gangbanger. A. not, · Page 53 - Page 56 CondenseIt TM REYNALDO GUEVARA JOHNSONv. GUEVARA .-----.,------"""'7":------·--.,..---...,.------'--,--------·· Page 57 You don'fremember any of those-···· 1 -_ 2 2 . conversations?' 3 A. No. 3 4 Q. Po you know what gang Juan Michel Delgado 4 5 5 was in? A. If I'm not mistaken, I think he was a 6 6 7. 7 Latin Eagle also. Q. How about Guillermo Vasquez, also known as_ 8 ..8 9 9 Memo, do you have any contact with him? A. Yes, I did. Memo, I had contacts with him 10 1o 11 II on the streets. 12 Q. And do you remember any particular 12 · 13 13 conversations with him? 14 14 A. No. Q. And do you remember any arrests that you 15 15 16 16 may have made of him?_ 17 A. No. 17 Q. Armando Mendez, did you know him? 18 f8 19. 19 A. Yes. Q. How did you know him? 20 20 A. From the same way. 21 21 22 22 Q. Since he was a little boy as we11? A. As well. 23 · 23 Q. All right. And do you recall any specific 24 24 "I 'Q: k Page 59 death of-Ricardo Fernandez thattookplace neaf'the Caguas Club ort·or about September 9th or lOth;· 1989? A. Yes. Q. And that's-- that was an-- you handled an investigation relating to that? .· A. I was part of the investigating officers on that. Q. How did you become involved in that investigation? A. I was assigned the next day. Q. On the day in which Ricardo Fernandez died you were not working? A. On the day of the incident? No, I was not. Q. Okay. And how qid you get assigned to the investigation? A. By a sergeant the next day. Q. Do you l<now the name of the sergeant that assigned you? A. It could have been Sergeant Mingey. I don It remember. Q. And could you tell us, how docs-- how did the assignment work? Did he explain the case to Page 58 1 2 _3 4 5 6 7 8 9 10 11 12 13 15 16 17 18 !9 20 21 22 ·_. 23 conversations you had with him'? A:No. · Q. Did you make any arrests of him? A. Not that I can remember. Q. Was he a drug dealer? A. He might have been, but I can't say for sure. Q. And with Vasquez, was he a drug dealer? A. The sarne way. They all might have been, but I can't say-Q. And you are not sure about Delgado being a drug dealer either then? A. That's correct. Q: How about Ricardo Fernandez; did you know him? A. No, I didn't. Q. He also was known as Little Rook. A. No. Q. You don't recall that name? A. No. Q. And Chris McCoy; did you know him prior to 1989? A. I still don't know who he is. Q. Okay. Now, you arc familiar with the "AMERICAN STENO (312) 236-1414 JR-JJ 044695 Page 60 1 you? 2 A. I believe it was an aggr'!yaied battery at that time. - It was never a murder on the scene. I believe he was taken to the hospital. I believe that's where he died at. So the case report was made as an aggravated battery, and we got a copy of the case report to follow up on this. Q. So would you get the copy of the case report from the officers that were -- that handled the aggravated battery --A. No. · Q. -- on the night that it happened? A. No. No. Q. What would you get? A. From the office, from our office. Q. Okay. 'But would they be reports from the·· officers that were on the scene? A. The report, the original report that was made. Q. Okay. A It's a general. Q. The original police report? · A Yes. 3 4 5' 6 7 8 9 I0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 57 - Page 60 JOHNSON v. GUEVARA REYNALDO GUEVARA Page 61 Page 63 Q. Okay. An<r.there wouldn'rhave been a ·• t· · with Perez? ·- 2 · · Ms: EKL: objection:· Assumes facts riot in suppletnental reportatthat time; right?· 3 evidence. 3 A. No. '.1· . . Q .. So when you received this assignmen,t, what . 4 THE WITNESS: Not at this time I don't. 5 BY MR. GARDINER: 5 responsibility did you have with respect to the 6 Q. You found Perez or not? 6 assignment? 7 A. I don't remember ifl did or not. 7 A. In the report it states who witnessed. So 8 . Q. Okay. And on the report also was listed .8 ._ we start looking for the witnesses. 9 Q. Okay. In the report it listed potential § Edwin Gomez. Do you know if you found Gomez? 1o A. I don't remember if I found any of those 10 witnesses? 11 guys on that day, or later on the ..· r1 A: Correct. · 12 Q. And you would go-- did you just go to 12 afternoon. 13 Q. Okay. The third name -· when you talk 13 talk to the or did you go with somebody 14 -about other -- anyof the guys, the third name 14 else? 15 listed on the general report was Reginald 15 A. No. My partner and I. 16 Robinson. Do· you know that person? 16 Q. Who was your partner at the-time? 17 A. At the time it was Steve Gawrys. 17 A. I heard of him. · -·-18 Q. Did you know who he was at the time -- on 18 Q. Doyouknow what witnesses:you went to 19 September 1Oth of 1989? 19 -- interview?. 20 A. Oh, talked to a lot ofthem, a lot of 20 A. No. 21 Q. Do you recall if yol1 interviewed that 21 people. Specific? No. I was looking for, 1 22 . believe -- if I I m not mistaken, I believe Perez was 22 person? 23 A. I don't recall. 23 named in there as a witness and some other guys and 24 Q. So tell me howyou went about your 24 I was looking for them. 2 ·- Page62 Q. So you were looking for the people that _ 2 _ w'ere listed iri the general report and one of those 3 was Samuel Perez? 4 A. I believe so. 5 Q. And so what time of day would you have 6 been assigned to the investigation? 7 A. ln the morning. 8 Q. So you -- did you work the first shift? 9 A. I workedfrom 9:00 in morning. 10 Q. All right. And you'd work till 4:00 or-11 A. Whatever -- well, if I had something going 12 or if there was an arrest made, I would continue 13 on. 14 · Q. Okay. And so did you talk _to Perez?· 15 A. I don't remember if I did talk to him at 16 that time or not on that day. I mighthave. 17 ·o. So that would have been September 1Oth? 18 A. Yes. 19 . · Q. Because it was an early morning or late 20 evening on the 9th where this person was killed; 21 . right? 22 A. I don't remember the exact time, but it 2i was in the _ 24 Q. Okay. So do you recall conversation STENO (312) 236-1414 --· JR-JJAMERICAN 044696 Page 64 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 investigation then. A. Just drove around and talked to people -them were negative answers, I don't know, I wasn't there -·· and that's it' Q. All right. You did at some point talk with Samuel Perez though; right? A I think I did, yeah. I don't know when. I don't remember when it was; but 1 believe I did, yes. Q. Do you know what conversation you had with him? A. Probably abm.ifthe.iricident. Q: Do you know if he told you anything? A. i don't remember ifhe did ot not. ( don't think he did. Q. Arid you just talked.to Samuel Perez because he was listed on tlie original report- by the responding officers? A. Yes. Q. Was there any other reason you would have talked to Perez? A. I would have probably talked to him anyway to, find out if, he knew anything about what ' happcl)ed. Page 61_- Page 64 REYNALDO GUEVARA CondenseIt TM JOHNSON v. GUEVARA Page67 -1 Q. Is that because of the position that he · held? 3 11 A. No, not just because of the position. It's because he was a member of the Folks Nation .. Q. So you thought he might have some information about what happened? A: Yes. ., .. Q. Was your understanding that a Spanish Cobra killed a Latin King at the Caguas Club? .. MS. EKL: objection. Foundation in tenns of what point in time you are talking about. 12 BY MR. GARDINER: J3 And when you received this assignment, did you -- in the course ofinteiviewing people, did you come to learn or believe that a Spanish Cobra had killed Fernandez who was a Latin Eagle? A. You are saying a "Latin Eagle," not a "Latin King"? Q. Right. I'm sorry. I made a mistake again, didn't I? I'll ask it again so it's clear. Was your understandingthat a Spanish Cobra had· killed a Latin Xing at the Caguas Club? MS. EKL: counsel, I think you said a "Latin King" again. 4 5 6 7 . 8 9 10 14 15 16 17 18 19 20 21 22 23 · 24 that some member of the Folk Nation had been involved in the death'af aLatin Eagle, were there 2 people that logically you wanted to speak with? 4 A At first it wasn'ta death, it was merely 5 an aggravated battery investigation -6 ...Q. Okay. 7 A. -- that turned to a death .. Afterwards it 8 turned to a murder. _ 9 Q. Okay. And as you were investigating the I 0 aggravated battery when you first were on this, 11 were there -- was your did you 12 W(lnt to speak with particular people because of the 13 gangs that were involved? 14 A. Yes. 15 Q. And Samuel Perez was one of those people? 16 A. Samuel Perez was one of them that I would 17 look for -- actually, would be the firstone that I I 8 . would look for. 19. Q. And why was he the first one? 20 A. Because he was the leader. 21 Q. All right. And who were the other people 22 that you looked for? 23 A Anybody else who belonged to the gang 24 because my understanding was it was a Folk party 1 2 . 2 · Q. Page 66 MR. GARDINER: I did a:gain, you're right. 1 Page 68 1 there. Okay. We'll.goonemoretime. I'llgetitright this time. 2 Q. So you are looking for Folk gang lnembers? 3 3 4 BY MR. GARDINER: 4 5 Was your understanding on September lOth of 1989 that a Spanish Cobra had killed a Latin Eagle at the Caguas Club? A. My understanding was that a Folk killed a Latin Eagle. Who and what gang it was, I wasn't aware of that at that point. Q. Did you understand that it was not a Latin Eagle that killed a Latin Eagle though? .It was some other Folk gang that killed a Latin Eagle? A. It was smne other Folks, right. Q. Okay. How is it that you became assigned to this case? · Was there a reason they picked you? A. Again, because I mainly grew up in that Humboldt Park area and I knew a lot of the · parties -- I mean, the gangs in that area. Q. And you were at Area 5, was that your assignment? A. Actually, we were Gangs North at that time. We covered Area 6 and Area 5. Q. Okay: So when since you understood Folks, right. Q. Okay. And you thought that Perez would give you informationthat would -- could lead you to the person that either battered or murdered Fernandez? A. Tothe gang or the person, yes: Q. Okay. And did he do that? A. Again, I don't think he ever gave me any information pertaining to that. · Q. What infomiatiot1 did he give you when you spoke with him? · A. I think it was negative information. Actually, I didn't-- you know, that he didn't know or whatever or that he would find out, Something to that effect. That's about it. Q. Was this an important investigation to you? . A: They were all important investigations to me. Q. Was this any more important than another investigation? A. No. 2 6 7 8 9 10 11 ·· 1 2 13 14 · 15 16 l7 .. 18 19 20 21 22 23 24 Q. STENO (312) 236-1414 JR-JJAMERICAN 044697 5 6 7 8 9 10 11 12 · 13 I4 15 16 17 18 19. 20 21 22 23 24 A. Page 65 - Page 68 JOHNSON v. GUEVARA Condenselt TM REYNALDO GUEVARA Page 69 . Q. ,Did: you ever take Samuel Perez·to A Their report. 2 . Police. Department in connection with your 3 .4 5 6 7 8 10 11 · 12 lJ · 14 15 16 17 18 .. 19 20 21 22 23 24 Page 71 the 2 · investigation? A ·I don't think I did. Q. Did you ever meet with Samuel Perez on the street and then have someone else take him into the · station_ in conne<::tion with this investigation? A. No. Q. Did you ever see Samuel Perez in the police· station in con·nection with this investigation? r don't remember. He might been there, but I don't remember. 1 don't think I saw 5 6 MS. EKL: objection. Assumes facts not in 7 evidence. 8 THE WITNESS:. First of all; I wasn't there 9 10 · when the original incident happ_enGd. So, 1i · therefore, I cbuldn 't tell you if I ever saw -- · 13 definitely not seen a myself. 14 BY MR. GARDINER: 15 Q. Okay. So after the original incident until today's date you never saw a four-by-four near the Caguas Club; right? A. Not me . Q, Did you go tothe scene the beating? A Yes. Q. And you did that in the ccmrse of your investigation? 12 him. with$amuel Perez in connection with the inve.stigation of the battery or death of Fernandez? A: Oh, I couldn't tell you if Ldid or not, no. Q. You don't know if you spoke with him? · A If I -- well, I spoke to him about it at the but Jrt>J.U I don't think I spoke to him again. that report? A Yes. Q. Did you ever see a four-by-four at the scene near the Caguas Club? · 3 4 A: Q. So how many times do you think you spoke · 16 17 18 . 19 20 21 22 23 24 Page 70 Q. Okay. Did you ever show pictures to z 3 4 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 · 22 23 24 Samuel Perez? A. No, I did i1ot. Q. Did you ever show him a gang picture book?· A. No. Q. Did you ever -- okay. Did you ever talk to him about a lineup? A. ·No. ,,,;.: ·.. Q. Did you ever meet with him and other gang members at any location to discuss the case? A. No, I didn't. ... What was your understanding of how · Fernandez came to be beaten? A My actually, because of · the report, it indicated that he was hit by a four-by-four. He was beaten in a gang -- there was a g'ang fight that started inside the Caguas Club and moved outside. ·.·· Q. And you learned that he was struck by a four-by-four from the original investigating officers? A. I don't remembel,'. Ldidn't talk to the original investigative .officer. Q. Okay. You just got their report'? . AMERICANSTENO (312)236-1414 JR-JJ 044698 Q. Okay. So your information was based on · ·I 2 3 4 5 6 7 8 9 10 II there-- me, of A Yes. :: Q. And would you have done that immediately Page 72 after receiving your assignment'? A. No. Q. When did you go-- if you started your assignment 011 the 1Oth of September; when did you go to the Caguas Club to look at the scene? A After breakfast. Q. So in the morning? A. Correct. Q. And at that time you didn't see a · four-by-four? A. I don't think I did. I don't think I did. i2 Q. All right. And did you ever interview any of the people that -- well, let me back up. 14 · As Iurider.stand it, the Caguas Club is on 15 the street level; right? 16 A. Correct. 17 Q. And then are there apartments above the 18 Caguas Club? 19 A. The Caguas Club? There might be 20 apartments. I don't think there were people living 21 there at that time. I don't think so. But I think 22 ·there might be maybe one floor, maybe two floors. 23 And; then again, it just might be -- I don't 24 remember right now . 13 Page 69 - Page 72 REYNALDO GUEVARA Condcnscltm JOHNSON v. GUEVARA Page 73 Q. In the course of your investigation did you intervie:W anyone that lived near the 3 . Caguas Club? 4 .. A. I've talked to people in there -- around 5 there in the neighborhood. I've talked to people. 6 As far as getting a complete statement from them 7.. and writil}g them down? No. 8 Q. So you did interview people that were · 9 around -- that lived near the Caguas Club? 1o A. Correct. 11 Q: But you didn't write down any of the names 12 you think? 13 A. No: I don't think it was-- you know, 14. they didn't have imy i11fonnatiori,so I didn't do 15 anything. 16. . Q. So when you were 17 investigation, tell me your thought process on 18 .where you wanted to look to find the perpetrator of 19 the crime. 20 A. Basically around the area of North A venue, 21 Artesian, Campbell, around the Spanish Cobra area 22 · ·where the- incident took place at. ·• -. 23 Q. Did you have any suspects in your mind 24 when you were assigned this investigation? Page 75 1 1 2 2 •. - 1 2 3 4 5 6 7 8 9 10 II 12 13 14 15 16. 17 18 19 20 21 22 23 24 . ·c . ', , 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1-9 20 21 22" 23 24 Q. So you would just go on the streets a11d see who· you could find? A. Correct. Q. And then you would talk to those people? A. Correct. Q. Did youconductyou.r investigation.always with your partner or were yo).l. on your own sometimes? A. No, with my partner. Q. So you wouldn't split up and have-- you would takc·one area and he would take another area? A. No. Q: And' was that your.. , always your pattern as a Gang Crime spec.ialist,to work side by side with a partner? A That's correct. Q. When you would takt: into the police· station, would your partner always be with you for doing that?. A. Yes. Q. And was your partner at the time always Gawrys? A. Yes. Q. So there was never a circumstance where he Page 74 Page 76 Definitely not. 1 would work one shift and you would work another Q. Now you said that Sarriuel Perez was the 2 ·shift at that time? first name that came to mind in terms of gaining 3 A No. information; right? 