Interrogation of Battalion Chief Kenneth Caudle Huntley Fire Protection District

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INTERROGATION OF
BATTALION CHIEF KENNETH CAUDLE
HUNTLEY FIRE PROTECTION DISTRICT
September 6, 2017
The interrogation interview of BATTALION
CHIEF KENNETH CAUDLE, taken in the above-entitled
cause before Linda A. Waliczek, a Certified
Shorthand Reporter of said State, taken at 11118
Main Street, Huntley, Illinois, on the 6th day of
September, 2017, at the hour of 9:15 a.m.
SCHELLI REPORTING SERVICE, LTD. (312) 558-1113

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1 APPEARANCES:
2 OTTOSEN BRITZ KELLY COOPER GILBERT & DiNOLFO,
3 LTD.
4 BY: MR. STEPHEN DINOLFO and
5 MR. VLADIMIR SHULIGA, JR.
6 1804 North Naper Boulevard, Suite 350
7 Naperville, Illinois 60563
8 (630) 682-0085
9 sdinolfo@ottosenbritz.com
10 Appeared on behalf of the
11 Huntley Fire Protection District;
12
13 JOLANTA A. ZINEVICH, LLC
14 BY: MS. JOLANTA A. ZINEVICH and
15 MR. THOMAS MCGUIRE
16 1214 West Northwest Highway
17 Suite H
18 Palatine, Illinois 60067
19 (847) 461-9373
20 Jzinevich@sbcglobal.net
21 Appeared on behalf of Battalion Chief
22 Kenneth Caudle.
23 ALSO PRESENT: CHIEF SCOTT RAVAGNIE
24 * * *

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1 I N D E X
2 WITNESS EXAMINATION
4 BATTALION CHIEF KENNETH CAUDLE 5
7 E X H I B I T S
8 NUMBER PAGE/LINE
9 Caudle Exhibit No. 1 5 8
17
18
19
20
21
22
23
24

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1 MR. DINOLFO: This is the administrative
2 interview of Battalion Chief Kenneth Caudle of the
3 Huntley Fire Protection District. This interview
4 is being conducted at the Huntley Fire Protection
5 District Annex at 9:20 a.m., on September 6,
6 2017.
7 For the record, my name is Steve
8 DiNolfo. I'm actually here on behalf of the
9 district and acting Chief Scott Ravagnie, who is
10 also present.
11 We have present for Battalion Chief
12 Caudle is --
13 MS. ZINEVICH: Jolanata Zinevich.
14 MR. McGUIRE: And Thomas McGuire,
15 M-c-G-u-i-r-e.
16 MR. DINOLFO: And, obviously, Battalion Chief
17 Caudle is present as well.
18 The interview is being conducted
19 under of the Firemen's Disciplinary Act and
20 according to the terms of a written order and
21 notice served to Battalion Chief Caudle on
22 August 25, 2017.
23
24

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1 WHEREUPON:
2 BATTALION CHIEF KENNETH CAUDLE,
3 called as a witness herein, was examined and
4 testified as follows:
5 MR. DINOLFO: Showing you what I'll mark as
6 Exhibit No. 1 for identification purposes.
7 (WHEREUPON, a certain document was
8 marked Caudle Exhibit No. 1, for
9 identification, as of 09/06/2017.)
10 (WHEREUPON, the document was tendered
11 to Battalion Chief Caudle.)
12 MR. MCGUIRE: Thank you.
13 MR. DINOLFO: Is that the order that was served
14 upon you on August 25, 2017?
15 BATTALION CHIEF CAUDLE: Yes, it was.
16 MR. DINOLFO: Does the second page bear your
17 signature and then a handwritten note with your
18 initials, I believe?
19 BATTALION CHIEF CAUDLE: Yes.
20 MR. DINOLFO: You acknowledge that you did
21 receive this; and you've had a chance, obviously, to
22 speak with counsel since they're here on your
23 behalf?
24 BATTALION CHIEF CAUDLE: I have.

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1 MR. DINOLFO: This interview will proceed with
2 myself and, if needed, acting Chief Ravagnie asking
3 questions. At the conclusion of the interview, you
4 or your attorneys may make any statement that you
5 wish.
6 This interview, as you can see, is
7 being taken by a court reporter and under the terms
8 of the Firemen's Disciplinary Act. You will be
9 accorded a copy of the transcript free of charge as
10 soon as it becomes available.
11 If, at any time, during this
12 interview you need to speak privately with your
13 attorney, please let us know. We'll go off the
14 record. You'll have an opportunity to speak
15 with him. And then when you're ready to go back
16 on the record, we will proceed with the
17 questioning.
18 This is an administrative interview
19 which focuses on your duties and actions as a
20 Huntley Fire Protection District employee. As such,
21 you have no right to refuse to answer the questions
22 put to you. Should you refuse to answer the
23 questions, Acting Chief Ravagnie will order you to
24 answer the questions. If you persist in that

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1 refusal, that course of action may lead to
2 additional discipline up to and including
3 termination.
4 Do you have any questions and how
5 we're going to proceed here today?
6 BATTALION CHIEF CAUDLE: I do not.
7 MR. MCGUIRE: I do.
8 MR. DINOLFO: Okay.
9 MR. MCGUIRE: I want to bring to your
10 attention, you may already know about it, but I'll
11 feel better if I state it for the record.
12 My client submitted his resignation
13 as Fire Chief to the board of trustees in the
14 fire protection district on August 11, 2007 -- 2017.
15 There is a point of law that a
16 resignation is effective when presented. After
17 submitting that resignation, he went back to his
18 rank as battalion chief, and that rank is under the
19 jurisdiction of the Board of Fire Commissioners of
20 the district.
21 So the question is: If he did any of
22 these alleged acts in his capacity as chief, the
23 question is whether or not we should proceed with a
24 possible -- key word, possible -- disciplinary

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1 action against the chief.
2 Now, the reason I say that is
3 because there's a Second District Illinois
4 Appellate Court case. The citation is 144
5 Ill.App.3d 517. The title is Gorr, G-o-r-r, v. The
6 Board of Fire & Police Commissioners of the Village
7 of Addison.
8 It is still good law today. It was
9 decided in 1986. I have a copy of the case,
10 Counsel, if you wish to look at it.
11 MR. DINOLFO: Thank you.
13 to counsel.)
14 MR. MCGUIRE: Basically, it says an individual
15 cannot be twice punished for the same thing.
16 So if these alleged wrongful acts --
17 key word is alleged -- did, indeed, occur; and if
18 they occurred while he was the fire chief, I don't
19 see where he's subject to disciplinary action. But
20 that's -- obviously, you have to make a decision on
21 that.
22 I stated my points.
23 MR. DINOLFO: Okay. Could you swear in the
24 witness?

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1 MR. MCGUIRE: He will not be sworn because
2 there is no provision in the Uniform Firemen's
3 Disciplinary Act for an oath to be given.
4 MR. DINOLFO: Chief, order him to take the
5 oath.
6 CHIEF RAVAGNIE: Deputy Chief Caudle, I order
7 you to take the oath.
8 MR. MCGUIRE: And I'm suggesting to you, Chief,
9 that even though you don't want to be charged with
10 insubordination, you do not consider yourself to be
11 under oath.
12 Do you understand that?
13 BATTALION CHIEF CAUDLE: I do.
14 MR. MCGUIRE: Okay. The chief has given you an
15 order, and we don't want to be charged with
16 insubordination, but take the oath.
17 (WHEREUPON, the witness was duly
18 sworn.)
19 MR. DINOLFO: At the outset, Chief Ravagnie,
20 will you order Battalion Chief Caudle to answer all
21 questions put to him today?
22 CHIEF RAVAGNIE: Battalion Chief Caudle, will
23 you, please, answer all the questions?

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1 MR. DINOLFO: Battalion Chief Caudle, how long
2 have you been with the Huntley Fire Protection
3 District?
4 BATTALION CHIEF CAUDLE: A little over
5 17 years.
6 MR. DINOLFO: Does the district operate under
7 the theory of a chain of command?
8 BATTALION CHIEF CAUDLE: It does.
9 MR. DINOLFO: Is the board part of the chain of
10 command as it pertains to the operation of the
11 district?
13 MR. DINOLFO: They would be at the top of the
14 chain.
15 BATTALION CHIEF CAUDLE: Absolutely.
16 MR. DINOLFO: The next person down would be the
17 chief, deputy chief, assistant chief, down to blue
18 shirts?
20 MR. DINOLFO: Does the chief of the district
21 answer to the board?
22 BATTALION CHIEF CAUDLE: He does.
23 MR. DINOLFO: Is the chief of the district
24 obligated to follow the board's directives and

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1 wishes?
3 MR. DINOLFO: I know often in the fire service
4 we use the term all order.
5 Is a board directive, in essence, an
6 order?
7 BATTALION CHIEF CAUDLE: Board of directive an
8 order, I believe so, yes.
9 MR. DINOLFO: What was your time frame that you
10 were chief here at the Huntley Fire Protection
11 District?
12 BATTALION CHIEF CAUDLE: I was promoted in
13 November of 2012.
14 MR. DINOLFO: And then you voluntarily resigned
15 your position on or about of the letter dated
16 August 11, 2017?
17 BATTALION CHIEF CAUDLE: Correct.
18 MR. DINOLFO: At the time that you attended
19 your voluntary resignation, you were acting under a
20 contract that was entered into in May of 2017,
21 correct?
23 MR. DINOLFO: Prior to May 1st of 2017, you had
24 another chief's employment contract that you

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1 operated under?
3 MR. DINOLFO: In addition to the contract that
4 you signed, does the district have rules,
5 regulations, policies, and procedures that apply to
6 you as an employee of the district?
8 MR. DINOLFO: Do those rules, regulations,
9 policies, and procedures apply to all employees of
10 the district?
11 BATTALION CHIEF CAUDLE: They do. I'm sorry
12 could you --
13 MR. DINOLFO: Sure. Do the rules, regulations,
14 policies, and procedures apply to all the
15 commissioned employees of the department?
16 BATTALION CHIEF CAUDLE: No. Everybody has
17 a -- line was different than everybody else.
18 MR. DINOLFO: Is there a general set of Rules
19 of Conduct that apply to all employees?
20 BATTALION CHIEF CAUDLE: Yes, there is.
21 MR. DINOLFO: Prior to entering into the
22 contract on May 1, 2017, were you working as a
23 part-time police officer?

