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IN THE CIR CU IT COURT OF COO K COUNTY COUNTY DEPARTM ENT, CRIMINAL DIVISION PEOPLE OF THE STATE OF ILLINOIS ) ) ) ) ) ) ) v. ANNABEL MELONGO Def endant -, , .' MOTlONTO OUASH SUBPOENAS No. 08CR I0502 Th e People of the State of Illinois, by and through their Attorn ey, ANITA ALV AREZ, State 's Attorney of Cook County, through her assistants, Robert Podlasek and Juli e Gunn igle. and request that this Honorable Court to quash th e Defendant's subpoena s issued to th e compla in ant, Carol Spizzirri, the Illinois Department of Publi c Health, fonner Save A Life board member Douglas Browne, and fonner Pal ati ne Mayor Rita Mullins and in support state the following: I. The Defendant haS-b een charged with three counts of Computer Tam perin g relating to her authorized access of th e Save A Life Foundati on's servers and the email accounts' 6ftheir founder, Carol Spizzirri. 2. The Defendant has issued a subpoena to Carol Spizzirri, commanding her appearance to testi fy and to bring th e foll ow in g: a. Documentation (emails, memos, faxes, documents of any kind) with description of computer events as they happened from Ap ril 2S lh _ May 1 st 2006 at Save A Life Foundation, located in Schiller Park, Illinois. This should include th e computers affected, li st of persons hired to fi x it , th e type of fil es affected, percentage of files recovered as we ll as the names of tcchnician(s) recovering the fil es. b. ALL communication(s) (emails, memos, fa xes, doc um ents of any kind) yo u have in yo ur possession regarding the above cited computer events. Communications should be, am ong other [sic], exchanges wit h th e Illinois Schiller Park Police department, th e Illinois Attorney General, Brian

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IN THE CIRCUIT COURT OF COOK COUNTY COUNTY DEPARTM ENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS ) ) ) ) ) ) )

v.

ANNABEL MELONGO Defendant -,

, .' MOTlONTO OUASH SUBPOENAS

No. 08CR I 0502

The People of the State of Illinois, by and through thei r Attorney, ANITA

ALV AREZ, State 's Attorney of Cook County, through her assistants, Robert Podlasek

and Julie Gunnigle. and request that this Honorable Court to quash the Defendant's

subpoenas issued to the complainant, Carol Spizzirri , the Illinois Department of Public

Health, fonner Save A Life board member Douglas Browne, and fonner Palatine Mayor

Rita Mullins and in support state the following:

I. The Defendant haS-been charged with three counts of Computer Tampering

relating to her authorized access of the Save A Life Foundation' s servers and the

email accounts '6ftheir founder, Carol Spizzirri .

2. The Defendant has issued a subpoena to Carol Spizzirri , commanding her

appearance to testi fy and to bring the following:

a. Documentation (emails, memos, faxes, documents of any kind) with description o f computer events as they happened from April 2Slh

_ May 1st

2006 at Save A Life Foundation, located in Schiller Park, Illinois. This should include the computers affected, li st of persons hired to fi x it, the type of files affected, percentage of files recovered as we ll as the names of tcchnician(s) recovering the files.

b. ALL communication(s) (emails, memos, faxes, documents of any kind) yo u have in your possession regarding the above cited computer events. Communications should be, among other [sic], exchanges with the Illinois Schiller Park Police department, the Illinois Attorney Genera l, Brian

Salerno, Don Peters, Dick Devine, any personnel at the Illinois Attorney General office and ALL Save A Life Foundation fonner employees on the incident.

c. Documentation (emails, memos, faxes, documents of any kind) on why Christian Sass was fired by Save A Life Foundation. Also provide

\. documentation on the state of the network, Scantron after the Defendant, Annabel Melongo left the company.

d. Documentation (emails, memos, faxes, documents of any kind) describing the Schiller Park Polic~ Department investigation. Description should include the name ofpoiice officer(s) that came to SALF to take report [sic] , name of the police investigator and the specific questions asked. Names ofindividual(s) having gone to the Schiller Park Police building as part of the investigation. Letter Commanding Schiller Park's Detective William Martin.

