Professional Documents
Culture Documents
JASON GONZALES, )
)
)
Plaintiff, )
)
) No. 2016 C 7915
-vs- )
)
MICHAEL J. MADIGAN, FRIENDS )
OF MICHAEL J. MADIGAN, 13TH )
WARD DEMOCRATIC ORGANIZATION )
SHAW DECREMER, SILVANA )
TABARES, RAY HANANIA, )
JOE BARBOZA and GRASIELA )
RODRIGUEZ, )
)
Defendants. )
Page 3 Page 5
1 - Continued- 1 THE VIDEOGRAPHER: This is Nick Paige
2 2 with Advance Video Solutions, Incorporated; 615
3 A P P E A R A N C E S: 3 Berkshire Court, Schaumburg, Illinois. I am the
4
5 DEL GALDO LAW GROUP, LLC 4 operator of this camera.
1441 South Harlem Avenue 5 This videotaped deposition of
6 Berwyn, Illinois 60402 6 Michael J. Madigan is being taken on behalf of the
(708) 222-7000 7 Plaintiff at 151 North Franklin Street, Chicago,
7 Email: sullivan@dlglawgroup.com
8 Illinois on September 13, 2018, approximately
8
9 BY: MR. SEAN SULLIVAN 9 11:06 a.m. as indicate
10 Appeared on behalf of Shaw Decremer. 10 d on the video screen
11 11 This case is captioned Jason Gonzales
12 RICHARD J. PRENDERGAST, LTD. 12 v. Michael J. Madigan, et al.
111 West Washington Street - Suite 1100
13 Chicago, Illinois 60602 13 At this time will all the attorneys
(312)641-0881 14 please identify themselves for the video record.
14 Email: Rprendergast@rjpltd.com 15 MR. PERAICA: Yes. For the record, Anthony
15 16 Peraica P-e-r-a-i-c-a representing Plaintiff, Jason
16 BY: DEIRDRE A. CLOSE
17 Gonzales, who is present at this deposition sitting to
17 Appeared on behalf of Silvana Tabares.
18 18 my left.
19 19 And if I could just go around the
20 ALSO PRESENT: Jason Gonzales (Plaintiff) 20 table to attorneys introduce themselves for the record
21 21 and whom they represent, please.
22 - - o o OO o o - -
23 22 MR. NALLY: Good morning, James P. Nally
24 23 N-a-l-l-y on behalf of Joe Barboza.
25 24 MR. ERDMAN: Scott B. Erdman E-r-d-m-a-n on
2 (Pages 2 to 5)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 6 Page 8
1 behalf of Defendant Grasiela Rodriguez. 1 Q I just want to go over some very basic
2 MR. SULLIVAN: Sean Sullivan 2 rules so that we can have a clear record both video and
3 S-u-l-l-i-v-a-n on behalf of the Defendant Shaw 3 written record.
4 Decremer. 4 Please allow me to finish my question
5 MS. CLOSE: Deidre Close C-l-o-s-e on 5 before you begin to answer. If for any reason you do
6 behalf of Silvana Tabares. 6 not understand a question that I'm asking, please let
7 MR. VAUGHT: Adam Vaught V as in Victor 7 me know and I'll try to repeat it, rephrase, break it
8 a-u-g-h-t on behalf of Mr. Madigan. 8 down into component parts.
9 MR. KASPER: And Michael Kasper K-a-s-p-e-r 9 If there are any objections pending,
10 for Defendant Madigan. 10 please allow us to make the record, all attorneys
11 THE VIDEOGRAPHER: And would the court 11 regarding the objections before you begin to answer.
12 reporter identify herself and swear-in the witness. 12 If at any point you need to take a
13 COURT REPORTER: Kim Causley with Causley 13 break to consult with your counsel, to take a bathroom
14 Court Reporting. 14 break or for any reason, all I ask is that you answer
15 Would you please raise your right 15 the question that is pending on the floor -- on the
16 hand? 16 table, and then we can take a break after that.
17 17 question and can answer it, please do so audibly using
18 18 words rather than body shrugs, head nods, mm-hmm,
19 (WHEREUPON, the witness was 19 uh-huh, or any other gestures, it does not make a clear
20 first duly sworn.) 20 record so we want to avoid that.
21 21 Is that understood?
22 22 A I think so.
23 23 Q Thank you.
24 24 Have you reviewed any documents in
Page 7 Page 9
1 MICHAEL J. MADIGAN, 1 preparation for your deposition today?
2 called as a witness herein, having been first duly 2 A I read the deposition of Alderman Quinn and
3 sworn, was examined and testified as follows: 3 the deposition of Tim Mapes.
4 4 Q Any other depositions that you read?
5 5 A No.
6 DIRECT EXAMINATION 6 Q Did you look at any of the pleadings or
7 7 motions?
8 BY MR. PERAICA: 8 A I've read pleadings, yes.
9 Q Can you please state your full name for the 9 Q Did you read the Second Amended Complaint
10 record and spell your last name? 10 that the Plaintiff filed?
11 A Michael J. Madigan M-a-d-i-g-a-n. 11 A Not that I recall.
12 Q Mr. Madigan, as you heard, I represent 12 Q Did you read any of the orders entered by
13 Jason Gonzales, Plaintiff in this case. You and I have 13 Judge Knelly recently in this case or at any point?
14 met before. Good to see you this morning. 14 A Not that I remember.
15 I want to state for the record that 15 Q Beside the two depositions that you
16 this deposition is being taken pursuant to the 16 indicated you went over, did you look at any
17 applicable Federal Code of Civil Procedure, Federal 17 documentation related to the allegations in this case?
18 Rules and the Local Rules of the Northern District of 18 A Not that I remember, no.
19 Illinois including the court order that the judge in 19 Q I'm about talking about any literature, any
20 this case Judge Knelly, entered a protective order 20 financial records, donor records, organizational
21 which was entered yesterday. 21 records, any records that were obtained during
22 Sir, have you given a deposition 22 discovery of this case?
23 before?
23 A Not that I remember.
24 A No.
24 Q I assume you met with your counsel prior
3 (Pages 6 to 9)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 10 Page 12
1 to? 1 Representative, any of your Fundraising Committees,
2 A Yes. 2 does Mr. Kasper serve in any other role regarding
3 Q Okay. Besides your attorneys, have you 3 those?
4 spoken to anyone in advance of this deposition? 4 A Not to the best -- the answer is no. To
5 A I spoke to my wife. 5 the best of my knowledge, the is answer no.
6 Q Anyone else? 6 Q I'm just going to go through these names
7 A I may have spoken to some of my children. 7 regarding the attorneys who are working on this case
8 Q Did you talk to any of the other Defendants 8 and the Law Firm of Hinshaw & Culbertson.
9 in this case before your deposition today? 9 Adam Vaught, do you know Mr. Vaught?
10 A No. 10 A I do.
11 Q Did you talk to any of the circulators or 11 Q Do you know him only in relation to this
12 notaries that were involved in the various petitions 12 case or do you know him in any other way?
13 here? 13 A I know him in relation to this case. He's
14 A No. 14 also the husband of a woman who served as Counsel to
15 Q Did you talk any of your donors in advance 15 the Speaker.
16 of this deposition? 16 Q And her name is?
17 A No. 17 A Heather.
18 Q So your family and your counsel would be 18 Q Full name?
19 the only people you spoke with, is that correct? 19 A Vaught.
20 A To the best of my memory. 20 Q Okay. Do you social with Mr. Vaught and
21 Q Okay. With respect to the attorneys who 21 his wife outside of the usual political gatherings?
22 are present in this room, I just want to establish your 22 A No.
23 relationship, if any, to the attorneys. 23 Q Do you know an attorney at Hinshaw
24 You're represented by Michael Kasper, 24 Culbertson by the name of Vince Rizzo?
Page 11 Page 13
1 and also by Hinshaw & Culbertson Law Firm, is that 1 A No.
2 correct? 2 Q Do you know an attorney working on your
3 A I'm represented by Kasper. And you're here 3 case at Hinshaw & Culbertson by the name of Carson
4 on behalf of Hinshaw? 4 Griffis?
5 MR. VAUGHT: Well, on behalf of you but 5 A No.
6 Hinshaw the firm is. 6 Q Do you know an attorney by the name of
7 THE WITNESS: So the answer is yes. 7 Gretchen Sperry?
8 BY MR. PERAICA: 8 A No.
9 Q Okay. Does your attorney Michael Kasper 9 Q Do you know an attorney by the name of
10 serve in any other political function or any other 10 J. Williams Roberts who works at Hinshaw & Culbertson?
11 function with you individually or you in any elected or 11 A I know Mr. Roberts.
12 appointed capacity? 12 Q How do you know Mr. Roberts?
13 A Well, Mr. Kasper is the General Counsel of 13 A Mr. Roberts is an attorney who's
14 the Democratic Party of Illinois. 14 represented me in different matters. At one time he
15 Q I would ask you to please keep your voice 15 was the United States Attorney for the Central District
16 loud so we can have, again, a clear record. 16 of Illinois, prior to that he was the State's Attorney
17 So he's General Counsel for the 17 of Sangamon County. At one time he was the Inspector
18 Democratic Party of Illinois? 18 General of the Legislative Ethics Commission.
19 A The answer is yes. 19 Q Is he still serving in any of those
20 Q Does he serve in any other function? 20 functions?
21 A Not that I recall. 21 A He's no longer the Inspector General.
22 Q Any financial function at all, Mr. Kasper, 22 Q Is he with the State of Illinois in any
23 that is related to the Party, your role on the 23 function?
24 Central -- State Central Committee, Committeeman, State 24 A To the best of my knowledge, no.
4 (Pages 10 to 13)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 14 Page 16
1 Q And what case did he represent you on or 1 who is here today.
2 in, Mr. Roberts, that is? 2 Do you know moving on to Richard J.
3 A Those were matters that involved the United 3 Prendergast, do you know him?
4 States Attorney's Office. 4 A Yes, I do.
5 Q Were those civil in nature or criminal in 5 Q And you know that he is the attorney for
6 nature? 6 Miss Tabares, Representative Tabares?
7 A They were not civil. 7 A Yes.
8 Q Are those matters over, completed, 8 Q How long have you known Mr. Prendergast?
9 finished? 9 A Many years.
10 A Yes, they are. 10 Q Multiple decades?
11 Q How about the attorney by the name of 11 A Yes.
12 Robert Shannon S-h-a-n-n-o-n also employed at Hinshaw & 12 Q He has ever represented you in any
13 Culbertson? 13 capacity?
14 A I believe I met him once. 14 A Yes.
15 Q And was that in relation to this case? 15 Q How so?
16 A Yes. 16 A In a matter before the Legislative
17 Q Do you know Mr. Shannon in any other 17 Inspector General.
18 capacity? 18 Q Is that the same case that Mr. Roberts
19 A No. 19 worked on?
20 Q Are you familiar with the Law Firm of 20 A To the best of my knowledge, no.
21 Del Galdo Law Offices? 21 Q So it was a different matter?
22 A Yes. 22 A Again, to the best of my knowledge, yes.
23 Q Do you know Michael Del Galdo, the 23 Q And how long ago was that?
24 principal at that firm? 24 A Approximately three to four, five years
Page 15 Page 17
1 A Yes, I do. 1 ago.
2 Q And how do you know Mr. Del Galdo? 2 Q Is he representing you currently in any
3 A As the practicing attorney many times in 3 official or private capacity?
4 the western suburbs and the southwestern suburbs. 4 A To the best of my knowledge, no.