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1 MR. DINOLFO: Where was that at?
2 BATTALION CHIEF CAUDLE: Prairie Grove Police
3 Department.
4 MR. DINOLFO: Is it your understanding that the
5 board at some point became aware that you were
6 working as a police officer?
8 MR. DINOLFO: You actually had conversations
9 with certain board members concerning you working a
10 second job as a police officer?
12 MR. DINOLFO: Was it made clear to you by the
13 board members that they did not want you to work as
14 a police officer?
16 MR. DINOLFO: As a matter of fact, they
17 directed you to quit that job?
19 MR. DINOLFO: Not only did they verbally tell
20 you to quit that job, they put it into your
21 employment contract that you signed on May 1, 2017,
22 correct?

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7 MR. MCGUIRE: You can go through it if you
8 want, just thumb through it. Make sure it's what we
9 had you look at previously.
10 MR. DINOLFO: Is that the employment contract
11 that you signed on May 1, 2017?
12 BATTALION CHIEF CAUDLE: It is.
13 MR. DINOLFO: Bears your signature on the last
14 page?
16 MR. DINOLFO: As we discussed, the board had a
17 conversation with you telling you to cease your
18 secondary employment as a police officer.
19 Would that be a board directive in
20 your mind?
22 MR. DINOLFO: If we go to Section 2A, as in
23 Adam, which is entitled, "Devotion of Full Time to
24 District," we go to that second page of your

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1 contract. It indicates that the parties, meaning
2 you and the board, that you would resign from your
3 position as a part-time police officer and shall
4 refrain from any police officer employment during
5 the term of this agreement.
6 Is that accurate?
8 MR. DINOLFO: You signed the contract saying
9 you would do so?
10 BATTALION CHIEF CAUDLE: I did.
11 MR. DINOLFO: So the board told you
12 verbally, you signed the contract indicating you
13 would do it. Did you do it?
14 BATTALION CHIEF CAUDLE: I did not.
15 MR. DINOLFO: So moving forward from the date
16 of May 1, 2017, you continued to work as a police
17 officer?
19 MR. DINOLFO: Why didn't you quit as you
20 agreed to in the contract and as directed by the
21 board?
22 BATTALION CHIEF CAUDLE: To be honest, I didn't
23 think it was that big of a deal to me. Obviously,
24 it was to the board. It was in the contract. I

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1 think I was a little stuck on myself. I also
2 probably -- a little bit of ego in there.
3 MR. DINOLFO: As an employee of the district --
4 let's make it in that general area -- are you
5 obligated to comply with the orders and directives
6 of the board?
7 BATTALION CHIEF CAUDLE: Yes, sir.
8 MR. DINOLFO: And there are actually rules and
9 regulations of the department that say you have to
10 do that, correct?
19 MR. DINOLFO: Do you recognize this to be the
20 section of the Huntley Fire Protection District
21 manual dealing with prohibited conduct?
22 BATTALION CHIEF CAUDLE: It looks familiar.
23 MR. DINOLFO: Section 4.21B, as in boy, sets
24 out some conduct that's prohibited, is that

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1 correct?
3 MR. DINOLFO: We start with No. 2,
4 "Disobedience of Policies, Rules, Orders." You're
5 required to follow those, correct?
6 BATTALION CHIEF CAUDLE: That's correct.
7 MR. DINOLFO: Go to No. 16, which is on
8 page 136 at the bottom. You have a duty to comply
9 with orders district work?
11 MR. DINOLFO: Go to page 138, No. 31, which is
12 "Insubordination." That's another set of privy to
13 conduct, is that correct?
14 BATTALION CHIEF CAUDLE: That is correct.
15 MR. DINOLFO: By ignoring the directive of the
16 board to quit your job as a police officer, and by
17 ignoring the terms of the contract, do you
18 believe that you complied with the order of the
19 board?
21 MR. DINOLFO: Do you believe that you followed
22 the order of the board?
24 MR. DINOLFO: Do you believe that your conduct

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1 was insubordinate to the board?
2 MR. MCGUIRE: Objection. That's a conclusion,
3 which I don't -- it's a legal conclusion, which I
4 don't think he should make.
5 MR. DINOLFO: Go ahead.
6 BATTALION CHIEF CAUDLE: I'm sorry. What was
7 the question again?
8 MR. DINOLFO: Do you believe that your conduct
9 of not following the board's directive was
10 insubordination?
12 MR. DINOLFO: So I understand, what were your
13 normal work hours or expectations of your normal
14 work hours, putting aside if you had calls that
15 you had to respond to, Monday through Friday as a
16 chief.
17 BATTALION CHIEF CAUDLE: Monday through Friday
18 anywhere from 7:00 to 8:00 to 3:00 or 4:00 in the
19 afternoon, depending on the day, depending on the
20 week.
21 MR. DINOLFO: On weekends would there be times
22 that you would be on call?
23 BATTALION CHIEF CAUDLE: Sometimes, yes.
24 MR. DINOLFO: Is that any set hours or

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1 you're --
2 BATTALION CHIEF CAUDLE: No.
3 MR. DINOLFO: -- just on call for the whole
4 weekend?
5 BATTALION CHIEF CAUDLE: Just on call. It's a
6 rotating schedule.
7 MR. DINOLFO: During the time that you were in
8 the capacity of chief, did you ever work as a police
9 officer during the 7:00 to 3:00, 8:00 to 4:00,
10 7:00 to 4:00 time frame that Monday through Friday?
11 BATTALION CHIEF CAUDLE: Not work, no.
12 MR. DINOLFO: Would you ever leave the district
13 and go to the police department to perform any
14 function?
15 BATTALION CHIEF CAUDLE: Not during that time
16 frame, no.
17 MR. DINOLFO: Showing you what I'm going to
18 mark as Exhibit No. 4 for identification
19 purposes.
20 MR. MCGUIRE: Give us a moment, please, so we
21 can look at it.
22 MR. DINOLFO: Take your time.
23
24

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6 MR. DINOLFO: You had a chance to look at it,
7 Counsel?
8 MR. MCGUIRE: I'm sorry?
9 MR. DINOLFO: You had to chance to go through
10 it?
11 MR. MCGUIRE: I have.
12 MR. DINOLFO: Battalion Chief Caudle, do you
13 recognize these to be time sheets of the Prairie
14 Grove Police Department?
15 BATTALION CHIEF CAUDLE: I do.
16 MR. DINOLFO: And they have your signature on
17 the bottom of each page, do they not?
18 BATTALION CHIEF CAUDLE: They do.
19 MR. DINOLFO: If you can see, there's numbers
20 written in, it looks like, marker. That's how I
21 received it.
22 BATTALION CHIEF CAUDLE: Okay.
23 MR. DINOLFO: If we were to take you to
24 page 151 at the bottom, there's a date of May 22nd.

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1 It's a Monday you wrote in? That's your
2 handwriting, right?
3 MR. MCGUIRE: Excuse me. Of what year?
4 MR. DINOLFO: 2017.
6 MR. DINOLFO: No problem.
7 BATTALION CHIEF CAUDLE: Okay. Yes, I got it.
8 MR. DINOLFO: It indicates, at least according
9 to you, that from 1300 hours to 1400 hours you were
10 doing computer, and it says, road work?
11 BATTALION CHIEF CAUDLE: Radio work.
12 MR. DINOLFO: Radio work. Would that be at the
13 Prairie Grove Police Department?
15 MR. DINOLFO: Where would you be doing that at?
16 BATTALION CHIEF CAUDLE: It was in my office.
17 MR. DINOLFO: In the police department?
18 BATTALION CHIEF CAUDLE: No, here.
19 MR. DINOLFO: At --
20 BATTALION CHIEF CAUDLE: At the station. That
21 was lunch hour.
22 MR. DINOLFO: And then on Thursday, 5/25, it
23 says, "Computer work from 12:00 to 1330." Again,
24 here, at the fire district office?

