Hegwood, Jr. v. Meijer, Inc

IN THE UNTTED : FOR THE NORTHERN OLEtRRCT ENOLS EASTERN DEXTSION FILED NAY 25 □□□□ THOMAS 6.8 TALMON HEGWOOD, TR, CLERK, Ug, DISTRICT □□□□ Plant ™Yerguea-- Noe. O2RB] MARIER. THC. and CASEY STEFANO Honorable GARY FEINERMAN, Defendants. oS: MOTTON FOR JUDGMENT BY DEFAM ET = NOW INTC COURT comes Talmon Hequood Je (Heqweod) procatiling pro Se and respectful ly moves the Court for ment ee ir in his favor acpinst Meijer Inc, and Casey rebar (Gte%ano). This Motion is being made. persvant to Federal Rules of Civil Procedun Fed. R.Civ.P 55 and Fed R.Civ.P 37(b) (2) (¢)}- The grounds for tris motion are as Fellows: \. Tolmon een (Hequced) tothe pre se plaintiff inthe obove captione: I matters and the defendaats ore Meijer, Ine, and Casey, Stefane (Stefane)- 2.On of about March 12011, Hequood’s COMPLAINT Which wae th submitted to the Circutt Gort of Cook Courtty was FQLED' after the. State tribunal seutinized the pleading and granted Hequced S 1 of 10 request fer leave. te preceed in that forum as apoer peracn. On April (L201%, defendants Neier, Vac, and Stefane Fil □ A pl erik in the Courts pursuantte 28U.5.C. See WAL(b) and (C) removin ‘Re cause from the state Cart te the United States District ‘Cot Cor the Nocthecn District of Dinels. 3 Hequiocd's COMPLAENT whieh was verified and notarized on Somrary 4, 2611 1S actually aten(ic) pace. document with numerce euette annexed sartte ond yrade. part thereof: Tt is annexed to detendatt Stefanos “FEDR cave t2(b)(6) motion fe dismiss as Exhibit A (Doc.a8\5- i-43 Hequocd's COMPLAINT) ( Doc 42 t-lb Stefare's motion to diamies). Among Whe.ten ((©) handprinted Pages of the COMPLATNT Filed by Hoquecd ts □ ection oS “aessge” See Doc t.(5~ Races B. Vond 10 ce TW 102, \O3.and (0). The RELTEF section is Peasserteal, reitterated and restated here. verbatin and Seriatim. nae for defendants filed appearances on April (Ute, Qett Decsar4 Sond& and defendants also Gled metions fur extension of time. te answer, (Dec atq) which was apantod by oxtler of the Court entered inhetherecordl of this causeon April 2cit (Dec. 4). 5. On Mau 15, 2011 Nieijer filed a motion te dismiss (Decax 4) ond O& Laine ISLA ia suppart of te Fel Row P Rb) □□□□□□ (Dec. se 12) and on male 2011, Grefene Hyled a like fed. Rv? □□□ motion (Doc ate). At the time defendants mections were filed he ee Wear old pre se plaintiff was Mma tes pital - na peid of Lact, hoavever Heawocd comtacted the Court's clesK telephonic lu. and ae ees □□□ extengion of time to respond Fo the despesitive motions Gled by defendants and Heaweed's oral requ est Was arated (Doc 4 21) Dr Avast “{, theese aranted Heauioacl one, Final extengion ef time to respond te the, defendants’ metions tea dismise te September €,2ON (Doe > of iG é. Realt-zing that □□□ the streke of o pen a United States Distich Court Sedge. 18 enabled te direct a five (S) Stor General te leave, the batHe-freld in Craq. Eran, Syria and Afghanaston Hecwood a Seventy year old male adutt African American citizen of the United States requested that thie Henoralbte Court please appcint Counsel fe □□□□□□ Heguioed with (egal repre sentation and \eave.te Proceed in Forma □□□□□□□ (Dec 429) (Oce.. #35) which requests were. denied bby -Hre Gourh(Dex st. 3c 33, 3). Therefore, in compliance with the order of Court Moc 28) Hequicc Filed pro se plaintiff's response +e defendants Mejjer and Stefene's Fule. 1A(b)(d) motions te dismias (Dew sk 3€)- On September 24, 2011, cetendants filed replies te Hequeod's response he their moticns(Docse □ Ceopyof which was never receiver by Heqwoo) and (Dec. 44) "Insofar as Hequiood \S concerned en or abot November (1 2011, the earth steed still, because, thrat was the doy United States District Coorh Sudag, Konerable, GARY cRAMEENAN wrth the Stroke of a pen Siqned a NIEMORANDUN OPEHTON AWD ORDER □□□□□□ 4HH4T and 50 which denied detendants Rule tX(b)\(c) meticns □□□□□□□□□□ clefendante’ desperation tackes relati AG te the requests tor imerunity 3 from Dee fog damage 6. The Cots ofde Docsken is □□□□□□□□□□□ ®. Beth defendants have cleorly manifested a pattem of deception and discex ery abuse. and the detendants hare werked toaether in their endeavourte be evasive which erhmacious cenduct reveal the defendant Flat ast refusal te acept+tne Carts actherity tn this litigation. Defendants have ached jointly and in bad Fath and literally auiPod drastic Sanchions. See Liakv. Wabash Railroad Co. 310 U.S.626 (U.S 1442); eee Nat'l Mertuege Cow. Brand statter 297 F.2d Cth Cir. (90); U.S. Postal Service. +Union Pacific R.Co. (22, □□ (Eth Cir. 1991); Maloney. U.S Postal Sevice, C33 F 2d 128 th Cirige’), 30f 10 Adriana Tnt'| Corp.v. Thoeren, HO Gt. Cir 490), There is no que stion bet that the Federal District Courts hone. tne inhewnt power te impose sanchions re int \igher of Findings that a party has acted in bad fatth, ve atiously, warchon|y oc fer CpPpresSjive ceasens, EAC Anc. V- erative de Sequrovs de Vida 3d. LEM at Cir 200% peg □□□ hers XV. Nasco, Tne U.S, 32 YS-4b, th S.Ch 22S, NERA 2A 2(US, 1491). q. On, Nevembe. Vt the Court Siqned an ORDER directing □□□□□□ ond Stefane “answer the cemplai nt “oy &/20rn"' (Dec. a 44), Acting joint defendosth Mei\er and detendart Stefano filed a Rey, beth a them styled ANSWER □□□ on, December &, 201, Dees. □□ □□□ 55). Acting jovtly ond ignobly defendants Meijer and Stefang hath ot them, Knowingly, intentionally, deceitful senaeively and 44 Shemati cally failed +o answer plain if Shonduritter pre sc complaint relating te Hequood alleaati cng, contentions and assertions regarding the. detendants conspiracy te: a. Attempting te manipulate, the, Geort b» Man} atid the Gthhe's Airmen d. Raita te ered) ECan rabNeantd > Failia 2 £ ent &. Failing te cecperdhe, witht ERS IN eSHgaticn fF. Falliad te cohio Requons Serety Prachring racial diserimination AH empting te hinder Sthatels Atternesy Asa cesultef defendants; willful and deceitful failure onthe pos of Meijentne ond Stefane te answer ondlor Plead Henwood and the Court has been precluded fom addressing the. issues asserted with implicit and Succine? Clarity inthe REMTER' sochion of eaux) & veri fjed complaint. 10. On April 24, 2E\6, Hequicod exocithect Onc duly Served □□□□□□□□□□ with his pre Go plaint AFERDANET FOR ENTRY OF DERAUKT™ which, uses RECEIVED ny te Casts of Coury on April 30, 2016. Hequced's □□□□□□□□ Par entry of default is required prjor eeeli AG G ydameanh ‘The □□□□□ aesetted in Hequocd's affidavit Aled on April 20, 2018 ace castabe here, Verbatim and seciatin. Ww A Jono Aime during he periec| Keauwcod Was consisterthy attending ocheole of higher education, Viz, colleaes and unwersities he plaged Q Fraternity Cne of the requirements + member ship Wad +o leam and be able to recite the Poem "TR" lay the famous learned, rena une On A qitted Poet Kur ard Kippl ind Relevant to the cause at hand i Kipplings ters akibe te that ¢ ort Keo. c Lal yee Seas tesingtteira ent Honing 3 cSt aout fee be ake. eltcuborce: Son thele □□ : orem coe ga Sad hsv OF bZING □□ . Dont deal jn liesor bein hate Nand ick den* lock ioe aead ror talk toe Ree TL You ean Give the Urrforaiving minute, siety seconds worth ef distance Cun: Af wou can-take one heop oF all Wour WANTINGS ant PSK it on Ane terme of sitd? and tes8 and \ose but rt aqain and or yee beainaing never breath a werd beat Your’ App Tf Yel can. ie the untocgt vi MALE 3 ty seconds worth of die The. Ucurs 14 the & and which 19 nore. You'Tt bea Man muy Sor. Se Tee. Sheahan, Esq, and Nlichael Durkin, Esq. has appeared en behalt “Meijer and Srefane. In point of fact, however defendarite are being represatted in addition to the Young lawyers hy the Top Noteh \auw finns Cunningham Mexer +Nedcine (defendatt Merer) and Storine Romelle and Durkin. Needless +e say detendants lowuyer are not only □□□□□□□ with the reaponsibity of Knowing the Fed RCiv.B. bh alec chaying them re they do nct -the drastict sanction of Apdemnent boy default should be employed Seal et Bulkers, Inc. v. Republic of America Armenia, F. Supp 2) □□□□□□□□□□ G Af in A less senere. sanction than default will act help theac. youn \ owyers. Te the _—_, tt will ne deoulst cripple them. forexample, in the course. ef a conversation with Meijer's attome Kequeod viewed video □□□□□□□ and respectt lly phete Counsel bocame « itt o umeatakye.. Hisancd Wastorced te complain to the United States Ne ideake Sodae. (MS) □□□ certain photos Were, produced. In point of Fad lhesever, the downleaded still photes dont coincide, withthe ddes qWyen in defendant Meijerss “IXTERROGATORIES' Yo PLAIKTETE" copyof which ie anneved hereto oad made @ part heraof as Exhibit A. A CHPy of Requced’e onawers +e Meijer’ interrogatories propounded to Reseed is annexed herete, Incorporated, herein and made port hereof ExhibrhB. An inspection and brief review of Exhibjt A shall clearly reveal) Mej\er attempted Yo prachi ce □□□□□□□□□ by questioning Hecqucod best dlaiadly being in He Meher Stere-cst TU Cermak Road Reman Tilinei's on December le,2016. Hequood was being held in detention at the Cook County Deportment oF Corrections (coo) om Sheaifting charge on December fo, 2lbe, as indicated by Heoweod □□□□ ANSWerS to Meijertne. iatemegatertes Served on Hequecd four 4) days past +he Gourt onlered deadline for semi " written discovery, There ig ne question bet & jedament kay defau tt should be, entered against chefen dont inthe amouth of nine million nine hundred thessand ninety ai hessond dollars 44,909,900. 00) with interest trom the dete of the incidest that ore described in Hegwoad's honduritken pose comphairth: Defendants Censpiradand violated □□ clearly estabilished constitutional ghts. Soe Briscoe. Lalue,(Cite Omitted | (citing Adickes v 9.1. Kress + G 396 US.144,.90 S.Ct. ISAS, Be LE AA HAWU-S.1710); Monely. City of Seliets _us IST SCE, FLEd 2d Biz (US ZoKT). Now defendents have encaced In @ “Sordid scheme’ ta defeat Reaquiocd’s valid claims, et GS ere ice + Bubber Co v.Hosaer US, _ 197 S.GEINTE.\9T LB Ad S85 (U.S 2017) Citing Chambers v Nasco □□□ u.9.32.); Stete Farm Fice + Cas Co.v.U.S.e« cal Rigsby _.131 SG. 4B, 196 L.Ed 2d BYO (us S.20ib Jond cages cited therein. The f.. = 2 hms defendant's interrogatories nded +o Heawood alse \ have him tie en himee\£ □ adtin Mectod Was a Stece cn September |, 20t, (See □□□ A ah Pouye. 2) 12. Annexed +o Heawood's meticn te compel Stefcno-+te cnewer Reqweed's Inhemogatories (Deca) as Exhibits Fand G (Sec Feotnet #4) ace, copies of Hequced's REQUEST FOR PRODUCTION CF DocumENTS and REQUEST FOR ADMISSIONS OF GENSINESS OF OOUIMENTS, Hequwecd complain te the MT that defeadarks were nt coopandting and were, In Fack, □□□□□□ bad faith, For example, Hequoed, pursuant te the Cout's divectves relating te written disa@very Doc #5€) sened en defendant Majer hic RADE FoR ADMESSTONS eee of which is incorporahalhere verbatim and seriatim and made a port heret as Exhibitc. Tn point of fact, however, based ona mae decided by the United Gates Court of Appeals forthe Seveath Greuit before Neqtesh was bom let alorethe Court, Nleijer responded by checting te eachof Hequood simple request for admission which nmbered \ese than Awertaytwe a2), A cepyot Mejjers: “ DEFENDANT, MEIIER, RESPONSES To PLATINIEFFS REQUEST FOR ADMISSIONS CH FaAcTS)" 1S inwrporated here. vedo, Sener ard mad € a part hereaf as Exhibit D. Defendants ace. in defaultand ibis □□□□□□□ Folly Submitted that thie tenerable Court should net hesitate nec be. reluctant to strike the, defendants! anawers tothe complaint and exercise, ths Inkierenth? power te reaulabe. Hreell insefor asthe Fed.R Civ. B and the Coots authority S concemed, Sce United States □□□□□□ Perez, \STF.3d.\ (ist Cir. (994). See alse, Engineers Teinty BBL □□□□□ ction, @25F. Supp 13; Flake vkcenel ) SO¥ F.Ad OR (3. On cc about Apcil 24,2018, Hequicod, Secved on Meijer "PLAINTIFFS RESPONSE To DEFENDANT MELIER'S ELRST SET OF □□□□□□ REQUEST FOR ADMESSIONS copy of which is incerperatedhere verbatim, Seriatim and made apart hereof as Exhibit □□ And possess ne qualms about abysing +Hhe. discovery precess.fer example, Meijer demanded that Hequicod respond he □□ for admissions numbering Qa whopping sikhy two), adclec-still~tragi oe. Meijer clemanded Hequeed respond to the same banal, redundant and irellevart admission relating te a dete; March 29,20t6 when a pheteqraph Was provided to teqwood. A cop of Meijer's: “DEFENDANT, METSERS, EERST SET OF REQUEST FOR ADMISStOns' was filed imtothe record of the cause. cthand on Apeil □□□□□ (Doc te t\2) contrary tothe Courl's Local Rules. The MS entered an OROER Dec ail) direct nq the. Clerk, of Court to remeve. (Dec ate 12) from the recend. Tn point ef Fach heweven sothis Henerable. Court wi | be enabled +o determi ne the ecrantness of the conteme table nature of defendant's inappropriate. cendect; which is aimed at disabling the. Conrt's dbilthy te foack on euccessfull ‘ Chambers v.Nasco, supra, See alse, Clinton v. Jones, 520 US. LloBl, LI □ □□□ IST LEd. 2d 445 (U.S 1491), this prose plaintf€ has re hereto as Exhibtt F, a copy of Meijer's document previcusly designated as (Doc ania) ule loacibal sare iasictie, and 2 steht 4 +he. Mo! CRDERED Hat same. be removed which alerted defendanka (or Should have. alerted defendants Anat -the: mest comply with the. applicable previsions cf Ane Fed. R.Gy.P andthe Courts Local Rules. \4. Ln point of fach heveves, in response te Hequcad’s “REQUEST POR PRODUCTION OF DOCUMENTS" sewed on Mdijer on December 20, 201; copy of which is incerporcted herein, made part hereof and annexed herete as Exhibit a: Meijer again acted contrary to the Fed. R.Civ.Pand the Court's local Rules by, i ling inte the record of our □□□□□□ CEFENOANT, MEXJER'S, RESPONSES TO PLATNTEFFS REQUEST POR PRODUCTION OF DOCUMENTS on Nilay NW ACIS nearly fiveS) menths subsequent Service. plaintiff world te feanthan condi were he to ne Re eee tent His prose: And as indi cote advance. Ground less Oh\ections and Fc\ sely claim Neausood LinveS) asoppostd to Si Ryhoc (cL) Simple requ ests for production of celevactk and admjacable exidence is haraseingMeijers document filed on May 2018 1S annexed hereto ac Exhibit □ 15.Tn poroeraph \ hereinabove. Hequicod quoted the moat eloquent Ruyard Kippling. Tn point of fact, haveren, Requeod fergot a. relesertt a terse. conclusion of Kippling, which states: WTF you Can force Your mind, newe and sinew +e contin ithe the ishondat run =epSit bes Man muy Sef. (Quoting et Ki ppting J ( Emphasi Une) le The Louth noted jn $e MEMORANDUM OPZATOK AND ORDER(Doc. até that Stefanc “euqgestion, Doe \5 at 6-4, the. Fact that Vequsaod □□□□□□□□ the amest repart te his complaint does net mean that he may be. deemed te have. accepted the trey of ts contents" is naieubles, mece ever nescience, and: the Court cited defendants bo Camellw □□□□ 362 F. ad VE, Gee Cth Gr 2004) (issui an order te shaw Cause. □□□□□□□ a defendant for Grquing that the “aint by attaching +e his complaitt the prison review boanl decigien he wae challenging, had in fact acepte tine decisions validity - Defendants ignored the Cocke cleur □□□□□ and guccinct hints; and, have wiclated the spivit 1£ net the letter of Fed. R.CN.P. Ws Weutd the Court be. Surprised iF Stetans had exgnt te have. Heaweod's excessive uae of Fore. claim diamiasel on iennontty qreunde t Given +the cavalier ond iqnolle manner in which the defo □□□□□ have. attempted te escape. Vials) (ty for the ingen te Receood ne sical inipry requiring SuTGeCY he Hequiced 'S nec) the pre oe painh woul not have been Surprised at all. hoiftussthe We. motecled Keameon ae atte bie toe Pa nee do Ta cathaeke uber ocr loutlors ‘personally Hegueed comptes and □□□□□□ Respectfully submitted, bait yf eX AST. G\MEK | (eQuwioad , Sr, pre Ge HIAICITOCRZOZAT Dke~\- K-16 Post OFF ice. Boe, GDOZ, Chicage, Zi conor. Ricaqe, THinors, this the dew of Max: 20\8. CERTTET CATR t-talaar tee ses.) = no eqwood, hereby com fy that hace. Served cit tenet meet ond cafe” lettere -ho defendants, copies of which annexed \erets and Which are La, ee made. Gq eark herest aS Group eehibrt TT. : eclore under he penalties of poqeny the-Cact elaborated ereinabeve crete, and correct. Weqaad, + Date os-24-\6 SUBSCREBED AND SWORN TO beteore. me this the 20 rile cf Muy □□□ "OFFICIAL SEAL" Mellicent Ear S | ; Notary Public, State of Illinois IYY\ GS ( a4 Cu ZUG i My Commission =:pires 12/5/2018 NGTARY PUBLEG Per both Sreten mene lotro of abhelegy: Gee Grogp Exhibit 2). In point of staat econ at 2 le, mes Si the p Cie eee oe ee Hecasood 2 Seer eee Ona ee Ne Speen seguee fer □□□□ GEAUTNESS or Rooters STEFAKO'S AE NSE TO REQUEST FOR OMENS □□ ade. host herew? a OPA ok which is onnesed heretes, | rol □□ delist re aa eeor og Exhibtt T A review of game roveals Shall nee and on ORDER es eeomee. 4 AMES {oe wacrarted Bealberee thy rch □□□□□□ cus an OF | MOF Sd 2o4(2 Ge 2009) Maven Tiff 280 F.2d □□□□ On, 7742-AJT/JCS IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TALMON HEGWOOD, JR., ) ) Plaintiff, ) ) Case No.: 1:17-CV-02887 VS. ) Honorable Gary Feinerman ) Magistrate Judge Daniel Martin MEIJJERS and CASEY STEFANO, ) ) Defendants. ) INTERROGATORIES TO PLAINTIFF NOW COMES the defendant, MEIJER, INC., incorrectly sued as MENERS, and pursuant to Federal Rule 26 of the Federal Rules of Civil Procedure propounds the following interrogatories to the Plaintiff, TALMON HEGWOOD, to be answered under oath within twenty-eight (28) days the following upon receipt hereof: Bs State your full name as well as all names by which you have been known or aliases, your date of birth, your present residence, and if married, the name of your spouse. ANSWER: 2. State the full name, address and telephone number of each person who witnessed or claims to have witnessed the occurrence alleged in your complaint. ANSWER: 3. State the full name, address and telephone number of each person not named (in no. 2 above) who was present or claims to have been present at the scene immediately before, at the time of or immediately after said occurrence, MOTION FOR QDEMIENT PN DEFAULT Exhibit ANSWER: 4. Describe in detail the reason(s) for which you were at the Meijer Store located at 7111 Cermak Road, Berwyn, Illinois on December 16, 2016. ANSWER: os Describe in detail the reason(s) for which you were at the Meijer Store located at 7111 Cermak Road, Berwyn, Illinois on September |, 2016, ANSWER: 6. Did you purchase merchandise from the Meijer Store located at 7111 Cermak Road, Berwyn, Illinois on December 16, 2016? If so, state the manner in which you paid for said merchandise. ANSWER: 7. Did you purchase merchandise from the Meijer Store located at 7111 Cermak Road, Berwyn, Illinois on September 1, 2016? If so, state the manner in which you paid for said merchandise. ANSWER: 8, Describe the facts and documentation on which Plaintiff bases his assertion that Meijer participated in a conspiracy with the City of Berwyn and others to breach Plaintiff's civil rights. ANSWER: 9, Identify any evidence of Meijer’s correspondence with its alleged co-conspirators. ANSWER: 10. Identify the name and, if known, the address and telephone number of each person likely to have discoverable information that you may use to support your claim that Meijer conspired with the City of Berwyn and others, With respect to each such person, identify in as much detail as possible the discoverable information he or she possesses. ANSWER: 11. Have you suffered any personal injury or serious illness since the date of the occurrence alleged in the Complaint? If so, state when, where and in general how you were injured or became seriously ill and describe in general, the nature of the injuries or illness, State further the names or the doctors or medical institutions treating or examining you and the dates of said treatment or examination. ANSWER: 12. Have you ever filed any other suit or any worker's compensation claim for your own injuries? If so, state the court or forum in which the lawsuit or claim was filed, the year filed and the complete title and docket number of said case, and the name and address of any attorney or attorneys representing you. ANSWER: 13. Do you have statements of any witnesses to the occurrence or to the condition of the premises in question other than yourself? If so, give the name and address of each such person giving a statement, the date on which the said statement was taken and by whom, whether the statement given was oral or written, whether the statement has been transcribed and if so, who now had a copy of the transcribed statement. ANSWER: 14. List the names and addresses of all other persons (other than yourself and person heretofore listed or specifically excluded) who have knowledge of the facts of said occurrence or of the injuries and damages following therefrom. ANSWER: 15. Has the plaintiff ever been convicted of a felony or a crime involving dishonesty? If so, provide the date of the conviction, the case or file number, the county and state where conviction was entered, the nature of the offense, the name of the judge entering the judgment and the nature and extent of the sentence. ANSWER: 16. Pursuant to Fed, Rule Civ. Pro. 26(a)2(A), provide the name and address of each expert who will offer any testimony and state: (a) The subject matter on which the witness will testify; (b) The conclusions and opinions of the witness and the bases therefor, (c) The qualifications of the witness; and (d) any reports prepared by the witness about the case. ANSWER: Respectfully Submitted, MEINERS. By:_—7- Z “One of the Attorneys for Defendant Amy J. Thompson Joseph C, Sheahan CUNNINGHAM, MEYER & VEDRINE, P.C. Altorneys for Defendant, Meijers One East Wacker Drive Suite 2200 Chicago, Illinois 60601 312-578-0049 FORTHE NORTHEAK DISTRICT OF LLLINOTS EASTERN Divrsiok TALMON [EGKOOD, SK. Plainti Ff, crV¥erSus- No, (Tt CN 0268 MELSER THC. and CASEY STEFANO, Honencible: MAREN G DANIEL MG Defendants. PLKENTERES SUPPLEMENTAL LAND AMMENDED Ga March (3, 2016, Taimon Heowooel, or (He wood) cerned on defendants Meijer, Tre, (Meijer) oad Casey Stefane Risincd wctis of “ PLACNTDFFS AKSWERS TO STEFANOS IKTERROSATORIES: Hequecd’s cnawers ond □□□□□□□ eee, Each of themiare reasserted