il v. melongo: state motion to quash defendant's subpoenas re: salf principals, 2/22/10

IN THE CIRCUIT COURT OF COOK COUNTY COUNTY DEPARTMENT, CRIMINAL DIVISION

^

^

PEOPLE OF THE STATE OF ILLINOIS ) ^ ^ ^ ^

) v. - ) No. 08CR10502

) ANNABEL MELONGO )

Defendant ) t

MOTION TO QUASH SUBPOENAS

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

ALVAREZ, 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, former Save A Life board member Douglas Browne, and former Palatine Mayor

Rita Mullins and in support state the following:

1. The Defendant ha&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 of their founder, Carol Spizzirri.

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

appearance to testify and to bring the following:

a. Documentation (emails, memos, faxes, documents of any kind) with description of computer events as they happened from April 28lh - May 1st

2006 at Save A Life Foundation, located in Schiller Park, Illinois. This should include the computers affected, list of persons hired to fix it, the type of files affected, percentage of files recovered as well as the names of technician(s) recovering the files.

b. ALL communication(s) (emails, memos, faxes, documents of any kind) you 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 General, Brian

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

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.

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

List contact information (emails, fax, address, phone) of ALL experts hired for the computed incident that occurred in April 28th- May 1st 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.

ALL copies of pay stubs issued to you by Save A Life Foundation during the years 2005, 2006, 2007. If not available, copies of back statements showing deposits being made.

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.

All documentation (emails, memos, faxes, 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.

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

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 the attached ABC investigative report's transcript, Attached Exhibit 'A.'

m. Provide all documentation (emails, memos, faxes, letters, bills, invoices, checks issued, financial records, documents of any kind) pertaining to Hogan & Hartson LLJP 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 use of a pre-trial subpoena, the Defendant must show l)sthat the

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

otherwise procurable 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 (111. 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 of SALF. The

Defendant has not demonstrated that these documents are evidentiary, 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 State of Illinois ask that this Honorable Court

quash the subpoenas issued by the Defendant or, in the alternative, sel this matter

for hearing at such a time before such appearances are commanded.

RespectjjiJly submitted

Julie Gunra^ley N-^_ >A«sistant State's Attorney

CliRTlFlCATKOFSHRVin;

I, the undersigned, state that Annabel Melongo P.O. Box 1537 Addison, IL 60101

have served the attached Motion to Quash upon:

by mailing it first class mail, with sufficient postage attached this 21s1 day of February, 2010. Per the Defendant's request, she was notified at 630-220-4132 that a paper copy was available at the State's Attorney's Office.

uife uunttij ssistant State's Attorned

:•

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS,

Plaintiff,

ANNABEL K. MELONGO

Defendant.

No. 08 CR-10S02

Subpoena Duces Tec urn TO; Carol Spizzirrt

» ■> *

■ » >

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 5. California Ave., Chicago, Illinois on March 3rd 2010, at 9.30 am.

YOU ARE COMMANDED ALSO to bring the following:

1. Documentation( emails, memos, faxes, documents of any kind ) with description of computer events, ^hey1nsppenedirorrrApr\\^2,8'h ^ May 1^^006"atSweA^LtfeFoundatTdn, Jocatrdln Schiller Park, Illinois. This should include the computers affected, list of persons hired to fix It, the type of files affected, percentage of files recovered as well as the names of technician^) recovering the f i tesr

2, ALL communication(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 the Illinois Schiller Park Police department, the Illinois Attorney General, Brian Salerno, Don Peters, Dick Devine, any personnel at the Illinois Attorney General office and ALL Save A Life Foundation former employees on the incident.

Exhibit A

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. Documentation! emails, rneVnos, 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 specific questions asked. Names of individual(s) having gone to the Schiller Park Police building as part of the investigation. Letter Commanding Schiller Park's Detective William Martin.

5. List contact information {email, fax*, address, phone) of ALL experts hired for the computer incident that occurred in April 28'" - May l r t 2006 at Save A Life Foundation headquarters in Schiller Park, Illinois. Also provided bills, invoices as well as copies of checks or bank statements resulting from their services.

