Burge Statement 2 by chicagonewscoop

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
MADISON HOBLEY,
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Plaintiff,
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No. 03 C 3678
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v.
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CHICAGO POLICE COMMANDER JON
BURGE. DET. ROBERT DWYER, DET. JAMES )
LOTITO. DET. VIRGIL MIKUS, DET. DANIEL )
McWEENEY, DET. JOHN PALADINO, SGT.
PATRICK GARRITY, and the CITY OF
CHICAGO,
Judge Aspen
Magistrate Judge Brown
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Defendants.
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DEFENDANT JON SURGE'S ANSWER TO
PLAINTIFF'S SECOND SET OF INTERROGATORIES
NOW COMES the Defendant, JON BURGE, by and through his attorneys, JAMES G.
SOTOS, MICHAEL W. CONDON and ELIZABETH A. EKL of HERVAS. SOTOS, CONDON
& BERSANI, P.C., and in response to Plaintiffs Second Set of Interrogatories propounded upon
it, states the following:
INTERROGATORIES
1.
To your knowledge, did any Person (including yourself) use any force, violence,
or torture at any point while interrogating Madison Hobley? If the answer is yes, please identify
said Person(s), describe the circumstances of how that force, violence, or torture was used, and
state who engaged in each particular act.
ANSWER:
Not to my knowledge.
2.
To your knowledge, did any Person (including yourself):
GOVERNMENT
| EXHIBIT
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a:
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(a) plant the gasoline can (Exhibit 8 at Plaintiffs criminal trial) at the scene of the
crime after the subject arson was committed? If the answer is yes, please identify said Person(s),
describe the circumstances of how said gas can was planted, and state who engaged in each
particular act;
ANSWER: Not to my knowledge.
(b) lie to prosecutors and/or conspire to give false testimony that Plaintiff confessed
to the crime for which he was convicted? If the answer is yes, please identify said Person(s),
describe the circumstances of how prosecutors were lied to and/or a conspiracy to testify falsely
occurred, and state who engaged in each particular act.
ANSWER: Not to my knowledge.
(c) provide assistance and/or make offers of assistance to Andre Council with respect
to criminal matters involving Council between the time of Plaintiffs arrest and his conviction at
trial? If the answer is yes, please identify the Person(s), describe the circumstances of what was
done to provide and/or offer such assistance, and state who engaged in each particular act.
ANSWER:
Several weeks/months after Plaintiff was arrested, I was contacted by a detective
who related that a witness in the case had been arrested for a Municipal Code or
Misdemeanor violation. I was requested to authorize a Personal Recognizance
Bond (I Bond) as a courtesy. I currently have no recollection if that person was
"Andre Council" or the name of the detective who requested the I Bond. I
authorized the I Bond and had no further involvement.
Is the manner in which Madison Hobley claims he was physically abused and/or
3.
tortured as described in Plaintiffs Complaint (including, for example, the allegation of "bagging"
with a typewriter cover) consistent with any other examples of physical abuse and/or torture on
the part of Chicago Police officers at Area 2 which you observed or have knowledge of?
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Please explain your answer and identify any other instances or examples of the same or similar
physical abuse and/or torture.
ANSWER: I have not observed nor do I have knowledge of any other examples of physical
abuse and/or torture on the part of Chicago Police officers at Area 2.
I, Jon Burge, after first being duly sworn, state on oath that I have read the foregoing
DEFENDANT JON BURGE'S ANSWER TO PLAINTIFF'S SECOND SET OF
INTERROGATORIES, and that the answers therein are true and correct to the best of my
knowledge and belief.
G
RGE
SUBSCRIBED AND SWORN to
before me this cPs~ day
of		, 2003.
! WENDYS.HE1DE
' Notary Public, state of Florida
My comm. expires April 10, 2007
	 No. 0D 202138
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Notary Public
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JAMES G. SOTOS
MICHAEL W. CONDON
ELIZABETH A. EKL
HERVAS, SOTOS, CONDON & BERSANI, P.C.
333 Pierce Road, Suite 195
Itasca, IL 60143-3156
(630) 773-4774
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