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1 BATTALION CHIEF CAUDLE: In my office, yeah.
2 That was just, like, setting up a laptop, load some
3 software, it loads for a couple of hours.
4 MR. DINOLFO: If we go to the next page 138 --
5 I didn't put them in this order, but it's how we got
6 them.
7 BATTALION CHIEF CAUDLE: I got it.
8 MR. DINOLFO: We look at Friday, 5/5 of 2017,
9 it indicates computer work from 11:00 a.m. to
10 3:00 p.m.?
11 BATTALION CHIEF CAUDLE: (Nonverbal response.)
12 MR. DINOLFO: Would that be done here at --
13 MR. MCGUIRE: Excuse me. You'll have to answer
14 yes or no.
15 BATTALION CHIEF CAUDLE: I'm sorry. I
16 apologize. Sorry. Yes.
17 MR. DINOLFO: Was that work that you did on a
18 computer of the Prairie Grove Police Department
19 while working here at the Huntley Fire Protection
20 District?
22 MR. DINOLFO: You did it in your office?
24 MR. DINOLFO: If I go to the next date, Friday,

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1 5/12, on the same page, from 1500 to 2300, shift
2 work, 1500, would you be off work then?
3 BATTALION CHIEF CAUDLE: By that time --
4 MR. DINOLFO: At 3:00 p.m.?
5 BATTALION CHIEF CAUDLE: By that time, yeah.
6 MR. DINOLFO: So maybe I can move this along a
7 little bit.
8 If it shows that during the times
9 where you have indicated to me that you would be
10 working from roughly 7:00 to 3:00, 8:00 to 4:00,
11 7:00 to 4:00, and I have time sheets at the Prairie
12 Grove Police Department entering computer work or
13 radio work during that time frame, would you have
14 been doing that at the fire district?
15 BATTALION CHIEF CAUDLE: In my office, yes.
16 MR. DINOLFO: On behalf the Prairie Grove
17 Police Department?
19 MR. DINOLFO: And being compensated by them for
20 that time?
21 BATTALION CHIEF CAUDLE: Obviously, yes.
22 MR. DINOLFO: Do you believe doing the computer
23 work while at the district, in the district
24 facilities comports with the expectations of the

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1 rules and regulations of the department having been
2 chief for many years?
3 MR. MCGUIRE: Let me confer with my client for
4 a moment.
5 MR. DINOLFO: Do you want us to step out?
6 MR. MCGUIRE: No.
7 (WHEREUPON, a discussion was had off
8 the record.)
9 MR. DINOLFO: Do you need the question read
10 back?
11 BATTALION CHIEF CAUDLE: Yes, please.
12 (WHEREUPON, the record was read by
13 the reporter.)
14 BATTALION CHIEF CAUDLE: I do. And I'll
15 explain. I will expound on it a little bit.
16 So senior staff, we have kind of what
17 we call a flex schedule, because we're on call all
18 the time, we do extra hours here and there.
19 Specifically, those dates that you
20 pulled up, the week before, I was over 60 hours for
21 the week. So while I did some of that stuff while I
22 was physically here, a lot of it was done during my
23 lunch hours.
24 I was on a really crazy diet that two

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1 months that I don't do lunches. It's weird, but
2 deputies can confer that.
3 So during my lunch hours is really
4 when I was doing it, and a lot of it is just really
5 turning on a machine, loading software, and it runs
6 for two or three hours. That's really all there was
7 to it.
8 It's really no different than when
9 people did that for us. Obviously, there was a
10 compensation factor in here, and I get that.
11 Because of my flex schedule, because
12 I am not really set to specific hours, because we do
13 extra hours that are -- come throughout the months,
14 sometimes hundreds of hours, we really never looked
15 at that, as an organization, for any of the senior
16 staff.
17 There's times where we would just
18 take off for an hour here to do a dentist
19 appointment or whatever the case may be because we
20 don't get overtime, stuff like that.
21 MR. DINOLFO: Do you --
22 MR. MCGUIRE: Excuse me just a moment.
23 May I confer with my client?
24 MR. DINOLFO: Sure.

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2 the record.)
5 Do you get comp time?
6 BATTALION CHIEF CAUDLE: No. I wish.
7 MR. DINOLFO: Obviously, you were being paid by
8 the Prairie Grove Police Department or Village of
9 Prairie Grove to perform those tasks. You were
10 also receiving some type of compensation from the
11 Huntley Fire Protection District during that time as
12 well?
13 BATTALION CHIEF CAUDLE: (Nonverbal response.)
14 MR. DINOLFO: Yes?
15 BATTALION CHIEF CAUDLE: I'm sorry. Yes.
16 MR. DINOLFO: When you signed your chief's
17 employment agreement, the section we already talked
18 about, was entitled, "Devotion of Full-Time to the
19 District," do you believe that doing your secondary
20 employment, computer and radio work, comports with
21 the devotion of full-time to the district?
22 BATTALION CHIEF CAUDLE: I do not.
23 MR. DINOLFO: Now, when you would go to work at
24 the police department, did you ever use the district

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1 vehicle for police work?
3 MR. DINOLFO: Would you use it to drive there?
5 MR. DINOLFO: You drive a personal vehicle?
6 BATTALION CHIEF CAUDLE: Personal vehicle.
7 MR. DINOLFO: Did you ever use the district
8 vehicle for any type of police work?
10 MR. DINOLFO: As a police officer, I assume
11 you're permitted to carry a weapon?
13 MR. DINOLFO: Have you ever had a weapon on
14 your person while at any district facilities?
16 MR. DINOLFO: Have you ever had a weapon in any
17 district property, be it a vehicle, building,
18 anything of that nature?
20 MR. DINOLFO: What occasions would you have a
21 weapon in the district property or vehicle, and
22 which was it, property or vehicle?
23 BATTALION CHIEF CAUDLE: Vehicle. Transporting
24 a weapon.

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1 Actually, one of the trustees bought
2 a handgun from me, and I took it to his house, and
3 he purchased it from me.
5 BATTALION CHIEF CAUDLE: And I believe once or
6 twice I probably went to the range.
7 Now, remember, in my contract, it
8 stipulated that my department vehicle be
9 used for personal use, and I took that as -- at
10 least I constituted it as personal use.
11 I know I went to the range a couple
12 of times with it. Obviously, not on me, in a
13 secured case, separated from the driver, according
14 to the laws. And I did take a -- I did have a
15 weapon, and I think I might have had some
16 ammunition, too, when I took it to the trustee's
17 house.
18 MR. MCGUIRE: Excuse me for a minute to
19 confirm?
22 the record.)
23 BATTALION CHIEF CAUDLE: That would be for
24 Trustee Brown's house.

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1 MR. DINOLFO: Did you have a gun safe in your
2 office when you were chief?
3 BATTALION CHIEF CAUDLE: I did, yes.
4 MR. DINOLFO: Did you ever store a gun in the
5 gun safe?
6 BATTALION CHIEF CAUDLE: There wasn't a gun in
7 the gun safe.
8 MR. MCGUIRE: I'm sorry. Would you repeat that
9 answer?
11 the reporter.)
13 MR. DINOLFO: So I guess the question I have
14 to ask is why did you have a gun safe in your
15 office?
16 BATTALION CHIEF CAUDLE: So it was a gun safe,
17 but it was used -- and this came up last November,
18 same conversation with Attorney Miller and Trustee
19 Brown.
20 I kept an extra set of keys in there
21 for the district. I kept the district credit cards
22 in there, and we used to have a lot of gift cards.
23 Now there's probably only three or four, and it was
24 all stored in there.

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1 That's all that was. Only reason
2 being because if I was gone, the deputies didn't
3 have keys to everything. This way they know they
4 can go in. I showed them the pass code to it, and
5 then this way they can get in and get keys for
6 everything. There was an extra lock box key in
7 there and a few other things.
9 BATTALION CHIEF CAUDLE: It was pretty small.
10 MR. DINOLFO: Did you ever store any type of
11 police equipment in the district vehicle?
12 BATTALION CHIEF CAUDLE: Well, no. Well, yes.
13 Let me take that back.
14 So I'm a TEM's member, tactical
15 medical emergency medic, and there was equipment for
16 the team that was in there.
17 MR. DINOLFO: Such as?
18 BATTALION CHIEF CAUDLE: Bullet proof vest,
19 department issued helmets, clothing, stuff like
20 that, stuff for the -- for our team.
21 MR. DINOLFO: So you can prepare and wear
22 uniform?
24 MR. DINOLFO: Any other equipment that

Page 31
1 belonged to the police aspect of your job in the
2 district?
3 BATTALION CHIEF CAUDLE: No, but there was
4 something on that list that was -- it was called a
5 NARK kit -- it's not a NARK kit. It's called a NIC
6 kit, N-I-C kit, and that's used for testing,
7 obviously, narcotics, and that was used for a while.
8 Not only was I on the TEMS team, but I'm also hazard
9 material specialist for Clan Labs, and we did a lot
10 of testing, and that's what that kit was in there
11 for.
12 MR. DINOLFO: So you're saying it was part of
13 the HAZMAT team?
15 MR. DINOLFO: If I asked the person that was
16 in charge of the HAZMAT team, and they tell me
17 that those kits are not part of the standard
18 equipment --
19 BATTALION CHIEF CAUDLE: It's not standard
20 equipment. It's specific to Clan Lab testing, and
21 there's three of us that are certified in Clan Labs:
22 Myself, Lieutenant Wojohowitz, and I think Ken
23 Larson just went there. He just put in the go. But
24 we haven't had Clan Labs since they passed the state

Page 32
1 law back in 2012 that you can only buy Sudafed one
2 package at a time, so Clan Labs really dropped off
3 since then.
4 MR. DINOLFO: Let me show you, just so we make
5 sure we're all talking about the same thing here,
6 Exhibit 5, please.
7 (WHEREUPON, certain photographs were
10 (WHEREUPON, the photographs were
11 tendered to Battalion Chief Caudle.)
12 BATTALION CHIEF CAUDLE: That's the kit that
13 was in the vehicle. That's why it was in the
14 vehicle.
15 MR. MCGUIRE: No, no, no. Hold off --
16 BATTALION CHIEF CAUDLE: I'm sorry.
17 MR. MCGUIRE: Hold off on your answer.
18 BATTALION CHIEF CAUDLE: I'm sorry.
20 MR. DINOLFO: The NARK kit, is that a similar
21 kit that would be used by the Prairie Grove Police
22 Department?
23 BATTALION CHIEF CAUDLE: All law enforcement
24 uses the same kit.