6. ALL copies of pay stubs issued to you by Save A Life Foundation during the years 2005, 2006, 2007. If not available, copies of back statements showing deposits being made.

7. 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.

8. ALL documentation! emails, 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. Contact information! address, fax, phone, email) on all companies having audited Save A Life Foundation over the years. The information should include the start and end date(V) for each company.

10. Provide ENTIRE personnel fifes of the following employees: Christian Sass, Dave Stolerow, Saquan Gholar, BobCokinis, Vinee 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 of temporary 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 & Hanson LLP as part of hs governmental consulting services as stated in your 2005 and 2006 auditing reports, Attached Exhibit "B".

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 the computer's incident as stated In the May 2008, Grand Jury.

15. 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"

YOUR FAILURE TO APPEAR IN RESPONSE TO THIS SUBPOENA WILL SUBJECT YOU TO PUNISHMENT FOR

CONTEMPT OF THIS COURT.

i - ■

WITNESS

Date

Any. No. 99500

Name: Annabel Melongo

Address: P.O. Box 1537

City/State/Zip: Addlson, IL 60101

Telephone: 630-220-4132

V " o Chicago Area Jobs o Classifieds ° Get Coupons

I Enter seaich phrase

mffmmmmmm News

Save-A-LifeTs main government funding may be drying up Thursday,. May 31, 2007

• Emai l " > • Print ,■ , , • Report a typo vLXf\chT\+ /\ SB

A Chuck Goudie More: Bio. Facebook. Twitter. News Team By Chuck Goudie

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

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

The Save-A-Life 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 of its major backers. **

"I've never supported it funding-wise," Jones said.

And Jones says the charity is not currently slated to receive money in next year's state budget. The apparent cut-off of government funds follows I-Team disclosures about Save-A-Life founder Carol Spizzdrri.

For years, while soliciting government funding, Spizzirri claimed to be a kidney transplant nurse and an RN, The NTeam's investigation found that the now-defunct college she attended never awarded her a degree of any kind; and government records show she has never been a registered nurse in either Wisconsin, as she told the 1-Team, or in Illinois. During questioning last November, Spizzirri walked out of our meeting and declined to be interviewed for 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 S88,000 in grant money.

"1 am concerned if in fact that she is not spending the taxpayer dollars we have entrusted in her to be spent correctly," 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 haven't seen all the results," said Trotter,

Both senators Trotter and Jones have been given awards by $ave-A-Life7 Jones for saving someone from choking in a Springfield restaurant. Since then, Jones says he has been wrongly listed as Save-A-Life's "Illinois spokesman" and that he has never even helped fund the group.

"What do 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 those questions." He wrote the letter to Chicago woman Julia Riokert after receiving her complaint about Save-A-Life's use of state funds. Rickert worked at Save-A-Life's Schiller Park headquarters in late February as a temporary employee.

' "I was told by the temp agency that Save-a-Life was looking for somebody to do proofreading, to proofread their instruction manual, a 600 page

•manual," saia Kictcert.

Rickert says she was told her assignment was to find misspellings in a new first responded manual being prepared for it's instructors but she savs her supervisor 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 school level. 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 cun-iculum, even though Rickert had no expertise in emergency response.

"I have proofreading experience but not technical writing experience 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 stakeholders 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 rewrite. The publisher declined to discuss with ABC7 what he called their "legal investigation." And she has filed a complaint with the Illinois inspector general asking that Save-A-Life be investigated. Save-A-Life pledges to happily "cooperate with an investigation by responsible parties to 4ispel these baseless allegations."

Save-A-Life filed a defamation lawsuit this month against a doctor and two other men who have publicly criticized 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-Life as they have in recent years,

(Copyright ©2010 WLS-TV/DT. All Rights Reserved.)