e. List contact infonnation (emails, fax, address, phone) of ALL experts hired for the computed incident that occurred in April 28th_May 15t 2006 at Save A Life Foundation headquarters in Schiller Park, Illinois. Also provided [sic] bills, invoices as well as copies of checks or bank statements reSUlting from their services.

f. ALL copies of pay stubs issued to you by Save A Life Foundation during the years 2005, 2006, 2007. Ifnot available, copies of back statements showing d&posits being made.

g. Documentation (emails, memos, faxes, documents of any kind) on individual(s) that were instrumental in helping Save A Life Foundation be in Illinois' state budget and in providing funds for SALF Springfield's office.

h. All documentation (emails, memos, faxes, documents of any kind) showing eannarks/money received from CDC (Center of Disease Control), DoD (Department of Defense), National Guard, Chicago Public Schools, Homeland Security, FEMA.

1. Contact infonnation (address, fax, phone, email) on all companies having audited Save A Life Foundation over the years. The infonnation should include the start and end date(s) for each company.

J. Provide ENTIRE personnel files of the following employees: Christian Sass, Dave Stolerow, Saquan Gholar, Bob Cokinis, Vince Davis, Robert Barnes, Dane Neal, Alfredo Salgado, Linda B. Reyna. Also provide ALL copies of checks/proof of salary issued to those employees.

k. Provide copies of the two checks given to Defendant, Annabel Melongo as [sic] result of her services at Save A Life Foundation, Inc.

1. Provide name of temporary agency that employed Anne Rickert who is mentioned in 1he attached ABC investigative report's transcript, Attached Exhibit' A. ' .

m. Provide all documentation (emails, memos, faxes, letters, bills, invoices, checks issued, financ'UlI records, documents of any kind) pertaining to Hogan & Hartson LI?~as part of its governmental consulting services as stated in your 2005 and 2006 auditing reports, Attached Exhibit "B."

n. Provide ALL documents (recovery recipes, payments to experts, expenses, recipes/invoices of any kind) showing proof of the financial lost [ sic] of $1.000.000 due to the computer's incident [sic] as stated in the May 2008, Grand Jury.

o. Provide documentation (emails, memos, faxes, letters, financial records, documents of any kind) for the donation in the amount of $25,000 by the Illinois Attorney General to Save A Life Foundation, Inc. Attached Exhibit "C"

3. To warrant the us~ ofa pre-trial subpoena, the Defendant must show l)Jhat the ,; .. ,

documents requested are evidentiary and relevant; 2) that the documents are not

otherwise procufable reasonably in the advance of trial by exercise of due

diligence; 3) that she cannot properly prepare for trial without the production and

that failure to obtain the documents may tend to unreasonably delay trial; and 4)

that the application is made in good faith and is not intended as a general "fishing

expedition." People v. Daniels, 805 N.E.2d 1206 (Ill. App. 2004). The Defendant

has not made such a showing.

4. A pretrial subpoena must comply with all four elements to be validly issued. A

reading of the subpoena issued by the Defendant in this case clearly shows a

fishing expedition and the fact that the subpoena was not issued in good faith.

Specifically, her requests include the entire personnel files of individuals not

involved in the incident, the pay stubs or bank account records of the alleged

victim, and the results of any audit ever performed for Save A Life Foundation

\.

(SALF). These documents are wholly unrelated to the charges against the

Defendant.

5. Further, even in the event that'these documents might have evidentiary value, the ~

Defendant has not demonstrated that these documents are not otherwise

procurable reasonably in advance of trial by the exercise of due diligence.

Through the discovery process the Defendant had been provided with the some of

information she has requested, including the names of individuals working to

recover data at SALF, the types of files affected, and the names of the police

investigators who came to SALF to take the report. Asking the victim in this case

to recreate information the Defendant already has is unreasonable, duplicative, ::.

and not made in good faith.

