Sei sulla pagina 1di 26

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 1 of 26 PageID #:110

extracting financial support
construction, s project and anticipated
McHugh Construction think
SOLIS he (GAYTAN) would make
project; and (iii) SoT'Is advised
company's hotef anddata center
for the benefit of McHugh before City Council
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
SOLIS indicated he had' and then
anyone for your campaign yet' Dan?'
figuring out how to helP out ' GAYTAN indicat'ed "LheY" lwhich

l':I t\:z:':-.-.|,::: --ii=a:_,b:r-i-:!

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 2 of 26 PageID #:111

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. "

-.: f !:_-.+r-:j-. '-:! -l )t;:-.;-\-. -.-..

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 3 of 26 PageID #:112

and GAYTAN explained

their hotel/data center deveropment project,
to provide financial
to solrs that McHugh construction wished
on November 10' 201-4' at'
1-30. Approximately one month later'
Wintrust. and the guys from McHugh Construction'
SoLIS was attempting to make good
She is my fundraiser [ ' ]' I believe
thistextmessagesreferenced"Wals I."'abelieveSOL]sintendedto

' i
i,,.:;:.r:..,! \- I f!,):r1 ,r-t
Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 4 of 26 PageID #:113

to refer to McHugh
believed SOLIS merely used the wrong name
' vi. Elgin SweePing'
Chris CacciaLore,
t'hat he hoped. the President of Elgin Sweeping,
Sweeping previously
Co. on or about September 2a' 2015' Elgin
on or about September 29 '
donated $2,500 to Citizens for Danny Solis

Subject l,ocation l,
aide who works in SoLIS,s City HalI office,
from SOLIS.

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 5 of 26 PageID #:114

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").

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 6 of 26 PageID #:115

isitthattheyareaskingfor'orwhatisitthattheywantmeto said:
said: "That's whaL I put-" SOLIS
do-oh. " The legislative
just to refreshyourmemory'"
havebeendoing that
said: "okay, yeah, I
SoLIs said: "okaY' alright'
10' 2oL5' at approximately 2:14 p'm'
135 - on or about

(Session#18553),soLISp}aced.anoutgoingcallonTargetPhone2 that
During the call' the fundraiser told SOLIS
to his fundraiser'

I t*.::t '|':':ii?
'.,. ,,. ':. -ra::r' ' t?n*11-t 'l
Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 7 of 26 PageID #:116

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."

jrt::'t2 !a;. a.. : - :.. ; .! y,.ltl:{,..:-:!,

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 8 of 26 PageID #:117

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.

;,,.: I ii';a:+<r:.., 1. : :._ :4.:1ja..:::itzid-

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 9 of 26 PageID #:118

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

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

'.: :.l t*;*:;1!:.:-:':',a'z;: .,'*:1t:+ Pl*'":'.'t'

- a- - a
Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 10 of 26 PageID #:119

I believe SOLIS is utilizing
138 ' Based on the
organization to pay for his
from 25th Ward Regular
personal expenses
F. solrs,s False Exculpatory
fort'h below'" during the course of "" .n-person
l-39. As set l
with or in
Moreover' t'hey often occurred
conduct discussed above'
them- SOLIS met
example' ofl or about October L7' 20L4'
l-40' For
that his former sirlfriend *"
the conversation
2. solrs also indicared durins ::"
":: "":"J;r:], ,r, t.'"11 estate development
raxen--aJJi;; ; ii, ii ;*:;lqrrsr*i$lr:
,"rJ*rs Nadhmi
marrer"r"orhar s"r=i-"""
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 s- t::uti:tt.t".
f inanc iaf @LLs*r
trnartcrar anarYs-:ss
are well in exct "f

1.- ._,r1:..:- ._.; 414:!>!ii.. .- i ..'. .: lf :.-:-r.11:---i
Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 11 of 26 PageID #:120

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

something illegal. " soLIS also noted during the conversation

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:, 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
it to soLIS that Businessman 2 wanted soLIS',s
event, was communicated
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
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,
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.
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] ' "

i:.}::*t1-, : l!'_ ' ..t:'.. i

a, . |''t:l;-: !a-, r.:::1- .,''r'::,\r' ;;t3:.:

