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The document discusses a Freedom of Information Act (FOIA) request regarding allegations made against a Chicago police officer and the response provided.

The FOIA request was regarding records pertaining to 19 allegations made against CPD officer John M. Cannon on social media and the employee disciplinary investigation conducted by COPA.

The officer was relieved of police powers and restricted from exercising any law enforcement duties or possessing firearms until the review process was completed.

August 25, 2022

Ms. Jennifer Bamberg


Via Email: [email protected]

Re: Freedom of Information Act Request F028956-082222, 22-060-255

Ms. Bamberg,

On behalf of the Civilian Office of Police Accountability (COPA), I am responding to your


Freedom of Information Act (FOIA) request received August 22, 2022, stating as follows:

Dear FOIA Officer, This is an order under the Illinois Freedom of Information Act, 5 ILCS 140.
Please provide the following: Records pertaining to the nineteen (19) allegations that CPD and
COPA served John M. Cannon with on or about January 13, 2021. The allegations regard
making inappropriate statements on social media. Records pertaining to the employee
disciplinary investigation into Cannon via the Civilian Office of Police Accountability.

With respect to your request, we have identified a COPA investigation under log number 2020-
0002942. Regarding this log number, COPA has completed our investigation, however, at this
time the review process is ongoing and COPA is unable to release the report until that is
complete, in accordance with 5/ILCS 140/7(1)(f). Additionally, because the requested report is a
record relating to a public body’s disciplinary case, and that case is currently in progress, we are
unable to release the summary report of investigation in accordance with 5 ILCS 140/7 (1)(n). At
this time, we will be producing the Quick View Report related to the investigation, as well as all
other materials in the case file related to Lieutenant Cannon which include emails, screen
captures of social media posts, interview statements. When the review process is completed the
final Summary Report will be posted to COPA’s website.

This review and disciplinary process is further explained on our website at


www.chicagocopa.org/wp-content/uploads/2016/07/COPA-Ordinance.pdf.

Please note that the documents produced must be redacted of certain information in accordance
with the following exemptions to the Illinois Freedom of Information Act:

5 ILCS 140/7(1)(b): Private information, which is defined as: Unique identifiers, including a
person's social security number, driver's license number, employee identification number,
biometric identifiers, personal financial information, passwords or other access codes, medical
records, home or personal telephone numbers, personal email addresses [. . . .] home address and
personal license plates.

To the extent that you consider this a denial of your FOIA request, you have a right of review by
the Illinois Attorney General’s Public Access Counselor, who can be contacted at 500 South
1615 WEST CHICAGO AVENUE, 4TH FLOOR, CHICAGO, ILLINOIS 60622
312.743.COPA (COMPLAINT LINE) | 312.746.3609 (MAIN LINE) | 312.745.3598 (TTY) | WWW.CHICAGOCOPA.ORG
Second Street, Springfield, Illinois 62706 or by telephone at (217) 558-0486. You may also seek
judicial review of denial under 5 ILCS 140/11 of FOIA.

Sincerely,

Nicolle Brown
Nicolle Brown
FOIA Officer
Quick View Report
INFORMATION/COMPLAINT DETAILS
Log No 2020-0002942
Primary Category Verbal Abuse Allegations of Bias 01B
Incident Type Complaint Register Affidavit Received No
Incident Origin Email Date of Incident
Status Closed at COPA Date of Incident To
Investigator EMILY PIERCE Supervisor STEFFANY HRENO
Incident Description Civilian Complaint: Complainant alleges accused PO is Bakker is Proud Boy and Lt.
Cannon engages in racist and misogynistic dialogue on social media. (see notes re
jurisdiction)
SPECIAL CONSIDERATIONS

CIVIL SUIT :No JUVENILE :No


CONFIDENTIAL :No PCRIA : No
EEOC :No PURSUIT RELATED :No
EXTRAORDINARY OCCURRENCE :No POLICE SHOOTING (U) :No
FATAL: No REPRESENTED :No
MAJOR CASE :No SELF INFLICTED INJURY :No
MOTOR VEHICLE (V) :No SERIOUS BODILY INJURY :No
INCARCERATED :No SUICIDE ATTEMPT :No
PPO :null WARD OF THE STATE :No

RELATED CPD

Role Name Star No. Employee No. Position On Duty


Accused JOHN CANNON 412 LIEUTENANT OF Off Duty
POLICE

RELATED NON CPD

Role Name DOB Address Mobile Phone Email


Reporting Party: /81
Witness

RELATED LOCATIONS
Role Address Beat District Location
Location of Unknown
Occurrence CHICAGO,

Report executed 8/23/22 NICOLE J BROWN Page 1 of 1


7/2/2020 Employee Alpha / Number / Star Query

Employee Alpha / Numper / star query


Report Date=7/ 2/ 2020 Requested By=
For CityWide

TITLE LAST FIRST MI STAR


# PC# EMP
# BIRTH
DATE AGE APPTIIT SEN YOJ ASGN DTL WATCHSEX RACE HGT WGT DIST
DATE DATE
9173 CANNONJOHN M 412 0 4 - 49 13-APR- - - 22 018
MAY 5 M WHT 506 175 022
1998 2018
THERE ARE 1 RECORD(S) DISPLAYED
FOR OFFICIAL USE ONLY - NOT FOR DISSEMINATION

clearnet01.chicagopolice.locaVtactical_reports/12/AdminRptAlphaStar code.asp 1/1


6/29/2020 Mail - Morgan Richardson - Outlook

Jessica Ciacco
Mon 6/29/2020 11:44 AM
To: Morgan Richardson

Morgan,

Please log a complaint based on the twitter link below. Please review the email thread, and then use the
twitter link below. Please let me know the log number.

Thx.

From: Jay Westensee < >


Sent: Monday, June 29, 2020 8:51AM
To: Jessica Ciacco < >
Cc: Andrea Kersten < >;Matthew Haynam < >
Subject: RE: Lieutenant John Cannon

Hi Jessica,

First thing this morning, can you please check on the status of Intake's efforts relative to the string below. I searched
for new #s associated with Cannon in CMS and did not see anything opened at the end of last week. Did not see an
initiation report in COPA-Intake, either, so follow-up w/ BIA may be necessary. Preference is to open based on the
Initiation Report, but if the Department isn't sending one, we can open independently.

Thanks. Please forward the # when it's generated.

Jay

From: Andrea Kersten < >


Sent: Friday, June 26, 2020 5:27 PM
To: Tina Skahill < >;LYNN MCCARTHY (States Attorney)
< >; Karen Konow < >; Jay Westensee
< >
Subject: Re: Lieutenant John Cannon

Will do. Sounds like it's happening now. I think Sgt Frierson is sending an initiation report.

AK

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From: Skahill, Tina M. < >


Sent: Friday, June 26, 2020 5:23:03 PM
To: Andrea Kersten < >;LYNN MCCARTHY (States Attorney)
< >; Karen Konow < >;Jay Westensee
< >
Subject: Re: Lieutenant John Cannon

Andrea,
Please let us know if COPA pulls the log number. Thanks.

Tina Skahill
Deputy Director
Bureau of Internal Affairs

https://outlook.office365.com/mail/inbox/id/AAQkADM1NDUwMDAyLTQ4YjYtNGUyMS05MTIILTQOMj15YWEzMWQzZQAQANd4EP14TfhDun3gg5xTs... 1/4
6/29/2020 Mail - Morgan Richardson - Outlook
Chicago Police Department

The Chicago Police Department's mission is to serve our communities and protect the lives, rights and property of all
people in Chicago.

This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally
privileged and/or confidential information. If you are not the intended recipient of this e-mail (or the person responsible for
delivering this document to the intended recipient), you are hereby notified that any dissemination, distribution, printing or
copying of this e-mail, and any attachment thereto, is strictly prohibited. If you have received this e-mail in error, please respond
to the individual sending the message, and permanently delete the original and any copy of any e-mail and printout thereof.

From: Andrea Kersten < >


Sent: Friday, June 26, 2020 5:19 PM
To: Skahill, Tina M. < >;LYNN MCCARTHY (States Attorney)
< >; Konow, Karen M. < >;Westensee, Jay
< >
Subject: Re: Lieutenant John Cannon

I didn't see anything on this either, but we can certainly open a log. Thank you!

AK

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From: Skahill, Tina M. < >


Sent: Friday, June 26, 2020 4:51:26 PM
To: LYNN MCCARTHY (States Attorney) < >; Andrea Kersten
< >;Karen Konow < >;Jay Westensee
< >
Subject: Re: Lieutenant John Cannon

Lynn,
I didn't see anything. I'll check with COPA. Adding Jay.

Tina Skahill
Deputy Director
Bureau of Internal Affairs
Chicago Police Department

The Chicago Police Department's mission is to serve our communities and protect the lives, rights and property of all
people in Chicago.

This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally
privileged and/or confidential information. If you are not the intended recipient of this e-mail (or the person responsible for
delivering this document to the intended recipient), you are hereby notified that any dissemination, distribution, printing or
copying of this e-mail, and any attachment thereto, is strictly prohibited. If you have received this e-mail in error, please respond
to the individual sending the message, and permanently delete the original and any copy of any e-mail and printout thereof.

From: LYNN MCCARTHY (States Attorney) < >


Sent: Friday, June 26, 2020 3:42 PM
To: Kersten, Andrea < >;Konow, Karen M. < >;

https://outlook.office365.com/mail/inbox/id/AAQkADM1NDUwMDAyLTQ4YjYtNGUyMS05MTIILTQOMj15YWEzMWQzZQAQANd4EP14TfhDun3gg5xTs... 2/4
6/29/2020 Mail - Morgan Richardson - Outlook

Skahill, Tina M. < >


Subject: Fw: Lieutenant John Cannon

Hello - the SAO received an email complaint about social media posts of CPD Lt. John Cannon. Trying to
determine if IAD or COPA is aware of this issue and looking into it. The information was contained in a
twitter link listed below. Please let me know.

Thanks,
Lynn

1507'

LYNN McCARTHY
Supervisor, Law Enforcement Accountability Division
Cook County State's Attorney's Office
2650 South California -- Room
Chicago, Illinois 60608
email:

From: LETURAH JACKSON (States Attorney) < >


Sent: Friday, June 26, 2020 2:41 PM
To: LYNN MCCARTHY (States Attorney) < >
Cc: JENNIFER COLEMAN (States Attorney) < >
Subject: Fwd: Lieutenant John Cannon

Good afternoon.

I could could not open the link in the body of the email. This email message is a complaint about the behavior of a
police officer and I wanted you to be aware.

Get Outlook for iOS

From: StatesAttorney < >


Sent: Friday, June 26, 2020 2:24 PM
To: LETURAH JACKSON (States Attorney)
Subject: FW: Lieutenant John Cannon

From: < >


Sent: Friday, June 26, 2020 1:04 PM
To: StatesAttorney < >
Subject: Lieutenant John Cannon

External Message Disclaimer


This message originated from an external source. Please use proper judgment and caution when
opening attachments, clicking links, or responding to this email.

Good afternoon,

I've recently learned of the behavior of Lieutenant John Cannon of the Chicago police department. The level of racism
and misogyny he shared across social media is astounding
( )and clearly makes him unfit to serve our
community. As a white man, I'm shielded from many of the problems of the Chicago Police department, but that
https://outlook.office365.com/mail/inbox/id/AAQkADM1NDUwMDAyLTQ4YjYtNGUyMS05MTIILTQOMj15YWEzMWQzZQAQANd4EP14TfhDun3gg5xTs... 3/4
6/29/2020 Mail - Morgan Richardson - Outlook

means I must use my privilege to speak out whenever possible. Our community is less safe as long as he carries a gun
and a badge, and I know you care deeply about the safety of our community.

Thank you,

https://outlook.office365.com/mail/inbox/id/AAQkADM1NDUwMDAyLTQ4YjYtNGUyMS05MTIILTQOMjI5VVVEzMWQzZQAQANd4EPI4TfhDun3gg5xTs... 4/4
CCIVILIAN
PA
OFFICE OF POLICE ACCOUNTABILITY

INTEGRITY • TRANSPARENCY • INDEPENDENCE • TIMELINESS

Via Email

Log No.: 2020-0002942

July 7, 2020

Dear :

The Civilian Office of Police Accountability (COPA) has determined that the complaint you
submitted to our office falls within our investigatory jurisdiction for further investigation.

Therefore, COPA will:


• Assign an investigator to the case,
• Gather relevant evidence,
• Identify and interview witnesses,
• Identify and interview involved officers, and
• Document our investigative summary.

Once COPA completes its investigation into the above-referenced matter, you will receive a letter
detailing our findings.

If you have any questions, please feel free to contact our main office at (312) 746-3609 between
the hours of 9:00 a.m. to 5:00 p.m., Monday through Friday, and ask to speak with a Case Liaison.
Please be sure to have the log number referenced above available when you call so that we can
quickly locate your case file.

Regards,

Jay Westensee
Deputy Chief Administrator-Chief Investigator

1615 WEST CHICAGO AVENUE, 4TH FLOOR, CHICAGO, ILLINOIS 60622


312.743.COPA (COMPLAINT LINE) 1312.746.3609 (MAIN LINE) 1312.745.3598 (TTY) I WWW.CHICAGOCOPA.ORG

Form 1.1. Last Revised 9/15/17.


6/29/2020 Mail - Madilyn Kohs - Outlook

0) Reply all \/ Delete 0 Junk Block •••

- log number: 2020-0002942

Madilyn Kohs
Mon 6/29/2020 2:34 PM
6 t <*-) •••
To:

Good Afternoon,

I am an investigator at COPA who is investigating your case right now. I see you made a
email complaint regarding racial remarks and other bias remarks on social media that
were made by Lt. Cannon from CPD. I wanted to clarify exactly what your complaint is
and or if you have other complaints against Lt. Cannon, If you have a moment can you
call me at .

Thank you,

Maday Kalw
Investigator Badge #99
Civilian Office of Police Accountability (COPA)
1615 W. Chicago Avenue
4th floor
Chicago, IL 60622
P: (312) 746- 3609
Ext:

https://outlook.office365.com/mail/deeplink?version=2020062103.04&popoutv2=1 1/1
Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Document title: (1) on Twitter: &quot;Meet @Chicago_Police Lieutenant John M. Cannon, whom enjoys trolling Facebook with racist, homophobic, transphobic an…
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Document title: (1) on Twitter: &quot;Meet @Chicago_Police Lieutenant John M. Cannon, whom enjoys trolling Facebook with racist, homophobic, transphobic an…
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Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Document title: (1) on Twitter: &quot;Meet @Chicago_Police Lieutenant John M. Cannon, whom enjoys trolling Facebook with racist, homophobic, transphobic an…
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Capture timestamp (UTC): Mon, 29 Jun 2020 19:24:56 GMT Page 1 of 1
Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Document title: (1) on Twitter: &quot;Meet @Chicago_Police Lieutenant John M. Cannon, whom enjoys trolling Facebook with racist, homophobic, transphobic an…
Capture URL:
Capture timestamp (UTC): Mon, 29 Jun 2020 19:25:28 GMT Page 1 of 1
Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Document title: (1) on Twitter: &quot;Meet @Chicago_Police Lieutenant John M. Cannon, whom enjoys trolling Facebook with racist, homophobic, transphobic an…
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Capture timestamp (UTC): Mon, 29 Jun 2020 19:25:40 GMT Page 1 of 1
Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Document title: (1) on Twitter: &quot;Meet @Chicago_Police Lieutenant John M. Cannon, whom enjoys trolling Facebook with racist, homophobic, transphobic an…
Capture URL:
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Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Document title: (1) on Twitter: &quot;Meet @Chicago_Police Lieutenant John M. Cannon, whom enjoys trolling Facebook with racist, homophobic, transphobic an…
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Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Document title: (1) on Twitter: &quot;Meet @Chicago_Police Lieutenant John M. Cannon, whom enjoys trolling Facebook with racist, homophobic, transphobic an…
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Document title: (1) Chicago Police on Twitter: "CPD Lieutenant John Cannon testified today in
front of the Public Safety Committee about his experience as a midnight Watch
Commander in @ChicagoCAPS18 and crimes he has seen related to false
representation of ride a share driver. Watch Cannon’s testimony below:
#CPDMediaCar https://t.co/GNSRBz6WjZ" / Twitter

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Document title: (1) Chicago Police on Twitter: &quot;CPD Lieutenant John Cannon testified today in front of the Public Safety Committee about his experience as a…
Capture URL:
Capture timestamp (UTC): Mon, 29 Jun 2020 19:27:28 GMT Page 1 of 1
Document title: (1) Chicago Police on Twitter: "CPD Lieutenant John Cannon testified today in
front of the Public Safety Committee about his experience as a midnight Watch
Commander in @ChicagoCAPS18 and crimes he has seen related to false
representation of ride a share driver. Watch Cannon’s testimony below:
#CPDMediaCar https://t.co/GNSRBz6WjZ" / Twitter

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Document title: (1) Chicago Police on Twitter: &quot;CPD Lieutenant John Cannon testified today in front of the Public Safety Committee about his experience as a…
Capture URL:
Capture timestamp (UTC): Mon, 29 Jun 2020 19:27:28 GMT Page 1 of 1
Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Page loaded at (UTC): Mon, 29 Jun 2020 19:19:12 GMT

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Document title: (1) on Twitter: &quot;Meet @Chicago_Police Lieutenant John M. Cannon, whom enjoys trolling Facebook with racist, homophobic, transphobic an…
Capture URL:
Capture timestamp (UTC): Mon, 29 Jun 2020 19:28:11 GMT Page 1 of 1
Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Page loaded at (UTC): Mon, 29 Jun 2020 19:19:12 GMT

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Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
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setting one hell of an example for the officers he commands @CPDReform
/ Twitter

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Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
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memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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Document title: (1) on Twitter: "Meet @Chicago_Police Lieutenant John M. Cannon, whom
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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
/ Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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enjoys trolling Facebook with racist, homophobic, transphobic and xenophobic
memes under the name “Samuel Hipster.” Hes your typical hateful Trump troll
setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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setting one hell of an example for the officers he commands @CPDReform https://
t.co/5MLzRjTeBa" / Twitter

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setting one hell of an example for the officers he commands @CPDReform
" / Twitter

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C PA
CIVILIAN OFFICE OF POLICE ACCOUNTABILITY
INTEGRITY • TRANSPARENCY • INDEPENDENCE • TIMELINESS

CONSENT TO RECORD INTERVIEW

Date: 10/28/20 Location: Remote due to COVID-19

(name) authorize investigator(s)

Emily Pierce and Elizabeth Brett (name)

from the Civilian Office of Police Accountability to audio / video (circle one or both, as
11am
applicable) record our interview on 10/28/20 (date) at

a.m. / p.m. (circle one)

I understand that I am not required to consent to such recording, and I have given permission to

the above-named investigator(s) freely and voluntarily and without threats or promises of any kind.

Signature

Witness

Witness

Last Revised 2/2/2020


PA
CIVILIAN OFFICE OF POLICE ACCOUNTABILITY
INTEGRITY • TRANSPARENCY • INDEPENDENCE • TIMELINESS

NOTICE

Investigator's Name: Additional Investigator's Name:

Emily Pierce Elizabeth Brett


Log Number: Date:

2020-2942 10/28/20
Statement of:

My name is Emily Pierce , and I am an investigator


with the City of Chicago's Civilian Office of Police Accountability (COPA). COPA is not a
part of the Chicago Police Department and I am not a police officer. My job is to investigate
police conduct, and I would like to speak with you to investigate the conduct of the police in
this incident. COPA may release your statement, for instance with a court order, subpoena, to
pursue disciplinary action against a police officer proven to have committed misconduct, or
for other reasons. If you have a lawyer, you are free to speak with that lawyer before giving
me a statement.

L , hereby state that I have read and/or


have been read this notice by the COPA investigator and, understanding this notice, I voluntarily
choose to give a statement to COPA.

10/28/2020
Signature of Interviewee Date and Time

Signature of Interviewee Date and Time

Last Revised 2/2/2020


anvass Musa ion

Chicago Police Department Edit Watch Information

Personnel Suite / Office AutornaVon Watch Screen.