6. The Defendant has made similar unreasonable demands of the Illinois Department

of Health (EXHIBIT B), former SALF board member Douglas Browne

(EXHIBIT C), and former Palatine Mayor Rita Mullins. The Defendant demands,

among other items, all communications, purchase orders, and invoices between

SALF and the Department of Health, Mr. Browne's pay stubs, and all

documentation "instrumental in helping Save A Life Foundation be in Illinois

budget." (EXHIBIT C, item 5).

7. These requests are unrelated to the investigation of computer intrusion at the Save

A Life Foundation. Mr. Browne, Ms. Mullins, and the Illinois Department of

Public Health were not involved in the day to day operations ofSALF. The

Defendant has not demonstrated that these documents are evident iary, relevant,

and requested in good faith. ,

8. The Defendant's subpoenas also command the appearance of Douglas Browne,

who is currently residing in Georgia, and the appearance of the Illinois

Department of Health in Springfield. Before these witnesses travel to Cook , , County at considerable inconvenience and personal expense, the People request

an opportunity to be heard on this matter.

9. Additionally, the State has not been served notice of any of the subpoenas and

requests both notice and an opportunity to be heard on all outstanding subpoenas

and future subpoenas issued by the Defendant.

Wherefore, the People of the Stale of Illinois ask that this Honorable Court

quash the subpoenas issued by the Defendant or, in the altemative, set this mailer

for hearing at st;lch a time before such appearances are commanded. ,

Jul e sistant State's Attorney

CERTIFICATE OF SERVICE

I, the undersigned, state that I have served the attached Motion to Quash upon: Annabel Melongo P.O. Box 1537 Addison, lL 6~10 1

by mai ling it first class mail . with sufficient postage attached thi s 21 st day of February, 20 10. Per the Defendant 's request, she was notified at 630·220A132 that a paper copy was available at the State's Attomey's Office.

" , >

IN THE CIRCUIT COURT OF COOK COUNlY, ILLINOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

.. PEOPLE OF THE STATE OF ILLINOIS, )

Plaintiff,

v. No. 08 CR-l0S02

ANNABEL K. MELONGO

Defendant;

Subpoena puces Tecum . TO: Carol Spizzirri

17479 Dartmoor Court,

Grayslake, IL 60030

Telephone: 847-366-1124

YOU ARE COMMANDED to appear to testify before the Honorable Judge Mary M. Brosnahan

In Room 303, 2650 S. California Ave. , Chicago, Illinois on March 3rd 2010, at 9.30 am.

YOU ARE COMMANDED ALSO to bring the following:

1. Oocumentation( emails, memos, faxes, documents of any kind) with description of computer events as lfreynappene-n-fro~rll-Z8th-·May ~~OOoatsave-P;Ltfe FtJl.ma~tlan.'ocatediti Schiller Park, Illinois. This should include the computers affected, list of persons hired to fix It, the type of files affected, percentage of flies recovered as well as the names of technlc:ian(s) recovering the ftlf!C

2. ALL communicatlon(s) ( emails, memos, faxes, documents of any kind ) you have in your possession regarding the above cited computer events. Communications should be, among other. exchanges with Jhe Illinois Schiller Park Pollee departmeflt. the Illinois Attorney General, Brian Salerno, Don Peters, Dic:k Devine .. any p~rsonnel at the Illinois Attorney General office and ALL Save A Ufe Foundation former employees on the incident.

ExhihitA

3. Documentation( emails, memos, faxes, documents of any kind) on why Christian Sass was fired by Save A life Foundation. Also provide documentation on the state of the network, Scantron

after the Defendant, Annabel Melongo, left the company.

4. Documentatlon( emails, meln1os, faxes, documents of any kind) describing the Schiller Park Police Department investigation. Description should include name of police officer(s} that came to SAlF to take report, name of the police Investigator and the speclfic Questions asked. Names of individual(s) having gone to the Schiller Park Police building as part afthe investigation. Letter

Commanding Sc:hlller Park's Detective William Martin. ~I

5. list contact information ( email, fa~ ~ddress, phone) of ALL expens hired for the computer incident that occurred in April 281h

- May lH 2006 at Save A l.lfe Foundation headquarters In Schiller Park, Illinois. Also provided bills, invokes as well as copies of thecks or bank statements

resulting from their services.

