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had deleted critical financial documents as she was about to be exposed by various
the heart of defendant's defense that Spizzirri had a motive to claim that Melongo
These false statements are relevant not only to Spizzirri's credibility but go to
certain prominent politicians like Gerry Chico and his wife sat SALF's board of
interviews, and even sworn grant applications; and (3) she falsely claimed that
as acollege graduate and Renal Transplant nurse in written materials, news
her non-for-profit Save A life Foundation; (2) she falsely represented her credentials
Spizzirri on whether: (1) she repeatedly lied and misrepresented the motivation of
1. To permit cross examination of the State's key witness Carol
BONJ EANand moves this court in limine as to the following:
NOWCOMES,ANNABEL MELONGO,by and through her attorney, J ENNIFER
OMNIBUS MOTION IN LIMINE
Steven J . Goebel
J udge Presiding.
PEOPLE OF THE STATE OF ILLINOIS,
, I( 08 CR 10502
IN THE CIRCUIT COURT OF COOK COUNTY
was attempting to bring SALF national and was applying for federal money. Indeed,
investigative series by Chuck Goudie of ABC7 News. Also, around that time, Spizzirri
fabrications were uncovered by various news outlets, including a 4-part
Defendant (and another SALF) employee of computer tampering, Spizzirri's
Critically, in fall of 2006, exactly around the time that Spizzirri accused
registered nurse, and had never worked in a renal transplant unit.
Furthermore, records show that Spizzirri did not even graduate college, was not a
In other words, Spizzirri's entire foundation was premised on lie.
road and not as a result of first responders unwillingness or inability to conduct life
Further, these records show that Christina died in a hospital NOT on the side of the
result of a single-car accident in which she was the sale driver and intoxicated.
Christina's medical records and death certificate prove that Christina died as a
Specifically police reports, the findings from a coroner's inquest, and
and tax payers were complete fabrications.
unit. These misrepresentations which were designed to raise money from donors
Science and that she was a registered nurse who had worked in a renal transplant
sworn federal grant application that her highest level of education was a Bachelor of
Spizzirri repeatedly represented in SALF publications, articles, and even on a
The Save a Life Foundation ("SALF") '" was founded in 1993 by Carol Spizzirri, RN,
after her 18 year old daughter, Christina J ean Spizzirri, bled to death following a hit
and run incident on Labor Day, 1992. First responders were not trained in life
supporting first aid skills, and consequently stood by helplessly waiting for
Emergency Medical Service (EMS) arrive some 30 minutes later.
Specifically, SALF's Annual Reports and website states the following:
after the Chuck Goudie series ran, the Federal Homeland Security told Spizzirri that
she would have to respond to these claims before receiving any federal money.
This evidence is critical not only because it goes directly to Spizzirri's
credibility and bias but more importantly, supports Defendant's defense that
Spizzirri falsified the charges of computer tampering and actually deleted and
altered SALF's financial records HERSELF in an effort to destroy evidence of
To this day, the Attorney General continues to investigate Spizzirri and
SALF's practices and for filing misleading annual reports. Indeed, Illinois State
Senator Tim Bivens has led the charge to see that Spizzirri and SALF exposed and
that tax payers money is returned.
2. To permit cross-examination of Spizzirri on whether she was forced
to undergo a psychological examination in a family court proceeding that resulted in
the findings that she is a paranoid schizophrenic, a pathological liar, and chronic
child abuser. And to cross-examine Spizzirri on whether she wrote a letter to her
ex-husband admitting to be a liar and threatening to kill herself and their children.
3. To permit cross-examination of Spizzirri on whether she failed to
return funds to the Village of Carpentsville that did not rightfully belong to her.
Former Fire Chief J ohn A Schuldt is prepared to testify that despite numerous efforts
to have unused funds returned to Carpentsville, Spizzirri refused to return the fund
or provide any explanation for failure to return the funds.
J ENNIFER ,BONJ EAN
7. To preclude the State from eliciting testimony from Detective Martin
that Ms. Melongo had been accused of sending "x-rated" emails to a Professor at the
University of Missouri in Kansas City. Such testimony is rank hearsay, was never
charged or proven and would be designed solely to prejudice Ms. Melongo.
4. To cross-examine Spizzirri on whether she wrote to her "close
personal friend" former Cook Count State's Attonrey that Schiller Park Police had
concluded that Melongo had stolen a SALF American Express credit card and made
unauthorized purchases on that card - a complete and utter false statement.
5. To cross examine Spizzirri about her prior shop lifting convictions and
any other convictions that the State has yet to provide to the defense.
6. To preclude the State from eliciting hearsay testimony from Detective