Employee Details

Star No.14121 Empbyee No. [ ] Sax [M ] Race [WHI

Nem [CANNON, [FULL


outs
JOHN M ] ste" Duni]
PC No. [ ] Position Code [9173 Postkin Description [LIEUTENANT OF POLICE ]
[01- -
Appointment Date [13-APR- Sank:city Date MAY Date of Birth -
199a ]
] 1971

P22
Address Home Phone N Cell Phone No. [ ] District of Residence

[]
Assigned Unit [01B -18TH DISTRICT- NEAR NORTH ] Untof Detail [ - ]
Detailed Dabs [] Modified Date 07-DEC-2020

Viaw Clean Shaven Exemption


Clean Shaven Exemption N I Assignment [] Card # [] Card Expiration Date []

View Watch Details


-
Mra Telephone No Pate TridnIng Band No [ ] FEMA BID No []
]

Furbugh year [2021 ] Segment 4108


Sagnent 11°M
Full[]

Cost Kerry [D] Current Watch MI


Section ri Teem [] Day Off
Squad []
Group[65 ] Bee[1891 ]
End Tine 1 [0500
Lunch Siert -rills 1 .[,2°00
Start lime 2i End Time 2 []
Assignment -We [FIELD ]
Comments []

[]
[FIELD
~YPeassvamcle [1 MAN MARKED CAR Vehicle No [NA Nara &Assignment LIEUTENANT
WITHOUT CAGE ]

[]
Location []

[]
Perf. Evaluation Year [201B 1st RevIew[EXCEEDS EXPECTATIONS ]
CurantAcaderrry Class [] Hours Par Shift [8 ] BWC Exempt [N

relpelkimeicagortorgipsklegO,Denetrio=chrls.thIcepopolle f?p=150aa211:1161664a49449734:NO:nTS 112


VIII2011 BMWait krtundan
Equipment information
Lacier Humber [ Gas Mask [13231)/C50 Mot EquIpmentn

Eildillanagamant Data
District [Ole]'Notch [1 ] ElldiMgmt [B] Sankt? M3 [001

Extended Hours the Wilde


VOWS No License Plate No. Vehicle Category n ] ]
JUStiftStkin

U to r.

repelferneiceacipaimonipidareADerierfo=chrlactacepopolkt•Jocal.Vp=15(1817.20:11(11664a49449734:240:::YES 212
SWORN AFFIDAVIT

Location of Incident: Date of Incident: Time of Incident:

Internet Multiple Multiple

1 , affirm that the statement I have given to the Civilian


Office of Police Accountability, and any allegations that I have made, are true.

(Signature of person making statement) (Printed name of person making statement)

10/28/2020
(Date)

State of Illinois
County of Cook

Signed and affirmed to before me on 1012eizo by: EA, LA Cie r


(Date) (Printed name ofNotary Public)

OFFICIAL SEAL
EMILY PIERCE
NOTARY PUBLIC •
MY COMMISSION STATE OF ILLINOIS
EXPIRES:10/18/21

(Seal) (Signature of Notary Public)

Attachment No.:

Complaint Log No.: 2020-2942

rev. 12/18/18
I DATE
REQUEST FOR INTERVIEW/STATEMENT/REPORT
CHICAGO POLICE DEPARTMENT 1/7/21
NAME RANK STAR NO. UNIT
TO:
JOHN M. CANNON LIEUTENANT 412 18

SUPERVISOR TO ACCOMPANY ABOVE PERSONNEL 0 YES Gil NO

YOUR APPEARANCE IS REQUIRED

ON - DATE TIME
AT 0 BUREAU OF INTERNAL AFFAIRS [E1 CIVILIAN OFFICE OF POLICE ACCOUNTABILITY
3510 S. Michigan Ave. 1615 West Chicago Ave. - 4th Floor
PAX 0610 Bell 745-6310 PAX 0114 Bell 746-3594
TUES JAN. 19 2021 7AM
AS El ACCUSED 0 WITNESS 0 COMPLAINANT

FOR STATEMENT 0 SUBMISSION OF A TO-FROM-SUBJECT REPORT

CONCERNING - NATURE OF COMPLAINT


ACCUSED STATEMENT

REFERENCE - DATE TIME LOCATION RD NO. CB NO. OTHER


MULTIPLE FACEBOOK N/A N/A N/A

You are to report to

RANK NAME STAR NO. PAX


MCS EMILY PIERCE 40 312-937-1267

NOTE: The member MUST notify the investigator of his/her inability to keep this scheduled appointment.

NOTIFICATION MADE TO UNIT DATE TIME

NOTIFICATION MADE BY UNIT HOW


EMILY PIERCE 113 DEPT. EMAIL/COURT NOTI F.
CONFIRMATION OF NOTIFICATION MADE BY UNIT DATE TIME

APPROVED SIGNATURE OF REQUESTER

El Copy to unit/watch commander: If the requested member is not available due to being on medical, furlough, transfer,
etc., YOU will notify B.I.A./C.O.P.A. immediately.

LOG NO.
2020-2942
ATTACHMENT NO

CPD-44.103 (REV. 9/17)


GIVEN TO ACCUSED
NOTIFICATION OF CHARGES/ALLEGATIONS DATE TIME
CHICAGO POLICE DEPARTMENT
0012 I 14-
NAME OF ACCUSED RANK STAR NO. EMPLOYEE NO. UNIT OF ASSIGNMENT
JOHN CANNON LT 412 018

The law provides that if you are to be charged with a criminal offense or if the Department seeks separation, you are
to be advised in writing of the specific illegal or improper acts alleged against or attributed to you.
Furthermore, Department policy provides that you have a right to be advised in writing of the names of complainants
and allegations against you prior to any questioning of you concerning the allegation regardless of the nature of the
allegation and even if the allegation is such that it will not result in the filing of criminal charges or the filing of
separation charges.
Accordingly, you are advised that the following allegations have been made against you:
COMPLAINANT(S)

1.
2.

3.

4.

1. It is alleged that on or about June 25, 2020, Lieutenant John Cannon made a statement on Facebook that was
disrespectful to CPD, in that he posted an image of a man in a Blue Lives Matter hat holding multiple boots in his arms,
with the text "how do I lick all these boots (sic.)
2. It is alleged that on or about June 25, 2020, Lieutenant John Cannon reposted a statement on Facebook that was
biased against African Americans and Muslims, in that it depicted a picture of President Obama wearing a turban with
the text "Obama is ISIS."
3. It is alleged that on or about June 25, 2020, Lieutenant John Cannon posted a statement on Facebook that was
biased against African Americans, in that it responded to an academic paper in support of the Black Lives Matter
movement by stating, "The factionalized element in charge of higher education, is dangerous to the Sovereign. Truly an
enemy of the State (sic)."
4. It is alleged that on or about June 13, 2020, Lieutenant John Cannon reposted a statement on Facebook that was
biased against African Americans and Asians, in that it depicted a white child with the words "asking her to apologize
for slavery" and an Asian child with the words "is like asking her to apologize for Pearl Harbor."

I hereby acknowledge receipt in writing of the charges or allegations aga

Sign

WITNESSES

LO NU BER INVESTIGATION
LOG NO.TYPE - CR
Orig na to investigator's file.
Copy to accused member. 2020-2942
ATTACHMENT NO.

CPD-44.115 (Rev. 8/16)


GIVEN TO ACCUSED
NOTIFICATION OF CHARGES/ALLEGATIONS DATE TIME
CHICAGO POLICE DEPARTMENT
)(tbrZ-f 2:14 M
NAME OF ACCUSED RANK STAR NO. EMPLOYEE NO. UNIT OF ASSIGNMENT
JOHN CANNON LT 412 018

The law provides that if you are to be charged with a criminal offense or if the Department seeks separation, you are
to be advised in writing of the specific illegal or improper acts alleged against or attributed to you.
Furthermore, Department policy provides that you have a right to be advised in writing of the names of complainants
and allegations against you prior to any questioning of you concerning the allegation regardless of the nature of the
allegation and even if the allegation is such that it will not result in the filing of criminal charges or the filing of
separation charges.
Accordingly, you are advised that the following allegations have been made against you:
COMPLAINANT(S)

1.

2

3.

4.

5. It is alleged that on or about June 8, 2020, Lieutenant John Cannon reposted a statement on Facebook that was
biased against African Americans, by stating, "Welcome to peasantry, equal not good enough huh?" and "White
privilege is a myth perpetuated by those who hate white people (sic)."
6. It is alleged that on or about April 5, 2020, Lieutenant John Cannon reposted a statement on Facebook that was
offensive toward members of the public, in that it depicted a man in a Sherriff uniform with the text "back up ya
sonsofbitches 6 feet away from me or I'll shoot your corona infested asses (sic)."
7. It is alleged that on or about February 9, 2020, Lieutenant John Cannon reposted a statement on Facebook that was
biased against homosexuals and firemen, in that it depicted four naked men in bed together with the text "meanwhile at
the firehouse..."
8. It is alleged that on or about September 9, 2019. Lieutenant John Cannon reposted a statement on Facebook that
was biased against women, in that it depicted an image of Clint Eastwood with the text, "A she-shed? In my day we
called that a kitchen," written below.

I hereby acknowledge receipt in writing of the charges or allegations ag st me.

Sign

WITNESSES

DISTRIBLA
LOG NUIV BEyt INVESTIGATION
LOG NO.TYPE - CR
Original to \lrWestigator's file.
Copy to accused member. 2020-2942
ATTACHMENT NO.

CPD-44.115 (Rev. 8/16)


GIVEN TO ACCUSED
NOTIFICATION OF CHARGES/ALLEGATIONS DATE TIME
CHICAGO POLICE DEPARTMENT
Ti) IA, jv Z! 15~~
NAME OF ACCUSED RANK STAR NO, EMPLOYEE NO. UNIT OF ASSIGNMENT
JOHN CANNON LT 412 018

The law provides that if you are to be charged with a criminal offense or if the Department seeks separation, you are
to be advised in writing of the specific illegal or improper acts alleged against or attributed to you.
Furthermore, Department policy provides that you have a right to be advised in writing of the names of complainants
and allegations against you prior to any questioning of you concerning the allegation regardless of the nature of the
allegation and even if the allegation is such that it will not result in the filing of criminal charges or the filing of
separation charges.
Accordingly, you are advised that the following allegations have been made against you:
COMPLAINANT(S)

1.

2.

3.

4.

9. It is alleged that on or about August 4, 2019, Lieutenant John Cannon reposted a statement on Facebook that was
biased against African Americans, in that he reposted a side-by-side image of Roseanne Barr and Jussie Smollett with
the text, "Racism in 2019: Fired after a bad joke (above Roseanne Barr), Working after an EVIL joke (above Jussie
Smollett)."
10. It is alleged that on or about May 18, 2019, Lieutenant John Cannon reposted a statement on Facebook that was
biased against African Americans and other minority groups, by stating, "Let me get this straight.. . the Democratic
candidate want to win back the vote of working class men and women by promising to take back our tax cut, open our
borders, give reparations to people my great great grandpa never harmed and use my taxes to pay off the debt of
college kids who look down upon me as being 'white privileged,' got it. (sic)"
11. It is alleged that on or about April 27, 2019, Lieutenant John Cannon reposted a statement on Facebook that was
biased against Muslims and women, in that it depicted photos of Ilhan Omar, Alexandria Ocasio-Cortez, Ayanna
Pressley, and Rashida Tlaib with the text, "We're new, bold, and we hate you too," and the response, "The party of
freaks, antisemitics, racist, DANGEROUS. The new KKK wing of the party (sic)."

I hereby acknowledge receipt in writing of the charges or allegations a ' st me.

Sig

WITNESSES

LOG NU BER INVESTIGATION


LOG NO TYPE - CR
Origin to investigator's file.
Copy to accused member. 2020-2942
ATTACHMENT NO.

CPD-44.115 (Rev. 8/16)


GIVEN TO ACCUSED
NOTIFICATION OF CHARGES/ALLEGATIONS DATE TIME
CHICAGO POLICE DEPARTMENT
71 121 2: )ct iofil
NAME OF ACCUSED RANK STAR NO. EMPLOYEE NO. UNIT OF ASSIGNMENT
JOHN CANNON LT 412 018

The law provides that if you are to be charged with a criminal offense or if the Department seeks separation, you are
to be advised in writing of the specific illegal or improper acts alleged against or attributed to you.
Furthermore, Department policy provides that you have a right to be advised in writing of the names of complainants
and allegations against you prior to any questioning of you concerning the allegation regardless of the nature of the
allegation and even if the allegation is such that it will not result in the filing of criminal charges or the filing of
separation charges.
Accordingly, you are advised that the following allegations have been made against you:
COMPLAINANT(S)

1.
2.

3.

4.

12. It is alleged that on or about April 16, 2019, Lieutenant John Cannon reposted a statement on Facebook that was
biased against Muslims, which depicts a cartoon wooden horse being pulled through a door. The text "America" is
written at the door and people appearing to stand with their hands up blocking the horse. The person dragging the
horse is depicted with the word "democrat" and the horse has the words "Ilhan Omar" and Sharia Law" written on it.
13. It is alleged that on or about March 15, 2019, Lieutenant John Cannon reposted a statement on Facebook that was
biased against Muslims, in that he reposted an image with the text, "I don't feel safe wearing my headscarf in Trump's
America," and the response, "Really? Try being a white catholic kid in a MAGA hat."
14. It is alleged on that or about March 10, 2019, Lieutenant John Cannon reposted a statement on Facebook that was
biased against Muslims, which depicts the image of Abdullah Zuber and states, "Jihad will continue until all the Hindus,
Christians, Buddhists, Atheists are killed. Your secularism & tolerance can not change our ideology. Quran does NOT
permit survival of non-Muslims (sic)." The text below advises, "Keep this in mind as new members of Congress who are
Muslim are sworn into office on this book of death and inequality (sic)."

I hereby acknowledge receipt in writing of the charges or allegations a l st me.

Signatu

WITNES

DIS
LOG UM,iER INVESTIGATION
LOG NO.TYPE - CR
Original t0investigator's file.
Copy to accused member. 2020-2942
ATTACHMENT NO.

CPD-44.115 (Rev. 8/16)


GIVEN TO ACCUSED
NOTIFICATION OF CHARGES/ALLEGATIONS DATE TIME
CHICAGO POLICE DEPARTMENT
30.121 re)
NAME OF ACCUSED RANK STAR NO. EMPLOYEE NO. UNIT OF ASSIGNMENT
JOHN CANNON LT 412 018

The law provides that if you are to be charged with a criminal offense or if the Department seeks separation, you are
to be advised in writing of the specific illegal or improper acts alleged against or attributed to you.
Furthermore, Department policy provides that you have a right to be advised in writing of the names of complainants
and allegations against you prior to any questioning of you concerning the allegation regardless of the nature of the
allegation and even if the allegation is such that it will not result in the filing of criminal charges or the filing of
separation charges.
Accordingly, you are advised that the following allegations have been made against you:
COMPLAINANT(S)

1.
2.

3.

4.

15. It is alleged that on or about January 28, 2019, Lieutenant John Cannon reposted a statement on Facebook that
was biased against members of the LGBTQ community, in that he reported side-by-side images of a young man in a
MAGA hat and a young person in drag with the text, "LIBERAL LOGIC: Kid in MAGA hat, offensive. Kid in drag,
BRAVE!"
16. It is alleged that on or about January 8, 2019, Lieutenant John Cannon reposted a statement on Facebook that was
biased against Hispanic people and immigrants, in that he reposted an image of soldiers with the text, "Democrats will
stop these people's paychecks," and an image of Hispanic people with the text, "To protect illegal people like this. Let
that sink in."
17. It is alleged that on or about November 18, 2018, Lieutenant John Cannon posted a statement on Facebook that
was biased against Hispanic people, by stating, "Working class Mexican residents of Tijuana are worried that the South
American invaders are going to compete for their jobs and bring crime and drugs. Let that sink in. And they are
probably correct in some respects (sic)."
18. It is alleged that on or about October 5, 2018, Lieutenant John Cannon posted a statement on Facebook that was
disrespectful to CPD, by stating, "Festering maggot filled pool of scum and villany (sic). I will be glad when I can leave."

I hereby acknowledge receipt in writing of the charges or allegations a t me.

Sig

WITNES
kto
071
D
L• MBER INVESTIGATION
On. • . to investigator's file. LOG NO.TYPE - CR
Copy to accused member. 2020-2942
ATTACHMENT NO.

CPD-44.115 (Rev. 8/16)


GIVEN TO ACCUSED
NOTIFICATION OF CHARGES/ALLEGATIONS DATE TIME
CHICAGO POLICE DEPARTMENT 3/i6(21
2tigeti^
NAME OF ACCUSED RANK STAR NO. EMPLOYEE NO. UNIT OF ASSIGNMENT
JOHN CANNON LT 412 018
The law provides that if you are to be charged with a criminal offense or if the Department seeks separation, you are
to be advised in writing of the specific illegal or improper acts alleged against or attributed to you.
Furthermore, Department policy provides that you have a right to be advised in writing of the names of complainants
and allegations against you prior to any questioning of you concerning the allegation regardless of the nature of the
allegation and even if the allegation is such that it will not result in the filing of criminal charges or the filing of
separation charges.
Accordingly, you are advised that the following allegations have been made against you:
COMPLAINANT(S)

1.
2.

3.

4.

19. It is alleged that on or about July 15, 2018, Lieutenant John Cannon posted a statement on Facebook that was
disrespectful to CPD, in that he responded to a post containing the BWC footage of a police-involved shooting by
stating, "Brave young warriors face to face with an urban terrorist and the better trained professional Police Officer won
the day. Excellent work by all the new batch of warriors. Love it. (sic)"

I hereby acknowledge receipt in writing of the charges or allegations against me.

WIT

DIST ION:
LOG = ER INVESTIGATION
Origi LOG NO.TYPE - CR
investigator's file.
Copy accused member. 2020-2942
ATTACHMENT NO.

CPD-44.115 (Rev. 8/16)


ADMINISTRATIVE PROCEEDINGS RIGHTS GIVEN TO ACCUSED
DATE TIME
(Statutory)
CHICAGO POLICE DEPARTMENT 3111' 12 r Z: 331 (1')
NAME OF ACCUSED RANK STAR NO. EMPLOYEE NO. UNIT OF ASSIGNMENT
JOHN CANNON LT. 412 018
The law provides that you are to be advised of the fol owing:
1. Any admission or statement made by you in the course of this hearing, interrogation or examination may
be used as the basis for your suspension or as the basis for charges seeking your removal or discharge or
suspension in excess of 30 days.
2. You have the right to counsel of your choosing to be present with you to advise you at this hearing,
interrogation or examination and you may consult with counsel as you desire.
3. You have a right to be given a reasonable time to obtain counsel of your own choosing.
4. You have no right to remain silent. You have an obligation to truthfully answer questions put to you. You
are advised that your statements or responses constitute an official police report.
5. If you refuse to answer questions put to you, you will be ordered by a superior officer to answer the
questions.
6. If you persist in your refusal after the order has been given to you, you are advised that such refusal
constitutes a violation of the Rules and Regulations of the Chicago Police Department and will serve as a
basis for which your discharge will be sought.
7. You are further advised that by law any admission or statement made by you during the course of this
hearing, interrogation or examination and the fruits thereof cannot be used against you in a subsequent
criminal proceeding.

NOTE: Rule 14 of the Chicago Police Department's Rules and Regulations prohibits making a false report, written or
oral. Making a false report, may result in separation from the Chicago Police Department.

I hereby acknowledge that I was informed of the above rights and Rule 14 of the Chicago Police Department's Rules
and Regulations prior to interrogation.

WITNESSES

DIST ON:
COMP I T LOG INVESTIGATION
Origina o investigator's file.
Copy to accused member. COMPLAINT LOG NO. TYPE -CR
2020-2942
ATTACHMENT NO.

CPD-44.105 (Rev. 6/09)


WAIVER OF COUNSEL/REQUEST TO SECURE COUNSEL
CHICAGO POLICE DEPARTMENT

NAME OF ACCUSED RANK STAR NO. UNIT OF ASSIGNMENT


JOHN CANNON LT 412 018

n WAIVER OF COUNSEL

I, the undersigned, hereby acknowledge that I have received and read the charges/allegations against me and I
knowingly and voluntarily wish to proceed with the hearing, examination or interrogation without having counsel of
my own choosing present to advise me during this hearing, examination or interrogation.

Date-Time TUES JAN 18 21 7 AM Signature

REQUEST TO SECURE LEGAL COUNSEL

I, tt e undersigned, having been advised of my right to counsel of my own choosing at all hearings, examinations and
interrogations in connection with the charges/allegations against me which have been given to me in writing and
receipt of which is hereby acknowledged, elect to secure the services of counsel and agree to proceed with said
hearing, examination or interrogation at

7 AM hours, on TUES JAN 18 20 21 in Room COPA, 4TH FLOOR

1615 W. CHICAGO AVE.


Chicago, Illinois, at which time said hearing, examination or interrogation shall be
commenced. By placing my signature upon this statement, I affirm m ish to secure said counsel and agree to
comply with Department hearing, examination or interrogation schecit d on mate aforesaid.

Date-Time Signa

W
Lift

NT REGISTER INVESTIGATION

Original to investigator's file COMPLAINT REGISTER NO 2020-2942


Duplicate to affected member
ATTACHMENT NO.
CPD-44.106 (Rev. 6/06)
COMPLAINANT AFFIDAVIT

I. A. ISSUE/BASIS

On or about May 31, 2020, the University of Illinois-Chicago John Marshall Law School's

(hereinafter "UIC-JMLS" or "JMLS") "operators" harassed and discriminated against me

based on my race, national origin, and profession, in violation of 775 ILCS 5/5-102 and 775

ILCS 5/5-102.2. As a direct result of this harassment and discrimination, my employer

charged me with nineteen (19) counts of administrative violations based upon my role as a

police officer; and, my employer rescinded multiple promotional offers.

