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KELLEHER&BUCKLEY, LLC 1025, Wns PanE De. | Nowra axancre I 6010 Davo P Bucky, 3, D,CPA! ‘ever, D ‘CamISTIANT, Deve, LD? aa aati Eee a nine ta epi eel Rom, Kinin. Floto, Cater & Wiscons? Press Release Melodie Oliniewiez is thankful for the ongoing lave and support provided by so many fiends, neighbors and community members. Even with this comfort, words sill cannot desrie the depths of Melodies ongoing pain and hardship eaused by the Sudden death of her husband and ‘watching her children suffer ftom the loss oftheir father. Melodie respectfully requests that the community, law enforcement, pension board and press reftain from rushing to, ot mispacing, Judgment, Melodie has faith that the tuth will come out in time, and if necessary, in court Relating to Melodie's attached cour filings, sometime on November 6, 2015, the Lake County State's Attomey’s Office, without notice to Melodie or her attorneys, and without probable eause, obtained a “fieeze order” restraining Melodie's avvess to her personal checking and savings accounts, Melodie and her counsel were dismayed to discover the existence ofthe freeze order ater Melodie unsuccessfully tried to purchase gas to fill up her ear on Monday, Novenber 9, 2015. [At this time, Melodie is unable to pay her ongoing mortgage, doctor bills and other fly ‘expenses, Therefore, Melodie has been forced to file the attached motion seeking a prompt hearing and lifting ofthe temporary court order that is freezing Melodie's personal checking and savings, accounts. Melodi’s attached motion addresses incomplete items contained in an affidavit from th Lake County State's Attomey's investigator concerning Explorer account funds. The investigtor’s affidavit stated that $26,800 of direct deposits went into the Explorer account from the Vilage of Fox Lake. The investigator's affidavit omitted the fact that this $26,800 amount was paid over a five year period ftom Melodie's husband's net paycheck and not fom the Village, The investigator's affidavit also referenced a $32,000 deposit into the Explorer account from [Nationwide Retirement Solutions on January 10, 2014, The investigators affidavit ome that ‘this $32,000 was deposited into the Explorer account by Melodie's husband from a loan he took cut from his own retirement plan, This January 10, 2014, $32,000 deposit also preceded her lnusband’s March 26, 2014 withdrawl of $7,000 from the Explorer sccount, ‘Again, Melodie respectfully requests that all refrain from rushing to, or misplacing, judgment. “Melodie has faith that the truth will come out. At ths time, Melodie and her attomeys will at be providing additional comments or interviews beyond the scope of this press release ani the attached cour filings. Melodie respectfully requests the press and public to respect her family’s privacy. Androw J. Kelleher, I. Hon, Henry “Skip ‘Vasil. Russis STATE OF ILLINOIS) i )ss agi COUNTYOFLAKE ) IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, LAKE COUNTY, ILLINOIS. IN THE MATTER OF FREEZING: ) BMO HARRIS BANK Accounts held ) oops “r,s by Charles J. Gliniewicz and/or ) ©. STEN DK: Fox Lake Police Explorers or ) GENERAL No. WA 966 Fox Lake Police Association, andlor ) Melodie Gliniewicz, being BMO Harris) Bank Account Numbers: ) 4816437916 and 0199003686, } MoTion pursuant To 720 1L0s sizeB-1¢n(2)_ (Ls) > FOR NEARING AND LIFTING OF TEMPORARY ORDER [Now comes MELODIE:GLINIEWICZ, applicant, by and through her attorneys, KELLEHER & BUCKLEY, LLC, end SMITH, LaLUZERNE & HARTMAN, LTD,, and pursuant to 720 ILCS 5/298-1(9(2), requests a hearing to lit the temporary restraining Drder mislabeled as a “reaze order" entered on application of the Lake County Sisi's ‘Attorney's Offiee on November 6, 2015 and states in support of said motion as follows: 4. _ On November 6, 2015, a “freeze order’ was entered by Judge Betar as fo BMO Harris Benk account IIE, see attached order. 