and incorporated in the supplemental ond and amended onswers the. United States Magi strobe Sudge, Honorable DANTE G_MARTIN (MS) instructed Hequced by“ MINUTE entry dated April 26, □□□□□ (Doc. +r tt)- On Apcil 4, 2018, Hequood served on Meijer ond Stefone copies of “PRO SE PLATHTETES ANSWERS AND AMENDMENT TO DEPENDANT STEFANO'S TNTERROGKTORTES” lequoad's anewers and responses, each of ther, ace. reasserted and incorporated in the following supplemertal and amended answers the Mm. instructed Heqwoer| mA Minute easier ARI) te Serve on Sefono's counsel, At the eutset tr should be neted defendants have not Aled a proper motion te compe answers +o any Spec} fe interregatery respons heretofore, provided by this pro se plaintiff. United Shotesy. Actes of MOTEOK FOR SUDGMENT PY DEFAULT Land, 915. U.S. Dist LEXTS 1261\, 20 Fed, R. Serv. 2d (Callaghan) \\Oo; Hour Milla of America, Pne.v Ree (477 U.3. Dish LEXES TSe\2; Ln Cesstcupe} Technoloaies Sec Liti wh on \96S U.S. Disk LETS 447.3 Fed RK. Secy 3d (Callaghan) (240 ; Sperling v Holfaon Sapp \3AVG 1196); Moccia Lowe's Home Clee. 2012. U.S. Dish LEXTS 183151; paths aicelth Rriness 20No US Dist LEXTS |\0623 (citing Pressleuw. och lke, 33 FR.D □□ 1964). Seoalan, Kingswars Prose Enc Farrell Rub Corr 30 F- Supp, TIS (0 CNN, 1939) (where Def encont ebjects to interrogatories Claiming -that the plainti f€ geeks te acquire in adilance of “triq| Mnouled @ ond information with respect defendant's defenses. The, defender 5 mation +o sustain ebyections wae Aenies\, Taf □□□ Rule 336) @) provides: OPTION TO PRODUCE BUSTNESS RECORDS. the. answer to an □□□□□□□ tory may be determined by examining, auditing, canpiling or eummarizynaa ray be-deteritined by <xamuning cxdthag, cacptling on □□□□□□□□□□□□□□ parhys business records Gnelucling Elec-troni \4 etore infermaticn) , and if the urlen of decwing of ascertaining ther anawer will be. Sobstant ally the eame. for either por the. responding party Wey answer by WW specifying the cecermls (hat must be cevtewed in SHGctert detail to enable the inkerroaatine re laccte and (dentify Shem as ceaclily asthe responding ei Coulcl; and 2) giving the arene ey Q reasonable opportunity To examina and audit the Fecords and to make Copies; compilations, abstracts, or Summaries L. Please state the full name, address and telephone number of each and eer person you belienecwrtnessed ony of the matere alleged im Plaintiff's complaich. ANSWER: PLAINTIFF'S ANSWERS TO STEFANO'S TKTERROGATORIES ficteen □□□□ Pages exclusive of Exhibts exeaited on March Wave and duly □□□□□□ ondefendarts are reasserted, yeitterted ond \ncorporated here seriatimn. The PRO SE PLATNTEFE'S ANSWERS AND AMENDMENT To DEFENDANT SPEFANO'S INTERROGATORIES cxecutted and duly Seed on defendatts are reasserted and incorporated here. seriatim and vecbetine Tatune with the April 2018 order of the (MIT Doc ae ttt) and as a supplement and amendment to Hequicod price answers and responses te Gtefone's inherragateries Heawoed would pot defendartt Stefane en notice thathe. believes Joseph Petersen witnesced matters in relation te Hequicar's retaliation claims cad conferttions, Hawever Soseph Retersen's “name, address ond telephone □□□□□□ io net within the cope of the. hrowledge of Requced. tn additicn be former Berwyn Slice officer Joseph Petersen Hequioad believes the tellowing persons also witnessed matters alleged in plaintiff's complaint: M. Richard Mrs. Deborah R. Stanisz CRS Depry Clerk OfFicial CaJct Reporter” Cj ey Court of Cook Courty Cireult Court ef Cock County 15CO Maubrook Square \S00 Maabroclh expose Maxwootl, EL 60153 Maywood’ Ti Me Nlork Te \Eag. Mie-Thomas Camstock, Esq, ASetatany Bove" DeKengler ASciotont ailic Berend Office of the Public Defender Office of the Public Defender ae Square. {S00 Reeenk Seyues Maywoo » a Koisd Mouywood; Tico) S> Thongs Dort, Esq. ae ohn Weller ert 2 for Coo Ch Tilinsis CoRR chan stent of Corrections County Builein, / Dalex Center 2100 Seu Chi fee Avenue. SO + Wastin ton. Street pisces Fh GOCE Chicane, x Gone (113) AH-EIO Ronerable Rarer Craseic Esanard M. Tever S50¢c 2 eli Ce ss Cirevit Coort oF Cook Covet Ci acer (Sco ee Square. euat West tet Street Mayu ad, Ti Gers Berwun, Ep co1ee (oe) a5 S600 Sef 20 The PRO SE PLAINTIFE'S ANSWERS AND AMENDMEND Jame: 5 i Berw neaequa officer Nlichae| Gallagher erusdn Police Department Berwun Police Officer CHOI West Bist Stee Berwyn Paice Desachnert Berwun, lh toyoz. CHCl West aot cheat Gee 5400 Berwyn, ELL 6C4O2Roe) 295-5600 Achille J. Chiappetta eSbeacss eA Beruyn Poli ce icor ee ees b4O\ est Al ot Sheet TIrtewnal Revenue □□ □□□ a (NOB) 195 -5eco IGTSN.Aulonwhthe BiNd, MS □□□□ aaa UT BY4ou CECI) C2O-21e4 William S. Massuci Berwin Fics Otcee eal) ce vVeEpe EXO| West Blet Street Berwyn, Th €oy4or Peter Podgor ski Berwin Po he OfFicer Ber Police Department GYO\IWest ast Street Beewun, Cl coyo2n aoe} 145 -56200 Jose ph R. Pesa Berutun Potice Department Berw gh Police Omicer ex ol West atet Street Berwyn, DW eoyor. Asmondo Campos Bern Police Officer Beriiun Police Depackmertt CHO! West 3Lst Street Berwyn, Sb covet KeNin lore Berwun Polige Cicer Berwin Poliee Department E40l WNest Bist | Srrect Berwyn, Ey b4Ou. 2. Fer each ond ex gon identified in uour anawer te nt ate Number |) please ste aakgoct Matter of heh You beliene. mee > 5 Persons winessed. k. Soseph Petersen was named in a civil rights come laink styled and numberwd : Hequiccd N. Chat Berwyn eseph Pokereen(Rctensen) was present when Hequoed was arrested by Sivefone. Peterson is also □□□□□□□□□ Totestify that Hequioed contacted the Berwyn Police Department to feport Hact an indi vidual was attempbing te molest a chilcl. Howexey, when Retersen arrived at the scene he arrested RReawood and; charagA Heqwood with shoplifting: Petersen was present in Couch when Hedured Was Sentenced te. cendvtend diachane and ecerttually testi Red ata heacia conceming the rewocation of conditional discharge; which rash im Qn illegal nine @) year sentence for Shoplitting-A copyct the “ORDER OF CONWIETMENT AND GEMTENCE TO TLITNOIS DEPARTMENT CE CORRECTIO Celati Ng, to Kequicod’s ogres by Petersen #5 annexed hereto and made a Port hereef as ExhibitA, and o copy of Hie “REPORT OF PROCEEDINGS revealing the nine @) year iNegal centence. Was reversed and Heawood Was fesentenced tea sentence for Sheplifting that aractly erceaded the +we @) te Fivels) year statutory Maximum for a Claas 3 □□□□□□ is annexed hereto, incorporated hein and made « port hereof as Exhih B. Peawood believes Peterson, Edword M Tovar (Tever), James TadrausKki Cadmweski), Achille o. Chiappetta Chiappetti), WillianS.Masuci (Maseuci), Peter J. Yadgorshi (Pedgorski), Jeseph R. Peso (Resa), Amendo Campos (Campos), Kevin Lore (herr), Michae| Gal lagher Gallegher), Sand Seared amealia (Scardamaglia) cad the Berwyn Chieh of Police. shall conficm □□ Contentions that delendartts mer and conacted a plon which subjectex Heqwood +o violation) of his “clearly estobilished’ rights, privileges ond iMmunities secured by the First Fourth, Fifth, Si th, Rightth and Fourteenth Amendments +o Ge bas and Constitution of the United States. 42U-S.C, Sec. 1483; Sec. 1785), Brodu u Morland, 313 U.S. ea (USided); Kyles v.whitley BW VS. BET (US. 1995); Tillman Bue, BIBF □□□□ □□ (NOT. 2011); Reiz. Corhex v. Cit of Chicago, 2O|e U.S.Digh LETS □□□□□ Saunclera-Elx Rohde, tre Fad SSE (1th Cin, 2019). Heaweod belies that the individuale named hewinabexe. will feel ty about facts □□□□□ support his claims that defendants conspired and Kneninal 4 □□□□□□□□□□ and malicicusly Violated his nights under fpeth the United States and Lilincis constibstions which pretect hie ridth-te be prokected from Unwasendble. searhed, Sciawes cad Unfoonded charges. U.S, Conch. □□□□□□ XIN; TA. Cong. 1910, art. |, Sec -&; Moxon Dwyer 2011 U 8. Dist. □□□□□ (WDT\. 200); Manuel v. City of Joliet, Copy of whichis annexed hacho, in corporated herein and made a part hewef as Exhibit G. Mrs, Deborah .Staniaz (Stanisz) mai) be called as a wilnese at the trial by Suny inthe couse captioned ahave and is eypected + testi ny that the. Transcript Exhibit 8) ie true and accurate. t+ronsce tet of the Repoct of Proceeding, conducted by Sudae Thoma Tucker who resentenced Heaweod on Tune 20t2 4o a term of Imprisonment For eight (@) years when the statutory Maximo Penalt 4 for sheplitting ts five (5) yoarss for a Clase 2 felony unlese extended term 12 announced in open cosck and inserted inthe. ORDER CF COMMITMENT AND SEHTERCE TO TIUINGLS DEPARTMENT OF CORRECTIO which as rexealed by the Exhibits & ond B annexed hereto was not: Mec. Klark Teague Ceaaye’) real be called a6 a winess atthe trial by jp to confiem that he recewed information Gem Tatemal keira & o+ 20 revealing Hequicod risked his coun perecnal Safety onid prevented a deranged jiamate. fram murdering a female sre membet Nes. Care| | ONei\|, at the Dixon Pace hal Cortex: Mr. Tom Dart (Dart) may he. called as a witness and jether Dart his desi ance i@ expected to Sees it Heqscod was held in detention at the Cook County Departmertt of Corrections (CLDaC) And was nest afforded credit he Sernied ja connection withthe (tleqal Eerttence that Was imposed In connection with+the arrest b Petersen Case lumber 08 CR 16307. Dartis also expected detest that eawoed was }oaing detained at ccdoc.on September 20\e aad September |, 20lle contrary to the ascectionS if, TRTERROGATORIES To PLATNTEEY propainded te Hequecd bry detendarit Meijer. Aocpyot tre, March |, 20l6 "VERTET CATION OF THCARCERRKTION provided by Dart ia oniexed hereto, Incerperated herein ond made a part hereof as □□□□□□□ E and a copy, of Meijers interrogatories, withthe dates of inddarks Speci fied hereinabove, 1S annexed Nertke and mede.a part hema as, Eahibit E Dart is also expected to conticm net Reaweod Was Hein detained at ccbocd on Avguat 3261b, when defendant Mayer Fal □□□□ asserted in “DEFENDANT, MELIERS EIRST SET OF REQUEST FOR ADMISSIONS: Copy of which is annexed hereto ond made. a part heracf as Exhibit Gu Hequood was “ present atthe Stare" Mrs, Chacise Weed (\Nood) shall be. subpoenaed te produce □□□□□□□ documents revealing Fequced isthe ca\Qinal TAs Whisle blewer ulho provided information +e the IRS and; Chief of Rirce Gor □□□□□ refused +o relum certain materials to Hea woor peravant te, a □□□□ ORDER +that was germane to and needed te prove, Requood'e cortentions and caused Hequeed irreparable prejudice with regard ¢ +e Hequood's endeavenr te secure. art awark From TRSM excess □ three. million @3,Cc00, 000.00) Nir. Tom Cornstack ( Comatock) may he, called +o Rens is expected to confem that Nejjers loss prevention acer □□□ Anderson (Andersen) Was presertt at the Cirait Couch of Cook □□□□□□ on or abait December 7,2011 and met with defendant Stefano, During the. meeting the defendants agreed +o \eave instead of See before a “ee and providi “A won Festirony in support of thar contertions that was asserted in the " COMPLALNT FOR PRELTNIENARY EXAMINATION (Doc ae ) cop of whichis annexed hereto and made a part hereof as Exhibth t (ahich Anderson "Denied" Saying in DEFENDANT METSERS RESPONSE TO PLAINTIFF'S REQUEST FOR ADMESSEONS OF FACTS Anderson and Stefano a areed that Stefone would appear before the state qrand jum and provide tripple heoraty embe □□□□□□□□□ and Known fa\ se testimony which denied Hequoed Due Reeess □□ relation tothe falae charge that was decided in Kequicod’s □□□□□□□ Heawood was discriminated against ay Neier ond Slefano aaa reau lt of Hequioad's race and religions beliets. Denson v. □□□□□□□ 20\¢ US, Dist Lexre, 5014 O.cNTN 20\@)(Citing Brunson. Murray, □□□□□ 696 Oth Cic. 2010). Kevin Lorre (Lere) 1 expected 40 er ify tyat he prepare hia Aacunents Styled: “OFEECTAL MORN POLECE REPORT Doce tS-\ fhag 13) in connection with the falee Shoplifting chorae Feeminated in Hequonl's favor Michael Galladner (Gallaqher) 18 expected + ofestity {habhe prepared a document st yled “OFEECTAL. SWORN POTCE REPORT” Doc.a.y5-\ Page \4) in connection with +he false shoplitting charae that was terminates \n Hecu ood's faver. Nicholas Sehjaonne (Schiavenne) ie expected to testify that he prepared a document Styled " OFFECTAL ONORN POLICE meta □□□ □ I5-| Page 1S) ta connection with jhe-false. shoplifting charae. that was decided in Heawond's favor, Scrivonne will confirm iMonfation in Doce □□□□ Defendant Stetane is expected to den that Stefano prepared document styled “OFFECTAL SWORN POLICE REPORT Doct 15-| Page. □□□□ stati ng Anderson: " growed Stefono-- a phele of -. Heasced ener Alrout December A,20\b. The alleqed offender's phole has Aispeeored\ and has caused Keaquecd Irreporalble. prey dice. to his ¢ ase-in-chief. Stef also 19 expected to testify thal Gtefane prepared ZiK(E) page clearmer styled "OFFECTAL SWORN POLTEGE REPORT (Docs (1-49) alochy claiming Stefano “detoined'a aukject later Mertified ac---Hequce| Near-the. restaurants restroom HH eqwood ulas arrested uhen Ste fang Saatched the door of the reatraan epen ond arated Hequeod arcund the neck why |e Heauiood □□□ holding his penis. Tames Tadrawsk) Tadewski) prepared a dowment we OFRECTAL SWORN POLICE REPORT" thease ‘| 20 orn TADROW SK. ook proteqaphs ofthe recevered property, Yecuiecd □□□□□□□□ TADROW Willadmit that Tadeauski tuned the prictexraphs over to defendant Stefan and Jor the State's Nikomnexy. ate police officers, Chiappe Naseuci, Padrawski, Resa and Campos will he called +e testy and Heawood believes their testimen wil confirm Brak Then tie” “ASSISTING CFELCERS" who aided and abetted in the anvat of equiecd\ on December 2,20\% fer Shopli Ting at Meijer . 3.Please State the full name, address and Telephone number of each and every person. vee intend +e call as awitness atrial. Y On ANSWER: Pl ai NTIEFS ANSWERS TO STEFANOS INTERROGATORIES executed on rarckh I, 20t& and duly served on defendants are. reasserted, reittemte and incorporated here. Verbatim and Seciabin. The PROSE PLATNEERES ANSWERS ARD AMENDMENT TO DEFENDANT SIRFANC'S JINTERROGATOATES execu and duly served on defendants a Kori\ 9, 2016 are, alse reasserted, reiterated and restated, here, verbatim and eefiatim, furevant te the. Minute entry of the NW (Doc se) this pre se plaintif- suppl ement- and ameru| Hequice | two □□ pace anawers as fellows? Heauioa's supplemen and amended answers te inherroagter 12S numbers | and Z are, restated here verbatim and <eriatin. 4. Foreachand ever person identi Ged in Uour anewer to Inferreqatoru ho. please state Bae egeck matter of ihe You anticipate these. persons will testify at trial, ANSWER: Plartift's supplemental and amended answers +e interrogates numbers \-3 ore restated and rettterated here. yerbotimand □□□□□□□□ 5. Please state the full name, address and telephone number of each person who Was not present at the time of the. matters □□□□□□□ in Plaintiff's complairch +o whom have male Statements and| or representations of any facks, events or occurrences of the alleged incl de ANSWER > Head made statements, andlor representahions □□□□ events and eccurrences of the alleagd inci dent to onorable Eric Holder Honorable Jeff Sessions Bakes. TE Give Washi novten, D ¢,26530 Washington S gSaeeke U.S, Seeret Senyice a50 Penn: Wand Ave, ue □ Washi naten, D.C, 26500 washington, b,c, 20530 b. Please state. cach and sin 8 that ups believe, Suppor your position that There, Was NO pro ele cayse. Sor yee" La ._ Cae acrest on er about December 220i For retail theft commifted on ar about Auqust 2015 under case number VoCR BENS. ANSWER: Heqwoods "PLAINTIFFS ANSWERS TO TNTERROGATORIES" executed and duly sefwed on defendants on March |4, 2018 ace, reasserted, reiterated ond incorporated here verbatim and seri □□□□□ The “PRO SE PLATTERS ANSWERS AND AMENDMENT TO DEFENDANT STREAKO'S INTERROGATOREES” executed crd served on defend ants on Apci| 4, 2012 ace gl ao reasserted, reitterated and ineocparated here verbatim and seriatin. Nor did Heqweod cart anu ShepliCring, from Meijer on. August St, IOl QS insinuated, alleged and cantended Fe Meijer's REQUEST FOR ADMTSSTORS OF FACTS recently Served on □□□□□□□ to which he has responder porsvantto dine April 26,2018 Minute entry of fhe MS (Dacse(t). As an amendment ond cupplement+to Hequece's pr ror >We @) ANSWERS +o the propound ec| interroagite nom tae pre se. plaintiff would point cut that a police officer mau, conduct a brief inves}{ qato Stop of Q perscn where tre, ofG cer reasonably believes the person has committed, of is Ghout+o commit chimes Defendant Stefano lied uhen he steled in his “ORELCEAL POLTCE REPORT that Stefone “detsined a abject later identi fied as Talmon Heauood O3/4/4e near the restaurant's restuom.” Stefanc arrested Hequeood in the cesteurant® restrem. SteGne was □□□□□□ pani ed. ou, had arson, as indicated by Stefano's OFELCLAL SWERN □□□□□□ REPORT Doce \5-\ Fone 18). Froot postive. Shot probable cause foc ee and Faleely charging Heaood wth shopli Hing Cam Meijer or AvauSt \\ 2015 can be ateaned from the Circuit Courts disposition ata he fact Anderson and \aiver Insine ake onc\ erally, Comb enc Heqwons is culpable for alleged Shoplifting offenses that occurred on August 2005, Avaust 3l,2016, December □□□ September |, and December Z, 2616, uiderntty all the □□□□□□□□ i) elon an issue involved in the, conkers presented fn the pro se Plaintitt hand prinbed COnPLARNT eee in the Ciresit Caorh of Cook County eriot to the favorable hermination of the fale shoplifting charge Filed by defendants Metyen Stefano and CoP, 2\. Adntt that the photaqraph attached as Exhibit depicts you in the heath and beauty or personal care. section of tne. Wy bi dates of alleged Shoplifting incidents Were communicated by, Ancleraon to Stefone and “acon, police. efficera, In □□□□□ at fact, Stefane, COP and others uwlho cons Pired with, ete late were, aut to ack Heqwood +o preven him. from pense tion te TRS, POTand FAL, Defendants ulere also motivatec by, a class baeed invidious diaciminatony animus and widhed +o and have in fach caved Weguocd physi cal, personal and metal ann and numeus anxieties too numerous te mention. Because tea: Weed 19 African American Ig an inset? ident basis fer Stefanc or any other poli ce, oicer +o ares Neawood or aes dork akinned individual. Dilineis v. Nacd low, $2% U.3.UT 8. 2e00) j Ttlinois yhidster SYO US.419 3,2004), Defendants totally and maliciously disregarded Heqwood eights Secured {by beth “the United States and Thincis constitutions whieh protect Weauood □□□ other American citizens! right +o be free from unrwasonole □□□□□□□ ond seizures. U.S, Const. amends, iy, KW} DA. Cons. \M10, art.) 8 6; United States v. Sake, 490 U.S. (U.9.1989) (queting Tem WOhjoO, □□□□□□ 1984); United States v. Bchmon, 689 F.2d CTHh Cir, 2012); Unibet States y. Uribe, 109 F 3d G46 (Hh Cie, Aet3)) Recpley House, □□□□□□ 325 (S.ch.2i\. 1190); Replay Clase 296 Ti.2d 491 6.ctRil.20(0); □□□□□ wMlitche ||, 653 900 (App Til, 2e0¢); Poople y. Gu095. 5) Ned Apexi, 2O0\'c) | feeple v. Faulkner, 2O11 XIL-App.Qet) ($0027 App. Titzer) □ Feaple ML. Booker 20\2 TApp (st) \SObB 2-0 (App.Al\. 2018); People y Seo 2018 TDi\. App. LEXRS ©35 (App. EW. 2018); Reopley. Hormon, 2018 TILApp □□ LEXTS (20 (App. 21.20/68); Pecpley Prano, 2018 App. U LEXTS 267 □□□□□ 20\8); Feoplay Redd, 201€ 1. App. U LES 263 Al.2018); Reoplen. Harris, 2016 Tit. App. □ KEXtS 26% App. Til. 201 é). Peopley. Timmsen, SO NAS 1092 Appi. 2018). The video Footage From Fbpeug's Restauran Shall reveal tha} Andersen and Stefane are. eu\pclale. for Violating □□□□□□□□ Fourth Amendment ahha. Peeples Thame, NE-2d U1 Ape XM, 1997) 7, Please state each and every fact that uou believe. suppe ovr position that tHepewWQsa No probable cause So yer Sent ee Ro peye Restaurant located at 6953 Cermak Read on December a, for retail thef> commited on or abouh December 2,20 under case, Number \ECR ESR, ANSWER PLAINTIFFS AKSNERS TO STEFANO'S INTE RROGATORRES excaute and dvly served on defendants on Marah ,2012 and the PROSE PLALNTEIFES ANSWERS AND AMENDMENT TO DBFENDANT STEFARO'S LNTERROGATOREES exeavted and served on defendants on April 4 □□□ are also reqaserted, cettherabed and Incorporated hore, he, □□□□ Plainti¥f’'s supplement and amended to intemegatory number © hereinabove.i& reasserted here, Please state each and exer fact that upe lnelieve Supports Your claim thet You were. Subjected to excesswe force, at the. Ropeue!S restaurant loccted af 6453 Cermak, Read on December 2, 2016. ANSWER? Stefane veed exccesive foyre when he Grablo« \ Hequicad by +h neck and evt of Hequiced' s breathing while Hequiced wes in the restroom at Fopeye's Louisiana Kitchen Restaurant: Heauicod nearly los Conecicusness: however, someene demanded that Stefano? "let him oe! Stefane eased his ori ond demanded ther Heawood respond t© his Andersons’ questions, te. what did yeu do with these, te □□□□□□ Keqwood Was it distress and vnable te Spea - Benowse, t+ wag cbyjou ‘that no shirte were In the tinu size restroom. Steffans hendesfed Hequood and he and at least for (4) ether uniformed Benny Police Oficess □□□ Hequood ta o patro | velicle. As Hequiced was being led away he overheard someone, whem he believes was Andens Sau: T gotthem, Evidewty, Andersen had brevdt chirp which he places ona seat inside of the Pepe e'S Lovisiana Kitchen restauratt. Tn-forther answer +o Toba Interrooptony qu mber @ abeve this Talmon Hegwood, Jr. #2017—0620227 Cook County Jail P.O, Box 089002 DIV2—D2-N-44 Chicago IL 60608 US pro se plaintift would peitteut that a claim tike his thet celete +o unreasonable and unebjechve ferce, In violation ef the. Constitution requires 2) an inp 2) which resulted directly and only from the vse of force Ret Wag cleady excessive +o the near and 3)the force used was clearly excesswe and ebjectively unreasonable. Hequeod Sustained aNerYy Geciovs injury in that the cheoki ng by Stefana caused internal heer ond G Hasve mass in hig neck. There, 1S no question but thal the facts, cortentions ond assertions in Keqweod complain and elaborated hereinabove and belous Supports Hequeed's claim that he was" Subjected te excessive forve ab the Popeye’ restaurant at 6953 Cenak Read on December 2,2016. Peter. Praubulski, e220 F Ad 6F1 Oth ic (981); Cannon v. Burky bile, 200 U.6. Dist LEXIS 139; Jehnaon v. Morel, □□□ F 2d 417 GthCir. 