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be}ieveGAYTANwasexplainingtoso],lsthathe(GAYTAN)was
attemptingto}eaveLheimpressionwithrepresenLativesofMcHugh
ConsLructionthatsol,lswastakingofficialact'iontoaidMcHugh
extracting financial support
construction, s project and anticipated
fromMcHughConstructioninreturnforthispurportedaction.
L2S.AccordingtofilingsforCit,izensforDannySo}iswiththe
IllinoisStateBoardofElections,onSeptember2g,20].4_thevery
samedaythat(i)GAYTANdiscussedhj-sreceiptofatextmessagefrom
..theguy,,associatedwithMcHughConstruction;(ii)GAYTA}Itold
McHugh Construction think
SOLIS was
SOLIS he (GAYTAN) would make
helpingoutMcHughConstruction..alltheway,,concerningthe
project; and (iii) SoT'Is advised
company's hotef anddata center
GAYTANtoteltMcHughConsLructionthathewouldcallaspecial
for the benefit of McHugh
meet.ing before City Council
ConsLruction_McHughConstructionmadea$l,500contribut'ionLo
CiLizens for DannY Solis '
i:2g. on or aboutOctober 7' 2Ot4'
at approximately 9:21 a'm'
on Target Phone 2 from
(CaII #94,.), soI,Is received an incoming calI
GAYTAN.Duringthecall,GAYTANadvisedSoLISthatindividualsfrom
McHughConstructionwouldcontinuetobackSo],ls.specifically,
GAYTANaskedSOLIS:..Haveyoustartedtodoanymeet.ingsyetwith
SOLIS indicated he had' and then
anyone for your campaign yet' Dan?'
GAYTANsaid:'.Well,theseguysfromah,theguysthatl.,vebeen
tellingyouabout,theonesfromthathoLeldeal,theywanttostarL
figuring out how to helP out ' GAYTAN indicat'ed "LheY" lwhich

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I believe to be a reference to representat.ives of McHugh


ConstrucLionl were "so happy" about SOIIS's quote in the "Tribune"
that .'it [UcHugh Construction's project] was hetd up because of union
negotiations. "" GAYTAN added that SOLIS had "really helped them out
big time, so if you see this guy t.oday, just make sure you take credit
for t.hat okay? He may bring that up to you today if he grabs you on
the-today, s your hearing right?" solJls confirmed there was a
hearing scheduled for 2:AO.'n GAYTAN added that "if the guys from
McHugh want to talk to you on the side at the end, just make sure
you knOw, 'H€1rr yeah, you've talked to ,JUan,' because I want yOu to
get, uh, they,re going to help out a IoL, so I just want to make sure
you get crediL for that quote in the Tribune, because it helped them
with all of their board members . . " Based on the foregoing, I
believe Construction to believe that SOLIS was
GAYTAN 1ed Mct{ugh

taking actions to benefit tvtcttugh ConsLruction in connection with

33 On or about OcLober 7, 20L4, the Chicago Tribune published a story


that noted t,hat "McHugh Construction will present plans to the City
Council Zoning Commiitee to build a 500-room hotel and adjacent
six-story dati center near Cermak Road and Indiana Avenue." The
article iurther noted that "The hotel project was yanked from the
Zoning Committee agenda lasL week. The committee's chairman, Ald-
Oanny-Solis, 25th, iaia the removal came at the request of South Loop
A1d. pat Dowell- because negotiations were ongoing between Unite Here
Locatr 1 and [Company 5] over the union's ability to organize at the
proposed hotel. "
34 According to records maintained by the City of Chicago, the Committee
on zonin{, Landmarks and Building Standards had a meeting schedufed
for octobeT 7, 201-4, at 2:00 p.m. The sole item on the agenda for
this meeting was consideration of a change of zoning in connection
wiLh the property located at 2207-22L5 South MichiganAvenue, l0l--133
East Cermak-Road, 2206-2258 South Indiana Avenue and l-l-8-132 East'
23'u Street.'McHugh ConstrucLion was Listed as one of the owners of
the property along wj-th two other entities. The stated purpose of
tne cfrange was "to alLow construcLion of a hotel and data storage
center. "

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and GAYTAN explained


their hotel/data center deveropment project,
to provide financial
to solrs that McHugh construction wished
backingtoSoI,lsinreturnforhisactions.Laterinthe
Conversation,GAYTANadded:'.Andd.on,tforgetLoday,whenyousee
thisguy,MikeMeagherfromah,fromMcHugh,justtakecreditfor
whateverhesaysyoudid'"SOLISreptied':"A1right'alright"'
on November 10' 201-4' at'
1-30. Approximately one month later'
approximatelyT:43p.m.(Catl#4L24),sol,lsreceivedanincomingcall
onTargetphone2fromGAyrAN.Duringthecall,themendiscussed
afundraiserforSOLIS.Specifically,SoLIstoldGAYTANhewould
bereceivingacallfromafundraiseronbehalfofSoI,ls:..shewanLs
toknowotherthanWintrustwhoitis,howmuch,soweCangetready
toorganize!L.'GAYTANreplied:"okay'Sure'iL'1I'it'lIbe
Danny'"
Wintrust. and the guys from McHugh Construction'
1-3l.OnNovemberl-9'201-4'atapproximatelyll-:04a'm'(Session
*4764),sol,lssentanoutgoingtextmessageonTargetPhone2Lo
GAYTAN'Themessagewasasfollows:..HeyJuan,[nameredacted]wilt
becal]inguabtwind.trustandWalsh[Construction]fundraising.
SoLIS was attempting to make good
She is my fundraiser [ ' ]' I believe
onMcHughConstruction,swillingnesstobackhimfinancially.While
thistextmessagesreferenced"Wals I."'abelieveSOL]sintendedto
refertoMcHughConstructionforsevera}reasons,includingthefact
LhatMcHughConstructionwasreferencedbyGAYTANinCall*4724rn
connectionwithafundraiser'WalshConsLructionisalsothename
ofaconstructioncompanyoperatingint.hechicagoarea,anditis

