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Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 1 of 46 PageID #:25

AO 106 (REV 4/10)


Affrdavit for Search
Warrant *tt$ffi 11l:Fr*;*ii'rdill:f f
OLTRT
sIoN
u ishp nrs D IvI
*n' c i" o n ir'"totb i il
No RTHE
"i*v' UNDER SEAL s*
'1
In the Matter of the
Search of:
Case Number: t 6l't 261
Room
The office located at
l2l North LaSalle'street'
described in
further
304, Chicago' "lt#t'
A-1
Attachment
A sEARcIr *ARRANT
AND AFFTDA,TT FoR
AppLrcATroN
or premises:
rorlowing propertv
I,stevenD.Nold.in,aSpecialAgentoftheFederalBureauoflnvestigation,requestasearchwarrantand
or perjurv rhat
I ;";j:
state under penarty "';: Tiff::::l:'"
District of lllinois'
located in the Northern """"r':"1;""O"*"t 1'O-'
evidence and instrumentalities'
under Fed' R' Crim' P' a1(c) is
search
The basis for the
to a violation of:
The search is related offense Description .nst the united.
---nit an offense agar
Cod,eSection' cac. 11,43
3?1' 666' 1343'
code, sections :"rH::1""J'.t-t::j,?ij*ffi|;'tT,6!H::H".-""jr:tlltl:
ritle 18, united states
ilffii?-p^Tnf E D iilH:":.l""iTi'"J"::l";*iffi.[;ff,il-xn;:l
MAY 2 ?2016 ::1""'i"""'TTff;:ffi;il;o'iio"
MAGISTRATE JUDGE
on the se facts:
Th"Y8ilN$idl.id,(tlea See Attached Affidavit'

attached sheet'
Continued on the
e
ApPti'cant's Signatur

my presence'
me and signed in
Sworn to before

Date: MaY 27' 2016


Illinois
City and State: Chicaeo'
.'.,.'* I
l"';Vt'?r: a;i l1:? tr1€!,
:

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 2 of 46 PageID #:26

)
STATE OF II']'INOIS )
SS

)
COUNTY OF COOK
AFFIDAVIT

I,STEVEND'NOLDIN'beingdulyswornorloath'stateasfollows:
I. PreLiminarv Matt'ers employed
Agent with the FBI and krave been
1-. I am a Special
bytheFBlsinceJune200E.InconnectionwithmyofficialFBl
duties,Ihaveexperienceinvestigat'ingviolationsoffederal
criminallaw,includingconspiracytocommiLanoffenseagainstt.he
UnitedSt,ates,inviolationofTiL}e].E,UnitedStatesCode,Section
371;briberyandgratuitiesconcerningprogramsreceivingfederal
funds,inviolat,ionofTitlelE,UnitedSt'atesCode,SecLion666i
wirefraud,inviolat'ionofTitlelB,UnitedstatesCode,SecLion
L343;honesLservicesfraud,inviolat'ionofTitlelB,UnitedSLates
to commit wire and honest
conspiracy and atLempt
code, section L346;

and conspiracy to
servicesfraud,inviolat.ionofTiqlels,Unit,edStatesCode,section commit
attempLed extortion
1349; and extortion' states code' secLion 1-95i
of ritre 18, uniLed
extortion, in vioration
(Lhe.subjectoffengeE,,).DuringmytenureasaSpecialAgentlhave
surveillance' as
in various tlrpes of electronic
also been involved

of criminal activities ' I have


wellasinthedebriefingofdefendants,witnesses,informantsand
others who have knowledge
participatedintheexecutionofmultiplefederalsearchwarrants.
2.Thisaffidavitismadeforthepurposeofestablishing
probablecauseinsupportofanapp}icationforawarranttosearch
locations (the 'subject Premises"):
the following
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 3 of 46 PageID #:27

SLreet ' Room


at l2l- North LaSalle
located
a ' The offices

S.I,IS, whickr ts further


3o4,Chicago,11}inois(trereinafter,*subjectlJocationl"l,which
office of A}derman DA}:{IEI,
is the City Ha'l A-''
in Attachment rslandAvenue'
described -.^_^A ar_ L64SsoutbrBlue

chicaso,,:,,*::";:::::"';:1'":;""ji"""""*211'whichis'uhe
Ward Regular Democratic
25t.|lWardofflcefoxAldermanDAI'IIEI,SoLlSand.ttrelocationof
25'n
Solis and the
Citizens forDanny
Otgar;:'zation'whichisfurt'herdescribedinAtLachmenLB-1;
c'Tberesidencelocatedats00southWellsStreet'Unit
C-1-;
described in Attachment'
522,Chicago'IIlinois(trereinafter'*Subiect!'ocation3rl'which
is further
g yesidence, which
is Sot,'S,
d ":'1 "*i:*:::':j':i":'#":'
t"'":::,
""'"*: solrs's
unir 812 East,
chicaso'
;;;r, solrs' s wire' and
residence used by solTs'
4rr1 , which
is a D-1;
described in Auractrment
]esated
son' which is further Tan and SPa'r
known as "CoPPer
e, The business
o"""*"' tn'""::j::*;" ff:::":';-i:t""
ar 1052 N. r^ilwaukee descrr;=;;*, (:rz)
further
trogsgien 5,,) , which is bearing rhe number
the
telephone
f. The cellular
by the
the system operated
2o8.0292,ln1ernationa}MobileSubscriberldentityNumber(..IMSI,,)
on
a cellular
'
840352309
telephone .'""*":
310410 to "Daniel
service provider Ar&r ' subscribed ::t'i-"11"'*i
SOITIS herer
used by DAI{IEL
IL 6A452' " arld F-1'
oak Forest,' ':,t^:^t'j
rsL
d.escribed in Attachment
vohich is ffurrher
Phone 2" ) '
j- lt''i:..a--:i:'.:.i.::-:.:-'',}-?-il*:"**i:{'-!
\
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 4 of 46 PageID #:28

3.Assetforthbelow'thereisprobablecausetobelievethat'
t'heSubjectPremisescontainevidenceandinstrumentalitiesof
Offenses' The statements in this
violaLions of the Subject
affid.avitarebasedonmypersonalknowledge,andoninformationl
havereceivedfromotherlawenforcementpersonnelandfrompersons
withknowled'geregardingre}evantfacts.Becausethisaffid.avitis
beingsubmittedforthelimitedpurposeofsecuringsearchwarrarrts,
Ihavenotinc}udedeachandeveryfactknowntomeconcerningt'his
investigation.IhaveSetforLhfactsthat,Ibelievearesufficient
to believe that evidence
and
Lo establish probable cause
instrumentalitiesofviolationsofLheSubjectoffensesarelocated
within the Sr:bject Premises'
4.Referenceismadetolawfullyrecordedconversationsinare
conversaLions
this affidavit' in certain instances' Lhese
summarizedandplacedincontext.MyundersLandingoftheseaided by the
(which often appears in brackets) is
conversations
contenLandcontextoftheconversations,myreviewofotherrecorded
a cooperating individual'
my
providedby
conversations, information
familiaritywiththefactsandcircumsLancesofthisinvestigation, with oLher
**-*y'.*perience as a 1aw enforcement off icer' my discussions
lawenforcementofficers,theexperienceofotherfawenforcement
agentsandofficersinthisinvestigation,andotherevidence
developed'duringthecourseoftheinvestigation.Thetimeslisted
fortherecordedConversationsareapproximate.Further,Summaries
oftherecordedconversationshereindonotrepresentfinalized
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 5 of 46 PageID #:29

that
not represent the enLire conversation
LranscriPts and maY

the identif ied individuals'


occurred between
rr' for the city of chicago' is the
derman

investisation beins conducte-^::":::


subject of an herein'
::::rtn"'.t:'
","i:"i:;,:i:;;;; cause
^= ::::
to ^::::_
believe that T;'"::':::
and others
SOLIS
have

there is reasonable in a series of


the Subject offenses by engaging
commitLed as a public
involve the abuse
of SOLIS's position
transactions trhat
official ' used his
SOLIS has agreed to use and
6. In particular'
positionasapublicofficialt.oobtainprivatebenefitsforhimself
l-951-' SOIJIS has received
of 1-8 U'S'C' S
and for others'
inviolation

take official action' in violation


aflowofprivatebenefitsfromindividualsforwhomsol,Isoffered
will likely
to take, has taken or Add'itionally' SOLIS has
L346' and t349'
of 18 U'S'C' SS L343'
solicited''accept'ed'andagreedtoaccepLprivatebenefitsand
campaigncontributionsintendingtobeinfluencedandrewardedin
connectionwithhisofficialacts,inviolationof].8U.S.C.s666.
7'rnthisparagraph'andinparagraphsBandg'ramoffering
myinLerpretationoftheevidencethatisfurtherdescribedinthe
SOLIS has agreed
to take
detailed below'
resL of this affidavit
' As
actioninhisofficialcapacityasanAldermanforprivatebenefit's
Specifically' a iooperating
MADIGAN'
directed to MICHAEL
individ.ualhasassistedabusinessman,Businessman].,inhisefforts

4
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 6 of 46 PageID #:30

tohavethezoningofapieceofpropertylocatedinChicagochanged
sothatahotelcouldbebuiltontheproperty'Sol,lsassuredthe
cooperatingindividualthat,inreturnforBusinessmanlretaining
MADIGAN,spersonallawfirmonLaxmatters,Businessmanlwould
receive'.anything,heneededinconnectionwiththehot'eldevelopment
project.AfterSOLlswasadvisedofBusinessmanl'sagreementto
hireMADIGAN,sfirm,SoLlSprovidedaletterofsupportforrezoning
ofthepropertytobeusedforthehoteldevelopmentproject,.See
pages 11 through 29 '
that SOI'IS has
8. There is reasonable cause to believe
receivedasteadyflowofpersonalbenefitsfromvariousindividuals
(ii) has offered to
for whom SOLrS (i) has taken official action'
to Lake official action in
take official action or (iii) is likel-y
the future, including the following:
a.ROBERToCALDEBo.'CALDEROhasProvidedSoLISwitha
stream of benefits, to incIiEE Viagra, "ti"ttglng for.prostitutionf rom
and.. securing campaigri contributions
services tor--JOlf'S,sweeping, in
relatives of Elgin a company . c{r,oeBo represented'
ordinance' In
from tie Citv's water
efforts to obtain an exemptidt, 'car,nrno in obt'aining t'he
return for these benef it.s, s;ii;lssisted
for Elgin sweeping'
i"qr.=t"a .".*ption
b. FREDERICK LArsJ{o' farm h?s p1?Y1*1^=o"IS with
so that- soLIS could hold a
}ArsKo-
the use of a multi-millionEorrat - ietsKo arso agreed to rease a dance
graduatio* p.tlv-i"i lll.""t'' -direction so soLIS could take economlc
studio prop"ily aL soLIS's;";;; business prttt.t=. t-91" for his
revenge on rri="'a;;;.;;
parthastakensfepstop"'"p-"="-"_"1!YordinancefavorableLo
has--participated in the approval
LATSKO,s business interestl,-Lnai'ATSKo'
of muftiple projects involving
g.Thereisreasonablecausetobelievethatsol,]shas
activelysolicitedmonetarycontributionsintelephonecalls,and
thesesolicitationshaverepeated}ycoincided.withSol,ls,spromises
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 7 of 46 PageID #:31