1989); Heque Cushman, 2605 U.S. Dist LRKES 21ce3 (DeTiL2005); Simmons v. Brien TTF. 3d 1043 Eth Cie. (946); Doyle v. Pasquine, 2006 □□□ Dist. LEXES 9718; Harper wv. Hacris County, Tex, 2t SIT Sth Gie.taa)i Lave Justus, 2007 US Dist LEXTS 4TTU Horris v. harvey. □□□□ □□□□ 320 (Hh Gc. (914), Edwanls Butler 2004 U.S. Dist. LEXTS 26564; Lampkin v. Cityof Naceqdeches, 13d 430 (Sth Cir. (VV); Hally. Ryan 2006 ).S. Dist LAxtS 1656 United States v. Genzolez, □□□□ 560 (Sth Gir. 200¢).T4 must by all meansbe noted and remembered, +hat Stefanc's conduct was also in direct contravention +e the. weiter “POLICY” of Berwyn Pelice De pactment relating te the. "USE OF FORCE. copy of which 1S anneyed te Hecuitood's Motion te Compel answers te interrogatories (Deca* 93) ond for the convie of defendants, a copyis annexed herete as Exhibit. Edibit □ at page 5 (top leHthond comer document) and also marked “STEFANO Talmon Hegwood, Jr. #2017—0620227 : Cook County Jail P.O. Box 089002 DIV2-D2-N-44 Chicago, IL 60608 1:17-cv—02887 000033 (lower right hand comer) impticrtly and explicitly forbid Stefane and other Berwyn police officers From attacki NG) Hequcod ond □□□□□□ Similarly Sitvated throat and] orneck areas. “Treterttional impacts +o the Wend and neck areas will be oveided unless The use. of deadly force. 18 reasonalte and Necessary. 7. Please separately identify and state each and aiery clement □□ damage that Yeu are seeking inthis cage as against defendomth Stefane, including but) not limited 40, the amoutts being Sova for loss Wages, personal iqqery pain and suffering, emotional clistreas and| or ponitwe damages. ANSWER PLAINTIFF'S ANSWERS TO STEFANO'S INTERROGATORIES execcted and served on defendants on March \4,2018 are. reasserted, witterated and incorporated here. versotim and Sectatim: and the "PRO SE PLAINTIFFS SUPPLEMENTAL AND AMENDED ANSWERS TO DEFENDANT STEFANO'S TNTERROGATORIES executed and served on defendants on April 4, 2018 are also reasserted, reiterated and incorporated her verbatim and seriatim- Tn tone and in compliance with the Court's Minute entry cated April Ql, 2\e (Dec ae 14) -Hhia pre ee plant supplements ond amends his prior answers as follows: a. Hequiced has been deprived of inheritence With regard to a preaee tH SER SOG Hequiacd's Cleaners + Tailors and ig irc debt in an amourtt in excess of twe hundred Taieeene ($250,000.00) a¢ q result of the Conduct of defendants b. Hequiood has been injpred In his mind, body and ecovlas a result of the unlawful conspiracy ON the part of defendants Meijer, Stefane, COP and ethers aimed at ond did, in fact deprive Hequeed of " clearly estobilished right privileges and imeuniti Secured by First, Fourt, Rtn, Sixth, Eighth and Fourteenth Amendment tcc wd fo OAM Talmon Hegwood, Jr. #2017-0620227 Cook County Jail P.O. Box 089002 DIV2—D2-—N-44 Chicago IL 60608 US +0 +he. laws and conetitutions of both the United States and the. State ef TWlinois, al\te Hequced damage in an amantjn excess of one million five hwadred thousand dollars (H1,5c0,c00.00). a. ae ae Stoked hereinabove. has been deprived of an qwand from the Internal Revenue Service in anamount inexcess of three million (43,000,000 .cO) aga ress the delibert) intentional, willful and malicious not to mention retaliatory conduct of defendonts. d. Heauood has heen deprived of the 41,200. yecr|y Veuelher One thevsand +wo hundred daver he had been granted by, the. ae Rousing Autherity CAA) as a rent aubsidy AS areslt of defendant's inkerttional, will Fl, sustematic, doedt fu and maticioes Failure on defendants and their ©-conspirators failurete □□□□□□ Kequioods personal ee him in direct defiance of a □□□□□ foRDER" dated February 25, 20% signed by Honorable Ramon Ocassio, all to Heawood's damage in on amount i excess of thicty five Sucant dollars ($35,c00.) e. Hequieced' 5 neck has been inured QS a result} of the excessiv use of forve on his person by Stetenc and upon information and beli Surgery is required and sciataos echeduled to. repair his □□□□□□□□ +o Heqwoad's damage in on amount eaceed ing ene million five hundr thevsand dotlars \,S00,c00) $. Heawood is entitled to ponitive damages in an amounttin excess of ($3,000,000.) three million ddllara with interest from the date of the ocoufrences and incidents described in Heawood's complai nt: 10. Please state the full name, address and telephone number of each and every person who ere ded you with medical treatment fer your ines allegedly uffered ag a result of YEUr OFRET of December 2,20\b, ANSWER > Hequood's “PLITNILFF'S ANSKERS TO STEFAKO'S THTERROGATORIES and PROSE PLAINTLFF'S ANSWERS AND AMENDMENT TO DEFENDANT STEFANO'S THTERPCGATORIES executed on Nard}, 2018 and April 94,2016 respectively and duly Sened on defendants are, reasserhed here. Verbatim on seciatim. Persuart te the Minute. entry (Doc sett) of the MT. Heawcod amende and supplement hie priar-two @) answers as follows: Hequioed has sent correspondence. to beth atherens whom are charged with the responsibil tty of viding lecal advise. and representation to def endents afong ak sixtyseven (60) □□□□□ of medical records compiled ond □□ boy Health Care Prefessionals (HOP) at the Berwyn Fire Depertnent and Macecl Hospital. Hequood is Seventh (7) years old and any Injory to an elderly Widividval, Ne matter what his ethnici ) and] oc apes is Very Geri0os. The medical reads the result of dracknes Admin stered +o Heauioed en December 2, 20IT Heawood was treated bu: Joseph, Chiappetta and Ryan Denson, whese reports ave annexed heres and marked on -the heck exes ofthe Exhibits as numbers 1-9. □□ MacNeal Wespitals EMRRGENCY ROOM Heauced was examined andl treated by Dr. Tudith Teoa-Bapti ste, EDD who prescribed "S00 ma DOSE pain medication be be administered "Every hours, (Teche Recexd Deca Tt should be noted that MacNeal Heapttel Is the Health Care □□□□□□□□ n Police Department contrac with and where ninety Five □□□□□□□□ (95%) of Beran peli ce. amrestees ulho require medical ass} □□□□□□ are troated. Detule Stang 2 eesidert ab Nachle Nurse Arctheny □□□□ ip PAD) alae administered trectmant -be Heaucod on December □□□□ The telephene numbers forthe Health Care, Profess} onal s 1s Fee) TS3-UCO.. Heawood has alse been examined ond 4reated ly the medical ebafE at Schn HK. Streage (Strecer’) Comal and Westlake Keo spitals. Copies Talmon Hegwood, Jr. #2017-0620227 Cook County Jail P.O. Box 089002 DIV2—D2-N-44 Chicago IL 60608 US of □□ medteal records from Streger, Cermak and Westlake Hesprtals shall he pre vided ~te defendants sub sequent to the. S cempliance with Guppacnas j ssvied pocsvortato Fed R.GP, 45. I. Howe you ever been convicted of CW crime. 4 If se, statethe, dete of the Conviction tre nature af the crime, and the penally impos ANSWER: Heqwood has been convicted of a crime. Pursvattte the □□□□□ ORDER (Doc 4-47) an updated rop sheet ules provided by defendant Stefano and tiat not only the, prose. plaintiff's conviction ond nature of offenses Wot awests as-vwiell. Heauiood, of course, Shall provide additional infermakion when the FBR provides Sane Pers Vont te Heauiced Peeedorn of informal en oct □□□□ 12. Have you ever heen a porty to ony \aweutt: TE go, Stele the Full caption of the \ou: suit incloding the decKet number, the. nature of the, lawsuit and the ultimate ouvbcome of the □□□□□ ANSWER: Heqwood has been o pee lawsuits asthe defendants are Canizarct asd So advised tne cb orvimere than omeoeccas ina irae attemet to pragedice Keauoced. The. lawavits □□□□□□ has been q party te are as fo\\ays: Hequced vy. Cityof Berwyn, 2089 US. Dish. LEMS 49365 (W.0 2 2009) Heawood v. Weis etol. 2004 US. Dish LEXTS TH45 (N.0-Ti\. 2004) Heawoal \. Redgers, (dau U.S. Dist LETS MTL (A DTA 1496) Hequiced v, Carson Pierre Seat et al. 1990 US.Dye} Les 4285 □□□□□ Heqwoed Shephard, U.S. Dist LENS 1356 NO Di\Vey \4 equoad \ Senes-Tapia, ekal. Ne, VI-W-OV2e (KM. Oi stT\. 2017) Heawoed ¥. IDOC may Contact muy dhomens at Heller Welmesr □□□□□□□ Heqwiced \. Meier tne and Casen Sretane Wo, 2OK7T- 254 (Gr Ch □□□□ Gout IS ef 20 Talmon Hegwood, Jr. #2017—0620227 Cook County Jail P.O. Box 089002 DIV2—D2-N-44 Chicago IL 60608 US Hequeod is also G pane clase action ewwil rights actons-which causes chal| be made available +o defoadonts aleng wrth other requested irformedion aS Sxpn 4Ssame is inthe Scope of Hequicod' Sg Krew ledqe.. Respect full Submitted, J OFAY ue Q wood, Ur, pro se, de DONOR ALY Die TR Peat Office, Boy OBQOOZ Chicaqn, Ty EOLOe CERTTERCATION XZ Talmen Heawood, Jr. costify under the penalties of perjury pursuant to 2BUSC. Sec, the facts asserted in m4 answers +e incterrogeteries ore-tme and Cerreck aimoert| |eqeeea, Vn SUBSCRIBED AND SWORN TO before me thie the! ton cf —s). —___.,, Ave " SEAL" Jot . Notary Public, State of Minois : My Commission Expires 42/5/2018 19 of 20 IN THE UNLTED STATES OFSIRECT COURT FOR THE NORTHERN OESTRELCT OF TLITNOTS EASTERN OLVESTON TALMON HEGWOOD, JR. Plainti 2, No. (2:11 cv 02887 a Henerabte GARY FEINERMAN METSER,TRG, and CASEY STEFANO, Honorable. DANTEL G. MARTEN, MS, Defendants, PLATNITFES ANSWERS TO STEFANOS INTERROGATORIES TNTERROGATORY No. 1; Please state the full name, address and telephone. number of each and eNesy Person You believed witnessed any of the. matters alleged in the complairch ANSWER? Fedecal Rule ef Civit Procedure, (Fad. R.Ciw. P) 334) providesia pectinent poct as fctlaws! “ OPTEOH To PRODUCE BUSINESS RECORDS, LF -the. anewer to an interrogatory may he <cetermined by examining, auditing. compiling oF Summarizing a partys business records ((n cluding electronically Stored information); and if the burden of derixing or ascertaining the. answer twill be schstantially the same Cor either party. the responding party may answer bys () Specifying the records that must be reviewed, in seffictent dertai\ te enable the interrogating party te locete and Ident them as readily asthe responding party could: and □□□ ye (2) giving the intemegating party Q@ reasonable, opportunity te examine and audit the records and +o make copies, compilations, abstracts, or Summaries. Defendartt Stefane Hally Perisred himee|f ond conspired utth defendant Meijer Tne, te cover-up where, Hequiced wag □□□□□□□□ Stefano and others preporad reports with Lallays informeakion ond émbellighments asserbed therein. An the defendants, reports, □□□□□□□ ina, bet not limited to the INCEDENT REPORT prepored by Neier OFFLCEAL. SWORK POLICE REPORTS, ARREST RRPORT prepared by Vow enforcement personel for the cihy of Becwyn, REPORT OF GRAND JURY PROCEEDING), MOTION and Pleading Filed in thre Cirarth Couch of Conk County Uti ncis Giting in Nayuced), PRDER of Honorable RAMON OcASSTO doted Fel ary 27, JIL (Which dismissed tne Lalse, sheplifting □□□□□□ over the OBIECTROK and demand for bral hou, jery ATANOK HEQNWOOD IR, CHeauoed) Prainttf? herein and Inthe more than seven hundred seventy pages of docoments which Heawood Seevred Vin a RRORMA te produce. and of which Reqwood □□□ □□□ Honorable. DARL G □□□□□□ United States Magistrate Sedae offered te counsel of record Re beth Meijer and Stetane. Hequicod Praduced the. seven hundred Selena (Me) Pages of douments ts defendante counsel Peeseant tothe ORnER of the Court dated February B 2618 (Dec te, G4). Tr point of Pach deferdants CaN Secure copies of the. We Paes CF decmentts by contacting MeNichela Sceuffas Ban, Genera| Gunsel forthe Cook conte Sheri ahich will ns dows} pron tde. the, name) addresse(S) and telephone. number(s) of ane) and cll persxve uho mae ne Facks within—the of their Krouledae. ¢elati ng to the, matter alleged in Raint-Cs 2 of ic COMPLAINT. ENTERROGKIORY No. 2: For each and every person identified in Your answer te Tnterrogatory No.1, please, tate, the sobject matter of whet You believe these. persens witnessed “The: information providal inthe cocunents referred te in this pre se Plaintif{S ANWAR to TNTRRROGKTORY No. 19 reasserted here. The. videos and pheteqraps are. what commen referred to as "silent witnesses and under the silent witnece theory the. enidence. Speaks fer rtsel® mefietd oft Inquiry atrilatedtbo Fed R.Civ.P as 14 loroad as the ope of examination under Pole 20a), Useful information can he Qle aned alse feom an Inspection and review fo Hequiced's " PLAINTEFFS TNTERROGATORTES" ond "PLATNTEFF'S ANSWERS ‘TO INTERROGATORIES" propounded to Hequiced\ buy Acfendant Meijer, Ine, coccnspimbocs whem deferdart Stefano col\eborabed with. The subject matter of what Hequiced, believe’the. persons witnessed fn the, Meijer Shore, and the, Popeye's Chick en Restovrant concerns at least 231 « (b) different Berwyn Felice unmarked and marked patrol vehides and at least seven different uniformed Berwyn Police Officers each reer □□□□□□ panies indi eating Heir Conduct 1g adtherized 3 eet □ displauing wi Ons, j-2, ninemillemerer quis, thicyes Ss, fr - vr Whois fity Sey en (21) dite Thee □□ were prepared by defendatts Stefane and Meijer and append bythe Chief af Police, CoP) for rerun Police, Department (Pb) ace in the, Posseasion. of Stefano, The decmert produced fy the United Stcbes Attorney fer the. Werthern Dishrict of nines ewe, access able. by ilizing the. Cooct's CH) ECF System, Hequiond s □□□ response te defendant Meijer notice. for prodsetien af decoment complete, copy ef which has been duly senied on Stefencs Pikomene, IS incorporated herein Jay reference, Tesheuld be. neterd thet Under Fed. R.ciy.P 33 Hequood 1% accorded the tiahct to invoke Such Protective orders under Rule, 33 as are appropriate, to the situation, Including bot net limited +o individuale whom are, attempting te aid cetendant= Menertne, Shefona and the unnamed Coneniratorss employed at the CCDOC Whoee overt acte tn fuctherance ef-the. conspiracy include bers net limber -ke ‘Tampering with mal to and from the Gort and denying Hequiced access to the □□□□□ library and facilites for ths vee In a meoningt\ manner TNTERROGATORY Nod Please state the full nate, addcess and telephone rwmber of cach ond Chery Person Meu intend +o call @ witness at trial. Hone ; be . neteie x i mbber|y F % Henerable Dercthy Broun, Gos K Ceunhy tinois Cirevit Courk ef Cook aia, Saonee epee es Zare Chi LAOS, se CD, Mayu ote ote Me Willi x. Mc tt, Mekinsen, ral Sustiae, FRAGA! Uv NES ; Criminal Guettes hee Coates loo Guster Hellan Read Clarke burg, WV 26206-0001 Mrs. : Sates Shanta, Gove Nice Charlene Caen Atrorm Loui Deportment ofthe tre: Suny hitcoonesy Rag mtction Aantemal Revenue Service: (will id address) i913 NK. Rulon White Blvd MS □□□□ Chickgo, GOCO\ Oaden, UT BHYoH 4 of □ INTERROGATORY No-: Foreach and every Person identi fied im your onewer +. interrogatony Ne. 3, please state the subject matter af what ane anki cl pare. these. pereen wi Wheatity +s eck Wi ANSWER ; Keaqweed intends to e@lieiy teshimeny Grom the neoroble Kim Fox thet the doursnernter viz. Grand tay Seber Stefan accurate, RERORTS CF PRECEEDINS relating to the shaphifing chorge ht WAS deci ded 1 Fao, Hea algo intend, intend te elicit testimony revealing “AS AG CRI@BYS was intally conceived after Anderson conspired with others ond alaned □□ NCOMPLAIHT FOR PRELIMINARY EXAMEHATE CA” copy of which □□ annexed herete, tncor po rated herein and made a art hereof as Exhibit □□ with shoplifting From“ Megiers Greco Sern Niolation ef 720 11.cs 5| le A~2(@), The pre se, PlaintifCauil\ alge att techy mer revealtn i Honorable. Udee, Remon Ocassic Signed oq ORR" copy of whichis annexed hereto and made a Poctheresf as Exhibit B, moandeting “thah the, shopliting □□□□□□ People. Heaweod, No. le CR J@GHS is } ami Sse. Annexed\ hereto, Incorporated herein and made a part herech as Bahilathcrie copy Of a Court Deeument or A coomert reveclin. Heoweoc| demondec and put defendants on nee that he heat to file a cemplawrt demanding er cee: and INnjunctre lier of abet Sanwany 23,2211 a mo prier te » CRDER diam □□□ the false, shopliPhag chorge: Berwyn police Krewingly, intentionally deceiHfully ancl maliejovely foiled +o advise Honcrable Kimiaerly Fon. thatthe “267: Shirts! refered te tn the scorn "GOMPLATHT POR PRELENGE NARY BXAMTNATRON copy ofwhich is annexed herete, Inco cabed herein as Exhibit Huwas “Rewvered horn ‘BUSTNESS "as ‘dicated □□ 5 of fe the BPD “EXRDENCE/PROPERTY FORM Defendants Meijer and Btefore, beth ef them, sheuld be ashamed fer Practicing a Proud upon the. State's Athomen, Ciresit Court and Hequiood. Now Stefanc ond Meijer expect thee Rlherneys to “pact the ced eee ina deaperate, and, ignoble attempt te ot civil Vidbility jn an ignob|e manner. □□□□□ itis vey doubtful the will manifest reloctance with regards to Imposing available sanction onthe recalcitrant party, ulho □□□□ invite. such a response. Ae @ matter af Lact dre Court hinked □□ the posaibility in the MEMORANDUM ORTNTON AND ORDER dated Septemper \4, 2011 which denied defendants motionte dianiss. Tere jg no question but defendartts have caused the pleadings to be multipli ed and come very close Crossing the line where Fed R.Cw.P, Wh is concerned. For example, onder neo charitable. stretch of the leaal imagination should there be. three ®@) drflerent Court ordera that Concern photographs (hich anyone. with common sense realize, had +o hare bean tumed over tothe State and Hequcod during the malicious proseastion jq the Cirauth Court), See 26U.$.C.8,S1F2T; Toue Tie + Rubber Ca. v. Attica Tice Carp 2018 US, Dist LETS 22... □□□□□□ example 19 defendants cloim that they mailed \etters te “Low □□□□□□□□□ Conmella Richard aon (Richard aon) ond Mudel Goutter (Gosker) beth whom responded to Kequood's administrabwe romed complairt "Grievance ae 2008 En Feevary 20, 2018 by sain □□□□□□□□ sen and Gautier “prp rot" receive, zee tetter from Meier's ceunse\ celoti ng to the hearing, had or Februany 2, 29\G. CCDOC □□□□□ initi ally ordered, Heauseo 4 to \2ave. the, low brary because □□□□ were Unaware of the hearing scheduled bythe Gouch A copy of the Geiexanee, | Response, 1S annexed henete, Incomerated herein and mode a part hereof as Exhibth E. |. Stefane's name, te onthe EXTPENCE PROPER Farm whichis marked Exhibt+ D TNTERROGATORN tho. S; Please state the full name, addazas and telephone number of each and even Person whe wos not presert at the time. of the. matters alleged in Plaintiff's Complaint to whem you hove. made, abatements andl ec representations of ony facts, exerts, on eccurrences of the □□□□□□□ deyck, ANSWER? OBSRCTION. Hequiced Previded a short, plain, and detailed □□□□□□□□□ facts in his eriginal COMPLAINT Aled tn the office ofthe Clark ofthe. Cirevit Courtot Cock Canby which defendant Meiier and Stetane elected to have removed te the Forum which mosh of the mes a haven ef refuge Cor Heausood ond othere ar. powerless, Criendless, penniless? bet nonetheless Gnd the wherewithal and aeek bo redress the deprivation of our nahts that are “clearly estab} ished" oy the, laws ond Gonstitukon ofthe United Statea, Every American citizen whe has access to a Computer and the Courts " Electronic Gase Filing (ECF) System. De fendartha propounded such a nescience (very tosthim proce Plaintiff □□□□□□□□ as a result of Hequoods offi danit(e) of service annexed +e his pleadings. Well, Hequiced would point out that he has been communi cating Nia Cone spondence, with the United States Secret Service 65), DOT, FAL, CBS, SunTimes rout nely For more than fourty (440) years. Hearwood has never □ Bolicited an funde nor complained falsely or unmeriterious| As a matter of Fact, Commurleatina with eek, DoS end others hae Keet Heawoad aliv Li erctrary bo tne desires of defendos who have and combine +o Cone. pire. te Cause. Heqwoed substar Hal personal prewdice, irreparable harm if not decth. Tof | INTERROGATORY Ho G: Please state each es ery Pact that you pect Supports your position Ynatthere wae ne probable case. cmtideccnn abot December 220K, for retail □□□□□ AeENG., Q ut August 2018, under case rwmber lb ANSWER: Hequood did net comit an retail theft on Augsat it 2015, December Ie Olle, MOP On & ‘. aa referred toin the d : ent □□ = BPW eer sas, COON TTERRCGATORIES To PLAINITFE \ Prepound ed to Keawoed by defendant Meuer Meijer Selars, COP ancl ethers Known and unknown soaagited hen 3e, +o □□ the fact that there Was no prcnala|e eqguse, Ser the arrest batrery, acorely oura zwre, Of ne or Decamberz, 20\% nor for the Lolee charaz rete ho the, alleged ehoplifting offense, that ataked oocurred, Cn Decem ber 2, 20\6- The deLendarhs COMEPICA violated Hequiood's clearly eatabtlisher MANDS | ectitans and Immunities epcured fp oA ne, Routh, Freekh, Sty and FoorbeenW Amendmenks, S22, Dehnsony Miller e€0 RAd 34 □□□ cin, □□□□□□ Moora ys Marketplace Resh Tne, 184 F.2d tSae Cth Cin WSS) Gromenos vtewel. Cas ./7191 F 2d VARA Guth Cin \4e) - Defendant May and Shefane Knee there wag no \e, eased ten the arrest of Haqueed In tha teller at the Popeye's Levisiana Kitechan' which je tre reason Andersen left the, Covurthevs after mecting with Stefano on or about Pecembe, 1, 20 and Anerfore,, Huqwood ia entitled te domagas See Broche v.Ciy ef Chicage, AS\T v8. Dieh LEXES He2reg, Meijer ond Stefanc attempted OQ eth do and did in fact miatead the, States Attecnen by laina, be the Grand Jury anal witholding exonerahing 2xtitdonae . A Copy of the REPORT OF PRECERATNG styled: "REPORT OF GRAND JURY PROCERDENGS Ig onnexed to Hequoed original Comprar CDeoa ae (5-1 Page. 33) “Directy behind the paguTdevs testinons Stefane again appeared before the, same, rane yermyons □□□□□ gommitted Pare™M when he fa} sel, claimed Hequoed WAS arrested “near the, stere oe copy of the, éond REPORT OF PROCRERINGS styled? " REPORT OF GRAND TURY PROCEEDINGS ie annexed to Heqwoed'e original ComPLAINT (Boats Page Aq-43) aad loth REPORTS ore incorporated jnrerein □□□ reference. TENTERROGATORN No.7 Please state each and ENEMA faek- that yet belteve supports yer posthi en that there was re prebab|e Cause. for your arrest of the Pop eye! s reshourant joaatad at 6aas Cermak Read en December 2,2Ote, for retoal thett Committed on or about December 2, □□ punder Case wm lo □□□□ ANSWER} Heguoed's ANSWER the RUTRRROGATORY Ho & ake® □□ restated here. Hequoed waa \mmedi ately" seized" when Shefone Snatched the deer opan and grokeed Keguocd ay the, neck and choked him, And arson Stood malt behind his co conspirator Sbefano, While Stefone choking Hequeed And @ecson Was Qsking questions “Where, ame, those, shirt?" Hequiorod Was Unable to discem whab was gel nq on because, he was aitll holding his penis and almost Sciled himeelf, SHefanc (8 tallerthan Hequood and becouse. Hequnood was holdin a his G ofl partis the, only part of Heawood's beds accessable, abthe tme waa Hequoed neck which Stefons Aqueezed and caused lhe a to almost lose anaaiov Sneass, At is elear thelr Daag and Anderson efRectwated a forceful arresh of Heqweed that was unreasonalale, unconstitutional and in contravention of Hequoods ‘clearly eatabi lished” Fights, tleqes ond Sng es Seavred bey the Fourth frmendimercth, See Baker v.MeCollan, HHS US. $37 (shy A\laci gkebv. Olive S10 U.S, 26 &.3,\9a4) Newseme vi Meblally, 25le fF. ad WAG □□□ 200\),.