5 Q Have you or you in any of your capacities 5 Q Was that the only case that he represented
6 ever been represented by Michael Del Galdo or Del Galdo 6 you, the one dealing with the Inspector General
7 Law Office? 7 investigation three or four years ago?
8 A To the best of my knowledge, no. 8 A Well, again, at this time my answer would
9 Q Do you work with Mr. Del Galdo on any 9 be that was the only case, but there may be items that
10 issues regarding the Town of Cicero whether they're in 10 I'm forgetting.
11 political sense or governmental sense? 11 Q Okay. Do you know of an attorney at
12 A The answer is no. 12 Mr. Prendergast's Office by the name of Deirdre
13 Q Do you know another attorney at the Del 13 Close?
14 Galdo Law Firm by the name of Cynthia Grandfield? 14 A No.
15 A No. 15 Q Do you know attorney at the same
16 Q Do you -- at the same law firm, these are 16 Prendergast Office by the name of Michael Laden?
17 the same name -- these are different names from the 17 A I believe I do.
18 same firm. 18 Q How do you know Mr. Laden?
19 Joseph Giambrone, do you know him? 19 A I believe that Mr. Layden was an attorney
20 A No.
20 involved in one aspect of legislative redistricting
21 Q Do you know attorney at Del Galdo Law
21 several years ago.
22 Office by the name of K. Austin Zimmer?
22 Q So it was that last redistricting that took
23 place?
23 A No.
24 A I don't recall whether it was the last or
24 Q Do you know -- well, you met Mr. Sullivan
5 (Pages 14 to 17)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 18 Page 20
1 the one before that. 1 campaigns?
2 Q Did he represent you individually or in 2 A To the best of my knowledge, no.
3 your capacity as a State official? 3 Q Are you familiar with the Law Firm Burke
4 A I don't remember. 4 Law?
5 Q Do you know an attorney by the name of 5 A Burke Law?
6 Michael Kreloff? 6 Q Yeah, J. Stalin in particular from that
7 A Yes, I do. 7 firm.
8 Q How do you know Mr. Kreloff? 8 A No.
9 A Well, Mr. Kreloff is active in Democratic 9 Q Mr. Madigan, just a routine question, have
10 politics. At one time he was a Township -- Democratic 10 you ever been charged with any crime involving fraud or
11 Township Committeeman in the northern suburbs, that's 11 dishonesty or perjury or anything dealing with lack of
12 how I would know him. 12 truthfulness?
13 Q Do you know Mr. Kreloff in his capacity as 13 A No.
14 an attorney? 14 Q Are you taking any medications that would
15 A I know he's an attorney. 15 impair your ability to hear, understand, and answer
16 Q Has he -- has Mr. Kreloff ever represented 16 questions today?
17 you in any capacity individually or in your official -- 17 A No.
18 A To the best of my knowledge, no. 18 Q And you do understand you're under oath,
19 Q Please allow me to finish my question. 19 correct?
20 A Yes, I will. 20 A I do.
21 Q Did Mr. Kreloff ever represent you in any 21 Q Are you currently involved in any other
22 official capacity? 22 lawsuit beside this one, civil lawsuit?
23 A Again, to the best of my knowledge, no. 23 A There's a matter filed by a former employee
24 Q Do you know an attorney by the name of 24 of our political committees.
Page 19 Page 21
1 Scott Erdman, who is present here today? 1 Q And who would that be?
2 A Only since I met him in this room today. 2 A Her name is Hampton.
3 Q Do you know that he represents Grasiela 3 Q Elena Hampton?
4 Rodriguez? 4 A So you know her?
5 A Well, you're telling me, so I'll accept it. 5 Q I read the paper.
6 Q Have you ever done business with 6 A Right, and it's at the EEOC.
7 Mr. Erdman in any capacity? 7 Q And who is representing you in that matter?
8 A To the best of my knowledge, no. 8 A Tony, I don't know the name of the law firm
9 Q Have you done any business with Mr. Erdman 9 today. It's a major law firm that does Employment Law.
10 when he was an employee of Cook County? 10 I don't know the name of the law firm.
11 A To the best of my knowledge, no. 11 Q I would ask that that information be
12 Q Do you know attorney James Nally who is 12 provided.
13 here on behalf of Joe Barboza? 13 A Sure.
14 A I know the name, and I think I've met him 14 Q Any other lawsuits besides the matter
15 for the first time today. 15 pending before EEOC brought by Elena Hampton?
16 Q Has Mr. Nally ever done work for you 16 A Not to my -- to the best of my knowledge,
17 individually in anyway? 17 no.
18 A To the best of my knowledge, no. 18 Q Have you been involved either as a
19 Q Did Mr. Nally ever represent any of the 19 Plaintiff or a Defendant in any lawsuits from
20 committees you're involved in? 20 April 2015 up until present day that were concluded
21 A To the best of my knowledge, no. 21 where you were either a Plaintiff or a Defendant?
22 Q Did Mr. Nally represent you in any 22 A To the best of my knowledge just the ones
23 political capacity for yourself as a candidate or 23 that we talked about.
24 anybody else that you support in the political 24 Q No others?
6 (Pages 18 to 21)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 22 Page 24
1 A Again, to the best of my knowledge, no. 1 A Yes.
2 Q Okay. Your middle initial J. stands for 2 Q Andrew Madigan?
3 Joseph? 3 A Yes.
4 A Yes. 4 Q All right. Have you had or adopted any
5 Q And how old are you now? 5 other children?
6 A 76. 6 A No.
7 Q And what is your date of birth? 7 Q Now, Lisa Madigan is still currently the
8 A April 1942. 8 Attorney General?
9 Q What is your marital status? 9 A Yes, she is.
10 A Married. 10 Q Of the State of Illinois.
11 Q What is your wife's name? 11 What about Tiffany Madigan, where is
12 A Shirley. 12 she employed?
13 Q Is she known as Shirley Madigan? 13 MR. VAUGHT: Tony, I'm objecting. We're
14 A Yes, she is. 14 getting past -- we're getting in -- you know, the
15 Q What was your wife's maiden last name? 15 protective order says not to get into the family other
16 MR. VAUGHT: Tony, I'm going to raise an 16 than into the Attorney General any involvement
17 objection. The protective order says we're not going 17 regarding the 2016 primary. There's no need for the
18 to get into families. 18 background.
19 MR. PERAICA: It is just background 19 MR. PERAICA: Well, it has to do with State
20 information. I'm not getting into that otherwise. 20 acts and the positions that the deponent holds. So I
21 MR. VAUGHT: Okay. 21 don't intend to spend a lot of time on this, but
22 THE WITNESS: Romago. 22 briefly, I think as a result of the Counts in the
23 23 Amended Complaint that were sustained, I'm able to ask
24 BY MR. PERAICA: 24 those questions.
Page 23 Page 25
1 Q How do you spell that? 1 MR. VAUGHT: Well, yesterday the Court
2 A You're going to cause a problem for me if I 2 entered an order that said the scope of the deposition
3 can't spell my wife's maiden name. 3 shall be restricted as follows: 2(c) "Counsel for
4 Q I won't tell her. 4 Plaintiff shall not question Defendant Madigan about
5 MR. VAUGHT: And I'll instruct him not to 5 his family members with the exception of questions
6 answer. 6 regarding any actions by Attorney General Lisa Madigan
7 THE WITNESS: Obviously, it's a French name 7 or her office directly related to the 2016 Democratic
8 so there's o-u-x on the end so like Romagoux 8 Primary Election in the 22nd District of the Illinois
9 R-o-m-a-g-o-u-x. 9 House of Representative Grasiela Rodriguez or Joe
10 BY MR. PERAICA: 10 Barboza and their respective families."
11 Q Thank you. 11 MR. PERAICA: Well, so that I can make my
12 Do you and your wife have children as 12 record. Are you going to instruct the witness not to
13 a result of the marriage? 13 answer if I ask him about the background of Tiffany
14 A Yes, we do. 14 Madigan's employment?
15 Q And how many children do you have? 15 MR. VAUGHT: I don't see how it's relevant,
16 A We have a total of four children. The 16 and it's outside the scope of the deposition and the
17 first child was conceived in a prior marriage that my 17 order that was entered by the Court yesterday that you
18 wife was involved in, and the last three were conceived 18 agreed -- this is an agreed order.
19 by both her and I. 19 MR. PERAICA: So the answer is yes?
20 Q So the four children would be Lisa Madigan? 20 MR. VAUGHT: Yes.
21 A Yes. 21 MR. PERAICA: Are you going to object to
22 Q Tiffany Madigan? 22 eliciting information from the deponent regarding
23 A Yes. 23 Jordan Matyas M-a-t-y-a-s, a husband of Tiffany Madigan
24 Q Nicole Madigan? 24 who is employed as Chief of Staff of Regional
7 (Pages 22 to 25)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 26 Page 28
1 Transportation Authority? 1 MR. VAUGHT: It's an order you agreed to.
2 MR. VAUGHT: Yes, if that's involved 2 MR. PERAICA: The record has been made.
3 with -- I mean, Tony, this is an order entered by the 3 THE WITNESS: We promise not to ask
4 Court that you agreed to. 4 questions about your family, too.
5 MR. PERAICA: And you will likely instruct 5 MR. PERAICA: You could.
6 Mr. Madigan not to answer that question either then, is 6 BY MR. PERAICA:
7 that correct? 7 Q What is your current address where you
8 MR. VAUGHT: I'm saying that you're not 8 live?
9 allowed to ask the question. 9 A 6400 South Keeler.
10 MR. PERAICA: Okay. Well, for the record, 10 Q How do you spell the street?
11 I do believe that that does not fall under the language 11 A K-e-e-l-e-r.
12 of the agreed order that was entered yesterday, 12 Q And what is the zip code there?
13 protective order that is. 13 A 60629.
14 But for the record, I will just 14 Q Who resides with you at that address?
15 state, and we can have the Court to deal with this 15 A My wife.
16 issue that the questions that I would elicit here would 16 Q Anybody else?
17 deal with work done by the husband of one of the 17 A No.
18 children of Mike Madigan, that is Tiffany Madigan who 18 Q How long have you lived at that address?
19 is married to Lobbyist Jordan Matyas who also in 19 A Since October of 1977.
20 addition to lobbying State Government is a Chief of 20 Q 48 years?
21 Staff for the RTA or Regional Transportation Authority 21 A Is that the count?
22 a State agency, so. 22 Q Almost.
23 MR. VAUGHT: Spouses of children are 23 A Okay.
24 considered family members. At least my in-laws take 24 Q Have you owned any other homes or
Page 27 Page 29
1 that position. 1 residences in Cook County?
2 MR. PERAICA: Mine don't. 2 A I own the residence at -- my wife and I own
3 MR. KASPER: I'm with you, Tony. 3 the residence at 6406 South Keeler?
4 BY MR. PERAICA: 4 Q Is that a single-family home as well?
5 Q Is your daughter Nicole Madigan employed as 5 A Yes, it is.
6 well? 6 Q And who lives there?