6. All copies of pay stubs issued to you by Save A Ufe Foundation during the years 200S, 2006, 2007. If not available, copies of back statements showing deposits being made.

7. Documentation( emails, memos, faxes, documents of any kind) an individual(s) that were instrumental in helping Save A Ufe Foundation be in Illinois' state budget and in providing funds for SAlF Springfield's office. .

8. ALL documentation ( emaHs, memos, faxes, letters, documents of any kind) showing earmarks/money received from CDC ( Center Of Disease Control ), DoD ( Department Of Defense), National Guard, Chicago Public Schools, Homeland Security, FEMA.

9. Contad information( ,ddress, fax, phone, email) on all companies having audited Save A life ., ~.

Foundation over the ~a~s. The information should include the start and end date(s) for each company.

10. Provide ENTIRE personnel files of the following employees: Christian Sass, Dave Stolerow, Saquan Gholar, BobCokinis, Vince Davis, Robert Barnes, Dane Neal, Alfredo Salgado, Linda B. Reyna. Also provide All copies of checks/proof of salary issued to those employees.

11. Provide copies of the two checks given to Defendant, Annabel Melongo as result of her services at Save A Life Foundation, Inc.

12. Provide name oftemporary agency that employed Anne Rickert who is mentioned in the attached ABC investigative report's transcript, Attached Exhibit 'A'.

13. Provide all documentation( emails, memos, faxes, letters, bills, Invoices, checks issued, financial records, documents of any kind) pertaining to Hogan & Hartson LLP as part of its governmental consulting services as stated In your 2005 and 2006 auditing reports, Attached Exhibit "8".

14. Provide All documents ( recovery recipes, payments to experts, expenses; recipes/invoices of any kind) showing proof of the financial lost of $ 1.000.000 due to tile computer's Incident as stated In the May 2008, Grand Jury.

15. Provide dcxumentation( emails, memos, faxes, letters, financial records, documents of any kind) for the donation in the amount of $25,000 by the Illinois Attorney Genera I to Save A life Foundation, Inc. Attached Exhibit "e"

YOUR FAIWRE TO APPEAR IN RESpONSE TO THIS SUBPOENA WIU SUBJECT YOU TO PUNISHMENT FOil

CONTEMPT OF THIS COURT.

Atty. No. 99S00

Name: Annabel MelanIa

Address ; P.O. Box 1537

City/State/ Zip: Addison, Il60'191 .'.\

Telephone: 630-220-4132

\

.. , , . . WIT~ES~. _~~~

Dat. J _ /).~~/O

Annabel Melongo
Text Box

~ 0 Cbicggo Area Jobs o Cl!l!l5ifieds o .Get C94DOns

, i i

--1

News

Save-A-Life's main government funding may be drying up Thursday, May 31, 2007

.~

.- !I!n!

.. Report a typo : .

.II Chuck Goudie More: l!iQ, Facebook, Twitter, News Team By Chuck Goudie

~I

May 30, 2007 (WLS) -- New details emerge about the embattled JIIinois charity The Save-A-Life Foundation -- and why it may be losing funding and political support.

The I-Team investigation of Save-A-Ufe last year uncovered a founder who fabricated her medical credentials. Now we've learned that Save-A­Life's primary government bankroll appears to be drying up.

The Save-A-Ufe Foundation claims its instructors have taught first aid skills to more than 2 million school children in Illinois and several other States the past decade. Since 2001, Save·A-Life has received millions of dollars in state and federal funding, and has listed powerful State Senate President Emil Jones as one onts major baokers. :.'\ ' .

"I've neyer supported it funding-wise," Jon.es said.

And Jones says the charity is nOf. currently slated to receive montty in next year's state budget. The apparent cut-off of government funds follows I-Team disclosures about Save-A-Life founder CiU'Ol Spizzirri.

for years, while soliciting government funding, Spizzirri claimed to be a kidney transplant nurse and an RN. The I· Team's investigation found that the now-defunct oollege she aUendtd never awarded her a degree of any kind; and govetnment records show she has never been a registered nurse in either Wisconsin, as she told the I· Team, or in Illinois. Durlng questioning last November, Spizzirri walked out of our meeting and declined to be interviewed. fOT this report.