\Nhile it ie Arua, that in making a deciatonto arrest teawood Or Onn other American Citizen & Police, eftirer \tKe, Stefan may rely on infermation provided +o him ha the, Vicki, or buy on eyewitness to the crjme, thabthe officer masonolel Palaoaha telling the troth, Ta point of Lach however site Bogie Fa wtdied thot he relied on fellow lew enforeemat perecnel; Spedfically hia dispatch offtcer, Bub the Biapakch officer did not Rave suffi dearth information te enable her be arm Stefano With Probable cavac, All Shefanc Nad was Avr, odae and Afmean Ametoon wiale adull ct aen of of the, “ed Stotes by the necks Ina Small geace,, holdin his pani 2 That may, have, heen probable cavae Ir TAG, Dx, mont of Fach however 1s net enoyah Yodan, ROP wae Te2novah Lon Fourth, fumendment purposes on December 2,20) 6, Sea, United States. Tohnson, SH FSd SU Ether, 2011) Docen □□□ Cityof Chicgeo, Be Bd ST Mth Cin 26M) and Goeeny Newhoch; Bos FE Bq 62Q Ath Cin 2011) and cases cited -hesein, LO of XNTERROGATORY No.8: Please cach and evens fact Hot You he \teve Supports your claim, that You were subjected te excegsiwe-fave at tke. Fopeye’ % restaurant located at □□□ Cammadk Road on December 2,20'. ANSWER: H equrcod's ANSWER “To INTERROGATORY Ne 7, alaove, |= reshabed here verbahim. Dnadditon th must be remembered that Stefos.o test Pied under oath that Stefane arrested Heautood "near the store! (Feferring to Meier's Store, “located at TW Neat Cermak Read"). See. REPORT OF GRAND SURY PROCEEDINGS onnexed bo Hequeed $e aina,\ COMPLATHT (Doce 1-1, Pages 34-43). And, again Stetanc asserted in arrest reports (which Stefano affirmed under the penalties of □□□□□ were tre) that the arrest \ocokion wag at Wea Cermatt Read Renwun. Stefane ret only, veed excessive, force. when he orresred Heauoed in the absence. of probable couse; Stefono also conspired ustth Mejjer te cover-up the. unconsttut onalttc. Contrary te defend arte! belief Stefane 1a nor Immune Serco. neni relies for Aamaqes Qa Q reault of the falae best FEN atthe Grand Jory Freceedings, nor Ror the fallacious contentions fa Stefancta arrest report See Briscoe. vLatve, (Cite Omitted). Tn Briacoe, the Supreme Court nor our Federal Caurt of Appeals considered the tsate whether a police, officer is ented +o tramunity for Perilous teshimany before a Grand Caslisle \N Brisae's frm Se cemplaint Bees thot Martin Hue, whe wae G& Bleomi naton Sadana poli og, Acer Vwag called agzawtnesS at probable case hearings and at Briswe's criminal trial; and, that police ofBicer Lodtue's testimeny □□□ Lalee, Because heorsa, is rouknely admigsable et Grand Ti uy Proavedi ce person can Joe. campellecl bo appears immont ts not or mo, be extended ho Goch liare . lof & And, ttmust be remembered that any Feree. used +o effectuate. an Negal unacenstitutional anes Qwhich 12 one, effectudked) withart a reasonable. attieulable Suspicion that the, individual orrested hod or was about to commit Shopliftin nee any atner: eriminal ofens) is unm@asonable, Excessive, Force, iS described hy the “Poitoy" of the Chief of Police, Por the City of Berwyn asd “All force, beyond what 1s reasonably required Ho success fully control a resistive subject or Protect the ofQcer or pn vote citizen, No feree, was ES when Stefanc with Anderson standing behind him; snatched the. Single ccupancy aren door of the eypac 2. heveing a tolleend □□□□□ Sink basin only epen and avabbed Heqwood hu the. neck, Kheausood sishained avery serious Injury and Decors han indicated Kary 1S rent Stefano totally ignored the POLZCY ea Chief of Police. which ehates; ntentional Trapacts 45 the he and neck oreas will be avoided unless the use of deadly Poree, reasonable. ancl necessany. The ferce. used ca Lequoodwhile □□□□□ the agent of Mager Tne, and other poltee watched Was not-eccidente Twas intentional use of excesewe force, against Keowood who had been iegally arrested wither “~ leqitimake Wat Reston which ran afoul of the ExhH Amendment applicable te Dtinsis state, low enforee ment personel bythe Foorteestre Amendments Weavscen WAS Oo pretrial detainee. In the sheodt of Stefano, Meiier and -hetr confedenaites ond was entitled to die preeess before ony pat ehmert could be inflicted. However Hequcod was trecally aacaulted in Vialabhion of hia cl early ootabaltched constitutional rights. See Grahantw, Conor 440 U.S 386 U.9.(989); Belly Wolfiah, HYtu.s. S20 U.S. 1974)) Hendicken Kingsley, 135 S.Ct 24e (U.S. 2015), As a matteref fack “Amesboos and detainees cannet be. pent ahed at all’ See Woodard v: Casey 2010 □□ 6. Dist. LExts 12N2SS Mil. 2017). See also, Mulvania v.Sheriftol Rod Relancl, F. 3d B49 CH Ge 20rt) (cited in Botte. Manes, 2011 US Dish. LATS (coLoz (VL. DXi 2011). Heguioo d hee been Served te endure relating prugieal and mental pain) physical because of the assaut ond mental becarse. others whom have. loaned thar weldh to defendart-a and yorred the conspiracy dened Hequiood adequate medical aseigtence tO repain tne large. cau MNaLsS that howe. formed tn the. lack of Keauocd's neck. ZXTERROGATORY Ho. 4: Please negra dant fy and state each and every element of denege that you ore, ace x thie case, as against Defendant Stefanc, Induding, but; net limited “reo, the amoonts aa □□□□ for \oat wages, personal ingucy pain and suffering: emotional □□□□□□□□ and| or penttive damages, ANSWER: Hequcad's COMPLATNT filed inthe office, ofthe, ClerKot the. Citouit Court of Cook Genky which Meijer and Shefanc had removed +o the U.S. Diatet Court for the Nerthem Diaka ch of links te restated here. Seriatim ond venbadim, Hequood's, COMPLAINT Piled with the United States Atemey fon the Northen District of Diinols 1s leo restated here, verbatimand seriatin, Hequasd'e ANSWERS TO-INTERROGATORTES propounded olim bu defendant Mailer are, Incorporaked, re along with Ke sealis RRATORSETS Nlatjer's NOTARCE FoR PRODUCTIO AS Seon a Mai tonal Fachvel information becomes available and □□□□□ ble to Heaucod it shall be provided tothe defendaite consel. Hea: wood has informakion via the Cooth Coury Chon ch □□□ Freedom Of Information Ack Request: cepy attached hereto ag Exhi □□□ □ Ger Fielde wv. \Wharrie, Ho R34 UOTEHhCr aori)(Ro immunity for proszcuter who-falsity reaords and Ropaciagte evidence) □□□ INTERROGATORY No. lO: Pleage chate the full name, address and Kelephene number of each, and aay person who haa provided Yeu with medica\ treatrrent fer your injuries allegedly suffered as a result of your arrest} on December 2,200 ANSWER: OBTECTION Requocd has hereto fone offerad more tron SEN 2 hundred seventy Sime (Ler) Rages of documents □□□ oe Meijer and Stefanos lawyers. Heweves □□□□□ @ incign ting counsel +o ace te, Aoctmenks: +he Federal Meat Bodog, ns se hear Stated □ hey aqid they denrt wart thenm- Nonetheless, Heqwoed AS @ □□□□□□□□ has executed a Gok Coorhy Health + Yoapital System (CCHRS) WREOURST AND AUTHORTE-ZATEON TO QopY HEALTH INFORMATION and poi ded come te cemscl for Merjer and Stefano which □□□□□□□ the lawyers to obtain copies of Heaweed's wnedical reads fro seven(a) dtfeceat Health Care £ acilities. An additional properly exeasked, authorization for release of the medical treatment documentabion be annexed hereto Incorporated herein and made @ port heresf a& Exhibit H.The, medical reard doarmentaton will no douks} reveal “the fullname address ona telephone numer ef each and even, person who has provided the prose PlaiakT □□ with medical treatment for the injery te Hequecd's neck sustaine asq resultof Stefonc's eccessive, UIneceasary and malidoss vse © foree ducing Me unconstttional arreat assauktand seizure of H equoced. Gee 18 U.6.08. Sec. 242; Butlary. Sherif Ces e 34 (aol (Ith Gr) Qoir)\(Naked Spo mat Sound in daughter's closet, officer clean □□□□ <1 and hondeuffed ugeng man), Scresis v. United States, S25 U.9.91(JA4S), ( pregecubion under 42,U.8.C. ond 1G U.8.C.242 for TES oe nu civil rights of indiwidual arrested for tity Dh ots □□ (tates vy Gonzalez, Injury toneckK Cre Omitted) ; United States \. Eradleu, 19 FSA WAC Cie 1999) : TNTERROGATORY Ho. (lz Have □□ exer been, convicted of On Ute □□ so, State the dete of the cenwictien the name of the crime andthe penalty ed result of the comicion, steat asieen Defendatte) Stelane and the Chiet Ff lice hag accese, te recals concerning Requedd's criminal hiskery Alse defendants have. provided Lolse \ehormation te the Feo and an investigation isonWhen Hea wood receives the comect and acurate, doamentalion game stal\ ke provided . INTERROGATORY tlo.i23 Have. You eter been a posts te a lace? THe, state the Lull coption of the lavsutt including the doethet runber, natuce of tire. law avtt and he ulmate ootcome of the lawauth ANSWER? OBSECTION. Defendants Gtefanc and Meijers peevided the infirmation relating te peice ctl achons brovght lay Hess ond Aoaing his existance for the past Snseticiy CA} Meare, T declare underthe penalties of parierd the. ahheve 1s tre. Respectfully submited, > ma ae) ey etiond | ee ne tao rf er DOCL Chicago. DL boLoh SUBSCRIARD AND AFSERMED before, me-tigartne Lf as of. Maweh 26lg. ae PURE camuetan:ntanoson | □□□ NOTARY PUBLIC, STATE OF ILLINGiS | AFETOANETT OF SERVICE Before. me, the underat gned outhority, did per Senally appear atftart TALMON HEGWOOD, TR, Known unto me, whe Firat being duly avon, according te lows, upon his oath, did depose ond state.> T. WEREBY CERTIY that □□ hove. served a tue and correct copy ot PLAINTLEF'S ANSWERS TO STEFANCS INTERROGATORIES on : ' . Toseoh C. Sheah Esa. ren ree □□□ RE iaanert Veciriie Pc. eh 8 A Lous Aico crbug At" asoat West Deron Ave, Suite, BOO One Ee Wacker Drive Retemont Hh eco\e Chieqao, ©SO6O| lliam G&. Mc Kinse □ Honorable Teff Sessions Seat Peas ma Ace Genera et sf ee ay U.S. Depactment Tush ce. Federa| Buceau Trhyesaaction Civil K a4 DINIRON Criminal Jootice. Sndormakon sewers qso Porm muon Bue, NAM (00 Custer Hollow Road Washington, B.C. 22520 Cl arksburg; WAL 26306- COC\ le Edwin Bisendcath Nirs. Laura an ee iat orpices poate Chicago Son Times CBS 6O Mines ASO CHocth Ocleons IS4 West Stth Street Chicago, A COGS New York, MY (cag by pladng Same wr Sealed envelones; propacly addwased, frat class postage prepaid and posting same. with the U.S. Postal Service, on trie the, day of Moreh, 20/2. TL declore under the peaolty pecjua the cheve, 19 tne.. almon\lequoad, Un, Mar #2Z0\1 OLB S227 P-4-2-— Post Ofice Bex C@Q00A AG J Chi cago, A -opoe SUBSCRERED AND deccrten TO pefore, me, thia shelf of Mncel sore. Anelka SK ad hae CARMELLA K. RICHARDSON NOTARY PUBLIC NOTARY PUBLIC, STATE OF Ii inoie UNTTED STATES DESTRICT COURT FOR THE NORTHERN OLSTRECT OFTLLINGTS EASTERN DINESION TALMON HEGWOOD IR. PlaiatifF, ~Versus- No. [T-Cv- 02.887 MEIJER, TNC, Et Al. Defendants, FO DEEEROANT ee OANERDMENT AMENDED and/or SUPPLEMENTAL anawerte INTERROGATORY Ko. 4 □□ Talmon Hequicod Sr: Hlequicod):s ANSWER to Stefans’s THTERROGATORY No. |: heretofore provided, is reasserted here. vechok at. an Onswering further Vhe. pro ee plantifthas annexed herets and incorporate herein Copies ot documents etyled completed “THMATE QRTENANCE. FORM □□□□ that were submitted te Cook County Department of Corrections €cnoc) official during the elongated period of Hequoods unconstitutional detention at CCbOC under ceDec " Booking 1D Number 2or1e12Ored 3 The. ari eVAACeS provide the names, date, and oventhel ming Support Heawood's NED claima against defendants CASEN STEFANO (Stefano) end Stefanos co-conspirator Meiier’s loes prevecttion agent Marass Anderson (Anderson) and. othere Krew and unknown +e the. pre □□ plaintiff who Know ngly interttionally retaliterily ond maliciously charge Heawood with breaking the \aus eS Majer on August \,2018- Seg. Buchmeiec v. City of Berwun, 2a15 US, fet □□□□□ “6319. > Intune and consistent with the spirit tf not the letter of United States Mogi strate. Judge. (Md) of Morch 22, 2016 (Docs 49) and April 5, 20te Doe suit) Heauecd has snieriaelh ener TNMATE. GETENANCE. FORM(S) numbered and dated as Fellows: |, COMTROLAAR Zale \a\e actes va\a-\e Lan 20 ag aa \2-\4-\bo 2 CONTROL a 20\b \Wa \2> O8-Ib CONTROL + 2O\b% 1360 da Boe Ne 5 CONTROLA 2Ol\C*% |S oA a WH | CONTROLAR 20 16K We 2-\3- \le CORTROLAR ZO lbL* 1603 FA 2---\e CONTROL ZO le%A 1388 “Ot \6 ‘CONTROL ZO te XK West, ~22-\bo “CONTROL 20 (KA (Bs a te iL. CONTROL 20 Ne Hany 4 (2-22-\e ILCORTROLAR 20\0% Wey peme [B.CONTROL 3 9O01GK Wit ated (n-le~th {4 CONTROL 2QcleK Wiss 9-04- Ite CONTROLS, 2OleK Wear sake ated □□ \tp.COMTROL +k mle X WSest (2-097 We TLCONTROL a 2ote (LeX2 does a Gee te CONTROL 2OKe % Worn hated □ (2-CA- Ve CONTROL 2\eK NEES □□□ Ie PO.CONTROL* N4ASs dated t2-IS3~ Ite TI. CORTRO LAR 20\c% I|e4o \p-28- No 22. COKTROL 20ie% 12159 dated 2-18" Ib 33, CONTRONIE ZOEK WUE ceted ‘ant Ke 2H CONTROLAR Olle K Wage a o.ta> Ve 25,CONTROVAe Zotex WHT qoted 12-09- Wh COKTROLA 2O\EK (Lod Geat- le CONTROLAR 2OITK CO24 ated tt 26. CONTROL #5 ZONK Go dated OlvOS | jae 201% O\BOR ed of-0% NI ROL 213 oe 37 thor K OC\2@2 da OlCONTROL & 22445 a: Oz \1- (1 Bo: 2O\LX o25 ot O2Z-|4~-(T By. CONTROL ©2(5\ ct O2-(a- (1 CONTROLS 201K dated OF Catt 3b. CONTROL & ZOI1K CAlee 4 Oe re (t CONTROL tH ZOITK OAtet cat Be. CONTROL Ae BITK ©2392 gored O2-20-\7 3q. CONTROL ZONK O26\3 dated ©O2-23-\7 0. CONTROL + 20K K 62509 dated) Sl- (o-(1 {. CONTROLA® 201K COZ74 dated orOoc lt 2. CONTROL te Z2OIT XK CIZIG q Ol-2z1-\1 U3. CONTROLFR K O1uNG eset CONT REL: ZOITR A O\-25-| CONTROL + 2% oo14 da Ol-(a-{t LCONTROL # 20or HAsO do \2- {CONTROL 2 K \2-|O- le CONTROL # 2O1TX@OTB8O dated CHIE Hequiacd's ARSWER to Stefone’s INTERACGATORY heretofore. previded is reasserted here. verbatin. Da ansuering focther “the oubject matter of whet (Neqwood) believe these. persons witnessed with cogards te Requecd’s Fale, imprisonment claim, can he, gleaned fren the video footage ag-wellas the numenns protearaph s produced ho Requieod bu defendants, persuont he at Jeoe(3) distinct orders of the Courk (Docs 64, 84, AG ond other) And jn suppor} of Hequeods TED claims this proge plainti ft □□□□□□ direct defendants +o the completed, THNMATE GRREVEANCES liebe, hereinabere and ottached. The Ccpac correchicnal atalf whe are. wttnesses te the emotional distress, mertal and prusi cal painte Which. Hequwoad was fored fo endure, aS Q eault of Stefano, Meijer, the. Chick ef Police (cor) and others whe □□□□□□□ with defendarts are identified, named and have facks within the scope of their Knowledge, are provided ta dowments numbers \theoudh 4B, Whi ch total 2:10 of the more thon ee pages of decuments Hequood referedte in his “AMeWER te defendant's TNTERROGATORY No.tO, Which 1 reasserted ond incorporated herein verbetinn Cleary. the emctional dishees inMicted| on tlequioad □□ nO than extreme and ostrageeus. Net onlydid Stefanc'S □□□□□□□ relat ng +o énatchina the door of tne bot let+ Oree Open while Keqwood Was holding his penis and erinaning ecirageons, but cho Kin Hequiecd copein him to almoet \omee, Condi venesS and Fat hai Kader Glanalore, On Co complaint whieh bed to a folac Sage and Mali lous Proseeuti ont Hegusood uns Qroesly ectreme ond Maufaps Criminal. Gee toU.ac., See, ZA2et see 4, Hequ cade ANSWER te Stefane's INTERROGATORY No.3 heretofore provided is reasserted here yerbobinn. tn focther Teapense Hequcod intends te cal\as expert witnesses the, following De DAL Thomas eat alg _ Beda Mattcon, mS uigae Dr. DiThemas Is erbected totestify Higt becow ee of Hequicod's Hepatitis Cline (ew) his blead wasthe cavse of the tissue mss famed in Hequood's neck after being choked fey defendart Stefano in the toilet area where Hequood Was illegally arrested. A. Hequceds ANSWER to Stefanos INTERROGATORY to. herebofor provided is reasserted here. verbotim, In futher ansui ering Heawood, would point ot that he intends te tlicit testimony from either Honorable Kimberly Fox (Mra.Fox) or a □□□ aae, the. Stote's Attomeu's to prove. +he Claim ascected in his orainal COMPLAEKT Akiak clefendants | @. Attempted +o manipulate the Court: b- Nani pulated the Tilincis State's ere ae her agsistonk who presecuted Leawood mplioudy atthe iniation, behest and instigation of Stetdho. Meijer Chico Police for ae whoare, □ dicoc reaponsible-tor the Knaun false. nee re. na te bstnot limited bo the Auqust It, 20\S Shepley ive at wae diam □□□□ via Mire Fox's motets nol\e ee ver Heawonk's apiecKion. A copy of the ORDER ofthe Honorable RAMOK Ccksins terminating the. case wood's Fayor is annexed herebe, \acorpocated herein ond made. a rt brook ; C. Monv factring evidence. which coveed confosion, ham and □□□□□□□□□ te Heawood's defense tothe false charge, Knowingly, intertionally, witfolla, deceit fully and maliGassly failing to produce favorable □ eta _. eNidence. Ne misdomearor and or Felony choplitting charges inthe face. of valid Court orders that were {ssued by the. Honorable PAMELA M-LEBMITRG Failing te cooperate. with IRS investigation which substantially prejudiced Taposh insofar as his WHTSTLEBLOWER, 4 3,000,000 claim ts concerned Failing te retum to Hequiced hie Sodal sen Debit Gard, Link Gard, and other property, nok controbond and rob connecked tothe false shoplit— ting charaes Progticin racial dj) scrimination and SE: Hequicod fer Suing Sesegh Roteraen end the Crh of Berwyn in eral Gaur praiicosy, Attempt crete Fox with regan to States MlocredS Avties and obligations — be ‘3 hihi 2. Scbiecty aood “ke & One-on-one. Shawup in the, one, person -teaj| □□ eels aken Restastesch (a ovacker ale. Coom there's Store.) hight iS now Closed which Gwses <poilotion of certain eNiderce. example, the peo se plaintifhis precluded trom danonatrating thab Meije*s video equipment that alleaed|y produced the Video farkacg. was rot functioning properly TNTERROGATORY Ho. 5 Hequiced s ANSWER to Stefoac's INTE RROGATORY No 5 □□□□□□□□ provided is Feassected here verlotim, In anewering further the persone named ARREST REPORTS (hwo) of them) and Berwyn Reltee Department” OFFIETL SWORN POLICE REPORT Guio(2) of them) wer, presentatthe Lime. of Keagwoed's fa se arrest and Moy have heen, or duty when Reanexxt WAS □□□□□□□ Choraed ond the CONPLATRT FOR PRELTHERARN EMAMENATION was falsifted by Stefano whe evidently signal Mares Anlerscn's etgraturaon loth complaints whereby the malicious and selechwe proeecstion of Hearn commenced □□ must be remembered thatthe falge charge terminated ofyen an elorpted periok i nr Hequacd's fowor is based on allegations ond an allecgad episcde diskiry. □□□□□□ , the tee) differart events alleagdly occurred mere, than fifteen dS) months apact. Prebble cause (ora Sontsin aa feo one charge. will not proclude malicious pre secution ait based ona separate charge. Becarsethe false charge was disimi seed over Hegwood's strenueve oyecHion □□□□□ revealed a Court decuments, annexed +o Hequoed's +" PLATATIR'S ANSWERS "To STEXANDS THTERROGATORIES execvted and Saved on beth attorneys for defendants on Nearch 4.2018 (which, again are. incomerated hereic) Seq, Group Exhipitc, Pages I-4, via, Past | indicating: NOLLE_ PROGEQUT” ond " DEFENDANT DEMAKIS TRIAL prepared, by Horterable. DOROTHY BROWA , Clerk forthe Ciro Coutof Cock Counta, X\lireis EMTERROGATORY Noe: Haquicods ANSWER to Stefand& SKTERROGATORY heretofore provided 13 reasserted here, Verhalim. SNTERROGATORY No-T. Hequood's AHSWER to Stefanos THTERROGKTOR No. 7, heretofore, proided ig reasserted here verbabint LNTERROGATORY NO. S, TNTERROGATORY No.4, XKHTERROGATORY No. 10, FNTRRROGA TORY No. Il cind HTERROGATORY 12.7 ANSWERS provided heretofore arerenccortal here verbotin and seriaekwt. Tn Lclher aneuer ing Heawcod hes annexed □□□□□□ copies of Hequoods medical records compiled Jay Medical Dockers and Health Care. Providers employed sheen hospital described below poravant te the April 5.2018 ORDER (Doc se Ill’) of Hencrable DANTEL G-MAREIK, ~ copy of which io onnexed herede Porn Your convience.. Respectfully aubmitted #20t} Ouke AZT See Post Cffice Pex © SIOOZ EhiCage, Ki coecoe Chicago, DiW\ineis, thie the Hh da of Apri\ zo\g CEWTLELCATION Talmo negseetash be one tnat+he TIFFS ANSWERS TO STEFANCS INTERROGATORIES" and the + i Pl e. Focuaging ee PLATNTIFF'S ANSWERS AND AMENDMEN otis ENDANT STRFANO'S THTERROGKTERTES OMpli arc, Ww} eae 2, with the Court's ORDER dated April 5,2018 Ovex tl) eand cocrectteo best of m Knowledge aid boliet A beliet Reepect fully submitted, WOOD se ZOAOZO227 HCL Post DIPICe Bet Seams. hicage, Ti KOwbos Chi cage Liljnoj i (&, this the inde, 4 of April, 20\% GUBSCRIBED ANO SWOR NTO before, me, this the 77d fi. ; ah . sorrel □□ NOTARY PUBLIC - STATE OF ILLINOIS MY COMMISSION EXPIRES:04/17/21 FORTHE HORTREAN EY STRE TLINOKS EASTERN OWESIOK PLAINES AFEIDANET OF SERWICE Before me, the undersi qned, a peraonolly appear affient TALMON HEGWOOD.TR,, Known unte me, Who iret being duly ewom, according te lew, UPON his oath, did depose. and. erate: T HEREBY CEATEFY that=l hove carved atrue and correct cxpy of PROSE PLATKTIFES ANSWERS AND AMENDMENT TO DEFENDANT STEFAHOS TNTERROGAIORIES on Mic. Michae| Oye Feq. Honorable. Uohn R.Lousch Storine Ramello+ porkin Atbormen S-At- bau : Rpordn 4501 West Devon Site Goo United oa Tadeo or □□□□ Rosemont, LL 6ools Chicago, Th WoEc\ Sea Meese SuSE thn Nem =r Bve © One Bast Wacker Prine Satetoo 350 Nocth Orleans Chicago, cobot Chicose. Ty COreh by placing Same. in eeoled envelopes, properly addreased, and entroating game to the Comectional staff at the Cook ees of Cesrection&S te be legged, photocopied ond posted with the US. Bstal Seniice XT declare under the penalties Xt penny the above ta tre. Reapect ful euhomitted , OFFICIAL SEAL M GAUTHIER 1 \ aanopemt Chicago, Th — QUESCREPEN AND SWORN TO hafore this the, 7 cows of April, 2018. IW THE UNTTED STATES OLSTRICT COURT FOR THE NORTHERN OCSTRICT OF TLLTNOTLS BASTERN DIVNISTON TALMION HEGNCOD, FR., Plainti fe , Byers Neo: \: 1 ev 2807 Heneoreble GARY FETNERMAN □□□ METSER, INC. and Honorable DANTEL G MARTIN. Mir CASEY STEFANO Beferulants, TS: Meier Inc., TO- Merier “Enc, ge MeBidre Acker, Esq. sfocenanginan mor +Nednine. INO Romello + Durkin pererreyt Sis ee . thomieys-At- Law One Badt Wacker Drwe West Devon Ave, Sutte, BOO Sutte 22cO Resemork, Ki Goots Chicago, □□□ coco} Pursuant to Fed R.Ciy.f 36, TALMON HEGWOOD, TR. (Heqweod) respectfully request +hab Mei\er, —ne, (Mei Jer) admit or deny thet the facts elaborated action only ond subject te any and oll abiecticns a5 to admtssablThy which may be, interposed e+ any Semimery jedaayent heaving and ( OF Jon trial in the chove- Styled cause. 