intheseverysamecallstotakeofficialactionbenefittingthe
the City'
contributors, who have official business with
has solicited monetary
a. For example' SOLIS and has expl-i:ltY-p-t-"m-ised that
contributions trom vIcTof REYES,arranged -uy nnvrs, solrs will steer
in return for monetary donati;;; pages 81 through 83- Moreover' a
Iegal business- to RElyns. see t"ifE.i" tf'"t, while such contributions
review of finan.itf-i"""ta"
arerepresenLed.tobec"mpaigncontributions,atLimesSoLlSuses
for his own personal use' including
fund.s derived fio*.l"trinlti-ons
ii..-p-Vtn""t of schoo] tuition for his son'
b.SoLISalsoagreedwithJUANGAYTANtoaccepLa give1 as'a reward for
qratuity from McHugh construttion that"was
SOl,lS, s official McHugh Constiuction in connection
aEts favoring"obtain
with the company's efforts o; to approval of a 500-room hotel
and data center project. ieptemnec ze, 20L4, two days after
-Cons"truction
wanLed to back SOLIS "big
GAYTAN totd soiis-t-f,at trtcHugh Lo the
Lime" because theywere tired'of onthe "B'S'" (that is' delays (i)
, and t.he very same day that GAYTAN
approvar or trrJlr'pr"i".t) McHugliconstruction think solrs
advised solfs that cAyrAN *""rJ*"ke
was help1ng out McHugh Corrstr',rcil"., "alf
the way" concerning their
tavraN to teII a iepresentative from
projecr, and. iiii-idl,rs rg1_d be preoared to calI a special
McHugh construciion t.hat soLIS would ConJtrrction made a $1,500
meeLing ao ,pilo""-tir" proieci, McHugh-
contribution Lo c:-ti'"t'" f or Danny Solis '
SOLIS assisLed Elgin Sweeping:1'"" "-t!t^11:
to obtain
c- required Elgin
an exemption from a water otairrri"e that *oitta have
of revenue to the Elgin city of
sweeping to pay a sig_nificr;-rrnorrrrt he t'old
this assisLance, president of
chicago. Aftir soLIS rerra"rea ieioEao' th"t he hoped the
sweeping's represent-a-tive, SOLIS's aslisLance' and then
Elgin Sweeping would "remember" from the president of
discussed how much money caidrnO *orfa raise
ElginSweepingandhistamiryme*r-u.q:,SolIssubsequentlyreceived
a $5,400 conL-ribution from the family's real estate
company'

]-0.ThereisreasonablecausetobelievethattheSubject
Premiseswillcontainevidenceconcerningthecommissionofthe
By way of examPle,
Subject Offenses' See pages 1l-6 through 131'
thereisreasonablecausetobelievethaL(i)Subjectl,ocationl,
relating: to
SoLIS,s office at City HaII, wiII contain documents
development projecls where soLIS has taken
official action in retufn
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 8 of 46 PageID #:32

25th
(ii) subject l,ocation 2, S.LIS,g
benefits;
for illicit private
details of money
Wardconstituentoffice,wi}}containrecordsrelatingtomonetary
including
by soLIS'
conLributions solicited and the timing
and receipt
of contributors'
received, the ibentity
which will constitute
ofsucttcontributions,aswe}lasrecordsofexpensesincurredby
Organization'
Democratic
the 25th Ward Regular expenditures as opposed to
'ssible
permlsbr"-",
proof of whaL are -,.,1i.
his .,"rsona1
personal expenses; (iii)
expens
by SoLIS to satisfy of his
expenditures made will conLain records
aesidence,
Subject l,ocatsion 3, soLIS,g

persona}expenditures,whichwouldconstituteevidencethatsol,Is
hasnotpaidforbenefitslavishedonhimbyoLhersandthaLhehas
a used by
usedfundsfromLhe25t'hWardRegu}arDemocraLicorganizationtopay
residence
4'
expenses; (iv) Subject' Loeation
for such
Solls,hiswife,,andhisSofl,willalsoconLainrecordsofhis
personalexpendiLures,whichwouldconstiLuLeevid.encethaLsolls
hasnotpaidforpersonalbenefitsandthathehasusedfundsfrom,
theZs.nWardRegularDemocraticorgantzationtopayforsuch
expenses;(v)Sulrjeci,I,ocaLion5,amassagepar}orwhereSoI,IS
and other
receivedprostitutionservicesforwhichCAIJDERomayhavepaid,will
prostitution
for Lhe
contain records
relating to pa)rmenLs
servicesreceivedbySoT'IS;and(vi)TargetPhone2'SoLIs'sce]Iular
telephone,wil}containevidenceconcerningSol,Is,suseofthe
facilityandcommunicationwithothersconcerningtheSubject
offenses '
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 9 of 46 PageID #:33

Probabl-e Cause
III. FacLs Establishinq the CiLy of Chicago is a
records'
l-l-' According to public
municipalcorporationandmunicipalsubdivisionoftheStateof the City
website www'USAspending'9oV'
Illinois' According Lo the fiscal years 2014 and
federal funds in
than $10' 000 in
received more
which
'otu' branch is the cit'y council'
The city's legislative
"'
iscomprisedofapproximatelyfift.yaldermen,eachofwhom
representsonelegislativedistrictoT..ward.,,Aldermenare
compensatedandpublicly-elected.TheCityCouncilhasthe rerated
ordinances and resorutions
policy and pass
auL'rority to set
totheresponsibilitiesofCit,ygovernment,includingapproving
zoning regulaLions'
13.Aldermenareassist'edintheirofficialduLiesbystaff
are paid City employees '
members, lvkro
wiLhin City HaIl' which is located
offices
L4' Aldermen have as well as offices within
I-'aSaIle Street in Chicago'
aL L2LNort'h
their wards' --^^ naNrET:
DANII sot,rs is the Alderman
According to
public records '
1-5 '

forthe25.nWardandamemberofChicago,gCitYCouncil.Information(including official
course of Lhis investigation
Lhe
gathered during

of the City Council's ZottLng'


correspondencefromsol,IsandaconsensualrecordingofSol,ls)
is t'he Chairman of
reflects that SOLIS The responsibilities
t euirding standards commiLtee-
T,andmarks

8
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 10 of 46 PageID #:34

thiscommitteeincludeapprovingchangesLothezoningofrea}
l'"r"::1 *;::= rnrerests riled
with the
:il:#'":"',"r::cia, SoIJIs answered \no/ to the
2oL5'
abouL May 1-2 '
Cit.y of Chicago on or
.question,*ln2014,didyoureceivefromanyperson(otherthan
more gifts having an
one oT
or a domestic partner)
relatives In his Statement of Economic
in excess of $250?"
aggregate value
20L5 '
on or about May '
1-
C1erk
filed with the Cook County *"^:tt*: "T'ist
Irrterests to Lhe fol}"*t:n
*N/A" in response
solrs answered a gift or gifts' or honorarium
entit'y from which in excess of $500'
the names of anY in tnt.ln-n:egate
singly or
or honoraria' valued calendar yea:r '"
the preceding
was received during
lT.InhisstatementofFinancia}Interestsfiledwiththe sn6/ to th€
S.LIS answered
on or about May 2, 20L6,
City of Chicago

followingquestion:..In20l.5,didyoureceivefromanyperson(other
thanrelativesoradomesticpartner)oneormoregiftshavingan
abouL May 2 ,
20L6,
Clerk on or
agg?egaLevalueinexcessof$250?,l51hissLatement,ofEconomic
with the Cook CounLy
Interests filed
SOT,ISanswered*N/A"inresponsetothefollowingguestion:"T'isL
thenamesofanyenLit,yfromwhichagifuorgifts,orhonorarium
orhonoraria,valuedsinglyorinLheaggregaLeinexcesgqf$500,
calendar yeaT '"
was received
during Lhe preceding
maY be filed
lE.Accordingtopubliclyavailableinformation,aStatementonline
City of Chicago
of FinancialInteresL for the
orin-person;CookCountyStatementsofFinanciallnterestarefiled

I
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 11 of 46 PageID #:35

City and Cook County Statements


online. Based on a review of SOLIS's
to have been filed
of Financial Interest' they appear
electronicallY '

pto*is" io Take of f icial- Action


A.sotls,sEffortstoobtainPrivateBusinessfortheBenefitsof
MADIeAlr, and soLIS's r11;."it
in Retsur" ;;t Business Steered to !{ADTGA}iI'
individual ("CS-1")
L9- In or around May 2Ol:4' a cooperating
began providing information to
the FBI ' CS-l- has historica]
involvementinavarietyofrealestateinvestmentanddevelopment
projectsintheChicagoarea'andasaresultofthisactivityhas
had contact wit'h soLIS '
20.CS-].hasbeenadvisedthatCs-lwillbechargedforhis
part,icipat,ioninafraudu}entschemet'hat,includedCS-l,smaterial
falserepresent,ationstoafinancialinstitutionandpurchasersof
realproperty,andmisappropriationoffundsobtainedfrom
purchasersthroughfalserepresenLationsmadebyCS-1..onMay1,
2oL4,CS-].receivedaprofferletterfromtheU.S'Attorney,soffice.
CS-liscooperatinginhopesofreceivingareducedsenLencein
connectionwiththisfuturecharge.WhileCs-lunderstandst,he
Unit'ed.Statesmayrecommend.toCS-l,ssentencingjudgeareduced
promises have been made to cs-1 as
to
sentence on these charges, no
whatCs-].,ssentencewillbeorwhatrecommendationtheUnitedStates
willmakeatsentencing.cs-l,whowasthed'irectorofafinancia}
institution,wasinvestigated.byt'heFDlCforallegedstructuring
ofcashdepositsatafinancialinstitutionovertheCourseof
severalyears.CivilchargesseekinghisremovalandprohibiLion

10
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 12 of 46 PageID #:36

induslry were not brought due to evidentiary


from the banking
ConcernsandstaLuteof}imitationsissues.Cs-lhaspreviously
providedinformationtolawenforcemenLandhasbeendeterminedto this
provided by Cs-1 in connection with
be reliable' lnformation
invest,igationhasbeencorroboratedbytheinformationprovidedin
thisaffidavit,includingtheconsensualrecordingsreferenced
herein -
the FBI that CS-1
ad'vised'
2a- In or around May 2014' CS-l-

represenLedBusinessmanL,aChinesebusinessmanandproperty
developer,inhiseffortstohavethezoningofapieceoflandlocated
(the "Hotel Property") '
aL 2O2OSouth Arckrer in Chicago' Illinois
changedsothatahotelcouldbebuiltontheHotelProperty.,
in or aroundMay 20i,4 and June 2OL4' CS-l-
22' When interviewed
sLatedthatapproximatelytwotoLhreemonthsearlier,Cs-1hadmet,
withsoI,lsinanat'tempttoobtainaletterofsupportfromsol,ls
forackrangeinthezoningoft.heHote}Propert.y.CS-lreportedthat,
afterthismeet'ing,CS-lbelievedthatsoI,lswould.providealetter
ofsupportforthezoningchange.Sol,lshadspecifiedt,hathewould
support'therezoningiftwoconditionsweremet:(1)Lheparcelof
landadjacent't.otheHotelPropertywasnotusedtobuildanother
order to finance ttre construction of !h'
c s - l- e xp 1 al ne_d _t-Y: *t rr " t r rand
^^'in ""Jff ; " ?sJ"t"=l e aJ
:s
that
tja!
if"- T:"-1q,ii,l"
these proce!. u,
hotel,Busines"*'"Iipil'*"q':.J"rr"??-iea1'"=t'"t"abroadandthen
Tr'" a roan
send the p'otttiS' ti et'"i"t="*''iiu'tlia--itt"*p-t
unit'ed- to take outfor'the
were not "'=t'"'J'i' advised t*n"t et-r"i"t="*'-"
i planned
with a u.s' banr]"-l'--]- Uusinessmen traveling-trom
hotel to cater' i" p"tt'' to !?uri"#"""a
tnJ'+i"""a gl""iruction of the
abroad. atto=a'#;t'"'r and peopre rn
hoter would h"'J;:;itiLta
it tr't=*J'J*5t'i:"t currencv
-u'"r19''i"'
commerce.