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to refer to McHugh
believed SOLIS merely used the wrong name
ConsLruction.
' vi. Elgin SweePing'
1'32-Asd.iscussedinparagraphs55throughg0above'SOLIS
assistedElginSweepinginobtaininganexemptionfromawater
ordinancethatwould'haverequiredElginSweepingtopaya
significantamount,ofrevenuetotheCityofChicago.Further,as
notedinparagraphS5,aftersol,Isdiscussedhowhehadtakent'his
officialactionLoassisLElginSweeping,SOLIStoldRoBERToCALDERo
Chris CacciaLore,
t'hat he hoped. the President of Elgin Sweeping,
would.'remember,,SoLls,sassistance,andthend.iscussedtheamount
ofmoneythatCALDERowouldraiseforSol,lsfromChrisCacciatore
and'hisre]atives.Asnotedinparagraphg0,so],lssubsequently
receivedacampaigncontribut'ionof$5'400from'Jos'Cacciatoreand
Sweeping previously
Co. on or about September 2a' 2015' Elgin
on or about September 29 '
donated $2,500 to Citizens for Danny Solis
201"4.

D.DocurnentsConcerningPotentialContributorsandAttendeesat
theFund'raiserandtheofficia].ActionSoughtbyThem.
l33.Basedoninterceptedcal}s,IbelievethaLalegis}ative
Subject l,ocation l,
aide who works in SoLIS,s City HalI office,
preparedandmaintainedalistofindividuals/entitiesthat,solls
wouldseekcont'ributionsfrom,togetherwiLhCorresponding
informationconcerningtheofficialactioneachconLribuLorsought
from SOLIS.

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a34.Forexample,onoraboutJuLy2T'20L5'atapproximately
2 :45 p.m. (Session #A4g81) , SOLIS received an incoming
call on Target
phone 2 from a legislative aide, who was using a telephone tocated
within soLIS,s city HaIl office (subject Location 1) ' During the
cal1, SOLIS discussed his plans to call an individual for a
contribution. specifically, soIJIs said: "on the Michigan Group, who
are the, who is the guy that a, we're doing the Carmichael for
lunintelligibleJ, I forgeL the name." The legislative aide said:
..That, s going to be, that' s Tom Meador. I did'n' t know if you wanted
.Cause we haven,t
to hit himup yet, UIII, just .Cause there,s like,
settled the deal yet, or how you wanted to treat that one, so I haven't
put him on the 1ist. yet. But his name is Tom Meador, M-E-A-D-E-R'
D-O-R.' II believe t.he legistlative aide told soLIS t.hat he might
not. want to solicit. a contribut.ion from Meador yet because solrs had
not yet. completed official action on a matLer involving Meador''u)
soLIS said: .'Then his name is not here, it's, the names I got' here
are-oh yeah, Tom Meador. " The legislative aide said: "And Tom Moore,
Tom Moore is the attorney." soLIS shortly thereafter said: 'tThey

should be smart enough to figure out how they can give me a


contribution, you know, not necessarily connecting with them, so f'm
just going to te11 them." [I believe that solls was explaining to
the legislative aide that Meador should be able Lo structure his

Based on information maintained by the city of chicago, I bel-ieve


M;;e;r is associated with the Michigan Avenue Real EstaEe Group, an
enLity that was "."Af"S-i zoning chlnge tfg* f-h? City of Chicago in
order to build Lwo four- story residential buildings (the "Michigan
Group Project").

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contributionSoastopreventanyassociationbeingdrawnbetween
thedonationandSol,Is,sofficialactsbenefiLtingMeador.lThe
legislativeaidesaid:..Yeah,abso}utely,I,mSure.Helg,|hey,te,
Lhe,he'sgotlike25T'LCs"'SOI'ISsaid:*Andtheeventwon'tbe
untilseptemberl0Lh.,,SoTJlsalsoaskedthelegislativeaideto
providehim,inconnectionwithhisfundraising,withinformation
aboutwhatofficialaCLseachpartythatwouldbecontactedhadasked
sollstotake:..WhatIneed'inadditiontothatinformation,iswhat
isitthattheyareaskingfor'orwhatisitthattheywantmeto said:
said: "That's whaL I put-" SOLIS
aide
do-oh. " The legislative
"oh,okay,rgotiL'youdid'youdidthaL'"Thelegislativeaide
just to refreshyourmemory'"
havebeendoing that
said: "okay, yeah, I
bYe'"
SoLIs said: "okaY' alright'
10' 2oL5' at approximately 2:14 p'm'
135 - on or about
September

(Session#18553),soLISp}aced.anoutgoingcallonTargetPhone2 that
During the call' the fundraiser told SOLIS
to his fundraiser'
shewantedtocheckinabout,thatnight,inreferencetoS0I,IS,STaste
ofthe25t,hWardfundraisingevent',andalsoaboutt.henextWednesday.
Sollsinformedthefundraiserthat'hejusthadlunchwithBRIANHYNES,
whosaidhesentanemailouttohisnetworkandwouldfollowupwith
calls,ioreferencetosolicitingdonations.Sol,lsandt'he
fundraiserthendiscussedwhowasgoingtoattendSo],IS,sfundraising
eventthratnight,,andthefundraiserinformed.soI,lsthatthemayor
wouldnotbethere'ThefundraiserinformedSOLlsthat'shewould

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send SOLIS's scheduler, who worked at Subject Location 1, '.the 1isL,,,


in reference to the attendees.
E. of Monetary Contributions Made to Him,
SOLIS Makes Personal Use
to Include Use for the Payment of His Son,s School Tuition.
136. Law enforcement officers have obtained financial records
concerning the use of a credit card account in the name of the .'25

