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IN THE CIRCUIT COURT OF COOK COUNTY

COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS ) ^ ^ ^ ^


^
) ^
v. - ) No. 08CR10502
)
ANNABEL MELONGO )
Defendant )
t

MOTION TO QUASH SUBPOENAS

The People of the State of Illinois, by and through their Attorney, ANITA

ALVAREZ, 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, former Save A Life board member Douglas Browne, and former Palatine Mayor

Rita Mullins and in support state the following:

1. The Defendant ha&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 of their founder, Carol Spizzirri.

2. The Defendant has issued a subpoena to Carol Spizzirri, commanding her

appearance to testify and to bring the following:


a. Documentation (emails, memos, faxes, documents of any kind) with
description of computer events as they happened from April 28lh - May 1st
2006 at Save A Life Foundation, located in Schiller Park, Illinois. This
should include the computers affected, list of persons hired to fix it, the
type of files affected, percentage of files recovered as well as the names of
technician(s) recovering the files.

b. ALL communication(s) (emails, memos, faxes, documents of any kind)


you have in your possession regarding the above cited computer events.
Communications should be, among other [sic], exchanges with the Illinois
Schiller Park Police department, the Illinois Attorney General, Brian
Salerno, Don Peters, Dick Devine, any personnel at the Illinois Attorney
General office and ALL Save A Life Foundation former employees on the
incident.

Documentation (emails, memos, faxes, documents of any kind) on why


Christian Sass was fired by Save A Life Foundation. Also provide
documentation on the state of the network, Scantron after the Defendant,
Annabel Melongo left the company.

Documentation (emails, memos, faxes, documents of any kind) describing


the Schiller Park Police Department investigation. Description should
include the name of police officer(s) that came to SALF to take report
[sic], name of the police investigator and the specific questions asked.
Names of individual(s) having gone to the Schiller Park Police building as
part of the investigation. Letter Commanding Schiller Park's Detective
William Martin.

List contact information (emails, fax, address, phone) of ALL experts


hired for the computed incident that occurred in April 28th- May 1st 2006
at Save A Life Foundation headquarters in Schiller Park, Illinois. Also
provided [sic] bills, invoices as well as copies of checks or bank
statements resulting from their services.

ALL copies of pay stubs issued to you by Save A Life Foundation during
the years 2005, 2006, 2007. If not available, copies of back statements
showing deposits being made.

Documentation (emails, memos, faxes, documents of any kind) on


individual(s) that were instrumental in helping Save A Life Foundation be
in Illinois' state budget and in providing funds for SALF Springfield's
office.

All documentation (emails, memos, faxes, documents of any kind)


showing earmarks/money received from CDC (Center of Disease
Control), DoD (Department of Defense), National Guard, Chicago Public
Schools, Homeland Security, FEMA.

Contact information (address, fax, phone, email) on all companies having


audited Save A Life Foundation over the years. The information should
include the start and end date(s) for each company.

Provide ENTIRE personnel files of the following employees: Christian


Sass, Dave Stolerow, Saquan Gholar, Bob Cokinis, Vince Davis, Robert
Barnes, Dane Neal, Alfredo Salgado, Linda B. Reyna. Also provide ALL
copies of checks/proof of salary issued to those employees.
k. Provide copies of the two checks given to Defendant, Annabel Melongo as
[sic] result of her services at Save A Life Foundation, Inc.

1. Provide name of temporary agency that employed Anne Rickert who is


mentioned in the attached ABC investigative report's transcript, Attached
Exhibit 'A.'

m. Provide all documentation (emails, memos, faxes, letters, bills, invoices,


checks issued, financial records, documents of any kind) pertaining to
Hogan & Hartson LLJP as part of its governmental consulting services as
stated in your 2005 and 2006 auditing reports, Attached Exhibit "B."

n. Provide ALL documents (recovery recipes, payments to experts, expenses,


recipes/invoices of any kind) showing proof of the financial lost [sic] of
$1,000,000 due to the computer's incident [sic] as stated in the May 2008,
Grand Jury.

o. Provide documentation (emails, memos, faxes, letters, financial records,


documents of any kind) for the donation in the amount of $25,000 by the
Illinois Attorney General to Save A Life Foundation, Inc. Attached
Exhibit "C"

3. To warrant the use of a pre-trial subpoena, the Defendant must show l)sthat the

documents requested are evidentiary and relevant; 2) that the documents are not

otherwise procurable reasonably in the advance of trial by exercise of due

diligence; 3) that she cannot properly prepare for trial without the production and

that failure to obtain the documents may tend to unreasonably delay trial; and 4)

that the application is made in good faith and is not intended as a general "fishing

expedition." People v. Daniels, 805 N.E.2d 1206 (111. App. 2004). The Defendant

has not made such a showing.

4. A pretrial subpoena must comply with all four elements to be validly issued. A

reading of the subpoena issued by the Defendant in this case clearly shows a

fishing expedition and the fact that the subpoena was not issued in good faith.
Specifically, her requests include the entire personnel files of individuals not

involved in the incident, the pay stubs or bank account records of the alleged

victim, and the results of any audit ever performed for Save A Life Foundation

(SALF). These documents are wholly unrelated to the charges against the

Defendant.

5. Further, even in the event that these documents might have evidentiary value, the

Defendant has not demonstrated that these documents are not otherwise

procurable reasonably in advance of trial by the exercise of due diligence.

Through the discovery process the Defendant had been provided with the some of

information she has requested, including the names of individuals working to

recover data at SALF, the types of files affected, and the names of the police

investigators who came to SALF to take the report. Asking the victim in this case

to recreate information the Defendant already has is unreasonable, duplicative,

and not made in good faith.

6. The Defendant has made similar unreasonable demands of the Illinois Department

of Health (EXHIBIT B), former SALF board member Douglas Browne

(EXHIBIT C), and former Palatine Mayor Rita Mullins. The Defendant demands,

among other items, all communications, purchase orders, and invoices between

SALF and the Department of Health, Mr. Browne's pay stubs, and all

documentation "instrumental in helping Save A Life Foundation be in Illinois

budget." (EXHIBIT C, item 5).