11
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 13 of 46 PageID #:37

hotel,and\2)BusinessmanlprovidedletLersofsupportfromthe
communitysupportingtheproposedrezoning.However,Cs_lstated
thatafterthemeeting'SOLISdidnot-"o**:"tat'ewithCS-labout 1 believed
the proposed zoning change ' CS-
to support
soLIS, s decision
avoid CS-l- ' CS-1- stated that
SOLIS was purposely trying to
approximate}ytwotothreeweeksear}ier(withintheApril20l4to
donaLe $2'500 to soLIS at this
May2oL4timeframe),CS-]-attendedafundraiserforSoLlS.
that cs-1
BuSinessman 1 reguested and CS-1 did so'
eccording
1's behalf'
fundraiser on Businessman

toCS-l.,sol,lsbegancommunicatingwithCs-lagainafLerthe
donation.' letLers r of supPort
that cs-L providedmultiple
23 ' cs-1- suated

LoSol,lsconcerningt,herezoningoftheHotelPropertyfromvarious
met with
"""":"-:"":: "r':::r""":-. on or abour Jurv 2 ., 2oL4' cs-r

soLISat'Subjectl,ocation1.regardingtheproposedzoningchangefor
thieHotelProperLy.AlsopresentwereBusinessmanl;alegislirtive
representing
fot SOLIS; and an atLorney
aide and' scheduler
BusinessmanlinconnectionwiththerezoningofthepropertY.This

of the letters of support from the


meetingwasnotrecorded.Cs-ladvisedthatduringthismeeting,
SOT,IS stated
that he wanted a]-l
communityinfavorofttrezoningchange,andthattwoletterswere.
missing:onefromtheChinatownChamberofCommerceandanotherfrom
4 :d of Erect'ions;t"";;*"-jr?i:L:t"?
:;il;""v
t,=-ri=ii'1p"igt*"""=*it."*X;:rq",:,'.'g:iffi
1
:::::l:::i ?1?il';;=-inessman '

72
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 14 of 46 PageID #:38

theChineseAmericanServiceLeague.Cs-lad.visedSo],fsthatLhese
the coming days '
letters would be provided in
advised' that' SOLIS had told CS-1 that the most
25. CS-1
importantletterofsupporLtoreceivewasfromtheChinatownChamber the
CS-1 provided an email that CS-1 received from
of Commerce'
ChinatownChamberofCommercet,hatreflectedthatso],lswassenta
letterofsupportfromtheChinatownChamberofCommerceonAugust
L,201-4'CS-1a}soreceivedanelectroniccopyofthisletteron to law
L, 2OL4' and has provided" a copy of this letter
August
American
CS-1 advised that CS-L received the Chinese
enforcemenL '
letter of support on August 8' 2oL4' and then
service r,eague,s
immed'iatelyforwardedthislettertotheattorneyrepresenting
Businessman 1'
law enforcement that' on or about August 5'
26. CS-1 advised'
2ol4,CS-lreceived.atelephonecallfromsol,Is,slegislativeaide.
Atthetimethiscallwasreceived,recordsmaintainedbyt.heCit,y
ofChicagoreflectt,hatanapplicat'ionforanamendmentLothe
Chicagozoningordinancetoallowtheconstructionofthehotelhad as
The aide instructed CS-1 to call SOLIS as soon
been filed'
possible.CS-ladvisedt,hatheplacedareturncalltoSol,Is.This
callwasnoLrecorded',Duringt,hiscall,soLISaskedcS-1ifCS-]- was '
responded that CS-]- knew who
MADIGAN
knew who I4ADIGAN was ' CS-1
with SOLIS
CS-l- had been instructed
not Lo have unrecorded contact
irst consulLinq *'"'i"Jr*."k;d a; call back solrs as !3;i
withouL ffirst. consurtang -1*{J-'1i'*t::;"'STi"ff:3i'?; "" soon

::'JiJl,"s,!i;i.T;sffi i=":1.!1i"*-"3i5'"3#:'?;#;;;-t-r',"eta.,*"''
*iSifrt not Providehis support '

13
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 15 of 46 PageID #:39

SOLIS stated that he (SOLIS) wanted to arrange a meeting bet.ween CS-1,


Businessman 1, MADIGAN and himself. CS-1 agreed and stated CS-1
would have to translate for Businessman 1 because Businessman 1 did
not speak English. SOLIS told CS-1 t.hat he (SOLIS) would contact
CS-1 j-n a couple of days to arrange the meeting. SOLIS did not specify

what the purpose of the meeting was.


27. On or about August 5, 201-4, CS-1 received an emaiL from
SOLIS's legislative aide that was addressed to CS-1, s ,.Gmail,,
account. n CS-1 provided a copy of the email to l-aw enforcement. The
aide sent the email froma Cityof Chicago email account. The subject
of the email was: "Meeting w/A1derman Daniel Solis & Speaker-
Madigan." The aide wrote: "Dear tCS-l-1 , The Alderman has asked me
to schedule a meeting with yourself, lBusinessman 1] and Speaker
Michael Madigan. Please let me know asap what. your availability is
Iike for August 18th, 19th, 2l-st and 22nd, after 11:00 a.m.,, No
explanation was provided in the email as to the purpose of the meeting.
Furt.hermore, CS-1 advised 1aw enforcemenL that he had not been
advised as to the purpose of the meeting with SOLIS and MADIGAN. In
a follow-up email sent by the aide l-ater that day, she advised the
meet.ing would Lake place on AugusL 18, 20L4, and specified the

Gmail is an email- service offered by Google. A representative of


Google, Inc. who routinely addresses law enforcement requesls for
information concerning Google's operations is not familiar wit.h the
existence of any communications infrastrucLure operated by Google
wit.hin the State of Ill-inois for the period from August 1, 2Ol4 to
September 22, 2014. Accordingfy, J have reason Lo believe that the
delivery of the email to CS-L (who is located within ll_l_inois) via
CS-1's Gmail account reguired the use of t.he channels of interstate
commerce. Based on this, I believe SOLIS caused the use of t.he
channels of int.erstate commerce in order Lo carry out this offense.

L4
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 16 of 46 PageID #:40

location of the meeting, which was 30 North Lasalle Street'


Room 3906 '

that is
A.review of publicly available information reflects
MADIGAN

apartnerinMadigan&Getzendanner,alawfirmthatmaintainsan
office at this location'
i.CongenguallyRecordedMeetingBet'weencs-1,solls,
MLDIGAfit and OEhers '
28.OnAugust18,2oL4'atapproximatelyll-:57d'Irl''CS-l
Iaw firm
attended a meeting within a conference room at MADIGAN',S
of this
office. cs-1 made a consensual vid.eo and audio recording
meeting. Initially, the foltowing ind'ividuals were present at the
meeting:CS-l-,BusinessmanL'MADIGAN'andMADIGAN'slawfirm
partner.
29.Duringthemeeting,CS-lexplainedthatBusinessmanlwas
..trying to d.o a hot.el in Chinatown right now." MADTGAN replied:
..Good,good.,,CS-]-actedasaLranslatorforBusinessmanlduring
and his 1aw firm
the conversation. cs-1 further explained to MADIGAN
parLner that Businessman 1 was a big developer in
china' and explained

that Businessman 1 owned two hotels in China'


SO."Jher$af-tgr,SOLIS'andanothertwoind'ividualsonSOLIS's
.jF*: -_...;.:...: -.
alEiii*L* -+
staf f jbtt#-t-ffe. me<lt'ing
3l.Duringthemeeting,CS-lexplainedthat,Businessmanlsaw
and that
an opporLunit,y because t'rea1 esLate" was "bouncing back"'
Businessman 1 ..wants to do the hotel in chinaLown.,' cs-1 explained
Lhat'Businessmanl-was.lookingformore''opportunityinfuLure
[businessopportunities]""MADIGANreplied:"Good'Very
was a lot of
good, very good"' and expressed his belief thaL there

15
l$-:,:-_..: ...-_ - -i, }.i-.r>J11;--.

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 17 of 46 PageID #:41

Chineseinvestmentcomingint'otheUnited"States.CS.l-thereafLer
inLerest in a reaL
project and Businessman l's
discussed a commercial
in the Chinatown community'
estate d'evelopment project
MADIGAN said': "WeII' our interest
32. Shortly thereafter'
buirdings rike that on the real estaLe
wourd be that we represent
f ew hotels ' And''
uh' we have a little
And we do qr:ite a
Laxes. -
differentapproachtorepresentationonhotelsthantheotherlaw
MADIGAN said that his partner could
f irms that do the work ""
provid.eanexplanation.Thereafter,MADIGAN,sparLnerexplained
firm's representation of hotels on tax matters '
the law 1]
explained that "the hotel that he's [Businessman
33 ' CS-l-

proposinginChinaLown,ibabouL6milliondollars,hopefullyweget
supportfromtheAldermanISoLTS]Loget,thezoningchange,,,andthen
askedhowrm:chtaxt,hishot,elwouldbesubjectLoandhowmuchin
taxescouldbesavedbyhiringagoodlawfirm.IunderstandCS-]-
tobetellingthoseinthemeeting,includingsol,ls,thatazoning
changewasrequiredforthehot'elprojecttogoforward.Basedon
theinformationprovidedbyCS-1'a-zoningchangewasrequiredt'o
project'
carry out the hotel development
34.MADIGAN,spartnerthendiscussedthepotentialtaxesowed
fromtheoperationofLhehotel,andthendepartedt,heroomtoget'
materialstrhat.wouldassisthiminca}culatingpotentia}taxeson
t.he hoLel ' cs-1 said:
MADIGAN',s parLner departed the room'
35 ' As
to meet' uh'
he just want Lo use this opporLunity
$ [Businessman 11,