4 Q. You were a team? A. He was the name -- the first guy whose 5 A Correct. name was on that report. 6 Q. Now, tell me what progress you made in the Q. Okay. Were there other people that were 7 course of the investigati()n of the battery or gang members that you thought were appropriate to 8 murder of Fernandez. ·. .. . interview to get information about the battery or 9 A. J mean, by talking to the people and, you murder of Fernandez? 10 know, and everything, we found out that it was a A. Oh, I thought all of them were. II Folk party and that it was one of the Folks that Q. So you didn't draw a distinction between 12 got into a fight 'with them "- for what reason, 1 gang leaders other than Sam Perez and other gang 13 have no idea -- but then that fight escalated and soldiers in trying to get infoin:lation? 14 it went outside the' Caguas Club. A. I was looking for anybody who was there, 15 Q. Okay. Do you know who gave you that whether he's a· soldier, a sergeantof anns or the 16 information'? lei:1der, the main leader. I was -· anybody. I 17 A. Right riow, at this·point, I don't recall didn't care who it was as long as he was from the 18 who did it; but that's what the talk was that was gang and he was in that area there. 19 going on, plus it was ori the police report. Q. When you-· well, wouldn't you draw a 20 Q. On that initial report that you received? 21 A. I believe so. ·· priority, though --.would you tend to go to people that had given you infonnation in the past that was· 22 Q. And so you had that infonnation. What did accurate? .. 23 you do about it? A. If I saw them. 24 0-.. I went out looking for witnesses again or A. STENO (312) 236-1414 JR-JJAMERICAN 044699 Page13 76 REYNALDO GUEVARA Condcnselt rM JOHNSONv. GUEVARA 7 Page 79 you wrote -- that he wrote? A Yeah; Q. So, as you sithere today, can you remember who you took .into· the .Police Department? MS. EKL: Are you speaking about other the people he! s alreadymcntimied? MR. GARDINER: Yeah. 8 BY MR. GARDINER: · 2 3 4 5 6 9 1o · Q. You mentioned two people so far. 19 . Do you recall any other persons that you brought into the Police Department as you sit here today? A. I believe I took in three, but I don't reme1i1ber their minies correctly. MR. GARDINER: Can you mark this as Guevara Deposition Exhibit No. 1. (Whereupon, Guevara Deposition . Exhibit No. 1 was marked for identification.) 20 BY MR. GARDINER: 21 Q. I' 11 show you what's been marked as Guevara Deposition Exhibit No. 1, which is 1abeled · Supplementary Report, and it contains RD No. M -414099 and consists of two pages labeled 11 12 13 14 15 16 17 18 22 23 24 Page 78 1 Page 80 A: People that I would talk to that says, Yeah, I was there and I saw' the fight and whatever. 4 I said, Okay, you, can you identify the· 5 guy or guys that were doingthe beating? 6 And they would say, Yes. 7 I would talk them and show them photos. 8 Q. Okay. And what people did you take in? 9 A. I thinkit was Armando. 10 Q. That's Mendez? 11 A. I believe so. 12 · Q. Okay. 13 A. And I believe Michel --Michel-- or 14 whatever. Some of the guys signedthe report that 15 I took in. I don't remember right now. ·. 16 ., Q. Well, would ·it help you to take a look at 17 the report? 18 A. Yeah. 19 Q. let me ask you, first of all, did 20 you write a report in this case? 21 A. Did.l.write a report? 22 Q. Yeah. 23 A. My partner typed it. 24 Q. Okay. And it's a supplemei1tal report that 10 and 11 in the bottom right-hand corner. 2 2 3 3 (312) 236-1414 JR-JJAME.RICANStENO 044700 Is this the report that you arc referring to? 4 A: Yes. 5 Q. Okay. 6 7 8 9 10 II 1i 13 14 15 16 17 18 19 20 21 Fernandez, Ricardo, is the victim. Okay. Let me see. Okay. Salvador Ortiz; Mendez. Q. So you mentioned Ortiz and Mendez. Are you still looking at that? A. Oh. Okay. Here. Gomez; Ortiz. Ortiz, I · don'tthh1k was ever brought into Area 6. I think it was Gomez, Michel and Vasquez, if I'm not-- or, no, Mendez, I believe. MS. EKL: rf you need a minute to look at the report, go ahead. THE WITNESS:· Okay; And actually Ortiz and Mendez were brought into Area 5 for the lineup. Okay. They did not view any photos.·'· And one, three and four, Michel, Gomez and Vasquez viewed photos, viewed the books. A. 22 BY MR .. GARDINER: 23 Q. Okay. So tell me, first of all, for MichCl, Juan Michel, who is also known as Delgado, · 24 Page 77 - Page 8C REYNALDO GUEVARA 1 2 3 4 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24 Condenselt ™ Page 81 Gomez and Vasquez; where did they reviewthe books? A They were brought into Area 6. · · Q. And who brought them to Area 6?. A. J belie"e we did, if I'm not mistaken. Q. Would you have brought all three of them together into Area 6? ... A. Could have. ..Q. You do,n't remember that? . A. No .. Q. And they would not have viewed the books out on the street; right? A. No. Q. bo you remember meeting with these people on the street before bringing them into the Area to view photo books? A. 1 would have had to. Q. All right. Do you where you met with them? A.. No, I do not. Q. And you didn't show them any ph?tographs on the street; right? ·A.-No. Q. You didn't lay out any photographs on a car hood or trunk; right? Page 82 1 2 3 4 5 6 7 8 .. -':·.'·--,· 9 10 11 12 13 14 15 16 17 18 19. 20 21 22 23 24 A No. No. Q: i\nd were you present when they viewed pho!ographs at Area 6'? A I was there, yes; Q. Was Samuel Perez there as well? A. No. Q. And when they viewed the photographs-could you us what you said to them before they viewed the photographs? . . A I didn't say anything. I gave them a book.. I said; Here's a book. Go through the book. }f you see anybody that was there, tell me who they are, .• Simple as that. One guy one room, the other guy wak iri room and the, other g\1.¥ was 1n another room, or -- either that, or they were on different tables. Q. So youwould present the books to them separately? . A. Correct. Q. They were not in the presence of each · othefwhen they werereviewing these picture books? A ·Not at the same time everybody looking at STENO (312)236""1414 JR-JJ.AMERICAN 044701 ··.. JOHNSON v. GUEVARA Page 83 the book. · 2 · Q. Okay. And that was yottr procedure and the 3 procedure of the Police Department at the time? .4 A. That was the procedure for us. Whether it • 5 was the department or not, I can't tell you that. Q. And what was the reason_ that you would . 7 want them separate when they were viewing the photo 8. books? 9 A Because I didn't want them talking to each 10 other, number one, or pointing afingcr at someone 11 who might not even be there ... 12 Q. And the picture book that you showed to .. 13 these three gentlemen, what picture book was it? 14 A. They were different books·. · 15 Q. All right. What books were they? 16 A.. Books. from the Disciples, from the Cobras, 17 from the Eagles, from the Dragpns. So they we.re 1.8 different books. 19 Q. So at least four books of'Folk gangs? 20 A. Of Folks, right. 21 Q. And would you stack up the books on the 22 · table and then· say, Go ahead?' 23 A. No. No. 24 Q. How would you do it? -· 1 1 2 3 4 5 6 7 8 9 1o II 12 13 _14 15 16 17 18 19 20 21 22 23 24 Page 84 A I would give one a book; I would give the other one another book; i would give the o'ther one another book; and let them go through the books. Q. Okay. A Then we switch them around. Q. Okay. And would you -- would you tell one person that another person had picked somebody out? A No. Q. All right. So you wouldn't speak to them about their selections before they made a selection; right? A No.· Q. And you would not speak to them about selections as you brought a new book in to someone; right? A No. Q: And when you --·did these three people make selections? A I believe they did, yeah. Q. All right. Who did they select? A l believe they picked Juan'Johnson. I believe they picked -- well, I believe they picked Juan Johnson and said his was also there -I believe that's way it was-- but Juan Johnson Page 8 L- Page 84 - REYNALDO GUEVARA Condenselt TM JOHNSON v GUEVARA Page 85 Page 87 and Franco; they were all picked. I A. Yes, I have cases like thatbefore. 2 - - - Q: Okay:· And did they pick Cordero as well 2 · Q. And in' this case wouldn't you have · 3 or not? 3 expected that -- well, so these three people -4 A. Cordero, yes. 4 I' 11 just strike that question. 5 Q. Okay. You don't have an independent 5 So these three people made the 6 recollection of who they picked; right? 6 identific11tion from these books all separately;. 7 right? 7 A:. No. No. .8 A: Yes; 8 Q. Now, these three persons, Michel, Gomez 9 and Vasquez, had they told you on the street that 9 Q. And they did it without any conversation I o they saw who had struck Fernandez? 10 with you? II A. I don't ren1ember if they told me that they · · 11 A. Yes. 12 saw who struck him. I2 Q .. And so if somebody picked -- if somebody 13 Q. Well, why did you bring these three in to 13 picked -- let's take Vasquez. If Vasquez picked a 14 view the pictures? I4 photographofiuan then what you do? 15 A. Because they saw the fight. 15 A. Then I would know Juan Johnson is one of 16 Q. Okay. So you don't know what they told 16 · the guys that I'm going to look for.c 17 you on the street? 17 Q. All right.. Would you do something with· 18 A. Basically 'that they can identify the guys 18 the picture book? 19 that were in the-fight. 19 A: No, not with the book itself. 20 Q. Okay. Now, were these three -- were 20 Q. All right. Would you do anything with the 21 these three people generally in the area of the 21 photogr-aph? 22 Caguas Club? ·22 A. Not with the photograph either. The 23 Did you know them to go into that area? 23 photograph stays in the book. The book is-- it's 24 A. Oh, yeah. 24 marked on there that from the book he was picked. I Page 86 I 2 3 . 5 6 7 8 9 1o 1I 12 13 14 15 ·16 17 18 19 20 21 22 23 24 Q. Okay. And would you have expected that these three people would have k.rioyvn who Juan Johnson was? A. Oh, they_allknew. Q. Okay. On the street did any of these three people say Juan Johnson was one of the persons that struck Fernandez? A. I don't remember if they did or not. Q. You would have asked them if they knew the name of the person that struck Fernandez; right? A. I would ask them, Do you know who was involved in the fight? · Q. But you don't recall what they said? A. No..The only thing that I can remember is.· that they said; Yeah, I can identify the guys who were at the fight. From that point on, we take them, they view photos. After the photos, they are taken to Area 5 and turned over to the detectives, and at that point my investigation is terminated. Q. But you've had cases where the witnesses say, Yeah, the person that did the striking, the beating, the murder, the shooting,· is so and so; right? (312) 236-1414 · JR-JJAMERICANSTENO 044702 Page 88 I Q. Okay. 2 A. Okay. And that's it. 3 4 Q. You said in the front of the book you write "that? . · 5 A. No. No. No. On the report. 6 Q. On the report. 7 8 9 10 1I 12' 13 14 15 16 17 18 I9 20 21 22 23 24 )'-ou a photocopy of the picture that he selected? A. No: Q. So when he names somebody, then you simply put it in your police report? A. You put itin the report. Q. on the pictures that were i-n that book, would --did you show them. the book that the Area kept or the Guevara book? · A. No, the Area. Q. Okay. And on the Area pictures arc there names underneath? A. No. Q. Okay. A.· There is no names 'underneath any picture. Q. Okay. Are they Polaroid pictures? ·A Some are Polaroid, some are IR photos. Q. From the processing? Page 85- Page 88 Condenselt n.t REYNALDO GUEVARA Page 89 . I A 3 6 · or "no." 4 BY MR. GARDINER: 5 Q. On the back of the pictures were the names? 8 A. On the back of the picture, yes. 9 Q. So when Vasquez picked out Juan Johnson, 10 you would look at the picture, and would you look 11 at the back of the of not? r2 A. No. Q. Because you knew what he looked like? .· 13 7 . 14 15 A. NO. .. Q. Oh. What would you do? Because at the .beginning of the books 17 there's pages naming everybody, the picture. and the . ·.. 18 page. 19 Q. I see. 20 A. So you keep that out and you go back. You 21 see the page, then you go and look and see whose 22 name is that ori there. 23 Q. Okay. And so each of these three would 24 have gone through all these books and picked out 16 Page 91 1 ·· Q: Why is it that you wouldn't have done that · 2. ·• as a Gang Crime specialist? ··' ·· 3 THE WITNESS: Yes. 4 5 Uh-huh. MS:·.EKL: You have to answer 2 A JOHNSONv.GUEVARA · 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A. Because it's a murder investigation-and you have to tum it over. Once you get the identification, you take the witnesses and you take them into Area 5 and tum them oveqo the detective and tell them they made identification, . and then they will take it from there on. Q. So you wouldn't go out in the street then and do further investigation at that po_int; atleast of the mimed persons? A. Oh, I probably did go back out to see if I find more or something: o·: Okay. But you turned over-- you would .· ... write your report and you would tum it over to the Area.. detectives? . A. The report would not be written at that . point. Not yet. Q. How would you communicate to the detectives then? A Tell them who they picked out of the · photos. · Q. Okay. So you would-- would you just talk to somebody at the Area then? Page 90 Page 92 the three people ·that ate identified in your A Yes. report, right, each of these three, Vasquez, Gomez . 2 Q. And ·a detective wouid been · ·· and Michel? 3 to the case or only assigned. once the IDs were A. They picked those guys. 4 made? Q: Okay. 'So do you know which of the three 5 A. No. The detective was already assigned to was the first to pick one of these persons that 6 the case. ultimately became a defendant? 7 Q. Okay . . . A. No . 8 A. I would turt1 them over to that particular 9 · detective. Q. And do you any conversation you had with Vasquez, Gomez or Michel about their 10 Q. Do you know what detceti ve was assigned to selections? 11 this case? A. No. 12 A. I don't remember. You ni ight be tight --Q. So when somebody any of these three 13 you might be right with O'Donnell, but I don't people ·ever say they were unsure about their 14 r'emerriber. selection? 15 Q. Okay. So you knew that Vasquez was a 16 Latin Eagle; right?· A: Not to me. Q. Did you .interview these three 17 A. Yeah. people after they made the photo identification? 18 Q. And you knew that Juan Michel or Juan A. No. They were brought into Area 5 and 19 Delgado ot Juanchi -- all his names -- was a turned over to the detectives. They interviewed 20 Latin Eagle as well; right? them. 21 A Yeah. Q. Okay. So O'Donnell would have interviewed 22 Q. And you knew-that Edwin Gomez was a them? 23 Latin Eagle; right? · 24 A. Yeah. .. . A. Whoever was the detective on the case. 0 2 3 '4 5 6 7 . 8 9 10 11 -12 13 14 15 16 17 18 19 20 21 22 23 24 , 4 •• STENO · (312)236.,-1414 JR-JJAMERICAN 044703 Page 89 - Page 92 REYNALDO GUEVARA CondenscltTM JOHNSON v. GUEVARA Page 93 · · 1 Q. And you knew that Juan Johnson was a 3 A. Yeah. 4 Q. And you knew that. Henry Johnson ·5 6 7 8 9 10 11 12 · 13 14 15 .16 17 18 19 20 21 22 23 24 2 3 4 ·5 6 7 8 9 10 11 12 13 14 15 'to J7 18 19 20 21. 22 23 24 1 right? 2 . _Page 95 . 2 W?S a A !-heard that he's capable of anything: Q. And who did70U hearthat from? 3 A From guys on the.street. 