Waid Reg Dem Org," in reference to Lhe 25'n Ward Regular Democrat.ic
Organizat,ion (the "Ward Credit Card Account"). Statements for the
Ward Credit Card Account reflect that there are at least three
authorized users associated with the account,, SOLIS, GRACE PERALES
and Robert Klunk. InLerceptions over Target Phone 2 confirm that
GRACE PERALES is SOLfS's sister, and that Klunk works in some

capacity for So1is." These financial records furt.her reflect that


the credit cards issued in SOLIS's and PERALES's names have been used
over a period of several year:s to purchase items and obtain services
that appear to be personal in nat,ure. For example, t.he credit card
statements reflect the following activity:
On or about December 24, 2009, the credit card issued
in SOLIS's name was used to make a payment of $100
to Mario Tricoci Hair S [alon] ;
On or about April 5, ZOLO, the credit card issued in
SOLIS's name was used to make a palrment of $246.38
in connection with an eye exam;
On or about November L4, 2010, the credit. card issued
in PERALES's name was used to make a palrment of $70. 95
to .I.C. Penney for "toddler separate infant
sleepwear girls playwear" ;

36 A review of publicly available sources on the int.ernet. refl-ects that


Klunk is identified in the City of Chicago's employee directory as
a "committee secretary."

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On or about September 5, 2011, the credit card issued


in PERALES's name was used to make a payment of
$404.80 to Babies R Us for "childrens clothing
extended payment option" ;
On or about October 25, 2011, t.he credit card issued
in SOLIS's name was used to make a payment of $2,567
Lo an orlhodontist i
On or about September 30, 20L2, Lhe credit. card
issued in PERALES's name was used to make a palrment
of $L56.24 t.o Mario Tricoci Hair Salon;
On or about November 4, 207-2, Lhe credit card issued
in SOLIS's name was used to make a palrment of $180.68
to Macy's for multiple it.ems, including an item
described as "boys 8-20 Po1o";
Onor about May 19, 20L3, Lhe credit card issued in
SOLIS's name was used to make a palrment of $40.31 to
Nordslrom for "kids shoes";
On or about
November 25, 2013, the credit card issued
in PERALES's name was used to make a palrment of $197
to Mario Tricoci Hair S Ialon] ;

On or about December 23, 2013, the crediL card issued


in SOLIS's name was used to make a pa)rment of $131-.08
to Macy's for "cookware" I
On or about March 14, 201-4, the credit card issued
in PERALES's name was used to make a payment of $299
to Le Petite Skin Boutique,' and
In 2014, the credit card issued in SOLIS's name was
used to make palrments totaling $12,51p.70 to The
Frances Xavier Warde School, in monthly increments
of $1, l-85. Based on publicly available information
on the internet, The Frances Xavier Warde School is
an elementary school l-ocated in downtown Chicago.
Further, based on the investigation to date,
including wire interceptions over Target Phone 2, it
is known thaL SOLIS's son at.tended The Frances Xavier
Warde School in 201-4 and 20L5. Based on the
recurring naLure of these payments and evidence
indicating that SOLIS's son attended t.his school, I
believe SOLIS used his credit, card Lo make payments
relating to his son's education.

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L37. Financial records obtained during the investigaLion


further reflect that all payments made for crediL card charges
incurred on Lhe Ward Credit Card Account by SOLIS and PERALES were
made from a bank accounL held in the name of the 25tkr Ward Regular
Democratic Organization at ,J.P. Morgan Chase Bank (the "Ward Bank
Account") . A review of documents associated with the opening of the
Ward. BankAccount (the account was opened August 10, 2006) reflect
that the two authorized signatories appearing on the signature card
are SOLIS and PERALES. A review of deposit activity for the Ward
Bank Accounl reflects Lhe deposit of numerous checks into the
account, many of which bear a note indicating that they are
contributions.

37 Bank records obtained during the investigaLion reflect that Solis


has made three deposiLs totaling $35,000 into the Ward Bank Account,
wkrich were accompanied by notations as follows: (1) 2/L7/2O1-L:
$15, OO0 (notation: loan) ; (2) 5/4/20L2: $l-5, 000 (notation: l-oan
repayments) ; and (3) 4/L0/201-3, $5,000 (notation: loan repayment) .
With-respecL to the second deposit, the records reflect a deposit
of $15,000 from the Ward Bank Account inLo Solis's personaL bank
account on April 1"9, 20L2. Subsequently, on May 2, 20L2, a payment
of $l-5,809 was made from Sol-is's personal bank accounL to the
fnternal- Revenue Service. AccordinglY, iL is beLieved that the
second deposiL is a repa)rment of a loan taken Lo pay the IRS. With
respect to the third deposit, the records reflect a deposit of $5,000
from the Ward Bank Account into Solis's personal bank account on or
about December 18, 2A12. Subsequently, on or about December 21,
2A12, Solis wrote a $5,000 check off his personal account to Paleo
Fit Meals. Accordingly, it is beLieved that the third deposit is
a repa)rment of a loan taken to make a purchase from Paleo Fit Mea]s.
At this point based on the bank records availabl-e to the government,
no correLation has been drawn between Lhe 2/1-7/2011 deposit and a
prior loan. It appears from various bank records that Llne 2/L7 /201-L
deposit is derived from a $30,000 payment Lhat was deposited into
an account in the name of Solis Enterprises on or about 2/7/201A.
TLris money originated from Lhe Chicago Real Estate Consulting Group.
Records maintained by the Illinois Secretary of State reflect that
BRIAN HYNES is the regisLered agent for the Chicago ReaI Estate
Consulting Group. Based on the invesLigation to date, HYNES has
extended various personal benefits to Solis in 2Q1,4 and 2015, and