2, Melodie Gliniewicz Is the ouner of the aforesaid account 3, _ The applicant, Melodie Gliniewicz, was not glven prior notice ofthe application by the State for an order pertaining to this account, 4, The order is defective and the application provided to the Court including the affidavit are deficient under 720 ILCS 5/298-1(1)(2) and must as a matter of law be stricken and held for naught in that ‘a. The application and affidavit in this mattor was signed by \Willam Biang, aninvestigetorwth the Lake County State's Attorney's office, notamember of the Department of State Police, Pursuant to 720 ILCS 5/298-(e), only the Department of State Police is authorized to serve seizure noices, warrants, subpoenas and summons Under the authority ofthis statute. Page t of § b. Although the freeze order’ and affidavit executed by Mr. Bang do not reference the precise section of statutory authorly forthe November 6, 2015 over, {the only section which permits action without notice to the owner ofthe account is 720 ILCS 5/298-1(1(2) entiled Protective Order. Under this provision the State may seek “omporary restraining order if the State demonstrates that there is probable ‘cause to belleve that the property with respect to which the order is sought would be subject to forfeiture under this eection, and ‘that provision of notice will jeopardize the availabilty of the property for forfeiture. 720 ies 67298-10902). {As the State has not and cannat demonstrate probable cause under either of the above requirements, the order must be stiicken DEFICIENCIES OF BIANG AFFIDAVIT ‘The alfidavit of Me. Blang is decent as to both requirements ofthe statute. A. _ The affidavitis not even addressed tothe financial institution sted on the “freeze order of Novernber 6, 2015." The order's directed to the applicant's account ‘at BMO Harris Bank but the affidavit asserts in two places that he funes sought tobe the subject of the Cour’s order were held at US Bank, NOT BMO Harris. The Court never should have issued the “freeze order" based upon an affidavit executed misidentyng the financial institution. This fs no different than making application for a search warrant and listing the wrong address on the affidavit for the property to be searched, see People v. Urbina, 393 Il.App.3d 1074 (2" Dist. 2008), whare the Appellate Court held that a wrong tnitnunber ona search warrant fora particular address was grounds to quash the warant 8B, The affidavit does not meet the requirement of showing probable ccause that the property would be subject to forfeiture. The application and affidavit donot reference any subsection ofthe statute that would constitute the criminal offense of money Jaundering. There are approximatsly ten diferent provisions under 298-t(a) that ‘constitutes the offense of money laundering, the State provided the court a three paragraph affidavit of Mr. Biang os to the applicant, Melodie Glniewicz, never staing probable cause as tothe offense of money laundering +. Paragraph 1 slates that the largest source of funds inthe ‘account are drect deposis from Fox Lake (presumably the applicant forthe order meant the Vilage of Fox Lake and not the geographic ares of Fox Lake but the affidavit doesnot Page 2 of § stato thal). Paragraph 1 notes that these are bi-weekly deposits in the amount of $2,000 ‘each. The paragraph does not alege that the deposited funds ar the result af a vdaton ‘fany section of the money laundering statue, and further, the State could not propery siege thatthe deposits were evidence of money laundering, tnese direct deposits were a orton ofthe applicant lat husband's salary. (It should be noted that tis informaon fn thase deposits was within the contol and knowledge ofthe Vilage of Fox Lake). As ‘ated, paragraph 1 dé ot allege anything that