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HEBB 2006 Client 18015

Federal Statements SAVE A LIFE FOUNDATION

Page 2 36-3869459

5/14/08 02 53PM

Statement 4 ■ Form 990, Part IV, Line 63 Loans from Officers, Directors, Trustees, and Key Employees

Balance.Due Lender's Name: Lender's Title: Repayment Terms: Interest Rate: Purpose of Loan: Original Amount: Balance Due:

CAROL J5PIZZIRRI PRESIDENT DUE ON DEMAND 5.001 OPERATIONS 61,496.

Tota l 9~ 178,974. 178.9747

Statement 5 Form 990, Part IV, Line 65 Other Liabilities

INSTRUCTOR DEPOSITS Rounding 8

Total £ 2,700.

1. 2770T

Statement 6 Schedule A, Part I * Compensation of Five Highest Paid Employees

Name an^ Address DANE NEAL '. 9950 LAWRENCE, SUITE 300' SCHILLER PARK, IL 60176 VINCENT DAVIS 9950 LAWRENCE, SUITE 300 SCHILLER PARK, IL 60176

Title 6 Average Hours Worked NATL POLICY DIR

40

DIR -STATE/MILI 40

Coropen-sation 63,520.

50,000.

Contribut. , EBP & DC. 0.

0.

Expense Account

5B4.

724,

Total

Statement 7 Schedule A, Part ll-A Compensation of Five Highest Paid Professional Service Contractors

jlame and Address H0GAN & HARTSON LLP COLUMBIA SQUARE, 555 THIRTEENTH ST WASHINGTON, DC 20004

-type of Service CONSULTING

Compensation 77,039.

Total 5 77.6357

SAVE A LIFE F O U N D A T I O N , INC.

STATEMENT OF ACTIVITIES

For the Year Ended December 31.2002 « F

INCOME

Public Support Contributions Private Grants Contributions In Kind Special Events Gross Income

Total Public Support

Government Contracts State of Illinois -1DPH Sute of Illinois - DCCA Sute of Hlifcois - AHjSrittJjf Federal - HHS/CDC

Total Government Contracts

Other Income Program Service Fees Miscellaneous " Course Materials Branch Fee Membership Dues

Total Other Income

Temporarily Unrestricted Restricted Total

1,353 31,500

123.081 93,606

1,353 31,500

123.081 93,606

249,540 249,540

2£$0O

600,000 600,000 200,000 200,000

- 25,000 31,619 31,819

25,000

31,693 225

149,960 (2.916)

205

831,819 856,8X9

31,693 225-

149,980 (2.916)

205

179.187 179,187

TOTAL INCOME (balances carried forward) 453,727 831,819 1,285,546

THE ACCOMPANYING NOTES ARE AN INTEGRAL PART OP THESE STATEMENTS

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AUDITEP FINANCIAL STATEMENTS

AHLBECK&COMPANY CERTIFIED nmuc ACCOUNTANTS

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PEOPLE OF THE STATE OF ILLINOIS, )

Plaintiff,

v.

ANNABEL K.MELONGO

Defendant.

No. 08 CR-10502

Subpoena DucesTecum TO: Illinois Department Of Public Health - Legal Dent.

535 W. Jefferson Streets >

Springfield. IL 62761


■■-■- irvRoom 303, 2650 S.California Ave., Chicago, Illinois on March 3rd 2010, at 9.30 am.


1. Provide ALL communications between the Illinois Department Of Public Health ( "IDPH" ) and Save A Life Foundation, 600 S. Second St., Suite 103, Springfield, IL 62704; 9950 W. Lawrence Ave Suite 300, Schiller Park, IL 60176-1216, 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 Life Foundation for any products or services of any kind.

5. Provide ALL invoices submitted by Safe A Life Foundation to IDPH for any purpose.

6. Provide ALL records of payment of any kind made by IDPH to Save A Life Foundation for any purpose, including but not limited to employment or payroll records, or payments for invoices submitted by it.

7. Provide ALL Resolutions passed by IDPH which refer or relate to Save A Life Foundation.

1N 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

ATTENTION: ANNABEL MELONGO'S SUPBOENA RESPONSE

Date 2HUr2DlD

Atty. No. 99500

Name: Annabel Melongo . .