B. PRIMA FACIE ALLEGATIONS:

1. I am a forty-nine-year-old white male of European descent, am married with three

(3) and six (6) .

2. I was an active member of the Unites States Air Force for two (2) years and

received an honorable discharge in and around 1992.

3. I have been employed by the Chicago Police Department for over twenty-two (22)

years; I have been in a supervisory role for approximately sixteen (16) years; and,

my current rank is Lieutenant.

4. I received a Bachelor's Degree of Arts in Administration of Justice from Southern

Illinois University in and around 1997; and, a Master's Degree of Arts in Public

Safety Administration from Calumet College of St. Joseph in and around 2015.

5. I am currently a part-time law student at UIC-JMLS; I am scheduled to graduate

in and around August 2021. My current GPA is 3.29.

6. UIC-JMLS is a "place of public accommodation" within the meaning of 775 ILCS

5/5-101 because it is a "a non-sectarian ... postgraduate school, or other place of

education" providing postgraduate legal education.

4848-8309-4752, v. 2
7. Each dean, administrator, professor, and all other faculty and staff of UIC-JMLS

is an "operator" within the meaning of 775 ILCS 5/5-101(B) and also a "public

official" within the meaning of 775 ILCS 5/5-101(C).

8. Deans, Administrators, Professors and staff at JMLS are aware of my race, gender,

national origin and profession.

9. UIC-JMLS keeps records of students who work as police officers.

10. On May 31, 2020 Dean sent an email to the entire UIC-JMLS

student body titled "Urgent message to the community" in which she made a series

of hateful, derogatory comments asserting unsupported and discriminatory

statements in regard to specific sexes, racial and ethnic groups.

11. Her email stated that "white men" and "police officers" in particular, "kill black

people." She further claimed that prosecutors as a group do not charge "white

people," and that they also do not charge white "police officers [who] kill black

people."

12. Dean email further stated that white police officers as a group

"unjustly and brutally kill black people and punish peaceful protestors through

violence."

13. In response to the Dean's use of inflammatory, race-based, hate speech, I

experienced a profound sense of injury and emotional distress.

14. The severe and highly inflammatory nature of Dean letter constituted

severe and pervasive harassment.

15. Dean correspondence labeled individuals of my racial, ethnic and

cultural background as being composed of only violent, murderous, bigoted

individuals. decision to publicize her hate speech to the entire student

4848-8309-4752, v. 2
body caused great suffering, made me feel unwelcomed and as though I was in a

hostile environment with a constant threat of being victimized by the racist and

discriminatory attitudes of UIC-JMLS' administration.

16. On or about June 2, 2020 I sent Dean an email wherein I asked her to

stop sending me such offensive, discriminatory emails.

17. Dean did not respond to my request

18. On or about June 22, 2020 Dean sent another email to the entire UIC-

JMLS student body wherein she stated that "white men, police and former police"

are categorically prone to violence due to race and national origin.

19. Dean further prodaimed that white police officers as a group all harbor

an "ideology of white supremacy" which impels them to violence.

20. Dean engaged in discriminatory conduct and actions that incited a

culture of severe and pervasive harassment; as the Dean of UIC-JMLS,

informed the entire UIC-JMLS student body that all white police officers commit

violence against black people because they are white supremacists.

21. Dean emails therefore constitute "severe or pervasive harassment of

an individual" within the meaning of 775 ILCS 5/5-102.2.

22. On or about- June 8, 2020, I filed an official complaint with UIC-JMLS regarding

inter alia Dean May 31, 2020 correspondence via the JMLS' portal via

https://jmls.uic.edu/security/discrimination-form/ per the suggestion of Dean

23. Neither Dean nor UIC-JMLS have taken any corrective action in

response to my complaint; and, as of the date of this filing I have not received any

findings or an outcome of my filed complaint.

4848-8309-4752, v. 2
24. Most recently, on or about March 8, 2021, I received email correspondence from

UICs Director of the Office for Access and Equity wherein he advised me, "OAE

received a copy of your complaint with JMLS on June 29, 2020 from the Dean of

JMIS. . . When analyzing a complaint we look at our University Non-

Discrimination Policy Statement available here. [included a hyperlink]. You did

not state a claim that would be a protected category and this matter was closed

administratively due to lack of jurisdiction on subject matter."

25. UIC-JMLS never informed me that my complaints had been "closed

administratively" or when that determination was made until I received this March

8, 2021 email and after sending many inquiries into the status of my complaints.

26. UIC-JIMLS' inaction to my complaint is a "denial of access to facilities goods or

services" of a place of public accommodation within the meaning of 775 ILCS

5/5-102.2

27. UIC-JMLS' inaction to my complaint constitutes a failure by a "covered entity ...

to take corrective action to stop the severe or pervasive harassment" within the

meaning of 775 ILCS 5/5-102.2.

28. Accordingly, the Illinois Department of Human Rights has jurisdiction over this

matter.

II. A. ISSUE/BASIS

On or about June 3, 2020, UIC-JMLS' "operators" harassed and discriminated against me

based on my race, national origin, religion and profession, in violation of 775 ILCS 5/5-102

and 775 ILCS 5/5-102.2. As a direct result of this harassment and discrimination, my

employer charged me with nineteen (19) counts of administrative violations based upon my

role as a police officer; and, my employer rescinded multiple promotional offers.

4848-8309-4752, v. 2
B. PRIMA FACIE ALLEGATIONS

1. I am a forty-nine-year-old white male of European descent, am married with three

(3) and six (6)

2. I was an active member of the Unites States Air Force for two (2) years and

received an honorable discharge in and around 1992.

3. I have been employed by the Chicago Police Department for over twenty-two (22)

years; I have been in a supervisory role for approximately sixteen (16) years; and,

my current rank is Lieutenant.

4. I received a Bachelor's Degree of Arts in Administration of Justice from Southern

Illinois University in and around 1997; and, a Master's Degree of Arts in Public

Safety Administration from Calumet College of St. Joseph in and around 2015.

5. I am currently a part-time law student at UIC-JMLS; I am scheduled to graduate

in and around August 2021. My current GPA is 3.29.

6. UIC-JMLS is a "place of public accommodation" within the meaning of 775 ILCS

5/5-101 because it is a "a non-sectarian ... postgraduate school, or other place of

education" providing postgraduate legal education.

7. Each dean, administrator, professor, and all other faculty and staff of UIC-JMLS

is an "operator" within the meaning of 775 ILCS 5/5-101(B) and also a "public

official" within the meaning of 775 ILCS 5/5-101(C).

8. Deans, Administrators, Professors and staff at JMLS are aware of my race, gender,

national origin, religion and profession.

9. I am a baptized, practicing Roman Catholic.

4848-8309-4752, v. 2
10. My is a practicing Roman Catholic. My late was a practicing Roman

Catholic. They were married in a Roman Catholic marriage ceremony in 1966 and

remained married for several decades thereafter.

11. I was born approximately 5 years after my marriage.

12. Publicly describing another person in an official communication as a "bastard" is,

inter a/ia, a declaration that the targeted person was conceived as the result of an

extramarital relationship of unmarried partners.

13. Conceiving children outside of the context of marriage is contrary to the teaching

of the Roman Catholic Church. See CATECHISM OF THE CATHOLIC CHURCH §§

2331-2391

14. On or about June 3, 2020 UIC-JMLS' Dean of Diversity, Equity and Inclusion,

Tania sent an email to all faculty, staff and students at JMLS that featured a

poster titled "BREATHE" including the message All Cops Are Bastards

("ACAB").

15. The Merriam-Webster English Dictionary defines the term "bastard" as

"1: an illegitimate child


2: something that is spurious (see SPURIOUS sense 3a), irregular, inferior, or
of questionable origin
3a: an offensive or disagreeable person —used as a generalized term of abuse."
MERRIAM-WEBSTER DICTIONARY, accessible at
https:/ /www.merriam-webster.com/dictionary/bastard

16. The Merriam-Webster English Dictionary defines "illegitimate" as: "not

recognized as lawful offspring; 4.ecOcally: born of parents not married to each

other." MERRIAM-WEBSTER DICTIONARY, accessible at fittps:/ /www.merriam-

webster.comidictionary/illegitimate

4848-8309-4752, v. 2
17. On or about June 4, 2020, I sent an email to Dean wherein I asked that she

refrain from sending emails with any similar content to "All Cops Are Bastards."

I communicated to Dean that I found such content to be incredibly

offensive, discriminatory and harassing to me and other members of my race,

national origin, religion and profession.

18. Further, "All Cops Are Bastards" ("ACAB") constituted severe and pervasive

harassment based upon my religious affiliation. By Dean applying the word

"bastard" to me, she declared that my parents had engaged in an extramarital

relationship in order to conceive me. Furthermore, assertion gravely

insulted my and deceased by accusing them of engaging in what our

religion teaches to be a gravely sinful action. "Bastard" is "a term of abuse" and

this term gravely injured me by calling into question the circumstances of my birth

and the integrity of my family, falsely alleging non-conformity to the principles of

our faith. Dean use of this type of offensive language caused me great

harm and insulted my faith and religion as a Roman Catholic.

19. On or about June 4, 2020, I requested that Dean refrain from disseminating

hateful, discriminatory, biased, and offensive materials to me via my JMLS student

email account; she refused to do so.

20. Additionally, I informed Dean her message containing the "All Cops Are

Bastards" ("ACAB") slogan was a highly offensive derogatory slur that that was

hurtful and harmful to me.

21. In denying my request, Dean told me that she would continue to include

me on any future emails and advised that I should simply ignore emails with

content that was offensive.

7
4848-8309-4752, v. 2
22. Shortly thereafter, Dean advised me that Dean told her I was a

police officer; and, Dean then suggested I should take an incomplete or

withdraw from classes at JMLS.

23. suggestion that I take an incomplete or withdraw from my classes

interfered with my access to JMLS' facilities and my legal education. JMLS'

administrators took action against me because I filed a complaint to their

objectively offensive email content.

24. On or about June 6, 2020, I responded to Dean above-mentioned email

wherein I informed her that I would not withdraw from classes and again asked

her to refrain from sending me offensive emails.

25. Both Dean and Dean refused to acknowledge my complaints;

and, instead, tried to prevent my access to a legal education. Additionally, neither

Dean nor Dean took any corrective action in response to my

complaints.

26. Dean and Dean email communications violated my rights to

be free from a severe or pervasive and harassing educational environment; and, to

be free from discrimination based on my race, national origin, religion and

profession. Their actions created a hostile educational environment.

27. Dean "All Cops Are Bastards" ("ACAB") message discriminated against

me and all persons of my race, national origin, religion and profession.

28. On or about June 8, 2020, Dean apologized to me for the "All Cops are

Bastards" ("ACAB") comment and admitted that it should not have been

distributed to the JMLS student body and community. apology and

admission confirmed that the message of "All Cops Are Bastards" ("ACAB") was

8
4848-8309-4752, v. 2
a discriminatory statement that JMLS, as a public university, cannot legally

disseminate.

29. Dean suggested she was not responsible for the message (even though it

had been sent under her name) and blamed other, unnamed JMLS employees for

the dissemination of the "All Cops Are Bastards" ("ACAB") slogan; and,

further stated it "shouldn't have been on the UIC flyer."

30. Further, stated that she advised the unnamed party or parties she claimed

were actually responsible: "I've let them know about it." did not indicate

who she let know about it.

31. On June 8, 2020 I responded to Dean and asked her again to stop sending

me hateful emails that are hurtful to me.

32. Dean did not undertake corrective action in response to my request.

33. On or about June 8, 2020, I filed a formal complaint with JMLS regarding inter aka

Dear; hateful communications regarding "All Cops Are Bastards"

("ACAB") via https:/ /jmls.uic.edu /security/discrimination-form/.

34. Most recently, on or about March 8, 2021, I received email correspondence from

UIC's Director of the Office for Access and Equity wherein he advised me, "OAE

received a copy of your complaint with JMLS on June 29, 2020 from the Dean of

JMLS. . . When analyzing a complaint we look at our University Non-

Discrimination Policy Statement available here. [included a hyperlink]. You did

not state a claim that would be a protected category and this matter was closed

administratively due to lack of jurisdiction on subject matter."

4848-8309-4752, v. 2
35. UIC-JMLS never informed me that my complaints had been "dosed

administratively" or when that determination was made until I received this March

8, 2021 email and after sending many inquiries into the status of my complaints.

-36. UIC-JIMLS' inaction to my complaints is a "denial of access to facilities goods or

services" of a place of public accommodation within the meaning of 775 ILCS

5/5-102.2

37. UIC-JMLS' inaction to my complaints constitutes a failure by a "covered entity ...

to take corrective action to stop the severe or pervasive harassment" within the

meaning of 775 ILCS 5/5-102.2.

38. As such, the Department of Human Rights has jurisdiction over this matter.

III. A. ISSUE/BASIS

On or about June 8, 2020, UIC-JMLS' "operators" harassed and discriminated against me

based on my race, national origin, religion, age and profession, in violation of 775 ILCS 5/5-

102 and 775 ILCS 5/5-102.2. As a direct result of this harassment and discrimination, my

employer charged me with nineteen (19) counts of administrative violations based upon my

role as a police officer; and, my employer rescinded multiple promotional offers.

B. PRIMA FACIE ALLEGATIONS

1. I am a forty-nine-year-old white male of European descent, am married with three

(3) and six (6) .

2. I was an active member of the Unites States Air Force for two (2) years and

received an honorable discharge in and around 1992.

10

4848-8309-4752, v. 2
3. I have been employed by the Chicago Police Department for over twenty-two (22)

years; I have been in a supervisory role for approximately sixteen (16) years; and,

my current rank is Lieutenant.

4. I received a Bachelor's Degree of Arts in Administration of Justice from Southern

Illinois University in and around 1997; and, a Master's Degree of Arts in Public

Safety Administration from Calumet College of St. Joseph in and around 2015.

5. I am currently a part-time law student at UIC-JMLS; I am scheduled to graduate

in and around August 2021. My current GPA is 3.29.

6. UIC-JMLS is a "place of public accommodation" within the meaning of 775 ILCS

5/5-101 because it is a "a non-sectarian ... postgraduate school, or other place of

education" providing postgraduate legal education.

7. Each dean, administrator, professor, and all other faculty and staff of UIC-JMLS

is an "operator" within the meaning of 775 ILCS 5/5-101(B) and also a "public

official" within the meaning of 775 ILCS 5/5-101(C).

8. Deans, Administrators, Professors and staff at JMLS are aware of my race, gender,

national origin, religion, age and profession.

9. On or about June 8, 2020, Dean stated that JMLS would not cease

dissemination of the discriminatory and harassing messages that had been recently

transmitted from administrators (specifically Dean and then Dean

to the entire JMLS student body.

10. Additionally, Dean responded to my email complaints about the

objectively offensive hate-speech sent via email to all JMLS students and offered

me access to counseling services. implied that because I complained about

the objectively offensive content, that I had mental health issues.

11

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11. Dean perceived that I had a disability and informed me that she spoke to

"the Head of the Counseling Department" about pairing me with a counselor

"familiar with law enforcement culture." My complaints had nothing to do with

my job as a police officer, my complaints addressed objectively offensive email

content disseminated to all JMLS students.

12. In response, I advised that I did not require counseling, I simply wanted

JMLS to cease its dissemination of offensive and discriminatory emails to the entire

student body.

13. suggestion that I needed mental health treatment was a thinly-veiled

reference to my age (significantly older than the typical UIC-JMLS student), and

that my age contributed to my distress. suggestions displayed her

perception of me as mentally disabled due to my age, generation, race, national

origin and religion. Additionally, questioned my ability to function in the

environment as enfeebled relative to other students. discriminated against

me based on my age and her actions constituted severe and pervasive harassment.

14. On June 8, 2020 Dean apologized to me for the discrimination and invited

me to file a complaint at https://jmis.uic.edu/security/discrimination-form/.

15. I filed an official complaint with JMLS regarding the discrimination and

harassment I endured.

16. Dean and Dean both failed to address or take any corrective

action to remediate the offensive content and hate speech the university allowed

to be disseminated through its administrators and the university's email system.

17. Dean failed to correct or remediate Dean and

discrimination and told me that I should create a separate folder to accept JMLS

12
4848-8309-4752, v. 2
emails; and, then, from that folder rcould decide which emails I want to open and

what emails I did not want to open without knowing the subject or content

18. Most recently, on or about March 8, 2021, I received email correspondence from

UIC's Director of the Office for Access and Equity wherein he advised me, "OAE

received a copy of your complaint with JMLS on June 29, 2020 from the Dean of

JMLS. . . When analyzing a complaint we look at our University Non-

Discrimination Policy Statement available here. [included a hyperlink]. You did

not state a claim that would be a protected category and this matter was closed

administratively due to lack of jurisdiction on subject matter."

19. UIC-JMLS never informed me that my complaints had been "closed

administratively" or when that determination was made until I received this March

8, 2021 email and after sending many inquiries into the status of my complaints.

20. UIC-JIMLS' non-response to my complaints is a "denial of access to facilities

goods or services" of a place of public accommodation within the meaning of 775

ILCS 5/5-102.2

21. UIC-JMLS' non-response to my complaints is a failure by a "covered entity ... to

take corrective action to stop the severe or pervasive harassment" within the

meaning of 775 ILCS 5/5-102.2.

22. Accordingly, the Department of Human Rights has jurisdiction over this matter.

IV. A. ISSUE /BASIS

On or about June 24, 2020, UIC "operators" discriminated and retaliated against me based on

my race, national origin, religion, age, alleged disability, and profession. These actions were in

direct violation of 775 ILCS 5/5-102; and, denied me access to facilities, goods, or services of

a place of public accommodation within the meaning of 775 ILCS 5/5-102.2. As a direct

13

4848-8309-4752, v. 2
result of this harassment, discrimination, and retaliation, my employer charged me with

nineteen (19) counts of administrative violations based upon my role as a police officer, and,

my employer rescinded multiple promotional offers.

B. PRIMA FACIE ALLEGATION

1. I am a forty-nine-year-old white male of European descent, am married with three

(3) and six (6) .

2. I was an active member of the Unites States Air Force for two (2) years and

received an honorable discharge in and around 1992.

3. I have been employed by the Chicago Police Department for over twenty-two (22)

years; I have been in a supervisory role for approximately sixteen (16) years; and,

my current rank is Lieutenant.

4. I received a Bachelor's Degree of Arts in Administration of Justice from Southern

Illinois University in and around 1997; and, a Master's Degree of Arts in Public

Safety Administration from Calumet College of St. Joseph in and around 2015.

5. I am currently a part-time law student at UIC-JMLS; I am scheduled to graduate

in and around August 2021. My current GPA is 3.29.

6. UIC-JMLS is a "place of public accommodation" within the meaning of 775 ILCS

5/5-101 because it is a "a non-sectarian ... postgraduate school, or other place of

education" providing postgraduate legal education.

7. John Marshall Law School ("JMLS") is a unit of the University of Illinois-Chicago.

Employees of John Marshall Law School are also employees of the University of

Illinois-Chicago.

8. Each dean, administrator, professor, including visiting lecturers, and all other

faculty and staff of UIC-JMIS or UIC is an "operator" within the meaning of 775

14

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ILCS 5/5-101(B) and also a "public official" within the meaning of 775 ILCS 5/5-

limp.
9. Deans, Administrators, Professors and staff at JMLS are aware of my race, gender,

national origin, religion, age and profession.

10. at all times relevant to this charge was employed as a visiting

Lecturer at the University of Illinois-Chicago, the parent institution of John

Marshall Law School.

11. On. or about June 25, 2020, disseminated a 4-page manifesto via email

from the UIC-JMLS National Lawyers Guild Chapter using the UIC-JMLS

university email system and sent to all members of the JMLS student body.

Therein, he demanded the removal of Chicago Police Officers from JMLS and

asserted it as a way to stop white supremacy.

12. exacerbated the offensive climate first established by Dean

May 31, 2020 email sent to the entire JMLS student body; and, perpetuated the

objectively harassing and discriminating environment based on race, national

origin, age, and profession. Further, harbored thinly-veiled hate and

discriminatory animus by calling email "[an] inadequate response to

white supremacy."

13. On or about June 25, 2020, I learned that Mr. was a visiting lecturer in

the Mathematics Department at UIC.

14. On or about June 25, 2020, I captured a screenshot of the discriminatory manifesto

and shared it on my own, private Facebook page under the pseudonym,

15

4848-8309-4752, v. 2
15. On or about June 25, 2020, I complained to Dean and Dean

regarding email and requested that he be restricted from sending me

hateful emails.

16. On or about June 25, 2020, Dean and Dean failed to respond to

my email, or even acknowledge receipt.

17. I emailed Dean and Dean on June 25, 2020 at 08:32am and

received the same as he was included on the same email thread. I put

on notice that I believed his email to be inappropriate and offensive as

communications disseminated through the UIC-JMLS' email communication

system and sent to the entire UIC-JMLS student community.

18. I also sent an email directly to in response to his four-page manifesto

and provided him a direct identification of me.