Page 33
1 MR. DINOLFO: Do you know if Prairie Grove
2 has -- if I were to look at their NARK kits, would
3 it be similar to the one we have here?
4 BATTALION CHIEF CAUDLE: No, not even close.
5 MR. DINOLFO: This would be more complex? Less
6 complex?
7 BATTALION CHIEF CAUDLE: This is just a
8 complete kit, and then I added some stuff in there.
9 You'll see there's safety glasses, some N95 masks,
10 some sampling -- sorry, some bottles. You can see
11 the top of the round bottles there. That's for
12 taking -- putting in the stuff that we collect from
13 the scene.
14 MR. DINOLFO: Just so I understand, this HAZMAT
15 team that you were on, was that through the fire
16 protection district?
18 MR. DINOLFO: How long had you had this kit,
19 would you say?
20 BATTALION CHIEF CAUDLE: A couple of years, at
21 least, if not longer.
22 MR. DINOLFO: Let me show you what I'll mark as
24

Page 34
6 MR. MCGUIRE: Hold for a moment. Look that
7 over first. Don't answer until I tell you.
8 MR. DINOLFO: There's two different things, so
9 I'm going to ask you about each page, so look at
10 them.
11 MR. MCGUIRE: Not yet, please.
12 MR. DINOLFO: Whenever you're ready, Counsel.
14 Thank you. Ready.
15 MR. DINOLFO: Page 1 of Exhibit No. 6 is
16 entitled, at least from the manual we found inside
17 of it, called, "Recon Scout."
19 MR. DINOLFO: And is this a district-issued
20 piece of equipment?
22 MR. DINOLFO: What is the purpose of that?
23 BATTALION CHIEF CAUDLE: We used it for
24 technical rescue. We could put it down pipes. We

Page 35
1 can look in small openings and areas, stuff like
2 that.
3 MR. DINOLFO: Does the district have a
4 technical rescue unit?
6 MR. DINOLFO: Is there one of these stored on
7 that vehicle as well?
8 BATTALION CHIEF CAUDLE: It is on that vehicle
9 now. This is from the special rescue team.
10 MR. DINOLFO: This was found in the equipment
11 that either was in your vehicle returned by
12 you --
13 BATTALION CHIEF CAUDLE: It was in my vehicle,
14 but it's been on the trailer for over almost a year
15 now.
16 MR. DINOLFO: If this was found in your vehicle
17 when you returned it back on whatever date you
18 returned it -- I forget the date --
19 BATTALION CHIEF CAUDLE: The 11th?
20 CHIEF RAVAGNIE: No. That was not in his
21 vehicle.
22 MR. DINOLFO: I'm sorry. I misunderstood.
23 BATTALION CHIEF CAUDLE: That was in the --
24 MR. DINOLFO: In the trailer?

Page 36
1 BATTALION CHIEF CAUDLE: -- in the trailer.
2 MR. DINOLFO: Okay. What about the second
3 page?
4 BATTALION CHIEF CAUDLE: I gave it to
5 Lieutenant Brown a while ago.
6 That's a tint meter.
7 MR. DINOLFO: Is that something that's used by
8 the fire district?
9 BATTALION CHIEF CAUDLE: I used it for the
10 district, yeah.
11 MR. DINOLFO: How so?
12 BATTALION CHIEF CAUDLE: Well, we had windows
13 tinted, and I just bought it. It was $75 to check
14 the tint on my vehicle and a few of the other
15 vehicles, but that was about it.
16 MR. DINOLFO: Is that your handwriting --
18 MR. DINOLFO: -- on the page?
20 MR. DINOLFO: What is that? Why did you fill
21 that out, the fine $120, if it's just for the
22 district?
23 BATTALION CHIEF CAUDLE: I was -- well, because
24 that's the actual statute for it, for tint above

Page 37
1 30 percent. That's the fine for it by state
2 statute.
3 MR. DINOLFO: I understand. But why did it
4 matter to you what the violation of the code was if
5 you were just checking the district's tint?
6 BATTALION CHIEF CAUDLE: That was for the other
7 job. That was for Prairie Grove. That was just
8 something I wrote down for myself.
9 MR. DINOLFO: Did you use this for Prairie
10 Grove as well?
11 BATTALION CHIEF CAUDLE: No, I did not.
12 MR. DINOLFO: How many vehicles does the
13 district have that's tinted that you had to check?
14 BATTALION CHIEF CAUDLE: I tested three.
15 MR. DINOLFO: The chief's vehicles?
17 MR. DINOLFO: So your Durango and then the
18 two --
19 BATTALION CHIEF CAUDLE: No. My two Durangos.
20 They both had tinted. And then we had something
21 else that had tint on it. I can't remember what it
22 was, new ambulance, maybe. I can't remember, to be
23 honest.
24 MR. DINOLFO: Did those vehicles come with

Page 38
1 tint, or did you add them on?
2 BATTALION CHIEF CAUDLE: Add them on after the
3 fact.
4 MR. DINOLFO: Did you do that yourself, or did
5 you take it to a company?
6 BATTALION CHIEF CAUDLE: Company did it.
7 MR. DINOLFO: But you bought this to check if
8 the company did it right?
9 BATTALION CHIEF CAUDLE: Correct. And I -- to
10 be honest, I thought it just was a cool thing to
11 have, which probably wasn't so smart.
12 MR. DINOLFO: Do you know if emergency
13 vehicles, such as ambulances or municipal vehicles
14 such as your fire district equipment, are exempt
15 from the tint window laws?
16 BATTALION CHIEF CAUDLE: They are, but we don't
17 like to do things above and beyond, so that was
18 really the reason is to check it.
19 MR. DINOLFO: District buy this or you buy
20 this?
21 BATTALION CHIEF CAUDLE: District bought that.
22 It was about 70 bucks.
23 MR. DINOLFO: Is it something the board
24 approved you to buy, or is it something under your

Page 39
1 authority?
2 BATTALION CHIEF CAUDLE: It's under my
3 authority.
4 MR. DINOLFO: While on duty as district
5 employee, did you ever pull a vehicle over with your
6 district vehicle?
7 BATTALION CHIEF CAUDLE: I did not pull a
8 vehicle over.
9 MR. DINOLFO: Did you ever pull behind a
10 vehicle and activate your emergency lights?
12 MR. DINOLFO: I'm referring to one that
13 occurred at the parking lot over -- right on 47
14 and -- did I say the right address?
15 I'll show you the pictures. Maybe
16 you can just tell me where it is, and we don't have
17 to guess.
18 MR. MCGUIRE: Counsel, can you tell me what
19 date this --
20 MR. DINOLFO: I'm going to ask him that
21 question and make sure I have it right.

Page 40
1 And I won't ask you any questions
2 until you had a chance to look at it. All right?
9 MR. MCGUIRE: I'm going to show this to my
10 co-counsel. I need to confer with my client.
12 the record.)
13 MR. MCGUIRE: Just give me a moment, please.
14 Thank you.
16 Do you recall the date of this
17 incident?
18 BATTALION CHIEF CAUDLE: I don't recall the
19 date, but it was a while ago.
20 MR. DINOLFO: So it's back when you had the red
21 Durango versus the --
22 BATTALION CHIEF CAUDLE: Yep.
23 MR. DINOLFO: -- white Durango, correct?

Page 41
1 MR. DINOLFO: Was it back in 2015, '16, '17, if
2 you remember the date?
3 BATTALION CHIEF CAUDLE: Had to be '15, end of
4 '15. I think it was cold out.
5 MR. DINOLFO: Where is this at?
6 BATTALION CHIEF CAUDLE: This is actually in
7 Lake in the Hills, just the other side of the river.
8 Lake in the Hills ends there and Algonquin picks up
9 right there. I don't remember.
10 MR. DINOLFO: Is that part of the Huntley Fire
11 Protection District?
13 MR. DINOLFO: So it would be Lake in the
14 Hills -- Algonquin, Lake in the Hills fire
15 district?
17 MR. DINOLFO: There appears to be a red
18 Durango, correct?
19 BATTALION CHIEF CAUDLE: That's correct.
20 MR. DINOLFO: A marked, I'm assuming, Lake in
21 the Hills police officer?
22 BATTALION CHIEF CAUDLE: Actually, there's a
23 couple -- there's an unmarked and a marked and then
24 there's also an Algonquin squad there.

Page 42
1 MR. DINOLFO: Is the black car the vehicle
2 at issue that's kind of parked in the parking
3 spot there?
5 MR. DINOLFO: I see you have your lights
6 activated, at least it appears to?
8 MR. DINOLFO: How did you come to be at that
9 location with your vehicle with the emergency lights
10 on?
11 BATTALION CHIEF CAUDLE: So I can tell you the
12 story?
13 This has been brought up before,
14 back in November with Attorney Miller and Trustee
15 Brown.
16 MR. MCGUIRE: Excuse me. If I may, what year?
17 November?
18 MR. DINOLFO: '15 or '16.
19 BATTALION CHIEF CAUDLE: No, no.
20 MR. DINOLFO: He said late '15, early '16.
21 BATTALION CHIEF CAUDLE: No, no. The meeting
22 that I had was November of '16.
24 BATTALION CHIEF CAUDLE: I was actually on my

Page 43
1 way home from work, about 3:30ish, and I was at
2 Algonquin and Lakewood, and there was a school
3 bus -- I was in the turn lane, there was a school
4 bus in the lane next to me, and then a car right
5 next to that right behind the bus. And there was
6 a young lady in there smoking a bong, a very
7 large two-liter bottle bong, homemade one. And the
8 kids are all watching her in the back of the school
9 bus.
10 So at that time, I contacted
11 dispatch, and told them that I had a lady -- had a
12 person smoking what seemed to be drugs, in a vehicle
13 behind the school bus. I continued to call it out
14 until Lake in the Hills unit picked her up. I think
15 it's Crystal Lake and Algonquin Road.
16 They followed her for a little bit
17 more and watched her, and then they actually did
18 the -- did the stop there at the 7-11 on Algonquin
19 Road.
20 MR. DINOLFO: So just so I -- I think I
21 understand.
22 Who activated the lights to make this
23 woman pull into where she ended up?
24 BATTALION CHIEF CAUDLE: I was next to the -- I