4 Q. And you don't know any of those people Spanish Cobra; right? 5 though? · 6 A. No. A Right. Q, Af1d you knew that Hector was a 7 Q. And. how about Henry Johnson, had you heard Spanish Cobra; right? 8 whether he was capable of violence? A: I don't know if I knew that. I don't ·9 A Yeah. think I did know he was Cobra, but he was a 10 Q. And you hadhcard that lie was? · 11 A Yeah. gangbanger. Q. Did you know if Cordero was a Spanish 12 Q. Who haJ you heard that from? ·Cobra? 13 A From the people on the street. · A. I didn't know Cordero. 14 Q. But y'ou don't recall the people Q. Were you concerned at all that these three J 5 that told you that? -16 A No .. Latin Eagles were picking ou.ttwo people that you . knew to be Cobras, Juan Johnson and Johnson? 17 Q. So when this photo identification was A I knew they picked out two Cobras, yes. 18 at Area 6, didyou believe that your work had . Q. Did that concern you as a Gang Crl.me 19 finished in connection with this investigation?· specialist? 20 A I believe that it might. At. that point in A No. 21 time that I would have to notify. and tum the. : Q: So the fact tliat there were -- you didn'·t '22 witnesses over to the detective on the case. consider that there might have been a bias by the 23 Q. So how do you tum the witnesses over? Do Latin Eagles to select a member of the Spanish · 24 you walk them over to the detectives? of Page 94 Cobras• for this murder? A. Nb. Q. And why did you not suspect that? A It was a -Folk party, Folks were always . arguing with each other. I mean, there's no if or buts about it. The Disciples, the Cobras, the Eagles, the Dragons, they would all be fighting amongst each other. So, no, I didn't. Q. Were you surprised that somebody would pick out Juan Johnson as a person that struck blows in this case? A No. Q. Why were you not surprised? ·· A. Like I said, this is a fight arnong the Folks. Any one of them could have done it. Q. Had you ever seen Juan Johnsol! participate .· in any violence as a gang member, as a person prior ·. to thattime? A Again, I don'tthink I ever arrested Juan Johnson othe!' than that day. So I couldn't say. . Q._ Had you ever heard on the street thatJuan Johnson was someone that was capable of violence? . ·A Yes. Q. What had you heard? ' STENO (312)236-"1414 JR-JJAMERICAN 044704 Page 96 I A. Drive over to Area 5. I was at Area 6 and I drove to Area 5. Q. So you put them in the squad car? 4 A I put iri the squad car. 5 Q. And went with Gawrys? 6 A. Yes. 7 _Q. All three of them . , H A I believe so. I believe they were all 9 three 10 Q. And then you brought thmn to Area 5. And 11 then what did you do after that? 12 · A.· At Area 5 you turri them to the 13 detective. 14 Q. Dojou know what the detective did there? 15 A. Well, he would separate them and start 16" talking to tliem. 11·' Q. Okay. ·.·Did you stick around while he was 18 talking to them? 19 A I don't remember at this point. I might 20 have . 21 :: Q. Okay. It wouldn't be for you to 22 · stick around as the detective spoke with 23 A. Correct. Well, noUn theirnmediate 24 interview with them. That's just the detective and 2 ·3 Page 93 - Page 96 REYNALDO GUEVARA 1 All right. Yo11 wouldn't sit in the · -· interyiew? A. No, not unless he says, You can come in. You know, fine. Q. In this case did you sit in on any interv1ews? A. I don't remember. ..... Q. And you can't tell us what people said, what any of these witnesses said in the witness interviews; right? A. Right. I don't think I was there with them. Q: Okay. So did you ever talk to O'Donnell about what he thought of the three witnesses that you brought to him? A. We might have had.someconversations, but I don't remember. Q. Did O'Donnell ever tell you that he didn't believe that Juan Johnson had caused harm to Ricardo Fernandez? A. No. Q. Did O'Donnell ever indicate to you any reservation about charging Juan Johnson with Q. 2 3 .. Page 99 No. I said I·don't believe "c I didn't ·2:- ·say ldun't believe-·-:- I>saict·-I dori't remeinber . 3 ., Q. Okay. Now, Ortiz is listed as a witness 4 on your report here as well. Can you tell me what 5 you did with Salvador Ortiz on September 10, 1989. 6 A. I think he was brought into Area 5 for a 7 lineup. 8 Q. Who brought him into Area 5? 9 · A It might have been me. I don't remember. 10 · I'm not saying that I -- it might have been me. 11 Q. Your reports don't refresh your memory 01; 12 that? 13 A. Well, he was brought into Area -- he was _ 14 brought i'uto.Area 5. ··· · · him. ·.I 4 5 6 7 8 9 10 II 12 13 14'' 15 16·. 17 18 19 20 21 22 23 24 1 2 3 4 5 6 7 s 9 10 11 12 13 14 15 16 17 18 Q. to-- But in this case you don'tremember going 18 19 0 . 20 21 22 23. 24 I don't remember. A. 22 Q. And you believe you didn't go to their homes, you just .saw brought thein right? Page 100 2 J 4 5 6 7 8 9 10 11 12 13 15 16 17 19 21 on the street and then ·· ·AMERICAN STENO· (312)236-1414 JR-JJ 044705 Witness No.2, that's Salvador Ortiz, and Mendez did not view the photo spread but were brought into Area 5 Violent Crime to view the physicallineup. Q. Can you tell me why didn't you have Ortiz and Mendezview the photos? A. First of all, we had three witnesses that JD'd those guys. SoT don't need any more witnesses to ID _;my more photos. Anything else from that point or is going to be physical, pick i ·• hirn out of the lineup. 20 21 23 17 18 BY MR. GARDINER: 19 24 15 A 16- · Armando Page 98 murder? A No. Q. When -- you said that you would have seen · these three people, Vasquez, Gomez and Michel, on . · the street and then brought them irt; right? A. Right. Q. Had you gone to any of their homes to get them prior to seeing them on the street? A. I don't think so. Q. It would have been unusual for you to go to specific persons' homes to get them in the course of your investigation? MS. EKL: Arc you talking about any investigation?· MR. uh-huh. THE WITNESS: No. I would probably go to their homes. 20 JOHNSON v, GUEVARA CondenseltTM Page 97 22 · 23 · 24 Okay. And why is that? Because all you need is one or two guys to identify somebOdy in the photo. You don't need everybody else:· That's just going to jeopardize the case. Q. WhY would it jeopardize the case? A. Sure it would. Q. Could you explain why it would. A. Well, because we're doing --we're in the position of doing a lineup on that day and bringing in someone to someone. Tp v;iew the sari1e books that were viewed before and then take him into don't work Area 5 to view a lineup, like that. Q. So the concem would be that the pictures would predispose the witnesses to making the same selection in the lineup'? · A. l·believe so. Q. Okay. So, as a result, instead of-these two gentlemen you brought to Area 5 ·directly? A. Brought directly there, yeah. MS. EKL: objection. Assumes facts not in evidence, that he was the one thafdirectly brought Q. A. Page 97 - Page 100 REYNALDO GUEVARA JOHNSON v. GUEVARA CondenseitTM Page· 101 Page I 03 them to Area 5. " . 1 ·2". ·BY MR. GARDINHR: Do you recall bringing them to Area 5? A. I don't-- I might have beenthe one, but I don't recall. I don't remember. Q. Do you have any idea who_ else it could lplVe been, if it wasn't you? A. Oh. It could have been anyone, any police officer. · Q. Were there other police officers· working with you on this investigation other than your partner and the detectives? A. Yes. Q. Do you know who they were? A. No. Right off the bat, no, 1 don't; but there were many. Q. So tell me-- you had three people that had told you that they could identify the · perpetrator that you took to view pictures. What about Ortiz, did he say he could identify the perpetrator or not? . A. I beiieve.he did. He saiO he could identify the guy. I believe they both said they could identify the person and they were brought Q. 3 4 5 6 7 8 9 10 li 12 13 14 15 16 17 18 19 20 21 . 22 23 24 3 4 ·5 6 7 8 9 o 1 11 12 13 14 0 15 16 17 18 19 20 21 . 22 Page 102 1 2 3 4 ·5 6 7 "8 9 10 II 12 13 14 15 16 11' 18 19 20 21· . 22 2.3 24 into 23 24 A. Yes. · Q. ·What's that? The reason is we didn't know who we were going get until we get the photo ID. Q. Okay. I see., And then you would have somebody to put in the lineup? A .Correct. Q. All right. Do you remember any residence where Gomez, McCoy, and Sam Perez were present? A. No. Q. And did you sec Chris McCoy at any time during the course of_your investigation? Right now I dcin 'tevcn know who Chris McCoy is. I don't remember. Q. And your reports don't give you any clue. · as to whether you saw.Chris McCoy; right·? A. A. No. Q. Now, with respect to -- were these the -were Michel, Gomez a11d Vasquez the only three people that you showed photographs to in the course of your investigation? · A. I believe so, yes. Q. And at the time that you showed Page 104 photographs to them,·you· never indicated to them that there were particular people that you wanted them to pick out? A. Definitely not. ·· Q. Arid you never implied to them thaithere were particular people that you wanted to have picked out? 5 to view the physical lineup. 2 Okay. You said "both," meaning Mendez and 3 Ortiz; right? 4 · A. Correct. .· Q. And liow did you-- how did you separate-5 6 why did you say Mendez and Ortiz should go to Area 5 to view a physical lineup and the other 7 three should go to view pictures? 8 A. No. 9 Q. And you never communicated to Samuel Perez A. Because I believe the other two guys were -- they were not all at the same time at 10 that there were particular people that you wanted Area 3 -- at Area 6. I believe the first three 11 picked out? 12 guys were there, the other two guys were not. They A. No. Q. Did you know if Perez-- whether Perez had were found later and brought into Area 5. 13 14 a friendly relationship with Juan Michel? Q. I see. And you just happened to putthem · , . 15 A. No, I did not. in the same report? 16 Q. Did you know if Sam Perez hatl · A. Yeah, 17 relationship or relationship with Edwin Gomez? Q. All right. And you don't recall whether A. I ·believe so. I believe he was friends 18 you picked these people -- any of these people up, 19 with all of them. but at least you transported them from the street? Q. All right. So you believe that Sam Perez 20 A. They were transported into Area 5 and 21 was friends with Juan Michel then? Area 6. Q. So is there a reason that you wouldn't 22 A I believe so, yes . have just brought Michel Gomez and Vasquez to see a 23 . Q, Arid did you believe Sam Perez was friends 24 with Vasquez? physical lineup immediately? Q. AMERICANSTENO (312) 236-1414. JR-JJ 044706 Page 101 -Page 104 REYNALDO GUEVARA CondcnseltTM JOHNSONv. GUEVARA Page i 07 Page 105 Yes. I A: 2 Q. And did you believe ·that Juan -- that 3 . Sam Perez 4 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24 friends with Ortiz? Yes. Q. And did you believe that Sam Perez was friends with Mendez? A Yes. Q. Based upon your experjence as a Gang Crime specialist, you would understand that Sam Perez would have some power over soldiers within his gang; right? A. Yes. Q. And you would believe that Sam Perez would have respect within other Folk gangs; right? A Yes. . Q. And he would be in a position to exert some influence over activities of people within his. gang; right? A. Ibelieve so, yes. Q. And you would believe that he would. have the ability to influence other Folk gang members; right? A. Yes. Q. And that's because of the position he held A : '. .. r Q. Yes. 2. A: I believe r was, yes. ·:r· "",·"Q. All right. And were you involved in bringing in person·s to fill the lineup?_ 5 A. I might have. 6 Q. Okay. Did you bring Juan Johnson to the . ? 7 .1met1p. 8 A. I don't remember if I did or not I could 9 have. 1o . . Q. There's nothing in your reports that would II · indicate that; rig;hi? 12 A. No. No. 13 Q. Arid you don't meeting Juan 14 Johnson at his house; right? 15 A. No, not at his house. 16 · Q. You· don't' remember meeting him and asking 17 him to go to a right? 18 A. No. .. 19 Q. You don't remember Juan Johnson asking you 20 if you were asking or telling him that he had to go 21 . to a lineup; right'? 22 . A No. 4 23 24 Q. That's not something you would have said to him? Page 106 2 3 4 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22. 23 24 within his organization -A. Correct. Q. -- as a section leader; right? A Right . Q. Do you have any idea how many people -well, let me back up. If Sam Perez were to tell Juan Michel to array, do you. believe select s.omeone from a Juan Michel 'would have done so? A. I have no idea. Q. And would that be your answer also as to Gomezand Vasquez? A. That would be my answer as to all of them. Q. And that would be your answer as to · whether Sam Perez would have sufficient influence to cause someone to pick out someone inappropriately on a lineup? A. I have no idea. Q. It would be. fair to say that Sam Perez -well,after the -- after you had picked up these five people and transported them to Area 6 and to Area 5 -- well, were you present for the in-person identification? A. For the lineup? STENO (312) 236-1414. JR-JJAMERICAN 044707 Page 108 A No. 2 ·Q. You don't remember handcuffing Juan Johnson to bring him in? A Really, J'don't remember if I handcuffed 5 him or not; but he· was arrested and he was brought 6 into Area 5. Q. You're j1.1st not sure if you were the .7 8. person that arrested him? .·A. No. I'm not sure if I was the person that 9 10 cuffed him. I believe that I was in the car when II my partner and I transported him to Area 5. 12 Q. While you were driving with Jwin Johnson 13 do you recall telling him that you had got him for 14• "the big one"? 15 A. No. 16 Q: Doyou remember laughing after saying . something to him? 17 18 - A. No. 19. Q; Do you remember saying to him that, "I've 20 got you for first degree murder"? .· 21 A No. 22 Q. Do you remember any con":ersation that you 23 had with Ju;mJohhson that day? 24 A. Once-tw was pl<Jced under arrest, no. 3 4 Page 105 - Page 108 REYNALDO GUEVARA 3 4 5 6 7 8 9 10 11 12 13 14 15 16 ·17 18 19 20 21 22 23 24 - . n 110 GARDINER: Q. ·With Juan Johnson in the car would you have told him what crime he was suspected of committing? A. 1 believe, · Q. But you don't remember specifically what you told him that day? A. No, I don't. Q. Would you have been happy to gain a conviction of Juan Johnson for murder? A. No. .. ·· Q. ·Why not? A. I wouldn't be happy and I wouldn't be sad. It's just a job that I'm doing. So it didn't bother-- it doesn't bother me whether he's found . guilty or innocent. Q. You're just doing·your job? A Just doing my job. Q. Okay. So evenif it's somebody that you had known for a long time, you were doing your job, it wouldn't bother you one way or the other? A. No, it wouldn't. . Q. All right. Did you feel that by -- that if you secured a conviction against Juan Johnson, 1 . BY Mit 2 3 4 5' 6 7 8 9 10 11 12 13 14 15 16 · 17 18 19 20 21 22 · 23 24 JOHNSON v. GUEVARA Page 109 Page 111 1· it would have s·ome impactOn the success of tlie Q. Would your procedure have been to speak with ·arrestee while transportirig a:n arrestee to· · 2 . Spanish Cobras? 3 MS. EKL: objection. Fot:m ofthe a lineup? A. Not really. After he gets after we.get 4 . question. the identification, we look for we put him in 5 THE WITNESS: No. the car -- arrested in the Qar and 6 BY MR .. GARDINER: transportedhim to Area 5. At that point, turn him 7 Q. Why not? · g over to the dicks, let them do the investigation. A. Because I wouldn.'t. Q. You wouldn't do an interview? 9 Q. Because he wasn't that important within 10 the group? Is that why? A. No. Q. And when you have somebody that you've 11 A. Whether he was important or not I have no known sincehe was 13 or 14 years old, though, you . 12 idea; but, no, I wouldn't. I mean, I'm there doing 13 my job. . would have been likely to speak with him to some · 14 -'· Q. didn't know.\Vhat he had ex fei1t; right? 