7 MR. VAUGHT: Tony, the same objection. 7 A Nobody.
8 MR. PERAICA: So you're instructing him not 8 Q It's vacant?
9 to answer? 9 A It's vacant.
10 MR. VAUGHT: I'm saying the Court doesn't 10 Q Did you own real estate in Ravenswood
11 allow you to ask the question. 11 neighborhood of Chicago sometime in the past?
12 MR. PERAICA: Okay. 12 A To the best of my knowledge, no.
13 BY MR. PERAICA: 13 Q Did you or your wife sell any property in
14 Q Finally, Andrew Madigan, he's your son, 14 Ravenswood, in particular, to Shaw Decremer and his
15 correct? 15 wife?
16 A Yes. 16 A The answer is no.
17 Q Is Andrew Madigan employed with Mesirow 17 Q Where did you graduate elementary school?
18 Financial? 18 A Saint Adrian.
19 MR. VAUGHT: Tony, same objection. 19 Q And where did you go to high school?
20 MR. PERAICA: Are you instructing him not 20 A St. Ignatius.
21 to answer that question? 21 Q Did you graduate?
22 MR. VAUGHT: I'm saying you don't get to 22 Q Yes, I did.
23 ask the question. 23 A What year was that in?
24 MR. PERAICA: Okay. All right. 24 A 1960.
8 (Pages 26 to 29)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 30 Page 32
1 Q After St. Ignatius High School, where did 1 A To the best of my knowledge, the answer is
2 you go to college? 2 no.
3 A Notre Dame. 3 Q Do you belong to any church or parish?
4 Q When did you graduate? 4 A No.
5 A '64, June of '64. 5 Q Were you a member in the past of
6 Q What did degree did you obtain? 6 St. Mary Star of the Sea?
7 A Bachelors of Arts BA. 7 A No.
8 Q And after graduating from Notre Dame, did 8 Q Were you a regular attendee at any
9 you go further in school? 9 particular church?
10 A The Loyola Law School. 10 A Once upon a time St. Adrian.
11 Q When did you graduate from Loyola Law 11 And let me amend that, for a time I
12 School? 12 would be a regular attendee at St. Nicholas of
13 A June of '67. 13 Tolentine.
14 Q Have you had any other education besides 14 Q These are all churches in Chicago around
15 that? Did you study or take seminars, obtain any 15 the area you live in?
16 certificates or diplomas post-graduating from law 16 A Southwest side of Chicago.
17 school at Loyola? 17 Q Now, in the past after you graduated from
18 A I have done CLE training. 18 Loyola Law School, did you go to work as an attorney?
19 Q Okay. Anything other than that? 19 A Yes, I did.
20 A Not that I recall. 20 Q And where did you work?
21 Q Do you belong to any clubs? 21 A At the Illinois Commerce Commission.
22 A Yes. 22 Q What did you do there?
23 Q Which ones? 23 A I was a hearing examiner.
24 A I belong to the Union League Club of 24 Q Just approximately how long were you there?
Page 31 Page 33
1 Chicago. I also belong to the Beverly Country Club. 1 A Approximately from sometime in late 1967
2 Q How long have you been a member Union 2 until sometime in 1969.
3 League Club of Chicago? 3 Q Was that a full-time or part-time position?
4 A Approximately 10 years. 4 A Full-time job.
5 Q How long have you been a member of Beverly 5 Q And after you left the job that you had
6 Country Club? 6 with Illinois Commerce Commission, did you go to work
7 A Approximately 10 to 15 years. 7 somewhere else?
8 Q Are you a member of the Lake Shore Club? 8 A City of Chicago Law Department.
9 A The Lake Shore Club no longer exists. 9 Q From when to when was that approximately?
10 Q Were you a member in the past? 10 A From sometime in 1969 until approximately
11 A Yes, I was. 11 December of '69.
12 Q When did it cease to exist? 12 Q And when you worked as an Assistant
13 A Tony, I think it was 30 years ago that was 13 Corporation Counsel for the City of Chicago during that
14 shut down. 14 time, what were your responsibilities, what did you do?
15 Q Do you belong to any legal professional 15 A I worked with the Liquor Control
16 associations or organizations? 16 Commissioner to analyze and review police reports and
17 A State Bar Association, Chicago Bar 17 prepare a summary report for the Liquor Commissioner.
18 Association. 18 Q After you left the City of Chicago as an
19 Q Any others? 19 Assistant Corporation Counsel in December of '69, where
20 A To the best of my knowledge, no. 20 did you go to work then?
21 Q Were you ever a member or an honorary 21 A The Illinois Constitutional Convention.
22 member of the Women's Bar Association? 22 Q And how long did that position last?
23 A I may have been a member for a short time. 23 A From December of '69 until approximately
24 Q You're no longer involved with them?
24 September of 1970.
9 (Pages 30 to 33)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 34 Page 36
1 Q What were your responsibilities in that 1 among lawyers in terms of cost sharing, so I wouldn't
2 position? 2 remember today what the structure or the arrangement
3 A I was a delegate to the convention. 3 was.
4 Q Was that a paid or unpaid position? 4 Q But the Firm of Madigan & Getzendanner has
5 A Compensated position. 5 been around since what year?
6 Q Was it considered full time or part time? 6 A I don't recall exactly when it became
7 A For me it was full time. 7 Madigan & Getzendanner.
8 Q And were you compensated by the State of 8 Q It's been a while?
9 Illinois? 9 A It's been a while.
10 A Yes. 10 Q Okay. Your father, was he also named
11 Q So during that period from December of '69 11 Michael Madigan?
12 to September of 1970, you were a convention delegate 12 A Yes.
13 working on the drafting of the Illinois State 13 Q Did he have a different middle initial?
14 Constitution? 14 A It was Michael J. Madigan.
15 A Yes. 15 Q Michael J. Okay.
16 Q After that employment ended in September of 16 Do you have any siblings?
17 1970, where did you go to work then? 17 A Yes.
18 A The Illinois House of Representatives. 18 Q How many?
19 Q When were you first sworn-in? 19 A One.
20 A January of '71. 20 Q What is the name?
21 Q And you have been serving in that capacity 21 A Marita M-a-r-i-t-a.
22 until the present time? 22 Q Last name?
23 A Yes. 23 A McGivney McGiveney M-c capital G-i-v-n-e-y.
24 Q You're also a principal in the Law Firm of 24 Q And how old is your sister?
Page 35 Page 37
1 Madigan & Getzendanner, is that correct? 1 A She is 71.
2 A The answer is yes. 2 Q Are both your mother and father deceased?
3 Q And how long have you worked in that 3 A Yes.
4 capacity as a principal at that law firm? 4 Q I know your father was involved in
5 MR. VAUGHT: Okay. Tony, I'm going to 5 politics, was your mother involved in politics as well
6 object here. The scope of deposition says, "The scope 6 when she was alive?
7 shall be restricted as follows: (b) Counsel for 7 A No.
8 Plaintiff shall not question Defendant Madigan 8 Q Your wife Shirley, is she involved with any
9 regarding his law practice." 9 committees that you were working with or control?
10 MR. PERAICA: I'm not. I'm just asking for 10 A She's the Chair of the Illinois Arts
11 a diagraphical background information from when to when 11 Council, which is a State agency appointed by the
12 was the deponent principal in Madigan & Getzendanner, 12 Governor.
13 that's all. 13 Q And the appropriation for the Illinois Arts
14 MR. VAUGHT: Then we're going to move on? 14 Council comes from the State taxpayers?
15 MR. PERAICA: Yeah. 15 A From the Illinois Legislature.
16 THE WITNESS: Tony, I started my law firm 16 Q Right, as part of the State budget?
17 in, I believe, 1972. And thereafter, why I was 17 A Yes.
18 associated with multiple lawyers and eventually it 18 Q Is your wife Shirley involved in any other
19 became Madigan & Getzendanner, but I'm not certain of 19 way in any of the governmental work or State agency
20 the date that it became Madigan & Getzendanner. 20 work or any board memberships in any other way besides
21 BY MR. PERAICA: 21 Illinois Arts Council?
22 Q Were you an equity partner or owner since 22 A Governmentally it you would be restricted
23 1972 in whatever formation or names were used? 23 to the Arts Council. Now, she'sinvolved with other
24 A For one period it was a loose arrangement 24 arts organizations such as the Erikson Institute. I
10 (Pages 34 to 37)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 38 Page 40
1 believe she's a board member there. 1 geographically close than others that are not
2 Q Any others? 2 geographically close, but I wouldn't describe any of
3 A There may be more, but I don't remember 3 these relationships as anything other than knowing that
4 them right now. 4 these people are involved with politics and from time
5 Q Is your wife still a Trustee at Loyola 5 to time why you may interact with them.
6 University? 6 Q All right. Do you have a close working
7 MR. VAUGHT: Tony, I'm going object. I 7 relationship with the Committeemen of the adjacent Ward
8 mean, this is again getting into family. We've already 8 Alderman Ed Burke who is also a Committeeman?
9 discussed this. It's not relevant. 9 A Correct. I would not describe it as a
10 MR. PERAICA: You're right. 10 close working relationship.
11 MR. VAUGHT: It's prohibited by the 11 Q You backed Ed Burke in the past when he ran
12 protective order. Let's just move on. 12 for State's Attorney it was back in the 80s, did you
13 BY MR. PERAICA: 13 not?
14 Q One more question on that point. 14 A I did.
15 Is Shirley Madigan involved as a 15 Q And he backed you when you ran for various
16 Director for After School Matters, Inc.? 16 offices, did you not?
17 A Tony, she may be, but I don't remember 17 A He supported me for State Representative.
18 right now. 18 Q Right. Do you and Committeeman Alderman Ed
19 Q Okay. That's fair. 19 Burke work closely on any races in the Primary or
20 I want to focus next group of 20 General Election generally?
21 questions on the political functions that you serve in 21 A Again, I wouldn't say closely.
22 both within the Democratic Party and in the leadership 22 Q Particularly in the months leading up to
23 position of the Party structure. 23 the filing for the March 2016 primary, so I'm talking
24 Are you a Democratic Committeeman of 24 from April of 2015 through about April of 2016, have
Page 39 Page 41
1 the 13th Ward? 1 you worked with Committeeman or Alderman Ed Burke on
2 A Yes. 2 any of the races in that cycle?
3 Q And how long have you been a Democratic 3 A To the best of my knowledge, maybe, that's
4 Committeeman of the 13th Ward? 4 what I can remember today.
5 A Since July of 1969. 5 Q Well, it's not that long ago, so I'm asking
6 Q And you are currently serving a deposition? 6 you if you recall having any conversations, for
7 A Yes. 7 example, with Alderman Ed Burke related to the March
8 Q As a Committeeman of the 13th Ward, do you 8 2016 primary when you were running yourself?
9 participate in the City of Chicago Democratic Party 9 A Not that I remember.