7. These requests are unrelated to the investigation of computer intrusion at the Save

A Life Foundation. Mr. Browne, Ms. Mullins, and the Illinois Department of
Public Health were not involved in the day to day operations of SALF. The

Defendant has not demonstrated that these documents are evidentiary, relevant,

and requested in good faith.

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

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 State of Illinois ask that this Honorable Court

quash the subpoenas issued by the Defendant or, in the alternative, sel this matter

for hearing at such a time before such appearances are commanded.

RespectjjiJly submitted

N
Julie Gunra^ley -^_
>A«sistant State's Attorney
CliRTlFlCATKOFSHRVin;

I, the undersigned, state that have served the attached Motion to Quash upon:
Annabel Melongo
P.O. Box 1537
Addison, IL 60101

by mailing it first class mail, with sufficient postage attached this 21s1 day of February,
2010. Per the Defendant's request, she was notified at 630-220-4132 that a paper copy
was available at the State's Attorney's Office.

uife uunttij
ssistant State's Attorned

:•
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS,

Plaintiff,

No. 08 CR-10S02

ANNABEL K. MELONGO

Defendant.

Subpoena Duces Tec urn


TO; Carol Spizzirrt
» ■> *
■ » >

17479 Dartmoor Court,

Grayslake, IL 60030

Telephone; 847-366-1124

YOU ARE COMMANDED t o appear t o testify before the Honorable Judge Mary M. Brosnahan

In Room 303, 2650 5. California Ave., Chicago, Illinois on March 3 rd 2010, at 9.30 am.

YOU ARE COMMANDED ALSO to bring the following:

1. Documentation( emails, memos, faxes, documents of any kind ) with description of computer
events, ^^hey1nsppenedirorrrApr\\^2,8'h ^ May 1^^006"atSweA^LtfeFoundatTdn, Jocatrdln
Schiller Park, Illinois. This should include the computers affected, list of persons hired to fix It,
the type of files affected, percentage of files recovered as well as the names of technician^)
recovering the fitesr

2, ALL communication(s) (emails, memos, faxes, documents of any kind ) you have in your
possession regarding the above cited computer events. Communications should be, among
other, exchanges with the Illinois Schiller Park Police department, the Illinois Attorney General,
Brian Salerno, Don Peters, Dick Devine, any personnel at the Illinois Attorney General office and
ALL Save A Life Foundation former employees on the incident.

Exhibit A
3. Documentation! emails, memos, faxes, documents of any kind) on why Christian Sass was fired
by Save A Life Foundation. Also provide documentation on the state of the network, Scantron
after the Defendant, Annabel Melongo, left the company.

4. Documentation! emails, rneVnos, faxes, documents of any kind ) describing the Schiller Park
Police Department investigation. Description should include name of police officer(s) that came
to SALF to take report, name of the police investigator and the specific questions asked. Names
of individual(s) having gone to the Schiller Park Police building as part of the investigation. Letter
Commanding Schiller Park's Detective William Martin.

5. List contact information {email, fax*, address, phone) of ALL experts hired for the computer
incident that occurred in April 28'" - May l r t 2006 at Save A Life Foundation headquarters in
Schiller Park, Illinois. Also provided bills, invoices as well as copies of checks or bank statements
resulting from their services.

6. ALL copies of pay stubs issued to you by Save A Life Foundation during the years 2005, 2006,
2007. If not available, copies of back statements showing deposits being made.

7. Documentation! emails, memos, faxes, documents of any kind ) on individual(s) that were
instrumental in helping Save A Life Foundation be in Illinois' state budget and in providing funds
for SALF Springfield's office.

8. ALL documentation! emails, memos, faxes, letters, documents of any kind ) showing
earmarks/money received from CDC { Center Of Disease Control), DoD ( Department Of
Defense ), National Guard, Chicago Public Schools, Homeland Security, FEMA.

9. Contact information! address, fax, phone, email) on all companies having audited Save A Life
Foundation over the years. The information should include the start and end date(V) for each
company.

10. Provide ENTIRE personnel fifes of the following employees: Christian Sass, Dave Stolerow,
Saquan Gholar, BobCokinis, Vinee Davis, Robert Barnes, Dane Neal, Alfredo Salgado, Linda B.
Reyna. Also provide ALL copies of checks/proof of salary issued to those employees.

11. Provide copies of the two checks given to Defendant, Annabel Melongo as result of her services
at Save A Life Foundation, inc.

12. Provide name of temporary agency that employed Anne Rickert who is mentioned in the
attached ABC investigative report's transcript, Attached Exhibit 'A',

13. Provide all documentation! emails, memos, faxes, letters, bills, invoices, checks issued, financial
records, documents of any kind ) pertaining to Hogan & Hanson LLP as part of hs governmental
consulting services as stated in your 2005 and 2006 auditing reports, Attached Exhibit "B".

14. Provide ALL documents (recovery recipes, payments to experts, expenses, recipes/invoices of
any kind) showing proof of the financial lost of $ 1.000.000 due to the computer's incident as
stated In the May 2008, Grand Jury.

15. Provide documentation! emails, memos, faxes, letters, financial records, documents of any kind )
for the donation in the amount of $25,000 by the Illinois Attorney General to Save A Life
Foundation, Inc. Attached Exhibit "C"
YOUR FAILURE TO APPEAR IN RESPONSE TO THIS SUBPOENA WILL SUBJECT YOU TO PUNISHMENT FOR

CONTEMPT OF THIS COURT.