19. On or about June 25, 2020 at approximately 10:52am., intensified his

misconduct and began to target me constituting severe and pervasive harassment.

20. then deliberately concealed his identity and launched a clandestine

campaign to retaliate against me when he used a fake name under the Twitter

handle

21. hacked into my private Facebook page, stole my content, misconstrued

the meanings and reposted them to other social media platforms to defame me,

discredit my complaints against him, and retaliate against me for communicating

my offense to his hateful speech sent through JMLS' email system.

22. On or about June 25, 2020, claimed responsibility for hacking into my

personal devices and accounts when on Twitter he stated that he hacked into my

16

4848-8309-4752, v. 2
private Facebook page because "[Lt. Cannon] forgot to change the URL of his

troll Facebook account."

23. On or about June 25, 2020, retaliated against me for exercising my

right to file a complaint to UIC-JMLS about his objectively offensive, hateful

and discriminatory communications. shared materials stolen from

my private, Facebook page under a pseudonym with an NBC reporter's Twitter

Page.

24. retaliated against me and subjected me to severe and pervasive

harassment by deliberately distorting the meaning, content and context of the

items he had illegally hacked from my private social media account.

did this all in an effort to defame me and ruin my reputation, simply because I

filed a complaint with UIC-JMLS regarding the inappropriate nature of his

email communications sent through the JMLS email system to all students.

25. As a direct result of severe and pervasive harassment, NBC

Chicago reporter Tia Ewing defamed me by broadcasting materials that

had obtained via hacking and subsequently distorted, on NBC

television News.

26. retaliated against me when he misrepresented the hacked and stolen

materials to Tia Ewing and to the Chicago Police Department ("CPD")

prompting a disciplinary investigation by the Civilian Office of Police

Accountability ("COPA).

27. From on or about June 25, 2020 until on or about August 12, 2020,

continued engaging in severe and pervasive harassment by posting and reposting

expressions stolen from my private Facebook page onto Twitter pages of, but not

17

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limited to, the Mayor of Chicago, Several CPD pages, Local Chicago News, UIC

John Marshall Law School, Civilian Office of Police Accountability ("COPA") and

Black Lives Matter.

28. From on or about June 25, 2020 to on or about June 27, 2020, under

his clandestine and fake Twitter handle continued to discriminate, harass and

retaliate against me by posting false, hateful and discriminatory statements, while

continuing the illusion that he was two separate people.

29. Additionally, continued his campaign of discrimination, retaliation and

harassment against me by posting on Twitter "you can see more of

(XhicAgo Police's Lieutenant John M. Cannon's racism, homophobia,

islamaphobia, transphobia and sexism yourself. I hope @CPDIteform

@CPD Media @ChietDavidl3rown @chicagosmayor take a look. His troll page

is public: https://www.facebook.com/john.m.cannon."

30. On or about June 27, 2020, discriminated, retaliated and harassed me

when he portrayed Police Officers as Nazis by posting a Blue Lives Matter flag

overlaying a Nazi flag.

31. On or about June 30, 2020, continued his discrimination, retaliation

and harassment against me when he called me a racist bigot and posted stolen,

misconstrued expressions to the Twitter page of COPA.

32. On or about July 8, 2020, continued his discrimination, retaliation and

harassment against me when he posted on Twitter, "fiacPalkicam.

@ChiefDavidBrown @chicagosmayor @ChicagoOEMC care to explain why a

racist, homophobic internet troll is the @ChicagoCAPS18 watch commander

if he is supposedly "under investigation?" It takes A LOT of clout to earn that

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4848-8309-4752, v. 2
role in that district.

33. On or about July 8, 2020 continued his discrimination, retaliation and

harassment against me when he Tweeted "PLEASE RETWEET: ANY

PROTESTORS ARRESTED DURING #CHICAGO #BlackLivcsMatter

#GeorgeFloyd PROTESTS BY Chicago Police: Let your attorney know the

@ChicagoCAPS18 Watch Commander Lieutenant John Cannon (whom

probably oversaw your arrest) is a racist, homophobic internet troll...."

34. On or about July 8, 2020 continued his discrimination, retaliation, and

harassment of me when he posted to Alderman Michelle Harris's Twitter

page @AldermanSmith43 my stolen and misconstrued expression and called for

legal action against me as part of my official Job capacity.

35. Between June 25, 2020 and on or after August 12, 2020, continued to

discriminate, retaliate, and harass me; and coerce others to do the same by publicly

posting his misconstrued version of my expressions to various Twitter accounts in

an attempt to destroy my reputation, diminish his own discrimination, and get me

fired from my job.

36. On or about August 12, 2020, Twitter page under the handle

was suspended by Twitter for violations of its rules.

37. On or about January 13, 2021, CPD's COPA served me with 19 allegations of

making statements on social media that were biased or disrespectful as a result of

retaliatory actions and severe and pervasive harassment directed at

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4848-8309-4752, v. 2
me. The COPA allegations that I exhibited bias or disrespect are false and without

merit.

38. The COPA allegations stem from hacking, theft, misappropriation,

and deliberate distortion of certain items from a social media account. His efforts

are direct retaliation for my protected activity of formally complaining to JMLS

about the objectively hateful, discriminatory and harassing communication that

disseminated to the entire JMLS student body through the university's

email system.

39. discriminated, retaliated, and harassed me by confecting false

accusations against me in order to induce the CPD and COPA to conduct

investigations and pursue discipline of me.

40. Such discrimination is ongoing and violates, inter aa, the Illinois Human Rights

Act, Illinois Whistleblower Act and other federal and state statutes.

41. As of the date of this filing and upon information and belief, received

no correction action for his discrimination and severe harassment directed at me.

42. UIC-JIMLS' non-response to my complaint is a "denial of access to facilities goods

or services" of a place of public accommodation within the meaning of 775 ILCS

5/5-102.2

43. UIC-JMLS' non-response to my complaint constitutes a failure by a "covered

entity ... to take corrective action to stop the severe or pervasive harassment"

within the meaning of 775 ILCS 5/5-102.2.

44. As such, the Department of Human Rights has jurisdiction over this matter.

20

4848-8309-4752, v. 2
V. A. ISSUE/BASIS

UIC-JMLS "operators" directly circulated communications via the UIC-JMLS email system

that denied my access to JMLS, a place of public accommodation; and, they did so by making

me feel unwelcome based on their unlawful discriminatory comments and communications

sent via the JMLS email platform and social media. These violations are in contravention of

775 ILCS 5/5-102 and 775 ILCS 5/5-102.2. As a direct result of this harassment,

discrimination, and retaliation, my employer charged me with nineteen (19) counts of

administrative violations based upon my role as a police officer; and, my employer rescinded

multiple promotional offers. Additionally, UIC-JMLS' operators' actions caused me severe

emotional distress.

B. PRIMA FACIE ALLEGATIONS

1. Complainant incorporates and realleges all facts alleged above in Sections I

through IV as if fully set forth herein.

2. 775 ILCS 5/5-102 prohibits any person, on the basis of unlawful

discrimination from

"Directly or indirectly, as the operator of a place of public

accommodation, publish, circulate, display or mail any written

communication, except a private communication sent in response to a

specific inquiry, which the operator knows is to the effect that any of

the facilities of the place of public accommodation will be denied to

any person or that any person is unwelcome, objectionable or

unacceptable because of unlawful discrimination."

3. Dean email communications clearly violated the provisions of 775

ILCS 5/5-102.

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4848-8309-4752, v. 2
4. Dean email communications constituted severe and pervasive

harassment in contravention of the provisions of 775 ILCS 5/5-102.

5. In response to my official complaint filed with JMLS, Dean suggestion

that I needed counseling and suffered from mental illness perpetuated the

severe and pervasive harassment in violation of the provisions of 775 ILCS

5/5-102.

6. UIC-JMLS violated my civil rights by its failure to take action, investigate, or

respond to my formal complaints of discrimination filed per Dean

advisement. Dean communications included categorical,

discriminatory assertions denigrating all persons of Caucasian or "white" race

or national origin attributing to all persons of such background certain negative

characteristics.

7. UIC-JIMLS' non-response to my complaint is a "denial of access to facilities

goods or services" of a place of public accommodation within the meaning of

775 ILCS 5/5-102.2.

8. UIC-JMLS' non-response to my complaints constitutes a failure by a "covered

entity ... to take corrective action to stop the severe or pervasive harassment"

within the meaning of 775 ILCS 5/5-102.2.

9. As such, the Department of Human Rights has jurisdiction over this matter.

VI. A. ISSUE /BASIS

Deans, professors and other staff at JMLS aided, abetted, and coerced others to discriminate,

retaliate, deny accommodations, harass, defame and force adverse employment actions against

me; collectively, these actions occurred due to my race, national origin, age, religion and

profession constituted "severe and pervasive harassment." UIC-JMLS, a "covered entity

22

4848-8309-4752, v. 2
failed to take corrective action." Moreover, these actions, inactions, failures and

communications were a "denial of access to facilities, goods, or services" of a place of public

accommodation within the meaning of 775 ILCS 5/5-102.2.

B. PRIMA FACIE ALLEGATIONS

1. Complainant incorporates and realleges all facts alleged above in Sections I

through V as if fully set forth herein.

2. In and around May 2020, Dean began a campaign of discrimination and

harassment directed at me, causing me to file official complaints with UIC-JMLS.

3. In and around June 2020, Dean continued the discrimination and

harassment against me, causing me to file official complaints with UIC-JMLS.

4. In and around June 2020, Dean continued the discrimination and harassment

against me, causing me to file official complaints with UIC-JMLS.

5. Starting in and around June 2020, Professor continued the

discrimination and harassment against me.

6. Additionally, Professor continued his discrimination, retaliation,

harassment, and defamation against me when he misrepresented information

about me to media reporters, to City of Chicago officials (both elected and

unelected), CPD officials, and COPA to further his unlawful violations against me.

7. Such aiding, abetting and coercion is ongoing and violates the Illinois Human

Rights Act, Illinois Whistleblower Act and federal law.

8. UIC-JIMLS and its staffs' actions of aiding and abetting discrimination are a

"denial of access to facilities goods or services" of a place of public

accommodation within the meaning of 775 ILCS 5/5-102.2

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9. UIC-JMLS and its staffs' actions of aiding and abetting discrimination are a failure

by a "covered entity ... to take corrective action to stop the severe or pervasive

harassment" within the meaning of 775 ILCS 5/5-102.2.

10. As such, the Department of Human Rights has jurisdiction over this matter.

VII. A. ISSUE/BASIS

UIC-JMLS perpetuated severe and pervasive harassment directed towards me when it failed

to address any of my multiple complaints that I filed per Dean direction. Additionally,

UIC-JMIS' repeated denials to cease the dissemination of hateful, biased, discriminatory,

harassing communications is a failure to take corrective action. These actions, inactions,

failures and communications were a "denial of access to facilities, goods, or services" of a

place of public accommodation within the meaning of 775 ILCS 5/5-102.2.

B. PRIMA FACIE ALLEGIATIONS

1. Complainant incorporates and realleges all facts alleged above in Sections I

through VI as if fully set forth herein.

2. On or about June 2, 2020, I responded to Dean discriminatory and

objectively offensive email communications sent through the UIC-JMLS email

system and asked her to stop sending me discriminatory emails through my JMLS

email; she denied me the accommodation.

3. On or about June 4, 2020, I sent an email to Dean and asked that she stop

sending me objectively offensive and discriminatory emails through the JMLS

email system because I could not believe that administrators of a public university

would send such insulting material; she denied the accommodation.

4. Dean denied my request for an accommodation when she told me to ignore

the discriminatory emails.

24

4848-8309-4752, v. 2
5. Dean denied my requested accommodation and instead told me that Dean

informed her that I was a police officer; Dean then suggested

that I take an incomplete or withdraw from classes at JMLS.

6. On or about June 6, 2020 Dean denied my requested accommodation after

I asked her to stop sending me hateful emails.

7. On or about June 6, 2020, Dean affirmed her denial of my requested

accommodation when I begged her to stop sending me hurtful and discriminatory

messages.

8. On or about June 8, 2020, Dean denied my requested accommodation when

I asked her again to stop sending me hateful emails that are hurtful to me.

9. On or about June 8, 2020, Dean denied my requested accommodation and

deferred my complaints to Dean regarding the UIC-JMLS' administrator?

discrimination.

10. On or about June 8, 2020, Dean denied my requested accommodation when

she reasserted that JMLS would not stop sending objectively offensive and

discriminatory emails to the entire JMLS student body.

11. Dean denied my requested accommodation when she told me that if I did

not want to receive offensive and discriminatory emails, I should manually create

a separate folder to accept emails. From that folder I would have to decide what

emails I wanted to open and what emails I did not want to open, without knowing

the email's content

12. On or about June 8, 2020 Dean denied my requested accommodation to

stop sending offensive and discriminatory emails through the JMLS email system

to the entire student body, when advised me to just file a complaint

25

4848-8309-4752, v. 2
13. UIC-JMLS violated my civil rights by its failure to take action, investigate, or

respond to my formal complaints of discrimination filed per Dean

advisement. Dean communications included categorical,

discriminatory assertions denigrating all persons of Caucasian or "white" race or

national origin attributing to all persons of such background certain negative

characteristics.

14. UIC-JIMLS' inaction to my complaints is a "denial of access to facilities goods or

services" of a place of public accommodation within the meaning of 775 ILCS

5/5-102.2

15. UIC-JMLS' inaction to my complaints constitutes a failure by a "covered entity ...

to take corrective action to stop the severe or pervasive harassment" within the

meaning of 775 ILCS 5/5-102.2.

16. As such, the Department of Human Rights has jurisdiction over this matter.

VIII. A. ISSUE/BASIS

UIC-JMLS retaliated against me for filing complaints for the unlawful discrimination

perpetuated by JMLS' administration and its use of the university's email system in doing so.

The complaints I filed reporting the unlawful discrimination constitutes protected activity. As

a result of filing complaints, UIC-JMLS administrators created a severe and pervasive

harassing environment interfering with my access to an education and to a place of public

accommodation, JMLS. As a direct result of this harassment, discrimination, and retaliation,

my employer charged me with nineteen (19) counts of administrative violations based upon

my role as a police officer, and, my employer rescinded multiple promotional offers.

Additionally, UIC-JMLS' operators' actions caused me severe emotional distress.

B. PRIMA FACIE ALLEGATIONS

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4848-8309-4752, v. 2
1. I am a forty-nine-year-old white male of European descent, am married with three

(3) and six (6)

2. I was an active member of the Unites States Air Force for two (2) years and

received an honorable discharge in and around 1992.

3. I have been employed by the Chicago Police Department for over twenty-two (22)

years; I have been in a supervisory role for approximately sixteen (16) years; and,

my current rank is Lieutenant.

4. I received a Bachelor's Degree of Arts in Administration of Justice from Southern

Illinois University in and around 1997; and, a Master's Degree of Arts in Public

Safety Administration from Calumet College in St Joseph in and around 2015.

5. I am currently a part-time law student at UIC-JMLS; I am scheduled to graduate

in and around August 2021. My current GPA is 3.29.

6. I am protected within the meaning of the Illinois Human Rights Act and the

Illinois Whistle Blower Act. I have been discriminated against and filed a complaint

about the discrimination

7. When I complained to UIC-JMLS' administrators regarding the objectively

offensive and discriminatory content disseminated through the university's email

system, a protected activity, JMLS retaliated against me.

8. JMLS' retaliation included but is not limited to, severe or pervasive harassment by

Professor that JMLS failed to take corrective action to stop.

9. JMLS' retaliation included the denial of my multiple requests to stop disseminating

offensive and discriminatory content through the JMLS email system to the entire

student body.

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4848-8309-4752, v. 2
10. JMLS advised me to withdraw from my classes after I filed my complaints; thus,

JMLS denied me access to enrollment, facilities, goods, or services.

11. On or about August 30, 2020 the CPD and COPA retaliated against me when I

was offered the Position of Commanding Officer of the Alternate Response Unit

of the CPD, but on or about September 18, 2020 CPD informed me that CPD

rescinded the offer.

12. On or about October 12, 2020 the CPD and COPA retaliated against me when I

was recommended for appointment to the Illinois Gaming Board ("IGB"), but the

appointment was never made.

13. On or about January 13, 2021 the CPD and COPA retaliated against me when I

was served with 19 allegations subject to investigation and discipline; up-to-and-

including being fired from my career and honorable 23-years of service to the

Citizens of Chicago.

14. CPD and COPA retaliated against me when it seeks unlawful enforcement of a

vague and ambiguous policy that removes my ability to prospectively exercise my

First Amendment Privilege.

15. CPD and COPA retaliated against me when it seeks unlawful enforcement of a

vague and ambiguous policy that has a disparate impact on me as a white male

because of the inequitable manner in which the policy has been enforced.

16. Such retaliation would not have occurred but for the illegal discrimination,

retaliation and harassment of UIC-JMLS' administration; and, the dereliction in

the efficacy of investigations undertaken by the CPD and COPA to uncover the

retaliation of UIC JMLS.

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17. On or about February 11, 2021 the CPD and COPA retaliated against me when I

was offered the job of Commanding Officer of the Narcotics Unit, but on or about

March 1, 2021 CPD informed me that CPD rescinded the offer.

18. Such retaliation is ongoing and violates the Illinois Human Rights Act, Illinois

Whistleblower Act and federal law.

CONCLUSION

UIC-JMLS is a covered entity and a place of public accommodation and is a public institution

under the Illinois Constitution and Illinois Statutes. Its dissemination of discriminatory content

through its email communications system to the entire student body is a clear violation of 775 ILCS

5/5-102, et seq. As a direct result of UIC-JMLS' actions, I have been damaged. I lost multiple

promotional opportunities; but, also, I, along with my family, have suffered severe emotional distress

due to UIC-JMLS' actions and failure to correct its operators' discriminatory and illegal actions.

JOHN M. CANNON
Complainant.

Subscribed and sworn to me

this day of March, 2021.

NOTARY PUBLIC-P

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4848-8309-4752, v. 2
Lt. John Cannon Log #2020-2942

1 CIVILIAN OFFICE OF POLICE ACCOUNTABILITY


Log # 2020-2942
2

8 STATEMENT OF LIEUTENANT JOHN CANNON


9 CONDUCTED BY INVESTIGATOR EMILY PIERCE
10 AND INVESTIGATOR GREG MASTERS
11 on 16 March 2021 at 12:38 p.m.
12 at the offices of the
13 Civilian Office of Police Accountability
14

15

16

17

18

19

20

21

22

23

24

Bridges Court Reporting Page: 1


Lt. John Cannon Log #2020-2942

1 EXAMINATION
2 INVESTIGATOR PIERCE: Okay. The following is
3 the digitally-recorded statement of the accused
4 Lieutenant John M. Cannon, Star number 412, assigned to
5 the 18th District. This is relative to an incident
6 with multiple dates of occurrence. This is recorded
7 under log number 2020-2942.
8 This statement is being conducted by COPA
9 Major Case Specialist Emily Pierce, badge number 40, at
10 COPA on March 16, 2021. We're beginning at
11 approximately 12:38 p.m. I'm accompanied by Major Case
12 Specialist Masters.
13 You want to introduce yourself?
14 INVESTIGATOR MASTERS: It's Greg Masters.
15 G-R-E-G. M-A-S-T-E-R-S. COPA badge number 71.
16 INVESTIGATOR PIERCE: Okay. This digital
17 recording device is very sensitive. It will pick up
18 any whispered conversations that occur within its
19 proximity.
20 So if you would like to take a break at any
21 time, just raise your hand. I'll pause the recording
22 and we'll take a break.
23 LIEUTENANT CANNON: Okay.
24 MS. Investigator Masters, real quick.

Bridges Court Reporting Page: 2


Lt. John Cannon Log #2020-2942

1 INVESTIGATOR PIERCE: Yeah.


2 MS. I wanted to wait until we were on
3 the record. Do we have the sworn affidavit?
4 INVESTIGATOR PIERCE: Yes, I have it. I can
5 get it for you. Would you mind if I wait? Or you want
6 me to get it right now?
7 MS. Well, I mean, before we get into
8 any substantive questioning, but I wanted to make the
9 request on the record.
10 INVESTIGATOR PIERCE: Here, I can show you
11 the electronic copy.
12 MS. Okay. That's fine.
13 INVESTIGATOR PIERCE: Okay. Let's see how
14 good -- my good 'ol memory is here. Yeah, I'm going to
15 go have to go to my desk. Sorry.
16 MS. Oh. Sorry.
17 INVESTIGATOR PIERCE: Okay. We're going to
18 pause the recording at 12:40 p.m. with Lieutenant
19 Cannon, Star number 412.
20 (A break was taken.)
21 INVESTIGATOR PIERCE: Okay. We're back on
22 the record with Lieutenant Cannon, Star number 412. It
23 is 12:43 p.m. on March 16, 2021.
24 We did not discuss this case while we were

Bridges Court Reporting Page: 3


Lt. John Cannon Log #2020-2942

1 paused on the recording, correct?


