Cook County Circuit Court Case No.

ALSTORY SIMON, Defendant-Petitioner

99 CR 769901

PETITION FOR POST-CONVICTION RELIEF

(Inclusive of Exhibits VOLS. I and II)
NOW COMES the Defendant, ALSTORY SIMON, by and through his attorneys, Connolly, Ekl &
Williams, P.C. and James G. Sotos and Associates, and in support of this Post-Conviction Petition
based upon newly discovered evidence establishing actual innocence states as follows:
In 1999 the Defendant was charged by indictment with four (4) counts of First Degree Murder. It
was alleged in the indictment that the Defendant shot and killed Jerry Hillard and Marilyn Green. On
September 7, 1999 the Defendant entered a plea of guilty to one count of Murder and one count of
Voluntary Manslaughter. Pursuant to an agreement with the prosecution and the concurrence of Judge
Thomas Fitzgerald, the Defendant was sentenced to thirty-seven (37) years in the Illinois Department of
Corrections (IDOC) for the murder of Marilyn Green and fifteen (15) years in the IDOC for the Voluntary
Manslaughter of Jerry Hillard.
The Defendant did not file a motion to vacate his plea of guilty and did not file a direct appeal
from his convictions. On July 18, 2001 the Defendant filed a Pro Se Petition for Post Conviction Relief. (
A copy is attached as Exhibit 1).
On October 5, 2001 the Honorable Evelyn B. Clay issued an order dismissing this petition without a
hearing and without appointment of counsel. (A copy of this order is attached as Exhibit 2). The
Defendant filed an appeal of Judge Clays order of dismissal which was denied by the Appellate Court for
the First Judicial District.
A.

BACKGROUND FACTS

1. On August 15, 1982 at approximately 1:00 a.m. Jerry Hillard and Marilyn Green were shot and killed
while in the bleachers of the swimming pool area of Washington Park located on the southeast side of
Chicago.
2. Jerry Hillard was found by members of the Chicago Police Department, alive, but unconscious in the
bleachers of Washington Park at the location where he had been shot. Marilyn Green staggered out of
the bleacher area after she had been shot and was found in critical condition approximately one block
from the bleachers.
3. A subsequent autopsy performed by the Cook County Medical examiner revealed that Jerry Hillard had
been shot twice in the head at close range. (Dr. Joann Richmonds Report of Postmortem Examination
performed on Jerry Hillard is attached as Exhibit 3).
4. The autopsy performed on Marilyn Green revealed that she had been shot three (3) times, twice in the
neck and once in the hand. The entrance wounds to the neck indicated that she had been shot at close
range. (Dr. Joann Richmonds Report of Postmortem Examination performed on Marilyn Green is
attached as Exhibit 4).
5. Officers from the Chicago Police Department initially located two witnesses to the shooting, Henry
Williams and William Taylor.
6. During his initial interview by the police, Henry Williams told the police that he had gone swimming in
the pool at Washington Park. When he exited the pool, he was confronted by a man he knew from the
neighborhood to be Anthony Porter. Porter pointed a handgun to his head and demanded his
money. Porter then walked into the bleachers where the two victims were located and a short time later
Williams heard several gunshots.

7. Henry Williams told the police that the man who robbed him at gunpoint, who then went into the
bleachers where the murders occurred, was Anthony Porter.
8. When initially interviewed by the police, William Taylor stated that he was in the swimming pool at the
time of the shooting in the bleachers and that he heard the shots. He did not identify anyone as the
shooter.
9. Later the night of the murders, Taylor admitted to the police that he had seen the man who had shot
the two victims in the bleachers and that he knew the man to be Anthony Porter. Mr. Taylor told the
police that he did not want to identify Porter in his initial interview because he was afraid of Anthony
Porter and his brothers.
10. The investigating officers contacted the Cook County States Attorneys Office Felony Review
Division, and Assistant States Attorney David Kerstein responded to Area 1 to participate in additional
interviews of Henry Williams and William Taylor.
11. Assistant States Attorney Kerstein accompanied Henry Williams, William Taylor and investigators
from the Chicago Police Department to the scene of the shooting at Washington Park.
12. While in the presence of Assistant States Attorney Kerstein, Henry Williams repeated that Anthony
Porter robbed him at gunpoint before moving into the bleachers where the murders occurred minutes
later. William Taylor explained that the man he knew to be Anthony Porter shot the two victims in the
bleachers of Washington Park.
13. While at the park with Williams and Taylor, Assistant States Attorney Kerstein and the police
detectives located two additional witnesses, Kenneth Edwards and Michael Woodfork, who were in the
swimming pool area at the time of the shooting.
14. Kenneth Edwards told the police and Assistant States Attorney Kerstein that he had been in the pool
area at the time of the shooting with Michael Woodfork, Mark Senior and Eugene Beckwith.
15. Kenneth Edwards identified Anthony Porter, an individual he knew from the neighborhood, as the
man who shot the two victims in the bleachers. Neither Michael Woodfork nor Eugene Beckwith made an
identification of the shooter at that time. Mark Senior was not located and interviewed by the detectives.
16. Assistant States Attorney Kerstein subsequently approved an arrest warrant for Anthony Porter for
the murders of Jerry Hillard and Marilyn Green.
17. At the time of the murders of Hillard and Green, Porter was on parole for a robbery he had pleaded
guilty to which occurred in the same area of the bleachers adjacent to the swimming pool of Washington
Park.
.
18. On August 17, 1982 Anthony Porter surrendered to members of the Chicago Police
Department. Porter made a statement claiming to have been with several friends, Luke, Tobar and
Tyrone Horton at the time of the murders.
19. Members of the Chicago Police Department interviewed Kenneth Doyle on August 17, 1982, who told
the police he was with Anthony Porter until 10:00-11:00 p.m., the night of the shooting of Green and
Hillard.
20. On August 18, 1982 William Taylor identified Anthony Porter in a line-up as the person he had seen
shoot Hillard and Green in the bleachers of the swimming pool area of Washington Park on August 15,
1982.