WITNESS

-
i ■

Date

Any. No. 99500

Name: Annabel Melongo

Address: P.O. Box 1537

City/State/Zip: Addlson, IL 60101

Telephone: 630-220-4132
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News

Save-A-LifeTs main government funding may be drying up


Thursday,. May 31, 2007
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SB

A
Chuck Goudie
More: Bio. Facebook. Twitter. News Team
By Chuck Goudie
May 30, 2007 (WLS) - New details emerge about the embattled Illinois charity The Save-A-Life Foundation - and why it may be losing funding and
political support.
The I-Team investigation of Save-A-Life last year uncovered a founder who fabricated her medical credentials. Now we've learned that Save^A-
Life's primary government bankroll appears to be drying up.
The Save-A-Life Foundation claims its instructors have taught first aid skills to more than 2 million school children in Illinois and several other states
the past decade. Since 2001, Save-A-Life has received millions of dollars in state and federal funding, and has listed powerful State Senate President
Emil Jones as one of its major backers. **
"I've never supported it funding-wise," Jones said.
And Jones says the charity is not currently slated to receive money in next year's state budget. The apparent cut-off of government funds follows
I-Team disclosures about Save-A-Life founder Carol Spizzdrri.
For years, while soliciting government funding, Spizzirri claimed to be a kidney transplant nurse and an RN, The NTeam's investigation found that the
now-defunct college she attended never awarded her a degree of any kind; and government records show she has never been a registered nurse in
either Wisconsin, as she told the 1-Team, or in Illinois. During questioning last November, Spizzirri walked out of our meeting and declined to be
interviewed for this report.
Over the past few years in Springfield, State Senator Donne Trotter has been the primary sponsor of funding for Save-A-Life in the Illinois budget,
last year $700,000 in taxpayer funds and another S88,000 in grant money.
"1 am concerned if in fact that she is not spending the taxpayer dollars we have entrusted in her to be spent correctly," said Trotter.
The South Side senator says that Illinois' auditor general would investigate how Save-A-Life has spent state money and fulfilled state contracts before
any consideration is given to future funding.
"To me, the jury is still out, because i haven't seen all the results," said Trotter,
Both senators Trotter and Jones have been given awards by $ave-A-Life7 Jones for saving someone from choking in a Springfield restaurant. Since
then, Jones says he has been wrongly listed as Save-A-Life's "Illinois spokesman" and that he has never even helped fund the group.
"What do you mean support? I saved a woman's life down here in Springfield and this group came together, and they want to honor me for the
woman choking to death in the Globe restaurant. Remember that?" Jones said.
In a letter, Jones writes that "issues and questions have been raised in the past year regarding SALF," and he "strongly encourages the foundation to
answer those questions." He wrote the letter to Chicago woman Julia Riokert after receiving her complaint about Save-A-Life's use of state funds.
Rickert worked at Save-A-Life's Schiller Park headquarters in late February as a temporary employee.
' "I was told by the temp agency that Save-a-Life was looking for somebody to do proofreading, to proofread their instruction manual, a 600 page
•manual," saia Kictcert.

Rickert says she was told her assignment was to find misspellings in a new first responded manual being prepared for it's instructors but she savs her
supervisor had something else in mind, ' '

"He never mentioned proofreading at all. He said their manual needed to be edited. They wanted it rewritten on a high school level. They wanted me
to rewrite the entire book line by line," said Rickert said.

A Save-A-Life spokesman confirms to ABC7 that temp workers typed the copyrighted book into their system then hired Rickert as a temp who was
told to rewrite it. The charity contends it was to be a first draft for a new training cun-iculum, even though Rickert had no expertise in emergency
response.

"I have proofreading experience but not technical writing experience and no medical background," said Rickert.
Save-A-Life officials say when the year-long project isfinished,it will be reviewed by "leading local and national EMS stakeholders and our
intellectual property attorney," and then "certified by the Illinois Department of Public Health."
Rickert has contacted the publisher of the book she was told to rewrite. The publisher declined to discuss with ABC7 what he called their "legal
investigation." And she has filed a complaint with the Illinois inspector general asking that Save-A-Life be investigated. Save-A-Life pledges to
happily "cooperate with an investigation by responsible parties to 4ispel these baseless allegations."
Save-A-Life filed a defamation lawsuit this month against a doctor and two other men who have publicly criticized the charity. In the suit,
Save-A-Life says the most serious allegations against them were "false, inflammatory and defamatory." Charity officials claim they have "lost
business opportunities," funding and have had to spend money to repair damage to their reputation.
Save-A-Life may be losing funding from the Chicago Public Schools as well. A CPS official says they "are scrutinizing every expense" and may not
have the budget to help out Save-A-Life as they have in recent years,
(Copyright ©2010 WLS-TV/DT. All Rights Reserved.)

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HEBB
2006 Federal Statements Page 2
Client 18015 SAVE A LIFE FOUNDATION 36-3869459
5/14/08 02 53PM

Statement 4 ■
Form 990, Part IV, Line 63
Loans from Officers, Directors, Trustees, and Key Employees
Balance.Due
Lender's Name: CAROL J5PIZZIRRI
Lender's Title: PRESIDENT
Repayment Terms: DUE ON DEMAND
Interest Rate: 5.001
Purpose of Loan: OPERATIONS
Original Amount: 61,496.
Balance Due: 178,974.
T o t a l 9~ 178.9747

Statement 5
Form 990, Part IV, Line 65
Other Liabilities

INSTRUCTOR DEPOSITS 8 2,700.


Rounding 1.
Total £ 2770T

Statement 6
Schedule A, Part I *
Compensation of Five Highest Paid Employees
Title 6 Average Coropen- Contribut. Expense
Name an^ Address Hours Worked sation , EBP & DC. Account
DANE NEAL '. NATL POLICY DIR 63,520. 0. 5B4.
9950 LAWRENCE, SUITE 300' 40
SCHILLER PARK, IL 60176
VINCENT DAVIS DIR -STATE/MILI 50,000. 0. 724,
9950 LAWRENCE, SUITE 300 40
SCHILLER PARK, IL 60176

Total

Statement 7
Schedule A, Part ll-A
Compensation of Five Highest Paid Professional Service Contractors

jlame and Address -type of Service Compensation


H0GAN & HARTSON LLP CONSULTING 77,039.
COLUMBIA SQUARE, 555 THIRTEENTH ST
WASHINGTON, DC 20004

Total 5 77.6357
SAVE A LIFE FOUNDATION, INC.