16
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 18 of 46 PageID #:42

Mr. Madigan and Alderman, and he is very interested in the Chinatown


parking lots projecL." CS-1 showed SOLIS and MADIGAN a site map of
a proposed commercial development project in the Chinatown area,
which was distinct and separate from the HoteI Property that CS-1
was attempting to have rezoned. MADIGAN asked for the
identificat.ion of various landmarks on the site map. CS-1 said that
Businessman 1 "wants to
if there is any opportunity, uh, he can
know
work with t.he State and the City to, to get a nice project,uh,
commercial project in Chinatown." SOLIS responded: "Okay." CS-1
noLed that Businessman t had a l-ot of resources in China to back him
up. MADIGAN replied: " SOLIS explained to MADIGAN
"Uh-hmm, uh-hmm.
the relationship of the property in question to a larger development
project.. SOLIS also explained to MADIGAN that the plan with t.he
parking project was to "replace the parking and add t.o it," and to
build "both residential and commercial on it [the propertyJ ." SOL]S
noted that "it's lthe real estate] gonna be open to proposals
.," and MADIGAN responded: "Uh-hmm, uh*hmm, uh-hmm, okay."
MADIGANasked: "Is this owned by the SLaLe?" I understand MADIGAN
to be asking whether certain property involved in the potential
parking 1ot project was owned by the State of Il1inois. SOLIS

replied: "The parking lot yes. " MADIGAN then asked abouL a parcel
of "vacant 1and." SOLIS explained there was a small parcel "east
of the CTA" that was "owned by the City. " Thereafter, MADfGAN, SOLIS
and SOLIS's sLaff member discussed who owned the propert.y involved
in the potential parking lot transaction.

t7
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 19 of 46 PageID #:43

what the timing would be for Businessman I to


36 - CS-I asked'
presenLaproposalforthedevelopmentofthelandinquestion:
he do something' do a
..What,s the right, the right timing' can
it'
now, and submit it to the City?' SoLfS explained that
proposal
was'.stillearlystages,"butthatifBusinessmanlhadaproposal CS-1
it wouldn't be an official "
"he should bring it up' but
said: "Okay'" MADIGAN added: "Okay'"
who had by this t.ime returned to
37 . Then, MADIGAN's Partner'
the taxes thaL would be
theconferenceroom'continuedtodiscuss
Ievied on the hotel '
asked what the charge would be for hiring MADIGAN's
38. CS-I
of
partner explained t'hat' the fee would be 12 \f 2e'
f irm. MADIGAN's

anytaxsavingsgeneratedbythefirm,orafixedfeeofapproximately
$3,000to$3,500ayear'SOT'ISadded:"ThereisnobetterfirmLhan
in terms of doing rear estate Laxes in the state'"
this firm
1] wanLs to know'
39. CS-1 said: "First of all' lBusinessman
any, uhm, cause he' he' he's in business ' He's in Chicago'
there's
Any other opportunities open' like' like'
he wants to do business'
maybeforhim?'CS-lsuggested"realestatedeals'd[Ydeals'"
were a lot of opportunities
in chinatown'
solrs replied thaL there
$And. uhm, I t'hink that there's'
just general growt'h
SOLIS added:
acrosstheCity,uhm,Icanseethatinmycommitteerightnow,aS
ChairmanofZoning,andlcanseeit,ifyougolookoutinLerms
ofthenumberofcranest,hatareworking,solwouldbehappyt,osit
down and talk'"

18
t4::?:al-+ -a_.+ ' !-_-:*:*:ii":,"iii.j: .

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 20 of 46 PageID #:44

of the
40. MADIGAN Lhereafter asked about the "status
representationofthishoLelwe,retalkingabout.,,MADIGANasked
BusineSSman 1 was "committed', to other people"', and cs-1
whether
replied:..Notyel.,,MADIGANconfirmedthathisfirmwas..under
consideration.,,MADIGANthendiscussedoptionsConcerningthefee
MADIGAN added': "We're not
interested in a
payment structure'
quickkillinghere.We,reinterestedinalong-termrelationship.,,
MADIGANthereafterindicaLe,dhisbeliefthathisfirmprovided
qual it.Y representation
the conclusion of the
4L. The meeting then concluded' At
meeting,soLISasked.MADIGANifhehad.'acoupleofminutes,,.and
MADIGANreplied:.'Ohyeah,sure.,,AfterCS-].tookphotographsof
BusinessmanlposingwithsoI,lsand'NIADIGAN,SoLISbegantelling
MADIGANthat'hehadfound,avideoofameeting..we,,had.cs-lasked
So],IsifCs-landBusinessman]-should.'waitoutside,,forSoLIS.
sollsresponded:'.Yeah.,,MADIGANtold'CS-landBusinessman]-:"If
youcouldwait,whYdon'tyouwaitinhere'"MADIGANthendirect'ed
Cs-landBusinessmanlt'oanoLherroomintheoffice.Sollsand
Busi-nessman 1 approximatery four
minutes
MADTGAN rejoined cs-1 and
Businessman 1 out of the
later. MADIGAN escorted SoLIS,, CS-1 and
office.SoLIS,CS-]-andBusinessmanldepartedtheofficetogether.
42.Immediatelyafterleavingtheofficespace,CS-tsaidto
]-l ' that' uh' I' he' he
SOLIS: "Ald'erman, uh' you know [Businessrnan
Ioveto,uh,uh,givethebusinessto'llh'Mr'speaker'butyouknow'
like,withoutyoursupport'thathotel'youknow'zoningchangeis

19
,.I te::an!-?.,.:, I - + :zi+ : Lrrr. !...tt
i

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 21 of 46 PageID #:45

verycritical-,youknowlike'without'wehavetogothroughzoning
change-'SOLISreplied:"Welfifheworkswit'htheSpeaker'he
witlgetanythingheneedsforthathote}.,,IunderstandSoLISto
betellingCS-l.t,hatifgusinessmanlhiresMADIGANashisprivate
attorneyforfuturetaxmatLersrelatingtotheplannedhotel,solls
wi]-Itakeanyofficialactionneed'edtobenefitBusinessmanlwith
respecttotheproposedhotel,inc}udingbutnotlimit'edtoSo],IS,s
officialsupport.astheChairmanoftheCityCouncil,sZoning,
Landmarks&BuildingstandardsCommitteeofar,yzotLLngchangefor
the hotel will be built on' CS-l replied: "Okay' thank
Lhe land
you."Sol,ISadded:*And'he'sgoingtobenefitfrombeingwiththe
Speaker'okay?'CS-l-thankedSOLIS'IunderstandSOLIStomean
thatbyhiringMADIGAN,sprivatefirm,Businessmarrlwouldensure
t,hatSoI,ISandMADIGANwou}dtakeofficialactionbenefitt,ing
as public officials '
Businessman 1 in their capacity
being promised by SOLIS t'hat Businessman l- would
43. Af ter
receive"anything"heneededforthehotelinreturnforhiring
MADIGAN,CS-ltoldSOI,ISwithreSpeCLLoa'.furrdraiseronthe4L]n,,u
Businessmanlhad..sentinmoneyt'obeavicechair,,,andthatCS-].
fundraiser"' SOLIS replied: "Thank
would "go on his behalf to the
CS-1 added: "He wanLs to
do
okay' very good' very good'"
you

SOLIS sch-eduled a fundraiser for


CS-1 advisea taw enforcement--t},at and consensually
september to, zo'i. cs-1 .ar"rriJa"a"tii""tr-rtaiaiser
i..Iiai:"r"", instruction of law
arr-el;rJ;
reLorded rris
.,, i o,.. *"nt . "Jgrr"
t ;jffi i;;-'-1{
".-the
1 3"fli"J'"e r-3 ;i'"'.'t* :i :
t
;+it "i
:m :l n:t:t JI'P-1"*i=';;$:1,^i'lJ ;.;t"
iE
""
a i t'" t a= a i s e r b e i ns
""
on the 4th.

20
- _=:. 'i?1-:.ii-l i--.
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 22 of 46 PageID #:46

"So do I ' so do 1"' Shortly


iL long term. " SOLIS replied:

thereafter,CS-1said:'\Hopefully,hecanbreakgroundthisyear.,,
begin
believe CS-1 expressed hope Lhat Businessman 1 could
tf
buildingthehotelthisyear.lSol,lsreplied:..Yeah'Iwilldo
process and. get everything he needs
whatever r can to speed up the
uh, breaking ground' alright?" [I understand SOLIS to
to begin,
meanthathewould.takewhateverofficialactionhewasabletoensure
thatConstructionofthehotelcouldbeginpromptly.JsoI,lsadded:
is that
..This is important. Very important "' [My understanding
sollsind.icatedthatitwas..veryimportant,,forBusinessmanlto
hireMADIGANLoensureofficialactionwouldbetakenforBusinessman
yes ' Yes ' So I will make sure
l, s benefit. I CS-l- replied: "okay'
[BusinesSman].]wi}lgivehimthebusiness.,,SoLlsreplied:..Good.
Good. "
the Retention of
ii. CS-L Contactg SOLIS to Discuss
MADIGAII's T'aw Firm'
l- : l-5 P'ffi' ' CS - I
44 . on August ' 2L 2OL4
' at approximately
placedacal]-toSoT,IS.Thiscallwaslawfullyrecorded.Duringthis
advised SOLIS that Businessman l- had agreed to hire
call, CS-1
Specifically' CS-l- told SOLIS that
Businessman
MADTGAN's law firm'

].hadtoldCS-ltocallsol,Isandthanksol,Isforarrangingameeting
h€
MADIGAN ' CS-1- added: "And also '
f or Businessman l- with

[Businessmanl]has,hehasdecided'touh,use,uhhisn.{ADIGAN,s]
tax service ' CS-1 asked if he should
law firm for his ' "'
contactMADIGANorhispartner.SoLIStoldCs-1:t.YoucancontacL
him,uhm,dh,andl'llcallhimtoo'andlethimknowyouwillbe

2l
;? :;': ,:I r''?'*tr''-'
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 23 of 46 PageID #:47

it's a long term


calling him"' CS-l- explained' that "because

relaLionship,\1h,probablylBusinessmanl]wanLtodoitwithhim like
Iike' uh' uh' uh' like' engagement' something
like a mult'i-year
replied: "Good' good' good'" CS-l- then said
that . .,, SoLIS

thatBusinessman]-had,remindedCs-]-aboutSoT,lS,S'.letterofsupport
forhiszoningchange,becausethezoningchangeiscominguponLhe
CS-1 asked: "Can he
get the letter from you before
Septembe T 4"' and
to call- his legislative aide
and
date?' SOT'IS told CS-1
that.
''tellhertogetitready.,,SoI,lsthenaskedCs-ltolocate..anybody
elseinthenetworkofpeopleyouknowthatuhm'wouldliketo
participateinmy,uhm,fundraisingeventseptemberl0,letmeknow.,,
Cs-]-agreedtolookformorepeople..tosupportthisevertL.,,I
believethatsol,Iswasattemptingtofurt,herusehisagreemenlto
provideafetterofsupportaSameansofextortingad'ditional
iinancial benefits from CS-l-'
iii.?:r,r?#?:t:i"r_x jr"."'.if.,i,H-"8!!:1ij,};33:t"tfl :
at a Zoning
zoning ctrange for ttre ro'J"i"ptoperty
E"rn*iEt'"e Hearing'
45'fnconnectionwiththisinvestigation'CS-l-hasprovided
the zoning
with email correspondence concerning
law enforcement
On or about August' 2L' 2Ol4' arl
change for the Hotel
Property'
aLtorneyforBusinessmanlsentanemailtoSoI,ls,s}egislativeaide,
forwardinganapplicatl.onforanamendmentoftheChicagozoning
rezone the Hotel Property'
ordinance uhat sought Lo