15 within the gang as of September lOth of 1989? A. Not about the incident. ; 16 A. 1 think it was, again, high up: 1 don't · . · Q.· And you you tell him · · what he was suspected-- what crime he was 17 know what rank he had, but he was high up. · suspected of? 18 Q. W ouldit have been unus.ual for an 18- or ·Ms. EKL: Again, are you talking about . 19 19-year-old to be high up in the Spanish Cobras? someone who is 13 or 14 -20 A. No. I've seen them younger. MR. GARDINER: No. 21 Q. So at::· could you tell us, at the lineup MS: EKL:, ·· or are you talking abou.tJuan 22 · did you provide the fillers for ilie lineup? Johnson? 23 MS. EKL: objection. Asked and answered. MR. GARDINER: I'll rephrase it. 24 THE· WHNESS: I don It remember ifl went . 2 Condenselt 1M STENO (312}236-1414 JR-JJAMERICAN 044708 2 3 4 5 6 7 8 9 10 11 12 13 1.4 15 16 17 18 19 20 21 22 23 24 ·, Page 112 out there. I could have been one of the guys that. did g·o out there looking for fillers. I could have been. BY MR. GARDINER: Q. Were you present at the lineup involving' Juan Johnson? A. Yes, I was .. Q. And could you tell us what side of the glass you were on? A. I was on with the witness and with the detective. Q. Okay. And was it just the two ofyou and the witness on the one side of the glass? A. Yes .. Q. And-A. It was him taking him over and I'm standing back. Q. And the room, how big isthe room? A. Maybea little bigger than this. Q. So a room maybe 15 feet long or so'? A. I would say about the same size as this. Q. Okay. Would around 15 feet or 12feet be . right? A. It's about the size of this-, yeah. Page 109 - Page 112 REYNALDO GUEVARA Condenselt no1 Page 113 1 .2 3 4 5 6. .7 8 10 · I1 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 115 · · Q. I just don't know what -- can you approximate the size of this room? A. I would say it's about 15, 20fect, I j . 4 think. Q. Okay. S6 you would be on one side, but 5 you would be standing off to the side? ·. 6 A By the.:door, yes. 7 Q. All right. Would you say anything to the 8 person making the idehtification? · 9 A. No, I would not. 1o Q All right. That would be handled by the · II detective? 12 A. That's correct. 13 Q. Can you tell us what you recall ofthe 14 lineup that Juan Johnson was in. 15 A.. There were -- at that particular lineup I 16 believe there were five or six guys. I don't . 17 remember exactly. Two of them was Juan Johnson and 18 ·his brother and they were all sitting down. The 19 reason why they were all sitting down is because of 20 the height. 21 Q. Because of th€ height? What do you mean? . · 22 A. The height. I think Henry was the 23 tallest. So we're trying to get people 24 Page·II4 approximately the same height, so we had them all · . 2 sitting down. It's hot easy to find fillers the 3 height of Henry. · 4 Q. Okay. 5 A. So we had everybody sitting down -- or at 6 least I didn't -- the detective did. 7 Q. Okay. Did the detective control the other 8 side of the glass ·as well? 9 A. No. There's another detective on the I 0 ·. other side, his partner. II Q. Okay. And he would bring in the people 12· for the lineup, the other detective would? 13. A. I don't understand your question. 14 Q. The partner would handle things on the 15 other side of the glass with the suspects and the 16 fillers? . 17 A. The partner would be standing to the side 18 in -- with the prisoners -- or with the · · . 19 . participants of the lineup. 20 Q. All right. Do you remember the . ·. 21 identification that was made by Ortiz? · 22 A. Right now, at this point, no, 'I don't; , 23 •· but, yeah, I believe he made the of. 24 Henry and the identification of his brother. 1 STENO (312)236-1414 JR-JJAMERICAN 044709 JOHNSON v. GUEVARA 1 2 3 4 5 6 7 8 9 1o II 12 13 14 15 16 17 18 19 20 21 22 23 . 24 Q: Of Juan? A. Yes. Q. Okay. And-- go ahead. A. No. No. That's it. Q. Okay. And how aboutthe identification of -- by Mendez, do you remember that? A. I 'don't remember exactly how the identifications were made, but I believe they identified the guys. Q. And how would it have worked with the -with Ortiz and Mendez, they have viewed the lineup separately? A. Definitely. Q. And was there lag ill betw'een? A. Yeah, there's a time period between them. Q. Would Mendez and Ortiz have been· able to· speak with each other between the two lineups, the two viewings? A. Nb. Q. And how was that assured that that wouldn 't·happcn? A. Once that person -- they are either ·at the beginning, beforethey're they' te all put together in one roorr! .. A'rter. a Page 116 detective comes, gets one of the witnesses, puts him in there, he identifiessomebody, he is taken and put somewhere else .. The ·<retecti:ve.gqeAJw.ck in there, gets. the next witness and the saine thing; back'arid',;; .};i·' forth with everybody. Q. Okay. A. Okay. But after the identification is made, nobody is put together. Everybody is separate. Q. Would Juan Johnson have been interviewed before this lineup or only after the lineup? A. You interviewed the suspect after they get fingered in a lineup.·· Q. Okay. And the othedhree people that had identified Juan Johnson, according toyou, by the -- based on the pictures, did those people stand for and view lineups as well'? A. Yeah, everybody views the lineup. Every witness views the lineup.· Q. So Vasquez viewed the lineup as well · A. Yes. Q, And Michel viewed the lineup as well; correct? Page 113- Page 116 REYNALDO GUEVARA A. 2 3 4 5 6 7. 8 9 10 II 12 13 14 15 16 17 18 19 20 ..+I 22 23 24 Yes; . Q. And Gomez viewed the lineup as well; 2 right? .... A. Yes .. Q. Did all three of those people identify Juan Johnson? A. J do.n!t remember. .. . Q. present for:.the lineups that were viewed by Michel, Gomez and Vasquez? A. I might have been, yes. Q You just don't remember those lineups? A. I don't. Q. Okay. And there's nothing that would ·. refn;:shyour memory as to those lineups; right? A. Well, there were two separate lineups. Okay .. ·· Q. Were there separate people in the lineups? A Oh, yes, there was separate people in the · lineup. There were Hispanics in the one with Cordero and Amer-Blacks in the other. Q. Okay. So the -- buUhe lineup that Juan Johnson was involved in was the satne lineup as -A The same lineup. 3 4 5 6 8 9 10 ii September 9th of 1989? A. Oh, I don'tren1ember. Q. Okay. Did you ever tell Sam Perez tha_t you knew that .a Cobra killed the Eagle? A. Definitely not. Q. Did you ever tell Sam Perez,"What Cobras killed the Eagle, 1 don't care"? A. No. Q. Did you ever tell Sam Perez that you would . prefer that it be "these guys" andpoint to Juan · Johnson and others? A 12 No. ·· Q. On the book that you the picture 13 14 · · book that you showed to the three witnesses, I 5 many pictures would appear on a page? 16 Books. Notjust a book; . ,., : 17 · Q. Yes, you're right. Okay. : 18 A. Books. 19 And, again, there's somewhere between 20 20 and 100 pictures in each of those books, 21 -probably even more. 22 · Q. How many ·would appeaion one page? Books 23 again A. Four. 24 . Q.· Do you remember seeing Ortiz at the Butera Page 118 Page 120 parking lot on September 10, 1989? five of the witnesses? 2 A. No. A. I believe so. 3 Q. Do you remember -- do you remember Q. Okay. Youdon'tknowofanybadblood 4 Salvador Ortiz ever asking, "What are these Blacks -. . . that existed between Pedro Cordero ana Sam Perez; 5 doing in here" in terms of the lineup or any other right? 6 identification? A No, I don't. 7 A No. Q. Do you picking up Henry Johnson? 8 Q. Did he ever question you as to how Blacks A Yeah, I think I did; bu! I don't remember 9 could be involved in the -- involved as potential for sure. I think I did. 10 defendants iri the case? Q. And that would have been with your 11 A No. partner? 12 Q. Do you know· a person nicknamed Saint? A Yeah, 13 A (Shaking head.) Q. You don't recall meeting with any of these 14 Q. You have tosay "yes" or "no." 15;';' '"A: 'Oh. No. I'm sorry. No. witnesses at Kostner and Armitage? 16 · Q. Okay. Is Area 6 _:Area: 6 is at what A No. · Q. You dmi't recall seeing Sam Perez in the 17 location? area of KoStner and Arinitage on September 10, I 989? 18' A Belmont and Western. A. No. 19 Q: And Area 5 is at Grand and Centnil? Q. And·you never transported Samuel Perez to 20 A Correct. any police station on that day? 21 Q. You never told Ortiz where any person A. No. 22 would be standing in the lineup; right? . Q. H.ave you ever transported Samuel Perez 2J .. A That's correct, no. to a police station since that time, since 24 Q. And did you ever tell him at any time that Q. And that was the same lineup viewed by all 2 3. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 STENO (312) 236-1414 JR-JJAMERICAN 044710 ' ' _ ... ·... Page 117 - Page 120 , . REYNALDO GUEVARA Condcnselt TM Page 121 one person 2 . - ·, one suspect used a bat? A.Noo 1 ·2 Q. Did you ever tell :my person at any tinl.C that one person had possessed -- one of the 5 suspects had possessed a board? 6 A. No. .Q... Did any person ever tell you that an .· 7 8 individual named Bolicua got hit with a 9 four-by-four? 10 A. No. Q. Did you: have conversations with Juan .. n 12 Johnson after his arrest? A. No. After he was turned over to the · 13 14 . dicks, no. Q. And in that 1 mean did you ever have any 15 16 . conversations with Juan Johnson from the time of 17 his arrest until today? 18 A. No. 19 Q. And after his cpnviction you never spoke 20 with him at court during the lockup? 21 A. No. 22. Q. You've.never saidto Juan Johnson/'Who is 23 fucking your wife today"? 24 A What? No. 3 3 4 4 Page 122 1 Q. You've never said to him, "How has your 2 day been? My days are going to get a lot better 3 when I see you go down again"? 4 A. No. Q. Do you know if Jose-" or Mr. Negron was a" 5 6 member of the Artesian and Le Moyne section of the 7 Spanish Cobras? . casts his answers A. I know he totally was member; butprevious I don It know 8 9 what, you know, section. 10 Q. Had you ever heard of anyone referring to 11 you as the stepfather of Mr. Negron? 12 . A Yeah. They say -;. they say that there. · 13 But me his stepfather? No. Never. 14 Q. You would never say that'? 15 A. No. I would never say it because it'.s not 16 true. 17 Q. But on the street did people refer to you 18 as the stepfather of Negron? 19 A Most of the guys bullshitting --or, I'm 20 . sorry-- BS'ing would say; but, no. . 21 Q. Would you correct people when they would 22 say you were the stepfather? . 23 A Definitely. 24 Q. Okay. Do you have any idea why people · a STENO (312) 236-1414 JR-JJAMERICAN 044711 s ·6 7 JOHNSON v. GUEVARA Page 123 would say that? A. No. Q. Do you-know where you would have picked up . the five witnesses onthe street from? MS. EKL: objection. Fonrfofthe . THE WITNESS:· No. 8 BY MR. GARDINER:. 9 And I'm sp.ecifically referring to the five persons that viewed the photo books or the lineups. I0 11 12 13 1'4 . IS Q. A. No. Have you ever caused charges· to be placed against a whO did not co:rnlnit the crime charged of? Q. },6 17 Q. Have YO\J. ever heard the term "hooking up"? 18 A. Yeah. 19 20 Q. Okay. And what does hooking up mean to you? A. To me, hooking up is ·when you hook somebody up to something, either to --either/or, 23 to a wall, hook them up to a crime, or whatever. 24 Q. Okay, So_ with respect to hooking up for a .. 21 22· .Page 124 cfline, least in the street people talk about 2 hooking up as being when places· a 3 another person that was not true; is that right? 4 A That's correct s Q. OkaY: You've never hooked up any 6 defendant; right? 7 A. No. about Negron in heard doubton the stn::et that people 8 Q. You have 9 believe that you hook up defendants? 10 A. Oh, I'm sure they say it allthe time. 11 Q. Well, you've heard that on the street J2 though, haven't you? 13 A. Yeah. 14·, Q. They've-- that your reputation-- would· .1.5 you agree your reputation is that as someone that 16 . has hooked up people? 17 MS. EKL: objection. Fonn of the 18 question. 19 THE WITNESS: That's what they're saying. 1. 20 BY MR. GARDINER: 21 Q. You've heard that from multiple gang members; right? A A few. Q. What gang members have, you heard. that 22 23 24 on Page 121 -Page 124 REYNALDO GUEVARA CondenseltTh1 JOHNSON v. GUEVARA Page 125 from? A I have no idea. 3 Q. That wouldn't stick in your mind?. 4 A No. 5 Q. Were you involved in a case called People 6 versus David Colon? .7 A. I (}on '.t.remember. 8 Q. Do you !ecall a case in which there were 9 witnesses named Efrain Sanchez and Julio Sanchez? 10 A No: II Q. Do you know a person named Efrain Sanchez? 12 A No. 13 Q. Doyou know of a person named Julio 14 Sanchez? · 15 A No. 16 .. Q. Were.you involved in. the murder 17 investigation of David Colon? 18 A. I don't even know who David Colon is. 19 Q. So your answer is that you were not 20 involved in that investigation? . 21 MS. EKL: objection . .Form of the 22 · question; 23 THE WITNESS: That, I don't remember. Page 127 A No. -1 2 24 Page 126 BY MR. GARDINER: 2 3 4 5 6 7 8 9 10 II 12 13 . 14 15 16 17 18 19 20 21 22 23 24 Q. Do you know a person named Canalee (phonetic) Saez, S-a-e-z? A. No. Q. ·Were you involved in the case or investigation involving Robert Almodovar, A-1-m-o-d-o-v-a-r? A. l rernember the case, yes. Q. All right. What can you tell us about the case? A. It was a double murder. Q. And you were an investigator on the case? ·· A Yes, I was. Q. Okay. Did you.conou.ct the lineup in that case? A I believe I did, yes. Q. ·oid you show pictures to Canalee Saez in that case? A I don't remember the name. I might have showed pictures to the witnesses. Q. Okay, And did you tell any witness in that case that "these people" -- pointing to particular people were the guys that did . shooting? STENO (312) 236-1414 JR-JJAMERICAN 044712 2 · . Q. Did you tell any witness in that case that 3 he should not mention that you showed him pictures 4 . beforehand? 5 6 A No. . Q. In connection with the investigation of 7 · the Almodovar case, did you show·pictures to any · persons outside of the Police Department -- excuse me -- police station? 10 A Yes. II Q. And what type of pictures did you show to 12 people? 13 A I believe there were IR photos. 14 Q: Were they photos in the Guevara books or 15 were they the -16 · · A. No. They were individual photos, IR 17 photos. 18 MS. EKL: And just for the record I'm 19 . going to object to -- have a continuing objection 20 to the reference to "Guevara books," the term 21 · itself. 8 9 22 BY MR. GARDINER: 23 Q. They were IR --particular IR photos? 24 A I believe so. Pag·e 128 So would you have had separate pictures 2 ·.with you in that investigation·? . 3 A I probably did, yes. 4 Q. Okay. So in that case at least you did 5 things differently than you did in· the Juan Johnson· .. 6 investigation; right? 7 A Yes. . . . 8 Q. Okay. Sq,t;tietimes you will.show -- in the course of yout·duties as a police officer you would 10 have-pictures with you that you would show to 11 people on the street? ··12 A On the street I would show pictures to 13 nobody. 14 Q. Okay . 15 A. On that partkular case I showed a picture I 6 to one of the victims, surviving victims, at her 17 house. 18 Q. Okay. So you Would not do it out in the 19 street, but you might do it in a house or in some 20 confined area? 21 A At the house, yeah, I would probably do 22 it. Yeah. 23 . Q. Did you -- were you involved in the 24 investigation relating to Thomas Sierra who Q. Page 125 -Page REYNALDO GUEVARA Condenselt Page 129 1 ultimately became a defendant? '1 ·A. Don't recall the same.· 2 3 3 .... Q.Do you recall speaking with Jose Melendez 4 4 relating to an identification made in a murder 5 5 investigation? ·6 ··A. No, I don't recall. § . 7 Q. Is there anything that would refresh your 7 memory as to your conversation with Jose Mendez? 