STATEMENT OF ACTIVITIES

For the Year Ended December 31.2002 «F


Temporarily
Unrestricted Restricted Total
INCOME
Public Support
Contributions 1,353 1,353
Private Grants 31,500 31,500
Contributions In Kind 123.081 123.081
Special Events Gross Income 93,606 93,606
Total Public Support 249,540 249,540

Government Contracts
State of Illinois -1DPH 600,000 600,000
Sute of Illinois - DCCA 200,000 200,000
Sute of Hlifcois - AHjSrittJjf 2£$0O - 25,000
Federal - HHS/CDC 31,619 31,819
Total Government Contracts 25,000 831,819 856,8X9

Other Income
Program Service Fees 31,693 31,693
Miscellaneous "^ 225 225-
Course Materials 149,960 149,980
Branch Fee (2.916) (2.916)
Membership Dues 205 205
Total Other Income 179.187 179,187

TOTAL INCOME (balances carried forward) 453,727 831,819 1,285,546

THE ACCOMPANYING NOTES ARE AN INTEGRAL PART OP THESE STATEMENTS


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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS, )

Plaintiff,

v. No. 08 CR-10502

ANNABEL K.MELONGO

Defendant.

Subpoena DucesTecum
TO: Illinois Department Of Public Health - Legal Dent.

535 W. Jefferson Streets >

Springfield. IL 62761

YOU ARE COMMANDED to appear to testify before the Honorable Judge Mary M. Brosnahan

■■-■- irvRoom 303, 2650 S.California Ave., Chicago, Illinois on March 3rd 2010, at 9.30 am.

YOU ARE COMMANDED ALSO to bring the following:

1. Provide ALL communications between the Illinois Department Of Public Health ( "IDPH" ) and
Save A Life Foundation, 600 S. Second St., Suite 103, Springfield, IL 62704; 9950 W. Lawrence Ave
Suite 300, Schiller Park, IL 60176-1216, or any other address which it may have used.

2. Provide All contracts/earmarks entered into between IDPH and Save A Life Foundation for any
purpose.

3. Provide ALL documents reflecting any training classes, courses or programs of any kind
conducted or sponsored by Save A Life Foundation, or to be conducted by it, for the
staff,students, faculty or others given to ISBE.

Exhibit B
4. Provide ALL purchase orders from IDPH to Save A Life Foundation for any products or services of
any kind.

5. Provide ALL invoices submitted by Safe A Life Foundation to IDPH for any purpose.

6. Provide ALL records of payment of any kind made by IDPH to Save A Life Foundation for any
purpose, including but not limited to employment or payroll records, or payments for invoices
submitted by it.

7. Provide ALL Resolutions passed by IDPH which refer or relate to Save A Life Foundation.

1N CASE YOU CAN'T APPEAR IN PERSON AT THE ABOVE MENTIONED DATE, PLEASE MAIL ALL THE

REQUESTED INFORMATION TO:

Judge Mary M. Brosnahan

Room 303,2650 S. California Ave., Chicago, Illinois

ATTENTION: ANNABEL MELONGO'S SUPBOENA RESPONSE

Date
2HUr2DlD
Atty. No. 99500

Name: Annabel Melongo . .

Address: P.O. Box 1537

City/State/Zip: Addison, IL 60101

Telephone: 630-220-4132
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS,

Plaintiff,

No. 08 CR-10502

ANNABEL K. MELONGO

Defendant.

Subpoena Duces Tecum


TO: Douglas Browne

2851 Evans Woods Dr. *:

Atlanta, GA 30340

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 3rdh 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* - 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 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 Deyine, Cook County State Attorney or
any emails exchange with ANY Save A Life Foundation employees regarding the incident.

Exhibit C
3. ALL your pay stubs or copies of checks issued by Save A Life Foundation to you during the years
2005, 2006,2007. If not available, copies of bank statements showing deposits being made.

4. Any document showing financial transaction(s) from Save A Life Foundation benefiting you.

5. Documentation! letters, faxes, memos, emails, documents of any kind) on individual(s) that were
instrumental in helping Save A Life Foundation be in Illinois' state budget, CDC, DoD
( Department of Defense ), National Guard, Homeland Security, FEMA.

6. Any documentation! financial statements, records, letters, emails, memos, faxes, document of
any kind) showing proof of lost as result of computer's incident occuring in April - May 2006 at
the Save A Life Foundation headquarters in Schiller Park, Illinois.

IN CASE YOU CAN'T APPEAR IN PERSON AT THE ABOVE MENTIONED DATE, PLEASE MAIL ALL THE

REQUESTED INFORMATION TO:

Judge Mary M. Brosnahan

Room 303, 2650 S. California Ave., Chicago, Illinois

ATTENTION: ANNABEL MELONGO'S SUPBOENA RESPONSE

;> WITNESS

Date
^JMiM+ys JL "Z 6/0
Atty. No. 99500

Name: Annabel Melongo

Address: P.O. Box 1537

City/State/Zip: Addison, IL 60101

Telephone: 630-220-4132
IN THE CIRCUIT COURT OF COOK COUNTY
COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS ) ^ ^ ^ ^


^
) ^
v. - ) No. 08CR10502
)
ANNABEL MELONGO )
Defendant )
t

MOTION TO QUASH SUBPOENAS

The People of the State of Illinois, by and through their Attorney, ANITA

ALVAREZ, 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, former Save A Life board member Douglas Browne, and former Palatine Mayor

Rita Mullins and in support state the following:

1. The Defendant ha&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 of their founder, Carol Spizzirri.

2. The Defendant has issued a subpoena to Carol Spizzirri, commanding her

appearance to testify and to bring the following:


a. Documentation (emails, memos, faxes, documents of any kind) with
description of computer events as they happened from April 28lh - May 1st
2006 at Save A Life Foundation, located in Schiller Park, Illinois. This
should include the computers affected, list of persons hired to fix it, the
type of files affected, percentage of files recovered as well as the names of
technician(s) recovering the files.

b. ALL communication(s) (emails, memos, faxes, documents of any kind)


you have in your possession regarding the above cited computer events.
Communications should be, among other [sic], exchanges with the Illinois
Schiller Park Police department, the Illinois Attorney General, Brian
Salerno, Don Peters, Dick Devine, any personnel at the Illinois Attorney
General office and ALL Save A Life Foundation former employees on the
incident.