22
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 24 of 46 PageID #:48

46 . or about Friday, August 22, 201-4, the aide replied to


On

this email: "Please prepare a draft, of the Ietter of support from


the Alderman."
47 . On or about August 29, 2014, CS-1 provided law enforcement
with a copy of an email he had received from SOLIS's aide via CS-1's
Gmail account. Attached to the emaiL was a signed letter of support
from SOLIS, supporting the requested zoning change to Lhe Hotel
Property. Specifically, the letter, which was on SOLIS's official
City Council letterhead, was dated August 26, 20L4, and addressed
to Patti Scudiero, Lhe Zoning Administrator, Bureau of Planning and
Zoning. The letler carried a subject line referring to the Hotel
Propert.y, and provided as follows:
I am writing to pledge my support for the zoning
change of the aforementioned address.
The applicant proposes to develop the
subject property to a new multi-storey [sic]
building consisting of a hotel with retail and
offices on the ground floor. To accomplish
this, Lhe applicant will reguire a zoning
change from a current C3-3 Commercial,
Manufacturing and Emplolrment Zoning to a C3-5
Commercial, Manufact,uring and Employment
Zoni'ng District.
Pl-ease feel free to contact [name redacted] ,
Legislative Aide and Scheduler, at my office on
(773) 744-6845 if you have any questions or
require further information. Thank you for
your time and attention.
RespectfuIly,
/s/ oanlel Solis
Daniel Solis
Alderman, 25thr Ward

oo
LN
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 25 of 46 PageID #:49

Chairman, Committee on Zoning, Landmarks and


Building Standards
48. CS-1 attended a hearing held by the City Council,s
Committee on Zoning, Landmarks and Building Standards in or around
september 20L4. cs-1 consensually recorded the hearing. sol,rs
presided. over the hearing. During the hearing, Busj-nessman 1,s
attorney presented the proposed change to the zoning of the Hotel
Property, and asked for support of the proposed change. sol,rs
replied: "I do give my support. I do give my support.,, SOLIS
exprained Lhat he was giving his support because t.he poputation in
chinatown was "exploding" and there was a need for a prace where
Chinese could feer "comfortable" within walking distance of
Chinat.own. solrs noted another committee member supported the
zoning change, and during his remarks, sol,rs also asked for the
support of the rest of the committee for the proposed zoning change.
During his remarks at the hearing, sol,rs did not reference his
promise to give cs-l- "anything" he needed for the hotel in return
for business steered to MADTGAN. The committee approved the
proposed change to the zoning of the Hotel property.
49 - fn September 201_4, CS-1- placed additional
consensually-recorded cal]s t.o IvIADTGAN at MADTGAN, s 1aw f irm. For
example, on September 1-5, 2014, at approximat,ely 10:12 a.m., CS-l-
placed an outgoing calr to MADTGAN; who was using t.elephone number
(773) 581-8000. Based on publicly available information, (773)
581-8000 is the telephone number for I4ADIGAN's fllinois General
Assembry District office. During the call-, cs-1- spoke to MADTGAN

24
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 26 of 46 PageID #:50

about arranging a time Lo meet with MADIGAN abouL the retention of


MADIGAN's firm. Specifically, CS-l- advised MADIGAN that
Businessman l wanted CS-1 to meet with MADIGAN to "go over the
contract," which I understand to refer to the agreement to retain
MADIGAN's firm. MADIGAN replied that CS-l had called and left a
message, but that MADIGAN had gotten the "wrong telephone number."
Thereafter, CS-1 provided his cel1 phone number to I4ADIGAN, and

MADIGAN confirmed that he had the wrong number for CS-1. MADIGAN

asked if he could call back CS-1 and set up a time for CS-1 to come

in and meeL with MADIGAN. MADIGAN added: "I think what you want to
do is to come in and sit down, and we'11, uil, we'11, we'11, we'1I
agree that we're going to represenL the property [the Hotel
PropertyJ . "
50. On September 15, 201,4, at approximately l-0:l-9 &.ffi., CS-1

placed an outgoing call to SOLIS, who was using Target Phone 2. This
call was recorded. During the ca1l, CS-l- updated SOLfS on his
conbact with MADIGAN. Specifically, CS-l- advised SOLfS that. he had
spoken Lo "Mr. Speaker IMADIGANI" and that "he woul-d caII me back
and to seL up a time with me so f can go over the cont.racL with him. "
SOLIS replied: "Excel1ent. Excellent. Very, very good. Thank
you. "
51. CS-1 placed additional fol1ow-up cal-ls to MADIGAN's

office. Despite t.he calIs, neither CS-1 nor Businessman t has yet
signed a reLenLion agreement with MADIGAN's law firm.

25
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 27 of 46 PageID #:51

o-r}i.i"r, (Il IIas Taken


B.soLlsHagReceived'A.FlowofBenefits.Fromlndividua].s=ForWhom
soLIs, r,,-tti" Capacitsy.o""iiGi""tga r"rt" orricial Action or
of f icial
(rr) *li 6irttiu-':
to.takT jiii.i"r a"ti",, Benefitsting
n.iiorr,- These
(III) r"..iir."iv
rndividu"i" arrd Their clients'
conducted over Target Phone 2 confirm that
52 - Interceptions
and multiple unpaid debts'' For example' on
SoLIS has poor cred,it.
oraboutMay2S'20!5'atapproximatelyl0:19a'm'(Session#1-2019)'
SoLlsreceivedanincomingcallfromBylineBank.Duringthecall, in the
soT,rs craimed he had done preLtf well- financiarry
although
pastseveralyears,heexp}ainedthatheexperiencedaforeclosure
onahomethreeyearsearlier.Asanotherexample,onoraboutApril
!6,2015,atapproximateIy11:41a'm'(Session#9021)'SOLISreceived
Collection
call on Target Phone 2 from Monterrey
an incoming
Selvices.ouringtheCaIl,SoLISwasadvised.thatheowedSL2,2T4.36
infeesforat'imeshareconLracLt.hat.hadbeenturnedoverfor
job so I'm sorry'"
SOLIS advised' that he was "ouL of a
collection'
Sol,Iswasaskedforinformationconcerningthede].iquency,andSoLIS
replied:"becauselcan'tpayit'I'msorry"'SOLISthenhungup
thephone.MultipleothercallsfromdebLcollectorsseekingpayment
have been intercepted over Target Phone 2 '
from SOLIS
gone through foreclosure
53. While SOLls has recently
proceedings,hasreceivedmultiplecal]sfromdebtcollectors,and

i : ; 33it ; Ii:
:t 1,": Wr,' ili : 1, ?':#: zl:;i il3' lli .t" ll.3'.'
"?
3lt*#ft :.:i;,r:i:i":xl;i::,'ti'.'^[?'1""='"ii*ts.":':,'",#il"'"
the or over Target Phone
authorized '"i""-'J*"i"" 'it;;";il;l;ations
2.

26
'.- .i..,..,:-.ii:- .fr,.-'.
I r...:',L.-1

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 28 of 46 PageID #:52

has been unable Lo readily obtain credit, he has been able to rely
upon a collection of associates-including but not l-imited to RoBERTO
CALDERO, and FREDERICK LATSKO-Lo provide him with a steady flow
of
personal benefits tn 2014 and.2015, and the evidence det'ailed below
ref,Iects that in reLurn, soLIS, in his capacity as an elected
official, (i) has taken official action, (ii) has offered to take
official action or (iii) is tikely to take official act.ion

benefitting these individuals and their clients as summarLzed in the


following chart and as di-scussed in greater detail befow:
fndLvidual re official Action(s)

CALDERO - viagra (uf s5-60, 73) o Assistance with obtaining


. Arrangement of Prostitution exemption for Elgin
services ({n eg-rs, B8-89) Sweeping from water
o Campaign contributions, including ordinance (lltl es-es,
conEribuEions from relatives of 76-86)
Elgin Sweeping executive (tItl
78-79,86-87)
LATSKO . Use of mulLi-million dol-Iar farm a Proposing ordinance
(fltle2 - er ) favorable to LATsKo 1!l ros)
o Agreement Eo lease dance studio a Participating in aPProval
property at SOLIS's insEruction of projects involving
(!lllsB-1oB) LATSKO ({l-l-3)

54. Furthermore, the investigation to date does not reflect


Lhat soLIS has reimbursed CALDERO or LATSKO for the benefits he has
received from them. Despite the absence of any evidence that, solls
has reimbursed CALDERO or LATSKO for theSe numerous benefits, soLIS
has filed statements of Financial Interests and statements of
Economic InLerests with both Lhe City of Chicago and the Cook County
C]erk, for the years 2oL4 and 2015, in which he has repeatedly
answered "no" to questions asking whether he has received gifts in
each year (i) from any person with an aggregate value greater than

27
J _.jr, ,'j .ir:
I riiila:.f,:: :1." ,t'r,.: ,

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 29 of 46 PageID #:53

$250;and(ii)fromanyentitywit,hanaggregateva}uegreaterthan
$500.Basedontheforegoingandtheotherevidencegatheredduring
thecourseofthisinvestigationthatisdiscussedint.hisaffidavit,
Lhereisreasonablecausetobelievethatsollshasattemptedt,o
concealtheconsiderablebenefitshehasreceivedfromthe
individualsandLhathehastakenofficialactioninreturnforthis
below'
stream of benef its as detailed
i' 3?tl:,:,.;:;l:: :: B:il:ilT'Hfl'*iiT:T1:il?:11;t*
io-ottaining an Exemption from
a Water
Sweeping,
Ordinance '

55.Asdescribed.below,ConversationsinterceptedoverTarget
Phone2betweenSoLISand.ROBERToCALDEROhaveshownthatCALDERo
on an on-going basis' Moreover'
CAI'DERO
supplies SOLIS wit'h Viagra
hasarrangedforSol,lstoreceivemassagesatalocationwherethe
workerswillperformsexualacLsuponsol,ls.Duringthesameperiod,
CAIDERorequestedSol,Is,sassisLanceinhisofficiatcapacit,yasa
Chicagoaldermanonavarietyofissues,includingassistancefor
known as Elgin Sweeping, with respect to a waLer
his clienL , a company
DeparLmenL ' Shortly after
SoLrS
the City's Water
biII involving
interceded.inthemattertoassistElginSweeping,Sol,lssolicited
campaigncontribut.ionsfromthepresidentofElginSweeping,Chris to,
members by making reference
Cacciatore, as well as his family
amongotkrerthings,Solls,sofficialactstakeninfavorofEtgin
Sweeping.ShortlyLhereafter'SOLISreceiveda$5'400monetary
contributionfromaCompanyoperated.byCacciatore,Ssiblings.