would ise tothe level of probable cause topatiove the propory in te aocount woul be subjctio forfeiture andi relevant oan rounds fora temporary resvaning order, (92), oF protective order () under te sat 2. Paragraph 2 of the allegation to the mis-identfed account alles that Charles J. Gniewicz (not the applicant Melodie Gliniowicz) deposited $7,000 Incash into this account on March 27, 2014. The affidavit goes on to state that Charles 4. Gliiewioz had the day prior withdrawn $7,000 from an Explorer account at US Bank, fending in account 3740. Nowhere inthis affidavit orn other affidavits fied inthis mater ‘does the State indicate how this transfers a violation of the money laundering statu. In fact the State's application identified account ending in 740 at US Bank as “acoount ame Fox Lake Explorers/Charles J. Glsiewlcz" and identifies the source of funds as “checking for individuals and organizations made payable to the Fox Lake Explorers program. This allegation again does not allege any violation of money iaundering statutes ‘and falls to identity who the ovmer of the funds 1s, other then Charles J. Glnievicz. Accordingly, as paragraph 2 of the atfdavit alleges that Charles J. Gliniewicz withdrew 57,000 from an account where he was sted as an owner and moved it into his wie's account, there Is no criminal allegation contained therein. The only allegation of erminal Conduct ie when the affidavit states tha the tranefer “may be indicative of inten to conce the activiy”. What a transfer “may be indictave" of snot an allegation that would support ‘a determination that probable cause exists that the crime of money laundering ocoutred and that Melodie Gliniewicz is guity of thet offense. 3, _ Having falledto allege with any specify the transfer of $7,000 fon March 27, 2014 was criminal in any way, the State then proceeds in paragraph 3 ofr. Biang’s affidavit to assert that between August 2013 (some 7 months before the $7,000 tranefer) and August 2015, Melodie Gliniewicz wrote four checks to US Bank Expirer ‘account (ending with 3740} totaling $8, 190.52. It should have been unclear tothe Court hhow this allegation was "probable cause” of a crime. The only date referted to in paragraph 3 Is December 22, 2014 when a check cleared; the paragraph goes on to sate that this wae “four monthe after the Hawall vacation was funded via the Explorers 9740, accounts.” Only by conjecture, guess and speculation - NOT PROBABLE CAUSE - could 2 court find that the $7,000 withdrawal on March 27, 2014 was a criminal act and that ‘Melodie Gliniowicz was eware ofthe criminal act, or how the affiant determined that the payment of $4,276.72 made on December 22, 20’ was for something four manths pr. Finally, reimbursement would indicate no criminal intent exists to permanently deprvethe (owner of property Page Sof 5 ‘The affidavit taken in full does not suggest probable cause thatthe crime of ‘money laundering was committed by Melodie Giniewz, does not allege who, other han ‘Charles J. Giniewicz, was the ovner of the Expiorer account 3740, and does not alege that Melodie Gliniowicz's account 3696 at BMO Harris Is subject to forfeiture under the money laundering statute. It ehould further be noted that inthe State's affidavit as to Fox Lake Explorers/Charles J. Gliniewice (US Bank account 3740 and credit card 8748),the State acknowledges (a) direct deposits from Fox Lake totaling $26,800 since December 2009, and (b) a single deposit of $32,000 from Nationwide Retirement Solutions on ‘January 10, 2014. Evidence will show thatthe $26,800 were crect deposits from the net ‘salary due to Charles J, Gliniewicz from the Vilage of Fox Lake and that the $32,000 was ‘Charles J. Giniewicz’s funds from a retirement plan loan taken by Charles J. Gniswicz from his own retirement account. Accordingly, $58,800 of the money in account 3740 ‘came from Charles