2 MS. So I -- no, we did not.
3 INVESTIGATOR PIERCE: Okay. Thank you.
4 MS. So I have some questions.
5 INVESTIGATOR PIERCE: Sure.
6 MS. There are no -- you're showing me
7 an affidavit from [phonetic] but there
8 are no cases. Or there are no allegations based on
9 his?
10 INVESTIGATOR PIERCE: I'm sorry?
11 MS. You --
12 INVESTIGATOR PIERCE: Oh, this -- these
13 are -- these allegations were Angela Hearts-Glass. The
14 deputy chief is the name on here. And that was -- we
15 hadn't -- didn't have the signed affidavit at the time
16 because of COVID. So we had to go and get the
17 affidavits later. So it's -- it's just a -- it's
18 something that I planned to or wasn't going to change
19 but can change at any time.
20 So he -- he is the complainant. He did us a
21 statement and signed the affidavit after giving the
22 statement because we weren't in person getting
23 paperwork signed.
24 MS. Okay.

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1 INVESTIGATOR PIERCE: Similar to the last


2 case that we -- I think that -- I'm sorry. I may be
3 confusing you --
4 MS. Yeah.
5 INVESTIGATOR PIERCE: -- with somebody else.
6 But the deputy chief went ahead and signed
7 off on these allegations prior to us having the paper
8 affidavit signed in hand.
9 MS. Okay. So then did the deputy
10 chief obtain an affidavit override?
11 INVESTIGATOR PIERCE: I'm honestly not sure
12 because we had the complainant on record agreeing to
13 sign the affidavit. We just hadn't personally met him
14 to get it signed. Does that make sense?
15 MS. I -- no, I totally -- it makes
16 sense.
17 INVESTIGATOR PIERCE: So at this point, what
18 I can do ask I can take these allegation forms, I can
19 put name on here and then I can
20 re-serve them to Lieutenant Cannon. We have a signed
21 affidavit.
22 MS. I get that. So I'm just going
23 to -- I'm going make an objection --
24 INVESTIGATOR PIERCE: Sure.

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1 MS. -- that you served Lieutenant


2 Cannon initially in -- the end of 2020.
3 So I want to be sure. Are you telling me
4 that there is no affidavit override obtained by Deputy
5 Chief Hearts-Glass?
6 INVESTIGATOR PIERCE: There is no affidavit
7 override.
8 MS. Okay.
9 INVESTIGATOR PIERCE: The complaint came in
10 the summer.
11 MS. Okay. So you served my client
12 with allegations without a signed affidavit as required
13 by the contract or in the absence of a signed
14 affidavit, by an affidavit override.
15 INVESTIGATOR PIERCE: That was what I -- the
16 instructions were for COVID.
17 So we have -- we obtained the verbal
18 authorization.
19 MS. I -- I -- I'm just getting it on
20 the record.
21 INVESTIGATOR PIERCE: No, I --
22 MS. So I understand what you're --
23 INVESTIGATOR PIERCE: No problem at all.
24 MS. I get it. But I'm just saying,

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1 you can have COVID-related. I'm just saying that we


2 have a contract that Lieutenant Cannon is working
3 under --
4 INVESTIGATOR PIERCE: Yeah.
5 MS. -- which requires one of those two
6 things.
7 INVESTIGATOR PIERCE: Sure.
8 MS. So we're on the record. No
9 affidavit override? No signed affidavit at the time
10 you initially served him with allegations?
11 INVESTIGATOR PIERCE: Without looking at my
12 case notes, like, I really -- I'm not sure if this was
13 an oversight in terms of the paperwork on my end.
14 Because the complainant signed the affidavit on --
15 MS. The 28th of October.
16 INVESTIGATOR PIERCE: 28th of October, right.
17 MS. Yeah, I see.
18 INVESTIGATOR PIERCE: Exactly.
19 So I -- without knowing the -- I don't have
20 the original date that I served because we served so
21 many different packets.
22 MS. Okay.
23 INVESTIGATOR PIERCE: So I had a affidavit
24 signed by the complainant, just for the record, on

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1 October the 28th of 2020. It is possible that this was


2 paperwork went out on this form as an error made by me
3 when there was actually an -- in fact, an affidavit
4 signed by the complainant.
5 So with -- when I'm looking here at this
6 packet with the date January 19, 2021 as our first
7 interview date, that indicates to me that around
8 January was when I served you with these papers which
9 would mean that we had the affidavit in place but I put
10 this on the wrong form.
11 Does that make sense?
12 MS. It -- yeah.
13 INVESTIGATOR PIERCE: So I --
14 MS. I understand --
15 INVESTIGATOR PIERCE: -- made a mistake in
16 the form and I am -- I am more than happy to -- it's a
17 very quick change for me to switch over to the COPA
18 allegations form and put the
19 complainant's name on there. No problem.
20 And I -- also, I apologize.
21 MS. Okay. Can we take a break real
22 quick?
23 INVESTIGATOR PIERCE: I'm going to pause the
24 recording at 12:47.

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Lt. John Cannon Log #2020-2942

1 (A break was taken.)


2 INVESTIGATOR PIERCE: Okay. We're now on the
3 record with Lieutenant Cannon. It's 12:52.
4 We did not discuss this case, correct?
5 MS. Correct.
6 INVESTIGATOR PIERCE: Okay.
7 MS. So we -- we would like you to
8 change the paperwork. We don't have to do it until
9 after --
10 INVESTIGATOR PIERCE: No problem.
11 MS. -- the statement.
12 INVESTIGATOR PIERCE: Sure. I understand.
13 MS. And then we will waive the
14 72 hours because you won't be -- won't have served the
15 paperwork with the correct information on that.
16 INVESTIGATOR PIERCE: Whatever you guys want.
17 LIEUTENANT CANNON: I understand that I get
18 the 72 hours, but I also understand that -- that this
19 statement is moving forward. So I -- I'll waive the
20 72 hours --
21 INVESTIGATOR PIERCE: Sure.
22 LIEUTENANT CANNON: -- provided that you
23 understand that I would like to have a copy with all
24 the proper complainants on there.

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1 Do I get a copy of the sworn affidavit?


2 INVESTIGATOR PIERCE: That, I'm not sure. Is
3 that --
4 LIEUTENANT CANNON: I think I do.
5 INVESTIGATOR PIERCE: I think --
6 INVESTIGATOR MASTERS: We generally don't,
7 no.
8 LIEUTENANT CANNON: Can I have a copy of the
9 sworn affidavit?
10 INVESTIGATOR PIERCE: As long as my
11 supervisor gives the green light, I have no problem
12 with that.
13 MS. Okay.
14 INVESTIGATOR MASTERS: Yeah, our general
15 policy is not to give out anything other than the
16 paperwork that you --
17 INVESTIGATOR PIERCE: We'll ask my -- my
18 supervisor's pretty flexible, so as long as that's
19 cool, I have no problems with that whatsoever and also
20 have no problem getting you the correct paperwork.
21 MS. Okay. So we'll agree -- but we --
22 we'll be doing it off the record at the end of the
23 statement so we --
24 INVESTIGATOR PIERCE: Sure.

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1 MS. -- don't have to --


2 INVESTIGATOR PIERCE: Sure. If he --
3 MS. -- belabor this point anymore.
4 INVESTIGATOR PIERCE: You got it. No -- I
5 have plenty of time.
6 If you want to, we can go on the record at
7 the end and say, hey, the paperwork is -- is settled
8 and -- and everybody's got what they need.
9 MS. I trust you, Emily, that you --
10 INVESTIGATOR PIERCE: Okay.
11 MS. -- will redo it. That's fine.
12 INVESTIGATOR PIERCE: I just -- to have the
13 record have everything showing. You know what I mean?
14 MS. Okay.
15 INVESTIGATOR PIERCE: I have no problem with
16 that whatsoever.
17 BY INVESTIGATOR PIERCE:
18 Q. Okay. So I had just mentioned that the digital
19 recording device is very sensitive. If you want to
20 take a break, just raise your hand. I will gladly
21 pause the recording.
22 Lieutenant Cannon, could you please state your
23 name, spelling your first and last name, Star number,
24 and unit of assignment?

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Lt. John Cannon Log #2020-2942

1 A. My name is John Cannon. My Star is 412. And


2 I'm assigned to the 18th District.
3 And now that we're started, I'd like to read a
4 statement into the record.
5 Q. Okay. Go ahead.
6 A. In the spring and summer of 2020, I was the
7 victim of illegal discrimination at a place of public
8 accommodation by those in high positions at UIC John
9 Marshall Law School. This was done deliberately to
10 discredit the complaints made by me against them at UIC
11 John Marshall Law School for the illegal
12 discrimination. Those complaints were made to UIC and
13 also now to the Illinois Department of Human Rights and
14 the EEOC.
15 Because I believe this query is in furtherance
16 of other illegal actions, I believe it is also an
17 illegal investigation I have been ordered to
18 participate in. And I will do so.
19 Because of those foregoing assertions, I want
20 to object to the proceedings here today.
21 And I would also like to supply for the record
22 a copy of the addendum complaint that I have made to
23 the Illinois Department of Human Rights and EEOC.
24 I don't know if there's formality we have to go

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Lt. John Cannon Log #2020-2942

1 through for me to submit --


2 INVESTIGATOR MASTERS: Tell us what you're
3 giving us.
4 INVESTIGATOR PIERCE: Yeah, at this point, I
5 just -- help me understand a little bit more.
6 MS. So Lieutenant Cannon, what he just
7 said is he has filed a formal complaint.
8 INVESTIGATOR PIERCE: Okay.
9 MS. He thinks it is relative to the
10 investigation that you are conducting.
11 INVESTIGATOR PIERCE: Okay.
12 MS. So as such, we are tendering it to
13 you. And I am going to mark it as Cannon Exhibit 1.
14 INVESTIGATOR PIERCE: You got it.
15 MS. So this is --
16 BY INVESTIGATOR PIERCE:
17 Q. So this is a complaint you filed regarding what
18 exactly?
19 A. Unlawful discrimination.
20 Q. Okay. And you mentioned UIC John Marshall Law
21 School?
22 A. I go to school there.
23 Q. So they -- you feel that they illegally
24 discriminated against you and that our complaint is

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1 somehow affiliated with UIC John Marshall?


2 A. I do feel that.
3 Q. Okay. Okay. Just wanted to make sure.
4 MS. I'm just going to -- so I've just
5 marked this Cannon Exhibit 1. I've dated it.
6 Lieutenant Cannon will initial it and then we will
7 tender it to you.
8 LIEUTENANT CANNON: Each page? Or just
9 page 1?
10 MS. We're just doing page 1.
11 INVESTIGATOR PIERCE: Sure.
12 And then I'm just going to upload this and
13 include this in the file. No problem.
14 MS. Thank you.
15 INVESTIGATOR PIERCE: Okay.
16 BY INVESTIGATOR PIERCE:
17 Q. So you are a student at UIC John Marshall Law
18 School?
19 A. I am.
20 Q. Okay. How long you been there?
21 A. Just under five years.
22 Q. Okay. Cool.
23 So back to this little preamble here, you
24 stated your name, spelling your first and last, Star

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1 number, and unit of assignment.


2 What is your year of birth and current age?
3 A. I was born in 1971. I'm 49 years old.
4 Q. Okay. And your date of --
5 A. Let me just --
6 MS. He -- she'll point to you --
7 Q. Yeah.
8 A. Okay.
9 Q. I know what --
10 A. I just want sure if I boilerplate this or not.
11 Q. You're a couple questions away from there.
12 And your date of appointment to Chicago Police
13 Department?
14 A. 13 April 1998.
15 Q. Okay. And how long have you been assigned to
16 your present unit?
17 A. Two years, give or take.
18 Q. So prior to 18, where were you?
19 A. 30 (unintelligible) Violent Crimes.
20 Q. Okay. About how long were you there?
21 A. Maybe a year or so. I was there as a sergeant.
22 Q. Sure. And are you aware that you are an
23 accused at this time?
24 A. I am.

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1 Q. Okay. Prior to today -- I know that you saw


2 the paperwork. We've discussed on the record the
3 complainant name is incorrect here and we're going to
4 fix that paperwork to reflect the complainant from the
5 affidavit after this statement.
6 I just want to make sure that your signature is
7 on these documents, but since we're moving that to the
8 end, I'm going to go ahead and put us on the record
9 again at the end with the documents just to cover this
10 portion of the preamble.
11 Lieutenant Cannon, are you aware that this
12 statement has the standing of an official departmental
13 report and any intentional falsification of any answer
14 to any question would be in direct violation of
15 department rules and regulations?
16 A. I do.
17 Q. Given that, I would like to remind you that
18 failure to provide a complete and accurate statement
19 could result in a finding of a violation of Rule 14
20 which could result in disciplinary action up to and
21 including separation from CPD.
22 Do you also understand that?
23 A. Yes.
24 Q. And are you represented by counsel of your

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Lt. John Cannon Log #2020-2942

1 choosing today?
2 A. Yes.
3 INVESTIGATOR PIERCE: Counsel, would you
4 introduce yourself?
5 MS. Good afternoon. My name is
6

7 MR. And good afternoon. My name is


8 and I'm an attorney representing Mr. Cannon
9 for the IDHR complaint and subsequent civil matters.
10 INVESTIGATOR PIERCE: Okay. For the record,
11 that's everybody in the room has introduced themselves.
12 There's no one else in this room.
13 BY INVESTIGATOR PIERCE:
14 Q. Lieutenant Cannon, prior to this statement, I
15 provided counsel with images that the allegations were
16 drawn me. I know that you've had time to review those.
17 Have you also had time to look over any
18 departmental reports or anything you've completed
19 relative to this incident?
20 It looks like nothing departmental, but some
21 civil things.
22 A. (No verbal response.)
23 Q. Are you prepared to give a statement in
24 conjunction with this investigation?

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Lt. John Cannon Log #2020-2942

1 MS. Yeah.
2 LIEUTENANT CANNON: Now?
3 MS. Yes.
4 A. Okay. On March 16, 2021 at whatever time it is
5 now at the Civilian Office of Police Accountability, I
6 am being required to give this statement based on
7 complaint register 2020-2942. It is my belief that
8 this statement will not be released in any subsequent
9 proceeding other than formal disciplinary proceedings
10 within the confines of the Chicago Police Department
11 itself.
12 I understand department policy requires me to
13 give this statement, and if I fail to comply, I can be
14 disciplined and/or lose my job. Therefore, I am giving
15 this statement today under duress.
16 This statement I am giving at this time is
17 based on the best recollection I have of the
18 circumstances surrounding the allegation under
19 2020-2942. Although the complaint was initiated in
20 2020, the oldest allegation is from 33 months ago.
21 Expecting me to remember specifics from an incident in
22 July 2018 is unreasonable.
23 While there may or may not be additional
24 information including, but not limited to, audio,

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Lt. John Cannon Log #2020-2942

1 video, written reports, or any other statement made in


2 connection with this incident that can either
3 corroborate or contradict the current statement I am
4 making, my statement is true as I recall it to be at
5 this time.
6 Finally, I object to COPA's investigation in
7 this matter. The subject matter of the allegations do
8 not fall within the powers and duties of the office and
9 chief administrator according to Chapter 7-2-78-120
10 [sic] of the Chicago Municipal Code. As such, COPA
11 does not have jurisdiction to conduct -- to conduct
12 this investigation.
13 INVESTIGATOR PIERCE: Okay. Give me one
14 second to just get caught up here. Okay. I'm just
15 reading about this -- this is?
16 INVESTIGATOR MASTERS: Exhibit 1?
17 INVESTIGATOR PIERCE: Yeah, Exhibit 1 for
18 Cannon.
19 BY INVESTIGATOR PIERCE:
20 Q. Looks like page 15 of Cannon Exhibit 1, which
21 was shared here with counsel today, point number 14, it
22 says, "On or about June 25, 2020, I captured a
23 screenshot of the discriminatory manifesto and shared
24 it on my own private Facebook page under the student

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Lt. John Cannon Log #2020-2942

1 named Samuel Hipster."


2 Student named Samuel Hipster Facebook page is
3 yours as per this, right?
4 A. Yes.
5 Q. Okay. So -- okay.
6 Regarding allegation 1: It is alleged that on
7 or about June 25, 2020, Lieutenant John Cannon made a
8 statement on Facebook that was disrespectful to CPD and
9 that he posted an image of a man in a "Blue Lives
10 Matter" hat holding multiple boots in his arms with the
11 text, "How do I lick all these boots?"
12 This was a screenshot from that.
13 What is your response to that allegation?
14 A. The Facebook page was registered in the name
15 Sam Hipster, not Lieutenant John Cannon so I would have
16 to deny that aspect of the allegation. This was done
17 to disassociate myself from the Chicago Police
18 Department and maintain anonymity.
19 This particular post does not look familiar to
20 me. I do not recall seeing it previous to this matter.
21 I just don't recall that post.
22 Q. Okay. But you did say that Samuel Hipster was
23 your own private Facebook?
24 A. We've already covered that.

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Lt. John Cannon Log #2020-2942

1 Q. Okay. And then -- so you said regarding this


2 post, you don't recall this post?
3 A. No.
4 Q. Okay.
5 A. And there's nothing to indicate that this came
6 from any post that I'm associated with on this exhibit.
7 Q. Okay. Regarding allegation 2: On or about
8 June 25, 2020, Lieutenant John Cannon reposted a
9 statement on Facebook that was biased against African
10 Americans and Muslims in that it depictured -- it
11 depicted a picture of President Obama wearing a turban
12 with the text, "Obama is ISIS."
13 Here's a screenshot from the page.
14 How do you stand on that allegation?
15 A. The Facebook page was registered in the name
16 Sam Hipster, not John Cannon. I'll have to deny that
17 aspect of the allegation. I covered that. This was
18 done to disassociate myself from the Chicago Police
19 Department.
20 The post is not objectively offensive and not
21 biased against African Americans or Muslims. It does
22 not make any reference to African Americans or Muslims.
23 Instead, the allegation implies that a subjective
24 analysis was used based on a misconstrued meaning to

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Lt. John Cannon Log #2020-2942

1 craft the allegation.


2 The caricature does look like elected
3 president -- former President Obama. An expression
4 regarding a former president is an expression made
5 regarding matters of public importance and public
6 concern.
7 Moreover, ISIS -- the ISIS reference is also an
8 expression made regarding a matter of public importance
9 and public concern because it is undeniable that ISIS
10 was a recognized terrorist organization that was highly
11 antithetical to this country.
12 As such -- and excluding the allegations that
13 are not at all referenced in the -- in the exhibit, I
14 deny the allegations.
15 Q. Okay. It is alleged that on or about June 25,
16 2020, Lieutenant John Cannon posted a statement on
17 Facebook that was biased against African Americans in
18 that it responded to an academic paper in support of
19 "Black Lives Matter" movement stating, "The
20 factionalized element in charge of higher education is
21 dangerous to the sovereign. Truly an enemy of the
22 state."
23 Here's a screenshot.
24 I know we discussed this -- this text which is

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1 illegible here. There was some back and forth between


2 you and my supervisor. This is apparently a -- could
3 have been an e-mail. I'm not actually sure.
4 But it is, I guess, UIC John Marshall Law
5 School's position on "Black Lives Matter" protests,
6 something to that effect, in this area here. I just
7 want to put that on the record.
8 A. Is that your definition of "academic paper"?
9 Q. I'm sorry?
10 A. Is your description of that a definition of an
11 "academic paper"?
12 Q. It's from -- it's some kind of paper from an
13 academic institution so I don't know. I don't have a
14 specific description of that. Just adding to the
15 record what's in there.
16 A. Okay.
17 MS. Can I see that exhibit real quick?
18 INVESTIGATOR PIERCE: Sure.
19 MS. Can I ask you: Is this how you --
20 is this how you're able to read the exhibit or is this
21 how the printout appears?
22 INVESTIGATOR PIERCE: The printout here is
23 illegible which is why I wanted to refer to it on the
24 record, but between you and , the text became

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1 clearer as it was drawn from Twitter.