21. On September 9, 1982 Anthony Porter was arraigned on an Indictment charging him with the murders
of Jerry Hillard and Marilyn Green and the Armed Robbery of Henry Williams as well as other lesser
charges. The cases were assigned to Judge Robert Skoldowski.
22. At the time of his arrest Anthony Porter was wanted for the shooting of Earl Lewis in the head on
August 1, 1982 while Mr. Lewis sat outside a building at 56th and Michigan in Chicago, approximately 1-2
blocks from the location where Hillard and Green had been shot. Porter pleaded guilty to that crime on
August 5, 1983. Mr. Lewis testified that Porter first kicked his dog and when Lewis questioned Porter as
to why he had kicked the dog Porter retrieved a gun and shot him in the head. (See pages 1005-1013 of
the transcript of the testimony of Earl Lewis in the Anthony Porter criminal trial attached as Exhibit 5). In
connection with the shooting of Earl Lewis, Porter was sentenced to six (6) years in the IDOC on August
5, 1983. (A copy of the Order of Sentence and Commitment is attached as Exhibit 6)
23. On September 7, 1983 Porter was found guilty by a jury of the murders of Jerry Hillard and Marilyn
Green, Unlawful Use of Weapons, Unlawful Restraint and the Armed Robbery of Williams.
24. During the criminal trial of Anthony Porter, William Taylor testified that he observed Porter, who
he knew from the neighborhood, standing over Jerry Hillard at the time shots were fired. (See the trial
testimony of William Taylor at pages 383-385 of Exhibit 6A). Henry Williams testified at the trial that
Anthony Porter, robbed him at gunpoint and then immediately proceeded into the bleachers where Hillard
and Green were shot. (See the trial testimony of Henry Williams at pages 452-457 attached as Exhibit
6B). Porter was also identified as having been in Washington Park immediately after the shooting by
Officer Anthony Liace of the Chicago Police Department. (See the trial testimony of Officer Liace at pages
567-570 of Exhibit 6C)
25. On September 21, 1983 Anthony Porter was sentenced to death by Judge Skolowski.
26. Porter was sentenced to thirty (30) years in the Illinois Department of Corrections for the Armed
Robbery of Henry Williams and to a lesser term in the IDOC for other offenses.
27. On April 24, 1987 attorney Kenneth Flaxman filed a Post Conviction Petition on behalf of Anthony
Porter wherein he contended that Alstory Simon was a suspect in the murders of Hillard and Green.
28. On May 8, 1987 Inez Jackson Simon, Alstory Simons wife, provided an oral statement to Willis
Ridley, an investigator working for Porter, denying any knowledge of who killed Hillard and Green and
acknowledging that she and her husband, Alstory Simon, were at the park earlier in the evening with
Hillard and Green. (The Investigative Report of Willis Ridley is attached as Exhibit 7).
29. On August 26, 1998 William Taylor provided an affidavit to Appolin Beaudouin, an investigator
working for Porter. In this statement Taylor made no mention of having lied at the Porter trial when he
testified that Porter killed Hillard and Green. (A copy of the statement is attached as Exhibit 8 ).
30. In late 1998 Northwestern University Journalism Professor David Protess, Private Investigator Paul
Ciolino and several journalism students began to investigate the case against Anthony Porter with the
goal of establishing that Porter was innocent of the murders of Hillard and Green.
31. It has been widely acclaimed that this team from Northwestern was responsible for developing
evidence which conclusively proved the innocence of Anthony Porter as well as the guilt of Alstory Simon
for the murders of Hillard and Green.
32. On December 11, 1998 Ciolino obtained a written statement from William Taylor (attached as
Exhibit 9) wherein Taylor claimed that he did not observe Porter actually fire the gun which killed Hillard
and Green. Taylor provided a similar statement to Professor Protess on December 14, 1998 (a copy of
the statement is attached as Exhibit 10).

33. On January 20, 1999 Walter Jackson, the nephew of Inez Jackson, signed an affidavit wherein he
claimed that Alstory Simon told him that he had shot and killed Hillard and Green. ( A copy of the affidavit
is attached as Exhibit 11)
34. On January 29, 1999 Inez Jackson signed a four (4) page statement and provided a video taped
statement to Protess, Ciolino and two (2) journalism students inculpating Simon in the murders of Hillard
and Green. (A copy of the statement is attached as Exhibit 12 and the video as Exhibit 13[1]
35. On February 3, 1999 Alstory Simon provided a video-taped statement to Ciolino and his partner
admitting to having shot Hillard and Green. Simon claimed that the shooting of Hillard was in self-defense
and the shooting of Green was accidental. (A copy of the video statement is attached as Exhibit 14)
36. That same day Ciolino arranged for attorney Jack Rimland to represent Simon pro-bono.
37. On February 5, 1999 Porter was released from custody.
38. On February 6, 1999 Simon was charged with the First Degree Murders of Hillard and Green.
39. No physical evidence has ever existed which connected Alstory Simon to the murders of Hillard and
Green.
40. On February 10, 1999 William Taylor provided a court reported statement under oath wherein he
stated that after the shooting of Hillard and Green, Anthony Porter, who he knew from the neighborhood,
ran past him. (A copy of the statement is attached as Exhibit 15, pages 13-14)
41. On February 9, 1999 Eugene Beckwith testified before the Grand Jury that he was in the swimming
pool of Washington Park with Mark Senior, Michael Woodfork and Kenneth Edwards when Hillard and
Green were killed. He testified that he saw Anthony Porter, who he knew from the neighborhood, in the
bleachers where the murders occurred immediately before the shooting of Hillard and Green. (The
transcript of Beckwiths Grand Jury testimony is attached as Exhibit 16, see pages 14 and 23)
42. On February 11, 1999 Mark Senior testified before the Grand Jury that he saw Porter, who he knew
from the neighborhood, in the bleachers where the murders occurred immediately before the shooting of
Hillard and Green. (A transcript of Seniors Grand Jury testimony is attached as Exhibit 17,see pages 4
and 8).
43. On February 17, 1999 Kenneth Edwards testified before the Grand Jury that he also saw Porter in the
bleachers where the murders occurred immediately before the shooting of Hillard and Green and that he
saw Porter shoot the victims. ( A copy of Edwards Grand Jury testimony is attached as Exhibit 18, pages
5, 6, 9 and 15).
44. On February 14, 1999 Walter Jackson gave a signed statement to Assistant States Attorney Thomas
Gainer claiming that Alstory Simon had admitted to him in 1982 that he had killed Hillard and
Green.(Attached as Exhibit 19)
45. On February 17, 1999 Paul Ciolino testified before the Grand Jury. (The transcript of his testimony is
attached as Exhibit 20).
46. On February 22, 1999 Professor Protess and students Thomas McCann, Shawn Armburst, Syandene
Rhodes-Pitts and Cara Rubinsky testified before the Grand Jury (The transcripts of their testimony of
Protess is attached as Exhibit 21; McCann is attached as Exhibit 22; Armburst is attached as Exhibit 23;
Rhodes-Pitts is attached as Exhibit 24; and Rubinsky is attached as Exhibit 25).
47. On March 11, 1999 Ciolino again testified before the Grand Jury. (The transcript of his testimony is
attached as Exhibit 26)