J. Gliniewicz. (Again, the information of which was within the coral and knowiedge of the Village of Fox Lake.) Also of note is thatthe same affidavit states that account 3740 was closed on Apri 1, 2016, yet inthe affidavit seeking to reeze" the applicant's funds, the affant s stating, oddly enough, thatthe applicant was writing checks to this closed account untl August 2015. “The State's pleading does not and cannot accurately state that the $7,000 withdrawn by Charles J. Gliniewicz from account 3740 was not part of the $58,800 (or ‘ther amounts) that Charles J. Glniewicz deposited into account 3740. There was no “money laundering" as to ths $7,000 transfer, as one cannot launder one’s own money. ©. Jeopardy of Avaliilty of Funds. As to this statutory requirement for 1 temporary restraining order under (N(2) of the money laundering statute, Mr. Bang's ‘affdavitoffers nothing. The pleadings ofthe State totally ignore the statutory mandatethat the State demonstrat that: ‘That there Is probable cause to believe that the properly with respect fo which the order is Sought would be subject to forfeiture under tis, ‘section and that provision of notice wil jeopardize the availabilty of the property for foreclosure, 720 ILCS 5/20B-1(9(2), “The more conclusory language of the Cout’s November , 2016 oder that the Court was “satisfied thatthe afidavt before me established probable cause to bolleve that the subject property so described is subject to forfeiture under 720 ICS 5/29B-1 and that grounds exist forthe issuance ofthis protective order" does not sais the statutory mandate under subsection (N(2) thatthe State must show that absent the cenity ofthis order the property may not be available. “The owner ofthis aecount in question, Meladie Giiniewiez, isa 61 old ‘widow with three children at home, one of whom Is a sophamare at Antioch High Schoo}, She has a home subject to a eubsiantal mortgage relative to the fair market valve of the Page 4 of § home, and is seeking retirement bensfs due her late husband, The State does notalage ‘hat Melodie Glinlowiez has threatened tn cose the account and fee th uriscetionorfhak the funds are in jeopardy. The grossly insuflent aidaute ofthe State have left Waoiie Glinjowicz without assets to put food on her table orto pay hor mortgage, an if teste 's going to use this extaorainary scion, it should be required to fofew the statutory ‘equirements {0 epek not a"reaze orde but a tomporaryrostraning order reer 720, Les 81298-10902) WHEREFORE, applicant, MELODIE GLINIEWICZ, prays this Honorable Court to immediatly Ii the temporary restraining order mischatactorzed as a "ez order entered November 6, 2015 and to slaw Melodie Glniewicz aon0ss to her propa Respectuty submited, KELLEHER & BUCKLEY, LLC CHARLES w. Suite ANDREW J. KELLEHER, JR. (6229687) HENRY . TONIGAN, I (2844139) YVASILI D. RUSSIS (6230171) KELLEHER & BUCKLEY, LLC 02'S, Wynstone Park Drive, Suite 100 North Barington IL 60010, earre82-9190 CHARLES W. SMITH (02641278) SMITH, LaLUZERNE & HARTMAN, LYD. (432881) One North County Stet ‘Waukegan, tinols 60085-4903, BaTITT8TIO0 Page 8 of § |N THE CIRCUTT COURT OF THE 19TH JUDICIAL CCU TARE COUNTY, ILLINOIS IVTHE MATTER OF FREEZING: JP MarganiChase Bank Accounts eld by Cares 1. Gliiowicz “Andlor Fox Lake Police Beplorrs or Fx Lake Polio Assia, ‘Ander Melado Gisiowics,bsing 1P Morge/Chaze Bank Acton Arodited wih tel socal eet a oS 2 APPLICATION AND AFFIDAVIT FOR FREEZE ORDER “Tals mater coming before the court, L Wil Bing, Investigator of he Lake County ‘State's Attorneys Ofc, being duly sworn tates a oli am la enforemeat offer forthe Lake County State's Atoms’ Office aad have season to allow that nse Cony of Lak, Sse of ling te above deserbad propery abet. {o pretuctive order ander frit pursuant 720 LCS 3293-1 fora violation of Mey TEzundrig, the fate which waren» ining of robsble