Over the past few years in Springfield, State Senator Donne Trotter has been the primary sponsor of funding for Save-A-Life in the IllinOis budget, last year $700,000 in taxpayer funds and another $88,000 in grant money,

"I am concerned if in fact that she is not spending the taxpayer dollars we have entrusted in her to be spent correctly. II said Trotter.

The South Side senator says that Illinois' auditor general would investigate how Save-A-Life has spent state money and fulfilled state contracts before any consideration is given to future funding.

''To me, the jury is still out, because I !Javen't seen all the results," $aid Trotter.

Both senators Trotter and Jones hllve be,," givep awards by Save-A-Life, Jones for saving someone from choking in a Springfield restaurant. Since then, Jones says he hB.$ been wrongly listed as Save-A-Life's "Illinois spokesman" ~nd that he has never even helped fund the group.

"What dQ yOU mean sUppOrt? I saved a woman's life down here in Springfield and this group came together, and they want to honor me for the woman choking to death in the Globe restaurant. Remember that?" Jones said.

In a letter Jones writes that "issues and questions have been raised in the past year regarding SALF," and he "strongly encourages the foundation to answer th~se questions." He wtOte the Jetter to Chicago woman Julia Rickert after receiving her complaint aoout Save-A-Life's use of state funds. Rickert worked at Save-A-Ufe's Schiller Park headquartet'S in late February as a temporary employee.

'·-~i was wid by the temp agency that Save-a~Life was looking for somebody to do proofreading, to proofread theil' instruction manual, a 600 pa~

Rickert says sh~ was told her assignment was to find misspellings in a flew fIrSt responder's manual being prepared for it's instructors, but she says her supe("Visor had something else in mind.

"He never mentioned proofreading at all. He said their manual needed to be edited. They wanted it rewritten On a high schoolleveI. They wanted me to rewrite the entire book line by line," said Rickert said.

A Save-A-Life spokesman confirms to ABC7 that temp workers typed the copyrighted book into their system then hired Rickert as a temp who was told to rewrite it. The charity contends it was to be a first draft for a new training curriculum, even thougJ1 R,ickert had no expertise in emergency response.

"( have proofreading experience but not technical writint ~xperience and no medical background," said Rickert.

Save-A-Life officials say when the year-long project is finished, it will be reviewed by "leading local and national EMS stak.eholders and our intellectual property attorney," and then "certified by the Illinois Department of Public Health."

Rickert has contacted the publisher of the book she was told to r~write. The publisher declined to discuss with ABC7 what he called their "legal investigation." And she has filed a complaint with the Illinois ins~tor general asking that Save-A·Ufe be investigated. Save-A-Ufe pledges to happily "cooperate with an investigation by responsible parties to ,d~1 these baseless allegations."

~

Save-A-Life fil.ro a defamation lawsuit this month against a doctor ~d tWQ other men who have publicly cdt;ciu:d the charity. In the suit, Save-A-Life says the most serious allegations against them were "false, inflammatory and defamatory." Charity officials claim they have "lost business opportunities," funding and have had to spend money to repair damage to their reputation.

Save-A-Life may be losing funding from the Chicago Public Schools as well. A CPS official says they "are scrutinizing every expense" and may not have the budget to help out Save·A-Ufe as they have in recent years.

(Copyright 102010 WLS-Tv/DT. All Rights Reserved.)

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2006 Federal Statements Page 2

CIi."t 18015 SAVE A LIFE FOUNDATION 36-_

51,4i08 02""'" Statement 4

, f orm 990, P. rt IV, Line 63 . Loans from Offlcer5, Dircdof"S, Trustees, and Key Employees

BAlIl]!;i!: DuO

Lender's Name : CAROL' SPIZZIRRI Lender I 5 Title : PRESWNT Rep.YlIent Terms : DUE : OEHAND Intere:st Rate : 5 . 00' Purpose or Loan : OP£RATIONS OriQinal Amount : 61,496 . Balance Due : 118; 911' Total ~ ~"8 9' .