48. On September 7, 1999 Simon plead guilty to the murder of Green and the voluntary manslaughter of
Hillard. He was sentenced to concurrent sentences of thirty-seven (37) years for murder and fifteen
years (15) for voluntary manslaughter. (A copy of the transcript of proceedings is attached as Exhibit 27).
49. On July 3, 2001 Simon filed a pro-se post conviction relief petition which was summarily dismissed by
the Honorable Judge Evelyn Clay without a hearing or appointment of counsel for the petitioner, Alstory
Simon.
50. Simon remains incarcerated in the Danville Correctional Center.
B. ADDITIONAL FACTS - NEWLY DISCOVERED EVIDENCE
Walter Jackson and Inez Jackson Simon
1. The Northwestern University Journalism students were not the first persons to approach Walter
Jackson in an attempt to help Anthony Porter. It has been alleged that when first approached by these
students that Walter Jackson, serving a sentence for first-degree murder, promptly told the students that
after seventeen (17) years of silence his conscience had gotten the better of him and he was now
prepared to testify that Alstory Simon confessed on the night of the murders that he had shot Hillard and
Green. (See Exhibit 11 )
2. In reality Walter Jackson was first approached by none other than Anthony Porter when both men were
incarcerated in the Danville Correctional Center in approximately 1994. (see the Affidavit attached as
Exhibit 28)
3. Walter Jackson now admits that in 1994 both he and Porter were incarcerated together at the Pontiac
Correctional Center when Porter asked him to help him beat his case by claiming that Simon, who was
married to his aunt, Inez Jackson Simon, had admitted to having killed HIllard and Green. (See Exhibit
28)
4. Prior to being approached by the journalism students on January 20, 1999 Walter Jackson had
received a letter from Professor David Protess asking Jackson to call him at home. Between Christmas
and New Years Day of 1998 Walter Jackson called Protess. During this conversation Protess told Walter
Jackson that if Jackson helped Protess free Anthony Porter that Protess would in turn help Jackson get
out of jail. Protess also wanted Jackson to help him get the cooperation of his aunt, Inez Jackson
Simon. Protess also told Jackson that there would be money waiting for him when he got out of
jail. Jackson told Protess he would do whatever he wanted. (See Exhibit 28)
5. After first talking to Walter Jackson, Protess then sent the journalism students to see Walter Jackson
with a statement for him to sign. Jackson signed the statement (See Exhibit 11) wherein Jackson claimed
that Simon had admitted to him that he shot Hillard and Green.
6. Walter Jackson now admits that the entire statement is false. Alstory Simon never told Walter Jackson
he shot Hillard and Green and the reason he signed this statement was because Protess had promised to
get him out of jail and provide him with money when he got out of jail. (See Exhibit 28)
7. Jackson was also asked by Protess to call Inez Jackson Simon and ask her to help Porter beat his
case. Jackson spoke on the phone with both Inez Jackson Simon and her daughter, Tiffany Jackson.
Jackson told both of them that if Inez helped Professor Protess get Porter out of jail that Protess was
going to help him get out of jail. Inez agreed to help.(See Exhibit 28)
8. On December 16, 1998 Protess and several of his students visited with Anthony Porter at the Cook
County Jail. All admit that during this interview it was Porter who raised the issue and told them that they
should locate and interview Walter Jackson and Inez Jackson because he knew that they would help
him. (See Exhibits 21, 22, 23, 24, and 25)

9. It was after Inez Jackson Simon was first contacted by Walter Jackson, who asked her to help free
Porter, that Protess, Ciolino and several of the students went to visit Inez on January 29, 1999.
10. On January 29, 1999 Inez Jackson Simon claimed both in a written statement and on video tape that
she was in Washington Park with Hillard, Green and her husband, Alstory Simon, drinking in the
bleachers. She claimed that Simon then fired two shots and both Hillard and Green immediately slumped
over on the bleachers. Inez claimed that Simon immediately grabbed her by the arm and pulled her out of
the park. After first stopping for a banana split at a local ice cream shop Inez claimed that they returned
to their apartment. Inez is claiming that after observing a violent double homicide involving her best
friend, which occurred after 1:00 a.m., she and the killer went out for ice cream. Inez admits that she
never told anyone that she had witnessed these murders for seventeen (17) years.
11. Inez Jackson Simon now admits that this entire story was false.
12. On November 10, 2005 Inez Jackson Simon provided both a signed affidavit (attached as Exhibit 29)
and a video taped statement to Private Investigators James Delorto and John Mazzola . On November
11, 2005 she was asked additional follow-up questions on video-tape by the same investigators (the video
taped statements of November 10th and 11th 2005 are attached as Exhibit 30).
13. Inez Jackson Simon now admits that she was not present in Washington Park when Hillard and
Green were killed. She has no knowledge of who killed the victims and no knowledge as to the
involvement of Alstory Simon.
14. Inez Jackson Simon has admitted that the reason she gave the false statement to Protess and Ciolino
was in an effort to help her nephew, Walter Jackson, and son, Sonny Jackson, get out of jail. She admits
that Walter Jackson called her and told her that if she helped Protess free Porter that Protess was going
to help him get out of jail. Inez also received a letter from her son, Sonny Jackson, who was also
incarcerated, telling her that it would help him if she helped get Porter out of jail by claiming that Alstory
Simon killed Hillard and Green.
15. Inez also states in her video-taped statements (See Exhibit 30) that Protess promised her money if
she helped him free Porter. She states that Protess repeatedly told her that she would get a big check.
16. Inez Jackson Simon also provided a video-taped statement on October 8, 2003 (attached as Exhibit
31 ) during which she states the following:

Attorney Martin Abrams called her sister and agreed to represent Inez at no cost.

That she and her sister, Rita Carlisle met in the office of Martin Abrams along with Protess and
Ciolino. She was told in this meeting that if she testified to anything different than what was contained
in her statement to Protess and Ciolino that she could go to jail.