8 8 MS. EKL: ·objection, assumes that there 9 9 10 10 was a conversation. TIIE WitNESS:- No. II II 12 !2 BY MR. GARDINER: 13 Q. And you don't recall showing a photo array 13 14 14 to Jose Melendez or to anyone in connection with 15 15 the case of People versus Thomas Sierra? ,'-". 16 16 A. No. I don't recall the case, period. 17 Q. Do you know. a person named Maria Rivera? 17 18 A. I know a lot of Marias. 18 19 Q. How about one named Maria Rivera? 19 A. I know a lot of Marias, Riveras; but I 20 20 21 don't know who you are referring to. 21 22 22 ·- Q. Do you know a Maria Rivera that lives at 23 23 1535 North Rockwell or lived at that address? 24 A. I don't remember if I do kno.w anybody that 24 1 Page 130 · lived there. I don't recall. Q. Do you remember a case of People versus 3 Gabriel Solachc? 4 A. Yes. 5 Q. Were you police officer assigned to that 6 case? 7 A It was my case. . .. . Q. All right. And that was a -- was it a 8 9 murder case? A. That was a kidnapping, double murder. 10 II Q. Okay. And were you the detective assigned 12 · to that case? 13 A. Yes, I was. 14 Q. And ·during the-course ofyour duties in 15 ·that case did you speak with a Maria Rivera? 16 · ·A Again, I don't remember names. 17 Q. Do you reme1nbet a lineup that was 18 conducted in connection with that case? 19 A. There were several lineups. 20 · Q. Do you-remember some witnesses viewing 21 multiple lineups? 22 A. Yes. 23 . -·Q. Did tell ·any witness in the case to 24 point out a specific individual in a lineup in the 2 3 4 a STENO (312) 236-1414 JR-JJAMERICAN 044713 Page 131 course·of your investigation? · A. No, i did not. · . , .. Q. Did you tell any witness in the Solache case to identify a person as someone who did the shooting? A. First of all, tha:t wasn't a shooting, it was a stabbing . Q. Okay. A. So, DO; The answer is no. · Q. Okay. I'll ask you again then. In the course of your investigation in that case did you tell anyone to identify the person -- a particular person as the who . committed the stabbing? A. No. Q. Did you 'talk to tlie assistant state's attorney in. that case? A. Numerous times. Q. During the course of your conversations with the state's attorney, did he ever tell you that a witness had stated that she identified an individual in a lineup at your direction? A. No. Q. What happened with the case of People Page 132 I 2 JOHNSON v. GUEVARA 5 6 7 8 9. I0 11 12 13 . 14 15 16 17 18 .. 19 20 21 . 23 24 versus Gabriel Solache? A. were three offenders.· One got the -- I believe gotthe death penalty, which it got reversed c- that's the female, ifl' xp. noh mistaken -- and. the two males;: were also found guilty. Q. Was there a person that -- against whom charges were dropped in that A. No, not that I -- oh,no, Definitely no. Q. Are you familiar with a case called People versus Goya or something like that? A. No. Q. G-o-y-a? A. I don't recall the name. Q. Do you know -- were you involved in the in_vestigation relating to the charges brought against Concepcion and Freddie Santiago? A. No, 1 don It remember the case either. Q. Do you remember speaking with a witness named Robert Ruiz in connection with any · investigation of yours? A. J don't recall the name. Q. And the Robert Ruiz I have has an address of 1867 Northwest 35th Street, Apartment 3, Miami, Page 129 -Page 132 ·t 2 3 4 5 6 7 8 9 10 Page 133 Page 135 1 · Bellwood, Illinois: Does that jog your-memory in Florida. Does that jog your memory? 2 'any way? A. No. · 3. A No. Q. Were you involved in the murder investigation relating to Daniel Rodriguez? 4 Q. ·Have you ever iold·any witness that the A. No, not on that case. 5 witness would have trouble next time you saw him if Q. So you.didn't work the case in which 6 he. did not make an identification of a person at a 7 lineup? ··· · ·· charges were.eventually brought against Daniel· 8 A. No. Rodriguez? 9 Q. Are you familiar with a person named A. No. Leshurn Hunt? Q. So you didn't-- did you know a witness 10 ·.·· ' L-e-s-h-u-r-n .. ' named David Velazquez? 11 .A Leshum Hunt, yes,.! do: A I don't know. I don't remember that 12 Q. How are you familiar with him? A I arrested him. ..· 13 name. Q. And ·in connection with murder case -14 Q. And during the time that he in your 15 custody did you give him little food or water and well, in the course of your career have you ever . 16 deprive him of sleep? threatened to pin :i murder on a person who did not A. The case is along time ago. I don't 17 commit the murder? 18 remember the case; but, no, the answer is no. I A No. 19 don't remember denying anybody food and water. Q. Did you ever threaten· to pin a murder 20 Q: Have you in your career ev'er slapped a person unless they falsely identified someone in a . 21 witness in the face? · murder case? . 22 A. No; A No . 23 Q. In the course of your career ha:ve you ever Q. Do you remember a claim by any person that you chained him to a wall in Area 5 and forced him 24 · the hair of a witness? ·.··· .. ,,.·. . ... . c- II 12 13 14 15 16 17 18 19 20 21 22 23 24 JOHNSONv. GUEVARA CondenseltTM REYNALDO GUEVARA 0 ., '•",• ·a wis Page 134 1 2 3 to sign a false statement? A. No.·· Q. Are .you familiar with Luis Figueroa? Don't recall the name. Q. Okay. Were you involved in the ca'seof . I0 People versus Angel Diaz? MS. EKL: I'm s9rry. Could you say again. MR. GARDINER: A·n-g-e-1, Diaz'. TilE WITNESS: I don't think so. II BY MR. GARDINER: 12 Q. Do you know 8 9 aperson -- a w·ithess named . 15 Luis Figueroa? Ms:·EKL: objection. Asked and answered .. MR. GARDINER: I'm sorry. 16 BY MR. GARDINER: 17 Q. Did you ever tell any person that they should identify a person named Angel Diai as a defendanLwhen he was not the appropriate person? A. No. Q: Are you familiar with Virgilio Calderon Muniz? A. The name doesn't ring a bell. Q. This person lived on Morris Street in 13 14 18 19 20 21 22 . 23 24 A. Q. Are you familiar with a Daniel Pena? 3 A .. I heard the name. -·· ,. > Q. Do you remember an investigation of a 5 ·Daniel Pena. that led to.charges against him? 6 A. I heard -- like I said, I heard the name. 7 I don't recall the case. 8 Q. During the course of your career have you 9 ever struck anyone in the face, ribs anq legs in 10 the course of your interrogation of them? 11 A.No. 12 Q. Are you familiarwithMelvinWarren? 13 A. No. ·14 Q. Do you recall an investigation that was 15 sustained against you by the Office of Professional 16 Standards relating.to Melvin Warrcil? 17 · A. I don't remember. 18 Q. Do you recall having sustained 19 investigation againstyou in which the claim was 20 that you had struck a, person with your fist, choked 21 him and verbally abused him?. n, A. I don't remember. 23 Q. Do you recallever having a suspension-or 24 other discipline imposed upon you by the Chicago 4 A 5 7 No. 1 2 ' 4 6 13p .. STEN();" (312) 236-1414 JR-JJAMERICAN 044714 a P:age l33 13t REYNALDO GUEVARA CondenseIt TM Page 137- 1 2 3 4 .5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I 2 3 4 5 6 7 8 .9 10 11 12 13 14 15 16 17 18 19 . 20 21 -. 22 .... .23 24 Police Department during your career? A. Yes.· Q. What discipline do you recall receiving? A. I received a suspended for -- supposed to be 30 days that got cut down to 10 days. Q. Wl).at was that for? A. That was for a bar thing." Q. Off-duty bar thing? A. Off-duty. Yeah: Q. Okay. And was that involving a woman? A:·oh. No. No. No.· No. Q. All right. So tell me about the off-duty bar thirig· first. . · A.. This was just a bar thing. Q. Okay. Can you tell me what happened?· A. That was done -- I believe it was Captain Bazerick (phonetic) who put the complaint against me because I failed to go into the statiori and make a report fill an. arrest for the guy -- for a person who was arrested. Q. You made an arrest in a bar when you were · off duty? A. Yeah. Q. Okay. And you didn't put in the report? Page 139 Have you had other discipline? A. Not to the best of my knowledge, no. Not 3 that I can remember. 4 Q. Do you recall a person named Raphael 5 Garcia? 6 A. No. 7 - · Q. Do you recall that there was an OPS 8 investigation opened on you in which the claim was 9 that you threw a person against a car, struck him 10 in the face several times, kicked him in the head 11 and hit him. in head? 12 A. No. No. 13 Q. Arid you don It recall a' daiin made like 14 that about your conduct when you were offduty? 15 A. No, I don't. 16 · ' Q. You don't recall receiving a two-day 17 suspension in connection with a claim rr!(.!.de as I had 18 just . . . 19 A. No. The only suspension I had was the 20 · < 1 0-day suspension. 21 Q. Do you remember arresting a person named 22 David Rivera? 23 A. At this tim.e {don't remember. 24 Q. Have you ever told a witness to say what · Q. ·· 2 '• Page 138 A. No, because he was arrested for disorderly conduct. There is no report needed 'for that. Q.,Okay.. was the violation then? A It was that T refused an order from a captain.· Q. And what was the order? A. The order was that he wanted me to go into the stati()n and sign the complaint, and I told him, You can do that, I don't need to go there to sign the complaint. And that was it. · Q. Had you -- wer'e you involved in fighting this person or not? A. No, l was not. Q. Can you tell us the circumstance that caused you to arrest this person? A. I was at the bar and the guy walked up to· · me and offered me some· dope -- to sell me some dope not knowing that I was a policeman. . So I identified myself as a police officer. The owner . of the bar he1trd the conversation, he comes out and he punches the guy, the guy takes off running. Q. Okay . A. And that was it. STENQ. (312) 236-1414 JR-JJAMERICAN 044715 JOHNSONv. GUEVARA Page 140 you wanted -- to say what you were telling him or 2 that he would spend titne in jail'? 3 A. No. 4 Q. Dm"),ou paJ1ner with Detective Ernie 5 Halverson at somepoint? 6 A. Yes. 7 Q. Whatye(lrs were;y,ou with him? 8 . He was my partner at the Solache case and . 9 we were partners for about 1Oyears or a little 10 more than 10 years. 11 Q. So in the '90s mostly? 12 A. Yeah. 13 Q. Do you know a person named Armando 14 ·.··Serrano? 15 ·A. I know a lot of Serranos, Armandos. 16" · Q. Did you ever strike a person in the face 17 with an open hano during the course of an 18 interview? 19 A. No. 20 Q. Do you know a Neida Serrano, N-e+d-a? 21 A: I can't say I do.· I don't recalL 22 c Q. Were you ever present when Detective 23 Halverson struck a.witness or_ a suspect? 24 A. Not to my knowledge. Page.13 7 - Page 14( REYNALDO GUEVARA. 1 2' J 4 5 6 7 8 .9 10 II 12 13 14 15 16 17 18 1.9 20 21 22 23 24 Condenseit TM JOHNSON v. GUEVARA Page 141 Page 143 you familiar with an. Adolfo Frias? I and leaving them f{)r several hours? A At this point I don't remember if I recall · 2 MS. EKL: C)bjection. Foundation. Vague. 3 c.THE WITNESS: I don'tremember ever the name or not. Q. Do you remember ever telling any person 4 handcuffing anybody to the wall and leaving them, that if the person would sign a confession 5 unless it was for his safety. admitting to the crime, his wife and children would 6 BY MR. GARDINER: . be released from custody? Q. And what recall of >this Dembski? ·· 7 A No. 8 A I believe that's the case -- I believe he Q. Do you remember anycase in which a· 9 was involved.in a homicide on Milwaukee and witness or suspect requested to call the Mexican 10 Belmont. Consulate? II . Q. Do you rec.all if that person speak 12 English? A. Q. Do you know a person named. Eliczer, 13 A I believe he could. I believe· he did E+i-c-z-czr, Cruzado, 14 · spoke a little bit of English. I don't remember A. 1 don't recall the name. 15 correctly, but I believe he did. Q. Have you ever told a witness that he would 16 Q. Do you recall that Dembski was presented 17 with an English statement that he had -- that he spend the rest of his life in jail unless he did what he was told? 18 was caused to 19 A. I don't remember. A No. Q. Are you familiar with a Santos Flores? 20 Q. Do you know a Rosauro, R -o-s-a-u-r-o, A Again, I remember a Flores, a case back in 21 Mejia? 22 1984; but I don't know if that's the one. you're A Don't remember the name. tiilking about. 23 Q. This is a person that he Q. 1 have an arrest in December of 1995. 24 was beaten by you during questioning. Q,. Are Page 142 I 2 3 4 A Ms'. EKL: 9 10 11 ::. 12 13 14 ·Y is 16 17 .· ::: 18 19 20 21 22 23 24 objection; . Form of the question. THE WITNESS: 7 8 1 Q: Have you ever restriCted the ability of a · being suspect to make a phone call while he '· ,.. held at the station? s: 6' No. .BY Mit GARDINER: Definitely not " Q. Do you know a witnessnamed Gloria Ortiz? Do you recall that? And you did not strike -- you have never 4 struck a suspect or a witness; right'l 2 Q. No. 5 A. 6 Q. Are you familiar with Adriimna Mejia and 7 8 9 10 Q. Do you recall any cases in which the courts have said that you or your partner violated Miranda? A No. ··· Q. Are you familiar with a Voytek, V-o-y+e-k,Dcmbski, D-e-m-b-s-k-i? A I vaguely remember a case like that. Q. I)o you recall putting a person in a Jacked interrogation room; handcuffing .them to the wall i6 STENO· (3'i:i)2T6'-l414 JR-JJAMERICAN 044716 No. 3 Don't recall the name. Q. Did you ever tell a witness that if she did not make a statement implicating someone that she would be arrested and her children would be taken her? ·· ·A No. A ·A. 11 12 13 14 15 17 18 i9 ·. 20 21 22 23 24 Arturo Reyes, codefendants in the Solache case? A Yes . Q. Could you tell me about the Soiache case. A. lt was a kidnapping of-- it was all over the TV-- a kidnapping of like a 2-, 3-year"old and a 6-month ·or 5-n1onthbaby. Tl:t.q¥ . ' , ... k1Hedthe parents on Leavitt. I think it was 24 or 2500 North on Leavitt in the basement. the lady and the two friends walked into a basement apartment and killed mamma -- stabbed daddy·75 times and stabbed mommy I· don't .know how many tiJl1es -- many, many times·-c and took two babies. Q. So they kidnapped the babies and then what happened in the case? A They took the kids .. And the lady, Mejia, the defendant, her husband saw the kidnapping kid on television and put tWO and two together, the ' Page 141- Page 144 Condcnsclt TM REYNALDO GUEVARA Page 145 family, and that was the baby that he had in his· 2 . 2 house. 3 Q. Okay.· 3 4 A. So they called us and we went to the 4 5 9th District -- the 8th District to pick up the 5 6 baby -- the kid. 6 Q. And what role did you have in that case? 7 7 . A. It was my case from the beginning. 8 8 9' Q. So were you the detecti'veoi1 the case? . 9 10 A. Correct. 10 II. Q. And who did you work that case with? 11 12 A. Ernie Halverson. 12 13 Q. What was the ultimate result with that 13 14 14 case? 15 A. I believe I said that she was sentenced to 15 16 16 death. 17 17 Q. Oh, 18 A. And the other two guy-s sente11ced , 18 19 to -- a long period of time. 19 20 Q. Okay. 20. 21 You received no discipline in connection 21 22 with the Juan Johnson case? 22 23 A No. 23 24 Q. In this case you are aware that Samuel 24 •1 - Page 146 Perez came forward at some point and recanted; right? A. I don't remember. I don't recall anything, 1 didn't know anything about that after the case was -- one of them was sentenced, the other one asked for the retrial. That was him again. And his brother copi_Jed a plea and di4 some d1,1ys and then he went to trial. . That's all I can tell you about that case. l don't remember any of the witnesses recanting anything or saying anything back. I don't recall ..· . 