City/State/Zip: Addison, IL 60101

Telephone: 630-220-4132




Plaintiff,

ANNABEL K. MELONGO

Defendant.

No. 08 CR-10502

Subpoena Duces Tecum TO: Douglas Browne

2851 Evans 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.


1. Provide documentation emails, letters, faxes, memos, financial statements, documents of any kind ) on the computer events as they happened from April 28* - May 1st 2006 at Save A Life 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 Deyine, Cook County State Attorney or any emails exchange with ANY Save A Life Foundation employees regarding the incident.

Exhibit C

3. ALL your pay stubs or copies of checks issued by Save A Life 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 Life Foundation benefiting you.

5. Documentation! letters, faxes, memos, emails, documents of any kind) on individual(s) that were instrumental in helping Save A Life Foundation be in Illinois' state budget, CDC, DoD ( Department of Defense ), National Guard, Homeland Security, FEMA.

6. Any documentation! financial statements, records, letters, emails, memos, faxes, document of any kind) showing proof of lost as result of computer's incident occuring in April - May 2006 at the Save A Life Foundation headquarters in Schiller Park, Illinois.

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



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


;>

Atty. No. 99500




Telephone: 630-220-4132

WITNESS

Date ^JMiM+ys JL "Z 6/0

IN THE CIRCUIT COURT OF COOK COUNTY COUNTY DEPARTMENT, CRIMINAL DIVISION

^

^

PEOPLE OF THE STATE OF ILLINOIS ) ^ ^ ^ ^

) v. - ) No. 08CR10502

) ANNABEL MELONGO )

Defendant ) t

MOTION TO QUASH SUBPOENAS

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

ALVAREZ, 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, former Save A Life board member Douglas Browne, and former Palatine Mayor

Rita Mullins and in support state the following:

1. The Defendant ha&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 of their founder, Carol Spizzirri.

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

appearance to testify and to bring the following:

a. Documentation (emails, memos, faxes, documents of any kind) with description of computer events as they happened from April 28lh - May 1st

2006 at Save A Life Foundation, located in Schiller Park, Illinois. This should include the computers affected, list of persons hired to fix it, the type of files affected, percentage of files recovered as well as the names of technician(s) recovering the files.

b. ALL communication(s) (emails, memos, faxes, documents of any kind) you 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 General, Brian

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

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.

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

List contact information (emails, fax, address, phone) of ALL experts hired for the computed incident that occurred in April 28th- May 1st 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.

ALL copies of pay stubs issued to you by Save A Life Foundation during the years 2005, 2006, 2007. If not available, copies of back statements showing deposits being made.

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.

All documentation (emails, memos, faxes, 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.

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

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 the attached ABC investigative report's transcript, Attached Exhibit 'A.'

m. Provide all documentation (emails, memos, faxes, letters, bills, invoices, checks issued, financial records, documents of any kind) pertaining to Hogan & Hartson LLJP 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 use of a pre-trial subpoena, the Defendant must show l)sthat the

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

otherwise procurable 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 (111. 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 of SALF. The

Defendant has not demonstrated that these documents are evidentiary, 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 State of Illinois ask that this Honorable Court

quash the subpoenas issued by the Defendant or, in the alternative, sel this matter

for hearing at such a time before such appearances are commanded.

RespectjjiJly submitted

Julie Gunra^ley N-^_ >A«sistant State's Attorney

CliRTlFlCATKOFSHRVin;

I, the undersigned, state that Annabel Melongo P.O. Box 1537 Addison, IL 60101

have served the attached Motion to Quash upon:

by mailing it first class mail, with sufficient postage attached this 21s1 day of February, 2010. Per the Defendant's request, she was notified at 630-220-4132 that a paper copy was available at the State's Attorney's Office.

uife uunttij ssistant State's Attorned

:•




Plaintiff,

ANNABEL K. MELONGO

Defendant.