2 MS. So I just say -- I'm asking: Were
3 you able to read every bit -- every word that is on
4 this exhibit -- whatever the exhibit number is -- like,
5 on your computer? I just want to --
6 INVESTIGATOR PIERCE: I -- I was able to
7 electronically read from the Twitter. These -- these
8 screenshots that were prepared for you were to protect
9 the other people. So I zoomed in.
10 MS. No. No. That's fine. All I'm
11 you asking is are you --
12 INVESTIGATOR PIERCE: Yes.
13 MS. -- you were able to read every --
14 INVESTIGATOR PIERCE: Correct.
15 MS. -- word --
16 INVESTIGATOR PIERCE: Correct.
17 MS. -- on this? Okay.
18 INVESTIGATOR PIERCE: So I had -- I had the
19 electronic version --
20 MS. Okay.
21 INVESTIGATOR PIERCE: -- to --
22 MS. (Unintelligible).
23 INVESTIGATOR PIERCE: -- to -- sure.
24 MS. Okay. I just want it to be on the

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1 record that I while I understand we cannot -- it's


2 illegible, all that stuff --
3 INVESTIGATOR PIERCE: Sure.
4 MS. -- that you were able to read the
5 entire -- you're saying you can read the entire --
6 INVESTIGATOR PIERCE: Exactly. Exactly.
7 MS. (Unintelligible).
8 INVESTIGATOR PIERCE: From the electronic,
9 right.
10 BY INVESTIGATOR PIERCE:
11 Q. The factionalized -- I said that already.
12 How do you stand on the this allegation?
13 A. Is -- is that the specific question? How do I
14 stand?
15 Q. How are you -- how -- what is your response to
16 this allegation against you?
17 A. It was not made by Lieutenant John Cannon. It
18 was made under the pseudonym Sam Hipster that was done
19 intentionally to disassociate myself from the Chicago
20 Police -- Police Department.
21 The post was made -- the e-mail was not an
22 academic paper but part of a series of policies
23 statements that were discriminatory towards me. The
24 e-mail and others from John Marshall Law School are

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1 evidence of discrimination that are subject of


2 complaints as illustrated in the exhibits that we
3 provided.
4 The post was not biased against African
5 Americans. The post never mentioned African Americans.
6 Instead, it was critical from a legal academic
7 perspective and a reference to Federalist 10 regarding
8 the danger presented to the sovereign when factions
9 become too powerful and imbedded in the American
10 fabric. This was articulated by James Madison in
11 Federalist 10.
12 As such, this expression was made on a matter
13 of public concern protected by the First Amendment.
14 I deny the allegation.
15 Q. Okay. Regarding allegation 4: It is alleged
16 that on or about June 13, 2020, Lieutenant John Cannon
17 reposted a statement on Facebook that was biased
18 against African Americans and Asians in that it
19 depicted a white child with the words "Asking her to
20 apologize for slavery," and an Asian child with the
21 words, "is like asking her to apologize for Pearl
22 Harbor."
23 Again, screenshot of the post there.
24 And what is your response to this allegation?

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1 A. The Facebook page was registered in the same


2 Sam Hipster, not Lieutenant John Cannon. I -- this was
3 done to disassociate myself from the Chicago Police
4 Department and maintain anonymity.
5 The post does -- does look familiar to me and I
6 may have shared it on my Facebook page. I do not have
7 a specific recollection of doing that.
8 The post does not express any animus directed
9 at any group whatsoever and certainly never
10 demonstrates negative animus towards African Americans
11 or Asians.
12 The post speaks about slavery but not in a way
13 that is biased against anyone but in a way that
14 illustrates a hypocrisy sometimes demonstrated in the
15 public sector and hypocrisy that is a matter of public
16 interest and public concern. The post is critical of
17 slavery, not supportive.
18 I deny the allegation.
19 Q. Okay. Allegation 5. It is alleged that on or
20 about June 8, 2020, Lieutenant John Cannon reposted a
21 statement on Facebook that was biased against African
22 Americans by stating, "Welcome to peasantry. Equal not
23 good enough, huh?" and "White privilege is a myth
24 perpetuated by those who hate white people."

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Lt. John Cannon Log #2020-2942

1 Screenshot of the post.


2 And what is your response to that?
3 A. The Facebook page was registered in the name
4 Sam Hipster, not John Cannon. This was done to
5 disassociate myself from the Chicago Police Department
6 and maintain anonymity.
7 The post does not look familiar to me. I do
8 not recall seeing it previously to this matter.
9 However, I may have shared it. I just don't recall
10 specifically doing so.
11 The post is not objectively -- objectively
12 offensive by -- and by extension also not biased
13 against African Americans. The expression does not
14 make any reference to African Americans. Instead, it
15 speaks in general terms about poverty, equality, and
16 hate, all matters of public interest and public
17 concern.
18 Because there is no reference to support the
19 alleged bias and the post was inappropriately and
20 subjectively analyzed, it is clear that the allegations
21 were leveled after subjective point of view.
22 I deny the allegations.
23 Q. Okay. It is -- number 6. It is alleged that
24 on or about April 5, 2020, Lieutenant John Cannon

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1 reposted a statement on Facebook that was offensive


2 towards members of the public in that it depicted a man
3 in a sheriff's uniform with the text, "Back up, you
4 son -- sons of bitches. Six feet away from me or I'll
5 shoot your corona-infested asses."
6 What is your response?
7 A. The Facebook page was registered in the name
8 Sam Hipster, not John Cannon. This was done to
9 disassociate myself from the Chicago Police Department
10 and maintain anonymity.
11 The post does look familiar to me and I may
12 have posted it. I don't recall specifically doing
13 that.
14 However, the post is not objectively offensive
15 against members of the public. The expression is an
16 image of comedian Jackie Gleason in his role as sheriff
17 in the comedy Smokey and the Bandit.
18 The expression is an satiric expression that I
19 thought was funny especially in light of the fact that
20 it featured Jackie Gleason, a comedic role -- in a
21 comedic role and can in no way be taken in any other
22 way but as a jestful expression.
23 Previously, Jackie Gleason was the featured
24 actor on many comedy shows. Probably the most popular

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1 being the TV show, The Honeymooners.


2 The particular expression does reference
3 coronavirus, the global pandemic we are currently in
4 the midst of. Surely the reference, though satiric in
5 nature and an expression made in jest cloaked in
6 comedy, is nevertheless made on a matter of public
7 interest and public concern.
8 It is not objectively offensive and cannot be
9 said to undermine trust unless that it is -- that the
10 charges made based on highly subjective point of view.
11 I deny the allegations.
12 Q. Allegation 7. It is alleged that on or about
13 February 9, 020, Lieutenant John Cannon reposted a
14 statement on Facebook that was biased against
15 homosexuals and firemen in that it depicted four naked
16 men in bed together with the text, "Meanwhile at the
17 fire house."
18 Lieutenant Cannon, what's your response?
19 A. This Facebook page -- the Facebook page was
20 registered in the name Sam Hipster, not Lieutenant John
21 Cannon. This was done to disassociate myself from the
22 Chicago Police Department and maintain an anonymity.
23 The post does look familiar to me. However,
24 the post is not biased against homosexuals or firemen.

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1 The expression does not show anyone naked. Instead,


2 the man in the photos -- the photo are shirtless.
3 There is nothing obscene. The expression makes no
4 reference to homosexuality.
5 The message was extracted based on a subjective
6 point of view and misconstrued meaning. The expression
7 being jestful is simply indicative of the longstanding
8 and friendly rivalry between firefighters and police
9 officers and is often manifested through humor and
10 poking fun.
11 Q. Just want to clarify for the record: You said
12 jestful?
13 A. Jestful.
14 Q. Okay. Sorry. Go ahead. "Poking fun" was the
15 last thing.
16 A. It cannot, on an objective balance, be
17 demonstrated that the expression undermines the public
18 trust. So I must deny the allegation.
19 I do say if the post has subjectively offended
20 anyone, I apologize for that. No offense was intended.
21 Q. Okay. Allegation number 8. It is alleged that
22 on or about September 9, 2019, Lieutenant John Cannon
23 reposted a statement on Facebook that was biased
24 against women in that it depicted an image of Clint

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1 Eastwood with the text, "A she-shed? In my day, we


2 called that a kitchen," written below.
3 What is your response to this allegation?
4 A. The Facebook page was registered in the name
5 Sam Hipster, not Lieutenant Cannon. This was done to
6 disassociate myself from the Chicago Police Department
7 and maintain anonymity.
8 The post does look familiar to me. I may have
9 shared it on my Facebook page, although I do not have a
10 specific recollection of that.
11 The post is not objectively biased against
12 women. Instead, the expression was a satirical play
13 off of a popular TV commercial created as an
14 advertisement for insurance. The expression was a
15 jestful spinoff of the popular advertisement and was
16 not intended to be biased.
17 The joke was private between my wife and I.
18 And she was not offended. Instead, she accepted it as
19 a non-offensive joke.
20 The expression includes a popular movie actor
21 to clearly illustrate the fictional aspect of the post.
22 The allegation is based on a subjective point of view
23 and a misconstrued meaning.
24 On an objective balance, it cannot be

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1 demonstrated that the joke rises to a level to


2 undermine a public trust. That has not occurred.
3 I deny the allegation.
4 Q. Okay. Allegation number 9. On or about
5 August 14, 2019, Lieutenant John Cannon reposted a
6 statement on Facebook that was biased against African
7 Americans in that he reposted a side-by-side image of
8 Roseanne Barr and Jussie Smollet with the text, "Racism
9 in 2019. Fired after a bad joke," above Roseanne Barr,
10 "Working after an evil joke," above Jussie Smollet.
11 What's your response to the allegation?
12 A. Excuse me. The Facebook page was registered in
13 the name Sam Hipster, never Lieutenant John Cannon.
14 This was done to disassociate myself from the Chicago
15 Police Department and maintain anonymity.
16 The post does look familiar to me and I may
17 have shared it on my Facebook although I do not have a
18 specific recollection of that.
19 However, the post is not objectively biased
20 against African Americans. It never references in any
21 way an animus or bias in any way towards any group.
22 Instead, it draws a comparative relationship between
23 two highly-publicized occurrences around the same time
24 and the disparity of how each situation was being

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1 handled.
2 It also directly illustrates that racism in all
3 forms is disgusting and an equal recognition of that
4 may be more appropriate.
5 The allegation, as leveled, is biased and --
6 and is based on a subjective point of view and
7 misconstrued meaning.
8 The expression made is not objectively
9 offensive to anyone and it was made on a matter of
10 public interest and public concern.
11 I deny the allegation.
12 If the post has somehow subjectively offended
13 anyone, I apologize for that. No offense was intended.
14 Q. Okay. Allegation 10. It is alleged that on or
15 about May 18, 2019, Lieutenant John Cannon reposted the
16 statement on Facebook that was biased against African
17 Americans and other minority groups by stating, "Let me
18 get this straight. The democratic candidate wants to
19 win back the vote of the working class men and women by
20 promising to take back our tax cut, open our borders,
21 give reparations to people my great-grandpa never
22 harmed and use my taxes to pay off the debt of college
23 kids who look down upon me as being white privileged.
24 Got it."

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1 Here's a photo.
2 And what is your response to that allegation?
3 A. The Facebook page was registered in the name
4 Sam Hipster, not with Lieutenant John Cannon. This was
5 done to disassociate myself from the Chicago Police
6 Department and maintain anonymity.
7 The post does not look familiar to me. I do
8 not recall seeing it prior to this matter. However, I
9 may have shared it on my Facebook page although I don't
10 have a specific recollection of that.
11 The post is not objectively biased against
12 African Americans. This particular allegation is
13 highly suggestive to the reader and it is highly
14 subjective on one particular point of view and a
15 misconstrued meaning.
16 The accuser specifically alleges bias against
17 African Americans and other minority groups. The
18 suggestive manner of this is absurd.
19 Holding a bias against any group on a protected
20 class is wrong, but deliberately crafting the
21 allegation in this manner, cherry-picking African
22 Americans and bunching anyone else into a common
23 category drums up the type of anger and vitriol that
24 suggests to any reader that the allegation -- of this

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1 allegation that the expression contains the worst kind


2 of bias.
3 The expression -- I'm just going to move
4 through this. We've covered much of it.
5 The expression can -- mentions a democratic
6 candidate, working class men and women, taxes, borders,
7 previous generations of Americans, taxes again, matters
8 of public perception. It does not mention African
9 Americans or minority groups. It was made specifically
10 on a matter of public interest and public concern.
11 As such, I reject the allegation. I deny.
12 Q. Okay. Number 11. It is alleged that on or
13 about April 27, 2019, Lieutenant John Cannon reposted
14 the statement on Facebook that was biased against
15 Muslims and women in that it depicted photos of Ilhan
16 Omar, Alexandria Ocasio-Cortez, Ayanna Pressley,
17 Rashida Tlaib lead with the text, "We're new, bold, and
18 we hate you too," and the response, "The party of
19 freaks, anti-semitics, racists, dangerous. The new KKK
20 wing of the party."
21 What is your response to that allegation?
22 A. The Facebook page was registered in the name
23 Sam Hipster, never Lieutenant John Cannon. This was
24 done to disassociate myself from the Chicago Police

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1 Department and maintain anonymity.


2 The post does not look familiar to me. I do
3 not recall seeing it prior to this matter. However, I
4 may have shared it on my Facebook page. I don't have a
5 specific recollection of that.
6 The post is not objectively biased against
7 Muslims or women. The allegations, in a manner very
8 similar to the previous allegation, is highly
9 suggestive from a subjective point of view and
10 misconstrued meanings. It does not mention Muslims or
11 women and expresses no animus to any protected class.
12 Instead, the expression features well-known and
13 controversial elected politicians who arguably share a
14 common ideology. The expression is highly critical of
15 anti-semites and racists making comparison to other
16 hate groups and likewise disgusting ideologies as being
17 dangerous, highly-debatable proposition.
18 The expression is made on a matter of public
19 concern and matters of public interest.
20 I deny the allegation.
21 If the expression has somehow subjectively
22 offended anyone, I would apologize for that.
23 Q. Okay. Allegation number 12. It is alleged
24 that on or about April 16, 2019, Lieutenant John Cannon

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1 reposted a statement on Facebook that was biased


2 against Muslims which depicts a cartoon wooden horse
3 being pulled through a door. The text "America" is
4 written at the door and people appearing to stand with
5 their hands up blocking the horse. The person dragging
6 the horse is depicted with the word "democrat" and the
7 horse has the words "Ilhan Omar" and "Sharia law"
8 written on it.
9 How do you respond to this allegation?
10 A. The Facebook page was registered to the name
11 Sam Hipster, not Lieutenant John Cannon. This was done
12 to disassociate myself from the Chicago Police
13 Department and maintain anonymity.
14 The post does not look familiar to me. I do
15 not recall seeing it prior to this matter. However, I
16 may have shared it on my Facebook page. I don't have a
17 specific recollection of that.
18 The post is not objectively biased against
19 Muslims. Instead, it expresses on a
20 highly-controversial elected politician who has
21 expressed biased and racist views as part of her public
22 ideology. Featured are words "America" and "democrat"
23 associated with a trojan horse, a commonly understood
24 image that indicates deceptive motives, and here, it

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1 relates to an elected official and political ideology.


2 The expression was made on a matter of public
3 interest and public concern.
4 I deny the allegation.
5 If the -- if the expression has somehow
6 subjectively offended anyone and it is attributed to
7 me, I apologize for that.
8 Q. Allegation 13. It is alleged that on or about
9 March 15, 2019, Lieutenant John Cannon reposted a
10 statement on Facebook that was biased against Muslims
11 in that he reposted an image with the text, "I don't
12 feel safe wearing my head scarf in Trump's America" and
13 the response, "Really? Try being a white kid -- a
14 white Catholic kid in a MAGA hat."
15 And your response to that allegation,
16 Lieutenant Cannon?
17 A. The Facebook page was registered in the name
18 Sam Hipster, not Lieutenant John Cannon. This was done
19 to disassociate myself from the Chicago Police
20 Department and maintain anonymity.
21 The post does not look familiar to me. I do
22 not recall seeing it prior to this matter, but I may
23 have shared it on my Facebook page although I don't
24 have a specific recollection of that.

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1 However, the post is not objectively biased


2 against Muslims. The expression -- the expression
3 depicted appears to illustrate the disparity of
4 treatment and public perceptions on race and religion
5 and how sometimes that disparity is, in itself, biased.
6 The message implied is critical of racial intent when
7 there is none inherit. The expression does not mention
8 Muslims and is not objectively biased against anything
9 other than hypocrisy.
10 The expression is based on a matter of public
11 concern and public interest.
12 Nevertheless, I deny the allegation.
13 If the allegation is being attributed to me and
14 somehow subjectively offensive to anyone, I would
15 apologize for that.
16 Q. Allegation number 14. It is alleged that on or
17 about March 10, 2019, Lieutenant John Cannon reposted a
18 statement on Facebook that was biased against Muslims
19 which depicts the image of Abdullah Zuber and states,
20 "Gee. I will continue until all the Hindus,
21 Christians, Buddhists, atheists are killed. Your
22 secularism and tolerance cannot change our ideology.
23 Quran does not permit survival of non-Muslims."
24 The text below advises, "Keep this in mind as

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1 new members of Congress who are Muslim are sworn into


2 office on this book of death and inequality."
3 What's your response to that allegation?
4 A. The Facebook page was registered in the name
5 Sam Hipster, not Lieutenant John Cannon. This was done
6 to disassociate myself from the Chicago Police
7 Department and maintain anonymity.
8 The post does not look familiar to me. I do
9 not recall seeing it prior to this matter. However, I
10 may have shared it on my Facebook page. I don't have a
11 specific recollection of that.
12 The post is not objectively biased against
13 Muslims. Instead, the post is critical against hate
14 and violence directed at people of different religions
15 and hate expressed towards those religious beliefs by
16 an individual who espouses an alternative belief.
17 The expression also warns against hate being
18 brought into Congress. Specifically -- or therefore,
19 the expression is based on a matter of public interest
20 and public concern.
21 I deny the allegations.
22 However, if the expression has somehow
23 subjectively offended anyone and it's being attributed
24 to me, I would apologize for that.

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1 Q. Okay. Allegation number 15. It is alleged


2 that on or about January 28th, 2019, Lieutenant John
3 Cannon reposted a statement on Facebook that was biased
4 against members of the LGBTQ community in that he
5 reported [sic] side-by-side images of a young man in a
6 MAGA hat and a young person in drag with the text,
7 "Liberal logic? Kid in MAGA hat. Offensive. Kid in
8 drag. Brave."
9 How do you respond to the allegation?
10 A. The Facebook page was registered in the name of
11 Sam Hipster, not Lieutenant John Cannon. This was done
12 to disassociate myself from the Chicago Police
13 Department and maintain anonymity.
14 The post does look familiar to me. I may have
15 seen it prior to this matter. I may have shared it on
16 my Facebook page although I do not have a specific
17 recollection of that.
18 However, the post is not objectively biased
19 against members of the LGBTQ community. It depicts an
20 image -- it depicts an image about a person exercising
21 First Amendment activity that was highly publicized at
22 the time. The expression is a commentary about the
23 disparity and hypocrisy that is sometimes demonstrated
24 on a national stage.

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1 The expression does not mention LGBTQ. It


2 expresses no hateful animus or bias. The expression is
3 on a matter of public interest and public concern.
4 The allegation, as crafted, is subjective,
5 suggestive and based on a misconstrued meaning.
6 On an objective balance, it has not been
7 demonstrated that the expression rises to a level to
8 undermine a public trust.
9 I deny the allegation.
10 However, if the expression has somehow
11 subjectively offended anyone and it is being attributed
12 to me, I would apologize for that.
13 Q. Okay. It is alleged that on or about
14 January 8, 2019, Lieutenant John Cannon reposted a
15 statement on Facebook that was biased against Hispanic
16 people and immigrants in that he reposted an image of
17 soldiers with the text, "Democrats will stop these
18 people's paychecks," and an image of Hispanic people
19 with the text, "to protect illegal people like this.
20 Let that sink in."
21 And what is your response, sir?
22 A. The Facebook page was registered in the name
23 Sam Hipster, not Lieutenant John Cannon, done to
24 disassociate myself from the Chicago Police Department

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1 and maintain anonymity.