2 3 4 5 6 7 8 9 10 II 12 JOHNSON v. GUEVARA Page 147 Juan Johnson one of them, in this MS. EKL: objection. First of all, it assumes facts not in evidence. There's no evidence that Samuel Perez ever picked ouUuan Johnson or anyone else. MR. GARDINER: Well, I'll rephrase it then if I phrased it wrongiy. BY MR. GARDINER: Q. Can you give us any reason why you believe Sam Perez would have testified that you told him Johnson to be responsible for thatyo:u wanted the murder of Fernandez? A. No, because i never talked to hip1 about that. . . Q. Can you think of any reason why Samuel Pe.rez would testify that way? A No. Q. Salvador Ortiz in connection with this case·has testified thatyou had showed him photographs and that you had told him that you wanted particular people picked out. Do you have _any can you t_(!ll us any reason why you believe Salvador Ortiz would give that testimony? Page 148 . Q. So you weren't -- after your involvement in September of 1989, you didn't have further 15 involvement_})ther than your testimony? 16 A The testimony. 17 Q. And you have a general knowledge that · 18 there was a retrial, ct cetera; right? 19 A. I have a knowledge Of the retrial, 20 Q. Okay .. Let me ask you this: As a person 21 that was in Gang Crimes arid has dealt with gangs 22 throughout his professional career, do you have an 23 opinion.pn why Samuel Perez would testify that you 24 had told him to piqk out particular defendants, A. No. 2 3 4 5 6 7 8 9 10 I I" 12 13 13 14 14 . ',,,,,.AmtncAN STENO (312) 236-1414. JR-JJ 044717 15 16 17 18 19 20 21 22 Q. What is -- do you have a beli(:f as to whether Juan Johnson is innocent of the murder of Fernandez? A. No, I dori 't. Q. Now, there are various community groups that have -- seem to focus on some of your actions as a police officer; is that fair to say? MS. EKL: objection. Form of the question. THE WITNESS: I've heard of it. BY MR. GARDINER: Q. Yeah. And can you tell me why you believe soine of these coinrtnfnity groups have focused· on your actions as a police officer? A. No,' I cannot. (Door knock interruption.) MR. GARDINER: EXcuse me. (Whereupon, recess was taken.) (Whereupon, a discussion was had off thc __rec<)rd.) a 23 24 Page 145 -Page 1 CondenseltTh JOHNSON v. GUEVARA Page 149 Page 151 {Whereupon, Mr. Daniel J, Stohr · i Breckenridge or BOo? · joined the deposition 2 A. No. via telephone.) 3 Q. Do you know Essovato (phonetic)? BY MR. GARDINER: 4 A.The name.doesn't ring a bell, no. Q. Sir, you can't remember any conversation 5 Q. How about Ramone Crespo (phonetic), do you · that you've had with Sergeant 0' Donnell in 6 know that person? · connection with this case; right? 7 . A. That name doesn'tringa.bell either.. A No. 8 Q. How about a woman named Morales? Do you Q: You have no opinion· as to whether Henry 9 ren1etnber MarisolMbrales? Johnson committed the murder in this case, do you? 10 A No. A I have not. 11 Q. So you weren It present for any interviews Q. You have no opinion as to whether Hector 12 of any witness; right? Franco was involved in the rriurder ofFemandez in 13 A. Not thatl can remember, no.· 14 this case either, do you? Q. Do you remember speaking or observing A No. 15 Assistant State's Attorney Bailey in connection 16 with this case? ,.. ·· Q. You have no opinion as 'to whether Pedio Cordero was involved in the murder in this case? 17 A Like I said, I spoke with state's . .A. No." 18 attorneys. Bow many, I don't know . Q. Do you know a person named Rita Hawkins? 19 ·. Q. How about at the time of the 20 investigation, d.id you speak with any Felony Review A Don't recall. Q. Or Renee Hawkins? 21 assistant state's attorney? A No.·· 22 · MS. EKL: And just so the record is clear, . Q. Rita.Beil? Do you know a Rita Bell? 23 you're talking about this investigation regarding 24 Juan Johnson; correct? A. No. REYNALDO GUEVARA c 1 2 3 4 5 6 7 8 .9 10 11 12 13 14 15 . 16 17 18 19 20 21 22 23 24 Page 150 1 2 •', -.. J,....;:-.- 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q. Did you ever at the Medical Examiner's Report in this case'? A Nq. Q. You pon' t recall anything -- you don't .. recall being present during any interview ofJuan Johnson in this case? A. I don't remember. Q. And there's nothing that would refresh _ your memorx as to what he .said during his interview; right? MS. EKL: objection. Assumes facts not in evidence that this witness was present. TilE WITNESS: No. BY MR. Q. Was a four-by-four ultimately recovered in · this case? A. I believe so. Q. But you weren't involved in anything involving the four-by-four?. A No. Q. Was it recovered before or after your involvement in the case? A. After, I believe. Q. Do you know a person named James STENO. (312) 236-1414 JR-JJAMERICAN 044718 Page 1.52 1 2 3 4 5' 6 7 8 9 1D 11 12 13 14 15 · 16 17 18 19 20 21 22 23 24 MR. GARDINER: Yes. MS. EKL: okay. THE WITNESS: I don't understand the question. BY MR. GARDINER: Q. Okay. During the-say in September of 1989, do you recall speaking with an assistant's state's attorney relating to this case'? A. Where? .. , .,., , Q. Anywhere. A. Felony Review? No, I didn't speak with Felony Review. Q. All right. And you weren't present when Felony Review was conducting any invf;:stigation in this· case? A. No. Q. So during your 30-something years as a police officer you·have been disciplined one time? That I can rec.all, yes. MR. GARDINER: I'm going to take a break and call Mr. Stohr and I think I'm going Jo conclude with a few more and we'll be dove. Okay? MS.EKL: Okay. Page 149 - Page 152 REYNALDO GUEVARA Condcnsclt.rM Page 153 (Whereupon, a recess was taken.) 1 -2 Page 155 Q. What other. lawsuits have you been involved 3 .I3Y MR. GARDINER: Q. Sir, I have a question about your defense in this case. Arc there people that you think · 6 . would have knowledge that would assist in your · 7 defense of this case? 8 A Well, I was not the only officer. There 9 wa:s a whoie·bunch ofofficers; Sure. 10 Q. And so it would be the other officers that 11 you think would assist you in the defense of the 12 case? 13 A. I believe you bring the witnesses in, 14 they'll probably--- you know, I don't know the way 15 they're going to react. That, I cannot answer or · 16 . give you an :answer on tliat. 17 Q. Okay. But in terms of those that you . _ 18 think would support you, It' would be the police 19 officers? 20 A. It would be the police officers and 2.1 probably some other -- some of the witnesses. I 22 mean, I can 'ltell YO\l. 23 Q.· Have you spoken with any people.in 24 connection with your defense of this case other 2 in? 3 Leshurn Hunt and Rodney Hunt. Q. Okay. That's another civil lawsuit? A. That's a civil lawsuit, yes. Q: What is the current status of that suit? A. Oh, this is a long time agb. Q. Okay. A In fact, the cor[JOration counsel i's a judge today. · Q. Okay. A. It's McCarthy. Q. Okay. James McCarthy? A. I think that's his name. 1 think that's his name. l think so. . Q. And are other you've been a defendantin? A. No. Q: You've been involved ina divorce though? A I was, yes. Divorce, yes. Q. How many divorces.have you been involved in? A. One. Q. And who did you divorce? 4 4 5 5 A. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 154 2 3 4 5 6 7 8 9 10 II 12 13 - 14 15 16 17 .. - 18 19 20 JOHNSON v. GUEVARA Page 156 than your counsel? A My wife, my first wife. A No. 2 Q. What was her name? Q. So you haven't talked to potential 3 A Gloria. witnesses? 4 MS. EKL I'm going tci object at this ·A !haven't talked to anybody, period, ·5 · point in time because I know that you· got except my attorney. 6 permission from the Court to expand into some Q. Okay: You wouldn't consider Samuelfl.erez 7 . questions x:egarding his family members; however, to be an enemy of yours, would you? 8 status of a divorce is not what you represented to A No. 9 the Court, that that .is in any way related to this Q. And you wouldn't consider Juan Johnson to 10 lawsuit. have been an enemy of yours on the street; right? II And if you believe there is some valid A. No. 12 basis you want tci discuss with me offthe record, Q. Do you believe that gangs were afraid of 13 we can talk about it and perhaps make it part of a you when you were working Gang Criri1esbaGk·in '89? 14 protective order -c I' don't want to have to come A I couldn't answer that either. 15 back-- but if you're just fishing into a general Q. Have you ever told othe'rpeople that the 16 · area of circumstances of his divorce, ·I would gangs were afraid of you? i 7 object and ask hirri not to answer those questions. 18 ... A. No. MR. GARDINER: Okay. Q. Have you· ever told any people that you 19 MR. STOHR: These are public records. could put cases on people? 20 MR. GARDINER: Well, a divorce would be a A. No. 21 public record. Q. Have you been involved in any other 22 MS. EKL: That's fine. He's already told lawsuits? .. 23 · you that he's divorced; but going into further. 24 ·questions about his family members, I would object A 0 21 22 23 24 STENO (312) 236-1414 JR-JJAMERICAN 044719 Page 153 -Page 156 Condensdt n.r REYNALDO GUEVARA 1 2 3 4 5 6 7 8 9 1o II 12 13 14 15 16 Page 157 to that at this time. MR. STOHR: He hasn'ts:tated when was,· divorced. MS. EKL: It's not relevantto this lawsuit. Questions regarding his family is part of some of the-matters that we've discussed that are protected. Counsel, at the time that we discussed · this in front of the Court you ·said that you had a theory of the case regarding why Guevara would want to put cases on Juan Johnson, and unless there's some representation made that this somehow goes to that theoiy and it's rt:levant tothc case, then I . may revisit my position; but at this time going into questions about his family or his ex-family I object to. · - · . · 17 BY MR. GARDINER: 18 All right. with now. 19 20 21 .. ·, 22 23 24 MS. EKL: I Page 159 unjustified verbal or physical altercations while ·2 _ on or off duty? · " ·3 A. I believe so, yes. 4 . Q. And were you aware of a rule that 5 prohibited you from making a false report written 6 or oral? 7 A. Yes. 8 Q. Were you aware of a rule that required 9 police Officers to ptofuptly report· anfinformation 10 concerning any crime or other unlawful action? 11 A. Yes. 12 Q. Were you aware of a rule that subjected a 13 police a"fficer to discipline for the fail me to 14 report to the Department violation of and 15 ._ or any other improper conduct which is 16 contrary to the policies, orders or directives of 17 the department? you tell us who you live 18 would object to that as welL 20 Q. )OHNSONv. GUEVARA A. Yes. . ·- Q. Other than the polic;e officers contained in the reports and the individuals that were named 21 .. in your report that we discussed today, are there 22 any other witnesses .that you are ·. 23 connection with the case involving Juan Johnson? A. No. 19 BYMR. GARDINER: Okay. _You filed a Yes. Q. When did you file the Q. as well?. · A. ·,·,·,._ .. Page 158 Page 160 I A.. I don't remember. It's been a while. 2 Q. 2 3 A. 3 4 5 6 7 Why did you file the bankruptcy? I was in debt. .. ' Q. Is there a reason thatyou were in debt? A. Oh, too many bills. Q. Okay. You don't dislike Juan Johnson? A. 19 20 2I 22 23 24 5 Yes. Q. Andwere you aware of a Chicago Police Departm(!nt rule that expressly prohibited disrespect or maltreatment of any person by a sworn member while on or off duty? . A Yes. · . Q. Were you aware that there was a rule that prohibited sworn members frorrt engaging in JR-JJAMERICANSTENO 044720 have no further questions. MS. EKL: ·We'll reserve signature. .::. . FURTHER DIWONENT SAITH NAUGHT .. 6 7. 8 Q. A. 18 4 N.o. Did you ever tell any person you wanted to 9 get Juan Johnson? 10 A. No. 11 Q. I have no further -- oh. Wait. Sorry. 12 Are ')lou familiar withthe Chicago Police 13 Department rules that pertained to you when you 1"4 were a police requ_iriog you to obeyall . 15 laws ·a1id maintain a courteous and respectful· 16 attitude when dealing withal! persons? 8 MR. GARDINER: I 9 10 11 12 13 ··-. 14 15 16 11 18 19 20 21 22 23 24 Page 157- Page 16C Condenselt TM REYNALDO GUEVARA JOHNSON V. dUEV ARA Page 163 Page 161 IN TI-!E UNITED STATES DISTRICT COURT NORTI-!ERKDISTRICT OF ILLINOIS EASTERN DIVISION 3 12 Illinois, appeared as attorney for the plaintiff; that MS. ELIZABETH A. EKL ef the firm of · JAMES G. SOTOS & ASSOCIATES, 550 East Devon, Suite 150, Itasca, Illineis, appeared as attorney for the defendants. I further certify that l am not a relative or employee or attorney or counselof any·of the parties, or a relative or employee of such attorney or counsel, or financially interested directly or indirectly in this action. In witness whereof, 1 have set my hand and affixed my seal of office, at Chicago, changes or corrections, if any, made on the. Errata 13 Illinois, this Sheet(>) attached hereto. 14 ) ) ) ) ) No: 05 C 1042 ) ) ) ) ) JUAN JOHNSON 4 Plaintiff, vs. 6 REYNALDO GUEVARA and the CITY OF CHICAGO, Defendant$. 9 . . -2 3 4 5 6 .7 8 This is to certify that I have read the I0 transcript of my deposition taken on the 9th day of II March 2007 in the foregoin!,\ cause, and that the I2 foregoing transcript accurately states the 13 questions i.lSked and •mswers given by me, with the 14 15 '9 10 11 16 15 17 16 18 !9 20 17 . REYNALDO GUEVARA. 18 Subscribed ana sworn to befiire ine this _ _ day of · · 2007. 1 ; 1/i,\ /-" 2007 . l. ·- ( --eynthia A. Sinkevicz, C.S.R: License No. 084-003518 19 20 21 22 ':Vii· day of 21 Notary Public 23 22 24. 23 24 1 2 STATE OF IL. LINOIS) ) COUNTY OF COOK .. Page 162 SS: ) 3 4 · 5. 6 7 I, Cynthia A. Sinkevicz, Certified Shorthand Reporter and Notary Pub he it1 and for the County of Cook and State of Illinois, do hereby certify that REYNALDO GUEVARA was first duly sworn 8 to testify the whole truth, and that the above .·deposition was recorded stenographically by me and 10 was reduced,to computerized tninscriptunder my 9 13 personal direction. I further certify that the said deposition shall be exan1ined at1r,i ·.. _._,reau·ovcr&y· ·-- 14. and shall be signed by him and that the said 11 12 15 16 17 18 19 20 21 22 23 24 ' deposition constitutes a true record ofthe testimony given by the said witness. I further certify that the said deposition was taken at the time and place specified and that . thc.taking of said deposition commenced on the 9th day of Marcl:l 2007, and was completed the same day. I further. certify that MR. THOMAS G. . GARDINER of the firin of GARDINER KOCH & . 53 West Jackson Boulevard, Suite 950, Chicago, STENO (312) 236-1414 JR-JJAMERICAN 044721 . ;·,,..;'; ;.. \ Page 161 -Page REYNALDO GUEVARA. 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' ·.• ' . ._. - Condenselt n.t retired (31 8:19 32:5 retirement (IJ . retrial [31 146:18 146:19 reversed PI revtew (51 151:20 152: I 1 152:14 7:17 7:20 146:6 132:4 81 :I 152:12 reviewing PI · 82:23 revisit [11 157:14 Reyes 111 144:7 Reynaldo fHJ 1:7 I: II 3:3 4:2 4:9 161:6 161:18 162:7 . ribs 111 136:9 Ricardo L5J 58:14 '. 59:1 59:12 80:6 97:21 ' right[l?lt) 4:17 5:16 5:21 5:20 6:1 6:5 6:13 6:20 7:17. 10:4 II :5 12:13 13:19 14:22 16:8 17:7 17:10 17:12 18:12 18:16 18:17 19:13 20:2 . 20:5 20:6 20:8 20:14 21:10 21:23 23:9 23:24 24:2 25:12 25:13 28:4 28:18 29:16 31: I 31:9 31:22 -· 32:5 32:14 35:21 36:4 36:5 36:7 36:8 37:10 39':4 39:8 39:12 39:13 39:19 40:1 42:4 42:5 42:13 43:8 44:19 45:2 45:11 45:15 45:19 49:12 49:15 49:23 51:20 . 52:11 54:6 55:13 56:3 56:15 57:24 61:2 62:10 62:21 64:5 64:6 65:19 66:1 ·66:2· . 66:14 67:21 68:3 71:17 72:12 72:15 72:24 74:4 76:17 78:15 81 :II 81:17 81:21 81;-24 . 83:15 83:20 84:9 84:11 84:15 84:20 85:6. 86:10 86:24 87.:7 . 87:17 87:20 88:13 90:2 92:12 92:13 92:16 92:20 92:23 93:2 . 93:8 93:5 93:6 97:12 . 97:2 97:11 98:5 98:6 . 98:24 101:15 102:3 102:17 103:8 103:14 103:17 104:20 105:11 105:14 105:18 105:22 106:3 106:4 107:3 107:11 107:14 107:17 107:21 109:14 110:21, 112:23 113:8 113:11 114:20 ,114:22. 11(:3 •'. 117:14 JR-JJAMERICAN 044730 STENO (312) 236,-1414 '118:6 119:17 124:3 124:6 126:9 128:6 i37:i2 144:4 146:18 149:7 151:12 152:13 157:18. right..:hartd[1J ring L4l. 49:24 151:4 151:7 Rita £31 149:19 149:23 rivalpJ 13:1 rivalries fl 1 Rivera f5J 129:19 129:22 139:22 Rivetas PI Robert i3J _ 132:20 .. 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Salvador p 11 . 