No. 08 CR-10S02

Subpoena Duces Tec urn TO; Carol Spizzirrt

» ■> *

■ » >

17479 Dartmoor Court,

Grayslake, IL 60030

Telephone; 847-366-1124


In Room 303, 2650 5. California Ave., Chicago, Illinois on March 3rd 2010, at 9.30 am.


1. Documentation( emails, memos, faxes, documents of any kind ) with description of computer events, ^hey1nsppenedirorrrApr\\^2,8'h ^ May 1^^006"atSweA^LtfeFoundatTdn, Jocatrdln Schiller Park, Illinois. This should include the computers affected, list of persons hired to fix It, the type of files affected, percentage of files recovered as well as the names of technician^) recovering the f i tesr

2, ALL communication(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 the Illinois Schiller Park Police department, the Illinois Attorney General, Brian Salerno, Don Peters, Dick Devine, any personnel at the Illinois Attorney General office and ALL Save A Life Foundation former employees on the incident.

Exhibit A

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. Documentation! emails, rneVnos, 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 specific questions asked. Names of individual(s) having gone to the Schiller Park Police building as part of the investigation. Letter Commanding Schiller Park's Detective William Martin.

5. List contact information {email, fax*, address, phone) of ALL experts hired for the computer incident that occurred in April 28'" - May l r t 2006 at Save A Life Foundation headquarters in Schiller Park, Illinois. Also provided bills, invoices as well as copies of checks or bank statements resulting from their services.

6. ALL copies of pay stubs issued to you by Save A Life Foundation during the years 2005, 2006, 2007. If not available, copies of back statements showing deposits being made.

7. 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.

8. ALL documentation! emails, 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. Contact information! address, fax, phone, email) on all companies having audited Save A Life Foundation over the years. The information should include the start and end date(V) for each company.

10. Provide ENTIRE personnel fifes of the following employees: Christian Sass, Dave Stolerow, Saquan Gholar, BobCokinis, Vinee 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 of temporary 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 & Hanson LLP as part of hs governmental consulting services as stated in your 2005 and 2006 auditing reports, Attached Exhibit "B".

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 the computer's incident as stated In the May 2008, Grand Jury.

15. 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"

YOUR FAILURE TO APPEAR IN RESPONSE TO THIS SUBPOENA WILL SUBJECT YOU TO PUNISHMENT FOR

CONTEMPT OF THIS COURT.

i - ■

WITNESS

Date

Any. No. 99500



City/State/Zip: Addlson, IL 60101

Telephone: 630-220-4132

V " o Chicago Area Jobs o Classifieds ° Get Coupons

I Enter seaich phrase

mffmmmmmm News

Save-A-LifeTs main government funding may be drying up Thursday,. May 31, 2007

• Emai l " > • Print ,■ , , • Report a typo vLXf\chT\+ /\ SB

A Chuck Goudie More: Bio. Facebook. Twitter. News Team By Chuck Goudie

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

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

The Save-A-Life 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 of its major backers. **

"I've never supported it funding-wise," Jones said.

And Jones says the charity is not currently slated to receive money in next year's state budget. The apparent cut-off of government funds follows I-Team disclosures about Save-A-Life founder Carol Spizzdrri.

For years, while soliciting government funding, Spizzirri claimed to be a kidney transplant nurse and an RN, The NTeam's investigation found that the now-defunct college she attended never awarded her a degree of any kind; and government records show she has never been a registered nurse in either Wisconsin, as she told the 1-Team, or in Illinois. During questioning last November, Spizzirri walked out of our meeting and declined to be interviewed for 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 S88,000 in grant money.

"1 am concerned if in fact that she is not spending the taxpayer dollars we have entrusted in her to be spent correctly," 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 haven't seen all the results," said Trotter,

Both senators Trotter and Jones have been given awards by $ave-A-Life7 Jones for saving someone from choking in a Springfield restaurant. Since then, Jones says he has been wrongly listed as Save-A-Life's "Illinois spokesman" and that he has never even helped fund the group.

"What do 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 those questions." He wrote the letter to Chicago woman Julia Riokert after receiving her complaint about Save-A-Life's use of state funds. Rickert worked at Save-A-Life's Schiller Park headquarters in late February as a temporary employee.