cause er unc ofa potetve oder or ‘Sauce marten, prsont o 725 LCE 5295-1, are lle 1. You fant states on September 1, 2015, Fox Lake Paice Offices responded woe ir sssstance afer thos rbjote ron fom Fox Lake Our, Lx Joseph Glewes, Upon ev « {Sinshot wis hoard da short me later L.Giewiez was osated ia Wooded urea soto death ‘2, Your sian sates hat Lt. Cliniowse dent bas ioe bean rl sco by tho Lake ‘County Coroners Office ey ovienee showed tht bal aun shot Sion Wis ls vm wespon, ‘ne it he potosive ve and ono in tha upper let re hs ors 43, Your aan state hat Lt. Glislowioz aa he Explorer prota forthe Vilage of Fox Lake, which es youth program for tens rstd in av enforcement, 44, Your afin sites hat wit messages and Facebook mesiges were reovered which inicued ha Clio ad i we Melodie Glnievoy exert uauhorend corel over Rid belonging the For Lake Explorer roman. Said messages ale showed tat there was eo ongoing ‘Ea beeen Gliniowiea andthe Fox Lake Vilage manager ove tn us end management of Explorer finds, 5, Your fin: sts tat he long inventive dea are the result of analysis of US ‘Banfcrevard and fei ead er, nclasing manly sttemens, cancel check, dept lips feet folowing accounts; Bask Accom umber Name US inc MMM FSET le Explor Cis. Gsewicz USEsk ENN Charles J. lisiewize US Bank NNN Chae iiniowien USBink NNT Fox ke Polos Aszoesion Mii — Fox Lake Eeplarr Post 300 i Melee Gisiowisz Cardcommany CardNumbee Name on Cad USSank MNO Fe [ke PolloeFxplores/ Charles J Gtnewice USSank — NNN Charles Giniewisz Fox Lake Bxplorers/ Charles J. Gliaiowiss~ US Bank account-3740 and ereit card 8748 Soweesof Fumi “Theprimary source of funds deposited to the US Bank account ended 3740 Inthe name of Fox Lle [plorrs/ hates J. Gleewce("Explorrs-3740)inaded checks from individuals and corgeizations made payable to the Fox Lake Repos program (269 checks toting $100,115.55). ‘Thee conssted primary af dratlon ror eal businesses, payments for service rendered .e, “pating lot soa), nd chests which spar ob fom pans enoling tui ellen inthe ‘Beplover prog 1 account alee reflects 204 depos toring $3289.97 nom he Vluge of Fox Laks and rele ies, Tie total eons of sect apoio Fox Lak ($26,800.00), checks fom tho Vilage ‘of Pox Lake made payable batho tha Explove program (3 checks totaling $7,551.25) well ast ‘Charles. finiowies (6 chock tuling 33,342.60). Choi tothe Explore: progam fom the Fox Take arse Chaba of Commere nda end ihe Pox Lake Volunteer Deparient tale $5,596.00, “The test deposts from Fo Lake bogus In Deserbur of 2009 with weekly depot of $50,The bekly dope then increased $75 satig lune 2010, $100 stag in Novernber 201, $150, ‘arn i November 2012, $25 sturtng i May 2013, $300 stating a Decobet 2013, as Really {o $480 (Maren 2014 - March 2015) Overall, et deposits fom Pox Lake wale $2500.00 he eccoot also reeled a single $32,000.0 depos ftom NATIONWIDE RETIREMENT SOLUTIONS on {10/2014, ‘Atta of 6 cash doposts to th account totaled $26,38.0, with telnet single depeit {(84,700,0) oecurng on 8/122018. Cah depos aveceped approximately 8430. oes of Pande -Reswetn September, 2008 an Apel 2015, ho account eppears io have bee welt cover eon ‘expenses on eonsizent bas. Thee included bok wus cures and signin prcases ‘Roun tsnsstions included Starbucks and Dunkin Donuts (238 tansuctions totaling $2485.19, estaurants (183 charges oaling $8,822 48, the Fox Lake Those (93 charge wuallng $2,515.75, ‘od ealth clubs, ele event rpstatin, end bemonal supplements (98 charzes oaling 5721692). Additionally there wer tal of 66 uansctions for adult etetalament nd dat weboles 62,623.52 charged otis ecout. 