The next time she traveled to Chicago a limousine was sent to pick her up and take her to a downtown
Chicago hotel. She does not know who paid for the hotel or the food and alcohol all of which were
provided to her at no charge.

During a trip to Chicago she and her attorney, Martin Abrams met with Protess at which time Abrams
told Protess that Inez could not accept less than $10,000 for her book rights. Inez stated that Protess
told her that he would get in touch with her when he got ready to write the book. She has never heard
from him in this regard.

In the presence of Protess, Inez states that Abrams told her that when Anthony Porter wins his civil
case that Porter would take care of her by giving her at least $500,000 out of the millions he would
collect. She has never received any money from Porter or from anyone on his behalf.

17. Inez Jackson Simons daughter, Tiffany Jackson, has submitted to a video-taped statement on
October 8, 2003 (attached as Exhibit 32) wherein she acknowledges that:

Her mother, Inez, has serious alcohol and drug problems.

She first met David Protess when he drove her and her mother to Chicago where they were lodged in
a hotel. Large amounts of alcohol were provided to her mother.

Her mother told her that she was helping to free Anthony Porter because Professor Protess was going
to help get Walter Jackson out of jail.

Inez told her that Protess had promised her she would receive money off book rights.

Walter Jackson called her at home looking for Inez and Walter told Tiffany that Anthony Porter had
kept him from being shanked (stabbed) in prison and that he appreciated what Porter had done for
him and that he was going to look out for Porter.

She has a close relationship with her mother who never told her that she had been present when
Hillard and Green were killed.
18. Rita Carlisle, the sister of Inez Jackson Simon has also provided a video-taped statement on
October 8, 2003 (attached as Exhibit 33) and stated the following:

She has a very close relationship with her sister, Inez Jackson

Simon and at no time did Inez ever tell her that she had been present in Washington Park when
Hillard and Green were killed.

Walter Jackson called her home and told her that Anthony Porter had saved his life and now he was
going to save Porters. Walter Jackson told her the reason he had talked to Professor Protess was
because Porter had saved his life and he was going to help save Porter.

Inez told her that she had been promised cash and money from book and movie deals by David
Protess.

Protess arranged for Inez to be represented by attorney Martin Abrams.

She was present when Abrams told Inez that if she did not continue to say the things contained in her
statement to Protess that she could go to jail.

She had a phone conversation with Martin Abrams after Inez Jackson Simons daughter, Tiffany
Jackson, had made a public statement that she did not believe that Alstory Simon had killed Hillard
and Green.

Mr. Abrams told Rita that Tiffany should keep her mouth shut.
William Taylor
19. Ciolino prepared a statement (see Exhibit10) which purported to be a recantation of the testimony
Taylor provided in the trial of Anthony Porter. In this statement Taylor states that on the night of the
murders of Hillard and Green that he did not see Porter with a gun or shoot anyone.

20. On February 10, 1999, in a court reported statement taken by Assistant States Attorney Thomas
Gainer, Taylor maintained that although he did not see Porter fire the gun he did see Porter run by him
immediately after the shooting in the bleachers. (See Exhibit 15)
21. The first member of the Northwestern journalism team working on behalf of Porter to talk to Taylor
was a student, Thomas McCann, who interviewed Taylor on November 28, 1999. Taylor told McCann
that Porter had shot Hillard and Green and that there was no doubt in his mind that Porter was guilty of
these murders. (See pages 10-18 of the Grand Jury testimony of McCann attached as Exhibit 22)
22. On December 11, 1998 Ciolino accompanied McCann to interview Taylor again. During this
conversation Taylor told Ciolino that he had seen Porter in the park the night of the murders. (See page
22 of Ciolinos Grand Jury testimony attached as Exhibit 20 ). This critical fact does not appear in the
statement prepared by Ciolino. The statement merely states that Taylor did not see Porter fire the gun.
(See Exhibit 10 )
23. Next Professor Protess went to talk to Taylor on December 14, 1998. Protess admits that this
interview took several hours during which Taylor was drinking wine. (See pages 36 and 45 of the Grand
Jury testimony of Protess attached as Exhibit 21). Protess admits that Taylor told him that the man who
ran past him immediately after the murders in the bleachers looked like Anthony Porter and that he
thought it was Anthony Porter. (See page 39 of Protess Grand Jury testimony attached as Exhibit
21). As was the case with the written statement prepared by Ciolino on December 11, 1998, this
important observation by Taylor does not appear in Taylors written statement obtained by Protess on
December 14, 1998.
24. On October 9, 2002 Taylor provided a deposition in a civil action filed by Anthony Porter against the
City of Chicago. During this deposition (attached as Exhibit 34 ) he revealed that he was very familiar
with Anthony Porter at the time of the murders of Hillard and Green. Specifically, he testified to the
following:

He was afraid of Porter and his brothers. (Pg. 43 of Exhibit 34)

He would see Porter one or two times a month in 1982. (Pg. 42 of Exhibit 34)

He knew Porter to be a neighborhood gang-banger. (Pg. 42 of Exhibit 34)

He had seen Porter jump a couple of his friends. (Pg. 43 of Exhibit 34)

He was afraid of Porter because Porter knew where he lived with his 95 year old grandmother. (Pg.
45 of Exhibit 34)

Porter was a bad person who would kill someone. (Pg. 88 of Exhibit 34 )
25. Taylor also told Ciolino that he had seen Porter commit a robbery of two old men outside his
grandmothers apartment. (See page 23 of Ciolinos Grand Jury testimony attached as Exhibit 20)
26. On November 8, 2005 William Taylor testified in the civil case filed by Porter against the City of
Chicago.(See the Transcript of Taylors testimony attached as Exhibit 35). During his testimony at trial
Taylor made the following additional statements which relate to his motives and bias in connection with
his testimony surrounding the murders of Hillard and Green:

He admitted that he testified in the 1983 criminal trial of Anthony Porter that he feared Porter because
he had seen Porter beat up andmug old men in the neighborhood. (Pg. 71 of Exhibit 35)

He had seen Porter beat up two of his friends. (Pg. 71 of Exhibit 35)

He was frightened of Porter because Porter knew where he lived with his 95 year old grandmother.

He admitted that he has appeared on national television and stated that the man who ran past him
immediately after the shooting of Hillard and Green looked like Anthony Porter. (Pg. 75 of Exhibit 35)

He admitted that the man who ran past him immediately after the shooting looked like Anthony
Porter. (Pg. 76 of Exhibit 35)

He admitted that the reason he signed the statement at the request of Ciolino on December 11, 1998
was because he wanted to get Ciolino to leave his house and that he was tired of people hounding
him for years to change his identification. (Pg. 77 of Exhibit 35).