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funds
I believe SOLIS is utilizing
138 ' Based on the
foregoing'
organization to pay for his
Democratic
from 25th Ward Regular
personal expenses
statements
F. solrs,s False Exculpatory
fort'h below'" during the course of "" .n-person
l-39. As set l
meetingwithCs-].and.interceptionsoverTargetPhone2,solls,at
Limes,madereferenceLohisunwi}lingnesstoconducti}legal
activity.Asdiscussedbelow,Ibelievet'hesestatementsare
with or in
pretextua},astheyhaveoccurredduringthecourseofthecrimina}
Moreover' t'hey often occurred
conduct discussed above'
Lhecontextofind'ividualsaboutwhomsol,IsexpresseddistrusLand,
according}y,anunwillingnesstoengageincriminalactivitywiLh
them- SOLIS met
example' ofl or about October L7' 20L4'
l-40' For
privatelywithCs_].andBusinessman2,aChinesebusinessmanand
propertyd.eveloper.Duringthismeeting,sol,ls,CS-].andBusinessman
2discussedBusinessman2,srelationshipwithsol,Is,sformer
girlfriend.AformermemberofSoT,ls,sStaffactedasanEnglish
transfatorforBusinessman2d.uringthemeeting.Sol,lscJaimedduring
t:ll^:::t:,:j:"
that his former sirlfriend *"
the conversation
2. solrs also indicared durins ::"
the
,,"r,,essman
":: "":"J;r:], ,r, t.'"11 estate development
oII,
raxen--aJJi;; ; ii, ii ;*:;lqrrsr*i$lr:
,"rJ*rs Nadhmi
HyNEs
marrer"r"orhar s"r=i-"_.ir""
ffi ;; ;, 1 r. r: -is T
g1s, ooo-
f f"1"*";, ir*:ili
-
;='?""r"'*r -:::' : ;:
-"
".h"tl l.".orrrrr"non or "ooi,t 2/a6/2oLL-:^..;;. si""a 9n, the
,i|li\ZiJTir3;;;*ii'q;rh."-Ie',t.,'XXi.fu'f.TL""o,p","o,,aritems
i s- t::uti:tt.t".
f inanc iaf @LLs*r
trnartcrar anarYs-:ss
$l-5,000.
are well in exct "f

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conversation t.hat he was worried t.hat he was "going to be doing


something illegal. " soLIS also noted during the conversation
that

solls did not want anything to d.o with his former girlfriend and
another individual. Businessman 2 informed soLIS that Businessman
2 had paid $100,000 to soLIS',s former girlfriend. solfs responded:
..wow., soLIS explained that he understood his former girlfriend was
me' And that
'.se11ing access to me, t.hat she would. bring people Lo
is true because she was my girlfriend, but I didn't know whether she
was being paid. she t.old me nobody was paying her anything'" soLIS
explained that it was "very common" for such pa)rments to occur (and
that. CS-1 had paid SOLIS's ex-chief of staff) but that such pa)rments
just me'
had t.o be disclosed publicly: "So that happens a lot, not
with everybody, but you can'L Iie about it'"'

38 According Lo CS-1, in 2010, cs-l- and Businessman 2 invited soLIS and


others to Shanghai, China to attend a world t*go.?'-?";--1,"9t?lTl
attended this ".r"iit. Businessman 2 told that during this
cs-1
it to soLIS that Businessman 2 wanted soLIS',s
event, was communicated
supportforBusinessman2,spurchaseofavacantlotownedbyLhe
2 advised CS-1 that
Ciry of Chicago-itn. v"""nt riot). Businessman based on CS-1's
tre iaia cash1o SOLIS on two separaLe occagions; these cash
conversations with Businessmui Z, CS-1 undersLood
pa)rments to soiia were made in exchange for solrs's support of
Businessmanr 2' of the Vacant Lot' One of the cash
"-""q"Gition
pa)rments was madeib solrs during solrs,s trip to shanghai, china
in 2010. The other cashpaymenLiuas made to SOLIS in a coffee shop
in Chicago. netords maiitiined by the fed.eral governmenL. reflect
that solrs arr1vla in the united states on May 4, 2OlO, from shanghai,
China.
CS-1- provided Iaw enforcement with a copy *In of an email he sentwasto SOLIS
the emai1, which dated
at the email address dan4].o@mac.Com.
May9,2AAO,CS-laskedSOLIS:"Danny,how'syourtripinShanghai?
Welcome back t; Chicago." CS-1 went on t'o request sOLIs's
assistance in otr1ai"i"g-" liquor license for a resLaurant ' SOLIS
i"pii.a Lo rhe email- ori l,lay tb,. ZO1O. With respect_to his irip Lo
gg"d inunderstanding
China, SOLIS T="J., "p-s ifi" tr'ip was_vgty w/ investment from china, the
p"l""i:-"I for a..r!i"p*'"nt incfridago_ [sici
Lppecifica11y Isic] [Businessman 2] ' "

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meeting with CS-1


r4L. In an in-person' consensually-recorded
thatoccurredonJanuary2S,20]-5,SoI,lsagainexpresseddist,rust
girrfriend. specifically, solrs asked cs-1 to relay
of his former
tocertainChinesebusinessmenthathewashavinghisfundraiserand
that'heneeded..asmuchsupportastheycangiveme.,,lnresponse,
Businessman 2's project"'I'il sure he will
CS-l said regarding
has
you if you support him"' SOLIS responded"'Everything
support
tobelegalld.on,twantanythinglikewhathewasd"oingwith
[firstnameofsol,Is,sformergirlfriend].,,CS-1said:..No,[o.
Thisis}egitimatebecausehejustwanLLo.'.ultimately,Ithink
hewantstohotel"""soT,lsthensaid':"No'whatlmeanis'