28
.:' j..:,, 1 i+:_.i+r..ff,i-l
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 30 of 46 PageID #:54

October L2' 2014' at approximately l-l-:42 a'm'


55. on or about'
(Session#1323),SoLIsplacedacalltoCALDERO'Duringthecall,
SoLISaskedCALDERoifhehadanyofthat.'medicine.,,CALDERo
respondedthathewouldmakeacallbecause*they,,toldhimyesterday
thattheyhadit.CAI,DEROsaidthathewouldseeifhecouldpick
itup.Basedonsubsequentinterceptedconversationsbetweensolls
when he asked
r believe soLrs was referring to viagra'
and cALDERo,
fot "medicine"' 3:1-4 p'm'
L3, 20L4, at approximately
51 . on or about November

(Session#4378)'SoLISplacedacalltoCALDERo'Duringthecall'
sollsaskedCAI,DERoifhecouldbringanyofthat..bluemedicine,"
whichlundersLandtobeareferencetoViagra.CALDERoagreedt,o
make a call to see if
he could get it done'
12 :31- p 'm'
or about November 15 2014 ' at approximateJ-y
58 . On '
(Session#4559),soI,lscaIledCALDERo.Duringt'hecaII,SoT,lsasked
CALDERowhetherhehadlocatedanyViagraforsol,ls.specifica}Iy,
any luck with the "brue medicine .,' CAI'DERO
had
solrs asked. if .AT,DERO
responded:'.Theytoldmeit'wassupposedt,ocomeinyest.erday.,,
CAI,DEROexplainedthat,ViagraandCialisaremoredifficultt,oget'
Act' informing SOLIS that' 10 pills cosL
Care
due to the Affordable
approximate}y$4o0,whichsurprisedso],ls.CALDERotoldSoLISthat
hissupplier\^,assupposedtoreceiveashipmentofacoupleofhundred

inf ormation, Viagra 1-s--?


1-Tn-Y:tU
Iccorains:1p."i1,.?L"r"i#it#l' i";;;;ifi to pr'"li=::Y'"Pf3 :llt:
Lo treat erectar materials for the Pharmaceutacar' LrrE YI'
i;"1;;;a in marketlns
are blue.

29
\:int:/,-'', '-;: . I i
na::ad l-:t") :..
-i
: -.'-.'* +l^:J:Yr-rj r'
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 31 of 46 PageID #:55

Vi-agra pilIs and that CALDERO wanted 50 so that he would have enough
for a while. In a subsequent recorded conversation, SOLIS and
CALDERO arranged to meet inperson. Because SOLIS expressed surprise
regarding the cost of Lhis pharmaceutical, the lack of discussion
regarding pa)rment in any of these calls, and the availability of this
drug for purchase with prescripLion, I believe that SOLIS did not
pay CALDERO for Viagra
59. On or about December 25, 2014, at approximately 9:47 p.m.
(Session #6885), SOLIS texted CALDERO. In the text, SOLIS asked:
"WiII u have any medicine [Viagral tomorrow?" CALDERO responded,
"YeS." SOLIS then responded, "Good, wi}l contact you tomorrow."
_
G0. On December 26, 201-4, in a series of conversations (Session
#690 8,' 6976, 691-8 , 6920) , CALDERO agreed to meeL SOLIS near Cicero

and Belmont in Chicago to provide SOLIS with the Viagra.


G:-. On or about March 31, 20::5, at approximately 11:28 a.m.
(Session #8L76), called SOLIS. During the caII, CALDERO
CALDERO

asked SOLIS about whet.her it was possible to receive approval for


re-zoning on a property located at Throop Street and Cermak Avenue
in Chicago since SOLIS was reelected. SOLIS told CALDERO that he
didn't know and needed to take a look at it. CALDERO said t.hat he
would call to set up a meeting with SOLIS to discuss that and other
matters.
52. On or about April 3, 20L5, at approximately 9:46 a.m.
(Session #8334) , SOLIS called CALDERO. During the call, SOLIS asked
CALDERO why he wanted to meet with him. CALDERo informed sol,ls that

30
-.- ! ia::1-:air::l:::'...5.:a:>-:4r*:_.
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 32 of 46 PageID #:56

hehada.'bunch,,ofdifferentissuestodiscusswithsor,Is.SoLlS
bring anybody'"
agreed Lo meeL, specifying' "[D]on't
approximately L2:02 p'm'
63. on or about May 27, 20:-5, at
(Session#1.1974),SollscalledCAI,DERo.Duringthecall,CALDERo
to tark with so1,rs regarding a water birl involving chris
asked
specifically' CALDERO
cacciatore, the president of Ergin sweeping.
you' Cou1d we have some time?
said: "Look, I want to catch up with
to talk you today t'hough about this water bill thing
. tll need'
to open source searches'
with Chris Cacciatore"' According
Cacciatoreisthepresident.ofElginSweeping.AccordingtotheCity
has several multi-million
of Chicago's website' Elgin Sweeping
dollar contracts with the city of
chicago'

54.Astheca}}continued,CAI,DERosaid:..IjusLneedtogive
youLhebasicinformationonit[referringtot,hewaLerbit}issue
I need to do"' SOLIS directed
with Chris Cacciatorel ' That's all
CALDERot'oprovidetheinformationtoalegislativeaide.'
approximat'ely 8"4L p'm'
65. on or about May 3A' 2015' at
(Session#12]-83),SoLIscalledCALDERO.,Duringthecall,CAI,DERo
requestedSol,Is,sassisLancewithobtainingapprovalbytheCiLyof
Chicagoforaspecial-usepermiLforAFreshstart,RecoveryHomes,,
aswellashisassistancewithawaLerpermitforChrisCacciatore.

ffitions-overTar9.etPhone2,Ibe1ievetheindividua1
-in tfiis call works ror solrs '
;;;;;;;d
on May 28' 2O:..5' the Zoning Board of
According to public records' Homes' a speciaf use Permit
e-rit"r' starL Recoverv
;;;;i;'-e"*i.'a particular home group livinq facititY in
to operaLe a community
Chicago.

31
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 33 of 46 PageID #:57

Specifically, said that he needed to talk with SOLIS about


CALDERO

A Fresh Start Recovery Homes and that "Judith [,:uay Frydland, Lhe
new Buildings Commissioner for the City of ChicagoJ had told us thaL

we should go in and appty for a special use permit. " I-rater


.

in the conversatj.on, CALDERO added: "I really need to help Chris


Cacciatore with t.his water permit, 'cause otherwise, he's going to
start. . ." "I told you, I Lold you I would set
SOLIS responded:
up a meeting just to find out how the helI t.hey came up with that
conclusion, you know?" CALDERO said: "f have no idea. So, dh, so
if you want to calI, You know, set up the meeting. But the other
thing is the Fresh Start Recovery Homes. So, the, Judith lFrydland]
to1d. them, was very confident, that if we went in for a special- use
permit, Lhat we could get it . BuL I t,hink [Alderman ,Joe] Moreno
changed his mind. 'Cause Moreno had been like neutral. Like f
rea1ly don' t, 1rou know, like he had not been. So, when Moreno changed
his mind and the zoning Board of Appeals ruled against him ."
SOLIS said: "Yeah, but if you are going to ask Joe [Moreno] or any
alderman to do something 1i-ke that before an election, they are going
Lo be at the very least hesitant." CALDERO responded: "No, no, ro,
we didn,t. That,s why we waited 'til after t.he election. No, I
wouldn't have even tried it before the election. So, so, an)rway,
anyway, it got denied on Wednesday. So, w€ got to figure it out.
I got to figure it out. I think I have a solution. We can figure
ouL something that would protect them. It's kind of a weird thing.
.Cause here's the thing, the Zoning Board of Appeals only rul-es, whaL

32
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 34 of 46 PageID #:58

the city is telling Lhem, is thaL they can have eight people plus
two managers in a p1-ace like that, and they don,t need a special- use
permit. But the problem is that, unless you do twelve plus two, it,, s
really kind of economically unfeasible to do it, because of all the
testing, alr of the other extra services you,ve got to do to keep
that place going. so, anyway, let's sit d.own.,, CALDERO said that
he would call or text SOLIS in the morning.
66. on or about.June 4,2015, dt approximatery 1:05 p.m.
(session #1-2438, 12439, ],2440) , sol,rs received text messages from
CALDERO. The text messages contained information from an employee
of the city of chicago's water Depart.ment. The texts stat.ed: ,,water
Department [; ] List of arl equipment with license plate [; ] per unit
$83.78 a day for 5 days a week[;] From the start of the season t.o
the end of the season [; ] April 6-November , 2O-l_5; $83 .7g x 5
27
days = $418.90 x 34 weeks = (914,242.50 per unit); x 7s t,rucks =
$1, 058 . 095 t . I Mike Tucker, Water Department . ,,'o

l_0 Based on my review of the contract Elgin sweeping entered into with
the city of chicago, which was obtained from-trrJ city of chicago,s
website, ds well as my review of Elgin sweeping;s websitd, r
understand that Elgin sweeping is in the 6usiness 6f ploviding street
cleaning services to the city and in connection with this iype of
service, Ergin sweeping uses a freet of vehicles. Based on my ilview
of _a city ordinance t,hat was passed. by the cit.y council on or about
,Ju1y 29, 20L5, r know that when a fiie hydrant is used. to provide
water for the filling of a truck or street sweeper, the amount iharged
for the water sh_al-l be gB3.78 per d.ay. t believe this t.ext message
is meant to refLect the revised chirges Lhat Elgin sweeping wirl_
incur as a result of this ordinance. . while the text messige"reads
"$1,058.095," r believe this amount is a tllgographical .rior, and
thre amount should be $1,059,195. Accordinglv, r believe that. as a
result of the new ordinance, Elgin sweeping would incur cosE,s
exceeding $1 million, and that GALDERo wishea solrs Lo prevent Ehe
new ordinance from ful-Iy applying to Elgin sweeping. CALDERo,s
efforts to limit the application of thJ new ordinJnce to Elgin

.),
d.)
.- 'a-l ,1,:'r'/. -.:- r.-:r..t>a..r:.,

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 35 of 46 PageID #:59

7"42 p'm'
67. on or about June g' 2OL5' at approximately
CALDERO' During the
(Session #1-2194),, SOLIS received a call from
call,CAI,DERoaskedifsol,lshadachancetotalkwiththeWater
*i6; y€tr" and asked CALDERO to remind
Commissioner. SOLIS said'
SOLIS's scheduler to "set uP meeting [wittr the water
Commissionerl . "
12:35 p'm'
68. on or about June 15' 2Ol5' at'approximat'ely
(Session#:13027),Sol,IscatledCAI,DERo.Duringthecall,CAI,DERo
begantoinquireabouttheWaterCommissionerbeforehewas
int.erruptedbysoLIS.Specifically,CAI,DERosaid'.'"[W]hatwasl
goingtotellyout.heWaterCommissioner_,,soLISt'hen
interrupted,informingCALDEROthaLhehad.just'finishedwiththe
they were about to vote on
Finance committ.ee and just reft because
Lhebonddeal.sol,lssaid.hewasgoingtobughisscheduler,..Lo
gett.hatscheduled.,IunderstandSollstobereferringt'oameeting
regarding t.he Water Commissioner'
69 . on JuIy 2, 201-5' dL
approximately 3 : 05 p 'm' (Session

#L4202), SOLIS called CALDERO'