' "I was told by the temp agency that Save-a-Life was looking for somebody to do proofreading, to proofread their instruction manual, a 600 page

•manual," saia Kictcert.

Rickert says she was told her assignment was to find misspellings in a new first responded manual being prepared for it's instructors but she savs her supervisor 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 school level. 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 cun-iculum, even though Rickert had no expertise in emergency response.

"I have proofreading experience but not technical writing experience 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 stakeholders 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 rewrite. The publisher declined to discuss with ABC7 what he called their "legal investigation." And she has filed a complaint with the Illinois inspector general asking that Save-A-Life be investigated. Save-A-Life pledges to happily "cooperate with an investigation by responsible parties to 4ispel these baseless allegations."

Save-A-Life filed a defamation lawsuit this month against a doctor and two other men who have publicly criticized 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-Life as they have in recent years,

(Copyright ©2010 WLS-TV/DT. All Rights Reserved.)

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HEBB 2006 Client 18015

Federal Statements SAVE A LIFE FOUNDATION

Page 2 36-3869459

5/14/08 02 53PM

Statement 4 ■ Form 990, Part IV, Line 63 Loans from Officers, Directors, Trustees, and Key Employees

Balance.Due Lender's Name: Lender's Title: Repayment Terms: Interest Rate: Purpose of Loan: Original Amount: Balance Due:

CAROL J5PIZZIRRI PRESIDENT DUE ON DEMAND 5.001 OPERATIONS 61,496.

Tota l 9~ 178,974. 178.9747

Statement 5 Form 990, Part IV, Line 65 Other Liabilities

INSTRUCTOR DEPOSITS Rounding 8

Total £ 2,700.

1. 2770T

Statement 6 Schedule A, Part I * Compensation of Five Highest Paid Employees

Name an^ Address DANE NEAL '. 9950 LAWRENCE, SUITE 300' SCHILLER PARK, IL 60176 VINCENT DAVIS 9950 LAWRENCE, SUITE 300 SCHILLER PARK, IL 60176

Title 6 Average Hours Worked NATL POLICY DIR

40

DIR -STATE/MILI 40

Coropen-sation 63,520.

50,000.

Contribut. , EBP & DC. 0.

0.

Expense Account

5B4.

724,

Total

Statement 7 Schedule A, Part ll-A Compensation of Five Highest Paid Professional Service Contractors

jlame and Address H0GAN & HARTSON LLP COLUMBIA SQUARE, 555 THIRTEENTH ST WASHINGTON, DC 20004

-type of Service CONSULTING

Compensation 77,039.

Total 5 77.6357

SAVE A LIFE F O U N D A T I O N , INC.

STATEMENT OF ACTIVITIES

For the Year Ended December 31.2002 « F

INCOME

Public Support Contributions Private Grants Contributions In Kind Special Events Gross Income

Total Public Support

Government Contracts State of Illinois -1DPH Sute of Illinois - DCCA Sute of Hlifcois - AHjSrittJjf Federal - HHS/CDC

Total Government Contracts

Other Income Program Service Fees Miscellaneous " Course Materials Branch Fee Membership Dues

Total Other Income

Temporarily Unrestricted Restricted Total

1,353 31,500

123.081 93,606

1,353 31,500

123.081 93,606

249,540 249,540

2£$0O

600,000 600,000 200,000 200,000

- 25,000 31,619 31,819

25,000

31,693 225

149,960 (2.916)

205

831,819 856,8X9

31,693 225-

149,980 (2.916)

205

179.187 179,187

TOTAL INCOME (balances carried forward) 453,727 831,819 1,285,546

THE ACCOMPANYING NOTES ARE AN INTEGRAL PART OP THESE STATEMENTS

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AUDITEP FINANCIAL STATEMENTS

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Plaintiff,

v.

ANNABEL K.MELONGO

Defendant.

No. 08 CR-10502

Subpoena DucesTecum TO: Illinois Department Of Public Health - Legal Dent.