uay zorol"liil:-= r-Joised that approximauel-v


AccordingtoCS-1,SOLIS's(n^ow)-formergirlfriendaccompaniedSOLIS
on his rrip ro di;;;
y.;;=*-;;,'-B-usin"s"*"J i fri-r.a -SoLIS's (now)because
former
rwo ro Lhree of t-he vacanL
tne_ acilri"It.i""
Lot
oirlf riend to2 rJcirit-"i.
fi;-;i- ir,. torrn"Jr--Jiiiiri""a; refationship with
iusinessman f rtr-i-t'"i-trit tnow)
- "
forler girlfriend-couId
sot,rs, and er"irr;I=*"t SotIS-;; itJp obtain a l-etLer
use her ref ationship wi.th """-tessfully 2's attempted
of support trom soljrs in connt";i;;iJr' eusj-t'"""*it'
the Vacant Lot'
prt"irr=" of
According to CS-1, Busines:if
2 advised CS-l- that SOLIS's former
qirlfriendu]-timatelycomplaineiioeusinessman2thatshehadnot
iaciritate the purchase of the
ieceived the necessary informatl;n-t.o z *"" not payino ti"r in a timely
vacant Lot, "'i-;dt'Businessmi"
f ashion ror neJ ;;i; ;;-;-iu"iiitJ;;t ior'is'" io'*" sirlf riend
i to,]td out his bid to purchase
thereforewithdrewBusinessm^n-iisbidtopurchasethevacantLot.
cs-1 advi".a rrrll'r;;; eusinessi"r,
witrraiawn' he was' furious' However'
the vacant L";l;;-;t"" Busines:T1",ft1;'"oi-s""r Lhe return of the cash
according Eo cs-l-, Businessman 2 believed SoLIS
"io'- to Sof,IS u-..."""
pa)rmenLs he-had ;J. in the future'
would "owe ntmi "o*tthing
in-person meeting with SoLIs
According to Cs-1, d'uring a differenL a pearl necklace as
and Businessman 1, Busine="*"ri-il;;;t;a'ggi,irs
solrs aeclined to accept
agift.(This-o?rttwasnot;;"";;'enforcei'rentdirectionor this
with Law..,ottJilll'"-rtto*I-td;;:)
coura:1'# tJt-t-i" iirtt valued less than
sift, ,rra .*p:'-"-itIJr:e
fifty dollars '

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according to what I hear, ISOLIS's former girlfriend] was asking for


money and I don'L knowwhaL the heII she was doing." In response,
CS-1 totd SOLIS that was in the past.
1,42. On or about May 21, 2oL5, dt approximately 12:1-5 p.m.
(Session #11518), SOLIS made an outgoing call on Target Phone 2.
During the ca11, SOLIS warned a female about his former girlfriend.
Specifically, SOLIS advised the female that no one should talk to
SOLIS's former girlfriend about maLters concerning SOLIS: "And
there's absolutely no reason why anybody should be calling Ifirst
name of former girlfriendl on issues or business t.hat involves me.
f don't Lrust that lady at aII. " SOLIS explained his concerns: "What
realIy got me concerned is I heard one time from somebody that.'s close
to [first name of former girlfriend], that she was saying she was
in on the deal with the hotel. That her and f were partners in that
dea1. And that's absolutely, not only it's noL true, I could noL
do that.. That is il1ega1. "

l-43. On or about May 29, 201,5, dt approximaLely 2:22 p.m.


(Session #3-209].'), SOLIS made.an outgoing call on Target Phone 2 to
a prospective consultant. During the-caII, SOLfS assauged the
prospective consultanL's concerns relaLing to poLential illegal
activity. Specifically, SOLIS said: "Hey, Iisten, I was t.hinking
about our conversation this morning. . f was just, wanted to make,
uh, uhm, something clear to You, cause r think you might have
misunderstood. I wouId, if, uhm, I think you could, uh, do very
well in the role I was telling you in terms of being a consultant,

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Uh, for some t,hese investors that are coming f rom China.,, The
prospective consultant said: "Yep." SOLIS continued: "But I would
never get any compensation for that, either directly or indirectly'"
The prospective consultant said: "okay. " soLIS continued: "Because
you, T, think when you guestioned'fs this legal?" I' you know'
absolutely, Uh, it probably would. not be legal, but even if it was
1egal and, it would be unethical. " The prospective consultant said:
.'Okay.,, SOLIS continued to note that "I geL compensation f or stuf f
I d.o be connected in washington, but not in chicago'" The
that may

prospective consultant asked. soLIS what the "nexL step" was' and
SOLIS replled.: "WefI, You know what'? Uh' you mentioned [name
redactedl . That's, LhaL's a possibility' The other possibility is

maybe, Lrh, uh, maybe it could also be my sister, Patti IDoYLE] .


or

Brian IHYNESI , or a combinat'ion Lhereof'" SOLIS suggested "a


conversation with Brian might, might he1p, " because "he actually has
more experience of any of the players we're talking about: me, Patti,
uh [name redacted]. Because he's been doing this for a long time'
He no }onger does it.. He'S no, no longer a consultant. He was a
lobbyist in springfield. He don't, he doesn'L do that anymore' He
doesn,t do that. in chicago. He has his own business where he's done
very well." The prospective consultant said: "sltre." soLIS
continued: "The only reason that the guy from London, uh, hired' him'
is, is, at my insistence, because I need an attorney I can trust'
and,llo,thatisrepresentinghimlAuchi]'"Theprospective
consultant said: "okay." soT,IS said: "which, which is the same

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reason I'd be interested in you, uh, becoming a, uhm, consultant


or

lobbyist.,, I believe soIJIS suggested directing work to the


prospective consultant in a conversation earlier in the d'ay that left
the prospective consultant with the impression that soLIS would
iI1egalIy benefit from this activity. Moreover, I believe soLIS',s
claim that he would not do anything illegal is pretextual- not only
because the prospective consultant was left with the impression
that
among other
SOLIS was proposing someLhing i11egal, but afso because,

things, of prior intercept.ions in which soLIS acknowled'ged that his


former girlfriend was hired by ind,ividuals to "buy" influence with
SOLIS, despite SOLIS's denial of knowledge of such activity to
CS-1

and Businessman 2."


a44.onoraboutJune25,2o].5,atapproximately1.0:51a.m.
(Session #1,3874) , SOLIS received an incoming call on Target Phbne
2 from HYNES. During the caI1, SOLIS t,oId HYNES about a recent
conversation he had with a zoning aLtorney regarding the Vacant' Lot
involving cs-l- and Businessman 2. soIJIs informed HYNES that he told
the zoning attorney, who represents Businessman 2, that everything
needed to be done legally due to the involvement of cs-l- and soLIS's
former girlfriend, with the project. specifically, soLIS said:
..speaking of developments, [name of zoning attorney] came i-nto Lo
see me this week... About the canal and Cermak property
that...remember [Businessman 2] wanted?" HYNES said: "Yeah, yeah'

39 In a subsequent conversation with the prospective consultant'


(Session #1"235'7\ , SOf,iS discussed her becoming an employee for the
City of Chicago.