4 Negiced was arrested en December 8 206 for allegedly pilfering the items of celleane listed in ExhibiFA &.On orabout December 3,20\6 Manus Anderson €nderson) □□□□□□ COMPLARNT FOR PRELENIENARY EXAMIHATION charaing Heqcood wit. misdemeaner retail theth: which was Subsequently enhanced toa □□□□□□ MOTION FOR SUDGMENT BY DEFRUET Evhilit ( 5. Andersen, an agent of Meijer, accompanied Stefanc and other Berwyn Police Department PD) officers when Hequced was arrested atthe Popeyes Chicken Restamart on December 2, 26). 4-The iavelvement of a state offical in a conspiracy te vielate, an American citizen's " clearly established" rights, privileges and immunities Secured by the laws and constitution of the United States plainly provides the State action that is essential to shou a direct vyolaton of the, citizen's United Stutes Constitution's Fourtezith Amendment Baqval Protection Nights, whether er notthe actions of Stefanc ond other police, were, offi ci ally authorized, December 3, arrest andor harye levied against Hequoed by Anderson otemmeel from an alleged thet Shab Andersen contended cccumed at Meiver on or Auquert I, 2018, lo. Sheplifking is @ petty offense, and the, stabste, of limitations for changing a pathy fense, te on alleged culprib1e s}x@) months gaecordi na +o \\jnole \ow, “, Heguiced ia a Shetyrine 4) year Ad male adult Afiean American citizen of the United States. B.Stefane and elanty five perverch (gs “le) of low enforvament personel employed and euperyised by the Chief of Pelice, (Cop) fer the lage, of Berwyn are, White Amentoan citizens. FT. Andersen was not atc work foo Melier .on Avguet i, 20V5tO. Anderson did not appear hetere, the Grand Dory +o testify commection with the. alleged Auaver 1.201, retail treft-from Mel\errbecause Anderson Know the, change, was talee. and: alec was cognizant Heauraod did not enter and leave. Mei\er on Asay Sti, 2018 With any merchandise. J Andersson engaged in an Unconstitstional one-cn. one, chowup Precadure which led toe the aiden adion of Heqoood as the, perpe: traitor ef the. alleged theft indidentrat Mei Ser on Avauet 21S, The, “packeb of pickures" Anderson tomed over-to the Bensuan Felice Department-alleged net Auqust \\, 20\S, depi ckec\ □ FRAGRANCE, | WENDSOH@ MUSK Celeane.” "SENSO DINE" tecthpaste. . 3. Andergon and|or Meller are. Viable to Hequacc| under 42U.S-. Sections (983 and t9@5(a) os a Consequence. of meeting treqethes at the OckPark Police Re portment en of deout December 2, 3,20leCircuit Court of Cock are December, 20}le, and at Meier during which Stefano, ChietoF Police and others Knewn and UnkKrewn to Heawood cevised aplan at med qhand did infact viclate Heaood consti tutional rights Ahat were." cl early eatulsi lished. IH) Anexcessiver force claim does not necessori ly required Showing of roodily injuny te estabilish a const) tutional viel ation. is. As aresu\+ of defendante' unconstitutional conduct Hea: Wood has been injured, in hie mind, hedy and Sos\,. Be cauge. Steffans, Andersen and others willfoly Transqressec Hequicod’s Const tut onal Rights and coused bodily ham, Stefano and Anderson are. Quilky of Felony offenses under IBY.SC,4 242. StePane's cokorke refused return, Keg wood! s perao nal Prop erty “ro hire despite 0. Court Order FAKED to Berwin uy the Assistant State's Attorney Who the Honorable Giada Ramon Deassto ordered te re form +he fonction on February 2, Abie, lB, Heawood presented Berwyn with a Gpy of the Court's ORDER signed by Sodaz Ramon Oceasio and instead of rehoming his property the. po lice Megally searched and abhiechecd Heasood, ke Bitter 19. Stefano, Anderson, COP and others Known and UN Kncuin +o Heawo ocd Were aware thot 4 2gusood Lied a \awsui} Frank a Them @5 defendants; which 1s why treic cohorts refoced □□ return Heavood'< eo and subjected the plainhift to additonal □□□□□□□□□□□□□□□□□□□□□ net speciftad in tae orjaina| COMPLAINT Filed by Hequioed jnthe Circuit Courh of Cook County. 20, Hegwood submitted a COMPLATNT +o the United States Mtornew for the, Northern District of TMNinois the Same day after he presented the ORPER’ of Tudge Ramon Ocassio fo Beran . 2\.The Clerk at the Benn Community Center dialed the telephone number for the Federal Bureay of Trvest gation And allouser Hequood be common caty, with the Fos Dek OFF} cers yuowen er & Renwun paltce, officer antered the Berwun Community Center, snatched the telephone fom We and hun 4 □□ up. notwithstanding heavsood advi sing the police, as +o whom he was Speaking, Respectfully submitted, Olnen ||Eaue0d Oe pre se. HAO OGIO227 P-HAZoK Post Office Box OBSFCNZ cago, Ti coeoe SUBSCRIBED AMD SNORN TO before me, this the rb 1a of DCRembey 201, Mag iis mec RY PUBLEC aterndes NOTARY PUB ae 8 AL SEAL ARY PUBLIC - STATE OF ILLINOIS ere) CAPIRES:42/27/17 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TALMON HEGWOOD, JR., ) ) Plaintiff, ) ) Vs. ) Case No.: 1:17-CV-02887 ) Honorable Gary Feinerman MEIJERS and CASEY STEFANO, ) ) Defendants. ) DEFENDANT, MEIJERS’, RESPONSES TO PLAINTIFF’S REQUEST FOR ADMISSIONS OF FACTS NOW COMES, Defendant, MEIJER, INC., incorrectly sued as “MEIJERS” (hereinafter referred to as “Meijer”), by and through its undersigned attorney, pursuant to Fed. R. Civ. P. 36 and for its Responses to Plaintiff's Request for Admissions of Facts states as follows: l. Hegwood was arrested on December 3, 2016 for allegedly pilfering the items of collogne [sic] listed in Exhibit A. RESPONSE: Objection. This request is vague and ambiguous. Subject to and without waiving said objections, Defendant denies Plaintiff's characterization of pilfering as that word is commonly understood, but Defendant admits that Plaintiff committed retail theft of cologne on August 11, 2015 from Defendant’s retail establishment as referenced in the Berwyn Police Report Incident No. 15-07477 (Plaintiff's Exhibit A). Answering further and subject to the prior objections, Defendant admits that Plaintiff was arrested on the referenced date in connection with his commission of additional retail theft from Defendant’s retail establishment on that same date. 2. On or about December 3, 2016 Marcus Anderson (Anderson) signed a COMPLAINT FOR PRELIMINARY EXAMINATION charging Hegwood with misdomeanor [sic] retail theft, which was subsequently enhanced to a felony offense. RESPONSE: Denied. MOTION FOR JUDGMENT BY DERAUET Exhik 3, Anderson, an agent of Meijer, accompanied Stefano and numerous other Berwyn Police Department (BPD) officers when Hegwood was arrested at the Popeyes Chicken Restaurant on December 2, 2016. RESPONSE: Objection. This request calls for a legal conclusion as to the relationship between Defendant and Anderson and, as such, requires no response. See Fidelity Trust Co. v. Stickney, 129 F.2d 506, 511 (7th Cir. 1942) (finding that request for admission of a conclusion of law rather than of facts is improper and may be refused). Subject to and without waiving said objection, Defendant denies Request No. 3. 4 The involvement of a state official in a conspiracy to violate an American citizen’s “clearly established” rights, privileges and immunities secured by the laws and constitution of the United States plainly provides the state action that is essential to show a direct violation of the citizen’s United States Constitution’s Fourteenth Amendment Equal Protection rights, whether or not the actions of Stefano and other police were officially authorized. RESPONSE: Objection. This request calls for a legal conclusion and, as such, requires no response. See Fidelity Trust Co. v. Stickney, 129 F.2d 506, 511 (7th Cir. 1942) (finding that a request for admission of a conclusion of law rather than of facts is improper and may be refused). 5. The December 3, 2016 arrest and/or charge levied against Hegwood by Anderson stemmed from an alleged theft that Anderson contended occurred at Meijer on or about August 11, 2015, RESPONSE: Objection. This request is vague and ambiguous with respect to the “arrest and/or charge levied against Hegwood by Anderson.” Objecting further, this request is duplicative of Request No. 1. Subject to and without waiving said objections, denied. 6. Shoplifting is a petty offense and the statute of limitations for charging a petty offense to an alleged culprit is six (6) months according to Illinois law, RESPONSE: Objection. This request calls for a legal conclusion and, as such, requires no response. See Fidelity Trust Co. v. Stickney, 129 F.2d 506, 511 (7th Cir. 1942) (finding that a request for admission of a conclusion of law rather than of facts is improper and may be refused). Hegwood is a sixtynine [sic] (69) year old male adult African American citizen of the United States. RESPONSE: Objection. This request seeks irrelevant information. Subject to and without waiving said objection, Defendant admits that Plaintiff is an African American adult male but specifically states that after making a diligent effort to ascertain Plaintiff's date of birth and/or age, the information known or readily available to it is insufficient to enable Defendant to admit or deny this Request. Defendant lacks knowledge and information regarding Plaintiff's age and is not, therefore, in a position to know if is 69 years old. As such, Defendant states that despite its reasonable efforts, it has insufficient knowledge to admit or deny the portion of this Request relating to Plaintiff's age. 8. Stefano and eightyfive [sic] percent (85%) of law enforcement personel [sic] employed and supervised by the Chief of Police (COP) for the Village of Berwyn are White American citizens. RESPONSE: Objection. This request seeks information that is irrelevant to the claim(s) against Defendant. Subject to and without waiving said objection, after making a diligent effort to ascertain the racial demographics of the Berwyn Police Department personnel, Defendant has insufficient information known or readily available to it to enable it to admit or deny this Request. Defendant lacks knowledge and information regarding the racial demographics of the Berwyn Police Department and, therefore, is not in a position to know whether 85% of the Berwyn Police Force is Caucasian American citizens. As such, Defendant states that despite its reasonable efforts, it has insufficient knowledge to admit or deny this Request. 9. Anderson was not at work for Meijer on August 11, 2015. RESPONSE: Denied. 10. Anderson did not appear before the Grand Jury to testify in connection with the alleged August 11, 2015 retail theft from Meijer, because Anderson knew the charge was false and also was cognizant that Hegwood did not enter and leave Meijer on August 11, 2015 with any merchandise. RESPONSE: Denied. 11. Anderson engaged in an unconstitutional one-on-one show up procedure which led to the misidentification of Hegwood as the perpatraitor [sic] of the alleged theft incident at Meijer on August 11, 2015. RESPONSE: Objection. This request calls for a legal conclusion and, as such, requires no response, See Fidelity Trust Co, v. Stickney, 129 F.2d 506, 511 (7th Cir. 1942) (finding that a request for admission of a conclusion of law rather than of facts is improper and may be refused). 12. The “packet of pictures” Anderson turned over to the Berwyn Police Departmetn allegedly on August 11, 2015 depicted “FRAGRANCE,” “WINDSONG” “MUSK” cologne” “SENSODYNE” toothpaste. RESPONSE: Denied. 13, Anderson and/or Meijer are liable to Hegwood under 42 U.S.C. Sections 1983 and 1985(3) as a consequence of meeting together at the Oak Park Police Department on or about December 2, 3, 2016; Circuit court of Cook County in December, 2016 and at Meijer during which Stefano, Chief of Police and others known and unknown to Hegwood devised a plan aimed at and did in fact violate Hegwood constitutional rights that were “clearly established.” RESPONSE: Objection. This request calls for a legal conclusion and, as such, requires no response. See Fidelity Trust Co. v. Stickney, 129 F.2d 506, 511 (7th Cir. 1942) (finding that a request for admission of a conclusion of law rather than of facts is improper and may be refused). 14. An excessive force claim does not necessarily require a showing of bodily injury to establish a constitutional violation. RESPONSE: Objection. This request calls for a legal conclusion and, as such, requires no response. See Fidelity Trust Co, v. Stickney, 129 F.2d 506, 511 (7th Cir. 1942) (finding that a request for admission of a conclusion of law rather than of facts is improper and may be refused). Objecting further, this request seeks information that is irrelevant to the claim(s) against Defendant. 15. As aresult of defendants’ unconstitutional conduct Hegwood has been injured in his mind, body and soul. RESPONSE: Objection. This request calls for a legal conclusion and, as such, requires no response. See Fidelity Trust Co. v. Stickney, 129 F.2d 506, 511 (7th Cir. 1942) (finding that a request for admission of a conclusion of law rather than of facts is improper and may be refused), Objecting further, this request is vague as the word “soul” is not defined for purposes of these requests. Subject to and without waiving said objections, denied. 16. | Because Stefano, Anderson and others willfuly [sic] transgressed Hegwood’s Constitutional Rights and caused bodily harm, Stefano and Anderson are guilty of felony offenses under 18 U.S.C § 242. RESPONSE: Objection. This request calls for a legal conclusion and, as such, requires no response. See Fidelity Trust Co. v. Stickney, 129 F.2d 506, 511 (7th Cir, 1942) (finding that a request for admission of a conclusion of law rather than of facts is improper and may be refused). LY, Stefano’s cohorts refused to retum Hegwood’s personal property to him despite a Court Order FAXED to Berwyn by the Assistant State’s Attorney who the Honorable Judge Ramon Ocassio ordered to perform the function on February 27, 2017. RESPONSE: Objection. This request is vague as the word “cohorts” is not defined for purposes of these requests. Objecting further, this request is compound and seeks information that is not relevant to the claim(s) against Defendant. Subject to and without waiving said objection, after making a diligent effort to ascertain whether Defendant Stefano and/or any of his colleagues withheld Plaintiff's personal property and whether a Court Order was transmitted to the Berwyn Police Department under the circumstances described by Plaintiff, Defendant has insufficient information known or readily available to it to enable it to admit or deny this Request. Defendant lacks knowledge and information regarding the actions (or inactions) of Defendant Stefano and/or his colleagues and the transmission of Court Orders by the Illinois Assistant State’s Attorney. As such, Defendant states that despite its reasonable efforts, it has insufficient knowledge to admit or deny this Request. 18. | Hegwood presented Berwyn with a copy of the Court’s ORDER signed by Judge Ramon Ocassio and instead of returning his property the police illegally searched and subjected Hegwood to battery. RESPONSE: Objection. This request calls for a legal conclusion and, as such, requires no response. See Fidelity Trust Co. v. Stickney, 129 F.2d 506, 511 (7th Cir. 1942) (finding that a request for admission of a conclusion of law rather than of facts is improper and may be refused). Objecting further, this request seeks information that is irrelevant to the claim(s) against Defendant. Subject to and without waiving said objection, after making a diligent effort to ascertain whether Plaintiff presented Berwyn with a copy of the referenced order and whether the police refused to return any property, Defendant has insufficient information known or readily available to it to enable it to admit or deny this Request. Defendant lacks knowledge and information regarding the interactions between Plaintiff and any individual from the City of Berwyn. As such, Defendant states that despite its reasonable efforts, it has insufficient knowledge to admit or deny this Request. 19. Stefano, Anderson, COP and others known and unknown to Hegwood were aware that Hegwood filed a lawsuit naming them as defendants; which is why their cohorts refused to return Hegwood’s property and subject the plaintiff to additional unconstitutionalities not specified in the original COMPLAINT filed by Hegwood in the Circuit Court of Cook County. RESPONSE: Objection. This request calls for a legal conclusion and, as such, requires no response. See Fidelity Trust Co. v. Stickney, 129 F.2d 506, 511 (7th Cir. 1942) (finding that a request for admission of a conclusion of law rather than of facts is improper and may be refused). Objecting further, this request is vague as the word “cohorts” is not defined for purposes of these requests nor is the phrase “additional unconstitutionalities not specified” and/or the phrase “others known and unknown to Hegwood.” Subject to and without waiving said objections, denied. 20. Hegwood submitted a COMPLAINT to the United States Attorney for the Northern District of Illinois the same day after he presented the “ORDER” of Judge Ramon Ocassio to Berwyn. RESPONSE: Objection. This request seeks information that is irrelevant to the claim(s) against Defendant. Subject to and without waiving said objection, after making a diligent effort to ascertain whether Plaintiff submitted the referenced document to the United States Attorney on the referenced date, Defendant has insufficient information known or readily available to it to enable it to admit or deny this Request. Defendant lacks knowledge and information regarding the actions of Plaintiff pertaining to contact with the United States Attorney. As such, Defendant states that despite its reasonable efforts, it has insufficient knowledge to admit or deny this Request. 21. The Clerk at the Berwyn Community Center dialed the telephone number for the Federal Bureau of Investigation and allowed Hegwood to communicate with the FBI’s Duty Officer, however, a Berwyn police officer entered the Berwyn Community Center, snatched the telephone from Hegwood and hung it up; notwithstanding Hegwood advising the police as to whom he was speaking. RESPONSE: Objection. This request seeks information that is irrelevant to the claim(s) against Defendant. Objecting further, this request is vague and overly broad as Plaintiff fails to note the date of the referenced encounter/events. Subject to and without waiving said objection, after making a diligent effort to ascertain whether the Berwyn Community Center Clerk called the Federal Bureau of Investigation and allowed Plaintiff to speak with the Duty Officer and whether a Berwyn Police Officer subsequently entered the premises and hung up the phone, Defendant has insufficient information known or readily available to it to enable it to admit or deny this Request. Defendant lacks knowledge and information regarding the actions of Plaintiff, the Clerk of the Berwyn Community Center and/or personnel of the Berwyn Police Department pertaining to the referenced encounter. As such, Defendant states that despite its reasonable efforts, it has insufficient knowledge to admit or deny this Request. Respectfully submitted, MEIJER, INC. By:__/s/ Joseph C. Sheahan One of its Attorneys Joseph C. Sheahan (IL Bar 6313969) CUNNINGHAM, MEYER & VEDRINE, P.C. 1 East Wacker Drive, Suite 2200 Chicago, Illinois 60601 Tel: (312) 578-0049 Fax: (312) 578-0247 E-Mail: jsheahan@cmvlaw.com Attorney for Meijer, Inc. TN THEUNITED STATES DIESTRECT COURT FOR THE Womrnene DISTRICT OF TIMINGS TALMOH HEGQWOOD, OR., Plaintie, oe Nenorable GAS FEENERMAN Honerable DANTE G. MARTIN □□ MELSER TNC, ETAL Defendats, PLATNTCFES RESPONSE. ‘TO DEFENDANT METDIER'S ELRST SAY OF REQUEST FOR ADMTSSIONS Pursuant to the applicable provisions of the federal Rules Civil Rocedure (Fed. R. Civ.P) 36, the Court's Lecal Rules andthe ORDER of United States Maaistrate Sudce,, Honorable Daniel G.Martin (Md) (Doc.4¢ (1), Talmon Weave od, or. (Heqwood) the pre se. plainttt? in the. above. captioned matter answerg " DEFENDANT MEIJERS, EERST SET OF REQUESTS FOR ADNITSSTONS (Doc. 4.2) filed inte the recon of +he. Cause on April 9, 2018, contrary tothe Court's Local Rules Get □□□□ as fol lows: The defendants ae culpable for "reckless disregard for the effect of their conduct on the proceedings" at hand ce cay implicitly and explicty be deemed tomtamaunttto willfulnese. Seo Taton itech v. Tnst fA Elec. 2016US. Dist LEXTS 19.947, Unity Sch Diet. VMavglin Assoc, 2018 U.8,0igt, LEXtS 244i. Notuthstonding defendant's conduct which has invited the. etry of default, Pro Se plaintiff respond MMOTIOK FoR SUDGWENT BY DEFAULT Extibrt □□ of = \. Admit thet, on August Bl, 2O|b, you were present at the Stere. RESPONS €_: Hequiood denies, under the penalties of perjury, +o the United States Departmertt of Justice (00S), Federal Borequ of Tpyestigation (Fer) and anyone. elee thet Hequood was" at the Store! on. August Sl, 20\b. Evident the telescope on the video equipment used to manufacture © video and/or photograph ef the person purported te be depicted atthe Store on Auaust 3h, ZD\b Was nor functioning properly, becaise Hequoed was being held in detention in 20l6 and taken the Initiative to ebtain “VERKEELCATIDON OF INCARCERATION from Cook County Deparctmest of Corrections (ccpoc } ulltich Shall provide proof positive and will be make available to defenders Store. and Casey Stefano (Stefene) who conspired ond Filed false police repors ond charac. against Heawoot ZB Kdmit-nat, on Auqust Bl, 2\le, you removed merchandise from the Store, to wit, various health and beauty, products Wwithost tendering any Payment for game. RESPONSE: Heqwood denies that he is culpable for removing any merchandise. fram the Store on Avast Bl, 2016; and heqwood □□□ assert his RESPONSE. provided in “\" hereinabove. En answering fucther Kequicod believes the videos and photoqraps clawn loaded therefrom are fake. Upon information ant belie€ the Store is now closed ond Was closed forthe ete purpose. of covering up and. spoilation of certain evidence which has caused alee) \f not icceparable prejudice. toa Hequood” & casein chiect. 