Statement 5 Fa"" 990, Part IV, Line 65 Other LlabiliUes

I NSTRUCTOR OEPOSITS S 2.100 . Round!n9 1.

Tota l I 2, 'nn .

Statement 6 . . Schedule A Part I ~ c ompensation of Five Highest P1ii1d Employees

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. T! tIe , Average COQIPen- Contr1.but. Expense Name aD~ Address Hours Worked U t iOR Eap & DC Account

DANE NEAL • NATL POLICY OIR 63,520 . O. 584 . 9950 LAWR£NCE, SUITE 300

1

'0 SCHILLER PARf( , I L 60116

VINCENT DAVIS DIR -STATE/ MILl 50,000 . O. 124 . 9950 LAWRENCE, SUITE 300 .0 SCHILLE:R PARK, lL 60176

Total ~ In, S2~ I I ~I I l~~~I ·

St.tement ? Schedule A Part II·A Compensation of Five Highect Paid Professlon.1 Service Contractors

tlam.: ADd Add[!:u IyDe 12' ~lu::1Z:i,e ,-glll2CD.:Ii.llURD HOGAN & HARTSON LLP CONSULTING 77,039. COLUMBIA SQUARE. SSS THIRTEENTH S1 WASHINGTON, DC 2000~

Total ! '7'7,~n ,

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SAVE A LIFE FOUNDA.TION, INC •

. ,' . STATEMENT OF ACTlVlTIES

For the Year Ended Dccanbr:r 31.2002 ~ ..

'-Temporarily

1.harcstriClCd Ratrictc:d 1"otal • - .... b

INCOME

hbllcSupport Contributions """S l,353 $ S 1.3'3 Privale Grants ~

31 • .500 31-'00 Contributions In Kind 123.081 123.081 Spedal Events Gross Income 9),606 93,606

'rotal Pa.bl"~ Stapport 14','''0 1"9~'iifO

GDTCmPlCDt COQuaelJ

SUite or U1inols • IOPH 600,000 600.000 Slate of Illinois - OCCA 200,000 200,000 St.le of 1l1i60is :..A*J'"ritit ~t ~ .. ,1J.a Federal - HHSlCDC 3l.8l9 3U\t9 Total GDventmcnl Contracts 15,000 831,819 856,819

OIhu llIcome Prog~m StfViCf. Fees 31,693 31,693 Miscelhlneous :~ 225 12s-. . COUfSC Materials 11-9,980 119.980 Branch Fee (2,916) (2,916) Membership Dues lOS 205

Total othu Incollle 119,187 179,187

- .. TOTAL INCOME (bpldnt:cs carried !orwtl.rtl) "",117 811,819 1.185.'~(i

THE ACCOMPANYING NOTES AJtE AN INTEGRAL PART OF mESE STATEMENTS

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...

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNlY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS, ) '"

Plaintiff,

"'I

v. No. 08 CR-I0S02

ANNABEL K. MELONGO

Defendant.

Subpoena Duces Tecum

TO; Illinois Department Of Public Health -legal Dept.

535 W. Jefferson Street .::..

Springfield. Il 62761

YOU ARE COMMANDED to appear to testify before the Honorable Judge Mary M. Brosnahan

.... _ .. ·in-Room 303,2650 5. California Ave., Chicago, Illinois on March 3rd 2010, at·9.30am.

YOU ARE COMMANDED ALSO to bring the following:

1~ Provide ALL communications between the Illinois Department Of Public Health ( "IDPH" ) and Save A Ufe Foundation, 600 S. Second St., Suite 103, Springfield, Il62704; 9950 W. lawrence Ave Suite 300, Schiller Park, Il60176-1216, or any other address which It may have used.

2. Provide All contracts/earmarks entered into between IDPH and Save A life Foundation for any purpose.

3. Provide ALL documents reflecting any traIning classes, courses or programs of any kind conducted or sponsored by Save A life Foundation, or to be conducted by it, for the staff/students, faculty or others given to ISBE.