10 work? 10 Q Did you ask Committeeman Alderman Ed Burke
11 A With the -- the City element of the Cook 11 to provide any assistance in anyway to you or your
12 County Democratic Party? 12 campaign in that March 2016 primary?
13 Q Yes. 13 A I presumed that I asked for his support.
14 A The answer is yes. 14 Q Is it your practice to ask all
15 Q Do you have a close relationship with all 15 Committeemen, Democratic Committeemen, who are
16 50 Ward Democratic Committeemen across the City of 16 contained within the 22nd House Representative District
17 Chicago or do you just focus on your local area where 17 to assist you?
18 you're at? 18 A In the ordinary course I would do that.
19 A I'm like you, I try to make friends 19 Q But you don't recall any particular
20 everywhere but not with great success. 20 meetings or conversations with Alderman Ed Burke?
21 Q All right. Do you have a close working 21 A I do not remember.
22 relationship with the Ward Committeemen surrounding 22 Q Did you ask Alderman Ed Burke or in his
23 13th Ward is my question? 23 capacity as a Committeeman Ed Burke to send any
24 A Obviously, you spend more time with those 24 literature out either on your -- on your behalf first
11 (Pages 38 to 41)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 42 Page 44
1 in that March 2016 primary? 1 of the 13th Ward?
2 A Not that I remember. 2 A In the 13th Ward why -- what we attempt to
3 Q Did you ask him to ask Alderman Ed Burke to 3 do is to persuade and encourage governments,
4 send any literature on behalf of any other candidates 4 governmental bodies to provide an appropriate level of
5 for or against in that March 2016 primary? 5 service to the people that live in the 13th Ward. And
6 A Not that I remember. 6 so citizens of the 13th Ward will come to our office
7 Q Are you aware that Alderman Ed Burke sent a 7 and ask for assistance in terms of their interaction
8 piece in support of Grasiela Rodriguez, one of your 8 with governments, and we attempt to help them.
9 primary opponents in the March 2016 primary? 9 Q Isn't that role of an Alderman of the Ward?
10 A I'm not aware of that. 10 A In part, but it's also a role that the 13th
11 Q Was your understanding or belief that 11 Ward Organization performs.
12 Alderman Ed Burke was supporting your re-election as a 12 Q The committeeman position is a party
13 member of the House of Representatives from the 22nd 13 position, an unpaid position, correct?
14 District in that March 2016 primary? 14 A Yes.
15 A The answer would be yes. 15 Q And generally speaking you get no budget or
16 Q According to my math, 1969 you would have 16 money for any staff from anybody from the party, for
17 been about what 27-years old when you were elected by 17 example?
18 your fellow precinct captains as a Committeeman of the 18 A Yes.
19 13th Ward? 19 Q So you have to generate and produce moneys
20 A About that age. 20 for the 13th Ward Democratic Organization, correct?
21 Q And you have served in that capacity almost 21 A Yes.
22 50 years, correct? 22 Q And you have to then use that money to
23 A Yes. 23 support the Democratic Party activities in that Ward on
24 Q So can you tell me how do you define the 24 behalf of yourself as a Democratic elected official or
Page 43 Page 45
1 role of a Democratic Committeeman of a Ward in the City 1 others who are running in that ward, correct?
2 of Chicago? 2 A Yes.
3 A My view of the responsibility of the Ward 3 Q And you would also then from that same
4 Committeeman is to work on behalf of Democratic 4 fundraising for the 13th Ward Democratic Organization
5 candidates in the general election; to distribute their 5 pay any staff people if you deem them appropriate to be
6 literature; to prepare a sample ballot, and to 6 hired?
7 distribute the sample ballot. 7 A Yes.
8 In the Primary Election why everybody 8 Q With all the other responsibilities that
9 is a Democratic or claim to be a Democratic and you 9 you have in your various roles, why would you want to
10 pick someone that you would support in the Primary 10 continue as a committeeman for 50 years?
11 Election. 11 A It's a good question.
12 Q And those would be activities related to 12 Q Have you figured out the answer? I'm
13 before or at election time. 13 curious.
14 What about when you're between 14 A My stock answer is to tell people that I'm
15 elections, what is the duty or role of a Democratic 15 rather peculiar.
16 Committeeman? 16 Q You're passionate about that position,
17 A My view would be to participate in the 17 right?
18 affairs of the Democratic Party, the ongoing affairs of 18 A You want an answer to that?
19 the Democratic Party, activities of the Democratic 19 Q Yes.
20 Party formulating issue positions of the Democratic 20 A I'm not sure I'm passionate, but I still
21 Party that might become determinative issues in the 21 perform the duties.
22 general election. 22 Q All the duties that you enumerated earlier
23 Q In your role as the 13th Ward Committeeman, 23 which overlap with the Alderman's Office, are those the
24 are you able to offer any services to the constituents 24 only duties that you as a committeeman would be
12 (Pages 42 to 45)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 46 Page 48
1 involved in or are there others? 1 neighboring committeeman Alderman Ed Burke, correct?
2 A Well, in general you stay abreast of 2 A I believe answer is yes.
3 Democratic Party positions, Democratic Party issues, 3 Q Chicago Tribune wrote in the past that
4 and to the best of your ability you think in terms of 4 during the last decade and a half that some 25 lawyers
5 future elections and working to provide support for 5 that you recommended were appointed or elected to the
6 those Democratic Party positions. 6 bench in Cook County?
7 Q Did you have anyone on the payroll as a 7 A That I recommended?
8 staff person or a contractor being paid by the 13th 8 Q Yes, it's a 15-year span.
9 Ward Regular Democratic Organization between April of 9 A And who did I give the recommendations to?
10 '15 and April of 2016? 10 Q Chief Judge or whoever is in charge of the
11 A I don't remember. 11 appointment process, Supreme Court possibly.
12 Q Would that be reflected if anyone was hired 12 A Are you talking about appointments by the
13 on any disclosure forms that you would file for the 13 Court or are you talking about the Democratic
14 organization? 14 Committee?
15 A The answer is yes. 15 Q Appointments.
16 Q As a 13th Ward Committeeman in the City of 16 A Okay. So you shifted over to a
17 Chicago, you are also part of the Cook County 17 different --
18 Democratic Organization which encompasses 50 Wards in 18 Q Right.
19 this City and the townships in suburban Cook County, is 19 A And you're talking about people appointed
20 that correct? 20 by the Supreme Court?
21 A The answer is yes. 21 Q Yes.
22 Q Do you participate in that role as a 13th 22 A I don't remember -- I don't remember who
23 Ward Democratic Committeeman in the Cook County 23 would have been appointed by the Court in my
24 Democratic Party activities? 24 recommendation.
Page 47 Page 49
1 A The answer is yes. 1 Q As far as the election of judges, do you
2 Q Does that include slating activity as well? 2 participate in the process of electing Democratic
3 A The answer is yes. 3 judges in Cook County?
4 Q Do you have any leadership role in either 4 A To the extent that those judges appear on
5 the Chicago Democratic Party or the Cook County 5 the 13th Ward sample ballot.
6 Democratic Party leadership structure? 6 Q Then you do?
7 A The answer is no. 7 A The answer is yes.
8 Q Are you in charge of any of the screening 8 Q Do you also participate as a Committeeman
9 committees? 9 in the filling of vacancies when an elected official
10 A The answer is no. 10 either retires, dies, or quits midterm and the vacancy
11 Q In particular, do you get involved with the 11 has to be filled?
12 judicial slating by the Chicago or Cook County 12 A Can you give me some examples.
13 Democratic Party? 13 Q For example, if the Alderman were to leave
14 A The answer is no. 14 in the 13th Ward you, as a Committeeman, would have a
15 Q Have you done so in the past? 15 voice in terms of who the replacement would be until
16 A Well, Tony, the full answer to your 16 the next special election or regular election, is that
17 question is that I don't serve as a Member of the 17 correct?
18 Committee on the Judiciary. I do not participate 18 MR. KASPER: Objection. I think you're
19 actively with that committee. There have been 19 going beyond the scope of the witness' knowledge.
20 instances where I supported individual candidates for 20 MR. PERAICA: If he knows.
21 judgeships and as I did that they were appearing before 21 BY MR. PERAICA:
22 that committee. 22 Q Do you know?
23 Q And the Judicial Evaluation Committee of 23 A Can you restate the question?
24 the Cook County Democratic Party is chaired by your 24 Q If an elected official whether Municipal,
13 (Pages 46 to 49)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 50 Page 52
1 County or State leaves midterm, would the role that you 1 Q And do you pay for that space that you
2 hold as a 13th Ward Democratic Committeeman come into 2 occupy from one of the funds that you control or how?
3 play in picking a replacement, a temporary replacement? 3 A It's from my personal money.
4 A If you focus just on the office of the 4 Q Who owns that building currently?
5 Alderman, I would make a recommendation to the Mayor. 5 A The Balzekas Museum.
6 It's the Mayor's appointment. 6 Q Right. Is it a non-for-profit corporation?
7 Q Right. 7 A I really don't know, but I presume it is.
8 A I would make a recommendation to the Mayor. 8 Q But you pay money from personal funds for
9 The Mayor may accept it or not accept it. 9 the rent, who do you pay it to?
10 Q Right. And what about if it's a State 10 A We write a check to the Balzekas Museum.
11 Representative, for example, would you play a role as a 11 Q Okay. And how much do you pay for rent as
12 Democratic Committeeman in replacing a person who left 12 13th Ward Committeeman?
13 for some reason in midterm? 13 A I don't recall.
14 A If part of the Legislative District were in 14 Q Who handles the payments for you?
15 the 13th Ward, why I would have a vote. 15 A The check is prepared for me.
16 Q Right. 16 Q By whom?
17 A I would vote. 17 MR. KASPER: I think that's beyond the
18 Q Yes. And if a State Senator were to quit 18 scope of this dep.
19 midterm that encompasses the 13th Ward, you would have 19 MR. PERAICA: He can say that.
20 a -- 20 BY MR. PERAICA:
21 A I would have a vote. 21 Q Is it?
22 Q Okay. So have you voted as such in these 22 A Well, I think it is yes.
23 special occasions, rare and infrequent occasions when 23 Q You don't know?
24 there was a vacancy? 24 A Oh, I know who prepares the check for me.
Page 51 Page 53
1 A Not that I remember, but I may have. 1 Q Well, who is it?
2 Q Okay. Do you have a 13th Ward Committeeman 2 A It's a woman that works in my law office.
3 office, physical office? 3 Q What's her name?
4 A Yes, I do. 4 A Marsha.
5 Q Where is that at? 5 Q Last name?
6 A 6500 South Pulaski. 6 A Thomas.
7 Q Is that on the second floor? 7 Q Do you -- does she prepare the checks and
8 A You've been there. The answer is yes. 8 you sign them --
9 Q And which part of the multiple offices and 9 A Yes.
10 cubicles is dedicated to the work as 13th Ward 10 Q -- or does she use a stamp?
11 Committeeman? 11 A No, no, I sign the checks.
12 A I think the answer to your question would 12 Q All right. And you never looked what the
13 be that the space that I occupy is on the northside of 13 amount is that you pay in rent?
14 the suite. It faces 64th Street -- excuse me -- 65th 14 A Oh, I've looked at it, but I don't remember
15 Street. 15 at this time.
16 Q Right. So you're talking about the extreme 16 Q Do you have any employees who work for you
17 north end of the -- 17 as a Committeeman of the 13th Ward?