Page 44
1 turned my lights on after that Lake in the Hills'
2 officer turned his lights on.
3 MR. DINOLFO: So he would have been in the
4 lead?
5 BATTALION CHIEF CAUDLE: He was -- I pulled
6 into the side, and he pulled up to the -- on the
7 side.
8 MR. DINOLFO: And --
9 BATTALION CHIEF CAUDLE: And I just turned mine
10 on because of where I was parked, so I didn't get
11 hit.
12 MR. DINOLFO: You're the police officer here,
13 so you can correct me if I'm wrong. Normally, was
14 it the marked squad or the unmarked --
15 BATTALION CHIEF CAUDLE: Unmarked squad, the
16 black unmarked squad.
17 MR. DINOLFO: Is there a reason why you took
18 the point, so to speak, versus the police
19 officer --
20 BATTALION CHIEF CAUDLE: That was just the way
21 I pulled in. That's all there was to it.
22 MR. DINOLFO: Why didn't you just pull into a
23 spot and wait because, obviously, it was a
24 police --

Page 45
1 BATTALION CHIEF CAUDLE: Matter.
2 MR. DINOLFO: -- matter, not yours? Right.
4 MR. DINOLFO: Why did you get involved as you
5 did, stopping where you stopped?
6 BATTALION CHIEF CAUDLE: Habit, I guess. I
7 don't know.
8 MR. DINOLFO: Police side kicked in?
9 BATTALION CHIEF CAUDLE: Maybe, yeah. It was
10 just habit.
11 MR. DINOLFO: Did you search the car at all?
12 BATTALION CHIEF CAUDLE: I opened up the back
13 door for the officer, but that was it.
14 MR. DINOLFO: How come you did that for the
15 officer?
16 BATTALION CHIEF CAUDLE: We kind of all know
17 each other, and I just opened the door and pointed
18 to where I saw her put the bong at.
19 I was going to be -- I was the
20 complainant, so I was going to sign the complaint.
21 MR. DINOLFO: Did you end up signing the --
22 BATTALION CHIEF CAUDLE: I didn't have to. The
23 officer had more than enough probable cause.
24 MR. DINOLFO: Just so I'm clear, you, at no

Page 46
1 time, activated your lights to initiate the stop and
2 then call the police?
3 BATTALION CHIEF CAUDLE: No. My lights were
4 on, and I pulled in, yes.
5 MR. DINOLFO: I want to make sure you weren't
6 the one --
7 BATTALION CHIEF CAUDLE: Initiating the traffic
8 stop?
9 MR. DINOLFO: Correct.
10 BATTALION CHIEF CAUDLE: No. I wasn't
11 initiating the traffic stop.
12 MR. DINOLFO: Now, we talked about your
13 secondary employment as a police officer. You also
14 had secondary employment as -- I'm going to put the
15 word out as -- an actor. That's my word, not yours,
16 okay? Is that correct?
17 BATTALION CHIEF CAUDLE: That is correct. It's
18 extra work it's called.
19 MR. DINOLFO: It was on Chicago Fire, Chicago
20 Med.
22 MR. DINOLFO: How long have you been doing that
23 activity?
24 BATTALION CHIEF CAUDLE: I've been doing that

Page 47
1 since -- I think the end of -- I started the end of
2 2013.
3 MR. DINOLFO: Did you advise the board that you
4 were working as an extra?
5 BATTALION CHIEF CAUDLE: No, I did not.
6 MR. DINOLFO: Did you get permission to work as
7 an extra?
9 MR. DINOLFO: When you signed your contract
10 again in April -- I'm sorry, May of 2017, where the
11 board indicated you have to get an advisement
12 advance of any secondary employment, did you advise
13 them at the time you signed it, hey, I'm doing this
14 work for Chicago Med or for Chicago Fire?
15 A. I did not. But I did tell two trustees
16 when I was delivering them to the airport for a
17 conference about three, four weeks ago --
19 BATTALION CHIEF CAUDLE: -- letting them --
20 really their wives brought it up. I was actually
21 talking to their wives, but Trustee Olson and
22 Trustee Saletta were in the vehicle. I did talk to
23 them quite extensively about it. They had a lot of
24 questions about the acting world and, you know, the

Page 48
1 sets and stuff like that.
2 So the two of them were aware of it.
3 But in my contract, I might have just misunderstood
4 it. I thought it said for permission for future
5 employment. I've been employed there since 2013.
6 That was --
7 MR. DINOLFO: I'm not saying you're wrong or
8 right, either way, at least it was your
9 understanding that since you had this job since
10 2013, you didn't need to get permission to do
11 it?
12 BATTALION CHIEF CAUDLE: And I don't really
13 call it a job. It's a hobby. I understand what
14 they're --
15 MR. DINOLFO: Does it ever take time away from
16 your daily duties here at the fire district?
17 BATTALION CHIEF CAUDLE: No. Anything that
18 ever happens, I just take a vacation day. It's
19 really been -- since 2013, it's only been nine
20 times. So it doesn't happen often, maybe once or
21 twice a year.
22 MR. DINOLFO: So I can break it down, I don't
23 know how long these shows have been on, so I
24 apologize. No offense. I don't watch them.

Page 49
1 When did you start with Chicago Fire?
2 BATTALION CHIEF CAUDLE: 2013.
3 MR. DINOLFO: What about Chicago Med?
4 BATTALION CHIEF CAUDLE: About the same time.
5 MR. DINOLFO: They've both been on about the
6 same time?
7 BATTALION CHIEF CAUDLE: No. Chicago Med came
8 in about a year and a half or two years later.
9 They're the same company. It's the same group of
10 people. It's Chicago Med, Chicago Fire, and Chicago
11 P.D. are all the same production crews. So it's all
12 really the same, same group -- organization, I
13 should say.
14 MR. DINOLFO: At least as of three, four weeks
15 ago you shared with Trustee Saletta --
16 BATTALION CHIEF CAUDLE: I can give you the
17 exact date, if you want?
19 BATTALION CHIEF CAUDLE: It was July 26th,
20 about 8 o'clock in the morning. That's when I was
21 taking them to the airport.
22 MR. DINOLFO: Just so I understand, back in
23 2013, were you the chief?
24 BATTALION CHIEF CAUDLE: Yeah. I was -- I just

Page 50
1 made chief. I was chief about a year. I made chief
2 in '12.
3 MR. DINOLFO: Was there any rule or regulation
4 that, at least back then, that you had to let the
5 board know?
6 BATTALION CHIEF CAUDLE: No, not that I
7 remember.
8 MR. DINOLFO: Continuing on kind of with the
9 acting theme, you did a video for Loyola Hospital,
10 correct?
12 MR. DINOLFO: Did you get permission from the
13 board to do that video?
15 MR. DINOLFO: Do you believe you needed to get
16 permission?
17 BATTALION CHIEF CAUDLE: I didn't believe so.
18 MR. DINOLFO: Why is that?
19 BATTALION CHIEF CAUDLE: Well, past practices,
20 and I thought it was under the chief's privy, to be
21 honest.
22 We filmed a movie here -- Chief, if
23 you can help me out, was it two and a half years
24 ago?

Page 51
1 MR. DINOLFO: He can't help you.
2 BATTALION CHIEF CAUDLE: Oh, he can't? Just a
3 date. I'm sorry.
4 MR. DINOLFO: As best you can.
5 BATTALION CHIEF CAUDLE: Yeah, just to confirm
6 the date.
7 MR. DINOLFO: What movie?
8 BATTALION CHIEF CAUDLE: We did a private film
9 at Station 2 about two years ago, maybe a little bit
10 longer now. It was actually filmed at the
11 firehouse, and the board didn't seem to object to
12 that.
13 MR. DINOLFO: Was the board made aware of it
14 beforehand?
15 BATTALION CHIEF CAUDLE: I believe so, yeah.
16 Actually, I know I talked to them at a board meeting
17 about it, and we were all pretty proud and excited
18 about it.
19 MR. DINOLFO: Before you made the movie, you
20 let them know that we were going to do the
21 movie?
22 BATTALION CHIEF CAUDLE: I'm pretty sure I did.
23 MR. DINOLFO: And this is the one a couple
24 three years ago?

Page 52
1 BATTALION CHIEF CAUDLE: Yeah. Anywhere
2 between two and three years ago.
3 MR. DINOLFO: In that one, two or three years
4 ago, were the employees in uniform and using
5 district equipment?
7 MR. DINOLFO: You let the board know back in
8 2014, '15, '16, whatever it was, of that private
9 movie.
10 The video you did for Loyola
11 Hospital, you told me you did not get permission?
13 MR. DINOLFO: You used employees of the
14 district in the video?
16 MR. DINOLFO: You were in uniform?
17 BATTALION CHIEF CAUDLE: I was.
18 MR. DINOLFO: You used district equipment?
19 BATTALION CHIEF CAUDLE: We did.
20 MR. DINOLFO: Apparatus and turnout gear?
22 MR. DINOLFO: Why in 2015, whenever that
23 private movie was done, whatever the date is, did
24 you let the board know beforehand, and in this case

Page 53
1 you did not? Why?
2 BATTALION CHIEF CAUDLE: Well, the movie was a
3 pretty big deal. They had to set cameras up and
4 lighting and all that kind of stuff, which involved
5 with production. This was a man and a woman that
6 came with a small hand-held camera, and that was
7 really all it was.
8 MR. DINOLFO: Was it done during your work
9 hours?
10 BATTALION CHIEF CAUDLE: It was.
11 MR. DINOLFO: As chief, at the time you were
12 chief, did you believe you needed to get permission
13 to use the district equipment and employees in that
14 video?
16 You're talking the video, the Loyola
17 video?
18 MR. DINOLFO: The Loyola video.
19 BATTALION CHIEF CAUDLE: I did not, no.
20 MR. DINOLFO: Obviously, the district has a --
21 and I'll use the word "social media policy."
23 MR. DINOLFO: It indicates that you were the
24 one that can give authority?