55:18 56:2 56:15 80:7 99:15 - 120:4 147:23 San;uuiJ74:13 104:16 104:20 105:3 105:5 105:13 106:7 106:19 118:5 119:3 119:6 147:10' Samuel [29J 50:18 52:14 52:22 53:11 53:22 54:7 ' 64:16 --· recorded - September 120:22 124:22 130:8 146:2 150:10 154:11 67:16 69:1 69:5 69:10 69:17 70:2 74:2 82:;i 104:9 rl8:20 145:24 146:23 147:4 147:15 154:7 Sanchez[4J 125:9 80:1 125:9 125:11 125:14 134:23 Santiago [11 132:17 Santos PI )41:20 149:23 SaW(13] 56:8 69:14 71:11 71:16 74:24 78:2 85:10 85:12 85:15 98:23 103:17 12:5 135:5 144:23 129:17 .97:4 130:15 says (21 n:1 scene [5J 60:3 60:18 71:6 71:19 . 72:5 129:20 schoolr21 9:18 126:6 9;24 ' seal [II 163:12 63:16 ,. 5: II 129:23 second 111 · section [9J 52:1 155:3 52:23 52.:24 53:1 133:4 •, 54:13 54:14 106:3 122:6 122:9 securedpJ 110:24 security t41 8:3 26:8 8:4 8:7 8:10 82:16 see [241 20:23 26:13 112:18 . 30:7 34:15 36:16 1 r5:24 36:22 39:16 47:11 51:9 69:10 71:5 26:7 72:9 .. 75:2. 80:7 143:20 82:13 89:21 89:19 91:12 .. 102:14 89:21 19:9 102:23 103:5. 103:12 44:1 I 122:3 132:23 seeingrJJ 98:8 151!:23 118:17 119:24 159:I2 seem [IJ 148:7 24:20 . select[JJ 84:20 159:14 93:24 106:8 138:22 selected £11 88:8 161:15 selectiont3J- 84:11 126:3 90 15 100:18 . · selections [4J 84:10 126:17 . 84:14 84:18 90:11 143:5 sell f4J 34:1 34:8 34:24 138:1·8 selling [141 34:10 160:5 34:14 34:16 34:21 55:13 35 I I 35:12 35:15 56: I 1 35·18 36':17 36:23 99:5 37'5 37:12 38:16 I47:18 3819 sense [1)25:2 103:9. · 44:I 104:23 sentence L1J 105:9 sentenced l3J I45:15 106:15 145:18 146:5. 118:17 ... separate rs1 83:7 119:9 96:15 116:10 104:5 117: IS 117:17 117:18 50:6 128:1 52:19 separately [3J 82:20 53:13 87:6 115:12 62:3 67:.f5. ,Septemberr3!J 20:.12 Index PageS I REYNALDO GUEVARA 44:17., 33:21'. 38:9 44:24 45:6 ' 45:13 45:22'' 46:4 45:17 47:6 49:15 49:2050:13 51:23 52:13 52:17 52:21 55:6 59:2 62:17 63:19 66:5 72:4 99:5 111:15 118:18 119:1 120:1 -- 146:14 152:7 sergeant[6J 20:21 59:18 59:19 59:21 74:16 149:6 serious (IJ 44:4 Serranor21 140:14 lf!{):20 Serranos [IJ 140:15 serviceman 11 J 5:2 serV-ingr21 12:2 43:24 31:14 set 121 163:11 severalr41 54:10 130:19 139:10 143: I Shaking121 5:6 120:13shall 121 162:13 '162:14 Sheet [IJ 161: 15 shift 131 62:8 76:1 76:2 shooting r4J 86:23 ' ' 126:24 131:5 131:6 Shorthand (21 1:16 1.62:5 show 1221 . )4 :S'c 28:4 28:5 28:7 28:18 28:20 29:7 30:6 31:3 70:1 70:4 77:20 78:779:21 81:20 88:14 126:17 127:7 127:11 128:8 128:10 1.28:12 showed[9] 83:12 103:21 103:24 119:13 119:14 126:20 127:3 128:15 147:19 showing L4J . 28:15 77':14 77:16 i29:13 side [10J 75:14 75:14 112:8 112:13 113:5 113:6 114:8 114:10 114:15 114:17 Sierra [2J 128:24' 129:15 sign (5J 134:1 138:8 138:9 141:5 143:18 signature [IJ 160:3 signed121 78:14 162:_14 similarity [IJ 28:12 simple 121 40:22 . 82:15 simplyrtJ 88:10 Sinkevicz (3J 1:16 162:4 163:17 sit £41 79:3 79:11 97:2 97:6 34:J} .. ·113:19 114:5 six £21 size Pi Condenselt ™ 113:20 114:2 -- ·28:2 113:17 ···' 112:21 112:24 113:2 slappedpJ 135:20 sleep [lJ 135:16 Solache [6J. 130:3 131:3 132:1 140:8 . 144:7 144:9 sold rsJ 34:4 34:5 34:6 34:7 34:7 34:7 37:8 37:16 soldierp) 74:16 soldiers 121 74:14 105:10 . '· solving [21 77:9 77:12 someone [111 23:4 26;19 69:683:10 84:14 94:22 100:12 100:12 106:8 106:16 106:16 109:20 124:2 124:15 . 131:'1, 133:20 142:12 sometimes [51 28:16_ 31:2 31:18 75:8 128:8 somewhere 121 116:3 119:19 sorry £71 46:21 65:19 120:15 122:20 134:7 134:15 158: II SBTOSr21 ·-· · · . 2:10 163:3 c source £21 15:9 18:19 Spanish [271 31:15 31:21 32:c2 33:9 37:17 37:20 40:15 42:16 42:18_ 44:U 44:14 46:17 ·46:22 52:10 65:8 65:15 65:21 66:6 73:21 . 93:5 .. 93:8 .·. 93:2 93:12 93:24 111:2 Ill: 19 122:7 Spankyr4J 50:11 50:14 51:1 51:24 speakrt4J 38:2 39:6 55:5 67:3 67:12 84:9 84:13 109:1 109:13 115:17 !'30: 15 143:11 151;20 152:11 speaking (51 79:5 129:3 132:19 151:14 152:7 specialist Jl9J 10:16 10:18 10:24 II :3 II :6 II :14 12:5 12:19 12:22 14:3 15:5 .· . 19:11 14:20 19:18 19:22 75:14 91:2 93:20 105:9 specific [6J 49:10 53:22 57:24 '61:21 98: II 130:24 . sergeant - through specifically [3J 23:7 stop[IJ 51:9 136:18 ' 110:6 123:9 °. stopped [IJ 19:2 switchrtJ: . 84:5 [IJ 162:18 strect[4:1] 2:7. 4:1 --speculation [2] 17:3 11:10 16:1 . 26:16 4:4 158:20 158:24 26:22 27:10 29:7 33:8 161:19 162:7 38:3 42:10 42:23 synoptic £3J spend (41 40:13 15:6 43:10 44:21 50:16 43:11 140:2 141:17 47:14 47:16 - 56:23 69:6· 72:15 split £11 75:10 T [I] 3:13 77:1 8}:11 77:21 spoke[IOJ 5'5:7. table[IJ 83:22 81:14 81:21 85:9 68:13 __ ,69:16 69:21.- -85:17 •91:9 86:5 tables [IJ 82:18 69:22 69:24 96:22 94:21 95:3 95:13 takes [IJ 138:22 _121:19 143:14 151:17 98:5 98:8 98:23 taking rsJ 1:15 spoken [1J 153:23 102:19 122:17 123:4 5:12 17:15 18:5 124:1 124:8 124:1 I spot £31 24:8 24:9 77:15 77:17 112:16 .-·· -' 128:11 128:12 1.28:19' 35:3 132:24 134:24 154:11 162:19 spreadTn 99:!6 . tallest (I! I I 3·24 11:1 I squad[21. 96:3 . streets 141 taughtpJ23:3 33:13 57:11 75:1 . 96:4 tea1Jl[l] 76:4 strike f3l 87:4 [1] 162:1 !40:16 __ 144:3 teenager £2J 33:16 . 144:16 stabbed £21 · 33:17 striking [IJ 86:22 144:17 149:3 struck:[,1J70:19 · telephone[IJ stabbing l2J 131:7 85:10 85:12 86:7 television (IJ 144:24 131:14 - . 86:10 94:10 q6:9 . telling L4J . 107:20 ·stack rii 83:21 136:20 1'39:9 140:23 108:13 140: I 141:4 stand [3124:8 24:9 ' 144:4 ten Ill · 9:9 ll6:18 subjected 111 159:12 tend [IJ 74:21 Standards [IJ 136:16 submitted [IJ .15:18 terin 121 123:17 - 127:20 standing £61 34:14 subpoena PI 29:11 tenninated [11 86:20 38:14 112:17 113:6 Subscrib¢d r1 1- 161:19 114:17 120:22 - tenns £4]65: 10 74:3 substantial (1J 44:1 120:5 153:17 start f2J 61:8 96:15 substantive 121 45:14 testified L5J 4:4 started(6J 10:1 45:18 __ . .. 10:14." 33:12 ·.. 33:12 5:16 143:23 147>10 success [tJ 11 I :I 147:19 70:17 72:3 s.uch [IJ 163:8 testify.pJ 146:23 state rs1 1:18 4:8 147:16 162:8 4:14 162:1 162:6 sufficient [11 106:15 testimony [4J state's 111 146:15 29:10 suit Lll 155:6 146:1.6 147:24 162:16 131;16 131:20 151:15 Suite(6J1:19 2:4 151:17' 151:21 152:8 157:10 2:7 2:11 162:24 theory 121 157:13 statemcnt-{41 . 73:6 .. 163:4 134:1 . 142:12 143:17 therefore (IJ71:11 supplemental (2J states £51 1:1 61:2 78:24 They'vepJ 124:14 I :14 61:7 161:1 _Supplementary· (II third 121 63;:1 3 63:14 c. 161:12 . 79:23 . .. ThomaS[4J 2:3 station 191 -69:7 support riJ 153:18 128:24 129:15 162:22 69:11 75:18 118:21 15:6 thought161 65:5 118:24 127:9 137:18 · supposed ri1 137:4 68:4 73:17 74:8 138:8 142:4 74:1 I 97:15 94:9 155:6. surprised 121 status 121 94)3 threaten PI _ . 133:19 .-156:8 ,· .. SUTVIVtng [I) 128:16 threatened 111 133:16 stays [II 87:23 suspectoo1 23:13 three [35J 25:7 stenographically [11 24:7 25:20 28:13. '9,4:3. 79:13 80:20 162:9 ' 116:13 121:1 140:23 81:5 83:13 84:17 step 121 16:3 26:12 141:10 142:3 144:4 85:8 85:13 85:20 stepfather 141 122:11 su.&pected [51 85:21 86:2 86:6 23:20 122:13 122:18 122:2Z 87:3 87:5 89:_23 )?:15 <Hl9:17 . 109:18 90:1 90:2 ' 90:5 Steve [IJ 61:17 110:3 90:13 . 90:17 93:15 stickr:w96:17 -96:22 suspects [121 24:21 96:7 96:9 97:15 -125:3 24:24 25:3 25:5 98:4 99:21 101:17 · . i 1:4 25:6 25:1 I 25:16 still 16i 7:6 102:8 102:11 103:20 25:22 73:;23 26:8 '50:19 50:20 58:23 116:15 117:5 119:14 114:15 121:5 80:10 132:2 suspended 111 137:4 Stohr (6]2:6 2:6 threW(!] 139:9 149:1 152:21 156:19 suspension (41 136:23 throughr-c.1 7:6 157:2. 139:17 139:19 139:20 13:4 28:23 82:12 Stonyc(IJ :49:23 sustained 121 •· JJ6,15 ss ' STENO (312)236-1414 JR-JJAMERICAN 044731 Index Page 10 I I I REYNALDO GUEVARA Condenselt TM -·-84:3 89:24 102:9 102:12 112:12 87:13 89:9 90:2· Westcm[IJ .. 120:18 11.3:18 115:17 115:18 90:10 92:15 . 98:4 , throughout [21 18:24. whereof[Il ' ' 163:11 . 117:15 132:5 i44:15 102:23 103:20 104:24 146:22 wherever [lJ . 30:8 HJ6:14··.··· 144:18 144:24 '144:24 ll6:21 . 117:9 times L9)38:lo 38:14 wholet21· 145:18 153:9 Velazquezrll 133:11 51:13 69:16 131:18 162:8 two-day [1J 139:16 139:10 144:17 144:18 verbal [IJ 159:1 . wife [4J 121.:23 141:6 144:18 27:22 verbally [IJ 136:21 1.56:1 156:1 127:11. todaypJ · 44:2 versus r6J 125:6 willing Pl 13:24 79:3 121:17 79:12 typed [IJ 78:23 129:15 . 130:2 132:1 121:23 )55:10 159:21 types [2114:22 within ruJ 1:17 37:8 132:11 134:6 32:23 37:20 52:22 today's PJ 71:16 ultimate 111 145:13 via LIJ 149:3 53:10 105:10 105:14 together [IIJ 31:10 ultimately [3J 90:7 victim L2J 28:6 105:17 106:1 111:9 31:12 46:12 46:13 129:1 150:15 80:6 Ill: 15 46:18 81:6 96:7 under[3J 26:6 victims l21 128:16 without[IJ 87:9 96:9 115:24 .. 116:9 ' 108:24 ·162:10 128:1.6 144:24 witness r64i 3:2 ' undercover £41 35:21 4:3 . view[I7J 26:5 4:1 5:9 t00[9) 5:4 15:10 36:1 36:5 36:8 26:10 80:19 81 :_15 5:14 12:9. . 13: II 23:20 42: II 46:7 85:14 86:18 99:16 13:15 17:4 underneath [21 88:18 21:18 . 51:1 51:15 55:2 99:17 99:20 100:12 . 22:17 23:11 88:21 26:9 158:5 100:12 100:14 10U9 26:23 ,27:7 40:6 understand [ISJ 5:14 . tookt9J 18:9 59:1 102:1 102:7 102:8 61:23 63:4 71:9 5:18 5:23 6:3 73:22 78:15 79:4 116:18 89:4. 80:17 97:10 (!;1 11 :4 12:9 79:13 101:19 144:18 98:16 99:3 99:15 viewed [l4J 80:21 23:2 44:22 48:9 144:22 111:5 111:24 ·112:10 80:21 81:10 82:2 66:11 72:14 105:9 ·. ·· trained [2J 23:7. 112:13 . 1·16:5 116:20 82':7 '82:9 100:'!3 114:13 152:3 26:6 123:7 124:19 125:23 115:11 116:21 116:23 understood [IJ .66:24 126:2I 127:2 training [211 7:7 1'29:1 I 117:2 117:9 I 18:1 unfriendly (11 22:18 9:1 130:23 131:3 9:4 131:2[ 9:5 123:10 132:19 133; 10 .134:10 9:5 9:7 9:11 40:24 Unitr21 20:22 83:7 .. viewingr3J 134:12 135:4 9:14 9:17 9:20 135:5 United [3J 1:1 115:23 130:20 21:21 22:1 135:21 135:24 139:24· 22:6 1:14 161:1 viewings [IJ 115:18 22:13 22:17 140:23 141:10 141:16 22:22 unjustified PJ 159:1 views [21 116:19 142:7 142:9 23:22 24:3 142:11 24:4 Unknowns 111 21 :II 116:20 143:3 24:14 144:4 27:14 148:11 .)50:12 I SQ:JJ .. 151;12 unlawfulriJ · . 159:10 . violated E3J . . traits [IJ 28:12 · 152:3 162:16 i63: 11 48:22 142:17 unless [6J 47:13 transcript [3J 161; 10 witnessed Pl _ · 61:7 97:4 133:20 141:17 violation [3) 49:4 161:12 162:10 157:11 143:5 138:3 159:14 witnesses [36] 23:14 transported £71 102:19 28.:8 28:19 28:21 unsure [IJ 90:14 violence [3J 94:17 102:20 106:21 108:11 55:2 56:21 61:8 94:22 95:8 109:7 118:20 118:23 unusual[3J 96:21 61:10 6U3 61:18 98:10 111:18 Violent £lJ 99:17 transporting [lJ 109:2 76:24. 77:14 77:15 up [36J 11:10 12:3 Virgilio £11 134:21 treat [IJ 40:18 86:21 ' 91:5 .··. 91:13 12:23 31:20 37:21 volunteerrs1 16:19 95:22 treated PI 40:17 95:23 97:10 37:23 40:21 55:20 16:20 16:23 26:19 97:15 99:21 99:23 trial [IJ 146:8 55:21 . 55:23 60:8 27:3 100:17 116: I 118:2 ·.· trouble [1J ·.· 135:5 66:17 72:13 . 75:10 118:15 119:14 123:4 volunteers r2J 26: f7 77:17 83:21 - 1.0_7:18 . true [9]. 12:14 . 13:6· 125:9 126:20 130:20 27:10 106:6 106:20 111:16 14:11 17:8 1.8:24 146:10 153:13 153:21 142:20 Voytekm . 111:17 LJ 1:19 118:8 53:18 122:16 124:3 154:4 . 159:22 123:3 123:17 123:19 VS[2] 1:6 161:5 womanr21 137:10 123:21 123:22 123:23 waitr21 48:13 158:11 trunk [I] 81:24 151:8 123:24 124:2 124:5 trust[lJ 22:24 .. word [2J 42:22 52:4 124:9 124:16 138:17 :walk r11 95:24 walked[2J 138:17 workedL4J truth [IJ 162:8 145:5 6:5 144:15 try [2) 28:9 29:21 62:9 49:9 upset [1]44:10 115:10 wall[4J 123:23 133:24 write £6J 18:4 trying 121 74:14 73:1·] used(4J 16:21 38:12 142:24 143:4 113:24 78:20 78:21 88:4 47:21 121:1 wam[lJ 40:2 91:15 tum rs1 91:4 91:6 usuallyr1J 25:19 136:12 writing[ II 91:15. .92:8 95:21 . V-o-y-t:e-:k£11 142:21 Warren £21 73:7 109:7' . 1'36:16 95:23 96:12 written [2], 91:17 Vague[ll 143:2 .· tumedm Wl11Cfl2] 135:15 135:19 159:5 47:17 vaguely (I] 142:22 67:7 67:8 86:19 8:13• week [21 8:12 wrongly(IJ 147:7 90:20 91:14 121:13 valid [I] 156:11 weeks [lJ 9:9 wrote [21 79:1 varies.r11 8:17 144:11 i';. TVu1 79:1 weightpJ 24:6 various [21 37:16 two £271 25:5 25:14 3:1 Xr21 3:13 WEISBERG £212) 148:6 25:19 25:22 26:7 162:23 yeaf[4J 5:5 5:10 .· 31:18 35:12 72:22 · Vasquez [191 57:8 6:12 7:21 WestrJJ i:19 2:4 79:9 79:24 93:16 58:8 80:13 . 80:21 162:24 ycarsr2o] 8:18 93:18 100:3 ' 100:21 81:1 85:9 87:13 '. :-' :·'.. :<:· ·. 8:20 . J4:4. .... 18:24 throughout - yourself 27:2 34:15. 3(22 34:9 )4:18 41:9 . 4US· 45:1 . 140:7 140:9 152:17 yet[IJ. · 91:18 young[2J 33:15 youngerr21 111:20 yourself L2J 32:21 34:11 34:20 41:11 109:12 140:10 33:15 33:16 31:3 •' .. . •'» . .. ... 0 <:'•,_ I .. - JR-JJAMERICAN 044732 STENO (312) 236-1414 I _.. Index Page 11 ..}.BEAT A-SSIGNED flr. 4 CLOTHING J FURS :or s ! DT :oR DR $ See N "'wa: __ _ w 0 OFF. 1 16. OFF'S. VEHICLE . I Ouseo Dsl'oLeNI YEAR I STATE LICENSE NO. MAKE DNA 1. _ 80. NARRATIVE FERNANI>EZ,Ricardo;M/WH/26;zo Jul 63;3857 N. Whipple 1st. VICTIM: 5-7, 160 ;member Latin Eagles gang. IR//648341 (deceased). '10 Sep 89;0045 hrs. ;2440 W. North Ave. ,street DATE,TIME,LOC. OF INC: ) __ ------- TUm, LOC. OF ARREST: OF}<'ENDERS: _ IR#833144·!______________________________________________________ . : !12- JOHNSON,Henry;M/B/21;6···1;220; 15Q8 N. Artesian 113- FRANCO,Hector A. ;M/WH/25;25 Apr64;2256 N. Lawndale; 5-9,200;IRI/65576S·-'·>. Spanish Cobras; Campbell & North Ave.- section GANG AFFILIATION: CHARGES: _____ _:_·________-___l1urder 1st. Degree__._ all three offenders _____________ 11 Sep 89; BR: DATE AND BRANCH: WITNESSES: JR-JJ 044733 Ill- )I\ITINUATION Of NARRATIVE PERMANEtii llilENTION fiLE ' WITNESSES CONT: . ' . ·,' -- ( ' l : - . '. IIJ.,. Hlt278-I369 ;nickname, \ . 114- VASQUEZ,Guillermo;M/WH/-21; 9 Apr 68f 1'704 N. Menard lst; Hf/889-0996; MEMO.· MENDEZ ,Armando ;M/WH/2.0;· l8_Aug 69; 2249 N. Menard 2nd. H//622;.,.4708; nickname, PLAYER E ·JWit..nesses allmembers of· tpe Lat:i,I;i Eagles street gang. INVENTORY: .. Reporting. ofJicer,s investigating the Murder of INVESTIGATION: FERNANDEZ,Ricardo found witnesses and brought them into A/6 Gang Crimes Office to view additional photos. 'the witnesses /11-3-4, picked the photos of Juan JOHNSON, Hector FRANGO and a fourth who is not in custody by the name of, 22 Apr 62;5-7,150;lka. 1020 N. Campbell 3rd. flr. ;nickname of PE'!'E. , IR/1752225, member of the Spanish Cobras. Witness #4 stated to r/o's after picking the photo of Juan JOHNSON that the other offender with JOHNSON was brother, but didn 1 t know . . T .. his name. Witnesses·#2, Salvador and II'S, Armando MENDEZ, did not .view a but were brought into A/5 VC to view a physical line-up when · were taken into custody. / . Reportiti.g tar the· offenders were 'photo 1 identified went to fhe were r/o s could find the offe?ders. R/O's while in the 1500 _ block of north Artesian, r/o 1 s spotted the three aforementioned offenders at 1508 N. Artesian on the str.eet These subjects were taken into and transported into A/ 5 VC to stand _ill a physical line""'tip. Efforts to locate the. fourth offender Pedro CORDERO.met with nega.tive results at this time. R/G 1 s -will attempt .to obtain a Warrant the fourth offender _fe.dro. CORDERO. For additional information on statements by witnesses refer to A/5 VC Suppl ement.ary if on CHARGES APPROVED BY ASA BAILEY: _ _:_• ----.. JJ ::S::· I a z 0 ...... · - - - - ------·----·---'-'"'11 .s;.. 0 1.0 1.0 -· - - = - - - - - - · - - - - · · - ·-·- - · - " - - - - - - .. ---c·--. ------:--:-tl ;o!Y ' JR-JJ 044734 ·. ... - :ERRATA SHEET . I wish to maktethe following changes for the followii1g reason(s) .. . PAGE LINE (3 SHOULD BE: REASON: Woo L.. d Pte..y- · -y-- /1)CJ H/.)-uc We u ls:L.. 6NLr SHOULD BE: _ _ _ _ _ _ _ _ -·- REASON:_.:.._...;"-'-----'--...._,;_---'-'---.;..;.;....,----- REASON-: ...... ----------'------------------------- SHOULD BE: _ _ _ _ _.;,.,__ _ _ _ _ _..___ __ -- REASON: _ _ ____,;,.-'-----,-----..,......----. SHOULDBE: _ _ _-_ .. _ .. _ ... _.·-·_·- - - - - - - - REASON: _ _ _ _ _ _ _ _ _ _.:...-----:----SHOULD BE:_·- - - - - - - - - - - - - - - . . . ·.: · SHOULD BE:.....,..:,..._ _ _ _---,-,_ _,.__,..__,...,..,..,....------,...,.-,.,..--REASON: _ _ _ _ _ _ _ _ _ SHOULD ' -REASON:_·- - - - - - - - - - - - · · - -- - - - - SHOULD BEr_ _ .REASON: SIGNATIJFJJ; JR-JJ 044735 _ ___;,_,_;__....._......__.;:--....-