1m August 2014 «pt aval resulted in $5,683.59 in charges to this account exching were ‘The bank satements show a US Airs care of $2,079.70 on $/1/2014 which st ely soled tote Hawa wip, butthiscennet be conned based on bank records alone ‘cash widharewal rom the account between September 2008 an pel 2015 totaled $29,157.80. The Tangent exh witha (7,000) at mac via counter itl on 37267204. The ey ater hs ‘wlhdewal (3127/2014), $7,000 cash was deposited wo the BMO Haris bank acount in he ae Df Malus A, Gtiniice (686), Based onthe mathing amount an lose ng ofthis exh Withdwwal aid eubeequot depos, iappear tat he $7,000 was tanaferea fom the Explore = 3740 account othe Moai Oevcesoooun The anata of fds Vaca ay be inalenve of an effort o conceal te atv. (Noe: Approximately two wes er, Melodie Glinewion wrote $7,000 chek to heslf which appeal been doposed JP Morgan ‘Chase Bark on 4/4/2014 A subpoena bas bon sbed to IP Morgan Chase Bank epading my ‘secon under the contr] of Mledo or Charos Glee, nd th predusion Is pending) “The secount wi lso used to make sveral Gan payment the largest of which (6152345) nas student loan mae othe Departnet of Edzetin op 27142014 A total of 8495.48 vas pdm. {Cas Loan via 14 monthly payments of $0682 beeen Fbrusy 2014 and March 2015. Purher ‘nvestigaton ie equtes to datermine the purge ois oan. Closing of US Bank Account, Opening af BMO Haris Aesount (0n37272015 Gniwise wrote chock to teeter $000 fom the US Bank Explorer 3740 ‘count fo opea anew scout t BMO Harris Bank the nme of Fox Lake Explore Post 300. Five dij later (4/1/2015), Glinewiezwansfed the remaining tlance athe Explorer 3740 ‘Ecol B540 48) ois personal acount US Bank (9965) snd lose the Xplor 5740 Fox Lake Explorer Post 300 ~ BMO Harris account ~ 7916 Sinwoes of Punds “Th primary souoe of funds depo othe Fox Lake Explorer Post 300 BMO Har accout, pied 7916 CExpltere 7916) was ccs Eom Inlvidonls nd organizations made payable tothe ‘Explorer program (12 checks totaling $15,450, he largest of whch wes one $,000 chek rom he Lake County Flr Assoeation n August 2015, [AS26100 check fom te Melodie A. likes BMO Hares bak aodount (3696) as deposed {othe Bxplres-7916 acount in Apo oF 2015, The meme iw ofthe Seek conned the sto, “Pal inal” Uses of Funds ‘Berweon Marchand September f 2015 the most significant us of funds in the acount was tree payments PF Patbons totaling $6242.90. PF Petsboneapperso bee pelle supply store locate Fe Metiony, IL. One of thas payments wat nade via ches wth norms” notated inthe mao ne. Gnowicz aso wrote wo chock wlling $2746.62 to his perrnal wom t US Bank 598) ‘which pear obo relmburstments fr eat ard payer mate on the Fp eit aed Hag), “This secount appears to have bon used to over frsonal expense to dome extn hough to leer ems than he US Bank Beplorers-3740 eeaour. In Jos 2015, Glinjowiee wrote chert Doral ‘iiiewie for $777.00 with “oss” aotutod in the mero line ofthe beck. ‘cash withdcaval or the acount totaled 8111245, and charges to the acount incloed American ‘Aine (1 tranaction for $696.70), restzarans( ansusions totalng $613.87), Best Boy ( transsetone for $754.5), and grocery an eonvenanc sors (9 traneecton ttlng $98.7, mong other miselaneos charges, The purpose of hess expences and whether or nt hay ad tothe Explorer program annot be determined based on ban ecordsslons Charles J, Glintewicz personal accounts - US Bank accounts 599 and 1562, credit card 8805 ‘Afr Olinigwics closed tbe US Bank Faplree-$740 acount in Marc 2015, be opened two frreonl cosounts at UB Balin Ape F2D1S CSB80 snd 152) dion othe sey Eglo coun at SMO srs Honk. Sources of Funds ‘Bicwesky Fo Lake direct pasts which bad previously boen deposited tothe US Ban Bxplarer- 5740 account eps o have ese nth new US Bal person eeooent ended $999, These ‘wore the agert sure of funding to the woount (UI depots totaling 84,950), Two chock rm he BBMO Hans Explorer seco 7916) oling $2,746.62 vere depoied fois woo, which appa to have been embursoments fr payors bead from the 8989 secoun tthe Explore ‘elecard ended “£748, ‘The aeaunt ended -1562 show animal avy, wit nly our nfs of 50 or es besween ‘pil