Page 54
2 MR. DINOLFO: If you're the one seeking to do
3 it, do you believe it's inherent that you can make
4 your own decision, or do you need or go to the board
5 based on how things work here?
6 BATTALION CHIEF CAUDLE: I felt it was within
7 my privy.
8 MR. DINOLFO: Just so we're making sure we're
9 talking about the same thing here --
10 BATTALION CHIEF CAUDLE: Sure.
11 MR. DINOLFO: -- showing you what I'll mark as
12 Exhibit 8, and I won't ask you any questions until
13 you're ready.
14 MR. MCGUIRE: Well done.
15 BATTALION CHIEF CAUDLE: And I won't answer any
16 until you tell me to.
22 MR. MCGUIRE: Ready if you are.
23 BATTALION CHIEF CAUDLE: I am ready, sir.
24 MR. DINOLFO: This is the social media policy

Page 55
1 that was in effect at the time you did the video for
2 Loyola?
4 MR. DINOLFO: And it is and was your
5 interpretation at the time that you, as chief, had
6 the authority to make the decisions that you made
7 concerning that video?
9 MR. DINOLFO: I want to now ask you about
10 April 11, 2016.
11 You were coming back from a district
12 meeting or meeting on behalf of the district in your
13 red Durango?
15 MR. DINOLFO: You were involved in a motor
16 vehicle accident?
18 MR. DINOLFO: I believe the police were called
19 out to the scene?
20 BATTALION CHIEF CAUDLE: Absolutely, yes.
21 MR. DINOLFO: At the time that the police were
22 called out to the scene, I think at least my
23 understanding, you were coming back from some sort
24 of meeting on behalf of the district?

Page 56
1 BATTALION CHIEF CAUDLE: Correct, a dispatch to
2 center meeting.
3 MR. DINOLFO: At the time that the police
4 arrived on the scene, were there any weapons in the
5 vehicle?
6 BATTALION CHIEF CAUDLE: No. I don't believe
7 so.
8 MR. DINOLFO: And by "weapons" I mean in your
9 vehicle, the district vehicle. Any pistols?
10 Shotguns? Anything of that nature in that
11 vehicle?
12 BATTALION CHIEF CAUDLE: I don't recall so.
13 MR. DINOLFO: So if there's information that a
14 weapon or a couple weapons were taken from your
15 vehicle, that would be incorrect?
16 BATTALION CHIEF CAUDLE: I'm trying to think.
17 Give me one minute.
18 MR. MCGUIRE: Can we take a break for a few
19 minutes --
20 MR. DINOLFO: Yes. Absolutely.
21 MR. MCGUIRE: -- so I can confer with my
22 client?
23 MR. DINOLFO: Absolutely. We'll step out for
24 you.

Page 57
2 (WHEREUPON, a recess was had.)
3 MR. DINOLFO: Can you read the last question,
4 please?
6 the reporter.)
7 BATTALION CHIEF CAUDLE: No. That would be
8 correct, there was.
9 MR. DINOLFO: What was in the vehicle?
10 BATTALION CHIEF CAUDLE: I had a riffle in the
11 vehicle.
12 MR. DINOLFO: Type of riffle?
13 BATTALION CHIEF CAUDLE: AR15.
14 MR. DINOLFO: Is that something that the
15 Prairie Grove Police Department uses?
17 MR. DINOLFO: Just your personal one?
18 BATTALION CHIEF CAUDLE: Just a personal one,
19 yes.
20 MR. DINOLFO: Why did you have it in your
21 car?
22 BATTALION CHIEF CAUDLE: To be honest with you,
23 I forget it was in there. Before the accident, I
24 was at range. I go to the range weekly or biweekly,

Page 58
1 and it was in there from there.
2 MR. DINOLFO: Have you ever been asked before
3 if there's ever been a weapon in that vehicle?
4 BATTALION CHIEF CAUDLE: Yes, I have.
5 MR. DINOLFO: What was your answer to those
6 questions?
7 BATTALION CHIEF CAUDLE: No. But not prior to
8 that -- wait a minute. What was the date? Yeah,
9 yes, I was. You are correct, yes.
10 MR. DINOLFO: So you were asked specifically if
11 on the date of that accident was a weapon removed
12 from that vehicle, and you had told who no?
13 BATTALION CHIEF CAUDLE: On the date of the
14 accident, no.
15 MR. DINOLFO: Or the follow up as part of the
16 accident?
17 BATTALION CHIEF CAUDLE: It was in November I
18 said no.
19 MR. DINOLFO: Did you know at the time there
20 was a weapon in the car when you said no?
21 BATTALION CHIEF CAUDLE: No, I did not. I
22 completely forget about it.
23 MR. DINOLFO: Now, some time after, how did it
24 come back to you that there was a weapon in the

Page 59
1 car?
2 BATTALION CHIEF CAUDLE: Just sparked my
3 memory. That's all it was.
4 MR. DINOLFO: Is that the only weapon that was
5 in the vehicle on the date of the accident?
6 BATTALION CHIEF CAUDLE: I believe so.
7 MR. DINOLFO: Now, as a result of that, I think
8 I learned that you suspended yourself for two days
9 without pay?
11 MR. DINOLFO: Did you inform the board of that?
13 MR. DINOLFO: Did you inform the board that you
14 weren't going to actually lose any pay since you
15 were going to use two vacation or sick days to cover
16 it?
18 MR. DINOLFO: Why not?
19 BATTALION CHIEF CAUDLE: Past practices we've
20 done that route. In fact, we've done that a couple
21 of weeks ago we tried to do that.
22 MR. DINOLFO: Is there a reason why you didn't
23 tell -- why you just told the board you were
24 suspending yourself two days but not letting

Page 60
1 them know that you were using vacation or sick
2 days?
3 BATTALION CHIEF CAUDLE: No, no reason.
4 Really, the reason behind it, at
5 least my thought process, is when I suspended myself
6 for two days, obviously, I lost two days of vacation
7 time.
8 If I would have suspended myself and
9 removed myself from the station, the work still
10 doesn't stop. I'm still getting the phone calls and
11 e-mails and the text messages, so it really kind of
12 defeats the purpose of being suspended for two
13 days.
14 MR. DINOLFO: No different than going on
15 vacation, though, right?
16 BATTALION CHIEF CAUDLE: Right. It never ends,
17 right.
18 MR. DINOLFO: Going back to that gun safe.
19 When you resigned as chief, did you
20 take that safe with you?
21 BATTALION CHIEF CAUDLE: I did. And the reason
22 being is I thought it was mine. I thought I
23 purchased it, but I went and checked my records, and
24 I did not.

Page 61
1 When I met with the chief that week
2 to sign the documents, it was listed on there, and I
3 thought I bought it. I went and checked, and I
4 brought it back to the chief the other day. He
5 received it back with a brand now battery in it.
6 MR. DINOLFO: When you took it, though, did it
7 have all the -- I think you said keys --
8 BATTALION CHIEF CAUDLE: Yeah, keys and all of
9 that.
10 So, basically, I took everything that
11 was in there. It's in the very top drawer in my
12 desk, and I locked the desk, and then, obviously,
13 the chief got the keys.
14 MR. DINOLFO: You emptied the safe before you
15 took it?
17 MR. DINOLFO: I want to circle back to the
18 Scout Pro, if that's the right name for it? The
19 Scout. Do you know what I'm referring to?
20 BATTALION CHIEF CAUDLE: The mini robot thing,
21 yes.
22 MR. DINOLFO: How much did that cost?
23 BATTALION CHIEF CAUDLE: I couldn't remember.
24 I couldn't tell you.

Page 62
1 MR. DINOLFO: What's your authority for
2 purchasing -- what was your authority for purchasing
3 when you were chief?
4 BATTALION CHIEF CAUDLE: $6,900, I thought,
5 7,000, somewhere around there.
6 MR. DINOLFO: Do you think it was more or less
7 than that amount?
8 BATTALION CHIEF CAUDLE: I don't believe it
9 was.
10 MR. DINOLFO: You believe it was less?
11 BATTALION CHIEF CAUDLE: I believe so. I don't
12 remember.
13 MR. DINOLFO: Besides you, who else was trained
14 on the use of that device?
15 BATTALION CHIEF CAUDLE: You'd have to check
16 with Lieutenant Brown. He's in charge of the SRT
17 Team. I told him it was in there, and get the guys
18 trained on it.
19 MR. DINOLFO: You were trained on it?
20 BATTALION CHIEF CAUDLE: Self-taught, plug it
21 in and turn it on.
22 MR. DINOLFO: As you sit here today, you don't
23 know if any other members of the department were
24 trained on it?

Page 63
1 BATTALION CHIEF CAUDLE: No, not with that
2 team. I couldn't tell you.
3 MR. DINOLFO: That's Lieutenant Brown?
4 BATTALION CHIEF CAUDLE: That's Lieutenant
5 Brown, yeah.
6 MR. MCGUIRE: Can I see the picture of that
7 device?
8 MR. DINOLFO: I gave it to you.
9 MR. MCGUIRE: Please go on.
10 MR. DINOLFO: Just point of clarification,
11 switching gears to the tint device, the tint
12 meter.
13 Obviously, you tested your
14 vehicle, the deputy chief's vehicles are all
15 factory --
16 BATTALION CHIEF CAUDLE: Factory, correct.
17 MR. DINOLFO: So they won't need to be
18 tested?
19 BATTALION CHIEF CAUDLE: Right.
20 MR. DINOLFO: None of the ambulances have tint
21 on the passenger compartment, so what other vehicle
22 were you testing?
23 BATTALION CHIEF CAUDLE: I know I tested the
24 two Durangos.