-- r. , Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 12 of 26 PageID #:121

meeting with CS-1

r4L. In an in-person' consensually-recorded
girrfriend. specifically, solrs asked cs-1 to relay
of his former
Businessman 2's project"'I'il sure he will
CS-l said regarding
you if you support him"' SOLIS responded"'Everything

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

on his rrip ro di;;;
y.;;=*-;;,'-B-usin"s"*"J i fri-r.a -SoLIS's (now)because
rwo ro Lhree of t-he vacanL
tne_ acilri"It.i""
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 """-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
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
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 '

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 13 of 26 PageID #:122

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 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,

. J ',+-:L i'?:,:Z':::.'1't :'*'L!:'>l&!:

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 14 of 26 PageID #:123

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] .


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'
consultant said: "okay." soT,IS said: "which, which is the same

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 15 of 26 PageID #:124

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


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
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

and Businessman 2."

(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.

; l \r.:.::4:;:: :.:.;:: ' '.,'.: +'.i 1>{.!i..1
Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 16 of 26 PageID #:125

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

in t.he picture on it. And..." HYNES interjected, "who is?

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

representing?, soLIS indicated he was representing Businessman '


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 '
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

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
involved with [Businessman 2] ' But when tCS-11 was involved with
SOLIS, s former girlfriendl was just counting that I was going to be
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

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 17 of 26 PageID #:126

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
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.

-;1 - '-.r:.1 tnn';;:t-'-' '.:
'- ;a .:.1 t?;:ta1!;r?.r:.::;-.
' .'* #+r-Yiri-l': l

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 18 of 26 PageID #:127


G. The Subject Premises l' subject Location 2'

'145' With regard to Sujrject Location
the following:
telephones, including including financial
financial records
a' CamPaign
contribuLions and expenditure records'
donations, in-kind
ledgers and receiPLs;
fund'raising activities
b' Information related to
and/or aLtendees at fundraising
records of contributors records of potent'ial
or other
c' Lists' spreadsheets
including' but not limited to'
actual campaign contribuEors
or committee thereof;
or a representative body staff
schedules and comrm:nications of
d' Calendars'
and correspondence concerning maLters which
e' T'etters
as actions taken on Lhese matters;
CommitLee, well

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 19 of 26 PageID #:128

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

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

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 20 of 26 PageID #:129

the Zoning Committee

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

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

SubjecL Offenses under investigation'

I have identified
I,ocation 1, as well as a review of public record.s,
Iegislative aides) for the purpose of obtaining
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

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 21 of 26 PageID #:130

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, 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


Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 22 of 26 PageID #:131

ad.dress. of the 2Sth Ward Regular
Democratic organization'
Regular Democratic
154. As noted' above' tkre 25xn Ward'
Under law' reporting
Ward Regular DemocraLic Organization'
Democractic organizat'ion are
entities such as the 25t.h ward Regular
particulars' for every
and (5) proof of payment' stating the
amounLs of money and other
believe that documents detailing the
and benefits witl be found within
subject Location 2' together with
1-46 above '
the other items specified in paragraph

".V : I i*:-?a:lt a:.:.a :. .:,+:2ni, >;nrr,r-.]

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 23 of 26 PageID #:132

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

what are
investigation, because these records wilI tend to establish
permissible expendit.ures (and the reasons for those
PERALES' that have been paid through the
use of organization funds '

iii. Subjeet' Location 3

3 is soLIS, s personal residence. The residence
is identified by the
ident,if ied as the resident of record f or Sulrj ect
l,ocation 3 .

According to lllinois secretary of state records, subject
26, 2o'l-5, as
3 is identified as solrs,s residence. on April 25 and
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'
journals or
within their residences, Lo include (a) books, records'
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

,... I t,'::.--.:-. -.-: += :- !+! i.

I Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 24 of 26 PageID #:133

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

! -:,. I 5:;-.>.;-,i-_

Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 25 of 26 PageID #:134

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
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,

:' '.1

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
20.,6,.and on other occasions was not able
to positivety identify the
exception of May L2, May 17 and May 25' FBI surveillance
and experience'
1-60. As discussed above' based on my training
that at Subject
wife and son live at Subject Location 4, it is expected
that certain
I,ocation 4, there wilt be documenLs confirming