Robert Simpson - Cook County State's Attorney

IIIREASONS FOR DENYING THE PETITIONThe facts of this case alone are sufficient reason to deny defendant’s request forclemency. The facts demonstrate that defendant had planned this armed robbery and that he waswilling to commit murder in order to achieve that goal. Prior to the armed robbery defendant laidout the plan for his co-defendants. Defendant and his accomplice, LaGroan, entered the store,spoke briefly to an employee and then returned to the car. Obviously, the purpose of this first visitto the store was to case it and see where the service counter was. Defendant then told hisaccomplices that he intended to rob the store and that if anything happened, he would “pop”someone. Defendant told LaGroan that she was to take the money and put it in her purse. Youngwas to remain in the car and act as the getaway driver.When LaGroan and defendant reentered the sore, defendant approached the service desk,showed his gun to an employee and announced a stickup. When the employee stated, “you’ve gotto be kidding”, defendant knocked her to the ground. As defendant was putting money intoLaGroan’s purse, Mrs. Lindich approached. Defendant turned to the victim and said “oh, you wantto help.” He then shot Mrs. Lindich in the throat, killing her. At trial, three store employeesidentified defendant as the man who was behind the service desk holding a gun. A store customeridentified defendant as the man she saw passing in the lane next to her, after she heard a man say,“This is a stick-up” and heard a loud “pop.” Two of the store employees and the customeridentified one of the guns recovered from defendant’s storage locker as the weapon they sawdefendant holding at the time of the offense. Defendant was identified as the culprit by severalwitnesses at a lineup and at trial.28