Documentation (emails, memos, faxes, documents of any kind) on why


Christian Sass was fired by Save A Life Foundation. Also provide
documentation on the state of the network, Scantron after the Defendant,
Annabel Melongo left the company.

Documentation (emails, memos, faxes, documents of any kind) describing


the Schiller Park Police Department investigation. Description should
include the name of police officer(s) that came to SALF to take report
[sic], name of the police investigator and the specific questions asked.
Names of individual(s) having gone to the Schiller Park Police building as
part of the investigation. Letter Commanding Schiller Park's Detective
William Martin.

List contact information (emails, fax, address, phone) of ALL experts


hired for the computed incident that occurred in April 28th- May 1st 2006
at Save A Life Foundation headquarters in Schiller Park, Illinois. Also
provided [sic] bills, invoices as well as copies of checks or bank
statements resulting from their services.

ALL copies of pay stubs issued to you by Save A Life Foundation during
the years 2005, 2006, 2007. If not available, copies of back statements
showing deposits being made.

Documentation (emails, memos, faxes, documents of any kind) on


individual(s) that were instrumental in helping Save A Life Foundation be
in Illinois' state budget and in providing funds for SALF Springfield's
office.

All documentation (emails, memos, faxes, documents of any kind)


showing earmarks/money received from CDC (Center of Disease
Control), DoD (Department of Defense), National Guard, Chicago Public
Schools, Homeland Security, FEMA.

Contact information (address, fax, phone, email) on all companies having


audited Save A Life Foundation over the years. The information should
include the start and end date(s) for each company.

Provide ENTIRE personnel files of the following employees: Christian


Sass, Dave Stolerow, Saquan Gholar, Bob Cokinis, Vince Davis, Robert
Barnes, Dane Neal, Alfredo Salgado, Linda B. Reyna. Also provide ALL
copies of checks/proof of salary issued to those employees.
k. Provide copies of the two checks given to Defendant, Annabel Melongo as
[sic] result of her services at Save A Life Foundation, Inc.

1. Provide name of temporary agency that employed Anne Rickert who is


mentioned in the attached ABC investigative report's transcript, Attached
Exhibit 'A.'

m. Provide all documentation (emails, memos, faxes, letters, bills, invoices,


checks issued, financial records, documents of any kind) pertaining to
Hogan & Hartson LLJP as part of its governmental consulting services as
stated in your 2005 and 2006 auditing reports, Attached Exhibit "B."

n. Provide ALL documents (recovery recipes, payments to experts, expenses,


recipes/invoices of any kind) showing proof of the financial lost [sic] of
$1,000,000 due to the computer's incident [sic] as stated in the May 2008,
Grand Jury.

o. Provide documentation (emails, memos, faxes, letters, financial records,


documents of any kind) for the donation in the amount of $25,000 by the
Illinois Attorney General to Save A Life Foundation, Inc. Attached
Exhibit "C"

3. To warrant the use of a pre-trial subpoena, the Defendant must show l)sthat the

documents requested are evidentiary and relevant; 2) that the documents are not

otherwise procurable reasonably in the advance of trial by exercise of due

diligence; 3) that she cannot properly prepare for trial without the production and

that failure to obtain the documents may tend to unreasonably delay trial; and 4)

that the application is made in good faith and is not intended as a general "fishing

expedition." People v. Daniels, 805 N.E.2d 1206 (111. App. 2004). The Defendant

has not made such a showing.

4. A pretrial subpoena must comply with all four elements to be validly issued. A

reading of the subpoena issued by the Defendant in this case clearly shows a

fishing expedition and the fact that the subpoena was not issued in good faith.
Specifically, her requests include the entire personnel files of individuals not

involved in the incident, the pay stubs or bank account records of the alleged

victim, and the results of any audit ever performed for Save A Life Foundation

(SALF). These documents are wholly unrelated to the charges against the

Defendant.

5. Further, even in the event that these documents might have evidentiary value, the

Defendant has not demonstrated that these documents are not otherwise

procurable reasonably in advance of trial by the exercise of due diligence.

Through the discovery process the Defendant had been provided with the some of

information she has requested, including the names of individuals working to

recover data at SALF, the types of files affected, and the names of the police

investigators who came to SALF to take the report. Asking the victim in this case

to recreate information the Defendant already has is unreasonable, duplicative,

and not made in good faith.

6. The Defendant has made similar unreasonable demands of the Illinois Department

of Health (EXHIBIT B), former SALF board member Douglas Browne

(EXHIBIT C), and former Palatine Mayor Rita Mullins. The Defendant demands,

among other items, all communications, purchase orders, and invoices between

SALF and the Department of Health, Mr. Browne's pay stubs, and all

documentation "instrumental in helping Save A Life Foundation be in Illinois

budget." (EXHIBIT C, item 5).

7. These requests are unrelated to the investigation of computer intrusion at the Save

A Life Foundation. Mr. Browne, Ms. Mullins, and the Illinois Department of
Public Health were not involved in the day to day operations of SALF. The

Defendant has not demonstrated that these documents are evidentiary, relevant,

and requested in good faith.

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

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 State of Illinois ask that this Honorable Court

quash the subpoenas issued by the Defendant or, in the alternative, sel this matter

for hearing at such a time before such appearances are commanded.

RespectjjiJly submitted

N
Julie Gunra^ley -^_
>A«sistant State's Attorney
CliRTlFlCATKOFSHRVin;

I, the undersigned, state that have served the attached Motion to Quash upon:
Annabel Melongo
P.O. Box 1537
Addison, IL 60101

by mailing it first class mail, with sufficient postage attached this 21s1 day of February,
2010. Per the Defendant's request, she was notified at 630-220-4132 that a paper copy
was available at the State's Attorney's Office.

uife uunttij
ssistant State's Attorned

:•
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS,

Plaintiff,

No. 08 CR-10S02

ANNABEL K. MELONGO

Defendant.

Subpoena Duces Tec urn


TO; Carol Spizzirrt
» ■> *
■ » >

17479 Dartmoor Court,

Grayslake, IL 60030

Telephone; 847-366-1124

YOU ARE COMMANDED t o appear t o testify before the Honorable Judge Mary M. Brosnahan

In Room 303, 2650 5. California Ave., Chicago, Illinois on March 3 rd 2010, at 9.30 am.