He admits telling Assistant States Attorney David Kerstein, during a visit to the swimming pool area of
Washington Park, exactly where he was when he saw Porter shoot the people in the bleachers. (Pg.
84 of Exhibit 35)

He states that he did not provide the statement to Ciolino (Exhibit 10) willingly. (pg. 95 of Exhibit 35)
Actions of Protess, Ciolino and Rimland
1. Walter Jackson acknowledges in his affidavit of November 29, 2005 that he provided false evidence
against Alstory Simon and encouraged Inez Jackson Simon to do the same as a direct result of promises
made to him by David Protess that Protess would both help him get out of jail and also provide him with
money when he got out of jail. (See Exhibit 28)
2. Inez Jackson Simon now admits that she made false statements implicating Alstory Simon in the
murders of Hillard and Green because Walter Jackson had told her that Protess had promised that he
would get her nephew, Walter Jackson, and her son, Sonny Jackson, out of jail. (See the affidavit of Inez
Jackson Simon attached as Exhibit 29)
3. Inez has also stated that Protess and Ciolino offered her large sums of money, and movie and book
deals if she provided testimony implicating Simon and helping to free Porter. (See video-taped
statement of Inez Jackson Simon attached as Exhibits 30 and 31)
4. This case does not represent the first and only time Protess and Ciolino offered witnesses money to
coerce them to provide testimony helpful to them. Professor Protess actually wrote in his
book, Promises of Justice, about another case when the same investigator, Paul Ciolino, posed as a
Hollywood producer, Jerry Bruckheimer, and offered a witness a movie deal in return for a change in his
testimony. (See excerpts from Promises of Justice attached as Exhibit 36)
5. In March of 1996 Protess and Ciolino were involved in attempting to free the defendants convicted in
what has been referred to as the Ford Heights Four case. Charles McCraney had been a significant
prosecution witness at the initial trial having provided inculpatory evidence against the defendants. In a
letter dated March 14, 1996 on Northwestern University letterhead, Protess tells McCraney that he can
not provide up-front money to him but that there will be book and movie deals from the case. Protess
told McCraney that he had monetary rights but only if he clears up his inconsistencies and is
straight about what he saw the night of the murders. (See the letter from Protess dated March 14, 1996
attached as Exhibit 37 ). In a handwritten note to McCraney, Protess advised the witness to contact him
because he had information for you that should be helpful financially. ( see Exhibit 38 )
6. Ciolino also was involved in freeing convicted murderer Madison Hobley from custody. In connection
with a civil suit filed by Hobley a deposition was taken from Andre Council, a key prosecution witness at

the trial of Hobley. On October 22, 2004 Mr. Council testified that Ciolino and another individual offered
him a free college education for his daughter and suggesting that he would never need to work again in
return for his recantation of his trial testimony against their client. (See pages 58-68 of the deposition
transcript of Andre Council attached as Exhibit 39)
7. On January 15, 2003 Ciolino provided testimony at a deposition in the civil case filed by Anthony
Porter. Ciolino falsely testified that he had never offered any witness anything of value in exchange
for favorable testimony including reference to moneys from any book and movie deals. (See pages 8081 of the deposition testimony of Ciolino attached as Exhibit 40)
8. Four years earlier, on January 14, 1999, Ciolino gave a deposition in the civil case filed by Ford
Heights Four. In that deposition, Ciolino admitted that he had posed as a Hollywood producer, that he
made an offer of a movie deal to a witness, and actually showed the witness a phony movie contract in
order to obtain a statement from the witness. (See pages 30-45 of the deposition transcript of Ciolino
attached as Exhibit 41)
9. Within twenty-four (24) hours of Simon providing Ciolino with a video-taped statement admitting to
having killed Hillard and Green, attorney Jack Rimland was hired by Paul Ciolino to represent Simon.
10. On February 4, 1999 Rimland stated publicly that obviously if he (Simon) is charged, hes looking at
the death penalty. (See Chicago Tribune article from February 4, 1999 attached as Exhibit 42).
11. Jack Rimland, Paul Ciolino and Martin Abrams all shared office space at 900 W. Jackson Ave. in
Chicago at the time Ciolino procured Rimland to represent Simon and Abrams represented Inez Jackson
Simon. (See Exhibit 42A). Rimland and Ciolino currently office together at 820 W. Jackson Suite 300 in
Chicago. (See Exhibit 42B)
12. On information and belief Rimland and Ciolino had a close personal and professional relationship
which included Rimland representing Ciolino on a criminal charge of Assault filed in case #00-5-005307 in
the Fifth District Circuit Court of Cook County.
13. Missing.
14. In 1999 Jack Rimland was the President of the Illinois Attorneys for Criminal Justice. On May 7,
1999, while purporting to be representing Alstory Simon, he presented awards to David Protess, Paul
Ciolino and five (5) students for their actions in freeing Anthony Porter and developing evidence against
his client. Rimland, in presenting these awards stated: David Protess and his students utilized their
talents as investigative journalists and successfully uncovered crucial evidence resulting in the freeing of
Anthony Porter. (See May 21, 1999 Inside Medill News attached as Exhibit 43).
15. On November 29, 2005 Rev. Robert Braun executed an affidavit (attached as Exhibit 44) where he
makes the following statements of fact regarding Alstory Simon and attorney, Jack Rimland.

Simon told him after his arrest that he was innocent of the murders of Hillard and Green but that he
was going to plead guilty because he had made a deal with the investigator working for the professor
from Northwestern.

Simon told him that the investigator (Ciolino) had offered him a lot of money from a movie and book
deal if he plead guilty and that he had been promised that the professor would get him out of jail after
two years.

Simon told him that his attorney, Jack Rimland, told him that he should go along with the deal and
plead guilty and that Rimland told him that it did not make any difference if he didnt commit the
murders.

16. Rev. Braun states in his affidavit (Exhibit 44) that he called Rimland personally and told Rimland he
thought it was wrong for Simon to plead guilty to a crime he did not commit. Rimland told him that it did
not make any difference if Simon did not commit the murders because it he went to trial he would get
convicted and then would get the death penalty.

Rev. Braun asked Rimland about whether Simon had a deal with Ciolino and Protess and would only
do two (2) years in jail. Rimland told him that he could trust both Protess and Ciolino and that they
were friends of his and that he did a lot of work with them.