3. Admit thet the surveillance foctace dated August □□□□□ shown +o you by Defense Counsel on of about teercary (6, □□□□ depicts you at the Stere on the indicated date. RESPONSE: Hequcod must OBSECT at this me ho defendayit Meijer's Fed. A.Civ.P. Ste request te admit number 3 fer tu □□ reasons, i) it concerns video “ speveillance. feotaae thaP Requcod has reasen to believe is fake and 2 the. equipment used te produce the video Peetaqe. ne lenaer □□□ as the Shore was Intent onallyy closed caveing spoilation.In further response. Heqweod's RESPONSE te REQUEST rember his reqaserted here. and: Hequoed was not in the Meijer Store on August 31, 2016. Attached, hereto, incorporated herein and made. a pact hececf as Exhibtta fe 4 copy ef “VERTERCATION OF TNCARCERATEON and Book ng Information revealing Heqwoed was detained at ccdoc and assigned # 2OlO12OYO 4S. The Booking informatian je marked as Exhibit A, 4. Admitthat the phetoaraph. atta ched hereto o¢ □□□□ □□□ A uias prev ided te tou bu loter dated March 14, BOW. RESPON SE 3 Heqwocd andre that eestoin Pi cures Which were opporertiy manufactured were. Prow ded +6 Heausood« S. Admitthat the phestograph attached hercto as ExhibitA dep ets ee enteri nq the Stere, on Avaust 2\, 2B)b. RESPONSE: OBsECTION. Heqwead was lacing detained at ecDoc on the Jct daw of August, 20\c. Alo, Hequood strenvousl abject +e the monumental number of requests. Fed. 3¢ requests fer admissions, over the years, have been brought in line with Fed. Rules of Civil Procedure. 2a) and 3a. Thenetore a Mou not make more. than, twenty Five Qs) requests to admit facts nor mat) he propound more. than Twenty fiye (2s) interrogator es. &. Admit that the phetegroph attached hereto as Exhibbe was provided +oueu by letter dated March 29,2018. RESPONSE: Nausea Strenvovsly ebject to request numper © □□□□□□□ Fed. R.Ciu P Se allaws the park es te narrow the isaies te be resolved at trial effechy ely ident Tying and el iminating those matters on which Heqwood cad Naijerand Stetane caree.. Local Union No. 39, Sheet Metal Workers Trtercn Anca FLA-CIOy Tripadi, 418 F.Supp. 290 (5.0. NY. 1996) (Pre se. litigant) 7. Admit+hat the photograph atteched hereto as ExhibtB depicts you walking in the. front aisle of the Store on Maver Al, ZC RESPONSE: This pro se \iti ant vehemently obiectte request} number for the reagon specified in his Gnswerte request □□□□□□ © hereinabove. Heqwood, qleo denn that the Lake. photograph □□□□□□□ Heqwood walKing in the front aisle of the Store on August 3\,20 □□□ Heguiood also ohhect to the igncble ond desperate attensTS onthe part of Metier, Stefano, Chief of Police (CoP) te emplou chi cone and. Aamearanship theoughout the litigari On. Fed. R-Civ,P. 3b(a) □□□ not desianed for chianeny ond gamesmon shi p- United States v. Kasubos ki, 834 F.2d. 1345 Cth Cir. 1987)/Tthalheim v. Eberheim, (24 FRO. □□□ □□□□ LEXTS IGTYB( \488) | United States v-Newng | \990 U.S. Dist LEXTS □□□□□ CA court Con prescr ike ao shorter o¢ \onger period wrhin which admissions denials or chiechions mau be. Sey ed); An Re Carnen, □□□ F ad. 415 Gth Gir. 200"); Estate of Sones, v. City of Martinsburg □□□□ US. Dist. LEXTS 193353 G01), Edwonds uv. Sinetas Tn re Inteco tnt| □□□□ 20\4 BonKe LEXTS 2728 (20\4). Most Federal Dierict Courts are. Teloctastr to Qrany O Wy dqament Yen G failure of a litigant parti colarly Where prose litigants ore. involved with a failure respond, let alone □□□ □□ & Admit that the photo gaph atta ched hereto as Exhibit B clepicts Ups eb; © wh, ish □ act Gites: Goth tek tea □□ neler LEXES 20c43 (aooH) Lex Chessssike Fustry Realactnceaeres, App LEXLS 5232 (Eth Cir. 2007). 6. Admit that the attached photograph’ attached hereto askahibt C Was provided +o ye by leHer dated March 29,2018. RESPONSE + Heqwoo 'S fespensd te requ est number & hereinabove. isveasserted here. OF curse, Fed.R.Gv.P □□ allows o-party to amend andlor Withdraw hie admissiona, if necessany to inedre. the □□□□□□□ disposition of cases! Carneyv.XXS Bare Came) 258 F 34 413 (Sth Cie, 2001). The FrAth Ciccurk has errictty applied the plain language. of Fed.R.Civ.P a6 MeMitlanyMem'| Heeman Health Sus. Wie US. □□□□ LEXSTS IVINT (201); Fin. + Sug, nc.w. Packer 2615 U.S. Drak Qcis)- G. Admit thet the phetoaraph allached herete as Exhibttc depicts uoy walhiing towards +he self check-cub lanes of the Store. On fusqust Al, 2oO\le~ RESPONSE: Hequced has declared under the penalties of □□□□ te the Director and Chief of the. Biechanisiny Section ofthe □ Federal Bureau of Lnvestigaton (FRY) that Hequeod did net walk” towarla the sel? Nek lanes of the Store. on Avauct3i.90 Not only could Heguood be held in contest and □□□ Be laine Reawoed could be subjected to Federal peseation as well er aterm pants obstruct justice. McCully V. Steph enville Indep □□□□ □□□ 2014 U.S. Dist LEXTS WASH SUS. jock et sc9, Sc can detendan 10. Admit hat the. photoqraph attached hereto as Exhibit D was provided +0 you by letter dated March 24, 2015. Bof Js object to mere than si Fra(eo) different request foradmi sei'ons RESPONSE: Hequicad's response te request to admit nomibers □□ and B are reasserted here... Hequood would also paiict cup that the. Phetoaraphs in question are. Presumably from a \iwew deo surveillance. machine. which waa not fHoackoni n properly. Therefore, porsvart te "The best evidence rule the produ ak. of the oriqinal ja mest detj nately required. The Federal Guts and the State Courtatoo have. found that ony -testimeny reqardi nd hat the witness observed on @ live Video Good requires foundational prect that the video System Was Foncti ening ee the time thatthe □□□□□□ were depj cted by the witness. hia foundational considembio 1%) howaver @ lower stoyrdarnd than He one used when admitting Video tape. fostane dna has been dounlooded as the. photographs Neij e's counsel have tendered te Heauwoe od pursuant te ot least three @) Ceoct arlene, under the “ silat witness theory : IU. Admit thet the photegraph attached hereto as Exhibit D depi cts you In the self check out lanes of the Store. on □□□□□□ 2 2e\e. RESPOK Heqwoo cl checks ond Chega that Heawood was in the Orn Kugust J, 2O0\b. Hequiccd has hermtolore aubmitted proof □□□□□□ inthe foam ef TuMaATE GRTEVANCE FORMS owl VERTEILCATFON OF TNCARCERATION Confirming Kequiced was detained at CROC Nn □□□□ 1. Adeni-b that the. photograph attached herebo as Exhibbth was provided be You buy letter dated March 24,2018. RE.SPON Heascod would respect tully reasKert here his respons to request to admit numbers {6,8 and WW, When certain pretearaphs were povided io not one of the issues asserted in Hequeod "s complalytt and presents no (seve oviteble for reselot on. The request i & cleacly cedundant and an ignable attempt te practice a Fraud upon □□□□□□ □□□ 13. Admit that the phet raph attached herets as Exhibit depicts you in the exif chek out lanes on Avquet 3t,2cle. RESPONSE. Objection | made te request tor admjesion, number 13. Ln pojat of fact however Hequcod's ensulera, responses and assertHons to Hequocd Answers te +he a ee propounded te Kim by defendants, as-wellas this pre Se P Ql ntift's PEARSE te request for admiacionS numbers 2,3, cand t\ hereinabove are. Feitterated, reasserted and repocted here. Seria mand verbatim he. Hequood shal| submitthe. pheteqraphe fothe FBT Crime Laboratory in Wachington, D.c.+o be analyzed ‘because. thie ic the secend dime Heaucod has been, accused oS Q criminal ofense. for which □□□□□□□ Was ond iS innocent which involved Phetographs prperting te or Hegwroed. “The Crime. Laboratory forthe FRX has previo sly heen, Called u to Wspect Surveillance. photos purporting te depict Heated an Prepared report retin FAX cant+ SH ibis and can't Say i+ jontt Hequiood depicted in a photo from surveillance. equipment. In any event; the prose. plaintiff denies that "Eehilit □ clepicts Hequiced inthe self check outlanes on Auqush 2) ,2oib. □□□□□□ Meijer, Inc., Stefano, COP and others Knowsingy, wil Fula, intentionally and deceit filly elected to clese the. Store. Sobsequentt to bang adviged of Fawood' lawersit demanding nine million nine □□□ mine dollars (4,994, 000, in damases both and purtitive with interest Gen the date ofthe onconstitotiona epsode described jn Hequiaac COMBLATAT he has been solbstanVially if rot isreparabl preipdi ced. There ig re waite preve ahether the teleswpe and vi eqvipmert was functi ning properly It. Ad mit that the photograph attached hereto ae Exhibit F panies to Hee by letter dated March 24,2018. RESPONSE: Heguicod mivet voice his OBTECTION te request feradatic sion number □ and the basis forthe ebiection io elaborated in request for admiosion RESPOKSES numbers {6 ond & hereinelsene, Ta further RESPONSE Hequoed would point out neither detenda Meiier or Stefane have. responded to Requicod's request for admissions sewed upon them in December, 2011 ond early TJanuan 2O\ie. The Foiluce to respond to Q request te admit wil permit the Court the Court to exter SASUuTaRY judgment: See, Kimy. Goldstein 2007 US. Digt. LEXEs Ni260; MS Bleferd Snack MactiIncw Weil 2016 US.Dist LEXES 35447 (tnarch S, 2018) 15, Admit thatthe. phetearaph attached hereto aa txhibit □ depicts Wow in the. health and. beauty personal care, eckion, of the Store, on huqust 3\,2O\b. RESPONSE Atthaugh Heeyscod do not have the Exhibit inhia immediate sight, the. pro se. plainti Se set he wasin the Meier Store, on Auquet 31 26}, TL should ales bee. noted that Heawood demonds strict proof Haat the teleccope. ond ideo equipment used to manifactore. the “photograph” purporting te depict hequoed WAS tuncKiening proper ’ \b&. Admit thot the. phetegraph chadat hereto ae Exhibit & was provided to by lether dated Nlardh 24.2018 RESPONSES Heaueod obyect and reassert here. Nig Ye.Sponee te request for admissions (34,5 677,69, 10.1, (a4 andiS are reasser ed here. seriatim and verbatim and these. repre secttations ace. hereby being made tothe ERE and POT under penalties of pagum. It, Admit that the. regen attached herets aa Exhibit & clepicts you in Hhe. heath and couty bearhy or personal Core gection ef the Storeon Avqust Al, Wie RESPONSE? Denied. Requeod objects and reassert’ hie respon te requeet for admissions 1,3,4,5, 61, 8G 10, M1, (Bit and are reasserted here yerloobim and declore under penalty of that defendants hove cenepiced and calevlated a achemeto manipulate his anawers und ces POnses to detendarts □□□□□□ two (62) diferent requ acts foc admiadiona. Nene of defendants’ numencis request for adwGasicn Con be Acemed odinttted under any charitable stretch of the leaal i maaination. tu w, Seer: | Gorden ne ZOIG).S. Diet LEXTS Qezo, United States v. 423,940.00 in US. Coren. 20\5 U.S. Dist LES 155723, Tourmaline Partnerg icy. Menaco, 2o\4 U.S. Dist LAYS 133205. 18. Admit that tre Pheteqraph attached hereto as Bxinilart tt was provided “Lo uot tu \etter dated Nlarch 24,2618. RESPOKSE: OBIECTRON tothe request foradmecion number \e& □□□□□□ Around that the Aefencort & March 29,201e letterie ack an □□□□□□□ Of lavor fact imolved ja the coarse. copticned alan &.. \9. Adenit that the phetooraph attached hereke as Exhibit th depicts eu the. health ond beauhy or perce nal core, section of dhe Shore, on Avquat Bi Ale. RESPONSE: Kequced’S response +o request te adimtt pumbers □□□□□ 54 WAS A, 7 and (8 are rensserred here seriakim and Verbatim. 20. Admit the pheloaraph attached hereto ae Exhibit Or provided te by letter dated Niarch 24,2Z0\e RESPONSE: Hequeod objects onthe ground that Actendarths letter 1S ne Q □□ an tssue involved inthe controversy presented tn the preee. Plaintiffs COMPLAENT Filed in the oice of the Clerk of the Circuit Gourtet es prior to the February 2h ZOV1 “ORDER” of the Honorable RAMON OCASSTO Ene. of onlya Few Shake Couet Todegs ee and vibrant enouoh to be Gppointed to the Prieetheod of the Federal vudict ecain relation to +he malicious ehoplifi AG) □□□□□□□ oor of which iS annexed hereto and made part hereof as Exhi □□□□□ whith ORDER reveals the false, shoplifting Charme wae decided in Hequicad’s Fava, 24. Admit that the photograph attached ag Exhibit&. depicts inthe hea|\+h and ae personal care, ection of the tone. On Auqus} Bl, Zl, At Fria point Reauiood woud Strenvovasly, oh\ect te defendants request for admissions responded to and answered herernabave and bela; particular in Night of the fackthe detendarts are not acting in good fart bub ere einen es man: ship and eb ceaner 4. A request for admission as te 3 & Pack in dispute - le, the core of Heauicad's ogsectiong cartenticns, allegstion and claims is facther beyond the proper eope of rostine and Neral a Olympic 1. Helding Covp (89 BR BAL, @S3 (WDRa-1995); Whitoker v Bett Concepts of Am, (6a BREE (Citi ng nett Trost Co. v.Willage. o€ Stickner, 129 F.2d SOUTH Cir. ne The defendants have. caused mich confusion, and impeded the Courts ceo adjudicate The. cavee at hand by persistently traccurgbe information; exaswe. Feuponse. and abso □□□□□□ False information. for exemple, on February 271, Die, exactly ane.) year aubeequent tothe Lovorala\ e Tesmination ofthe Selse Shoplithi na chara, during the hearing eonducted by the Court" Nejjers counsel reported -that re a of the December 2, inciderth exist which neted inthe Court's Ory 21,2018 minshe entry (Deca), copy aniexed hereto. th pant f-fact however James Tadvowski prepared an OFELCEAL SWORN, POLICE REPORT” copy omexed hertte that clear| contradict reoresertations made to the. Gourt in that the BPDO abetaA “AS Teck the felteuing phetographs oF the recovered ae | elating 4o the Dee.2 incident! The OrercrAL SyorN nce REPORT Daca Is-\, Page. 20) fist the auc 4) distinct items that Janes Tad rows photog hed on“ Date (2]02(20eBecouse of the fatec reprecerdchon fog deLendantia counse Concerning the none exigtence of the. protoaruphe and ely of the daun loaded picires of the merchandise Video sete and Photographs rropofachired are nadmiesable theretore, Hequios Velho mest Okyeck te defendant's cequest for admissions That concen any Video eee and photoqraphs. Fes. KR. Civ. BW; SEC. Betterman, Ua Dist LECKS TeSsy, 22. Admit that the pheto raph attached hereto as Exhibit) wag Provided +o Yew by letter ated Nilarch, 24, ZO\G_ □□ oaiocdkes te any adi Ssjens mqueat concem) □□ endatts letter relating to photyruchs, Heauacd's ce. □□□ requ est for admissio nai snd Z\ are, elltend, BS. Admit the, ehetearagh attached hereto as Exhibit T depicts You in the health and beauty Of pecaonal care. cection of the Stere on Auavst at, 2olb, RESPONSE: Nequecd objeds forthe nacene Speci fj edin hia □□□□□ GES A, 5,7, VW, 1, 15) 17%) 19, and 21 whi elt F2SPCMNSES Ore reasserted □□□□ 24. Admit that tre photogquph attached hereto as Exhibitk provided to by letter dated March 29, ZE\E. RESPONSE? Objection. Heawood's response to request for admia~ SIONS humber 23,15) 12/1, 9, are ceageerted here. verbatine. ielic 25. Kdmt that +e. phetooraph attached herete as Exhibit C ie picts you in the, health asic ea or personal care Section o the. Store on August 3 20le with a plastic baq en the shel RESPOKSE: Hequicod muss object and pag hie wad \athe Store. on August 3, 2016, Also,-the request for admFseion 18 for beyond the sega of rom disoxery is cme at on dhemgt fe foke advan: of this Sever C10) Years of age male adult African American. crhizen of the United Stakes who is comer 4 being held in legal dention and being Subbtected to grosaly inhumane. conditions at □□□□□ Taylor ¥. reat Lakes Waste Sow, 2000 US,Dist LEXTS 47946, Ae. Admit that the photograph attached hereto as Exhibit Was previded to usu mu eter dated March 29, 2018. RESPONSE: Heaquacd's réapense +o Niejier's requ est far adiniasions RUMers |, 14, 10.) 8, 20,22, 24,30, 32,34,36,38 ond 44 are reasserted and reitergtord here verbatim asd serighm. 21. Admit thatthe photecaraph cttached hereto as Exhibytt or leaving the health anc heauhy er personal care, secon Stereo Avast Bt, 20K. RESPONSE: He auood opject and denu thot he vsas in the Stow on ST 31,201. His objection \g cca? on his responses elakorrted hereinabove. and beleus ifically numbers 2, SU Ah (SNUG 2 oad 2S: 28. Admit that the photogcaghy attached Ween ue mW WAS Provided te You by letter dated March 24,2018 RESPORSE: Hequicod ravst strenson sly objec for the reasons that are specified in Meijer's request fer admissions numbers 3,5,46,8, 1O)A,\8, 22,24, 2, 30 32/24; 36,38 and 44 hereinabove and below. violation of Fed.R. Gy. P. i Weij\er has Bough the Same joonal ancl tedont admissions no tesco than twentyfve 25 mes Ts unfair □ AA Admit that the photograph attached hereto oe Exhilait M Was provi ded ee (or depicts yoo leaving he health ond hearty personal care settion of the Store on August with a plastic RESPONSE: This humble. seventy Ce) of age mole adult African American citizen of the United States mush etrenous|y Object te elefendartt Mejjen onk,, request for adn ssions 24, St, 33, 35,31, 39, NO astheadmissions request- any, infocmation remotely relating te Nideo toctae. andlor Fake downloaded photearaphe particularly □ light ef the Facts asserted in Raguced’s response, to number □□□ Ever ASSuMing omverde that a Federal Dietrick Gosct Coxtef Appeals □□ conclude Meijer ie not inviclation ef Fel R.civF i\;the Melyer Store if cloged and- the crifical question □□ whether treq wood entered the Store on the Slat aay of Avqush 20\6 and omitted the misdemeanerc Shepli fin 4 ctfenae for whick Heascoc was Faloely charge. uihich, chorae, wT muah be cemembered Was Atami oned by the Ceorh of competent jvrsdichion. Alse “a request for admissicn asto & □□□□□□□□ fack in dispute 16 beyend the proper Se pe aft normal andler reasonable discoveny. First National Bak + Test Co. v. Skoie, “191 Cth Gir. 1981), Fed A.Civ.P Sua) 268U.S.0.4 Fellewing secon TZ □ - T+ con be said WHthovt compun ction that the mattary which, 4 admit ted would dispose. of the natontecase of contrev Therefore the request, all si (62) of them are, vioronec eet ali in □□□□ of the fact Heqwood COMPLATHT confends thet his amrest au misdomeanor shoplifting charge. amourtted te False arrestand mMolicious prose on, Gordian. City of Chicago, 2012. US. Dish □□□□□ 22108 (Feinerman®:.) McRae v. Comeg 2015 NS.DiskLExrs (30238 Powelly. CityoF Bern, 66 F.Supp. 3d aq (LOT on)! Bechmeien v.Cityof Benuiua, 20% US. Dish LRETS 44319 (N Dai. 2018)(ZaglhS) aii id 2018 US.Dish LEXTS S074 □□□□□□□□□□□□□□□□□□□□□ Menuels Cetyat Sct (Bt (U.S. 2ofT)....., and eases cited. therein \3 of 20. Admit thatthe photograph attached herte as Exhibit N was provided te you by “letter dated Moy 24, 2018. RESPONSE: Hequcod dees"not deny thatthe pce ed comespondence from Nieijer's attemer s. art po! nt of Sock hosjwer he. obect te pequests all of themand eachofthem oabeve and below +hat cone Mm correspondence, from Meries'e coun.se □□ ae Counsel for defendants are lawyers net pores to the cause anid thejc May 14, 10\8 \etter 15 nob at issue, and itis too □□□□ te corech di Scovery deficiencies becase Hequiced has already Seuqhttan entry of default Acceptance Tndem ns Coy STAAvte Sales iC, □□□ \).5. LETS 89905> Estete of Jonesy. City of Mactinslourg ZC\e U.S. Dist 1913353; MeMillany. Mem'| Hermann Health Sug, 20le □□□□ □□□ Wate 3). Adenitqthat Ahe photegrorh atlached hereto as Exhibit depicte walKirig near the checkout lanes of the Sloreon Avovev a, □□□□ RESPONSE,: Denied, . 39, Nd mit Anat the photograph attached hereto as Exhi □□□□ was provided to you by letter dated Marc, 294,2018RESPONSE > Obyecti on and Response number 20 is ceasserted here =3. Admit that the photograph aitfached hereto as ExnibitO depicts you \eont ng the Store on August 31, 20i6 with a plesti a haw RESPONSE: Denied. Admit thet the photograph attached hereto as Exhibit P uso: provided +e You wee dated Niorch 24. 