YOU ARE COMMANDED ALSO to bring the following:

1. Documentation( emails, memos, faxes, documents of any kind ) with description of computer
events, ^^hey1nsppenedirorrrApr\\^2,8'h ^ May 1^^006"atSweA^LtfeFoundatTdn, Jocatrdln
Schiller Park, Illinois. This should include the computers affected, list of persons hired to fix It,
the type of files affected, percentage of files recovered as well as the names of technician^)
recovering the fitesr

2, ALL communication(s) (emails, memos, faxes, documents of any kind ) you have in your
possession regarding the above cited computer events. Communications should be, among
other, exchanges with the Illinois Schiller Park Police department, the Illinois Attorney General,
Brian Salerno, Don Peters, Dick Devine, any personnel at the Illinois Attorney General office and
ALL Save A Life Foundation former employees on the incident.

Exhibit A
3. Documentation! emails, memos, faxes, documents of any kind) on why Christian Sass was fired
by Save A Life Foundation. Also provide documentation on the state of the network, Scantron
after the Defendant, Annabel Melongo, left the company.

4. Documentation! emails, rneVnos, faxes, documents of any kind ) describing the Schiller Park
Police Department investigation. Description should include name of police officer(s) that came
to SALF to take report, name of the police investigator and the specific questions asked. Names
of individual(s) having gone to the Schiller Park Police building as part of the investigation. Letter
Commanding Schiller Park's Detective William Martin.

5. List contact information {email, fax*, address, phone) of ALL experts hired for the computer
incident that occurred in April 28'" - May l r t 2006 at Save A Life Foundation headquarters in
Schiller Park, Illinois. Also provided bills, invoices as well as copies of checks or bank statements
resulting from their services.

6. ALL copies of pay stubs issued to you by Save A Life Foundation during the years 2005, 2006,
2007. If not available, copies of back statements showing deposits being made.

7. Documentation! emails, memos, faxes, documents of any kind ) on individual(s) that were
instrumental in helping Save A Life Foundation be in Illinois' state budget and in providing funds
for SALF Springfield's office.

8. ALL documentation! emails, memos, faxes, letters, documents of any kind ) showing
earmarks/money received from CDC { Center Of Disease Control), DoD ( Department Of
Defense ), National Guard, Chicago Public Schools, Homeland Security, FEMA.

9. Contact information! address, fax, phone, email) on all companies having audited Save A Life
Foundation over the years. The information should include the start and end date(V) for each
company.

10. Provide ENTIRE personnel fifes of the following employees: Christian Sass, Dave Stolerow,
Saquan Gholar, BobCokinis, Vinee Davis, Robert Barnes, Dane Neal, Alfredo Salgado, Linda B.
Reyna. Also provide ALL copies of checks/proof of salary issued to those employees.

11. Provide copies of the two checks given to Defendant, Annabel Melongo as result of her services
at Save A Life Foundation, inc.

12. Provide name of temporary agency that employed Anne Rickert who is mentioned in the
attached ABC investigative report's transcript, Attached Exhibit 'A',

13. Provide all documentation! emails, memos, faxes, letters, bills, invoices, checks issued, financial
records, documents of any kind ) pertaining to Hogan & Hanson LLP as part of hs governmental
consulting services as stated in your 2005 and 2006 auditing reports, Attached Exhibit "B".

14. Provide ALL documents (recovery recipes, payments to experts, expenses, recipes/invoices of
any kind) showing proof of the financial lost of $ 1.000.000 due to the computer's incident as
stated In the May 2008, Grand Jury.

15. Provide documentation! emails, memos, faxes, letters, financial records, documents of any kind )
for the donation in the amount of $25,000 by the Illinois Attorney General to Save A Life
Foundation, Inc. Attached Exhibit "C"
YOUR FAILURE TO APPEAR IN RESPONSE TO THIS SUBPOENA WILL SUBJECT YOU TO PUNISHMENT FOR

CONTEMPT OF THIS COURT.

WITNESS

-
i ■

Date

Any. No. 99500

Name: Annabel Melongo

Address: P.O. Box 1537

City/State/Zip: Addlson, IL 60101

Telephone: 630-220-4132
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News

Save-A-LifeTs main government funding may be drying up


Thursday,. May 31, 2007
• Email ">
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SB

A
Chuck Goudie
More: Bio. Facebook. Twitter. News Team
By Chuck Goudie
May 30, 2007 (WLS) - New details emerge about the embattled Illinois charity The Save-A-Life Foundation - and why it may be losing funding and
political support.
The I-Team investigation of Save-A-Life last year uncovered a founder who fabricated her medical credentials. Now we've learned that Save^A-
Life's primary government bankroll appears to be drying up.
The Save-A-Life Foundation claims its instructors have taught first aid skills to more than 2 million school children in Illinois and several other states
the past decade. Since 2001, Save-A-Life has received millions of dollars in state and federal funding, and has listed powerful State Senate President
Emil Jones as one of its major backers. **
"I've never supported it funding-wise," Jones said.
And Jones says the charity is not currently slated to receive money in next year's state budget. The apparent cut-off of government funds follows
I-Team disclosures about Save-A-Life founder Carol Spizzdrri.
For years, while soliciting government funding, Spizzirri claimed to be a kidney transplant nurse and an RN, The NTeam's investigation found that the
now-defunct college she attended never awarded her a degree of any kind; and government records show she has never been a registered nurse in
either Wisconsin, as she told the 1-Team, or in Illinois. During questioning last November, Spizzirri walked out of our meeting and declined to be
interviewed for this report.
Over the past few years in Springfield, State Senator Donne Trotter has been the primary sponsor of funding for Save-A-Life in the Illinois budget,
last year $700,000 in taxpayer funds and another S88,000 in grant money.
"1 am concerned if in fact that she is not spending the taxpayer dollars we have entrusted in her to be spent correctly," said Trotter.
The South Side senator says that Illinois' auditor general would investigate how Save-A-Life has spent state money and fulfilled state contracts before
any consideration is given to future funding.
"To me, the jury is still out, because i haven't seen all the results," said Trotter,
Both senators Trotter and Jones have been given awards by $ave-A-Life7 Jones for saving someone from choking in a Springfield restaurant. Since
then, Jones says he has been wrongly listed as Save-A-Life's "Illinois spokesman" and that he has never even helped fund the group.
"What do you mean support? I saved a woman's life down here in Springfield and this group came together, and they want to honor me for the
woman choking to death in the Globe restaurant. Remember that?" Jones said.
In a letter, Jones writes that "issues and questions have been raised in the past year regarding SALF," and he "strongly encourages the foundation to
answer those questions." He wrote the letter to Chicago woman Julia Riokert after receiving her complaint about Save-A-Life's use of state funds.
Rickert worked at Save-A-Life's Schiller Park headquarters in late February as a temporary employee.
' "I was told by the temp agency that Save-a-Life was looking for somebody to do proofreading, to proofread their instruction manual, a 600 page
•manual," saia Kictcert.

