IN THE CIRCUIT COURT OF THE TWENTY-SECOND JUDICIAL DISTRICT,
MCHENRY COUNTY, ILLINOIS
PEOPLE OF THE STATE OF ILLINOIS, )
Plaintift ) -
v } No. 16MR /7 Qe
)
) Fling ry
Certain Individual Members of the ) lar 1
Mcllenry County Board, ) 7 206
Defendants ) NE we
NT OF JAL PROSECUTOR
NOW COME the People of the State of Illinois, by their attorney, LOUIS A. BIANCHI,
McHenry County’s State’s Attomey, through Michael Combs, duly appointed Assistant State’s
Attomey, and pursuant to 55 ILCS 5/3-9008 moves for the appointment of a special prosecutor in
this case. In further support of the motion, the People state the following:
1. State Representative Jack Franks has written a letter to the State’s Attorney questioning
the legality of certain McHenry County Board Members claiming eligibility for IMRF pension
benefits. (The letter and the attachments to Franks’ letter are attached as Exhibit A). In his
correspondence, Representative Franks alleges that members of the board who have certified under
oath that they have worked at least 1,000 hours per year have potentially committed perjury.
Representative Franks believes that a crime may have been committed by members of the County
Board, and he believes this matter needs to be investigated and, if necessary, prosecuted.
2. The State's Attorney statutorily serves as legal counsel for the County. Therefore, an
actual conflict of interest prevents the State's Attorney ftom investigating or prosecuting this
matter. .
3. The State's Attomey has consulted with the Officg af hg Ug TAAGMERMERABecut0r
FOR
sand requested if it could investigate whether