535 W. Jefferson Streets >

Springfield. IL 62761


■■-■- irvRoom 303, 2650 S.California Ave., Chicago, Illinois on March 3rd 2010, at 9.30 am.


1. Provide ALL communications between the Illinois Department Of Public Health ( "IDPH" ) and Save A Life Foundation, 600 S. Second St., Suite 103, Springfield, IL 62704; 9950 W. Lawrence Ave Suite 300, Schiller Park, IL 60176-1216, 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 Life Foundation for any products or services of any kind.

5. Provide ALL invoices submitted by Safe A Life Foundation to IDPH for any purpose.

6. Provide ALL records of payment of any kind made by IDPH to Save A Life Foundation for any purpose, including but not limited to employment or payroll records, or payments for invoices submitted by it.

7. Provide ALL Resolutions passed by IDPH which refer or relate to Save A Life Foundation.

1N CASE YOU CAN'T APPEAR IN PERSON AT THE ABOVE MENTIONED DATE, PLEASE MAIL ALL THE



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


Date 2HUr2DlD

Atty. No. 99500

Name: Annabel Melongo . .



Telephone: 630-220-4132




Plaintiff,

ANNABEL K. MELONGO

Defendant.

No. 08 CR-10502

Subpoena Duces Tecum TO: Douglas Browne

2851 Evans 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.


1. Provide documentation emails, letters, faxes, memos, financial statements, documents of any kind ) on the computer events as they happened from April 28* - May 1st 2006 at Save A Life 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 Deyine, Cook County State Attorney or any emails exchange with ANY Save A Life Foundation employees regarding the incident.

Exhibit C

3. ALL your pay stubs or copies of checks issued by Save A Life 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 Life Foundation benefiting you.

5. Documentation! letters, faxes, memos, emails, documents of any kind) on individual(s) that were instrumental in helping Save A Life Foundation be in Illinois' state budget, CDC, DoD ( Department of Defense ), National Guard, Homeland Security, FEMA.

6. Any documentation! financial statements, records, letters, emails, memos, faxes, document of any kind) showing proof of lost as result of computer's incident occuring in April - May 2006 at the Save A Life Foundation headquarters in Schiller Park, Illinois.




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


;>

Atty. No. 99500




Telephone: 630-220-4132

WITNESS

Date ^JMiM+ys JL "Z 6/0




)

Plaintiff, )

)

v. ) No. 08 CR-10502

)

ANNABEL K. MELONGO )

)

Defendant. )

Subpoena Duces Tecum TO: Rita Mullins

858 N. Virginia Lake Ct.

Palatine, IL 60067

T elephone: 8 47-359-4854


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


1 . Details description of computer events as they happened from April 28th - May 1 s t 2006 at Save A Life Foundation, located in Schiller Park, Illinois (“SALF”). This should include the computers affected, list of persons hired to fix it, the type of files affected, experts being hired.

2. Any document(s) you might have in your possession regarding the above mentioned computer's 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, any emails exchange with ANY Save A Life Foundation employees regarding the incident.

3. Documentation( emails, memos, 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 specific questions asked. Names of individual(s) having gone to the Schiller Park Police building as part of the investigation. Letter Commanding Schiller Park's Detective William Martin.

4. Documentation( emails, memos, 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 specific questions asked. Names of individual(s) having gone to the Schiller Park Police building as part of the investigation. Letter Commanding Schiller Park's Detective William Martin.

5. ALL your pay stubs or copies of checks issued by Save A Life Foundation to you during the years 2005, 2006, 2007. If not available copies of back statements showing deposits being made.

6. Documentation on any financial transaction from Save A Life Foundation benefiting you or your political campaign(s).

7. 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.

8. ALL documentation( emails, 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. Provide ALL documents ( financial records, bills, invoices, memos, faxes, document of any kind ) showing proof of lost as result of computer's incident occurring at SALF in April – May 2006.




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


WITNESS

Date

Atty. No. 99500




Telephone: 630-220-4132

il v. melongo: state motion to quash defendant's subpoenas re: salf principals, 2/22/10

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