Rickert says she was told her assignment was to find misspellings in a new first responded manual being prepared for it's instructors but she savs her
supervisor had something else in mind, ' '

"He never mentioned proofreading at all. He said their manual needed to be edited. They wanted it rewritten on a high school level. They wanted me
to rewrite the entire book line by line," said Rickert said.

A Save-A-Life spokesman confirms to ABC7 that temp workers typed the copyrighted book into their system then hired Rickert as a temp who was
told to rewrite it. The charity contends it was to be a first draft for a new training cun-iculum, even though Rickert had no expertise in emergency
response.

"I have proofreading experience but not technical writing experience and no medical background," said Rickert.
Save-A-Life officials say when the year-long project isfinished,it will be reviewed by "leading local and national EMS stakeholders and our
intellectual property attorney," and then "certified by the Illinois Department of Public Health."
Rickert has contacted the publisher of the book she was told to rewrite. The publisher declined to discuss with ABC7 what he called their "legal
investigation." And she has filed a complaint with the Illinois inspector general asking that Save-A-Life be investigated. Save-A-Life pledges to
happily "cooperate with an investigation by responsible parties to 4ispel these baseless allegations."
Save-A-Life filed a defamation lawsuit this month against a doctor and two other men who have publicly criticized the charity. In the suit,
Save-A-Life says the most serious allegations against them were "false, inflammatory and defamatory." Charity officials claim they have "lost
business opportunities," funding and have had to spend money to repair damage to their reputation.
Save-A-Life may be losing funding from the Chicago Public Schools as well. A CPS official says they "are scrutinizing every expense" and may not
have the budget to help out Save-A-Life as they have in recent years,
(Copyright ©2010 WLS-TV/DT. All Rights Reserved.)

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HEBB
2006 Federal Statements Page 2
Client 18015 SAVE A LIFE FOUNDATION 36-3869459
5/14/08 02 53PM

Statement 4 ■
Form 990, Part IV, Line 63
Loans from Officers, Directors, Trustees, and Key Employees
Balance.Due
Lender's Name: CAROL J5PIZZIRRI
Lender's Title: PRESIDENT
Repayment Terms: DUE ON DEMAND
Interest Rate: 5.001
Purpose of Loan: OPERATIONS
Original Amount: 61,496.
Balance Due: 178,974.
T o t a l 9~ 178.9747

Statement 5
Form 990, Part IV, Line 65
Other Liabilities

INSTRUCTOR DEPOSITS 8 2,700.


Rounding 1.
Total £ 2770T

Statement 6
Schedule A, Part I *
Compensation of Five Highest Paid Employees
Title 6 Average Coropen- Contribut. Expense
Name an^ Address Hours Worked sation , EBP & DC. Account
DANE NEAL '. NATL POLICY DIR 63,520. 0. 5B4.
9950 LAWRENCE, SUITE 300' 40
SCHILLER PARK, IL 60176
VINCENT DAVIS DIR -STATE/MILI 50,000. 0. 724,
9950 LAWRENCE, SUITE 300 40
SCHILLER PARK, IL 60176

Total

Statement 7
Schedule A, Part ll-A
Compensation of Five Highest Paid Professional Service Contractors

jlame and Address -type of Service Compensation


H0GAN & HARTSON LLP CONSULTING 77,039.
COLUMBIA SQUARE, 555 THIRTEENTH ST
WASHINGTON, DC 20004

Total 5 77.6357
SAVE A LIFE FOUNDATION, INC.

STATEMENT OF ACTIVITIES

For the Year Ended December 31.2002 «F


Temporarily
Unrestricted Restricted Total
INCOME
Public Support
Contributions 1,353 1,353
Private Grants 31,500 31,500
Contributions In Kind 123.081 123.081
Special Events Gross Income 93,606 93,606
Total Public Support 249,540 249,540

Government Contracts
State of Illinois -1DPH 600,000 600,000
Sute of Illinois - DCCA 200,000 200,000
Sute of Hlifcois - AHjSrittJjf 2£$0O - 25,000
Federal - HHS/CDC 31,619 31,819
Total Government Contracts 25,000 831,819 856,8X9

Other Income
Program Service Fees 31,693 31,693
Miscellaneous "^ 225 225-
Course Materials 149,960 149,980
Branch Fee (2.916) (2.916)
Membership Dues 205 205
Total Other Income 179.187 179,187

TOTAL INCOME (balances carried forward) 453,727 831,819 1,285,546

THE ACCOMPANYING NOTES ARE AN INTEGRAL PART OP THESE STATEMENTS


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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS, )

Plaintiff,

v. No. 08 CR-10502

ANNABEL K.MELONGO

Defendant.

Subpoena DucesTecum
TO: Illinois Department Of Public Health - Legal Dent.

535 W. Jefferson Streets >

Springfield. IL 62761

YOU ARE COMMANDED to appear to testify before the Honorable Judge Mary M. Brosnahan

■■-■- irvRoom 303, 2650 S.California Ave., Chicago, Illinois on March 3rd 2010, at 9.30 am.

YOU ARE COMMANDED ALSO to bring the following:

1. Provide ALL communications between the Illinois Department Of Public Health ( "IDPH" ) and
Save A Life Foundation, 600 S. Second St., Suite 103, Springfield, IL 62704; 9950 W. Lawrence Ave
Suite 300, Schiller Park, IL 60176-1216, or any other address which it may have used.