and August of 2015. These appear ave bess euomato ansfr between his eecoumt end ‘he other pesorl account ended 909. es of Funds “This pooount apport have boa used fr del lving expenses vehicle expense, fins li, movi theater esau, hal slo, ef) The most signifi we of finds wat payne to Cs, {one (S anstcuens toiling 83,640.52), Ciniewi'e personal eet rd ended 8805 lcs estan $2,000 in total charges The largest ‘pense category was alts event registration (37548), Those Were pul tothe Tough Mee Race aswell as CT Event Registration, wish eppearso be sac entrance fee collentn service, Melodie A. Glintewicz account -US Bank-3696 Sowess of Funds “Te lenges source of funding elected inthe US Ban account nthe name of Modi A Orisiewice was dec depos rom Fox Ll (5 deposits waling $109,569. These depose sveragod prendately $2,000 each and wor pald on -wecly bas (00 372772014, $7000 in esh was deposi to his account Ths occured th dy afer Cha J (linewies withdrew 87000 in ash oe th Beplores acount (US Bunke-3740), Therefore, sppent ely that he $7,000 in each was watered om the Explorer acount oth pan ‘oem. This eat rnsfr may be indole Finan fo conceal te acti Uses of Pent Between August 2013 and Augst 2015, Mlode Gliniowise wrote four choco the US Berk ‘Buplorr account (3740) waling 86,190 52. The lnget of there checks (84,275.72) reflets the ‘olaton "Hawa enue pin ul” Tis check cleaed on 1272/14, approxiatly Four mans ‘ortho Hawa! veson ve finded vs the Explorer 574D acco. Fox Late Police Assocation acount—US Bank-0751 does mot apg that Charles Gisovce was slaatory on this aeourt. The acount appa to have beg used pat nt eposory fr dotlons om ndividuals end lel basoeses ue ‘Sonus events such ae “Shap wih a Cop The agetcanveutr oth eacount was Dockers Dues (Gceheks totaling 86954940), se the moe lglian use of fond was Wal-Mart purcaoes (12 ‘payments tuling $47,908.76). ‘Asogle choc was yt to Madi Gtniewne in September of 2008 fr $175.00, with “Bagppst {br ferah neat nthe mem in. Asie Rom th check, hs acount des nat appear tobe ‘sociated with Chari. Glsowios or lode Olisewice “The sionoy held inl accounts esaclated with te JP Morgan/ChaseBenk secoums more fully desctbed stove have been wod inthe commision ofthe ofese of theft and money Taundering, Accordingly. itis herhy deed tht J Morgan/Chase Bank el Recs the stone is ey oedema eS ed Le ls : “Si of Aine Sues toand swom before on J“ 6°J ag eR Taber IN TUN CIRCUIT COURT OF THE 19TH JUDICIAL CRRCUIT ‘LAKE COUNTY, ILLINOIS IRUTHE MATTER OF FREEZING: [P Morphine Banke Accounts hod by Chaves J Glewice [nile tox Lake Polis Explore: or Fo ae oles Amosiston, ‘dor Madi nes bring IP MergvChase Hak Asounts Asosted wih Ber sotel cue nbs A FREEZE ORDER, TO: Investigator Will Blng of th Lake County Stas Atorey’sOfesand al ene ofs in Sue of ix hving before mes afi by Ive, og eso fo te at {Coury of Lake, Sat of ine tees crn propery, bang 7 egeChase Bek Account Nanbernsocated wit een oxtty ne A I, re uo Forti he Sus of nls ptoace 7a Mos Copel Sates SOD, taney 1 MorgarChase Bank Account ald by Cars J. Oiiewie ‘andlor Foe Late Poe Usplver or Fok Lake Poles Asosatin, ‘Ande Meodie Calg, bl 1? MorpulChase Bk Accounts socated with socal ‘ou ube oT un stad tat th dvi before me etait probable outset balve t th sujot property 1 dsb ig suet free unde TaDILCS 9293+ and en potas xis tbe sence oF ‘hs peeve ede. “THEREFORE YOU ARE HEREBY SUBIBCT TO: sid reurning onder roping the prop ‘pes above od ay eke anyon all acon to preseve he avai of ald propery Scie ‘Eat expense moe tun 30 dae afer th ton whieh tis enare, eles ts exec or oad ese ahwn, oc woles the pry tuna whom beware conus 6a extsion Yous ec ‘Siomanded io natiy the Oc of i Snes Aaa of Lake Count oh role bee, frovide whan vestry ofthe prope seized senate vale, ad thet, paren: tis 6 dayor_ 2704: 209

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