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Court UnsealedDepositionFeb 5, 2026

P009747-020326-001-335

March 19, 2025 Mr. Russell Brown Executive Director Washington Association of Prosecuting Attorneys 206 10th Ave SE Olympia WA 98501 Subject: Update - Potential Disclosures concerning Government Witness – CVEO 1 Leonardo J. Bobadilla, Badge Number X807 Dear Mr. Brown: On April 17, 2024, the Washington State Patrol (WSP) provided notification regarding the above￾named employee: “It is alleged CVEO 1 coerced and/or assaulted his ex-girlfriend. It is also alleged CVEO 1 engaged in acts of child

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DOJ Data Set 9OtherUnknown

FBI PUBLIC AFFAIRS - DIRECTOR'S AM NEWS BRIEFING

FBI PUBLIC AFFAIRS - DIRECTOR'S AM NEWS BRIEFING WEDNESDAY, AUGUST 21, 2019 5:00 AM EDT Three Arrested In Domestic Terror Threats Across US On Tuesday. David Muir opened ABC World News Tonight (8/20, lead story, 2:30, 6.49M) 'with the disturbing new headline, after El Paso and Dayton: tonight, news of three new threats, three new arrests. Authorities say these threats of mass shootings in three separate states. Police in Florida handcuffing this 15-year-old boy with his mother by his side. He is accused of threatening to take his father's assault-style weapon to school to shoot several other people." ABC's Victor Oquendo reported, "In Indianapolis, 38-year-old truck driver Thomas Matthew McVicker was arrested. Authorities say they stopped him less than a week before he planned on attacking a church in Memphis. ... And in Seattle, 35-year-old Eric Lin was arrested for allegedly writing on Facebook that he would 'kill all Hispanic Hispanics in Miami and other places.' These thre

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DOJ Data Set 9OtherUnknown

EFTA00186748

EFTA00186748 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: CUSTODIAN OF RECORDS Clerk of Court and Comptroller 15th Judicial Circuit of Florida Palm Beach County Courthouse 205 North Dixie Highway West Palm Beach, FL 33401 SUBPOENA TO TESTIFY BEFORE GRAND JURY FGJ 05-02(WPB)-FriJNo. OLY-17 SUBPOENA FOR: PERSON DOCUMENTS OR OBJECT[S] YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date and time specified below. PLACE: Palm Beach County Courthouse Juvenile Courts Building 205 N. Dixie Highway West Palm Beach, Florida 33401 (Temporary location for the United States District Courthouse, West Palm Beach) ROOM: Room 4-A DATE AND TIME: August 18, 2006 9:00am YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006, referring or relating to Jeffrey Epstein a

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Dept. of JusticeAug 22, 2017

1 May 1 1255-May 6 237_Redacted.pdf

Kristen M. Simkins me: Sent Tn: Subject: Atladimem: LT. THOMAS E. ALLEN JR Thomas S. Allen. Jr. Sunday. May BIL EDIE 12:55 AM Allyson FL Dwell; Brenda McKin1e?c C. Kay Wandring: Caitlyn D. Neff: Daniel?le Minarch?lck: JeFFrey' T. Hite; Jon D. Fisher. Jonathan M. Mfl?n-der. Joseph 5. Kolenorluan Mendez: Kevin T. Jeirles; [any Lidgett Lee R. Shea??er: Lorinda L. Brown.- Matti-new T. Fishet: Melanie Gordan; Michael S. Woods Richard C. 5mm; Shephanie D. Calander?mtus Report SMDIE 20150501004

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Court UnsealedJan 4, 2024

Unsealed Jeffrey Epstein court papers

January 3, 2024 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s December 18, 2023, unsealing order, and following conferral with Defendant, Plaintiff files this set of documents ordered unsealed. The filing of these documents ordered unsealed will be done on a rolling basis until c

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