Rimland also told Braun that he did not have a conflict of interest in representing Simon despite his
relationship with Protess and Ciolino.
17. On April 1, 2003 Anthony Porter provided testimony at a deposition in the civil case he had
filed against the City of Chicago. He clearly and unequivocally states, under oath, that he was never in
Washington Park the day or night of the murders of Hillard and Green. (See page 67 of the deposition
transcript of Porter attached as Exhibit 45 )
C. Alstory Simons Claims of Coercion by Ciolino and Rimlands Ineffective Assistance of Counsel
(see the Affidavit of Alstory Simon attached as Exhibit 46)
No Involvement in Murders
1. I was at Washington Park on August 15, 1982, the day of the Bud Billiken day parade, with several
people, including my wife Inez Jackson, and Jerry Hillard and Marilyn Green.
2. Inez got drunk, and we left early in the evening to check on the kids. When we left the park Hillard and
Green were alive. We stopped for some ice cream and went home.
3. The next day Chicago police officers came to our place at 5323 S. Federal in the projects, and showed
us pictures of Jerry and Marilyn. Inez took the police to Marilyns parents place.
Leaving Chicago and Moving to Milwaukee
4. One night, a week or two after the murders, gang bangers fired gunshots into our apartment and I told
Inez that we had to leave. We moved to Roosevelt and Racine and stayed with a friend of mine for a
couple of months, and then moved to Milwaukee around the end of 1982 or beginning of 1983.
5. I lived and worked in Milwaukee for 17 years until 1999. I never had any trouble with the law except
for one charge of possession of cocaine in the 1990's and a couple of arrests for problems I had with
Inez.
6. Inez was a serious drug addict and alcoholic. She would use the house to have sex with people when I
was at work so she could get money for drugs, and we would fight, and the police would come to the
house. The problems between me and Inez got worse and worse, and finally, around 1991, I threw Inez
out of the house, and never saw her again until I saw her on television in 1999 saying she saw me commit
two murders in 1982.
Initial Contact by Investigators and others working for Porter
7. Sometime before I threw Inez out, an investigator came to our house and said he represented Anthony
Porter and wanted to talk to me and Inez about the murders. We told him that we saw the victims at the
park but went home earlier in the evening to check on Inezs kids, and didnt hear about the murders until
the next day.
8. In late 1998, two girls came to my house and said they were doing some school project about the case,
and asked if I would talk to them about it. I told them the truth too, and then another guy, who I now know

to be professor David Protess, walked up to the house and accused me of doing the murders. I told him
to leave.
Ciolino Comes to his House on February 3, 1999
9. At approximately 6:30 am. on February 3, 1999, two men armed with guns came to my house in
Milwaukee. They told me they were police investigators from Illinois, and accused me of shooting Jerry
Hillard and Marilyn Green. They told me that my ex-wife Inez and other witnesses had signed
statements stating that I had committed the murders. At the time I had been up all night doing cocaine
and drinking with my girlfriend Pearl Russ, who was getting ready to leave for work when they arrived.
10. I told the person who I now know to be Paul Ciolino that he was crazy, that I did not kill anybody, and
that he and his partner should leave my house. He told me they were not going anywhere, and
that I had better look at the evidence he had.
11. Ciolino then made me watch a videotape of a black male person stating that he was a witness to the
murders and that he actually saw me shoot the two victims. At this point I became angry, repeated that I
knew nothing about the murders, told them that the witness in the videotape was a liar, and again told the
men to leave my house.
12. They refused to leave. They showed me a statement from Inezs nephew, Walter Jackson, stating
that I told him on the day of the murders that I killed the victims. I continued to tell the men that I didnt kill
anybody, that this was all crazy, and that they should leave right then.
13. During this whole time, Ciolino kept telling me that they had all the evidence they needed to convict
me, that I was going to go down for these murders and end up on death row, and there was nothing I
could do about it. After showing me the videotape and the affidavits, Ciolino said I want you to see
something, and they tuned the TV to a station that was doing a story about the murders. The TV story
presented the same professor who had previously come to my house with the girls, saying Anthony Porter
was innocent, and the story also included a video tape of Inez saying that she saw me shoot the
victims. Ciolino also showed me a signed statement where Inez said she saw me shoot Jerry Hillard and
Marilyn Green.
14. After seeing this story on TV, I was no longer just angry. I was scared to death. For the first time I
believed that I was actually going to be charged with committing the murders. One of the men then
turned the TV off and Ciolino said that he was going to level with me. He said that the men were not
police investigators, but actually, were private investigators who worked for the professor who they
had just shown me on television. He said they had all the evidence they needed to put me on death row,
and that the Chicago police were on their way to arrest me right then. He said that once the police get to
my house there would be nothing more he could do for me, and this was my one and only chance to help
myself by giving a statement saying that I shot the two victims in self-defense.
15. Ciolino said that he and the professor wanted to free Anthony Porter, that when he got out, millions of
dollars were going to be made on movies and book deals, that I would be entitled to a lot of the money,
and that they were not concerned with hurting me. He convinced me that he was actually trying to help
me by giving me a way out before the police got to my house to arrest me. He said that if I gave a
statement saying I did the crimes in self-defense, that he would get me a free lawyer, that the professor
could make it so that I only had to serve a short time in prison, and that when I got out, Id be taken care
of financially, and would not have to work again. I told Ciolino that this was all crazy, that I did not kill
anyone, and that I could not believe they were doing this. At one point, Ciolino put his hand on his gun
and said that we could do this the easy way, or we could do it the hard way, but either way, I was going to
give a statement. I even attempted to get to the phone to call the Milwaukee police, at which time the
other investigator, who was also armed, stood in front of the phone and blocked me from getting to