Page 64
1 MR. DINOLFO: Your two chief Durangos?
2 BATTALION CHIEF CAUDLE: Correct, yeah. The
3 two Durangos.
4 I thought there was a third vehicle.
5 I could have sworn there was.
6 MR. DINOLFO: I didn't check this off, if I
7 asked this, I apologize.
8 You never used that tint meter for
9 Prairie Grove police work?
10 BATTALION CHIEF CAUDLE: I did not, no.
11 MR. DINOLFO: If you give me one minute, I'm
12 going to confer with Lad here and see if I missed
13 anything.
14 MR. MCGUIRE: Well, can we take a brief recess?
15 MR. DINOLFO: Absolutely.
16 (WHEREUPON, a recess was had.)
17 MR. DINOLFO: Just a couple more things.
18 There was one other piece of
19 equipment that was returned when you resigned as
20 chief, and that was called an Epilog? It's
21 like a --
22 BATTALION CHIEF CAUDLE: It's a laser machine,
23 yes. That wasn't returned -- that was returned a
24 long time ago, not when I resigned.

Page 65
1 MR. DINOLFO: It's been here for a while?
3 MR. DINOLFO: Because nobody saw it until the
4 time that you resigned, but it's been --
5 BATTALION CHIEF CAUDLE: No, no. It's been in
6 the back room for a long time.
7 MR. DINOLFO: Okay. And that's -- I'm sorry.
8 Go ahead.
9 MR. MCGUIRE: What's an Epilog?
10 MR. DINOLFO: That's a laser machine used for
11 what?
12 BATTALION CHIEF CAUDLE: For engraving.
13 MR. DINOLFO: The district bought that?
14 BATTALION CHIEF CAUDLE: Yes, yeah.
15 MR. DINOLFO: A while ago?
16 BATTALION CHIEF CAUDLE: A long time ago. At
17 least two years ago, if not longer, because we did
18 glasses for all the members two Christmases ago,
19 engraved our patch on them. So it's got to be two
20 years, I think. If not longer.
21 MR. DINOLFO: Last thing I want to touch on is
22 your resignation as chief.
23 I think you shared with me you that
24 you did that voluntarily?

Page 66
2 MR. MCGUIRE: I just want to bring out that
3 there is an Illinois Appellate Court case by the
4 name of Bauer, B-a-u-e-r, v. Saper, S-a-p-e-r. It's
5 a Third District Illinois Appellate Court case, and
6 it says basically the resignation is effective when
7 presented. In other words, it doesn't have to be
8 accepted. It's effective.
10 MR. MCGUIRE: Just for the record. Obviously,
11 I put it in the record. I'm going to stop
12 talking.
13 MR. DINOLFO: You indicated that it was a
14 voluntary resignation done, I think, in a letter
15 after consulting with your family?
17 MR. DINOLFO: Nobody at the district told you
18 to do it?
20 MR. DINOLFO: No board member told you to do
21 it?
23 MR. DINOLFO: You just decided that you had
24 reached a point where you didn't want to be

Page 67
1 chief anymore?
2 BATTALION CHIEF CAUDLE: Correct. I believe we
3 had that conversation in your office.
4 MR. DINOLFO: Okay. That's all the questions I
5 have.
6 Do you or does your attorney wish to
7 make any statement for the record? If not, we can
8 conclude.
9 MR. MCGUIRE: No.
10 I have a couple of things to cover
11 here.
12 MR. DINOLFO: Sure. Thank you.
13 MR. MCGUIRE: More in the form of
14 clarification.
15 Are you presently employed by the
16 fire protection district?
17 BATTALION CHIEF CAUDLE: I am.
18 MR. MCGUIRE: In what capacity?
19 BATTALION CHIEF CAUDLE: Battalion chief.
20 MR. MCGUIRE: Now, we went through the command
21 structure of the department. We know there's a
22 chief.
23 Where does battalion chief fit in?
24 BATTALION CHIEF CAUDLE: In the third line. It

Page 68
1 falls underneath the deputy chief, and then falls in
2 line with the chief.
3 MR. MCGUIRE: The position of deputy chief,
4 is that appointed by the board of fire
5 commissioners?
6 BATTALION CHIEF CAUDLE: It's appointed by the
7 board of trustees, I believe.
8 MR. MCGUIRE: And the position of chief is
9 appointed by whom?
10 BATTALION CHIEF CAUDLE: The board of trustees.
11 MR. MCGUIRE: What other ranks did you hold,
12 positions did you hold, in the fire department prior
13 to battalion chief?
14 BATTALION CHIEF CAUDLE: Firefighter medic
15 lieutenant, captain, and then the captain rank was
16 furloughed. We did a ranking restructuring, and
17 that turned to battalion chief, then I was deputy
18 chief, and then chief.
19 MR. MCGUIRE: All of the positions from
20 battalion chief down, were they covered by the board
21 of fire commissioners --
23 MR. MCGUIRE: -- as opposed to the board of
24 trustees?

Page 69
2 MR. MCGUIRE: And in the sense of being paid
3 overtime, is my understanding correct, that you were
4 not paid for overtime while functioning as fire
5 chief?
7 MR. MCGUIRE: What is the normal workweek for a
8 member of the fire department? Forty hours?
9 Eighty hours?
10 MR. DINOLFO: For what, chief?
11 MR. MCGUIRE: No. For any member of the fire
12 department.
13 BATTALION CHIEF CAUDLE: There's different --
14 MR. MCGUIRE: Let's take a blue shirt.
15 BATTALION CHIEF CAUDLE: Blue shirts, shift
16 personnel work 24 hours on, 48 hours off, about
17 121 days a year, minus furloughs and vacation and
18 Kelly days.
19 MR. MCGUIRE: As battalion chief, what's the
20 number of hours that you work in a week?
21 BATTALION CHIEF CAUDLE: Battalion chiefs are
22 on the same schedule, 24/48.
23 MR. MCGUIRE: Are you paid overtime as a
24 battalion chief?

Page 70
2 MR. MCGUIRE: This tint that counsel brought
3 up, was a bill submitted by you to the board of
4 trustees for the tinting?
5 BATTALION CHIEF CAUDLE: No. It's in their
6 board packet. It's not in -- we don't do individual
7 bills for anything. It's in a board packet, a
8 monthly board packet.
9 MR. MCGUIRE: Did it go to the board of
10 trustees?
12 MR. MCGUIRE: Did they pay it?
14 MR. MCGUIRE: Did you receive any questions?
15 Were you asked any questions about the matter?
17 MR. MCGUIRE: This Loyola thing, it's a video,
18 am I correct?
20 MR. MCGUIRE: As opposed to a movie?
22 MR. MCGUIRE: How did that come about that
23 Loyola comes out here and does a video? Would you
24 explain how it came about?

Page 71
1 BATTALION CHIEF CAUDLE: Sure.
2 I actually had cervical spine fusion
3 a year ago, C3-C4. Thought it was career ending.
4 Pretty devastating. Usually you don't come back
5 from that type of surgery.
6 I went through Loyola University for
7 it. And after the surgery was a success, I was
8 released to full duty from the department physician
9 and the surgeon.
10 They contacted me and said they
11 wanted to do a -- I guess, a small video, and it was
12 about three minutes.
13 MR. MCGUIRE: Who contacted you?
14 BATTALION CHIEF CAUDLE: Loyola media.
15 MR. MCGUIRE: Go ahead.
16 BATTALION CHIEF CAUDLE: I don't know their
17 exact names.
18 They had contacted and asked to do
19 that. I, again, didn't think it was wrong, and I
20 did.
21 It was noncompensated. There was no
22 pay. It was all volunteer. Really, it was just a
23 great way for us to show that even firefighters,
24 having a bad time in their life or rough time in

Page 72
1 their life, you can come back from it.
2 We're very pro firefighter health and
3 safety and awareness here. It really was just a
4 piece of that.
5 And believe it or not, I had three
6 firefighters contact me with the same symptoms and
7 now seeking treatment for the same thing that I had,
8 which was kind of neat.
9 MR. MCGUIRE: Did the trustees know in advance
10 that you were going to do it?
11 BATTALION CHIEF CAUDLE: They did not.
12 MR. MCGUIRE: Did they know afterwards; and, if
13 so, when?
14 BATTALION CHIEF CAUDLE: They did.
15 I sent the board of trustees and the
16 commissioners a link to the video, thanking them for
17 the support during the process, and, obviously,
18 having to deal with that personally and
19 professionally.
20 I sent them a link, and I even got a
21 reply back from, I think, two trustees saying it
22 was --
23 MR. MCGUIRE: Who were the two trustees to the
24 best of your recollection?

Page 73
1 BATTALION CHIEF CAUDLE: I know Bonnie Bayser
2 was one, and I think John Davis was the other. They
3 e-mailed me back saying nice video. And I think
4 Brenda Kardys replied back, also, as one of the
5 commissioners about the video, also.
6 MR. MCGUIRE: Did that occur while you were the
7 fire chief?
8 BATTALION CHIEF CAUDLE: It did.
9 I never hid it from anybody. I was
10 very proud of it, and it was really just trying to
11 show other firemen they can get help for the same
12 pain.
13 MR. MCGUIRE: How long did it take to make that
14 video?
15 BATTALION CHIEF CAUDLE: They were here
16 45 minutes, I think. It was about it. It wasn't
17 really long.
18 MR. MCGUIRE: Were any calls missed or delayed
19 as a result?
20 BATTALION CHIEF CAUDLE: Absolutely not, no.
21 MR. MCGUIRE: Do you have any --
22 MR. DINOLFO: I just have one clarification --
23 MR. MCGUIRE: Please.
24 MR. DINOLFO: -- from your questions concerning

Page 74
1 the video.
2 The social media policy, if you have
3 that Exhibit No. 8.
5 MR. DINOLFO: If we go to page 3 of 5 at the
6 bottom --
8 MR. DINOLFO: -- it says, "Unauthorized
9 endorsements and advertisements."
10 Do you see that under 4.1?
11 BATTALION CHIEF CAUDLE: 4.1, yes.
12 MR. MCGUIRE: Hold on a moment. Let me read
13 it.
15 BATTALION CHIEF CAUDLE: I'm not seeing where
16 you're at, Steve.
17 MR. MCGUIRE: I'll show it to you in a moment.
18 MR. DINOLFO: I just want to make sure we're
19 talking about the same thing.
20 BATTALION CHIEF CAUDLE: 4.1?
21 MR. DINOLFO: You got it?
22 MR. MCGUIRE: Right under the blue. I say that
23 because there's blue coloring on it.
24 BATTALION CHIEF CAUDLE: Okay.