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yeah, right.,, SoLIS said: ..And' then [first name of SoLIS,s former
girlf riendJ t'ried to give iL over to her boyf riend?,, I{YNES

responded.,"Right."SoLISsaid:"Andah'sonowthey're'he'sback
in t.he picture on it. And..." HYNES interjected, "who is?
The

boyfriend or lBusinessman 2] ? who is [the zoning at'torney]

representing?, soLIS indicated he was representing Businessman '


2

SOLIS continued'
HYNES said: " [Businessman 2] . Okay' Fine' Good"'

'.Aird. so, grrr, I told lfirst name of


zoning at'torneyl the history of
it and you know what, and I told [first name of zoning attorneyl '
youknowwhat,[firstnameofzoningattorneyJ?Becauseofthis
history, I want to make sure everything is on the up and up [done
1ega1ly1 . And so, um. . . I told him that I was gonna Lalk to some
people

int,hecityand.Iwasgoingtotalktoyoubecauselwanttomake
thing
sure that if r go ahead and do this, LL, s t.he, it's the right
to do and thaL none of this...because tcs-1], he was involved,
involved in both, with both sides. weII, he was involved" ' with
when they
Ifirst name of sol]s's former girlfriendl and her friends
tried to recruit ICS-1] to get investors from China to take it away
from[Businessman2]andnowwhenhecouldn'Lraiseit'nowhe's
involved with [Businessman 2] ' But when tCS-11 was involved with
.[firstnameofSol,ls,sformergirlfriend]andherfriends,I
hadnot,YoUknow,Iwasn,tsupport.ingit'.Ithinklfirst,nameof
SOLIS, s former girlfriendl was just counting that I was going to be
I
able to do it, Eh, even though we weren,t together or whatever.
don,t know...But it just, it looks, it sounds fishy and I'mnoL sure

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I should go along with it. and that's why I wanted to talk to you about
it." HYNES said: "Okay. No, definitely." SOLIS said: "So, anYway

lfirst name of zoning attorneyl will prob...might talk to you abouL


it.' HYNES said: 'tOkay. Yeah, I'Il be back on Tuesday"'
145. I believe that the various statements referenced above
regarding SOLIS's claims that "[e]verything has to be Iega1;" that
he would not do anything iIlegaI; that everything in connection with
Businessman 2 and CS-1 needed to be on the "up and up" were pre-textual
for a number of reasons. First, soLIS appears to want to distance
himself from any connection to his former girlfriend, particularly
in Iight of Businessman 2's disc1osure to SOLIS that Businessman 2
paid SOLIS' s former girlfriend in connection with the Vacant
$f 00, 000
Lot. As expressed by SOLIS to HYNES, SOLIS understood that the
payment was to buy access to soLIS, and soLIS no longer trusts his
former girlfriend. Moreover, Lhese statements occurred whiIe,
among other things: (i) SOLIS promised Lo take official action in
return for the retenLion of MADIGAN's firm by Businessman 1-; (ii)
information provided by CS-1 that Businessman 2 gave SOLIS two cash
pa)ment.s in exchange for SOLIS'S support of Businessman 2's
acguisitionoftheVacantLot.;(iii)thesteadyflowofbenefitsthat
SOLIS received while taking official actions for the benefit of the
indiwiduals providing him the benefits; and (iv) Lhe connections
SOLIS made between his requests and receipt of campaign contributions
and the official actions t.hat he took or was willing to Lake on behalf
of t.he contribuLors.

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I

G. The Subject Premises l' subject Location 2'


'145' With regard to Sujrject Location
SubjectLocation3'subjectLocatlon4'subject'LocationS'and
TargetFhone2andbasedonmytrainingandexperienceinfraudand
publiccorruptioninvestigat.ions,Ibelievethat.publicofficials,
suchasS0T,Is,maintainvariousrecords,inbot'hpaperande}ectronic
format,withintheiroffices,placesofbusiness'residences'and
the following:
telephones, including including financial
financial records
a' CamPaign
reports'
contribuLions and expenditure records'
donations, in-kind
ledgers and receiPLs;
fund'raising activities
b' Information related to
includingadvertisemenLs'photographs'inviLations'letLersorevents;
and/or aLtendees at fundraising
records of contributors records of potent'ial
or
or other
c' Lists' spreadsheets
including' but not limited to'
actual campaign contribuEors
contiibuLorswithpotentialmattersbeforetheChicagoCityCouncil
or committee thereof;
or a representative body staff
schedules and comrm:nications of
d' Calendars'
members;
and correspondence concerning maLters which
e' T'etters
haveappearedormaylikelyappearbeforetheChicagoCityCounci}
orarepresentativebodyorcommitteethereof,includingtheZoning
as actions taken on Lhese matters;
as
CommitLee, well