it. Ciolino told me that people have accidents in their homes all the time, and that we could even have an
accident right now.
16. By this time, I was convinced that if I did not say I shot the two victims in self-defense, that they had
enough evidence to convict me of murder and that I would end up on death row. Ciolino asked me if I
could read, and when I said that I could, he told me to read what was in the papers he had. He wrote on
a pad of paper and said that we would practice my statement until I memorized it well enough to say on
videotape. I then read the affidavits Ciolino gave me, and he told me to just say that I only shot Jerry
because I thought he was going for a weapon, and that Marilyn getting shot was just an accident
because she just got in the way. Ciolino emphasized to me that it was important for me to say when I
shot them that I was in fear for my life and that shooting Marilyn was just an accident. He said that he
would make sure that it was a self defense case.
17. After we practiced the statement several times, Ciolino had me say the statement on the videotape. I
had the papers he showed me next to me when I was giving the statement so I could remind myself of
things if I forgot what he wanted me to say. At some point, Ciolino made a phone call and told me that
attorney Jack Rimland would be representing me. He assured me that, just as he was doing with
Anthony Porter, Professor Protess would be able to pull the strings necessary to have me released from
prison after a short time.
Representation by Rimland
18. At various times, attorney Rimland also told me I could face the death penalty, that the prosecution
had a strong case against me, and that I needed to make a deal so that I could avoid death row or life in
prison. He never told me that the person in Ciolinos videotape was an actor, that several people had
identified Anthony Porter as either the shooter or being at the scene of the crimes when they occurred,
that Porter had denied being at the park that night, that Inez Jacksons statement about me was obviously
untrue, or that the tactics Ciolino used to get me to make a statement were illegal.
19. Rimland never told me that I had a right to file a motion in court for a judge to determine whether the
statement I gave to Ciolino was admissible against me in light of the tactics used by Ciolino. In short, he
never told me that I had any sensible alternative other than to plead guilty and to take the deal the
prosecution was offering. Rimland also never told me that he shared office space with Ciolino nor that he
had a close personal and professional relationship with both Ciolino and Protess.
20. Rimland told me that the only witness who saw Porter in the park the night of the murders of Hillard
and Green was William Taylor and that he had recanted his trial testimony and he had not seen Porter
commit the murders. He never told me that there were any other witnesses who saw Porter in
Washington Park the night of the murders. Rimland never discussed with me any of the evidence which
showed that Porter had committed these murders. Rimland never provided me with transcripts of what
any witness had testified to before the Grand Jury nor did he inform me what any witness had testified
to. He told me that the evidence against me was so strong that I had no option but to plead guilty.
21. Rimland also told me that Inez Jacksons nephew Walter Jackson had told police that I was behind
some murder he committed in Milwaukee in the early 1980's, and that if I did not take the deal, I was
going to be prosecuted for that case as well. It wasnt until the sentencing hearing that I heard the
Milwaukee County District Attorney state that they knew I did not shoot the victim in that case, that I was
not present at the shooting, and that they did not have a strong case against me. Rimland told me that I
had to sound convincing at the plea agreement for everything to work out and that I needed to apologize
to Marilyn Greens mother, which I did even though I hadnt done anything to her daughter. I knew
nothing about Jacksons murder in Milwaukee and was completely uninvolved in it.
22. Sometime after I plead guilty, Rimland sent me a letter advising me that our business was concluded
and that he was no longer representing me. By this time, I had begun to understand that

Protess and Ciolino were not going to take steps to have me released from prison, and that I was not
going to receive any money. As a result, I began my own efforts to secure my freedom by filing a pro-se
post-conviction petition. In preparing my pro-se post-conviction petition, I did not have access to the
materials and witnesses necessary to adequately set forth all of the facts and circumstances involved in
the denial of my constitutional rights.
23. I had no involvement in the murders of Jerry Hillard and Marilyn Green. I only gave the statement to
Ciolino because he had convinced me that if I did not say that I killed these people in self-defense I was
gong to death row and there was nothing I could do about it. He also convinced me that if I did say I
killed them in self-defense I would serve just a couple of years in prison and that I would benefit from
movie and book deals when Protess got me released.
ARGUMENT
Petitioners rights under the Constitutions of the United States and the State of Illinois were substantially
violated during the pendency of this case. Newly discovered evidence has revealed that Petitioner was
denied (1) his due process rights and (2) his right to effective assistance of counsel. This newly
discovered evidence was neither available to Petitioner immediately after his guilty plea or during his first
Post-Conviction Petition.
Further, Petitioner was unable to gather this newly discovered evidence until recently due to his current
incarceration. This newly discovered evidence only came to light recently during a civil lawsuit filed by the
original suspect, Anthony Porter.
Accordingly, the matters raised in this Post-Conviction Petition could not have been raised in the previous
petition because the supporting facts were unknown to Petitioner. See People v. Flores, 153 Ill. 2d 264,
274, 606 N.E.2d 1078, 1083 (1993). Here, the newly discovered evidence supporting either of these
constitutional violations requires this Court to grant Petitioners Post-Conviction Petition and conduct an
evidentiary hearing concerning the violation of Petitioners constitutional rights.
1. Due Process Violation
Actual innocence based solely on newly discovered evidence may be raised in a post-conviction petition
as a violation of a defendants due process rights. However, the supporting evidence must be new,
material, noncumulative, and so conclusive that it would probably change the result on retrial. People v.
Johnson, 205 Ill. 2d 381, 392, 793 N.E.2d 591, 598-99 (2002).
Here, the newly discovered evidence establishes that the factual basis upon which Petitioner pleaded
guilty and was convicted was fabricated using threats, promises, and coercion, and has since been
recanted in its entirety.
As such, no credible evidence remains inculpating Petitioner in the murders.
The only evidence implicating Petitioner, other than his coerced confession, was the statements of Walter
Jackson and Inez Jackson. However, the newly discovered evidence establishes that these statements
were obtained through promises of money and of getting Walter out of prison. These statements have
since been recanted in toto.
Additionally, Petitioners alleged confession was obtained by Investigator Ciolino using these falsified and
fabricated statements. When Ciolino confronted Petitioner with this false evidence, including a phony
video tape statement of an actor claiming to be a witness, and a national news story falsely accusing him
of murders, Ciolino continued to coerce Petitioners confession by

refusing to leave Petitioners house when he was told to do so,

falsely telling Petitioner he had ample evidence to convict him of the murders,

falsely telling Petitioner that the police were on their way to his house to arrest him,

falsely telling Petitioner that this was his only chance to help himself by claiming he shot the victims in
self-defense,

refusing to allow Petitioner to use the phone to call the Milwaukee police,

telling Petitioner that he would make a statement whether we do this the easy way or we do it the
hard way,

suggesting to Petitioner that people have accidents all the time in their homes and Petitioner could
have an accident that morning,

promising Petitioner a lawyer free of charge,

falsely assuring Petitioner that he would only serve a short time in prison if he confessed,