Exhibit B

4. Provide All purchase orders from IDPH to Save A Ufe Foundatlon for any products or services of any kind .

5. Provide AU Invoices submitted by Safe A Ufe Found<l tlon to IDPH for any purpose.

6. Provide All records of payment of any kind made by IDPH to Save A Ufe Foundation for any purpose, Including but not IIl'(Ilted to employment or payroll records, or payments for Invoices submitted by It.

1, Provide All Resolutions passed by IDPH which refer or relate to Save A Ufe Foundation.

" , ,

'1N'CASE'YOU CANtT APPEAR-IN PERSON -AT ·THE ABOVE MENTIONED DATE, PLEASE MAIL ~l~ THf.

REQUESTED INFORMATION TO:

Judie Mary M. Brosnahan

Room 303, 2650 S. California Ave. I Chicago, illinois

AUENTION: ANNABEL MELONGO'S SUPBOENA RESPONSE

wrrNESS ~ID~ ~n Oat. 2dlo- ;2010

Atty. No. 99500

Name: Anoabel Metongo __ ~

Address: P.O. Box 1537

Clty/Stat./Zlp: AddIson, IL 60101

Telephone: 630·2204132

..

Annabel Melongo
Text Box

IN THE CIRCUIT COURT OF COOK COUNTY, IlliNOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

....

PEOPLE OF THE STATE OF ILUNOIS, )

Plaintiff,

v. No. 08 CR-10502

ANNABEL K. MELONGO

Defendant.

Subpoena Duces Tecum

TO: Douglas Browne

2851 Eyans Woods Dr.

Atlanta. GA 30340

YOU ARE COMMANDED to appear to testify before the Honorable Judge Mary M. Brosnahan

in Room 303, 2650 S. California Ave., Chicago, Illinois on March 3rdh 2010, at 9.30 am.

YOU ARE COMMANDED ALSO to bring the following:

1. Provide documentation( emails, letters, faxes, memos, financial statements, documents of any kind) on the computer events as they happened from April 28th

- May 1st 2006 at Save A Ufe Foundation, located in Schiller Park, Illinois. This should include the computers affected, list of persons hired to fix it, the type of files affected, name of experts hired.

2. Any document{s) you might have in your possession regarding the events. Documents should be

among other: any documents, emails, fax with the Illinois Schiller Park Police department, the Illinois Attorney General, Brian Salerno, Don Peters, Dick Devine, Cook County State Attorney or

any emails exchange with ANY Save A Ufe Foundation employees regarding the incident.

Exhibit C

3. All your pay stubs or copies of checks issued by Save A Ufe Foundation to you during the years 2005,2006,2007. If not available, copies of bank statements showing deposits being made.

4. Any document showing financial transaction(s) from Save A Ufe Foundation benefiting you. , 5. Documentation( letters, faxes, memos, emalls, documents of any kind) on individual(s) that were

instrumental In helping Save A Ufe Foundation be in Illinois' state budget, CDC, 000

( Department of Defense I, National Guard, Homeland Security, FEMA.

6. Any documentation{ financial statements, records, letters, emalls, memos, faxes, document of any kind) showing proof of lost ¥ result of computer's incident occuring in April- May 2006 at the Save A Ufe Foundation headquarters In Schiller P<lrk, illinois.

IN CASE YOU CAN'T APPEAR IN PERSON AT THE ABOVE MENTIONED DATE, PLEASE MAIL All THE

REQUESTED INFORMATION TO:

Judge Mary M. Brosnahan

Room 303, 2650 S, California Ave" Chicago, Illinois

AITENTION; ANNABEL MElONGO'S SUPBOENA RESPONSE

W~IT~N~ES~S~_~~~~~~~~~~~!A"~

Date 1~ 0 z(}/o Atty. No. 99500

Name: Annabel Melango

Address: P.O. Box 1537

City/Slate/Zip: Addison, Il60101

Telephone: 630-220-4132

Annabel Melongo
Text Box