During the call' SOLIS informed
massage with a "nice ending"'
r
.ALDER. Lhat, he was rooking for a

believethaLsol,lswasinterestedinamassageinwhichLhemasseuse
wouldperformaSexaCLonsol,Is,whichwasreferredtoasa..nice
such a massage for solrs later
ending. "" CALDERo agreed to arrange

Sweeping is discussed furLher herein'


l-1 NCr C criminal
i J',ffiiJ, Ji#
#;;;; ;i;"1*
;:ii!::.. :P:
;;
;;; ;;r ;";! o c curred mo re than
on "1""?':::,,:1"'31Lo,J?i":
#I:,"#HJJ
10 vears ago. o, o' abo[t
yr'V-go
' 20:l.5' -6uring Lhis loz44
approximately
-t1,ar
aL
call'
a.m. (session +rzIzei, cALDERo'citi"a
sot,rs'

34
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 36 of 46 PageID #:60

that night and also asked SOLIS if he had received feedback from the
Water Department. Specifically, SOLIS said: " [L] et me tell you why
r called. r want to get a good massage, with a nice ending. Do you
know any good places?" CALDERO informed soI,rs that he knew of such
a prace, and explained that he .'and. [name redact.ed] were just there
like Monday." sol,rs responded: .'you want to go tonight sometj-me?,,
CALDERO agreed to do so and said that. he would make an appoint.ment:

"You got to give me a time and r can calr. you got to cal_l_ for an
appointment.'" sol,rs asked: "what kind of women do they got there?,,
CALDERO responded: "Asian. " sol,rs said.: .'oh good ! , good, good.
Good
r like Asian." CALDERO responded: "rt's [name redacted],s absorut,e
favorite." sol,rs asked: "Asian?" CALDERO confirmed. solrs t.hen
specified: "okay, you te1], teII them r want the same one that does
[name redacted.] .,' CALDERO said he would schedule an appointment.
CALDERO said: "Let me make sure Lhat it.,s avairabre, and then what

el-se was r going to terr you? oh, the water Department-did you get.
any feed back?" r believe GALDERo is asking sol,rs if he received

solrs asked CALDERO t.o investigate a massage parlor that might be


offering prostitution services-. sol,rs direcied CALDERO tj send
someone to the massage. parlor to see what services they offered.
specifically, sol,rs said: "[,f]ust send. somebody over thbre to get,
a massage. see what happens." CALDERo asked for the add.ress, which
sol,rs provided. As the call continued, sol,rs said: ,,,lust check it
out, you know. 'cause they just opened on the 15th so they may not
do anything for now. But it,s noL just happy end.ings-[sei act
performed on the customerl. r thint< the iaei-ihat thJy aiso have
girls without any licenses, masseuses without any 1icenses.,,
CAIJDERO responded, 'r'11 check out whet.her t.he ricenses and the
names. f'11- check it out." sol,rs instructed CALDERo to send
someone else t,o invest,igate because CALDERo might be identified. rn
a.subsequent caIl, sol,rs suggest.ed this busineis might be associat.ed
with SOLIS's former girlfriend.

35
:: . :..4- | P\:1a,a/.\'r':i,'....ri :ira:q!.i--7
,
--r

la
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 37 of 46 PageID #:61

problem' SOLIS said: " [W] e


any feedback concerning Elgin sweeping's
can talk when we geL together'"
5:35 p'm' (Session
70. On JuIy 2, 201'5' dt approximately
#L4245) , SOl,lS ca11ed CALDERO '
During the call ' SOI-'IS and CALDERO

discussedt,heirvisittoamassageparlor.specifically,sol,lsasked
CALDERowherehewas.CALDEROsaidthathewasfiveblocksaway.
name is [nsame redacted] ' Just
tel]
CALDERO instructed SOLIS: "Her
TeI1 her you're there for
her you're there to see, You're wiLh me'
the six o'c1ock with Roberto'""
TL.FBIsurveillanceobservedSoLISenLerSr-rbjectl,ocation5,
whichisonthenorthsideofChicago'atapproximately5:36p'm'
laterthatevening.Avehic}eregisteredtoCALDEROwasobserved
parkinginfrontofSubjectLocatLon5atapproximately5:42p'm'
AlonemaleexitedthevehicleandenteredSubjectl,ocation5.
L2:L7 p'm' (Session
72. on JuIy 9, 2OL5' at approximately
#1-4652 ) , CALDERO called SOLIS '
During the cal] ' CALDERO asked SOLIS

tojoinhimatt'hesamemassageparlor'subjectLocation5'SOLIS
agreedtogo.Specifically,CALDEROsaid;..H€},listen,tomorrow
with [name redacted] in
at nine o'cIock. You wanL to get together
That's 'cause' that's
the evening?' SOLIS said: "Yeah' yeah'
LomorrowisthelasLdayl'mhere'Yeah'feL'sdothat"'CALDERO
said:'.Yeah,yeah.That,swhatlthought.Hejustcalledme.He,s

obtained durinq the course byof this


l2 None of the bank records tJ-".""L"ts used"or conLrolled SOLIS
ltr.stigation and relating transactions at Subject
show any Payments to or "r.aic card
Location 5'

36
': l,:_:a!_ #,{

1
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 38 of 46 PageID #:62

gonna come in at . I'm picking him up at the airport at eight"


We,re gonna go to the place we wenL to onMi]waukee" aL nine." SOLIS
respond.ed, "Excellent, excellent. ThaL',s great." CALDERO said:
"Okay. I'11 trY t.o set it uP."
73. On JuIy 10, 20L5, at approximately 1-1:53 a.rn. (Session
#: 4799), SOLIS caIled CALDERO. During the call, soLIS asked CALDERO
if they were still getting together at Subject Location 5 that
evening. SpecificalIy, SOLIS asked: "Are we still meeting today?"
responded,: "AL what time? HoId on, hey, Danny. Yeah, we're
CALDERO

meeting. I'm picking up [name redacted] aL 8. " Later, SOLIS asked


CALDERO: "Okay, so are you making the arrangements with the, uh,
massage place?" CALDERO responded: "Yeah, t.hose are already made,
andwe're set up for nine o'cl-ock. Same girt you had last time' " SOLIS
said: "Okay, okay. Hey, listen, I'rlgoing to, I'm leaving for Taiwan
Lomorrow morning." CALDERO responded: "Yeah, you told me you're
Ieaving tomorrow, right,?" SOLIS Lhen asked: "Yeah, is there any way
you can get me, uh, any more of that medicine fViagral you got me
Iast time?" CALDERO said: "I've gol some on me. I can let you have
some, yeah.,, soLIS responded: "Yeah, yeah. whatever you can would
be appreciated."
74. About an hour }ater, at approximately L2:51 p.m. (Session
#14814) , CALDERO sent a Lext message to SOLIS. The text message said:
..Can have someone follow up with the water deparLment concerning
Elgin sweeping [?1 " SOLIS responded to the texL message (Session
13 The street CALDERO referenced is the same street where SOLIS was
observed on.7u1y 2, 20]5, when heentered Subject Location 5.

37
*;1-:;.r.,ii'Pl.{--l

t
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 39 of 46 PageID #:63

#14815) by telling to call an individual, who was referenced


CALDERO

by their first name. Based on that first name, and my review of


records maintained by the City of Chicago, I believe SOLfS instructed
CALDERO to contact a legislative aide who works for SOLIS at. Subject
Loeation L, to set up a meeting to discuss the offical action SOLIS
may take on behalf of E1gin Sweeping.
75. FBI established surveillance in the area of subject
Location 5 that evening- Lhe same 1ocation where the FBI had seen
solJls and GALDERO on JuIy 2, 2OL5..At approximately 8:55 P.R.,
surveill-ance observed SOLIS enter Subject Location 5 and proceed past.

the reception area. At approximately 9:05 P.r., surveillance


observed CALDERO's vehicle putl in front of Subject Location 5 ' At
that time, a third man exited. t.he vehicle. Surveillance observed
the third man enter Subject Location 5 after being let inside t'he
Iocked. door of Subject Location 5 by a woman who arrived at Subject
Location 5 shortly after the t.hird man. Surveillance observed the
third man proceed past the reception area. Shortly thereafter,
CALDERO approached Subject Location 5 on foot and entered Sr:bject

Location 5 at about 9:08 p.m. Surveillance observed CALDERO walk


past the reception area. At approximately 9:53 pm., surveillance
observed a woman aL the front counLer of Lhe reception area appear
Lo conduct a transaction with a male, believed to be CALDERO'
Surveillance then observed CALDERO walk out of Subject Location 5.
Surveillance then observed CALDERO park his vehicle on the street
at. 10:08 p.m. and reenLer Srrbject Location 5. At approximat,ely l-0:18

38
i.''--:',-.::__ i ., .!.i ,.rr:*r.!.
:-.1.

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 40 of 46 PageID #:64

p.fr., surveillance observed CALDERO exit subject, Location 5' A few


minutes 1ater, surveillance observed CALDERO's vehicle conduct a
u-Lurn and park in front of subject lJocation 5, and then CALDERO
exited the vehicle and reentered subject Location 5' At

approximately L0z22 P.8., surveillance observed soLIS' CALDERO and


the third man exit subject tocation 5. surveill-ance observed that
soLIS, CALDERO and the third man exited subject Location 5 without
appearing to conduct a transaction at the counter and then entered
CALDERO's vehicle. which Lhen departed the area'
75.onoraboutJuLy27,2015,dtapproximatelyLz54p.m.
(Session #L49'70), SOLIS called CALDERO' During the call' SOLfS and
CALDERO discussed an ordinance relating Lo the city's
water

Department,. specif ic aLLy, CAi,DERO said: "Hey , dh, I heeded to, Lalk
to you for a few minutes on this dh, bilt for the waLer, ah the
ordinance for the water, ah Department." soLIS said: "Did chris
ever talk to Tom Powers lthe Commissioner of Water Management] ?"
CALDERO said: "I don't know if they communicated'
I don't think they
have. r sent you a draft that I believe we can change the ordinance
j-L?"
by including one sentence in there. Did you take a look at
SOLIS said: ..No, [o . I've been running around. Ah,
give it t1.rr' :.--:..r*
t&l'";
[solrs,s legislative aide]." CALDERO agreed to send the draft
="-''

the aide and said that he also sent it to SoLIS's "personal email."'n

Based on information developed during this i_nvestigation, SOLIS uses


address.
1"4
danielsoliseroogmail.com is his personal_ email For
by Google reflecr.s
;;;fui;, informiiior. proridedwiln Lhat Lhe recovery
email- ,"=o.i.t.h the account is
daniel.solis@cityofchicago.org. As noted above, SOLIS is employed

39
i h:.,ji:':: .?- .. ;+ r.J: z!-*,t -,,

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 41 of 46 PageID #:65

Later,CALDEROexplainedhisproposedrevisiontotheordinance
wou}dprovidethat.ifapersonwasproviding..waLer,forapublic
serviceonbehalfofthestate,thecityorthefedera].governmenL,
thatyouwouldbelimitedtoanincreaseofnomorethan25percent
overyour]-astbill.,IbelieveCALDERoaskedso],Istousehis
officialpositionasanAldermaninordertoassist'CALDERo,sclient
inreceivinganexemptionfromlegislation,sothatCALDERo,sclient
willnothavetopayt.heCityasmuchforwaterusage.Thereafter,
SollsinstructedCALDERotot,ellhisaideto..bringittothe
attention of Claudia Claudia from the mayor's office'"
3:03 p'm'
77. on or abouL JuLy 27 ' 20L5' at approximately
(Session#L4ggg),So],IscalledJoeCacciatore,asiblingofChris
Cacciatore.JoeCacciaLoresuggested.thatheandso],lsgettogether
foragameofgolf.SoLlsagreed.,andad'ded:..Imetwithyourbrother
andRoberLoacoupleofweeksago,I,mLryingt'ohelpt,hemwiththat
housingthing[inrefer.encetoAFreshStartRecoveryHomes].,,Joe
Cacciatorerepliedthatwas'.good,,andt,hathewantedt.otalktoSoLlS
reason I also called you
about other maLLers ' SOLIS t'hen said: "The
10th, my TasLe of the 25th
is for my event on the ].ot,h, September
help me ouL as you usually
Ward. I'm hoping you and your family can
asked if
do.,, Joe cacciat.orereplied.'.we definitery wi11." sol'rs

account is used bv sor,rs-


3:ii:rx11".Jf,rfff i:ff*"'.Li,i,-*;-rhis service offered bv Goosre'
As discus=.a "n3ll:]'"ilir,";;-;;*"rr- of the emair
Accordinslv, r h;;""'tt""o" to utiii'!-;h:;-11:.d-eliverv
cmair account required the use of the
from caldero a"*"joiis;s-
commerct'*"-8"";d on'this' I believe SOLIS
channels of inLerstate in order to carry out this
caused an intersiate ,ire tr"rrJ*i""[r,
offense.