18 A Suite. 18 A I don't remember.
19 Q -- building? 19 Q You don't remember?
20 A Building. 20 A Your question is 13th Ward, so I presume
21 Q The suite? 21 you're referring to the banking account maintained by
22 A Correct. 22 the 13th Ward.
23 Q On the second floor? 23 Q Yes. I'm asking whether you as a 13th Ward
24 A Second floor. 24 Democratic Committeeman have any staff that you pay for
14 (Pages 50 to 53)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 54 Page 56
1 their services? 1 the work as a 13th Ward Committeeman on average?
2 A Today I don't remember if we do today. We 2 A As needed.
3 may have in the past. 3 Q At the height of the Primary Election
4 Q How about between April of 2015 and April 4 campaign, what would be your involvement as a
5 of 2016? 5 committeeman at that time?
6 A Same answer. I don't remember, but we may 6 A Again, as needed.
7 have. 7 Q How many precinct captains do you have as a
8 Q Do you know how many people you have on 8 13th Ward Committeeman?
9 staff as a Democratic Committeeman of the 13th Ward? 9 A Today I believe there are about 55
10 A No. 10 precincts in the 13th Ward.
11 Q And do you know how those individuals, if 11 Q I thought there were 48 myself, but is
12 you do have them, would get paid and from where? 12 that -- you don't know or?
13 A Well, there would be a payroll check 13 A Your count -- your number may be correct.
14 written for them. 14 Q But in terms of precinct captains you
15 Q And would Marsha Thomas handle that as 15 estimate about 55?
16 well? 16 A Whatever the number of precincts then that
17 A No. 17 would be the number of precinct captains.
18 Q Who handles that? 18 Q So if there are 48 precincts you --
19 A The checks at the 13th Ward are prepared by 19 A 48 captains.
20 Sue Carpentier. 20 Q What is the extent of your interaction with
21 Q Sue Carpenter? 21 the precinct captains of the 13th Ward Democratic
22 A Carpentier. 22 Party, how often do you meet with them?
23 Q Carpentier. 23 A A minimal amount of time.
24 A Yeah. 24 Q Do you have someone who coordinates that on
Page 55 Page 57
1 Q And where does she work? 1 a more regular basis with the precinct captains?
2 A At 6500 South Pulaski. 2 A Alderman Quinn.
3 Q And what is her function there? 3 Q Anybody else other than Alderman Quinn who
4 A She writes the checks to pay the bills. 4 interacts with the precinct captains on a regular
5 Q For the 13th Ward Democratic Organization? 5 basis?
6 A Yes. 6 A Well, today there's a man named Moe Zahdan
7 Q Any others? 7 who works with Alderman Quinn.
8 A No, just the bills that come in for the 8 Q He's the, I believe, what Chief of Staff
9 13th Ward Organization. The bills that are going to be 9 or --
10 paid by the 13th Ward Democratic Organization. 10 A No.
11 Q Is this the same account that Marsha Thomas 11 Q -- Superintendent?
12 uses to pay the rent? 12 A He's the Ward Superintendent.
13 A No. 13 Q So Moe Zahdan is the Ward Superintendent of
14 Q That's a separate account? 14 the 13th Ward also assists Alderman Quinn and you to
15 A Well, you recall I told you that I use my 15 work with the precinct captains throughout the year but
16 personal money to pay for my space. 16 especially during and leading up to election?
17 Q All right. 17 A The answer is yes.
18 A That's the check that's prepared by Marsh 18 Q Do you join the committeeman to go
19 Thomas. 19 door-to-door in any outreach efforts to the
20 Q When you say "personal money," is that 20 constituents?
21 money coming from Madigan & Getzendanner Law Firm or is 21 A No.
22 it from your personal checking or savings account? 22 Q Have you done that during the 2016 primary
23 A Personal account. 23 cycle?
24 Q How many hours a week do you dedicate to 24 A No.
15 (Pages 54 to 57)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 58 Page 60
1 Q Did you go door-to-door at all -- 1 BY MR. PERAICA:
2 A No. 2 Q So he acted in that role even though he
3 Q -- during that time? 3 didn't have the official designation as such?
4 A No. 4 A The answer is yes.
5 Q What is your interaction typically with the 5 Q Did Alderman Marty Quinn as a coordinator
6 13th Ward Alderman Marty Quinn? 6 for your re-election campaign in March of 2016 have any
7 A We meet and talk sometimes everyday, 7 assistants that worked with him in that regard that you
8 sometimes everyday. 8 know of?
9 Q Other than talking to each other, do you do 9 A Not that I recall today.
10 anything else? 10 Q For example, like Moe Zahdan?
11 A Can you rephrase the question? 11 A He may have been. He may have been.
12 Q Do you delegate any other responsibilities 12 Q Any others that you would be able to
13 or functions to Alderman Quinn as a Ward Committeeman? 13 identify?
14 A Well, not that I can remember now. We -- 14 A Not that I can recall.
15 we meet, we talk, we work through issues and problems. 15 Q So, again, in your opinion and based on
16 Q And when you say "issues and problems," are 16 your knowledge and years of service as a Democratic
17 you talking about constituents' issues and problems? 17 Ward Committeeman for almost 50 years, how did the
18 A Both that and campaign issues and problems. 18 offices of the 13th Ward Alderman, in this case,
19 Q And what role does Marty Quinn, Alderman 19 Marty Quinn now, Frank Olivo before him, and your role
20 Quinn, play in any campaign issues? 20 as a 22nd District Democratic Representative, how did
21 A Well, depending upon the campaign he may be 21 they interact?
22 involved in the campaign he may not be. If he's 22 A We would maintain a joint service office so
23 involved in the campaign, why he'll be involved in the 23 we would combine our resources to provide constituent
24 campaign. 24 service to both 13th Ward and 22nd District.
Page 59 Page 61
1 Q Was Marty Quinn, Alderman Quinn, involved 1 Q And can you elaborate on that, what type of
2 in your re-election campaign in March of 2016? 2 typical activity would that involve?
3 A Yes. 3 A It's generally being responsive to requests
4 Q In what role? 4 from citizens of the area, whatever a citizen might
5 A Just as an advisor, as a coordinator. 5 wish to talk to us about.
6 Q Was the Alderman Marty Quinn your campaign 6 MR. PERAICA: Let's label this as
7 manager? 7 Exhibit -- you got them out?
8 A There was no designated campaign manager. 8 MR. VAUGHT: Is this the snow plowing?
9 Q Did Marty Quinn act in that role? 9 MR. PERAICA: Hm?
10 A Marty Quinn acted as an advisor and as a 10 MR. VAUGHT: Is this the snow plow?
11 coordinator, that's what he did. 11 MR. PERAICA: No, I'm going to save that,
12 Q Coordinator of the campaign? 12 though.
13 A Coordinator of the campaign. 13 MR. VAUGHT: You're going to save it.
14 Q That would be a campaign manager? 14
15 MR. VAUGHT: Objection. That's been asked 15 (WHEREUPON, said document was
16 and answered. He said there was no -- 16 so marked as Madigan Deposition
17 BY MR. PERAICA: 17 Exhibit No. 1, for identification.)
18 Q Is that true?
18
19 MR. VAUGHT: He said there was no campaign
19 BY MR. PERAICA:
20 manager, then he said he was a coordinator.
20 Q I marked this as Madigan Deposition
21 Exhibit No. 1, would you take a look at this?
21 MR. PERAICA: I heard what he said.
22 A Sure.
22 THE WITNESS: There was no campaign
23
23 manager. What Marty did would be the type of things
24 (Document tendered)
24 that would be done by a campaign manager.
16 (Pages 58 to 61)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 62 Page 64
1 BY MR. PERAICA: 1 question was what arrangement. So maybe I suggest,
2 Q Have you had a chance to look at it? 2 Mr. Peraica, why don't you just you reask the question
3 A I have. 3 so it's accurate as to what you're actually asking.
4 Q At the bottom of this, which is a snapshot 4 MR. PERAICA: That's fair. Let me rephrase
5 from the website that is maintained by you and Alderman 5 the question.
6 Quinn it says, "Paid for by the 13th Ward Democratic 6 BY MR. PERAICA:
7 Organization" at the bottom. 7 Q And please if you don't understand what I'm
8 Do you see that? 8 asking, which may happen again, please let me know, and
9 A I do. 9 I'll try to rephrase it.
10 Q So is this creation and design and 10 Looking at this Madigan Exhibit 1
11 maintenance of this website maintained by the 13th Ward 11 paid for by the 13th Ward Democratic Organization, my
12 Democratic Organization? 12 question is what work do you as a Democratic
13 A I don't know the answer to that question. 13 Committeeman do at these two locations in conjunction
14 Q Do you recall paying for the creation of 14 with Alderman Quinn?
15 this website? 15 A Can you state it again?
16 A I do not remember. 16 Q Yeah, what work do you do as a committeeman
17 Q Do you recall discussing with Alderman 17 at 6500 South Pulaski and 6014 South Central with
18 Quinn the creation of this website? 18 Alderman Quinn?
19 A I do not remember. 19 A Well, for one thing I've never been inside
20 Q Have you met with any web designers to talk 20 the office at 6014 South Central. I've never been
21 about what should be contained in terms of text or 21 inside the office.
22 pictures on this website? 22 Q Who pays the rent for that office?
23 A I do not remember. 23 A Today I don't know. I'd have to go back
24 Q It lists here at the top where it says 24 and ask.
Page 63 Page 65
1 "Welcome to the Madigan-Quinn Website" two offices, 1 Q Have you personally ever paid rent for 6014
2 correct? 2 South Central?
3 A Correct. 3 A I don't remember.
4 Q And one is that you mentioned before 6500 4 Q Do you recall if the Democratic
5 South Pulaski, and the other is 6014 South Central, is 5 Organization of the 13th Ward paid rent at that
6 that correct? 6 location?
7 A That's correct. 7 A I don't remember.
8 Q What is the arrangement that you and 8 Q Do you remember if the State of Illinois on
9 Alderman Quinn have regarding the work done at these 9 behalf of you as a State Representative of the 22nd
10 two offices by the 13th Ward Democratic Organization? 10 District paid rent at that office?
11 A Can you restate the question? 11 A I don't remember.
12 MR. PERAICA: Can you read the question, 12 Q Did the State of Illinois pay any rent at
13 please? 13 6500 South Pulaski?
14 14 A The answer is that the State of Illinois
15 (WHEREUPON: The question was 15 pays for some space at 6500 South Pulaski.
16 read as follows: "Q What is 16 Q And what space particularly is paid for by
17 the arrangement that you and 17 the State of Illinois at 6500 South Pulaski?
18 Alderman Quinn have regarding
18 A I wouldn't remember. If it's not, I have
19 the work done at these two
19 to back and ask.
20 offices by the 13th Ward
20 Q And who would be the person making that
21 designation in terms of what areas are for what
21 Democratic Organization?"?)
22
22 purpose?