2 The post does look familiar to me. I have seen
3 it prior to this matter. I may have shared it on my
4 Facebook page although I do not have a specific
5 recollection of that.
6 The post is not objectively biased against
7 Hispanics or immigrants. The expression is a
8 commentary regarding the disparity of treatment by
9 politicians between American service members and others
10 who express extreme disdain for America because they
11 are giving the middle finger which commonly means "F.
12 you."
13 The expression does not mention Hispanics or
14 immigrants and the allegation is indicative of a
15 suggestive and subjective point of view.
16 Nevertheless, the expression is squarely on a
17 matter of public interest and public concern.
18 I object -- or I deny the allegation.
19 However, if the expression had somehow
20 subjectively offended anyone and it is being attributed
21 to me, I apologize for that.
22 Q. Okay. Allegation number 17 says it's alleged
23 that on or about number -- I'm sorry -- November 18,
24 2018, Lieutenant John Cannon posted a statement on his

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1 Facebook that was biased against Hispanic people by


2 stating, "Working class Mexican residents of Tijuana
3 are worried that the South American invaders are going
4 to compete for their jobs and bring crime and drugs.
5 Let that sink in. And they are probably correct in
6 some respects."
7 How do you respond to that allegation?
8 A. The Facebook page was registered in the name of
9 Sam Hipster, not John Cannon, done to disassociate
10 myself from the Chicago Police Department and maintain
11 anonymity.
12 The post does look familiar to me. I may have
13 seen it prior to this matter. I may have shared it on
14 my Facebook page. I don't have a specific recollection
15 of that.
16 The post is not objectively biased against
17 Hispanics. Instead, it illustrates the fears of
18 Mexican people regarding a flood of South American
19 residents entering Mexico and have -- on Mexican
20 committee and public safety.
21 The expression does not suggest any animus
22 directed at Hispanics. Instead, the expression is on
23 relationships between immigration, economics, and
24 public safety, all matters of public interest and

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1 public concern.
2 On an objective balance, it cannot be
3 demonstrated that the expression rises to a level to
4 undermine a public trust.
5 I deny the allegation.
6 However, if the expression has somehow
7 subjectively offended anyone, I apologize for that. No
8 offense was intended.
9 Q. Allegation number 18. It is alleged that on or
10 about October 5, 2018, Lieutenant John Cannon posted a
11 statement on Facebook that was disrespectful to CPD by
12 stating, "Festering maggot-filled pool of scum and
13 villainy, I will be glad when I can leave."
14 What did you mean by that?
15 A. The Facebook page was registered in the name
16 Sam Hipster, not John Cannon, done to disassociate
17 myself from the Chicago Police Department and maintain
18 anonymity.
19 The post does look familiar to me. I have seen
20 it prior to this matter. I wrote it on Sam Hipster
21 Facebook.
22 The post is not objectively disrespectful to
23 CPD. The post does not mention CPD or anything of
24 substance whatsoever that could objectively be

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1 attributed to any one thing. The comments are vague


2 and ambiguous and could never be considered
3 disrespectful to CPD or any other identified group,
4 class, agency, or individual.
5 To the contrary, the words are a direct
6 reference that is highly misquoted to a scene in a Star
7 Wars movie. That is all.
8 Instead, the allegation, as crafted, is
9 suggestive, based on a narrow and subjective point of
10 the view and somehow manufactured -- and that somehow
11 manufactured a disrespect allegation out of nothing.
12 The post is so vague and ambiguous that it
13 could not even fit into what might be evaluated on any
14 balancing scale. It means nothing substantive.
15 I deny the allegations as presented.
16 If the expression has somehow subjected --
17 subjectively offended anyone, I would apologize for
18 that.
19 Q. And finally, allegation number 19. It is
20 alleged that on or about July 15, 2018, Lieutenant John
21 Cannon posted a statement on Facebook that was
22 disrespectful to CPD in that he responded to a post
23 containing body-worn camera footage of a
24 police-involved shooting by stating, "Brave, young

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1 warriors face to face with an urban terrorist and the


2 better trained professional police officer won the day.
3 Excellent work, all, by the new batch of warriors.
4 Love it."
5 And your response?
6 LIEUTENANT CANNON: I'm good.
7 MR. Okay.
8 LIEUTENANT CANNON: I thought you were --
9 MR. Nope.
10 LIEUTENANT CANNON: -- getting ready to say
11 something.
12 A. The Facebook page was registered in the name
13 Sam Hipster, not Lieutenant John Cannon, done to
14 disassociate myself from the Chicago Police Department
15 and maintain anonymity.
16 The post does look familiar to me. I have seen
17 it prior to this matter. I may have shared it on my
18 Facebook page although I do not have specific
19 recollection of that.
20 The post is not objectively disrespectful to
21 CPD. The expression was made on a body-worn camera
22 post made public by CPD. It is complimentary to the
23 Chicago Police Department and its use-of-force training
24 as manifested by a police officer who was faced with

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1 the unfortunate decision to use force. Based on the


2 officer's training, he was able to survive and win a
3 gunfight.
4 The expression was made on a matter of public
5 interest and public concern.
6 I deny the allegation.
7 However, if the allegation has somehow
8 subjectively offended anyone, I would apologize for
9 that.
10 Q. Okay. You mentioned registering the name --
11 the handle, it's called -- of the social media posts to
12 Sam Hipster in an effort to disassociate from CPD and
13 maintain anonymity; is that correct?
14 A. Yes.
15 Q. Okay. This is a selfie that was posted to the
16 account.
17 LIEUTENANT CANNON: We need a break.
18 INVESTIGATOR PIERCE: Okay. I'm going to
19 pause the recording at 1:38 with Lieutenant Cannon.
20 March -- March 16, 2021.
21 (A break was taken.)
22 INVESTIGATOR PIERCE: Okay. We're back on
23 the record with John Cannon. That's Lieutenant John
24 Cannon, Star number 412. It is 1:42 p.m. on March 16,

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1 2021.
2 We did not discuss this case while we were
3 paused, correct?
4 MS. Correct.
5 LIEUTENANT CANNON: Correct.
6 BY INVESTIGATOR PIERCE:
7 Q. And Lieutenant Cannon, I had just asked you --
8 you said that you registered the name under Samuel
9 Hipster -- that's the handle of the account -- to
10 disassociate from CPD and maintain anonymity, but I
11 just provided a selfie here.
12 I also have the acceptance letter from John
13 Marshall Law School addressed to John Cannon with a
14 statement made by Samuel Hipster. It says, "The
15 liberal police-hating class at this law school probably
16 hate the fact that a rotten police officer kicks ass
17 there. Just give me my law degree, you assholes."
18 And then the handle is Samuel Hipster, as
19 you've already named, but the actual Facebook URL is
20 John M. Cannon, III.
21 A. Uh-huh.
22 Q. How -- how -- what is your intention -- how are
23 you able to maintain anonymity of this account with
24 this kind of stuff posted on there?

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1 A. This URL was never posted on my Facebook. This


2 was a URL that was stolen by someone who retaliated
3 against me after I -- after I made a discrimination
4 complaint against them.
5 So the person who did this found this by
6 hacking into my private account that was registered
7 under Sam Hipster, posted this on his own Twitter
8 account.
9 MR. Just identify what you're --
10 what you're saying he posted.
11 LIEUTENANT CANNON: This.
12 MR. What you're referring to.
13 A. The URL which has my name on it.
14 Q. Okay.
15 A. This isn't something that's just public. It
16 was -- it was stolen and it was used as a way to
17 demonstrate how that person obtained my information in
18 retaliation of my discriminatory complaints against him
19 and his retaliation and harassment.
20 Q. Okay. And the acceptance letter to law school
21 and the rotten police-hating class there?
22 A. This is not an acceptance letter. This is a
23 letter -- well, you can't really tell because it's so
24 highly pixilated, but what this is was a congratulatory

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1 letter to me having had made the dean's list also taken


2 by the same person who is discrim -- or I complained
3 against and who retaliated and harassed me in response
4 to my official complaints against him.
5 Q. Okay. And the selfie?
6 A. This is a picture of me after having given
7 myself a haircut. It identifies me as Sam Hipster. It
8 doesn't identify me as a Chicago police officer, a
9 lieutenant. Any of the text on here is highly
10 pixilated. I can't make out what it is.
11 But there is no identifying -- identifying
12 information on this other than a picture of me with
13 respect to the Chicago Police Department.
14 Q. Okay. With respect to the Chicago Police
15 Department, this says something to the effect of taking
16 the oath to fight and uphold liberty.
17 Did you take an oath to fight and uphold
18 liberty?
19 A. I can't read that. That's a highly
20 pixilated --
21 Q. I -- I have the electronic copy which is much
22 less pixilated. It does say taking the oath to fight
23 and uphold liberty. I just -- did you take an oath to
24 fight and --

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1 A. I'm just going to object to the question. It's


2 highly irrelevant. It has nothing to do with the
3 allegations.
4 Q. Okay. I have one other question.
5 Do you -- do you consider sexism, racism,
6 homophobia, xenophobia, things of that nature, do you
7 consider those subjective?
8 A. I would say that many of the allegations
9 presented against me have been done so in a
10 subjective -- subjective way. I -- anytime you're
11 talking about an opinion, it subjective. The form of
12 the question is itself subjective.
13 I -- I mean, I object to that question.
14 I do disagree with making judgments based on
15 protected classes. I think racism and discrimination,
16 hypocrisy in all forms are wrong, but none of that
17 occurred with me and certainly not -- not -- not to the
18 point where I have offended a public trust that has not
19 been demonstrated.
20 Except for some -- a few jestful expressions,
21 everything that I have been subject to allegations are
22 are on matters of public concern, public importance,
23 protected under common law, widely-accepted principles.
24 Q. Okay. So jestful. In other words, you find it

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1 funny, right?
2 A. We have already covered the --
3 Q. I just -- I want to -- because the word
4 "jestful" is not necessarily common, I want to
5 understand.
6 When you were using "jestful," are you using
7 that to mean something that you find funny or a
8 community finds funny or humorous?
9 MR. When he used jestful today in
10 his statement?
11 INVESTIGATOR PIERCE: Just -- yeah, he
12 referred to, like, two of the allegations as jestful.
13 A. I think -- ask the question again. I'm not
14 really sure what you're asking.
15 Q. When you use the word "jestful," are you using
16 that to mean humorous or funny to you?
17 A. If we looked it up in the dictionary, I think
18 jestful would probably be referred to as something
19 humorous. That's what it means to me.
20 Q. Okay. And finally, you said the person --
21 someone -- someone stole your -- your congratulations
22 for making the dean's list and your -- how did that
23 come to -- how did they come to have this letter?
24 A. It was taken from the Sam Hipster Facebook

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1 page.
2 MR. I think it's spelled out in the
3 IDHR allegations.
4 LIEUTENANT CANNON: It is.
5 Q. So --
6 MR. But you don't know exactly
7 how -- exactly how --
8 Q. You mean --
9 A. I have pretty good idea.
10 Q. Let me just -- because we're dealing with the
11 internet.
12 So you mean that someone screenshotted this and
13 came into possession of it in that way or somehow
14 cropped it online or something like that? They didn't
15 receive your congratulations letter from the dean's
16 list, right?
17 A. No. No, they didn't receive it from me.
18 Q. Okay. So "This liberal, police-hating class at
19 the law school hate that the fact that a rotten police
20 officers kicks ass. Just give me my law degree,
21 assholes" with the congratulations, this is a post from
22 Samuel Hipster.
23 Your response to this was that someone took
24 this from you?

Bridges Court Reporting Page: 55


Lt. John Cannon Log #2020-2942

1 A. Someone did take it from me.


2 Q. Okay. But this --
3 A. Someone took all of these expressions from me
4 as retaliation and harassment in a way to discredit me
5 from -- from discriminatory charges I made months ago
6 prior to any of this.
7 But for the retaliation and discrimination, we
8 would not be here today.
9 Q. Okay. So this -- you posted this under the
10 Samuel Hipster account, correct?
11 A. Is there a -- is there an allegation specific
12 to that post?
13 Q. I'm sorry?
14 A. Is there an additional allegation specific to
15 any of these posts?
16 Q. You said that you registered Samuel Hipster as
17 the handle to disassociate yourself and maintain
18 anonymity, so, yes, this affects every single
19 allegation.
20 A. But there's no specific allegation of
21 misconduct regarding these posts? I have 19
22 allegations against me today.
23 Q. Right. This -- this -- this disassociating
24 from CPD and maintaining anonymity led every single

Bridges Court Reporting Page: 56


Lt. John Cannon Log #2020-2942

1 response to the allegation.


2 So this letter addressed to you, it -- it
3 conflicts with maintaining anonymity. So that's why
4 I'm asking you -- I'm trying to understand what you're
5 saying about the person coming to possess this. I want
6 to make sure that I understand and -- that you posted
7 this, this person somehow got it and used it against
8 you?
9 A. Okay. I think I understand.
10 MS. I also -- excuse me.
11 So I know you're trying to use this as proof
12 that he's not maintaining anonymity because he said the
13 word "police" in there?
14 INVESTIGATOR PIERCE: Yeah, there's a --
15 yeah. Right. There's the police in there, the law
16 school that he goes to, his name, his -- whatever his
17 e-mail, his links, these things. That's -- I'm just --
18 he said anonymity and disassociating from CPD, but
19 it's -- they hate that a rotten police officer is
20 there.
21 I'm trying to understand his -- someone stole
22 it from him. I want to make sure that he -- you know,
23 this is him. You see what I'm saying?
24 MS. I do see what you're saying. I

Bridges Court Reporting Page: 57


Lt. John Cannon Log #2020-2942

1 just --
2 INVESTIGATOR PIERCE: Which thus far is my
3 understanding, but I want to make sure that I'm not
4 incorrect.
5 MS. I just want to be clear. He says
6 the word "police." It did not say "Chicago Police."
7 INVESTIGATOR PIERCE: Okay. Yeah. No. I --
8 I -- I am not disputing any of that. I'm -- I'm --
9 the -- Lieutenant Cannon said that someone stole this
10 from him so I'm trying to understand what -- what
11 specifically was stolen.
12 MR. And if I could just for the
13 record?
14 INVESTIGATOR PIERCE: Sure.
15 MR. The complainant in this case,
16 I'm assuming COPA inquired of the complainant as to how
17 they received these -- these messages on a private
18 Facebook page when he was not a friend with Mr. Cannon.
19 So I'm assuming COPA has already inquired as to how he
20 received these private Facebook posts which apparently
21 are the subject of this -- Mr. [phonetic]
22 allegations.
23 INVESTIGATOR PIERCE: Okay.
24 ///

Bridges Court Reporting Page: 58


Lt. John Cannon Log #2020-2942

1 BY INVESTIGATOR PIERCE:
2 Q. Did you want to elaborate on the stealing of
3 this particular post?
4 A. It's been pretty well-covered. I -- the --
5 somebody took expressions from me in retaliation and
6 harassment. "Me" being Sam Hipster.
7 Q. Okay.
8 A. The page was private. It was not associated
9 facially to the Chicago Police Department. Any
10 assertions or assumptions that it was would have had to
11 have occurred by somebody accessing my page which was
12 private and --
13 Q. You mean, in other words, visiting or going to
14 your page? Not logging in with your login information?
15 A. I'm not sure about that.
16 Q. Okay. Okay.
17 INVESTIGATOR PIERCE: I don't have anything
18 else.
19 MS. I do have one question.
20 INVESTIGATOR PIERCE: Sure.
21 MS. So I -- again, just going back to
22 the -- the man who signed this sworn affidavit.
23 LIEUTENANT CANNON: Yeah.
24 MS. He -- he is the one who made all

Bridges Court Reporting Page: 59


Lt. John Cannon Log #2020-2942

1 these assertions, right? In his sworn affidavit --


2 INVESTIGATOR PIERCE: Right.
3 MS. So it's an audio --
4 INVESTIGATOR PIERCE: Audio recorded.
5 MS. It's audio recorded.
6 INVESTIGATOR PIERCE: Right. Right.
7 MS. So for example, the one where
8 Lieutenant Cannon I don't think recalls posting or
9 whatever he wrote about a maggot-filled whatever with
10 "I can't wait to leave," so that individual who made --
11 who signed this sworn affidavit said he found that
12 offensive to the CPD?
13 INVESTIGATOR PIERCE: Correct.
14 MS. And so all of the allegations like
15 that, the 19 allegations, those are the words and how
16 offended the person who signed the complaint? He was
17 offended in all those aspects?
18 INVESTIGATOR PIERCE: Correct.
19 MS. Okay. Sorry, Greg.
20 INVESTIGATOR MASTERS: May I
21 (unintelligible)?
22 INVESTIGATOR PIERCE: The allegations?
23 INVESTIGATOR MASTERS: No, just the last --
24 INVESTIGATOR PIERCE: Sure.

Bridges Court Reporting Page: 60


Lt. John Cannon Log #2020-2942

1 INVESTIGATOR MASTERS: -- identification --


2 INVESTIGATOR PIERCE: Okay.
3 INVESTIGATOR MASTERS: -- related.
4 BY INVESTIGATOR MASTERS:
5 Q. Looking again at the dean's -- the post with
6 the dean's list letter from UIC John Marshall --
7 A. Yes.
8 Q. -- and where it -- the words on there where it
9 says -- where it refers to -- I'm sorry. I'm having
10 trouble --
11 INVESTIGATOR PIERCE: I know.
12 Q. -- reading it. I don't want to -- I won't ask
13 Investigator Pierce to --
14 INVESTIGATOR MASTERS: I don't want to be
15 confused of having both of us asking questions, but --
16 INVESTIGATOR PIERCE: Sure.
17 INVESTIGATOR MASTERS: -- if you could read
18 what that actually says there.
19 INVESTIGATOR PIERCE: "The liberal police" --
20 this is coming from a -- these -- these are drawn from
21 things that have been page vaulted from -- from Twitter
22 which are -- because of having to protect the
23 identities, this is how this had to be formatted. As a
24 courtesy, I wanted to -- you know.

Bridges Court Reporting Page: 61


Lt. John Cannon Log #2020-2942

1 It says, "The liberal -- the liberal,


2 police-hating class at this law school probably hates
3 the fact that a rotten police officer kicks ass there.
4 Just give me my law degree, you assholes."
5 BY INVESTIGATOR MASTERS:
6 Q. Okay. Those words that Investigator Pierce
7 just read, is that something that you're now contending
8 someone who hacked your account wrote or it -- did you
9 actually write those words?
10 A. I -- I don't specifically recall writing those
11 words. I -- I don't have a specific recollection of
12 that. So I'm not making any contention on that
13 whatsoever.
14 Q. Okay. Do you recall ever making a -- a post
15 that included your letter from the dean?
16 A. I -- I'm familiar with that, right? I don't
17 specifically remember.
18 Yeah, I -- it -- I -- you know, I probably
19 posted that on my Facebook page. I don't recall
20 specifically doing it. I don't have a specific
21 recollection of it.
22 Q. Okay. And the page here where it shows -- it
23 says Samuel's profile link and then it says -- has the
24 URL that ends with John M. Cannon --

Bridges Court Reporting Page: 62


Lt. John Cannon Log #2020-2942

1 A. Yep.
2 Q. -- III --
3 A. Yes.
4 Q. -- you're saying this was somehow taken from
5 you by the person who hacked you; is that correct?
6 A. You know, if you used the term "hacked" in a
7 generic way, then the answer to that question is yes.
8 Q. Okay. How are -- when you used the word
9 "hacked" earlier, what did the word mean to you?
10 A. Well, it means somebody without permission goes
11 onto some sort of an electronic platform, possibly
12 social media, and -- and that's it. They access you
13 without permission somehow circumventing whatever
14 protective measures might happen to be there.
15 Q. Okay. At some point, was the Facebook URL that
16 ends with John M. Cannon, III, is that something you at
17 some point registered with Facebook expecting it not to
18 be seen by the public?
19 A. I -- I don't know how those URLs are created by
20 Facebook.
21 Q. Do you have any knowledge of that URL being
22 associated with you?
23 A. Only because of that, what -- only because of
24 the exhibit that you're showing me today. I never put

Bridges Court Reporting Page: 63


Lt. John Cannon Log #2020-2942

1 anything -- I never memorialized or even researched


2 what my Facebook URL or any Facebook URL might be.
3 Q. And when you signed up for your Facebook
4 account, did you provide Facebook with your real name?
5 A. It's been so long, I don't remember what
6 information they asked for.
7 Q. Do you still have that Facebook account?
8 A. The account is now inactive.
9 Q. Would you be able to reactivate it if you chose
10 to?
11 A. I haven't tried to.
12 Q. When you mentioned, you know, repeatedly
13 blocking -- you know, creating the Facebook account
14 under the name Samuel Hipster in order to maintain
15 anonymity and disassociate yourself from the Chicago
16 Police Department, why is it that you wanted to be
17 anonymous and not associated with the Chicago Police
18 Department?
19 A. My -- my initial reasons for wanting to
20 disassociate my name from the Chicago Police Department
21 is because I have heard stories that people who wanted
22 to do harm to police officers might look for them on
23 social media. So I wanted to protect myself and my
24 family from that kind of attack.

Bridges Court Reporting Page: 64


Lt. John Cannon Log #2020-2942

1 Q. And when your Facebook account was active -- I


2 don't expect you to list everyone, but generally
3 speaking, what -- who were the people you were friends
4 with on Facebook who would have been able to see your
5 posts?
6 A. I would say friends and family.
7 Q. And those -- did those people presumably know
8 that you are, in fact, Lieutenant John Cannon of the
9 Chicago Police Department?
10 A. I would just have to not presume anything at
11 this point. It's -- that makes this way more
12 subjective than it needs to be.
13 Q. Okay. But would you agree that your friends
14 and family generally know that you're a Chicago police
15 lieutenant?
16 A. I think I don't want to presume anything.
17 Q. And referencing -- I know we talked about
18 hacking a little bit and what that may or may not mean
19 in this context, but to your -- to the best of your
20 knowledge, has anyone else ever posted anything on your
21 Facebook account?
22 A. I really don't know.
23 Q. Have you ever noticed posts on your Facebook
24 account that you didn't make?