L02
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f. Credit. card statements, bi11s, payment

records/Iedgers or receiPts;
g. Employee palrment records, to include IRS reporting
documents such as forms L099 or W2;

h. proof of occupancy, such as as utility and telephone

bi1ls, mail envelopes, or addressed correspondence, which in turn


demonstrates possession, control and association with other
evidence relevant to the investigation;
i. Computers, electronic devices and removable media
storage devices which may conLain information related to the above

items.
i. Subject Location 1
L47. As further described in Attachment A-1, Subject Location
1 is SOLIS's Cit.y HaII office. On March 8, 20L6, CS-t visited SOLfS's

office aL at Subject Location 1 at the direction of the FBI. .CS-1


was equipped with concealed video and audio recorders. According
t.o CS-l- and as observed on the video, Subject Location f- is behind
a door that states "Commj-tLee on Zonirrg." Subject Location l bears
SOLIS's name and office number, 304. According to CS-1 and as
observed on the video, CS-l entered Subjeet Location l and spoke with
a legislative aide and an unknown woman, who were located inside
Subject Location 1.
L48. As discirssed herein, SOLIS is the Chairman of the City
Council's Zoning, Landmarks & Building SLandards CommiLtee.
Furthermore, SOLIS has agreed t.o take official action on multiple

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the Zoning Committee


occasions with respect to maLters pending before
and elsewLrere. owing to his chairmanship
of the Zoning committee'

andhisparticipationintheaffairsoft'heCityCouncifitis
reasonabletobelievethat,soI,lsmainLainswithinhisCityHall
that wilr be heard
office documents rerating to deveropment. projects
and have been heard.by the Zoning Committee,
inc}uding those projects
possession of documents
that are discussed in this affidavit. SoLIs, s
withrespecttothoseprojectsonwhichhehasagreedtotakeorhas
taken official action on is itself proof of
his participation in the

SubjecL Offenses under investigation'


L4g.BasedontheiruseoftelephoneslocatedwithinSubject
I have identified
I,ocation 1, as well as a review of public record.s,
CityofChicago.employeeswhoworkasapartofSoLlS,ssLaffwithin
SubjectLocationl.Asnotedonmult'ipleoccasionsherein,Solls
hasmainLainedcontacLwiththeseemployees(includinghis
information
Iegislative aides) for the purpose of obtaining
concerningtheprogressofpendingprojects,todirecttheoperation
ofhisofficeandtoobtaininformationabouthisschedule.
l50.InaddiLion,basedoninterceptedConversations,
in paragraph l-34'
including the intercepted conversation set forth
and/or received
I believe a legislaLive aide prepared, maintained'
wished to receive
Iists of individuals and entities for whom soLIS
amonetarycontributionfrom,aswellastheofficialactionthat
thesecontributorswishedsol,lstotake.]tisthereforereasonable
tobelievethatcopiesoftheselists,dswellasinformation

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concerning contributors, the benefits they and others have conferred


on SOLIS, and official acLion taken or to be taken on their behalf
will be found within Subject Location L.
151- Additionally, as set forth above, legislative aides to
SOLIS have scheduled meetings with individuals, including the Water
commissioner, and handl-ed requests from individuals, such as
CALDERO. It is therefore reasonable to believe that i-nformation
relating to these requests will be found within Subject Location 1.
ii. Subject Location 2

L52. As further described in ALtachment B-1, Subject Location


2 is solrs's 25th ward constituent service office. According t.o the
website ward25.com, SOLIS's 25th Ward constituent service office is
Iocated at 1800 South Blue Island. During recenL surveillance on
March L, 2016, however, surveilrance observed t.hat sol,rs, s 25th ward
office was located at subject Location 2, as shown on At.tachment. B-1.
l-53. According to a St,atement of Economic fnterests f iled by
solrs with the cook County Clerk on or about May 1, 201-s and on May
2, 20L6, SOL]S identified the ,zSLh Ward Regular Democratic
organization as a political organization with which he was involved
and from which income in excess of $1,200 was derived during the
preceding year. SOLIS idenLified Subject Location 2 as the address
of 25th Ward Regular Democratic Organization in his Statement. of
Economic rnterests filed on May 2, 2oJ-6. According to a statement
of Financiar rnterests fired by solrs with the city of Chicago on
or about May L2, 20]5, sol,rs also identified the 25th ward Regular

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Democraticorganizationasapoliticalorganizationwithwhichhe
wasinvolvedandfromwhichhereceivesincomeinexcessof$1.000
theprecedingyear.so],]sident'ifiedSubjeeEl,ocation2asthe
ad.dress. of the 2Sth Ward Regular
Democratic organization'
Regular Democratic
154. As noted' above' tkre 25xn Ward'
organizationhasmaderegularreportstothel}linoisStateBoard
ofElecLionsconcerningmonetaryContributionsreceivedbythe2sth
Under law' reporting
Ward Regular DemocraLic Organization'
Democractic organizat'ion are
entities such as the 25t.h ward Regular
requiredLomainLain,fortwoyears,record.sconcerning(1)thetotal
contributionsmadetoorforthecommitLee,Q)thefullnameand
mailingaddressofeverypersonmakingacontributionandthedate
andamountLhereof,(3)thetotalexpendituresbyoronbehalfof
Lhecommittee,Glthefullnameandmailingaddressofeveryperson
towhomanyexpenditureismade'andLhedateandamount'thereof;
particulars' for every
and (5) proof of payment' stating the
expendituremadebyoronbehalfofthecommittee.Itherefore
amounLs of money and other
believe that documents detailing the
benefitsreceivedbySo}isand'theorganizaLion,theidentityof
iontributors,andthet'imingofthereceiptofsuchcontributions
and benefits witl be found within
subject Location 2' together with
1-46 above '
the other items specified in paragraph
155.Inaddit'ion,asnotedinparagraphs]-36throughl38,there
isreasontobelievethatsol,lshasLakenfundsfromthebankaccount
usedbythe25LnWardRegularDemocraticorganizationforhis

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ward Regular
personal use. It is reasonable to believe that the 25th
Democrat ic organization will- maintain records
concerning IegitimaLe

expensesincurredbytheorganizationinthecarryingonofits
politica}activities.Thisinformationisrelevanttothis
what are
investigation, because these records wilI tend to establish
permissible
permissible expendit.ures (and the reasons for those
expenditures)asopposed'tothepersonalexpensesofsoI,lsand
PERALES' that have been paid through the
use of organization funds '

iii. Subjeet' Location 3

156.AsfurtherdescribedinAt'tachmentC-l,SubjectLocation
3 is soLIS, s personal residence. The residence
is identified by the
number,,522,,affixed.tothewalladjacent.tot'hedoor'According
toutilityrecordsreceivedonoraboutAprilLg,2Ot6,.sOllsis
ident,if ied as the resident of record f or Sulrj ect
l,ocation 3 .