23 A Alderman Quinn.
23 MR. SULLIVAN: I think the court reporter
24 Q And not you?
24 has incorrectly restated the question. I think the
17 (Pages 62 to 65)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 66 Page 68
1 A Correct. 1 A The answer is no.
2 Q So you've never been at 6014 South Central? 2 Q Do you have any office as a State Central
3 A I've never been inside the office. I've 3 Committeeman?
4 driven past it, but I've never been inside the office. 4 A No.
5 Q This is your service office? 5 Q Do you have anything to do with the design,
6 A It is. 6 launch, content of this website that's before you
7 Q But you've never been there? 7 Madigan Exhibit 1?
8 A I've never been there. 8 A The answer is no.
9 Q Did you ever assign a person that you paid 9 Q Is this done solely by Alderman Quinn and
10 to be there? 10 his staff?
11 A I don't remember. 11 A I wouldn't know.
12 Q Was Elena Hampton ever assigned to work at 12 Q As a 22nd District Representative, do you
13 this office? 13 have a joint arrangement like you have here with you
14 A I don't remember. 14 and Alderman Quinn with any of the other Aldermen who
15 Q Did you in any of your multiple capacities 15 are part of the 22nd House District?
16 or in your control of these various funds that you 16 A State it again.
17 control allocate any moneys for any expense, payroll, 17 Q Do you have an arrangement with any other
18 rent, utilities, anything in relation to 6014 South 18 elected official who is part of your 22nd House
19 Central? 19 District that you represent?
20 A I don't remember. 20 A An arrangement related to office -- sharing
21 Q But you do remember 6500 South Pulaski? 21 of office space?
22 A Yes. 22 Q Sharing of office space.
23 Q And you do pay a percentage of the usage 23 A The answer is no.
24 there? 24 Q Creation of a website as the one here?
Page 67 Page 69
1 MR. VAUGHT: Can you define -- 1 A I don't remember. To the best of my
2 MR. KASPER: Yeah, who's you, Tony? 2 knowledge, no.
3 MR. PERAICA: Pardon me? 3 Q Engagement in joint activities for
4 MR. KASPER: Who's you? 4 constituent services, any other Aldermen --
5 MR. VAUGHT: Who's you? 5 A Not that I remember.
6 BY MR. PERAICA: 6 Q So Alderman Quinn would be the only one
7 Q You as the State Central -- pardon me. 7 that you have --
8 As the Ward Committeeman of the 13th 8 A To the best of my knowledge, the answer is
9 Ward. 9 yes.
10 MR. KASPER: Well, he's already testified 10 Q How do you distinguish the role as a
11 that he pays personally some money. 11 Democratic Committeeman of 13th Ward from your role as
12 MR. PERAICA: Okay. So that's him. 12 a Third Congressional District State Central
13 MR. KASPER: Yeah, that's the you you're 13 Committeeman, Democratic State Central Committeeman?
14 talking about from his personal -- from his personal 14 A As a local Ward Committeeman, my focus is
15 account? 15 on local issues, local activities.
16 MR. PERAICA: Yeah. 16 As a member of the State Committee,
17 MR. KASPER: Objection; asked and answered. 17 my focus is on State issues.
18 BY MR. PERAICA: 18 Q And what are your functions within the
19 Q And you have the State of Illinois pay for 19 Democratic Party as the Third District State Central
20 a certain square footage of the second floor office 20 Committeeman, what are your responsibilities?
21 space at 6500 South Pulaski? 21 A My responsibility would be to be a member
22 A The answer is yes. 22 of the State Central Committee of the Democratic Party.
23 Q Do you have an office as a State Central 23 If there were votes taken with the State Committee, I
24 Committeeman in that same 6500 South Pulaski location? 24 would be expected to participate in the votes.
18 (Pages 66 to 69)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 70 Page 72
1 Q Do you? 1 joining you in this race in the Third Congressional
2 A Yes, I do. 2 District for State Central Committeeman that she
3 Q Do you also serve in addition to Third 3 contribute funds?
4 Congressional District Democratic State Central 4 A I believe the answer is no.
5 Committeeman, do you also serve as a Chairman of the 5 Q As a member of the State Central Committee
6 Democratic Party? 6 and as a Chairman of the Democratic Party, do you get
7 A Yes, I do. 7 to elect the Executive Director of the Democratic
8 Q And how are you elected in that role? 8 Party?
9 A By other members of the State Committee. 9 A Historically, the Chair is appointed the
10 Q And there are two from every Congressional 10 Executive Director.
11 District? 11 Q And who appoints the Executive Director?
12 A Yes. 12 A As I said, historically the chair --
13 Q And who is your running mate in the Third 13 Q Right.
14 Congressional District as a State Central Democratic 14 A -- appointed the Executive Director.
15 Committeeman? 15 Q That would be you?
16 A Silvana Tabares. 16 A Yes.
17 Q Who is in the past been a member of the 17 Q In April 2015 through April of 2016, who
18 Illinois House of Representatives? 18 was the Chairman of the Democratic -- who was the
19 A The answer is yes. 19 Executive Director of the Democratic Party?
20 Q And currently serves as an Alderman of the 20 A Tim Mapes.
21 adjacent to the 23rd Ward? 21 Q Who was also your Chief of Staff as a
22 A The answer is yes. 22 Speaker of the House?
23 Q Which is also part of your 22nd District, 23 A Yes.
24 parts of it at least -- 24 Q And in that same period April of 2015
Page 71 Page 73
1 A The answer is yes. 1 through April of 2016, you were the Chairman of the
2 Q 23rd Ward, correct? 2 Democratic Party of the State of Illinois, correct?
3 A The answer is yes. 3 A Yes.
4 Q Did you have anything to do with her, 4 Q You were the Third Congressional District
5 meaning, Silvana Tabares, being placed as a running 5 Committeeman?
6 mate with you for the Third Congressional District 6 A Yes.
7 State Central Committeeman? 7 Q You were there 13th Ward Committeeman?
8 A Yes, I did. 8 A Yes.
9 Q How so? 9 Q You were the 22nd District House of
10 A I met with her and suggested that she might 10 Representative member?
11 want to run for the office, and she agreed to do it. 11 A Yes.
12 Q Have you met or interviewed any other 12 Q You were Speaker of the House?
13 potential candidates? 13 A Yes.
14 A No. 14 Q What would be the purpose of running for
15 Q She was the only one? 15 Third Congressional District State Central Committeeman
16 A Yes. 16 with all the other responsibilities that you have?
17 Q You asked her and she said yes? 17 A My purpose would be to become a member of
18 A The answer is yes. 18 the State Committee so I'm active in Illinois
19 Q Did you pay for that campaign for you and 19 Democratic politics, and I would have a choice to be a
20 Silvana Tabares to run as candidates in the Third 20 member of the State Committee or not be a member of the
21 Congressional District for State Central Committeeman? 21 State Committee. Given my level of interest in
22 A I believe we ran a joint campaign which was 22 Democratic politics in Illinois why I chose to attempt
23 paid for probably by Friends of Michael J. Madigan. 23 to become a member of the State Committee.
24 Q Did you ask Silvana Tabares as part of her 24 Q And what benefits do you get from that
19 (Pages 70 to 73)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 74 Page 76
1 role? 1 and nomination for the office of Lieutenant Governor,
2 A Can you -- 2 and the State Committee met and vote for Shelia Simon
3 Q What benefit would you obtain from serving 3 to become Quinn's running mate for Lieutenant Governor.
4 in that role? 4 Q Would that be the only circumstance?
5 A Well, you'd be actively involved in the 5 A To the best of my knowledge that's the only
6 deliberations of the State Committee. 6 time that the State Committee would be replacing
7 Q Any other benefits or roles? 7 people.
8 A You get to meet and talk to a lot of 8 Q Looking, again, at the Madigan Exhibit 1.
9 people. 9 It says here under "Bringing Government To You" that
10 Q Do you go statewide and campaign on behalf 10 any information would be directed to Quinn Service
11 of other individuals? 11 Office, and there are two numbers given here.
12 A No. 12 Is this the Alderman Quinn Aldermanic
13 Q You don't even go out and meet your own 13 Service Office that's being referred to --
14 constituents in the 13th Ward you said? 14 A Where does it state "Bringing Government To
15 A I meet them all the time. I met one this 15 You"? Where does that state that?
16 morning coming into the building. 16 Q Right here. It's a headline.
17 Q Are you able to offer any services as a 17 A Gotcha. Okay.
18 Third Congressional District Democratic Committeeman to 18 And the question again?
19 anyone? 19 Q Two paragraphs down there's an information
20 A Well, you can offer the service of 20 given about where the constituents or any interested
21 representing Democratic people and Democratic voters at 21 party was looking at this website would call for
22 the level of the State Committee. 22 services, and there's a Madigan-Quinn service office
23 Q You also get to appointment the vacancies 23 and two numbers are given.
24 as a member of the Third Congressional District, if 24 A And the question is?
Page 75 Page 77
1 someone, for example, a congressman were to leave you 1 Q That's for the two locations, one on
2 would have a say in the replacement? 2 Central, and one on Pulaski, correct?
3 A No. 3 A 8000 is Pulaski and 1313 is Central.
4 Q Not as a Committeeman? 4 Q But you said you don't have anybody at the
5 A In the case of the Congress, it's a special 5 Central office that you can remember, right?
6 election. 6 A I don't think I said that.
7 Q But to fill a vacancy? 7 Q Do you?
8 A For what office? 8 A Do I know what? What's your question?
9 Q For Congress, for example. 9 Q Do you have anyone that you place there to
10 A It's a special election. 10 work there on your behalf on Central Avenue?
11 Q All right. What about for any other 11 A I know the name of one woman that works
12 office, let's put aside congress? 12 there that's Jen Solski.
13 A Well, the only time that the State 13 Q Is she being paid by 13th Ward Democratic
14 Committee fills vacancies is where there's a vacancy in 14 Organization?
15 nomination between primary and the general election. 15 A I don't know the answer to that question.
16 Q Right. So, for example, when Judy 16 Q All right. Do you want to take a short
17 Barr-Topinka was elected Treasurer or Comptroller, I 17 break? Are you okay?
18 forget which now, and died before she took office, 18 A I'm great.
19 would the Central Committee -- 19 Q All right. Good. Let's go on then.
20 A No, no, no. The better example would be 20 A So thankful to spend so much time with you.
21 in the case of Pat Quinn and the Primary Election where 21 THE VIDEOGRAPHER: Counsel, I was going to
22 Quinn was nominated and -- for the office of Lieutenant 22 ask you to change the tape.
23 Governor, one individual won the Primary Election and 23 MR. PERAICA: Go ahead. 10 minutes.
24 then resigned the candidacy. So there was a vacancy 24 THE VIDEOGRAPHER: Well, I was going to ask
20 (Pages 74 to 77)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 78 Page 80
1 you in 10 minutes to change the tape. 1 today there you are Democratic candidates for State
2 MR. PERAICA: Do you want to go on for the 2 Offices, and we're working with them to help them get
3 next 10 minutes or do you want to stop it now? It's up 3 elected. In addition, we work with candidates for the
4 to you. 4 Illinois House, candidates for the Illinois Senate,
5 THE VIDEOGRAPHER: It's up to you. 5 candidates for the United States Congress.
6 MR. PERAICA: All right. Let's go for 10 6 Q Any others?
7 minutes, and then we'll take a break if that's okay 7 A Not that I can remember at this time.