20\8. RESPONSE - Obiec oOn- Heaweods response, +o number BO 2B, Ake, ZY, 22, 20,18, Wey IN, (2,10, S and 4 are regsserted and restated here. □□ 38. Admit that the phofearaph attached hereto as ExhibthP depicts You leaving the Store. on August 3(,2016 witha plastic baq. Ree PONSE: Hequiced vehemently chiect to defendant's request for admissions number 35: and deny Hequicod WAS |n □□□ Store on Auavst3i, Be. Admit that the photograph attached Ihereto as Exhibit Q wos ees: To You by letter dated March 28,20) 2. RESPO Bs Hequiced muiet obj ectte any, and all request COncerrina, the. inacdini ssable. Protoara hie and Video Survey llonee pletures because Some, 19 a central bate Aispute . Fidelity IwstCo.v Heke supra (whidh was cite thar □□ Fimesin Mayer's response +e Heaucod's requests for admissions of feck 37 Admit that the ea, attached hersts aa Exhibrt ¢ Was provided to you by letter dated March 29,2018. RESPONSR: Hequioad’s response to request S Ze, 34 and BZereséerted here. Hequicod deny he wae in the Store. on August Bl, 2018 A. Admit thatthe So. attached hereto as Exhibit R was provided te you by letter cd Moreh 29,2018 RESPORSE> Heawoed responee. to request Zo is reasserted □□□□ B41 Admit that the pereyan attached herete as Exhibit R depicts You leaviqg the Store. on Rogues Zl, 2oleRESPONSE: Hequood ebjects ond denies he was In the Shore. on Avaust 3\, 20\b Ho. Admit that yee never paid for the merchondise within the Plastic bag depicted in Behibrts Ki MN, © and P. 15 ef □ RESPONSE: Heaquood streavausly object te defendants! atterpts to circumvent Be Pules by requesting an admission as+to □□ central fact in dispute, LE, the cere of Hequood's corterction. Qvicken Loans v.Tolly SUPE, Fidelity Tt Co, Stickney, supra. Ut Admit rat, on December 2, 20lb, You vere, present at the. Stere. RESPONSE: Admitted 4A. Admit that on December 2, Yeu removed merchandise. from the Store to with Chicags Cubs Appere|, uiltthos} paying Sor soy RESPONSE: Denied. AlSe this pro se plaintive object Ger two FEASOHNS. □□ The Waquest for admi ssion i o\beyond the preper □□□ Stope cf pormal di SCOvery and 2) Defendatrs hove. peovided re false material declarations to the State. grand jury and interchienally witheld emeal ekenerahina exidencethat caused Laval to enter @ Plea to a misdomeanoe shoplifting charge. Knouing that Neljer was elased and Keqwoed would be depraved of dee poxess in Stake. Coos where Leawood was Subjectad te selectve and malicious proseastic Email v Crane D3 Fad 16,119 Ath Ge 1998); Indicna Stube Tench Assn v. Board, tol E 3d 104, 81 CH Cir 144); Olechy, Village of □□□□□□□ brook F.3d 386 (Hh Cir. (948), Tt should benoted that □□□□□□□□ has filed two@ differen+ complant> aimed atthe convickion's contra valid onc cocking te have. the conspirators proseceted und Title 18 USC. Sec. 242 See, he, United States v Gonzalez, Se (Sth Cie 2606)( Where non-white American Gtizen died fom neck □□□□□ ulhe prier to his demiscd stutad- Seale ene - - “Tell Shem 5 Kill me ..Tell-them to take me to aospital \ tt Bhould alec benetad that the United Stetes Rene honorable Shin □□□ Lavsch, T, hag no intention of baina on idle, epactator te the diminution of the low ond constitution ef the United States. □□ □□ □□ 43. Admitthat the somveit lence Leakage doled December x, 2016, Shown vou by Acfense counsel on ordbout February Vig, 201% depicks You at the Store onthe indicated date. RESPONSE: Heancod deny that fhe prolearaph depicts, Wim. 4. Adenit that the photograph attached hereto as Exhibtt S wag provided 40 You bu leer dated March 24, 2018. RESPONSE: Heqwood VehemenHy cbjechs to ony ond all requ est for admissions relating to ExtibaihS ond can ord a\\ photoaraphss, Videe Surve) (lange tectaae that way eve heen provided. Hig responses +0 Fequest for admissions 4) lo) 810,18, 20,22, 24.26, ond 30 ore reasserted here. Tn addition the same chiections ae made te request for admiestor 4€, 50, 52,54, 5658, Go which, concern an 18602 pet in conten ereyyy and is improper ond in light ef the Lack-the came. reqs est wins advanced ro less than twarhy five (26) dames it is reaconalsly clear-tat □□□ defondertts have persistontty manifested Lath, confomacy ond Qa di oe Sor the heatthof 4his seventy Co) yeor of age. male. adult Affiean American cl zen the Uited States, MS Admit thet the photoaroph. ettached hereto as Exhibit S depicts Yow entering the Store on December 2, 20\b. RESPONSE: Hequced objects to Majjers request for admissions rumbers 45,47, 49, 51, 53, 59,57, 59 et and Ga andi} must be □□□□□□ bered that a Neier e\eched bo close. the, Stere-eo Leawood would be unalble bc @ thot the “vi □ ott December 2, 201le ETteatoo! bs Det ee On eraboulr February, \b, 20\'S depicts Heasood atthe Store ext the indicafed date! Leye x. City of Chi cage, 2011 U.S. Dish LEXIS JEXORL. □□ □□ Rule 36, stiet albeit clees not re ulate every COncelYGja| error ner Gutomaticalluy deem any tack ithe héetause. of hime.. Bread Music HDs, 2015 U.S. Diet Lerrs 433\5> Paniaquay. Walter Mdde, Zoe US. Dist LEXTS Seisd) 123 F Sop Ad (NY. Dele); Seoul Gardenctne, 2612, U.S Dist. □□□□□ 8 ReapectFu \\ 4 SS mitted ga dr pre Se, LO} Okz2E)274 D- je Post Offi ce. Ror oMqcnz. Chi a Ti) LOeocs 18 of □□ THE U STATES DU CT CourT FOR THE NORTHERN OUSTRLCE OF TLLTNGOES EASTERN GOCESTOK TALMION HEGWCOD, SR., Plain: FF, Ss Horacable GbE PEXNERMAN, rt GAR ‘| BeOS GAMTEL G MARTIN □ MELTER, AKC. ETAL, Defendants. AF ECDANEET OF SERVICE Before me, the undersianed nee th, did personally appear afFiant, TAUMON Heguiced, Ur. Kron unto the, whe Fire bein « duly aaierTt, according te Lau, upon his oath, did depose ond State T WRREBY CERTIFY that have served atwe and comect copy ot AINTIFE'S RESPONSE TO DEFENDANT wean EYPRSE SET OF RECDEST FOR ADNESSIONS on: Michoel Ducks Wor t R-Lausch Jn Or 3- , o rt Ce aot Devon Suite. BOO 219 Sodth Pearbom Street Resemont, Tt 60o0le Chicage, DL coeot Me. Michael Sheahan, eat Mc. Edword Eisendrath, Ee4Conninqgham Wee ne. a ef Seca ae neaie Drive a oe Coles Chi cage. Ti. 6&6} Chicago, Te eOes54 by placing same in sealed envelopes, having the communications, sheteceanted, □□□□□□ vert Peace affixed and delhiverect 2 the. mailrocin atthe. econ te wos posted uth +he-U,S Postal Service. on ris the And dayof Nags 2018, T,Talmeon Hequicod Or. dect above 1S-+true aon: under the penalties of pager tre Respectfelly cutsmitted, alenon M\eatisood a Cee Post OMice Be% CBIR Chicagqe: booee SUBSCRIBED AHD GNCRK TO before me, this tree Arseiy — □□ M GAUTHIER NOTARY PUBLIC - STATE OF ILLINOIS MY COMMISSION EXPIRES:04/17/21 COOK COuy; | Thomas Dart Sp Cara Smith Sheriff SHERIFE Executive Directoy COOK COUNTY DEPARTMENT OF CORREC TIONS RECORDS OFFICE 2700 S. Calitomia Avenue Chicago, Minois 60608 TX: (773) 674-6810 Fax: (773) 674-7297 VERIFICATION OF IN CARCERATION JAIL BOOKING NUMBER: O15 092.020] __ TODAY’S DATE: - |- | lo REGARDING: Heg t boad lalmon DATE OF BIRTH: _25- Ue, SECURITY NUMBER. 335. 42~o9 DD to your request the following information is submitted: Booking Number: AOD\S -9 O2.02¢ >) Sail Booking Number\ SS SSS entered in CcbDoc: ey = a H-1S Date entered in cepoc\ Released: \ Date Released: #: | 5 cu O86 Cc >| Case/Docket #: (s): Petas \ \ \ \e-++ ————__ Charge (s): □□ \ | : Londt 4 Disposition: □ □ Date: Disposition Date: □□ et of A.A. Form h— neat .l ia ee ee ee aa ee 2 i i a Friday, July 14, 2097 COOK COUNTY SHERIFF'S OFFICE nn 5:04:37 AM BOOKING CARD ae ges Prisoner Type: Pre-Trial athe Bkg Date/Time: 6/20/2017 5:17 PM Hair Color. Black Citizen Of, USA rive Age: 69 Eye Color: Brown Birth Place: USA os DOB: 3/13/1948 Height 6 ft On Religion: Catholic SSN #: 335-42-0938 Weight: 170 Gang: FBI #: 744716F Build: Medium SID 110937100 Complex: Medium Brown SE ee IR#: 121196 Arrest Address: Home Address: City: State: Zip: Phone #: Emergency Name: Relationship: CCOMS Case Type Docket # Current Bond Last Court Date Court ID 244982 State Statute 17400294701 6/30/2017 9:00 AM Maywood Case Continued x= a Alias Full Name Date of Birth SSN Associated Booking Daie Alias Type 2 Hegwood, Talmon 3/13/1948 335-42-0938 20170620227 6/20/2017 Alias Hegwood, Talmon 3/15/1948 335-42-0938 20170620227 6/20/2017 Commit Name 3 Hegwood, Talmon 3/15/1948 335-42-0938 | 20170610011 6/10/2017 Commit Name = Hegwood, Talmon 3/15/1948 335-42-0938 20170406002 4/6/2017 Commit Name Hegwood, Talmon 3/14/1948 335-42-0938 20161204093 12/4/2016 Commit Name Hegwood, Talmon 3/14/1948 335-42-0938 20150820201 8/20/2015 Commit Name Hegwood, Talmon 3/14/1948 335-42-0938 20141203076 12/3/2014 Commit Name Hegwood, Talmon 3/14/1948 20080076791 10/8/2014 Name Any Information and Reports produced from | the Cook County Offender Management Systern (CCOMS) is for internal distribution only. For an Order (Rev. 02/24/05) CCG N00 PEOPLE OF THE STATE OF stNOrs v. No. J@CRIPE43 and ieee: □□□ i | ~ - ° ORDER THIS matter coming, before, the Court and the Court rAd Yrisdictionover the subject matter and the hereto and bein aduieen in the premises: sCTIS HEREBY On ERED that the oe NG od ) 3 3 j j a te ees ee Noi |e RI\BBYS is cismiss tre FURTHER ORDERED that Chief of Police for the Ser Police Department (BPD) andjor law enforcement eer Senet Lor the cit. of Baruyr. □□□□□□ +o Talmon Hes wood, Or, eNoee all Roberts trot □□□□□□□ . to Rim Which was derom Berwin bo ice Bepartment □□ abevt December 2, aan. immediately vpon Rear and|or presentation of this ORDER {Oo ORPERED. | PRB ry FEB 27 2017 No.: ; Y BROWN . Court for: = —__ Dated: Zip: =< ' ew Qea Gell { Judge Judge’s No. NOROTHY RROWN ERRE OF TW CTRCTIIT CATIVgT OE CHNMNY eCrTiArrs,s wit4tttmio IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS Talmon Hegwood, Jr., ) ) Plaintiff, ) ) Case No. 17 C2887 V. ) ) Magistrate Judge Daniel G. Martin Meijer, Inc, et al, ) ) Defendant. ) ORDER The Clerk of Court is directed to remove document numbers 105, 106, 107, 108, 109, and 112 from the public record. Local Rule 26.3 expressly forbids the filing of discovery materials in the absence of a court order. BE □□□ □□ □□□□□□ Date: 4/09/2018 /s/ Daniel G. Martin United States Magistrate Judge 7742-AJTIICS IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TALMON HEGWOOD, JR., ) Plaintiff, ) Case No.: 1:17-CV-02887 Vs. ) Honorable Gary Feinerman ) Magistrate Judge Daniel Martin MEIJERS and CASEY STEFANO, ) Defendants. DEFENDANT, METLIER’S, FIRST SET OF REQUESTS FOR ADMISSIONS _ NOW COMES the defendant, MEIJER, INC,, incorrectly sued as MEIJERS, and pursuant to Federal Rule 36 of the Federal Rules of Civil Procedure submits the following Requests for Admissions to the Plaintiff, TALMON HEGWOOD: INSTRUCTIONS [f Talmon Hegwood, Jr, (hereafter the “Plaintiff’) fails to respond or object to any request within 30 days of the service of the Requests, the matter shall be deemed admitted under Fed. R. Civ. P. 36. As is more fully set out in Fed. R. Civ. P. 36(a), the Plaintiff must admit or deny each request, and, where necessary, specify the parts of each request to which he objects or cannot in good faith admit or deny. If the Plaintiff objects to only part of a Request, it must admit or deny the remainder of the Request. In the event that the Plaintiff objects to or denies any Request or portion of a Request, the Plaintiff must state the reasons for his objection or denial. These Requests shall be deemed continuing and supplemental answers shall be required if : MOTION FOR MDGMEAT BY DEFAULT □□□□□□□ you directly or indirectly obtain further information after your initial response as provided by Fed. R. Civ. P. 26(e). Each Request solicits all information obtainable by the Plaintiff. If you answer a Request on the basis that you lack sufficient information to respond, describe any and all efforts you made to inform yourself of the facts and circumstances necessary to answer or respond, DEFINITIONS l. The word "or" is used herein in its inclusive sense unless the context clearly requires otherwise. 2 The term "document" means and includes without limitation all correspondence, agmorade: vertificates, notes, hooks, marnals; pamphlets; brochures_advertisements. hooks of □□ □ account, balance sheets, financial statements, profit and loss statements, working papers, schedules, diaries, calendars, logs, time records, equipment records, microfilms, transcripts, recordings, tapes, telexes, telegrams, files, proposals, bids, offers, contracts, agreements, change orders, worksheets, drawings, blue prints, designs, specifications, time cards, compilations, graphs, charts, bills, statements, invoices, receipts, bills of lading, shipping records, confirmations, applications, purchase orders, checks, checkbooks and other checking records, photographs, formulae, prescriptions, studies, projections, reports, computer programs, information contained in computer banks, tapes, cards, printouts and drafts to the extent they differ from the originals, and all other records and papers of any nature whatsoever. 3. Any reference to a specifically named person, corporation or other entity and any reference generally to "person" shall include the employees, agents, representatives and other persons acting on behalf thereof or through whom the referenced person acts. The term "person" means and includes natural persons, corporations, partnerships, joint ventures, sole proprietorships, associations, trusts, estates, firms and any other entity. 4, As used herein, "Plaintiff' means, unless otherwise indicated, Talmon Hegwood, Jr. 5. “You” or “Your” means the Plaintiff, Talmon Hegwood, Jr, and all persons acting on behalf of the Plaintiff. 6. As used herein, "Defendant", shall be deemed to include Meijer Inc., as well as its agents, attorneys, representatives or any other person acting on its behalf or on behalf of any one of them, unless otherwise indicated. RE. Jeo Stefan as used herein, meuus-Defendant Officer Gasey Stefano = 9) SS 8. As used herein, “the Store” shall be deemed to reference the Meijer Retail Store located at 7111 Cermak Road, Berwyn, [llinois 60402. FIRST SET OF ADMISSIONS 1. Admit that, on August 31, 2016, you were present at the Store. RESPONSE: 2, Admit that, on August 31, 2016, you removed merchandise from the store, to wit, various health and beauty products, without tendering any payment for the same. RESPONSE: 3. Admit that the surveillance footage dated August 31, 2016, shown to you by Defense Counsel on or about February 16, 2018, depicts you at the Store on the indicated date. RESPONSE: 4, Admit that the photograph attached hereto as Exhibit A was provided to you by letter dated March 29, 2018. RESPONSE: 5. Admit that the photograph attached hereto as Exhibit A depicts you entering the Store on August 31, 2016. RESPONSE: 6. Admit that the photograph attached hereto as Exhibit B was provided to you by letter dated March 29, 2018. RESPONSE: 7. Admit that the photograph attached hereto as Exhibit B depicts you walking in the front aisle of the Store on August 31, 2016, RESPONSE: “covet: UBFOS <Ageaitdhabdie photograph attached hereto-as Exhibit C vas provider to you by □ letter dated March 29, 2018. RESPONSE: 9. Admit that the photograph attached hereto as Exhibit C depicts you walking towards the self check-out lanes of the Store on August 31, 2016. RESPONSE: 10. Admit that the photograph attached hereto as Exhibit D was provided to you by letter dated March 29, 2018. RESPONSE: 11. | Admit that the photograph attached hereto as Exhibit D depicts you in the self check-out lanes of the Store on August 31, 2016. RESPONSE: 12. Admit that the photograph attached hereto as Exhibit E was provided to you by letter dated March 29, 2018. RESPONSE: 13. Admit that the photograph attached hereto as Exhibit E depicts you in the self check-out lanes of the Store on August 31, 2016, RESPONSE: 14. | Admit that the photograph attached hereto as Exhibit F was provided to you by letter dated March 29, 2018. RESPONSE: 15. | Admit that the photograph attached hereto as Exhibit F depicts you in the health and beauty or personal care section of the Store on August 31, 2016, RESPONSE: 16. Admit that the photograph attached hereto as Exhibit G was provided to you by letter dated March 29, 2018. RESPONSE: 7. “Admit that the photograph attached hereto as Exhibit G depicts you in the health and beauty or personal care section of the Store on August 31, 2016. RESPONSE: 18. Admit that the photograph attached hereto as Exhibit H was provided to you by letter dated March 29, 2018, RESPONSE: 19. Admit that the photograph attached hereto as Exhibit H depicts you in the health and beauty or personal care section of the Store on August 31, 2016. RESPONSE: 20. Admit that the photograph attached hereto as Exhibit I was provided to you by letter dated March 29, 2018. RESPONSE: 21. □ Admit that the photograph attached hereto as Exhibit I depicts you in the health and beauty or personal care section of the Store on August 31, 2016. RESPONSE: 22. Admit that the photograph attached hereto as Exhibit J was provided to you by letter dated March 29, 2018. RESPONSE: 23, Admit that the photograph attached hereto as Exhibit J depicts you in the health and beauty or personal care section of the Store on August 3 1, 2016. RESPONSE: 24, Admit that the photograph attached hereto as Exhibit K was provided to you by letter dated March 29, 2018. RESPONSE: 25. Admit that the photograph attached hereto as Exhibit K depicts you in the health and beauty or personal care section of the Store on August 31, 2016 with a plastic bag on the shelf. RESPONSE: 26. Admit that the photograph attached hereto as Exhibit L was provided to you by letter dated March 29, 2018. RESPONSE: 27. Admit that the photograph attached hereto as Exhibit L depicts you leaving the health and beauty or personal care section of the Store on August 31, 2016 with a plastic bag. RESPONSE: 28. Admit that the photograph attached hereto as Exhibit M was provided to you by letter dated March 29, 2018. RESPONSE: 29. Admit that the photograph attached hereto as Exhibit M depicts you leaving the health and beauty or personal care section of the Store on August 31, 2016 with a plastic bag. RESPONSE: 30. Admit that the photograph attached hereto as Exhibit N was provided to you by letter dated March 29, 2018. RESPONSE: 31. Admit that the photograph attached hereto as Exhibit N depicts you walking near the check-out lanes of the Store on August 31, 2016 with a plastic bag. RESPONSE: 32. Admit that the photograph attached hereto as Exhibit O was provided to you by letter dated March 29, 2018. RESPONSE: . 33. Admit that the photograph attached hereto as’ Exhibit O depicts you leaving the Store on August 31, 2016 with a plastic bag, RESPONSE: 34. Admit that the photograph attached hereto as Exhibit P was provided to you by letter dated March 29, 2018. RESPONSE: 35. Admit that the photograph attached hereto as Exhibit P depicts you leaving the Store on August 31, 2016 with a plastic bag, RESPONSE: 36, Admit that the photograph attached hereto as Exhibit Q was provided to you by letter dated March 29, 2018. RESPONSE: 37. Admit that the photograph attached hereto as Exhibit Q depicts you leaving the Store on August 31, 2016. RESPONSE: 38. Admit that the photograph attached hereto as Exhibit R was provided to you by letter dated March 29, 2018. RESPONSE: 39. Admit that the photograph attached hereto as Exhibit R depicts you leaving the Store on August 31, 2016. RESPONSE: 40. Admit that you never paid for the merchandise within the plastic bag depicted in Exhibits K, L, M, N, O and P. RESPONSE: 41, Admit that, on December 2, 2016, you were present at the Store. RESPONSE: 42. Admit that, on December 2, 2016, you removed merchandise from the store, to wit, Chicago Cubs Apparel, without tendering any payment for the same. RESPONSE: 43, Admit that the surveillance footage dated December 2, 2016, shown to you by Defense Counsel on or about February 16, 2018, depicts you at the Store on the indicated date. RESPONSE: 44. Admit that the photograph attached hereto as Exhibit S was provided to you by letter dated March 29, 2018. RESPONSE: 45. Admit that the photograph attached hereto as Exhibit S depicts you entering the Store on December 2, 2016. RESPONSE: 46. Admit that the photograph attached hereto as Exhibit T was provided to you by letter dated March 29, 2018. RESPONSE: 47. Admit that the photograph attached hereto as Exhibit T depicts you walking in the Store near a frozen food cooler on December 2, 2016. RESPONSE: 48. Admit that the photograph attached hereto as Exhibit U was provided to you by letter dated March 29, 2018. RESPONSE: 49, Admit that the photograph attached hereto as Exhibit U depicts you near Chicago Cubs Apparel the Store on December 2, 2016. RESPONSE: 50, Admit that the photograph attached hereto as Exhibit V was provided to you by letter dated March 29, 2018. RESPONSE: 51. Admit that the photograph attached hereto as Exhibit V depicts you with your hands on merchandise at the Store on December 2, 2016, RESPONSE: =" 52. Admit that the photograph attached hereto as Exhibit W was provided to you by letter dated March 29, 2018. RESPONSE: 53, Admit that the photograph attached hereto as Exhibit W depicts you walking away from an apparel display with merchandise at the Store on December 2, 2016. RESPONSE: $4, Admit that the photograph attached hereto as Exhibit X was provided to you by letter dated March 29, 2018. RESPONSE: 55. Admit that the photograph attached hereto as Exhibit X depicts you walking in a main aisle at the Store on December 2, 2016 with merchandise under your arm. RESPONSE: 56. Admit that the photograph attached hereto as Exhibit Y was provided to you by letter dated March 29, 2018. RESPONSE: 57, Admit that the photograph attached hereto as Exhibit Y depicts you walking towards the exit of the Store on December 2, 2016 with merchandise under your arm. RESPONSE: 58. Admit that the photograph attached hereto as Exhibit Z was provided to you by letter dated March 29, 2018. RESPONSE: 59. Admit that the photograph attached hereto as Exhibit Z depicts you exiting the Store on December 2, 2016 with merchandise under your arm, RESPONSE: 60. Admit that the photograph attached hereto as Exhibit AA was provided to you by letter dated March 29, 2018. RESPONSE: □ 61, Admit that the photograph attached hereto as Exhibit AA depicts you exiting the Store on December 2, 2016 with merchandise under your arm, RESPONSE: 62, Admit that you never paid for the merchandise under your arm as depicted in Exhibits V, W, X, Y, Z and AA before you exited the Store. RESPONSE: Respectfully Submitted, MEIJER, INC. of the Attorneys for Defendant Amy J. Thompson Joseph C, Sheahan CUNNINGHAM, MEYER & VEDRINE, P.C, Attorneys for Defendant, Meijer, Inc. One East Wacker Drive Suite 2200 Chicago, Illinois 60601 312-578-0049 [10] BALTED STATES OXSTRICT COURT FOR THE NORTHEAN PRSTELCT OF TILTNOTS TALMON, HEAWOOD, TR. Plaintift, ~versus~ Ro. \:1-cv- 2867 Honorable GARY FEXNERMAN, i Horiorable PAMTE b. A. MARTE, bass, MEISER ,Hc.,and CASEY SpREANO, Nefendants. REQUEST FOR PRODUCTION OF DOCUMENTS TO; Metier, Tne, go ir Joseph C. Shechon Esq. URAL ham Meyer tNedsine EC. Kioonene- fics (East Res Ove Suite. 2300 Chicago, Tiinois 6660) Talmon Hequioed Tr: (Kequeod) plaint44¥ herein respectfully request that Meijer, tne, (Mejier) defendant hesein produce. te Hequoed within Arichy □□□ days of the, date, of thie dlecorery devise the. deauments ond materiale lated below, This request 19 being made, pursuant te Fad. RiCiv,P 3M, \. Pictures of ti blue. Chicane Cubs Necd Series Champlorahip hoodies Gad (5) aray World Srlna Chet sions: T ahacts that lose prexersti on moh Moreus Taderson (Andeszon) retrieved from a eect In the Pepeue's Restaurant on or about December 2, 2016. 