Page 75
1 MR. DINOLFO: I'll wait until he's done
2 reading.
3 MR. MCGUIRE: Read the rest. Read that policy
4 from the beginning (indicating).
5 MR. DINOLFO: I'll help you. Just really
6 quick, focus on C and D. That's what I'm going to
7 ask you about.
8 MR. MCGUIRE: Well, I thank you, and he'll do
9 so but --
10 MR. DINOLFO: Read the whole thing. I'm just
11 letting you know those are the ones I'm going to ask
12 you questions about.
13 MR. MCGUIRE: Good enough.
14 When did this Loyola thing occur, if
15 you'll answer that? By that, I mean the video.
16 BATTALION CHIEF CAUDLE: I think I sent the
17 trustees that like on the 8th of August, so it was
18 done the month before '17, so I think they came here
19 in July of '17.
20 MR. MCGUIRE: Okay. I want you to read that
21 entire section to yourself starting here
22 (indicating). Read the whole thing first to
23 yourself.
24 Just a moment, please.

Page 76
1 Are you ready, Chief?
3 MR. DINOLFO: The first section I want to start
4 with is 4.1, "Unauthorized Endorsements and
5 Advertisements." Are you with me?
7 MR. DINOLFO: Obviously, it sets forth that
8 you're not supposed to do it unless specifically
9 authorized by the fire chief, correct?
11 MR. DINOLFO: It's my understanding you
12 authorized yourself?
14 MR. DINOLFO: What you authorized yourself to
15 do, if we go to section -- that same section, letter
16 C or D, you were supporting the services, the
17 medical services that Loyola performed on you
18 because you had a good outcome?
20 MR. DINOLFO: I don't know if it would be
21 considered a commercial, but it's a video or -- it's
22 an advertisement for Loyola?
23 BATTALION CHIEF CAUDLE: It's a YouTube video.

Page 77
1 MR. MCGUIRE: Of course we disagree with the
2 characterization of advertisement. That's your
3 word, not mine.
4 Go ahead.
5 MR. DINOLFO: So do you believe it was a
6 commercial?
7 BATTALION CHIEF CAUDLE: No. It was not a
8 commercial.
9 MR. DINOLFO: Do you believe it was a social or
10 nonprofit publication?
11 BATTALION CHIEF CAUDLE: Well, the hospital is
12 nonprofit.
13 MR. DINOLFO: Did it constitute a motion
14 picture film, video, public broadcast, or on any
15 websites?
16 BATTALION CHIEF CAUDLE: It was on YouTube.
17 MR. DINOLFO: Now, in this it says, basically,
18 that if any members acting in his or her individual
19 capacity or through an outside group or organization
20 is affiliated with this district, the members shall
21 give a specific disclaiming statement that such
22 speech or expression is not representative of the
23 Huntley Fire Protection District.
24 Did you do that?

Page 78
2 MR. DINOLFO: I understand there's some
3 considerations you can look at to decide whether
4 something -- I guess, if you can permit yourself to
5 do the speech in this case, right?
6 BATTALION CHIEF CAUDLE: Right.
7 MR. DINOLFO: I see you considered those
8 factors, and given the nature of it, that it was
9 appropriate for you to do what you did?
11 MR. DINOLFO: Last thing I want to touch on,
12 your counsel asked you about the bill for the tint
13 meter?
15 MR. DINOLFO: Was that a specific bill given,
16 or was it just part of your general credit card
17 statement that is --
18 BATTALION CHIEF CAUDLE: Just regular.
19 MR. DINOLFO: So you didn't give an actual bill
20 from XYZ tint place --
21 BATTALION CHIEF CAUDLE: No. Absolutely not.
22 It's just with the general packet.
23 MR. DINOLFO: So here's my credit card
24 statement for the month? It gets

Page 79
1 authorized?
2 BATTALION CHIEF CAUDLE: Correct, absolutely.
3 MR. DINOLFO: Anything else, Chief?
4 Mr. McGuire, I have nothing else.
5 Are you all set?
6 MR. MCGUIRE: I'm over set, okay.
7 But the one thing, as you know,
8 Counsel, and I've been on the other side on a
9 lot of these things representing chiefs, it
10 appears to me that you have somewhat of a cancer
11 within the organization that -- and I don't know
12 where it is -- that some of these things that
13 have been brought up may be considered to be
14 making a mountain out of a molehill, and somebody's
15 riding around with a camera and things of that
16 nature.
17 And I say that that's something that
18 the district should take into consideration, that
19 whoever does become the chief, if, indeed, we have
20 this infantile attitude, it's going to raise its
21 ugly head with whoever becomes the fire chief of
22 this district.
23 That's all I have.
24 MR. DINOLFO: We're done.

Page 80
1 The time is 10:52 a.m.
2 (Which were all the proceedings
3 had in the above-entitled cause
4 on this date.)
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Page 81
1 STATE OF ILLINOIS )
2 ) SS:
3 COUNTY OF COOK )
4 I, LINDA A. WALICZEK, a Certified
5 Shorthand Reporter of the State of Illinois, do
6 hereby certify that I reported in shorthand the
7 proceedings had at the interrogation aforesaid, and
8 that the foregoing is a true, complete and correct
9 transcript of the proceedings of said interrogation
10 as appears from my stenographic notes so taken and
11 transcribed under my personal direction.
12 IN WITNESS WHEREOF, I do hereunto set my
13 hand at Chicago, Illinois, this 21st day of
14 September, 2017.
15
16
17 Certified Shorthand Reporter
18
19 C.S.R. Certificate No. 84-3865.
20
21
22
23
24

Interrogation of Battalion Chief Kenneth Caudle Huntley Fire Protection District

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Interrogation of Battalion Chief Kenneth Caudle Huntley Fire Protection District

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Page 1

BATTALION CHIEF KENNETH CAUDLE

HUNTLEY FIRE PROTECTION DISTRICT

The interrogation interview of BATTALION

CHIEF KENNETH CAUDLE, taken in the above-entitled

cause before Linda A. Waliczek, a Certified

Shorthand Reporter of said State, taken at 11118

Main Street, Huntley, Illinois, on the 6th day of

September, 2017, at the hour of 9:15 a.m.

SCHELLI REPORTING SERVICE, LTD. (312) 558-1113

2 OTTOSEN BRITZ KELLY COOPER GILBERT & DiNOLFO,

4 BY: MR. STEPHEN DINOLFO and

5 MR. VLADIMIR SHULIGA, JR.

6 1804 North Naper Boulevard, Suite 350

7 Naperville, Illinois 60563

10 Appeared on behalf of the

11 Huntley Fire Protection District;

13 JOLANTA A. ZINEVICH, LLC

14 BY: MS. JOLANTA A. ZINEVICH and

15 MR. THOMAS MCGUIRE

16 1214 West Northwest Highway

18 Palatine, Illinois 60067

21 Appeared on behalf of Battalion Chief

23 ALSO PRESENT: CHIEF SCOTT RAVAGNIE

SCHELLI REPORTING SERVICE, LTD. (312) 558-1113

4 BATTALION CHIEF KENNETH CAUDLE 5

9 Caudle Exhibit No. 1 5 8

10 Caudle Exhibit No. 2 14 3

11 Caudle Exhibit No. 3 16 15

12 Caudle Exhibit No. 4 20 2

13 Caudle Exhibit No. 5 32 8

14 Caudle Exhibit No. 6 34 2

15 Caudle Exhibit No. 7 40 5

16 Caudle Exhibit No. 8 54 17

SCHELLI REPORTING SERVICE, LTD. (312) 558-1113

2 interview of Battalion Chief Kenneth Caudle of the

3 Huntley Fire Protection District. This interview

4 is being conducted at the Huntley Fire Protection

5 District Annex at 9:20 a.m., on September 6,

7 For the record, my name is Steve

8 DiNolfo. I'm actually here on behalf of the

9 district and acting Chief Scott Ravagnie, who is

11 We have present for Battalion Chief

13 MS. ZINEVICH: Jolanata Zinevich.

14 MR. McGUIRE: And Thomas McGuire,

16 MR. DINOLFO: And, obviously, Battalion Chief

17 Caudle is present as well.

18 The interview is being conducted

19 under of the Firemen's Disciplinary Act and

20 according to the terms of a written order and

21 notice served to Battalion Chief Caudle on

22 August 25, 2017.

SCHELLI REPORTING SERVICE, LTD. (312) 558-1113

2 BATTALION CHIEF KENNETH CAUDLE,

3 called as a witness herein, was examined and

5 MR. DINOLFO: Showing you what I'll mark as

6 Exhibit No. 1 for identification purposes.

7 (WHEREUPON, a certain document was

8 marked Caudle Exhibit No. 1, for

10 (WHEREUPON, the document was tendered

11 to Battalion Chief Caudle.)

12 MR. MCGUIRE: Thank you.

13 MR. DINOLFO: Is that the order that was served

14 upon you on August 25, 2017?