8 with everyone? 8 Q What about the administrative duties, those
9 MR. SULLIVAN: Absolutely fine with me. 9 would be political functions, but do you have any
10 MR. PERAICA: Thank you, sir. 10 administrative responsibilities as a Chairman of the
11 BY MR. PERAICA: 11 Democratic -- State of Illinois Democratic Party?
12 Q So you don't have this kind of a joint 12 A To the extent that you are coordinating
13 arrangement with, for example, Bedford Park or Burbank 13 campaigns, working with other campaigns to the extent
14 or Chicago Ridge or any other municipalities in the 14 that you're required to file reports disclosure
15 Third Congressional District, do you? 15 reports.
16 A The answer is yes. 16 Q Who would do that for you as Chairman of
17 Q Which ones? 17 the State Democratic Party?
18 A No, you're correct. You said I don't have 18 A Historically, Tim Mapes would do that.
19 that arrangement. The answer is I do not have the 19 Q Now, Tim Mapes has --
20 arrangement. 20 A Resigned.
21 Q Thank you. 21 Q Resigned and retired?
22 When were you elected the Chairman of 22 A Resigned.
23 the Democratic Party of Illinois? 23 Q Resigned.
24 A Tony, I don't remember the exact date. 24 Did you force Tim Mapes to resign?
Page 79 Page 81
1 You could probably understand -- 1 A I told him to submit his resignation.
2 Q I have information that it was in 1998, 2 Q And he did?
3 would that be about right? 3 A He did.
4 A Right. 4 Q And you accepted it?
5 Q So about 20 years now? 5 A I did.
6 A Maybe more than 20 years. It's one of 6 Q So who is the Executive Director of the
7 those situations where you have so much fun you forget 7 Illinois Democratic Party now?
8 things. 8 A There's a interim Executive Director named
9 Q Yeah. Okay. We talked about your role as 9 Christian Mitchell. He's a State Representative.
10 a 13th Ward Democratic Committeeman. We talked bit 10 Q Did he replace Tim Mapes?
11 about your role as a Third Congressional District State 11 A He became the interim Executive Director.
12 Central Committeeman. We talked a little bit about the 12 Q And you appointed former -- is he still a
13 role that you're in as Chairman of the Democratic Party 13 State Representative?
14 of Illinois, and I just want to ask you about that in 14 A Yes.
15 particular. 15 Q So he's serving as a State Representative
16 Besides what you already said about 16 and as interim Executive Director of the Illinois
17 naming an Executive Director or appointing an Executive 17 Democratic Party?
18 Director and participating in the filling of vacancies
18 A Yes.
19 at the State level that you talked about, what other
19 Q Why is this an interim rather than a full
20 role or position do you play or occupy as the Chairman
20 appointment as an Executive Director?
21 of the Democratic Party of Illinois?
21 A It's just a result of the circumstances
22 that existed when he was appointed as the interim
22 A You work with any Illinois Democratic which
23 Executive Director.
23 is to get involved with the Democratic Party of
24 Q When you were elected Chairman of the
24 Illinois. You work with different candidates and so
21 (Pages 78 to 81)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 82 Page 84
1 Democratic Party of Illinois, did you relocate the 1 A Upon recommendation of Alderman Quinn.
2 headquarters of the Party from Chicago to Springfield? 2 Q Does anyone else provide advice and consent
3 A I wouldn't say that I relocated the 3 or is it just Alderman Quinn?
4 headquarters. The Democratic Party of Illinois 4 A We're like you we listen to everybody.
5 maintains an office in Springfield, and it maintains an 5 Q Okay. But ultimately the call is yours as
6 office in Chicago. 6 to who would be in that position as a precinct captain?
7 Q Where is the office in Chicago for the 7 A Well, under the statute.
8 Illinois State Democratic Party? 8 Q Yeah. So you can remove someone at will if
9 A 111 West Washington. 9 you wanted to as a Democratic precinct captain?
10 Q And where is the office for the State Party 10 A The answer is yes.
11 in Springfield? 11 Q Other than you and Alderman Quinn is anyone
12 A It's at the intersection of Veterans 12 else -- well, you said Moe Zahdan would assist, other
13 Parkway and Monroe. 13 than the three of you is anyone else working on a
14 Q Besides you as the Chairman of the 14 regular basis to interact with the captains or
15 Democratic Party and your appointed interim Executive 15 administer the 13th Ward Regular Democratic
16 Director Representative of Christian Mitchell, are 16 Organization?
17 there any other individuals who serve in administrative 17 MR. KASPER: Excuse me. Tony, are you
18 functions at State of Illinois Democratic Party? 18 talking about now?
19 A Yes, there's a Mary Morrisey who is the 19 MR. PERAICA: I'm talking about the period
20 Chief Operating Officer, and there's an Emily Wurth 20 during April of 2015 through April of 2016.
21 W-u-r-t-h who is the Chief Finance Officer. 21 MR. KASPER: So all this -- we'll just
22 Q Any others? 22 assume that all this line of questioning is --
23 A There are other employees there, but the 23 MR. PERAICA: Yes.
24 names I've given you would be the main people. 24 MR. KASPER: -- confined to that window of
Page 83 Page 85
1 Q How many employees are there total at the 1 time?
2 both Chicago and the Springfield offices? 2 MR. PERAICA: Correct.
3 A I don't know the answer to the question, 3 THE WITNESS: Restate the question.
4 and it fluctuates so during campaigns there's more. 4 BY MR. PERAICA:
5 When you're not in a campaign season there's less. 5 Q Other than yourself, Alderman Marty Quinn,
6 Q Okay. Going to the 13th Ward Democratic 6 Moe Zahdan, who is the Ward Superintendent and Chief of
7 Organization, is there a membership requirement for 7 Staff to Quinn, anyone else working with the precinct
8 acceptance as a member of the 13th Ward Democratic 8 captains of the 13th Ward Democratic Organization on a
9 Organization? 9 regular basis?
10 A Well, we would hope that they're Democrats. 10 A During that time period that you set out?
11 Q Anything else? 11 Q Yes.
12 A There is -- the answer is no. 12 A Kevin Quinn.
13 Q So there's no membership fee or anything of 13 Q And what was Kevin Quinn's role?
14 that sort that one would have to pay? 14 A To work with and interact with the precinct
15 A The answer is yes. There is no membership 15 captains.
16 fee. 16 Q Was he a precinct captain coordinator as
17 Q Does one have to by necessity serve as a 17 one would be normally called?
18 precinct captain or assistant precinct captain or is 18 A The answer is yes.
19 that optional? 19 Q And is Kevin Quinn still with your 13th
20 A That's optional. That's a decision to be 20 Ward Democratic Organization?
21 made by the individual. 21 A No.
22 Q And the final call as to who would be the 22 Q What happened there?
23 precinct captain in any precinct in the 13th Ward is 23 A He was terminated.
24 made by you as Committeeman?
24 Q By?
22 (Pages 82 to 85)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 86 Page 88
1 A Me. 1 Quinn being a close associate and assistant in terms of
2 Q And that was your unilateral decision? 2 the work of the organization and Kevin Quinn who is
3 A Yes. 3 Marty Quinn's brother, is that correct?
4 Q And why did you terminate him? 4 A That's correct.
5 A Because of wrongdoing on his part. 5 Q Being a precinct captain coordinator, would
6 Q And the wrongdoing would be what? 6 any other individuals besides them -- besides you and
7 MR. KASPER: Objection. 7 Marty and Kevin Quinn who worked as coordinators or
8 MR. VAUGHT: I will object this is outside 8 leaders of the 13th Ward Democratic Organization?
9 of the scope. This was post April 2016. It's not 9 A During that period of time?
10 relevant to this lawsuit. 10 Q Correct.
11 BY MR. PERAICA: 11 A Those are the two that I would know of.
12 Q Well, did it have to do with his work on 12 Q Does Moe Zahdan have a particular role
13 the political front for you as a Committeeman? 13 within the 13th Ward Democratic Organization either
14 A The answer to that question is no. 14 loosely assigned or a structure?
15 Q Did it have to do with his outside 15 A He would work with Alderman Quinn in terms
16 activities outside of the 13th Ward Democratic 16 of coordinating activities of Members of the Ward
17 Organization? 17 Organization.
18 MR. KASPER: Objection. 18 Q So who -- since you don't deal with the
19 MR. PERAICA: Yes. 19 precinct captains directly, who would report to you as
20 MR. KASPER: That by itself proves that 20 to any concerns that they would have?
21 it's outside the scope of the deposition. 21 A Alderman Quinn.
22 MR. PERAICA: During that period. 22 Q Does Moe Zahdan report to Alderman Quinn
23 MR. KASPER: This is not covered by the 23 who then reports to you or does Moe Zahdan report
24 scope of the deposition. 24 directly to you?
Page 87 Page 89
1 MR. PERAICA: What paragraph are you 1 A Moe does not report directly to me.
2 referring to? 2 Q So he would go through Alderman Marty
3 MR. VAUGHT: 2(d). 3 Quinn?
4 MR. PERAICA: Well, let's take a break, if 4 A That's correct.
5 we may at this point, and we'll come back with that 5 Q Does Kevin Quinn report directly to you or
6 question. 6 does he go through his brother Marty Quinn?
7 THE VIDEOGRAPHER: This is the end of Tape 7 A Kevin Quinn has been terminated.
8 1. We're off the record at 12:32. 8 Q I know while he worked.
9 9 A He would have reported to his brother.
10 (WHEREUPON, a break was had.) 10 Q Marty Quinn?
11 11 A Yes.
12 MR. PERAICA: Back on the record. 12 Q As I was looking at the D-2s for payment
13 THE VIDEOGRAPHER: Tape 2 back on the 13 made to the political workers and operatives, there was
14 record at 12:51. 14 a distinction between a merit pay and a bonus pay, are
15 15 you familiar with that?
16 (WHEREUPON, the deposition of 16 A I'm familiar with payments made to people
17 Michael J. Madigan was 17 for political work without regard to the adjective that
18 resumed.) 18 you used.
19 19 Q So did the 13th Ward Democratic
20 BY MR. PERAICA: 20 Organization pay precinct captains bonus money for
21 Q Mr. Madigan, we were talking about the 21 political work?
22 structure that you had at the 13th Ward Democratic 22 A The answer is yes.
23 Organization at 6500 South Pulaski, and you mentioned 23 Q And what would be the criteria to qualify
24 in addition to yourself as Committeeman, Alderman Marty 24 for receiving a bonus pay?
23 (Pages 86 to 89)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 90 Page 92
1 A That would be a recommendation by Alderman 1 A I'm the named beneficiary on the title, and
2 Quinn. 2 I make spending decisions.
3 Q And that's the only basis that you would 3 Q Are you the chairman of that committee?
4 have to determine whether to give someone a bonus or 4 A I'm not sure of the legal titles associated
5 not? 5 with the committee.
6 A The recommendation of Alderman Quinn. 6 Q Is it fair to say that no moneys get spent
7 Q What would Alderman Quinn use as a 7 from Friends of Michael J. Madigan Committee unless you
8 criteria, is there some certain test that would have to 8 approve it?