2Cnwvotge, rexealing Meijer tne, purchased Chicago Cubs World Saries Chomptonship hoodies and Zhits tebe sold, displayed and morketedin □□□□□ Photo’ perporting +o portra Wasated Anderson provided +p OfFPi cer ate eons (acters) lonaecton® HF the. complaint ne signed Ahat led te the rralicfaug Preac.cution, of Hequcod . 4, Copy of the “ORDERS OF Honorable Tudge RAMON Occesic uthich dismissed ta Yihee shoplifting Chowne. ond ordered Borwiun Police. te return Heaucod:< properkyte Reawood 5. tt of a and all decoments Hat within pe Sees of our Knowledee an ee within the Scope, of sour Anew\ eda e. | & Aiexart te iia. a ch described in He. Srptants Wey er ondlor ke Qgerct Signed that ted +e the proscevhion of Weaweod. Ase courtesy Reniced hae annexed hee. copies of The " OFERCAL SworRW POLLCE REPO AT excceted by Steffans concern ng the. jncidurcks thet vielate Henpiced's clear\4 estabitighed constivtienal hts. Respectfully eubmitted, Ps pre se. me ZOVLO 227 Poet Office Ber OBF0OA AR Shh GOwes bat SUBSCRIBED AWD SWORN TO ore. me, +hia thy ay of TAME 217. TARY PUR: “OFFICIAL SEAL" M RUIZ-NAVARRO Notary Public, State of Iinois Commission Expires 6/19/2021 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TALMON HEGWOOD, JR., ) ) Plaintiff, ) ) vs, ) Case No.: 1:17-CV-02887 ) Honorable Gary Feinerman MEIJERS and CASEY STEFANO, ) ) Defendants. ) DEFENDANT, MEIJERS’, RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS NOW COMES, Defendant, MEIJER. INC., incorrectly sued as “MEIJERS.” by and through its undersigned attorney, pursuant to Fed. R. Civ. P. 34 and for its Responses to Plaintiff's Request for Production of Documents states as follows: 1. Pictures of the (11) blue Chicago Cubs World Series Championship hoodies and (15) grey World Series Championship T-shirts that loss prevention agent Marcus Anderson (Anderson) retrieved from a seat in the Popeye’s Restaurant on or about December 2, 2016. RESPONSE: Objection. This request is vague, ambiguous and assumes facts not in evidence. Subject to and without waiving said objections, Defendant affirmatively states that Mr. Anderson did not retrieve any of the stolen merchandise from a seat in the Popeye’s Restaurant or elsewhere and did not take any pictures of the stolen merchandise. Answering further and subject to the prior objections, the only pictures of the stolen merchandise known to Defendant and in its custody and control are the surveillance footage and still shot images produced by Defendant pursuant to the Court’s request and provided to Plaintiff via letter on March 29, 2018, the receipt of which was acknowledged by Plaintiff during the April 5, 2018 court appearance. 2. Invoise [sic] revealing Meijer, Inc. purchased Chicago Cubs World Series Championship hoodies and T-shirts to be sold, displayed and marketed in Meijer. LAR STR mea 5s So SARL Su Bede: □□ L □□ □□□ RESPONSE: Objection. This request is vague, ambiguous, harassing and seeks information that is neither relevant nor reasonably calculated to lead to the discovery of relevant evidence. 3, “Photo” purporting to portray Hegwood Anderson provided to Officer Casey Stefano (Stefano) in connection with the complaint he signed that led to the malicious prosecution of Hegwood. RESPONSE: Objection. This request is vague, ambiguous, argumentative and duplicative. Subject to and without waiving said objections, see photographs provided to Plaintiff by letter dated January 26, 2018 in response to Plaintiff's subpoena directed at Defendant and pursuant to Docket Entry No. 75. 4. Copy of the “ORDER” of Honorable Judge RAMON Ocassio which dismissed the false shoplifting charge and ordered Berwyn Police to return Hegwood’s property to Hegwood. RESPONSE: Objection. This request vague, ambiguous, argumentative, assumes facts not in evidence and is better directed at other individuals/entities. Subject to and without waiving said objections, no such Order or document is in Defendant’s custody, possession or control. Ae Copy of any and all documents that within the scope of your knowledge and/or within the scope of your Attorney's knowledge is relevant to the conduct described in the complaints Meijer and/or its agent signed that Jeg to the prosection of Hegwood. RESPONSE: Objection. This request is vague, ambiguous, overly broad, and secks information that is neither relevant nor reasonably calculated to lead to the discovery of relevant evidence. Subject to and without waiving said objections, none other than the surveillance footage previously shown to Plaintiff, the still frames from said surveillance footage supplied to Plaintiff, documents supplied to Plaintiff by Defendant in response to his subpoena (as referenced in Defendant’s Response to Request No. 3), documents provided to and retained by the Berwyn Police Department at the time of the offenses and the attached theft reports. Respectfully submitted, MEIER, INC. By:__/s/ Joseph C. Sheahan One of its Attorneys Joseph C. Sheahan (IL Bar 6313969) CUNNINGHAM, MEYER & VEDRINE, P.C. | East Wacker Drive, Suite 2200 Chicago, Illinois 60601 Tel: (312) 578-0049 Fax: (312) 578-0247 E-Mail: jsheahan@emvlaw.com Attorney for Meijer, Inc. CERTIFICATE OF SERVICE A copy of the DEFENDANT’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS filed electronically this 11" day of May, 2018. Notice of this filing will be sent to all parties by mail. Parties may access this filing through the court’s electronic system. Pro se Plaintiff Talmon Hegwood, Jr. 4642 S. Michigan, #358 Chicago, Illinois 60653 Talmon Hegwoud, Jr. #20170620227-D-2-D-2-N-44 Medical Unit P.O. Box 089002 Chicago, [inois 60608 Talmon Hegwood, Jr. #20170620227 RTU H-3 P.O, Box 089002 Chicago. [linois 60608 Attorneys for Co-Defendant Andrew Y, Acker Storino, Ramello & Durkin 9501 West Devon 8"" Floor Rosemont, Illinois 60018 847-318-9500 Andrew/@srd-law.com MRDurkin‘@)srd-law.com /s/Joseph C. Sheahan Joseph C. Sheahan (#6313969) CUNNINGHAM, MEYER & VEDRINE, P.C. One East Wacker Drive. Suite 2200 Chicago, Illinois 60601 (312) 578-0049 (312) 578-0247 - fax Email: jsheahan(@jemvlaw.com Attorneys for Defendant, Meijer, Inc. MOTION FoR DUDGMENT BY DEFAUET Exhibtt Gra Rae ae Si) bn ee 2 BOSE MCGOMOaNn Ese. anninghe 1 Meuet +Nedring, P.C. lene Ea: Wacker Drive Suite Zoo Meage, Ew 6Oe0} Re: Hequioed —v- pfer, Ene, etal. NS 2teen= aoe. are eS ee enorable Gary Feinesman, J tSneomrcric WiaaiSartare ani. Nia rl | way Dea Aarne Stace 5 Please. review your “RESPONSES TO Prarerrre's’ NTE RROG, AyORT & ond REQUEST POR ADMTSETONS OF FAS” land compare iwtth uour . ANGERS TO PLATHTTEE: COMM AINT™ hh aunderaigned 1s net satiefed with responses te leqiimate ennee’ mode Sor diacowen ner the cnewere your chert provided. he chore, please. accept thie leer as mu endedecc “neck ond confer . eX ona © }_porsuedt te Rule 218) @)G) ofthe BAR Wee. P in on effect bes reselue, ‘he moter whereby, Ye neceasichy | DC Covets,_Imatuement™ mau tee. alles aed A Lie ely response. to tere letter westd be prident: almonf\eq@sood, Ur. | teestetis Spied, pest Office Bex □ S4m>2. Chicase - COecs WIBSCRTBED AND SWORN To ee = [Peferg ree, ne vi sets ee PUBLIC - STATE OF ILLINOIS — (_\ 2 _ ST ai “¥PIRES:O7/30/1B8 a 1p aeRO | ____s NOTARY Pie □ March bebe — tal sicas ——_—— □□□ □□ □□ ae a NRE ERS a Be: Mal 4: AEE eats Diane □□□ Sieben Please. “ind _enclesed a copy of srw _tertterr dake □ ctenth te Say te pe personally upsnd man, □□ the _lmpression. Se eS es □□□□ of the lawyers charaed With the respon sibi ids of poaitding TWofeadants with gl cepresentchan. T-sschd ask □□□□ □□ please, nate, Counsel, my demeenar and_mannerign Thad eur Ineperson mesting was more.than cordfal, TeecaltSvnutdll, Shak oth uooend _KHlemey Duckin let smiles.on vcur faces Fn gaint cf fact haven _T_weld to the Court; se if the United States Naaistrate, Ladee, Henecadble Daniel. Mortin Opin my bse eae □□□ 2 -_eppesiitien ceunse| 1s impropary rest-assanel □□□□□ ReEMarckh ACi@ i Page 2oPA recened te documents described tama affixed sufficient postnge and delive The lage the U.S Postal Senuice, Ta fact, stated: “The □□□□ cep Te Oe ll fend enoloand herewitl ‘| \ of the prose plaints answers te intecrogabedes,— lof Docume ates ~ Welicn For & Cmeclidalion | Crler ond ReqestTor 00 PE quaciacke ale Moe eeued pon tones □□□□□ □ i! Please accopt thas: letter as my “mect and canker deee. and □ Please, produce tne mikeside ceqested therein (which ace alse in ony mekion te compel discven, Bocas 60 __ Neure tru 9s arperesd eae ee Vee, 4 Ht nm wood, A ee See cs SE A ct ah en ipl ean i ke OK CeAOO □□ {20+ Henondple. Daniel G.Morkin —_Chicagp, LOWOH Peno rable, Gary Feinerm on, □□ Honorable Sohn BR Lav ¢ commen Nin Michae| pee ee ee □□ ae □□ IS ROO SORE TE reme, HUG the “dey of tech eee ee la 3 _____ Mellicent Ear-—-—-—- : a ee □□ 2 Notary Public, State of Illinois _ April4 2016 Nir. Michael Durkin, Gcrelle Rome lle Tein pees ~Ke- Low \ s+ Deven. Suite @ca Resemont, Tj Re: Hee uw Meiier Tne, etal Ns - one eae: Srorable GARY { : ( Heneatle CNET a NES □□ Deore Mr, Durkin: Dori no, the April 52018 Status hear ng conducted ba the United States Magistrate Edae, Henerable Daniel G Martin( □□□ □□ and Me. Joseph ©. Shechan beth indicetted Hhect You did net receive the cepics ef plaintiff's "REQUEST FOR ADMITSSTONS C& GENUENESS OF DOCUMENTS gerved upon beth counsel of vecorl in the qhove referenced couse. pursuant tothe “PRISONER MAH BOK RULE, ond the Fed. □□ □□□ P as ao-the Courta Lace Rules a& indicated bay rm" AFEXDAYIT OF See Gnaened to tre above clesceibedl Fed R.CW.P Be clicxovery, deviae. therfer<, that same any additional COPIES WAKE MA led tc npr Did you mecaN ethe. Fed. R.Cv.P Be disccreny device Tf sa, plese. provide upon responses 18, OF course, my" mee and confer’ \eker and hepato He will obviate the. necessity ef Ri ng a mehiern to compclo CLEPNS Ee, Enclocu| herewith, please, find a copy of ma medical cesocla Tred compiled Sy Health Care. Providers emplayert fy Mactteal tesprtal on the date of my unconshteticnal armrest by defendats Cosey Shera ank Nieijernc, \ocs” prexention agent Mores Aniecsert, Tf yer rocal| ' Ceorasel the, Mit iwatructec\this pre Se. parnhit □□ Nic. echae VOriay ay. April q 20\8 Page 2of & preide numbers ot and [oron doumet™ inthe Soture when fespeading te defendants Aieceveny mequet®. Please pete, Coonsxl the. enclosed copies of ma medical retorts have. numbers that ore or me devi couse. much copfucion. Werefoce, te auntd this TZ haw Faken +e, (i becty te ofGK hunber \—&[ on the enelosec| medi cal records □ blank, back sides—-ae TR dace net case the decuments 42 become Inad migsable oy maki cay marking sheen nel made by one of NacNe«a| Ke sprkal ceek Batiews ledge _ receett Ane. encle<cod Paes of medical cocerl =. lecferreqetecies nan moais Ser pees Kon and; purscant te the. Naluakkle hint ofthe MS supp lemest- ye and mGpcrnees, desi respectrell, une. defendants to ayia thar anscero te aciqinal ee angers +o interrcacle tess and PErELe, Ve ma Peqvests made poranant te the applicable. praentaacns of the Fed. 2 Cw.B, and plens<. PONT Snot Answers . Copies of cles medical carers and documatts cshall be mode cwailalsle to both atonens Gf red loa the undersianed □ the neerfuvre. Tanthe meantime, T wich beth of wer well. Sincerely, falmen Wedd 000, Or, ZOVWWORAE AZT D-te~ FQ Post Of ce Bek Gor, Chicago, TW bomeé ec: when Honorable. 16 > =, Wic. Jeneph Clee a Svs SCRTB , GD AND Suemite before. me tnie the Td Aeeil, owes, Co OFFIWIAL . MGAUTHIER NOTARY PUBLIC STATE OF ILLINOIS Liv ORME CION EXPIRES 04/17/21 Ale Mord, 2016 Stone Rents ee geet Wat Devon Svite Boo esemerh SR cocie, om Kemiced x Metien etal. fon, US. ek Ch Hencs) Ginny Feineomen GO Honiel & Rerice MS. Dear Attorney Doclin: United States Magi atrate. Su dae, Henerable Danie| G.Mastin indicated nq the. ee On March 22,20\18 that both you and Attomen, Woee ph C. Shechon, Eaq." are. fine Yoong, lawerg,’ and that “personal attacks on SEs ein counse,| onnecesSonu. Evidently, Nag strate Madge, Machin, (Sedge Nartin) recconized in Yeu two atternens what 2. ecu! when Ley viatted me here, at the Cook Courhy Deporhment of Comections (CeBec) and permitted me to view the video tostane on Your computer, Tf Up recall, Counsel ou and Athecrney Shechan were tredtod with the utmost Regpect and advised both of pe thob: Am ne □□□□□ for Yeu “ Xvecall with sharp Clarity Stating during, Our In person Meetin rs to beth of pe "Doctor ore, like wine, best wien they are at But auyer arg liKe bread, best when they are. Ma ond now Did Trot? Well, thatia still my Gentimect which iene out Yat, Zot 2 by the Way You were, treated ducing our in-person masking and, of course the commente of tne Federal Nagi atrate.. Therelare, please. do net Wmaaine that TE held cr Contempt or enmity fon Yeu OF Your Clients. And, please accept m4 homble appelagy if * tone, in any of the documenta Prepared buy this weiter mas, hae jndigcted otherwise. Meo, during the hooring Yee ond KHeray Cheahan, stated you dik net fecejve (*)" Plainkift's Response te Defendonts, Stefands First Request for □ Productton of Documents’ @)" Plaintifl's Anowers te Stefonc'g Tnterogtoces G)"Plantiffs Responte-to Neijer's Notes for Production of Documents” □□□□□□□ HAS Answers to Citea jer's) Interrogekores' (6) " Plawtifl's Motion □□□□□ Consolidation Onler ad: “Plane Request for Production of Documents. The Cart atabe H woutd Sian an ORDER, directing Loy Lalbrorton, Mra. Momie| Gavtier +o cayae ancther copy of och decument to be mailed to Wo, Yas will find o PH ef each, docomertt Veted herknabsye, enclosed herantth, Tam alae enclosing ce pies of the enyelopes. which enclosed copies of the matertale the law librarian, Mes. Richaleon, skated she had previously delix ew bo the ecpoc maj\room, to be, Fested wrth the 1S Poot Service add creased to Wee, ek Shechan and Atkernen) Amy 3. Thompéon, Esq. Tf WOU heed cny thing, else from Youre Analy, Please, dont hesitate to let me Know, Sincere| —_ ec: wfencl, fei a Mer. eae C. Srechan. BPOMORPO ZZ Deb 2K Horeectle Gen, Pane Pout Olhicc Ben omtcae Martin Chicaeg, SL ovo tenealat eae g Meth SUBSCRIBED AND — das of 20\8. See 3 Notary Public, State of ilinois ——___________3___ Notary Public, State of Illinois _ IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TALMON HEGWOOD, JR., ) Plaintiff, ) Case No. 1:1 7-cv-02887 Vs. ) Honorable Judge Gary Feinerman MEIJERS and CASEY STEFANO, Defendants. DEFENDANT CASEY STEFANO’S RESPONSE TO REQUEST FOR ADMISSIONS OF GENUINENESS OF DOCUMENTS NOW COMES the Defendant, CASEY STEFANO (“Stefano”), by and through his attorneys, Storino, Ramello & Durkin, and for his Response to Request for Admissions of Genuineness of Documents, states as follows: l. “ARREST REPORT” prepared by Stefano as “1" Arresting Officer” who acknowledges” and affirms /sic/ under penalty of perjury that the facts stated in the document... are accurate...” The document that a “VISUAL CHECK of Hegwood revealed no “obvious pain or injury” and arrest “Location 7111 W. Cermak Road.” RESPONSE: Defendant Stefano objects to Request to Admit Number 1 because it is vague and ambiguous, and does not accurately summarize or state the terms of the document sought to be admitted. Without waiving said objections Defendant Stefano denies request Number 1, as the document attached and referenced as Exhibit E was not prepared by him. ae MOTION FOR GUDGMEKT BY DBFALLT Exhibit 7 2. “ARREST REPORT” prepared by Stefano as “1** Arresting Officer” who again “affirms /sic] under penalty of perjury that the facts stated in the document are accurate...” The document states that a VISUAL CHECK OF ARRESTEE.., Hegwood revealed “obvious pain or injury” and Arrest Location 7111 W. Cermak Road. RESPONSE: Defendant Stefano objects to Request to Admit Number 2 because it is vague and ambiguous, and does not accurately summarize or state the terms of the document sought to be admitted. Without waiving said objections Defendant Stefano denies request Number 2, as the document attached and referenced as Exhibit F was not prepared by him. 3. “OFFICIAL SWORN POLICE REPORT” which is a six (6) page document stating that Stefano, James Tadrowski, (Tadrowski) Achille Chiappetta, (“Chiapetta) Edward Tovar, (*Tovar) William Messuci, (Massuci) Peter J. Podgorski, (Podgorski) Joseph R. Pesa (Pesa) and Armando Campos (Campos) arrested Hegwood at “Popeyes Restaurant located at 6935 Cermak Road, not at 7111 Cermak Rd. The document also state that Meijer, Inc., “store security... detained Hegwood “with on scene officers including Stefano. RESPONSE: Defendant Stefano objects to Request to Admit Number 3 because it is vague and ambiguous, and does not accurately summarize or state the terms of the document sought to be admitted. Without waiving said objections Defendant Stefano denies request Number 3. Defendant Stefano states that the 6 page Berwyn Police Department Official Sworn Police Report for Incident #16-12181, proffered as Document Number 3, and not labeled as any exhibit, identifies the “Location of the Offense” as occurring at “7111 W CERMAK RD Berwyn, IL 60402” and in the “Primary Narrative” section of the report it states, in relevant part, as follows: “I (Defendant Stefano) was dispatched to a retail theft at the Meijer’s Store located at 7111 Cermak Rd. While in route, further radio traffic indicated that the offender in the retail theft went into the Popeye’s Restaurant located at 6935 Cermak Rd. * * * I detained a subject later identified as Talmon Hegwood (DOB 3/14/1948) near the restaurant’s restroom.” (Emphasis added.). The 6 page report does not say James Tadrowski, (Tadrowski) Achille Chiappetta, (“Chiappetta) Edward Tovar, (*Tovar) William Messuci, (Massuci) Peter J. Podgorski, (Podgorski) Joseph R. Pesa (Pesa) and Armando Campos (Campos) arrested Hegwood and it does not say that Meijers, Inc. store security detained Hegwood with on scene officers including Stefano. 4. “OFFICIAL SWORN POLICE REPORT” which is a five (5) page document stating Meijer’s loss prevention agent Marcus Anderson “walked in” Berwyn Police Department on August 11, 2015 and handed Kevin Lorr “a packet of some pictures stapled to a receipt as well as a compact disk with footage of a retail theft of “items taken” from Defendant Meijer. RESPONSE: Defendant Stefano objects to Request to Admit Number 4 because it is vague and ambiguous, and does not accurately summarize or state the terms of the document sought to be admitted. Without waiving said objections, Defendant Stefano denies request Number 4. Defendant Stefano states that the 5 page Berwyn Police Department Official Sworn Police Report for Incident #15-07477, proffered as Document Number 4, and not labeled as any exhibit, was not created by him by states in the “Primary Narrative” section of the report, in relevant part, as follows: “In summary, while assigned to the desk I (Kevin Lorr) met with Marcus Anderson, a loss prevention agent for Meijer Marketplace, 7111 Cermak. Mr, Anderson handed me a packet of some pictures stapled to a receipt as well as compact dise with footage of a retail theft he related occurred on today’s date around 10:00 a.m.”. Respectfully submitted, Led R. Durkin Andrew Y. Acker andrew(@srd-law.com ARDC No. 6211620 Michael R. Durkin mdurkin2(@ard-law.com ARDC No. 6292753 Storino Ramello and Durkin 9501 W, Devon Ave., Suite 800 Rosemont, IL 60018 847-318-9500 CERTIFICATE OF SERVICE I, Christina Dimopoulos, a non-attorney, on oath states that I served DEFENDANT CASEY __STEFANO’S RESPONSE TO REQUEST FOR ADMISSIONS _OF GENUINENESS OF DOCUMENTS to the individuals whose appearances are on file for this matter along with a hard copy of the foregoing to: Talmon Hegwood, Jr., Pro Se 4642 S, Michigan, #358 Chicago, Iinois 60653 Talmon Hegwood, Jr., Pro Se #20170620227-D-2-D-2-N-44 Medical Unit P.O. Box 089002 Chicago, Illinois 60608 Talmon Hegwood, Jr., Pro Se #20170620227 RTU H-3 P.O. Box 089002 Chicago, Illinois 60608 Joseph C. Sheahan Cunningham Meyer & Vedrine, P.C. One E. Wacker Drive, Suite 2200 Chicago, IL 60601 jsheahan@cmvlaw.com by inserting a copy thereof in a stamped and properly addressed envelope via certified mailing and regular mail by depositing same in the U.S, mail box at 9501 W. Devon Avenue, Suite 800, Rosemont, Illinois 60018, on the May 16, 2018. /s/ Christina Dimopoulos Andrew Y. Acker andrew@)srd-law.com ARDC No. 6211620 Michael R. Durkin mdurkin2@ard-law.com ARDC No. 6292753 Storino Ramello and Durkin 9501 W. Devon Ave., Suite 800 Rosemont, IL 60018 847-318-9500 TN THE UNETEO STATES OLSTALCT couRT FORTHE NORTHERN DISTRICT CF -TLINOES FASTERN DINTSIDK TALMON HEGWOOCD JR., Plainti-e -versus- No. (1-w-C2€S( □□ oncrable GARY FEENERMAN MELISER INC. and CASEY STRFAHC Henerab Defendants Before me, the, undersigned Suse did personally appear □□□□□ TALIICN HEGWOCD, TR. Know urtte me, whd ficak bein duly Som, peor ehna re law, Upen his eath, did depose, and abahy. THEREBY CERTINN that T have queved atmwe cad cormect copy f pleaclin 44 styled? “MOTTON FOR TUDGMERT BY DEEMILT on Me. Andrew Y Acker Esc Mrs Amy Sean Thomeson, Fac Me Michael Duckin Bsc. Me SOdPhe, Sheshen, Eat Storing Rome |lo + Dur Kin n Meyer + Vedrink Attorieus «A= [cu Attery Hecht AAW Suite 2300 750( West Devon Ave Suite Goo One, East Wacker Dejwe vite 22 R ceemont TL toot & Cr fence, □□□ CeO) Honorable John R.Lousch, Ip Honorable Edwin Rieendeath States At ancy Chief Bxaccutive OO cex" Wepartmentt of Tustice Chicaoce Se Ss N ectheth Rea ot ot Whinolse Sse BO ee South Deateom Street ie sc Cinieago, TW ececd Chicaae. Tt 606s Placing some in Sealed enwelopes, l4 addressed ancl □□□□□□□ cam ae the as. Pestal Serrice pa Hae the A You of Jine, 2018 pall er Said date, 2018 “I. DECLARE under penalties of pecyeny) the cohove |S +e. WViritrd, 05-22-16 AMON leGweoocd, Ur, ' SOBSCREBED SOR, TO " =AL" before me, ehisthe day ef Mey soe, 3 Crees TYY\ 000) 4 Cp 2 Notary Public, State of Illinois GA! my Commission Expires 12/5/2018