Location
According to lllinois secretary of state records, subject
26, 2o'l-5, as
3 is identified as solrs,s residence. on April 25 and
registered
welI as May 11-, 20:6, surveillance observed t',he vehicle
in which
to soLIS parked. in the front turnaround area of the building
Subject Location 3 is located'
l,5T.Basedonmytrainingandexperience,individualsmaintain
documenLsregardingtheirpersonalfinances,Ioans,andexpenditures
journals or
within their residences, Lo include (a) books, records'
records'of
other records of original entry; (b) Iedgers and other
assets, Iiabilities, oI capitat account balances; (c) records of
j-nvoices and receipts; (d) records of
income or expenses including

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Iessors or lessee; (e) records of receipts or disbursements; (f)


accounting information; (g) bank statements, check registers, or
canceled checks; (h) duplicate deposit tickets; (i) bank account
reconciliations; (j) passbooks, certificates of deposit, money
orders, or cashier's or official checks; (k) records of payroll or
employee earnings, (I) records of bartering activity such as
exchanges of property or services; (m) financial statements or
copies of tax returns; and (n) credit card statements, bills, payment

records/ledgers or receipts.
158. Records concerning SOLIS's personal finances are relevant
to the investigation of the Subject Offenees for multiple reasons.
Among them are the following. First,, ds noted earlier in t.he
affidavit, thus far no evidence has been found to demonstraLe that
SOT,IS has paid for the benefits lavished upon him by others. Records

documenting expenditures SOLIS has made will a1low investigators to


determine what it.ems and services SOLIS has paid for, and will also
help establish which benefits he has not paid for. Establishing the
extent of payments SOLIS has made, and for what, items and services,
wilt establish what items and services he has not paid for are
connected to an illicit purpose. Second, records concerning SOLIS's
personal finances woul-d tend to show his inabilit.y to pay for many

of the benefits he has received, such as the use of LATSKO's


mult.i-million dotlar farm. Third, because individuals typically
maintain documents relating to their finances at home, it is
reasonable to believe that SOLIS would maintain documents relating

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t.o any loans he received fromGARY FEARS, referenced above in footnote


L7, at his residence in the event such documents exi-st.. such
documenLs would d.emonstrate the terms of the roan and any payments
that have been made with respect to the 1oan. In addition, documents
tending to show a lack of formality or memorialization concerning
the terms of the loan would tend to demonstraLe that this loan was
concealed and therefore made for an illicit purpose. Fourth, because
individuals typically maintain records concerning their personal
expenses at home, it is expected that t'hese d.ocuments will be found
at Subject Location 3, and that these d"ocuments will- confirm that
certain expenditures made by using his debit card associated
SOLIS
with the 25t.h ward Regular Democratic organization (such as, for
exampre, school- tuition expenses) are in fact personal expenses.
Final1y. it is reasonable to believe that SOLIS wiIl also maintain
in his residence documents relating to economic and other benefits
he has received, incruding benefit,s received from third parLies, such

as the individuals identified herein who have provided him with


benef it.s
iv. Subject Location 4

159. As furt.her described in Attachment, D-1, subject r,ocat,ion


4 is the residence of SOLIS's wife and son and SOLfS's other residence.
rn his Statement of Financial rnLerests that he fil-ed with the City
of Chicago on May 2, 20]-6, sol,rs identified subjeet Location 4 as
the residence of his wife. on April 25, 2ot| at approximately 9:12
d.IIt., on April 26, 2016 at approximately 9:28 a.m., on May 11 , 207_6,

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ai Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 26 of 26 PageID #:135

at approximately B:55
at approximately g:05 a.m., on May 12, 201-6,
a'm' ' on May 25' 20A6
d.In., on May 17, 2015 at approximately 9:00
at approximately 8 :28
at approximately 8 :14 a 'm' ' and on May 26 ' 2016
d.ITI.,FBIsurveillanceobservedavehicleregistered.toSoI,lS}eaving
theparkinggarageatsubjectLocation4.FBlsurvei}lanceobserved
soLISaSthedriverofthisvehicleonApril25,20l.6andMayll,
20.,6,.and on other occasions was not able
to positivety identify the
driver.Althoughsurveillancewasunabletodeterminethedriver
oftheseotheroccasions,nooneelseotherthanSol,Ishasbeen
observeddrivingthisvehicleduringsurveillance.Withthe
observed
exception of May L2, May 17 and May 25' FBI surveillance
t,hevehic}eproceedtosubjectl,ocation3.Basedonintercepted
ConversationsinJutyandAugustof2ol-5,so],lsand.hiswifewere
workingtoresolvemaritalissuesandhadbegunlivingtogetheragain
afteraperiodofseparation.Atthesametime,so],lscontinuesto
maintainhisresidenceatsrrbjectLocation3.
and experience'
1-60. As discussed above' based on my training
individua].smaintaindocumentsregardingtheirpersonalfinances,
loans,andexpenditureswithint'heirresidences.Asnotedabove,
theWardCredit'CardAccounthasbeenusedforexpendituresthat
appeartobeassociated.withSolls,sfamily,toincludeschool
tuitionpaymentst'oSOLIS'sson'sschool'palrmenttoanorthodontist'
and.paymenLsforcookwareandchildren,sclothing.BecauseSoLlS,s
that at Subject
wife and son live at Subject Location 4, it is expected
that certain
I,ocation 4, there wilt be documenLs confirming

110