9 be met? 9 A The answer is yes.
10 A I wouldn't have the answer to that. 10 Q Is this strictly a vehicle for donations or
11 Q All right. What about the merit pay, do 11 is there an organizational structure in this committee?
12 you know -- 12 A This committee would be for spending
13 A I think the merit pay and the bonus pay are 13 purposes.
14 the same. 14 Q So does it have an office as such?
15 Q I saw throughout the D-2's verbiage used, 15 A No.
16 you know, best efforts, does that relate to being able 16 Q Does it have any staff, Friends of
17 to, if you know, does that relate to their best efforts 17 Michael J. Madigan Committee, does it have any staff?
18 on -- in that particular reporting cycle when that D-2 18 A Not on a formal basis.
19 was filed or is that simply that you didn't have an 19 Q As needed part time?
20 address for that person and couldn't locate it or do 20 A That's a good way to say it.
21 you know what that means? 21 Q Do you have any independent contractors
22 A I have no idea what it means. 22 that work for the committee?
23 Q Are the moneys that the 13th Ward 23 A Well, we may.
24 Democratic Organization raises spent outside of the 24 Q Again, as needed during elections?
Page 91 Page 93
1 13th Ward? 1 A As needed, sure.
2 A They could be. 2 Q Besides yourself as the person with sole
3 Q So that would be your discretion? 3 discretion for expenditure of funds from Friends of
4 A The answer is yes. 4 Michael J. Madigan, does anyone else have any either
5 Q In other words, you can go to any area of 5 reporting function or any other function besides
6 the 22nd District that you represent and spend money 6 yourself?
7 from the 13th Ward Democratic Organization? 7 A In terms of preparing the disclosure
8 A The answer is yes. 8 reports?
9 Q Committee called Friends of Michael J. 9 Q Yes.
10 Madigan, are you familiar with that? 10 A Well, Emily Wurth who's been mentioned
11 A Yes, I am. 11 already would do that.
12 Q And do you know when was that committee 12 Q She would be the Chief Financial Officer of
13 formed approximately? 13 sorts?
14 A Tony, I have no idea. 14 A That's a fair characterization.
15 Q Has it been in existence for a decade or 15 Q Other than Emily Wurth and yourself, anyone
16 two? 16 else?
17 A It's been existence for multiple years. 17 A At one time Tim Mapes.
18 Q Is it still in existence? 18 Q What was Tim Mapes' role before he resigned
19 A Yes it is. 19 with respect to Friends of Michael J. Madigan?
20 Q Was it in existence during the period 20 A He would have been the significant manager
21 leading up to the March 2016 Primary? 21 of that account.
22 A The answer is yes. 22 Q Would Tim Mapes have to during his tenure
23 Q And what role do you play in that
23 with Friends of Michael J. Madigan get your permission
24 committee?
24 for expenditure of funds from that committee?
24 (Pages 90 to 93)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 94 Page 96
1 A More or less, more or less. 1 Friends of Michael J. Madigan only donated money to
2 Q Did you as a matter of practice or policy 2 Democratic candidates at Stale level or below?
3 have any limits up to which he could spend without 3 A Well, as a general rule it supports
4 checking with you and over a certain amount he would 4 Democrats. There may be some Republicans that receive
5 have to check with you? 5 support from that committee. I wouldn't remember at
6 A The answer is no, but he would bring to me 6 this time.
7 significant on spending. 7 Q I couldn't find any, but...
8 Q All right. Anyone else involved during the 8 A You didn't get any checks?
9 existence of that committee besides yourself, Emily 9 Q No.
10 Wurth, Tim Mapes? 10 Do you inform donors or potential
11 A Not that I can remember. 11 donors that funds that are donated to Friends of
12 Q Any reporting in terms of expenditures of 12 Michael J. Madigan may be used for other than your
13 Friends of Michael J. Madigan Committee where the terms 13 various offices that you run for?
14 of merit and bonus are used in the description of 14 A The answer is no.
15 payment to individuals who did work on behalf of the 15 Q Do you inform donors or potential donors
16 committee, would your answer be the same as it was 16 that you will provide funding for Democratic or other
17 before that those would be interchangeable? 17 candidates down the ballot who have nothing to do with
18 A Yes. 18 your district or your ward where you serve as a
19 Q Yes? 19 Democratic Committeeman, meaning, their even outside of
20 A Yes. 20 Cook County?
21 Q Besides supporting your election 21 MR. KASPER: Objection, Tony. I think this
22 efforts -- well, let me strike that question. 22 is beyond the scope of the deposition.
23 Did the Friends of Michael J. Madigan 23 Again, in Paragraph 2(d) "Plaintiff
24 support your re-election activities in the 22nd House 24 shall not question Defendant Madigan regarding the
Page 95 Page 97
1 District? 1 current structure, actions and\or operations of any
2 A The answer is yes. 2 political organizations."
3 Q Did the Friends of Michael J. Madigan 3 MR. PERAICA: Okay. You're right.
4 support your activities for election as a Third 4 BY MR. PERAICA:
5 Congressional District State Central Committeeman? 5 Q So looking at the period of April 2015
6 A I believe the answer is yes. 6 through April of 2016, did Friends of Michael J.
7 Q Did the Friends of Michael J. Madigan 7 Madigan Committee financially support candidates during
8 Committee support your efforts as a State Party 8 that election cycle other than yourself?
9 Chairman? 9 A I don't remember, but I would presume that
10 A Yes. 10 it did.
11 Q Did you also from this Friends of Michael 11 Q Are there any other political organizations
12 J. Madigan Committee support candidacies of other 12 that you belong to other than what we have discussed so
13 individuals? 13 far?
14 A The answer is yes. 14 A Organizations?
15 Q Would that be at the State and Local level 15 Q Political organizations.
16 Congressional level or all of the levels? 16 A Political organizations?
17 A It would not be -- that particular 17 Q Right.
18 committee would not be supportive of Congressional 18 A What did we talk about the 13th Ward
19 candidates because that's a blended committee. For the 19 Organization and --
20 Congressional candidates you need, as you know, Federal 20 Q 13th Ward, Third District, State Democratic
21 hard money. But that committee would be involved with 21 Party, any other political organizations?
22 candidates for State office, candidates for the 22 A I don't think so. I think it's 13th Ward
23 legislature. 23 Democratic Organization, Cook County Central Committee,
24 Q And is it fair to say that that committee, 24 State Central Committee.
25 (Pages 94 to 97)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 98 Page 100
1 Q Are you a member of any national political 1 Alderman who is paid by the City of Chicago, you have
2 committees? 2 his Ward Superintendent present at your office at
3 A I'm a member of the Democratic National 3 6500 South Pulaski paid for by the taxpayers of the
4 Committee because the Chair of the State Party is 4 City of Chicago, how do you distinguish their, and how
5 automatically a member of the DNC. 5 do they segregate their political functions from their
6 Q Do you serve on any particular committee or 6 governmental functions?
7 are you a member at large or what's the -- 7 A In the case of Moe Zahdan, he would only be
8 A At the DNC? 8 at the political offices at 6500 South Pulaski when
9 Q Yes. 9 he's not on the City payroll, so he would come there
10 A I'm simply a member. 10 after work.
11 Q How often do you participate in meetings at 11 In the case of the alderman, he's an
12 the DNC, Democratic National Committee? 12 elected official, and he apportions his time as he
13 A Very seldom. 13 deems best.
14 Q Is it once every two years with the 14 Q You would agree that one is not to use
15 congressional elections or less than that or? 15 government resources for political purposes, right?
16 A It might be more than that. 16 A The answer is yes.
17 Q More than that. Annually? 17 Q So in the apportionment of time whether for
18 A As a general rule, I don't attend their 18 yourself or these other individuals that work closely
19 meetings. 19 with you, do you enforce that segregation between the
20 Q Are you in any leadership position there at 20 governmental and political work?
21 the DNC, just asking? 21 A That's a rule that we operate under. Let
22 A Well, do you think they do that for me if I 22 me speak for myself. All right? So I have certain
23 don't go to their meetings? 23 obligations as a State Representative, as the Speaker,
24 Q It happens, yes. 24 and I fulfill those obligations. I give whatever time
26 (Pages 98 to 101)
CAUSLEY COURT REPORTING
(708) 989-0509
Michael J. Madigan
September 13, 2018
Page 102 Page 104
1 Q Are there any other elected officials who 1 conversion date than a later one.
2 have that office? 2 Q So I'm asking you as a matter of policy
3 A No. 3 since you're the guy who sets policy there, is it a
4 Q Just the two of you? 4 month before the Primary Election, is it three months
5 A Yes. 5 before, six months before, when?
6 Q And then Alderman Quinn's support staff 6 A I don't have the exact answer for you. I
7 Moe Zahdan has his office there? 7 can go back and check our records.
8 A Well, Moe occupies one of the offices that 8 Q If you would.
9 you're referring to in the southern part of the suite. 9 A We would. But let me repeat, we're going
10 Q Okay. 10 to exercise caution. If we're going to err on the side
11 A When he's there. 11 of caution, they have a longer date rather than a
12 Q Right. 12 shorter date.
13 A Now, again, he's only there when he 13 Q Are the telephones outside of your office
14 finishes his work with the City. 14 at the northern end of the Balzekas building at
15 Q Right. And is that paid for by the City, 15 6500 South Pulaski, are those outside phones paid for
16 that office or is it paid for by someone else? 16 by you or the taxpayers?
17 A Well, in certain times it's paid for either 17 A For the telephones in the office, when
18 by the City or the State. When we get into a heavy 18 we're not in campaign season some are paid for by the
19 political season, it's paid for with campaign money. 19 City of Chicago, some are paid for by the State of
20 Q So how do you actually keep track of what 20 Illinois. There's a line in my office that I pay for
21 it is being used for on any particular day? 21 personally. Once we get to campaign season everything
22 A We operate with a great deal of caution so 22 is converted to campaign payments.
23 when it gets -- when we're moving into the busy 23 Q When I questioned Alderman Silvana Tabares,
24 political campaign season, all the payments are done 24 who I believe at that time was still State
Page 259
1 STATE OF ILLINOIS )
)
2 COUNTY OF C O O K )
3 I, Kimberly E. Causley, Certified Shorthand Reporter
4 and Notary Public in and for the County of Cook, State
5 of Illinois, do hereby certify that on the 13th day of
6 September at 11:00 p.m., the discovery deposition of,
7 MICHAEL J. MADIGAN, was taken before me, reported
8 stenographically and as thereafter reduced to
9 typewritten form under my direction and control.
10 The deposition was to be taken at 151 North
11 Franklin Street, Chicago, Illinois, and there were
12 present Counsel as previously set forth.
13 The said witness, MICHAEL J. MADIGAN, was first
14 duly sworn to tell the truth, the whole truth and
15 nothing but the truth, and was then examined upon oral
16 interrogatories.
17 I further certify that the foregoing is a true,
18 accurate and complete record of the questions asked of
19 and answers made by the said witness MICHAEL J.
20 MADIGAN, at the time and place herinabove referred to.
21 The undersigned is not interested in the within
22 case, nor of kin or Counsel to any of the parties.
23
24
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