2. Provide All contracts/earmarks entered into between IDPH and Save A Life Foundation for any
purpose.

3. Provide ALL documents reflecting any training classes, courses or programs of any kind
conducted or sponsored by Save A Life Foundation, or to be conducted by it, for the
staff,students, faculty or others given to ISBE.

Exhibit B
4. Provide ALL purchase orders from IDPH to Save A Life Foundation for any products or services of
any kind.

5. Provide ALL invoices submitted by Safe A Life Foundation to IDPH for any purpose.

6. Provide ALL records of payment of any kind made by IDPH to Save A Life Foundation for any
purpose, including but not limited to employment or payroll records, or payments for invoices
submitted by it.

7. Provide ALL Resolutions passed by IDPH which refer or relate to Save A Life Foundation.

1N CASE YOU CAN'T APPEAR IN PERSON AT THE ABOVE MENTIONED DATE, PLEASE MAIL ALL THE

REQUESTED INFORMATION TO:

Judge Mary M. Brosnahan

Room 303,2650 S. California Ave., Chicago, Illinois

ATTENTION: ANNABEL MELONGO'S SUPBOENA RESPONSE

Date
2HUr2DlD
Atty. No. 99500

Name: Annabel Melongo . .

Address: P.O. Box 1537

City/State/Zip: Addison, IL 60101

Telephone: 630-220-4132
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS,

Plaintiff,

No. 08 CR-10502

ANNABEL K. MELONGO

Defendant.

Subpoena Duces Tecum


TO: Douglas Browne

2851 Evans Woods Dr. *:

Atlanta, GA 30340

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 3rdh 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* - 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 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 Deyine, Cook County State Attorney or
any emails exchange with ANY Save A Life Foundation employees regarding the incident.

Exhibit C
3. ALL your pay stubs or copies of checks issued by Save A Life Foundation to you during the years
2005, 2006,2007. If not available, copies of bank statements showing deposits being made.

4. Any document showing financial transaction(s) from Save A Life Foundation benefiting you.

5. Documentation! letters, faxes, memos, emails, documents of any kind) on individual(s) that were
instrumental in helping Save A Life Foundation be in Illinois' state budget, CDC, DoD
( Department of Defense ), National Guard, Homeland Security, FEMA.

6. Any documentation! financial statements, records, letters, emails, memos, faxes, document of
any kind) showing proof of lost as result of computer's incident occuring in April - May 2006 at
the Save A Life Foundation headquarters in Schiller Park, Illinois.

IN CASE YOU CAN'T APPEAR IN PERSON AT THE ABOVE MENTIONED DATE, PLEASE MAIL ALL THE

REQUESTED INFORMATION TO:

Judge Mary M. Brosnahan

Room 303, 2650 S. California Ave., Chicago, Illinois

ATTENTION: ANNABEL MELONGO'S SUPBOENA RESPONSE

;> WITNESS

Date
^JMiM+ys JL "Z 6/0
Atty. No. 99500

Name: Annabel Melongo

Address: P.O. Box 1537

City/State/Zip: Addison, IL 60101

Telephone: 630-220-4132
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS, )

Plaintiff, )

v. ) No. 08 CR-10502

ANNABEL K. MELONGO )

Defendant. )

Subpoena Duces Tecum


TO: Rita Mullins

858 N. Virginia Lake Ct.

Palatine, IL 60067

T elephone: 847-359-4854

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 2010, at 9.30 am.

YOU ARE COMMANDED ALSO to bring the following:

1 . Details description of computer events as they happened from April 28th - May 1 s t 2006 at Save
A Life Foundation, located in Schiller Park, Illinois (“SALF”). This should include the computers
affected, list of persons hired to fix it, the type of files affected, experts being hired.

2. Any document(s) you might have in your possession regarding the above mentioned computer's
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,
any emails exchange with ANY Save A Life Foundation employees regarding the incident.

3. Documentation( emails, memos, faxes, documents of any kind ) describing the Schiller Park
Police Department investigation. Description should include name of police officer(s) that came
to SALF to take report, name of the police investigator and the specific questions asked. Names
of individual(s) having gone to the Schiller Park Police building as part of the investigation. Letter
Commanding Schiller Park's Detective William Martin.

4. Documentation( emails, memos, faxes, documents of any kind ) describing the Schiller Park
Police Department investigation. Description should include name of police officer(s) that came
to SALF to take report, name of the police investigator and the specific questions asked. Names
of individual(s) having gone to the Schiller Park Police building as part of the investigation. Letter
Commanding Schiller Park's Detective William Martin.

5. ALL your pay stubs or copies of checks issued by Save A Life Foundation to you during the years
2005, 2006, 2007. If not available copies of back statements showing deposits being made.

6. Documentation on any financial transaction from Save A Life Foundation benefiting you or your
political campaign(s).

7. Documentation( emails, memos, faxes, documents of any kind ) on individual(s) that were
instrumental in helping Save A Life Foundation be in Illinois' state budget and in providing funds
for SALF Springfield's office.

8. ALL documentation( emails, memos, faxes, letters, documents of any kind ) showing earmarks/
money received from CDC ( Center Of Disease Control ), DoD ( Department Of Defense ),
National Guard, Chicago Public Schools, Homeland Security, FEMA.

9. Provide ALL documents ( financial records, bills, invoices, memos, faxes, document of any kind )
showing proof of lost as result of computer's incident occurring at SALF in April – May 2006.
IN CASE YOU CAN'T APPEAR IN PERSON AT THE ABOVE MENTIONED DATE, PLEASE MAIL ALL THE

REQUESTED INFORMATION TO:

Judge Mary M . Brosnahan

Room 303, 2650 S. California Ave. , Chicago, Illinois

ATTENTION: ANNABEL MELONGO'S SUPBOENA RESPONSE

WITNESS

Date

Atty. No. 99500

Name: Annabel Melongo

Address: P.O. Box 1537

City/State/Zip: Addison, IL 60101

Telephone: 630-220-4132