BOND PROFFER

CHARGE: ATTEMPT MURDER/PEACE OFFICER (720 ILCS 5/8-4(a) (720 ILCS 5/9-
1(b)(1)) (Class X)

AGGRAVATED BATTERY/PEACE OFFICER/FIREARM (720 ILCS 5/12-3.05(e)(2)) (Cl X)

AGGRAVATED UNLAWFUL RESTRAINT (720 ILCS 5/10-3.1(a)) (CLASS 3)

AGGRAVATED ASSAULT/PEACE OFFICER (720 ILCS 5/12-2(c)(6)) (CLASS 4)

DEFENDANT: Dragan Volodymyr, Age 43 (DOB: 5/8/76)

Date, Time, Location: 8/15/19 at approximately 1:30 a.m., I-294 N/B, mile post 46.75,
Glenview, Illinois

Date, Time, Location: 8/15/19 at approximately 6:00 p.m. 407 Hickory Drive, Wheeling IL

VICTIM 1: IL State Trooper

VICTIM 2: IL State Trooper

The People expect the evidence to show:

At approximately 1:30 a.m., D’s motorcycle was curbed for speeding by V1, an IL State
Trooper. V1 called in the license plate registration prior to making contact with D. Upon
approach, D could not provide proof of insurance at which time D began acting nervous and
uneasy. At this time, V1 learned D had an active arrest warrant and escorted D to the back of
V1’s squad car. V1 did not handcuff or search D prior to placing the D in the rear of V1’s squad
car. V1 returned to the front seat of the squad car and waited for confirmation of D’s warrant.
The warrant was confirmed over dispatch.

While in V1’s squad car, D continued to act nervous and uneasy telling V1 that D cannot go to
jail. The D then attempted to open the rear passenger squad door and go back to his motorcycle
V1 began to exit the squad car and D ordered V1 to remain in the vehicle. At this time, D
retrieved a firearm and pulled the slide of the firearm to the rear to chamber a round. V1 and
W1, an assisting IL State Trooper, negotiated with D. Eventually, D acquiesced and removed
the magazine from the firearm but refused to remove the chambered round.

V1 and W1 continued to negotiate with D. D agreed to leave if V1 would roll down D’s window
so D could open the squad car door and return to D’s motorcycle. D left the scene and no one
was injured.
The incident was captured on V1’s in-squad camera. Following the incident, IL State Troopers
obtained a search warrant for D’s residence.

At approximately 6:00 p.m., IL State Police Officers, including a SWAT team, arrived at D’s
residence to execute the search warrant. At the time the search warrant was executed, IL State
Police arrived at D’s residence in marked vehicles and wore uniforms identifying themselves as
IL State Police Officers. SWAT Officers identified themselves and demanded D exit the
residence. The D refused to comply.

IL State Police Officers breached the front door of D’s residence at which time D fired 2-3
gunshots. D relocated to the basement of the residence and observed V2, an IL State Police
SWAT officer, outside the residence. At that time, D fired a single gunshot at V2 which struck
V2 in the right arm close to V2’s wrist. IL State Police applied a tourniquet and took V2 to
safety. V2 was transported to a local hospital and treated.

IL State Police continued to make entry into D’s residence at which time D walked out with his
hands on his head and a holster on. D placed in custody.

IL State Police SWAT Officers verified D was the sole occupant in the residence. IL State
Police recovered multiple 9 mm shell casings and a 9 mm handgun from the basement of D’s
residence. IL State Police recovered the motorcycle D was driving earlier that morning from D’s
garage.

D made post-Miranda admissions to riding his bike from Chicago to Wheeling when V1 curbed
him for speeding. D admitted to having a gun in the back of the squad car and admitted to using
the gun to force the officers to let him go because he did not want to go back to jail. D admitted
to pulling out the gun and racking it so officers knew he had it. D admitted to firing 2-3 shot
before officers entered his residence because he wanted to let officers know he was there. D
made admissions to knowing officers wanted him out of the house but D did not want to leave.
D made admissions to using the same gun as earlier in the night. D admitted that when he saw
V2 standing there, he wanted to hurt V2 and teach him a lesson.

IL State police provided video which captured officer’s initial breach of D’s residence and D’s
initial shots.