falsely telling Petitioner that he would be taken care of financially if he agreed to give a statement that
he shot the victims in self-defense.
Accordingly, when the evidence used to coerce Petitioners confession is recanted, the confession itself
becomes unreliable, leaving absolutely no evidence, either witnesses or physical evidence, that Petitioner
committed the murders.
Further, it is well settled that a coerced guilty plea deprives a defendant of liberty without due process of
law.
As such, an allegation that a guilty plea was coerced raises a substantial constitutional issue and clears
the way for a collateral attack on the conviction. People v. Crislip, 20 Ill. App. 3d 175, 178, 312 N.E.2d
830, 833 (5th Dist. 1974), citing Machibroada v. United States, 368 U.S. 487, 82 S. Ct. 510 (1962).
Moreover, a coerced guilty plea raises matters outside the record. As such, these claims cannot be
adjudicated on the pleadings and record alone, and the petition is entitled to a hearing. See Crislip, 20
Ill.App.3d at 178, 312 N.E.2d at 833, citing People v. Thomas, 38 Ill. 2d 321, 324-25, 231 N.E.2d 436,
437-38 (1967).
Thus, on this basis alone, an evidentiary hearing must be conducted.
Moreover, the newly discovered evidence establishes that Petitioner was coerced by his own attorney to
plead guilty to the alleged crimes, even though he was innocent.
The new evidence establishes that Petitioners attorney, Jack Rimland, represented Petitioner pro-bono
(as promised by Ciolino), previously worked with Ciolino on similar cases, and shared an office with
Ciolino.
Moreover, attorney Rimland coerced Petitioner to plead guilty by representing that

the case against him was strong, although the evidence against him was fabricated and several
witnesses implicated Porter as the gunman,

he could face the death penalty if he did not plead guilty,

the witnesses implicating Porter recanted, and

the police had evidence that Petitioner was involved in a murder in Milwaukee and if he did not agree
to plead guilty, he would be prosecuted for that case.
Now, the newly discovered evidence indicates that Petitioner was coerced by attorney Rimland into
pleading guilty based on fabricated evidence of his guilt.
2. Ineffective Assistance of Counsel
To establish a claim for ineffective assistance of counsel, Petitioner must show that counsels
representation fell below an objective standard of reasonableness so as to deny him the right to
counsel guaranteed under the 6th Amendment. See Strickland v. Washington, 466 U.S. 668, 687-88,
104 S. Ct. 2052, 2064 (1984).
Petitioner must establish that the deficient performance resulted in prejudice, which requires a showing
that there is reasonable probability that, but for counsels performance, the results of the trial would have
been different. Reasonable probability equates to a probability sufficient to undermine the confidence in
the outcome. Strickland, 466 U.S. at 694, 104 S. Ct. at 2068; People v. Haynes,192 Ill. 2d 437, 472-73,
737 N.E.2d 169, 189 (2000).
Furthermore, [t]he Illinois Supreme Court has repeatedly recognized that waiver or procedural default
may not preclude an ineffective assistance claim for what trial or appellate counsel allegedly ought to
have done in representing a criminal defendant. People v. Makiel, 358 Ill.App. 3d 102, 105, 830 N.E.2d
731, 737 (1st Dist. 2005).
Besides establishing that attorney Rimland wrongfully coerced Petitioner into pleading, the newly
discovered evidence establishes that Rimland also failed to investigate the legitimacy of the evidence
against Petitioner, but rather took it at faced value based on his own incompetence or his conflict of
interest due to his relationship with Investigator Ciolino and Professor Protess.
Either way, attorney Rimland provided ineffective assistance of counsel in violation of the 6th
Amendment.
Attorneys have an obligation to explore all readily available sources of evidence that might benefit their
clients. Defense counsel has a professional obligation, both legal and ethical, to explore and investigate
a clients case.
Failure to conduct an investigation and develop a defense has been found to be ineffective
assistance. See Makiel, 358 Ill. App. 3d at 107, 830 N.E.2d at 739.
Here, within 6 months of representing Petitioner, attorney Rimland allowed Petitioner to plead guilty when
conflicting evidence as to his guilt existed, which in fact was presented to the grand jury.
Clearly, Rimland could not investigate both the evidence implicating and exculpating Petitioner within this
6-month time frame. In fact, Rimland stated that it did not make any difference if Petitioner did not commit
the murders because the evidence (which we now know was fabricated) was sufficient to convict him and
he would get the death penalty. (See Affidavit of Reverend Braun Exhibit 44).
Moreover, attorney Rimlands failure to investigate the Petitioners case and develop a defense is
explained by his close relationship with Ciolino and Investigator Protess. The newly discovered evidence
establishes that Rimland and Ciolino share an office, and on May 7, 1999, while purportedly representing
Petitioner and before Petitioner pleaded guilty, Rimland presented awards to Protess and Ciolino for their
actions in freeing Anthony Porter, and in so doing, gathering evidence against Petitioner.
Clearly, any evidence negating Petitioners guilt would question the legitimacy of the evidence gathered
against him, and in turn, supporting Porters release. As such, Rimland had, at the very least, a conflict of

interest based on his relationship with those investigating the case against Petitioner, and at the very
worst, a motive to not investigate the inculpatory evidence and quickly coerce Petitioner to plead to the
alleged murders in order to preserve the legitimacy of Porters release.
Rimlands actions evidence an absolute absence of objectivity in his representation of Petitioner related to
these murders. As such, an evidentiary hearing must be conducted concerning Rimlands ineffective
assistance during his representation of Petitioner.
CONCLUSION
Wherefore, Petitioner, Alstory Simon, respectfully requests that this Honorable Court grant his PostConviction Petition. Petitioner believes that the newly discovered evidence is so persuasive in
establishing the alleged constitutional violations, this Court must grant Petitioners Post-Conviction
Petition and conduct a full evidentiary hearing. See e.g. People v. House, 141 Ill.2d 323,
388-89, 566 N.E.2d 259, 288-89 (1990).
Respectfully submitted;
Terry A. Ekl
Connolly, Ekl & Williams, P.C.
James G. Sotos
James G. Sotos & Associates
Terry A. Ekl
Connolly, Ekl & Williams, P.C.
Attorney # 21572
115 W. 55th St. Suite 400
Clarendon Hills, Illinois 60514
Phone #:

630-654-1624

James G. Sotos
James G. Sotos & Associates
Attorney # 42176
333 Pierce Road Suite 195
Itasca, Illinois 60143
Phone #:

630-860-4341