Subpoena puces Tecum - IllinoisCorruption.net

IN THE CIRCUIT COURT OF COOK COUNTY
COUNTY DEPARTM ENT, CRIMINAL DIVISION
PEOPLE OF THE STATE OF ILLINOIS )
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v.
ANNABEL MELONGO
Defendant
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MOTlONTO OUASH SUBPOENAS
No. 08CR I 0502
The People of the State of Illinois, by and through thei r Attorney, ANITA
ALV AREZ, State's Attorney of Cook County, through her assistants, Robert Podlasek
and Julie Gunnigle. and request that this Honorable Court to quash the Defendant's
subpoenas issued to the complainant, Carol Spizzirri, the Illinois Department of Public
Health, fonner Save A Life board member Douglas Browne, and fonner Palati ne Mayor
Rita Mullins and in support state the following:
I. The Defendant haS-been charged with three counts of Computer Tampering
relating to her authorized access of the Save A Life Foundation's servers and the
email accounts '6ftheir founder, Carol Spizzirri.
2. The Defendant has issued a subpoena to Carol Spizzirri, commanding her
appearance to testi fy and to bring the following:
a. Documentation (emails, memos, faxes, documents of any kind) with
description of computer events as they happened from April 2S lh _ May 1 st
2006 at Save A Life Foundation, located in Schiller Park, Illinois. This
should include the computers affected, list of persons hired to fi x it, the
type of files affected, percentage of files recovered as we ll as the names of
tcchnician(s) recovering the files.
b. ALL communication(s) (emails, memos, faxes, documents of any kind)
yo u have in your possession regarding the above cited computer events.
Communications should be, among other [sic], exchanges wit h th e Illinois
Schiller Park Police department, the Illinois Attorney General, Brian

Public Health were not involved in the day to day operations ofSALF. The
Defendant has not demonstrated that these documents are evidentiary, relevant,
and requested in good faith.
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8. The Defendant's subpoenas also command the appearance of Douglas Browne,
who is currently residing in Georgia, and the appearance of the Illinois
Department of Health in Springfield. Before these witnesses travel to Cook
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County at considerable inconvenience and personal expense, the People request
an opportunity to be heard on this matter.
9. Additionally, the State has not been served notice of any of the subpoenas and
requests both notice and an opportunity to be heard on all outstanding subpoenas
and future subpoenas issued by the Defendant.
Wherefore, the People of the Stale of Illinois ask that this Honorable Court
quash the subpoenas issued by the Defendant or, in the altemative, set this mailer
for hearing at st;lch a time before such appearances are commanded.
,
Jul e
sistant State's Attorney

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f; For its work during 2006, the firm's South Florida offices won the
Florida Chief Justice's Law Firm Commendation Award for Pro
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Bono Work, presented in January 2007 .

PEOPLE OF THE STATE OF ILUNOIS, )
Plaintiff,
ANNABEL K. MELONGO
TO: Douglas Browne
2851 Eyans Woods Dr.
Atlanta. GA 30340
IN THE CIRCUIT COURT OF COOK COUNTY, IlliNOIS
....
COUNTY DEPARTMENT, CRIMINAL DIVISION
v. No. 08 CR-10502
Defendant.
Subpoena Duces Tecum
YOU ARE COMMANDED to appear to testify before the Honorable Judge Mary M. Brosnahan
in Room 303, 2650 S. California Ave., Chicago, Illinois on March 3rd h 2010, at 9.30 am.
YOU ARE COMMANDED ALSO to bring the following:
1. Provide documentation( emails, letters, faxes, memos, financial statements, documents of any
kind) on the computer events as they happened from April 28 th - May 1 st 2006 at Save A Ufe
Foundation, located in Schiller Park, Illinois. This should include the computers affected, list of
persons hired to fix it, the type of files affected, name of experts hired.
2. Any document{s) you might have in your possession regarding the events. Documents should be
among other: any documents, emails, fax with the Illinois Schiller Park Police department, the
Illinois Attorney General, Brian Salerno, Don Peters, Dick Devine, Cook County State Attorney or
any emails exchange with ANY Save A Ufe Foundation employees regarding the incident.
Exhibit C