40
t
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 42 of 46 PageID #:66

JoeCacciatorewished.to.'Coordinatethat,,[donat'ionstoSoI,]S]with
therestofthefamily,orifJoeCacciatorepreferredthaLsoi,fs
.foe Cacciatore ind'icated that' he
call the ..other guys separately."
preferredtocoordinatethed'onat'ionfromthefami}y,.'I,IItakethe
leadonthat,okay?'SOLISagreed'andnoted"Ithinkl'mgoingto
ah tomorrow on' on some ordinance that I have
see Chris [Cacciatore] '
t,odofortheElgint,hing,,,inreferencetoElginSweeping.Solls
can
added: 'rI have to rework it." iloe Cacciatore told SOI'IS: "you

letChrisknowthaLwe,wespokeaboutit,butl,Iltakethelead
intermsofcoordinatingeveryoneinmyfami}y.,,soLISsaid:..If
youguyscouldhelpmereachacertainamount'Lhatwouldbevery
t'Yep' I hear ya'"
hetpful. Okay?" Joe Cacciatore said:
on or about JuLy 27 201-5' at approximately 4:02 p'm'
78. '
(Session#1.5056),SoLIscalledCALDERo.Duringt.hecall,SoLISand
CALDERodiscussedSolls,sinLentiontocallChrisCacciatoreto
solicitamorreLarycontribution.sol,lsadvised,CALDERot,hathewas
atTomBowen's'uoffice"causel'mdoingRY'uh'callsformy
fundraiser.,,so],lsadded:'..IwasgorrnacallChrisCacciatore,buL
beforelcalledhimlwanttotalkLoyou'um'Lomorrowl'lIfollow
upwiththat,ordinancetheyneed.,,CALDERosaid.:'.Uhhuh,yeah,IeL,S
notconnecLthetwo'Listen'Ijust'IjusthadlunchwithChris'
hejustgavemeacheckfor$5,00ofor[nameredacted],okay,Ihave
thesamecommitmentforyou.,,[Iunderstandt.hisLobeawarning
handles
daLe, I believe that Tom Bowen
15 Based on the intercePtions to Bowen ;" -;;a telieved to be a citY
*"ai" affairs for SOLIS '
empIoYee.

41
..
l'l;/*)t:-=:: :..?. F::,.:?:. +_ai.i--l

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 43 of 46 PageID #:67

fromCAT,DERot,oSoI,ISthattheyshouldnotexp}icitlylinkafinancial
contributiontoSOI,IS,sactionsonbehalfofCAI.,DERo,sclient.]
redacted's] name and put my name
SoLIS said: "Wel1' scratch out [name

dumb'' CALDERO said: "I can' I can white it out' I


on there d'umb call
they still seII White Out'" SOLIS taughed and the
can, I think
was abruptly terminated'
2015' at approximately 4:O4 p'm'
7g. on or about Ju.;y 27
'
(Session#15057),SoLIScalledCAi,DERo:Duringthecall,soLIS
continueddiscussinghisintentiontocallChrisCacciaLore.
Specifical}y,SoLISaskedCALDERohowheshouldtimehiscallasking
foramonetaryd.onationfromChrisCacciatoreinrelaLiontoSoLlS,s
officialactiononbeha}fofChrisCacciaLore:.'soshouldlcallhim
orshouldlwait'foryou?,CAI,DEROreplied.:..Youshouldlookatthat
ordinancefirst.,getclearancefrom,makesurethaLit'snotgoing
problem but you gotta let
me
I tried to find
to be a problem' that' soLIS
[I believe GALDERO t'o be suggesting
know if that, works. "
shouldensurehecouldtakeofficialactionbenefittingChris
Cacciatorebeforesolicitingmoneyfromhim.]So],lsconfirmed:hold off
Okay' so 1'1I
..Yeah, yeah, yeah, I'1I find out tomorrow'

ont.hat,buLthenlalsowantyoutolineupotherpot'ential Danny' You


CAT'DERO said: "You have l-0 commiLted'
contribulors'"
have].0commitLedfrommealltoget,her,okay?,,[Ibelievethisireans
LhatCAI,DERowaspreparedtoarrangeforatotalcontributionofat
least'$lo,0o0toSoT,ISfromvariousdonors.]SoLISsaid.:.'Okay.,,
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 44 of 46 PageID #:68

80. on or about ,Jury 27, 2aL5, at approximatery 4.t45 p.m.


(Session #15071), Sor,rs received an incoming call from a member
of
his Ardermanic staff. During the call, sol,rs and the staff member
discussed the status of Elgin sweeping, s proposed amendment to the
water ordinance. The staff member advised SoLIs that Tom powers
needed to speak with sol,rs about '.an ordinance going in for Ergin
sweeping." The staff member indicated that powers had been trying
to get in touch with someone from Etgin sweeping for the rast two
to three weeks, and that powers had an issue with,'what they are
proposing. " so],rs instruct.ed t.hat he wanted powers to tal-k to Elgin
Sweeping before SOLfS Lalked to Powers: "Have them talk before I tal_k
to them. " sol,rs advised he would talk to him [powersJ tomorrow. The
staff member noted that Powers was "worried,, because the ordinance
was "going in tomorrow." SOLIS reit,erated that powers should talk
to them [E]gin Sweepingl before SOLfS talked to t.hem.
81. on or about Jul,y 27, zot5, at approximaLery 7:03 p.m.
(session #15095), sol,rs made a call to a member of his staff. During
the calr, sol,rs and the staff member discussed the st,atus of Elgin
sweeping's proposed amendment to the water ordinance. The staff
member noted that the water commissioner was '.concerned,, with ..some
of the items in the ordinance,,, and alregedly had been trying to get.
ahord of chris cacciatore to ..clarify some of the items that
are pending." The staff member added that the Water Commissioner
did not want to l-et the amendment proceed the following day without
obtaining further information: ,,He,s trying to solve this, but he

43
a.' ..?: lt tr::a.,1.+t;"::..:.::+
l ....-* :r.:.* ji:+j.q:;,:L

Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 45 of 46 PageID #:69

doesn,L want Eo go in there trying to push this Lhrough' " SOLIS

expressedhisdispleasureatthisdevelopment:..lt,sverysimpIe
me ' I mean ' I met with them'
and. I think somebod'y' s bullshitting
saying he can't get
he lPowers] said he would work. on it' now he's
aholdof'em.So,what'shis'whaL'shissuggestionthen?"The
preferred to have
staff member indicated that the water commissioner
thewaterordinancepasswithoutElginSweeping'sproposed
amendment,arrd..thencontinueLoworkonitwith'emuntilthenext
again expressed his
council meeting, or committee meeLing-" soLIS
displeasure:*Whyd'oeshelPowers]letmeknowthisnow?"So],fs
indicat.ed he would caII CALDERO '
8:20 a.m.
82. on or abouL ,Ju1y 28, 201-5, at approximately
(Session #1511-6), SOLIS ca1led' CALDERO' During the
caII' SOLIS and

CALDERodiscussedtheproposedamendmenttothewaterordinance.
CALDERO advised that he had
given Chris Cacciatore "the office number
to call Powers
for Tom Powers, " and' that he would instruct Cacciatore
at9:00.soLISinstructedCALDERotohaveCacciatorecallPowers
at8:30.SOLISad'ded:"Hewantsmetoletitpassasis'andthen
CALDERo said:
we,Ir take care of it. at t.he nexL commiLtee meeLing'"
..okal, as long as we undersLand what it is that we're going to fix
alright' we'I1
at the next meeLing, that's fine ' " SOLIS said: "Yeah'
talk laLer. "
1:59 p.m.
83. on or about August 5, 201'5, at approximately
(Session #1-5806), CALDERocalledSoI,IS.Duringthecall,SoLIS
of Chicago's Water
agreed to set uP a meeting with the City

44
Case: 1:16-mc-00261 Document #: 1 Filed: 05/27/16 Page 46 of 46 PageID #:70

Commissioner. SpecificalIy, CALDERO said: "Ah, couple things,


Iisten, I haven't goLlen any direction on where we're going with this
waLer issue. " SOLIS said: "They're lthe Water Department] supposed
to take care of it for me, ah, out.side of the ordinance. So, dh,
ask [a SOLIS legislative aide] to fo]Iow up with the meeting with
the commissioner Lo me." [f understand SOLIS Lo mean that he had
arranged for request for relief on behalf of Elgin
CALDERO's
Sweeping/Cnris Cacciatore to be handled ("take care of it for me")
without having to make a formal amendment to the applicable city
ordinance. I CALDERO said: "He's called, he's called the
commissioner three Limes, like Friday, Monday, and Tuesday." SOLIS
asked: "Who did?" said.: "Chris, Chris Cacciatore called
CALDERO

because that's what-" SOLIS said: "No, [o, [o. TeIl [a SOLTS
legislative aidel to set up a meeting with me and the
commissioner.,, CALDERO said: "okay. Not a problem. " soLIS said:
..I wanL to see how he lthe Water Commissioner] is going to take care
of lunintelligiblel . "
84 . On or about August 18, 201-5, at approximat.elY 8:04 a.m.
(Session #L6952), CALDERO sent a text message t.o SOLIS. CALDERO
wrote: "r'm meeting with Chris in a few minutes regarding the waLer
department. give me a call when you get a chance." I believe CALDERO
wished to speak to SOLIS about his effort to obtain an exemption from
an ordinance for his client.
85. On or about August 18, 201-5, at approximately 8:04 a.m.
(Session #16963 ) , CALDERO sent SOLIS a text message. CALDERO wrote:

45