Bridges Court Reporting Page: 65


Lt. John Cannon Log #2020-2942

1 A. Well, if I say yes to that, then my previous


2 answer would be false.
3 I don't know the answer. I -- I understand
4 what you're asking me, but I don't know if anyone has
5 ever done that.
6 Q. Can you explain how -- how that is? How is it
7 that you don't know if you were -- if you -- were you
8 regularly accessing your Facebook page in 2018 and 2019
9 and 2020?
10 MS. Okay. So we're going to object.
11 So you want him to explain how he doesn't know
12 something?
13 INVESTIGATOR MASTERS: What I want to -- what
14 I want him to explain is if he was actively using his
15 Facebook page, seeing, you know, that it shows what
16 he's posted, if someone else was posting on it, I --
17 I'm trying to understand how he wouldn't have noticed
18 that.
19 MS. But he answered several times that
20 he does not know how someone posted it. So he doesn't
21 know that.
22 But now you want him to say, well, how come
23 you didn't know that? He want -- you want him to --
24 just so I am understanding. So you want him to explain

Bridges Court Reporting Page: 66


Lt. John Cannon Log #2020-2942

1 how he does not know how someone may or may not --


2 INVESTIGATOR MASTERS: If there is an
3 explanation for how if someone else was accessing his
4 page and he didn't notice.
5 BY INVESTIGATOR MASTERS:
6 Q. How -- how is that that you wouldn't have seen
7 the posts that you didn't make on your own page?
8 A. That's a convoluted question.
9 Q. It is. We've gone back and forth enough times
10 here. I don't think we're going to get anywhere with
11 the questions so I'll withdraw it.
12 INVESTIGATOR PIERCE: Okay. Anything else,
13 Greg?
14 INVESTIGATOR MASTERS: No. That's all I
15 have.
16 BY INVESTIGATOR PIERCE:
17 Q. Just for the record, these documents, the
18 exhibits with the law degree, the selfie, the handle,
19 things like that, I -- I -- it became clear to me
20 earlier when you were talking, these things were
21 private to you and that the fact that someone has it
22 is -- is basically a violation of that privacy and that
23 when you described somebody coming to possess it and
24 things like that is like the presumption of a private

Bridges Court Reporting Page: 67


Lt. John Cannon Log #2020-2942

1 Facebook account, somebody being on there


2 screenshotting these things or whatever, you're --
3 you -- they violated the privacy agreement of Facebook
4 and therefore, hacked, or whatever words that we've
5 loosely used in this investigation, correct?
6 A. I'm not sure what the rules of Facebook are as
7 far as that goes, but --
8 Q. To you.
9 A. But I do say that somebody without permission
10 accessed stuff from a Facebook page not associated with
11 the Chicago Police Department but with a pseudonym, Sam
12 -- Samuel Hipster, that I control.
13 Q. Okay.
14 A. Used to control.
15 Q. That is no longer, is what you're saying?
16 A. Right.
17 Q. How long has that been?
18 A. I don't remember.
19 Q. Okay.
20 INVESTIGATOR PIERCE: Do you have anything
21 else, Greg?
22 INVESTIGATOR MASTERS: Just a follow-up to
23 that.
24 ///

Bridges Court Reporting Page: 68


Lt. John Cannon Log #2020-2942

1 BY INVESTIGATOR MASTERS:
2 Q. What -- during the entire time you were in
3 control and using your Facebook account, was it always
4 set to be private?
5 A. I don't know the answer to that question.
6 Q. So at some point, was your Facebook page public
7 where anyone on the internet could look at it?
8 A. I don't remember.
9 INVESTIGATOR MASTERS: I don't have anything
10 further.
11 INVESTIGATOR PIERCE: Okay.
12 BY INVESTIGATOR PIERCE:
13 Q. Is there anything that I didn't ask you that I
14 should have or anything that you would like to add to
15 this statement?
16 A. I would like to give a few closing
17 statements -- words. I'm going to make it a lot
18 shorter than I have written.
19 So by and large, the statements I made were on
20 matters of public interest and public concern protected
21 under the First Amendment even including a possibly no
22 restricted space under common law principles. Nothing
23 I did was offensive.
24 The Chicago Police Department operates from a

Bridges Court Reporting Page: 69


Lt. John Cannon Log #2020-2942

1 very vague and ambiguous social media policy especially


2 when compared to other major police departments. The
3 Chicago Police Department has never trained extensively
4 or even minimally on what it believes Chicago police
5 officers can and can't post. I object to that.
6 So I object to the vague and ambiguous nature
7 of the policy and the fact that it has never been
8 trained on giving clear guidance to its members on what
9 they may or may not post.
10 Q. Anything else?
11 A. No, I don't think so.
12 INVESTIGATOR PIERCE: Okay. This now
13 concludes the station -- the statement portion of this
14 investigation.
15 I am going to leave the -- I'm going to turn
16 off the recording.
17 I'm going to correct the paperwork, get
18 Lieutenant Cannon the copies after he signs them, and
19 then I'm going to go back on the record just to make
20 sure we have the appropriate -- because it is included
21 in my preamble about the paperwork.
22 And then we'll be good to go.
23 MS. Okay.
24 INVESTIGATOR PIERCE: This now concludes the

Bridges Court Reporting Page: 70


Lt. John Cannon Log #2020-2942

1 recorded statement of Lieutenant John Cannon, Star


2 number 412, assigned to the 18th District.
3 (A break was taken.)
4 INVESTIGATOR PIERCE: Okay. We're back on
5 the record with Lieutenant John Cannon, Star number
6 412. The time is 2:21 on March 16, 2021.
7 We started this statement with incorrect
8 paperwork. It stated that the complainant was Angela
9 Hearts-Glass.
10 We did, in fact, have an affidavit for this
11 case. Therefore, the complainant's name was corrected
12 to reflect the complainant, and
13 Lieutenant Cannon went ahead and signed the allegation
14 forms. There's, like, seven pages. Allegations 1
15 through 19. The time that he signed these is 2:19 p.m.
16 None of these allegations were altered or
17 anything. They were presented to him before the case
18 and even as early as January.
19 But the administrative proceeding rights and
20 the request to secure counsel form were signed prior to
21 the -- the allegation forms that were corrected. So
22 with have all the paperwork corrected to reflect the
23 complainant and we're good to go.
24 This now concludes the digitally-recorded

Bridges Court Reporting Page: 71


Lt. John Cannon Log #2020-2942

1 statement of Lieutenant Cannon, Star number 412,


2 March 16, 2021 at 2:24 p.m.
3 - - - - - - - - - - - -
4

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

Bridges Court Reporting Page: 72


Lt. John Cannon Log #2020-2942

1 STATE OF ILLINOIS )
) SS.
2 COUNTY OF COOK )
3

4 I, SAMANTHA N. MCNETT, RPR, CRR, CCR do


5 hereby certify that I transcribed an audio file to the
6 best of ability of the above proceedings and that the
7 foregoing is a true and correct transcript of said
8 audio file.
9

10

11

12 ___ ____________
Samantha N. McNett, RPR, CRR, CCR
13

14

15

16

17

18

19

20

21

22

23

24

Bridges Court Reporting Page: 73


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'White Privilege'

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Who state White People
Samuel Hipster
REAL RACISM IN
2019
Samuel Hipster
13 2.0 111

I DON4 FEEL SAFE WEARING MY


'HEADSCARF IN TRUMP'S AMERICA

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Samuel Hipster
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" Jihad will continue until


all the Hindus, Christians,
Buddhists, Atheists are
killed. Your secularism 84
tolerance can not change
• our ideology. Quran does
NOT permit survival
of Non-Muslims."
Ahdullah

Keep this in mind as new members of


Congress who are Muslim are sworn
into office on this book of death and
inequality.
See Notice

01 1 • ' ri
I . Samuel Hipster •••

l'AW Nov 18, 2018

Working class Mexican residents of Tijuana are


worried that the South American Invaders are going
to compete for their jobs and bring crime and drugs.

Let that sink in. And they are probably correct in


some respects.
08

05 Like Q Comment 6 Share


4 Samuel Hipster •••

Li
114W Oct 5, 2018

Festering maggot filled pool of


scum and villany. I will be glad
when I can leave.
00133 14 Comments

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Brave yoLrg wart ors face to 'face with an urban


terrorist arid the better trained professional Police
Officer 'Joon the day. Exce lent wore by all the new
batch of warriors. Love it.

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Chicago pace just released this bodycarr footage


of yos!..sprday's policp-involved shooting on the
South Side The content is, as you 'no... See More

This video may show violent or graphic


content.

this vie ezi so Cal decide It VOU


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t.: See video


09-Jul-2021 10:12:33 AM
CHICAGO POLICE DEPARTMENT

Sustained Complaints History Report

JOHN M CANNON Emp# : Unit : 018 Date of Appointment : 04/13/98

No Complaint History
Report Date. 09-Jul-2021
Report Time: 10:20:34
Produced By: Information
Services
Division
Chicago Police Department
Run By:
Human Resources Division
*Only for active personnel

Complimentary History
Name
M
CANNON,
JOHN 9173 412 018
Title Unit Detail Unit
55824
Emp Number

Total No.
2004
CRIME
REDUCTION
RIBBON
Achievements

2009
CRIME
2019 REDUCTION
CRIME AWARD
REDUCTION
AWARD 1
ATTENDANCE
RECOGNITION
COMPLIMENTARY
LETTER AWARD 15
DEPARTMENT
COMMENDATION
DEPLOYMENT
OPERATIONS
CENTER
AW (1 10
,15)1)(111111/
HONORABLE
MENTION
HONORABLE
MENTION
RIBBONA 152
2
' `c::5

JOINT
OPERATIONS
MILITARY AWARD
SERVICE
AWA-
NATO
SUMMIT
POLICE SERVICE
OFFICER
0 ,. THAWARD
1
(1*

PRESIDENTIAL
PROBLEMEL
SWARD N PLOYMENT
Lilt AWARD
IN
2008
0

RECOGNITION
SPECIAL/OUTSIDE
GOVERNMENTAL
COMMENDATION AGENCY
AWARD 2
TOTAL
AWARDS 183

NOTE THIS REPORT IS FOR OFFICIAL LAW Chicago Police Department


ENFORCEMENT !AUTHORIZED USE ONLY. THE
INFORMATION IS CURRENT AS OF THE DATE
AND TIME OF THE REPORT. THIS REPORT IS
CLEAR Page 1 of 1
NOT FOR PUBLIC DISSEMBIATION. Citizen & Law Enforcement Analysis & Reporting System
CHICAGO POLICE DEPARTMENT 09-JUL-2021 10:11:29 AM

Sustained Complaints History Report

Social Sec. # Name Star #. Emp. # Rank Description Unit


CANNON JOHN M. 412 9173 LIEUTENANT OF POLICE 018
Sex Race Birth Date Appointed Date No. Of CR's No. Of SPAR'S
M WHITE -1971 13-APR-1998 0 0

Page 1 of 1
Chicago Police Department
Internal Affairs Division
SPAR HISTORY REPORT (Sustained Findings)
Employee* Name Star# Unit Position Sex Race Birth Date Date of A

CANNON, JOHN M 412 0181- LIEUTENANT OF POLICE M WHITE -1971 13-Al

History : Total No. SPAR's: 0

Log # Incident Date Completed Date Disciplinary Action Transgression Type Suspension Dates

For Official Police Purposes Only! This inform n is confidential and should not be disseminated for reasons other than its intended purpose.
CLEAR, Personnel Suite: Automated SPAR Application Print Date and Time 09-JUL-2021 10:12:44 Printed By :
Lori E. Lightfoot Department of Police • City of Chicago David 0. Brown
Mayor 3510 S. Michigan Avenue • Chicago, Illinois 60653 Superintendent of Police

January 10, 2022

Andrea Kersten
Interim Chief Administrator
Civilian Office of Police Accountability
1615 West Chicago Avenue, 4th Floor
Chicago, IL 60622

RE: Superintendent's Review Period Log Number 2020-0002942


Request Review Period Extended up to thirty (30) additional days

Dear Chief Administrator:

According to the Municipal Code of Chicago Section 2-78-130, the Superintendent of the Chicago
Police Department may request the Review Period of a disciplinary-related recommendation by the Civilian
Office of Police Accountability be extended for up to thirty (30) additional days for a total Review Period not to
exceed ninety (90) days.

The Department, therefore, respectfully requests until close of business February 17, 2022 to complete
the review of Log Number 2020-0002942.

Sincerely,

Superintendent of Police
Chicago Police Department

Emergency and TTY: 9-1-1 • Non Emergency and TTY: (within city limits) 3-1-1 • Non Emergency and TTY: (outside city limits) (312) 746-6000
E-mail: police(djcityofchicago.org • Website: www.cityofchicago.orWpolice
BUREAU OF INTERNAL AFFAIRS 09 MARCH 2022
Investigations Division LOG NO. 2020 - 0002942
TO: Yolanda L. TALLEY
Chief
Bureau of Internal Affairs

FROM: Julio C. GUEVARA #2122


Sergeant
Bureau of Internal Affairs
General Investigations Section

SUBJECT: Synoptic Report - Relief of Police Powers

MEMBER: Lieutenant John M. CANNON


Star #412
Employee #
Unit: 005th District
C/S: 13 APR 1998
DOB: 1971

LOCATION: 3510 S. Michigan Ave. (Unit 121 - Bureau of Internal Affairs)

On 09 MARCH 2022, the undersigned was instructed by Lieutenant Matthew D. PRICE


#794, of this command to meet with Lieutenant CANNON for the purpose of notifying LT
John M. CANNON #412 of his duty restrictions pending the outcome of the investigation
of LOG No. 2020 - 0002942.

At approximately 1005 hours, the undersigned met with Attorney of the


PBPA who assisted LT CANNON to Unit 121- Bureau of Internal Affairs. LT CANNON
was to be relieved of his police powers by the authority of Chief Yolanda L. TALLEY of
this command. The undersigned presented LT CANNON with a Notification of Duty
Restrictions form and notified LT CANNON of his duty restrictions at 1015 hours. LT
CANNON acknowledged the notification of restrictions by initialing next to each line as
the undersigned read them aloud. LT Jonathan C. RECKARD #348, LT PRICE #794 and
Attorney , were present as witnesses.

The undersigned presented LT CANNON with an Equipment Transaction Receipt form


upon LT CANNON surrendering his Chicago Police Department star #412, shield and
identification card. LT CANNON acknowledged surrendering his Chicago Police
Department equipment at 1017 hours.

LT CANNON was relocated to the Human Resources Division - Unit 123 for the purpose
of obtaining a temporary identification card and reassignment (SGT. JOHNSON #904).
SGT JOHNSON was tendered a copy of the Notification of Duty Restrictions (Sworn
Member). LT CANNON was reassigned to the Alternate Response Section - Unit 376.

Page 1
BUREAU OF INTERNAL AFFAIRS 09 MARCH 2022
Investigations Division LOG NO. 2020 - 0002942
Officer Kevin GRAHAM #18453 Employee Assistance Program Professional
Counseling Division - Peer Support Unit 128 was contacted at 09:40 hours.

Julio C. GUEVARA #2122


Sergeant
Bureau of Internal Affairs
General Investigations Section

APPROVED:

Jonath n C. RECKARD
ffrr
Lieutenant
Bureau of Internal Affairs
C / 0 — Special Investigations Section

Page 2
NOTIFICATION OF DUTY RESTRICTIONS (SWORN MEMBERS) DATE oof Af( z rl
CHICAGO POLICE DEPARTMENT
TO: \ NAME OF MEMBER STIO NO. EMPLOYEE NPD. UNIT OF ASSIGNMENT
Jolivn
COMitIDINGX .VIsz
- 4'cl\NOI)
iC!F MEMBER
tl 5-5e D

FROM: CHIEF, BUREAU OF INTERNAL AFFAIRS


Pending the conclusion of the investigation of this Log Number and based on the authority vested in me by the
Superintendent of Police, you are hereby directed and expressly ordered by me as follows:
(C PPLICABLE BOX(ES) AND HAVE THE ACCUSED INITIAL IN THE SPACE FOLLOWING EACH BOX)
You are not to carry a firearm or any other weapon.
If so ordered by the courts to surrender firearms, it is your responsibility to immediately make
arrangements to surrender any firearms in your possession.
You are not to exercise the power of arrest or any other police power bestowed upon you by virtue
of your employment as a sworn member of the Chicago Police Department.
You are to surrender your Chicago Police Star, Shield and Identification Card as directed.
You are not to drive or operate any Departmental Transportation Equipment which will include but
not be limited to: motor vehicle, watercraft, bicycle, or any electronic powered transportation
equipment except as directed by your Commanding Officer.
You are not to attend or testify in any court in the capacity of a Chicago Police Officer unless
subpoenaed.
You are to obey any orders given by any supervisor of the Chicago Police Department.
If incarcerated or held over to bond you will be carried in a no-pay status until you notify your
unit of assignment of your choice to use elective or compensatory time.
You will report to (unit) on ,2 at (hours) as ordered.
❑ 10.

NOTE: These duty restrictions do NOT relieve you of your court appearance responsibilities regarding your inability
to attend court as set forth in the appropriate Department directives. In addition, you are to notify your Commanding
Officer of any forthcoming court appearance, Grand Jury hearing or other governmental hearing in which you are the
complainant or a witness or otherwise required to testify.
This order will continue until further notice. Violation of this order will subject you to disciplinary action and may be
used as the basis to bring charges against you seeking separation.

A., J4. .4 e± or.% f 4 , acknowledge having received the above stated order given

by • C- \ievo,v-6\ tt on 9 .0.4-e o.0- at /6 :


E)
WITNESS SIGNAT

TO COMMANDING OFFICER OF ABOVE MEMBER: This is to inform you that the above listed Department
member currently assigned to your command has been relieved of Police powers. The above listed restrictions
have been placed on the member and will remain in effect until further notice.
All supervisors of your command will be informed of the restrictions and will take immediate action if violations are,
noted. If the member is transferred or detailed to another unit within the Department, immediate notification will be
made to the Bureau of Internal Affairs at 745 - 6125, PAX 0602.
NOTE: When a member notifies you of a forthcoming appearance in court, at a Grand Jury hearing or
other governmental hearing as a complainant or witness, it will be your responsibility to notify the
appropriate attorney of the member's duty restrictions and duty status.
RECEIVED NAME RANK LOG i\ ,3
-,..) _000
COMPLAINT CATEGORY/COMPLAINT CATEGORY DESCRIPTION

DATE
(516 \A"V--t 16cW ACMe&kNU
TIME
?>vc-1
'ATTACHMENT NO.
non Al Onito..... 01141 1.11., +.11.1.1.10.... 11).11.4..\ CH.. IV...H..... I . ..sr...v....4:w.. in;
DATE
EQUIPMENT TRANSACTION RECEIPT
HUMAN RESOURCES DIVISION
CHICAGO POLICE DEPARTMENT 0( kAk-f),
NA E (LAST - FIRST - M.L)

L.-A-1\1 )\/ 0 0 .---Ci l f\V\ 1J \


STAR NO. EMPLOYEE NO. UNIT NO.
11_._ VC' 1"-C-
TYPE OF EQUIPMENT TYPE OF EQUIPMENT RETURNED
(CHECK ONE) (CHECK ALL THAT APPLY)

rt SWORN

EXEMPT
El CROSSING GUARD
I TAR (SERIAL NO.)
SHIELD (SERIAL NO.)
IDENTIFICATION CARD
❑ I.P.R.A ❑ BADGE (SERIAL NO.)
El OTHER (EXPLAIN) ❑ OTHER (SPECIFY)

TYPE OF TRANSACTION (CHECK ALL THAT APPLY):


El LOST SHIELD NEW NO SERIAL
0 LOST STAR, NEW NO. SERIAL
❑ STOLEN SHIELD NEW NO. SFRIAL
0 STOLEN STAR NEW NO. SERIAL
❑ RECOVERED SHIELD NO. SERIAL
0 RECOVERED STAR NO. SERIAL
El STOLEN BADGE NEW NO. SERIAL
El LOST BADGE NEW NO. SERIAL
RETIREMENT STAR ISSUED YES OR NO SERIAL
El RETIREMENT
CI
El RETURN TO DUTY El RESIGNATION
0 EXCHANGE NEW NO. SERIAL 0 OTHER (EXPLAIN)

EQUIPMENT TO BE PLACED ON HOLD FOR: (CHECK ONE)

❑ DPR EI LEAVE OF ABSENCE 0 PAB It ADMINISTRATIVE HOLD 0 MILITARY LEAVE


COMMENTS
oplcone Wed 6
ra 2 4z_

EQUIPMENT RETURNED BY: (PRINT NAME) (SI DATE/TIMW NO.


I UNIT
EQUIP ENT CE
C vEis?
) BY: (PRINT NAME) , (SIG DAT M UNIT bJ0.1

EQUIP ENT C, D BY HUMAN RESOURCES DIV.: (PRINT NAME) (S D TE/TIIV1E

77XC 1 -C-(vA}
E UIPMAIT ISSUED BY HUMAN RESOURCEp DIV.: (PRINT NAME) (S
E‘'' 7 Aec-g 2 ,:..2._
DATE/TM E
iL...)47L, it. . /6--.4.4, S-' Al,) ‘, 9 A4a , P) ol_
THIS SECTION IS TO BE COMPLETED ONLY WHEN EQUIPMENT IS LO ECOVERED.

R.D. NO. CLASSIFICATION IUCR

DATE OF REPORT A.M.F.N. NO. DISTRICT OF OCCURRENCE

WHERE. IF NOT CHICAGO CLASSIFICATION REPORT NO.

CPO-62.141 (REV. 10/10)

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