Professional Documents
Culture Documents
be}ieveGAYTANwasexplainingtoso],lsthathe(GAYTAN)was
attemptingto}eaveLheimpressionwithrepresenLativesofMcHugh
ConsLructionthatsol,lswastakingofficialact'iontoaidMcHugh
extracting financial support
construction, s project and anticipated
fromMcHughConstructioninreturnforthispurportedaction.
L2S.AccordingtofilingsforCit,izensforDannySo}iswiththe
IllinoisStateBoardofElections,onSeptember2g,20].4_thevery
samedaythat(i)GAYTANdiscussedhj-sreceiptofatextmessagefrom
..theguy,,associatedwithMcHughConstruction;(ii)GAYTA}Itold
McHugh Construction think
SOLIS was
SOLIS he (GAYTAN) would make
helpingoutMcHughConstruction..alltheway,,concerningthe
project; and (iii) SoT'Is advised
company's hotef anddata center
GAYTANtoteltMcHughConsLructionthathewouldcallaspecial
for the benefit of McHugh
meet.ing before City Council
ConsLruction_McHughConstructionmadea$l,500contribut'ionLo
CiLizens for DannY Solis '
i:2g. on or aboutOctober 7' 2Ot4'
at approximately 9:21 a'm'
on Target Phone 2 from
(CaII #94,.), soI,Is received an incoming calI
GAYTAN.Duringthecall,GAYTANadvisedSoLISthatindividualsfrom
McHughConstructionwouldcontinuetobackSo],ls.specifically,
GAYTANaskedSOLIS:..Haveyoustartedtodoanymeet.ingsyetwith
SOLIS indicated he had' and then
anyone for your campaign yet' Dan?'
GAYTANsaid:'.Well,theseguysfromah,theguysthatl.,vebeen
tellingyouabout,theonesfromthathoLeldeal,theywanttostarL
figuring out how to helP out ' GAYTAN indicat'ed "LheY" lwhich
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Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 4 of 26 PageID #:113
to refer to McHugh
believed SOLIS merely used the wrong name
ConsLruction.
' vi. Elgin SweePing'
1'32-Asd.iscussedinparagraphs55throughg0above'SOLIS
assistedElginSweepinginobtaininganexemptionfromawater
ordinancethatwould'haverequiredElginSweepingtopaya
significantamount,ofrevenuetotheCityofChicago.Further,as
notedinparagraphS5,aftersol,Isdiscussedhowhehadtakent'his
officialactionLoassisLElginSweeping,SOLIStoldRoBERToCALDERo
Chris CacciaLore,
t'hat he hoped. the President of Elgin Sweeping,
would.'remember,,SoLls,sassistance,andthend.iscussedtheamount
ofmoneythatCALDERowouldraiseforSol,lsfromChrisCacciatore
and'hisre]atives.Asnotedinparagraphg0,so],lssubsequently
receivedacampaigncontribut'ionof$5'400from'Jos'Cacciatoreand
Sweeping previously
Co. on or about September 2a' 2015' Elgin
on or about September 29 '
donated $2,500 to Citizens for Danny Solis
201"4.
D.DocurnentsConcerningPotentialContributorsandAttendeesat
theFund'raiserandtheofficia].ActionSoughtbyThem.
l33.Basedoninterceptedcal}s,IbelievethaLalegis}ative
Subject l,ocation l,
aide who works in SoLIS,s City HalI office,
preparedandmaintainedalistofindividuals/entitiesthat,solls
wouldseekcont'ributionsfrom,togetherwiLhCorresponding
informationconcerningtheofficialactioneachconLribuLorsought
from SOLIS.
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a34.Forexample,onoraboutJuLy2T'20L5'atapproximately
2 :45 p.m. (Session #A4g81) , SOLIS received an incoming
call on Target
phone 2 from a legislative aide, who was using a telephone tocated
within soLIS,s city HaIl office (subject Location 1) ' During the
cal1, SOLIS discussed his plans to call an individual for a
contribution. specifically, soIJIs said: "on the Michigan Group, who
are the, who is the guy that a, we're doing the Carmichael for
lunintelligibleJ, I forgeL the name." The legislative aide said:
..That, s going to be, that' s Tom Meador. I did'n' t know if you wanted
.Cause we haven,t
to hit himup yet, UIII, just .Cause there,s like,
settled the deal yet, or how you wanted to treat that one, so I haven't
put him on the 1ist. yet. But his name is Tom Meador, M-E-A-D-E-R'
D-O-R.' II believe t.he legistlative aide told soLIS t.hat he might
not. want to solicit. a contribut.ion from Meador yet because solrs had
not yet. completed official action on a matLer involving Meador''u)
soLIS said: .'Then his name is not here, it's, the names I got' here
are-oh yeah, Tom Meador. " The legislative aide said: "And Tom Moore,
Tom Moore is the attorney." soLIS shortly thereafter said: 'tThey
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contributionSoastopreventanyassociationbeingdrawnbetween
thedonationandSol,Is,sofficialactsbenefiLtingMeador.lThe
legislativeaidesaid:..Yeah,abso}utely,I,mSure.Helg,|hey,te,
Lhe,he'sgotlike25T'LCs"'SOI'ISsaid:*Andtheeventwon'tbe
untilseptemberl0Lh.,,SoTJlsalsoaskedthelegislativeaideto
providehim,inconnectionwithhisfundraising,withinformation
aboutwhatofficialaCLseachpartythatwouldbecontactedhadasked
sollstotake:..WhatIneed'inadditiontothatinformation,iswhat
isitthattheyareaskingfor'orwhatisitthattheywantmeto said:
said: "That's whaL I put-" SOLIS
aide
do-oh. " The legislative
"oh,okay,rgotiL'youdid'youdidthaL'"Thelegislativeaide
just to refreshyourmemory'"
havebeendoing that
said: "okay, yeah, I
bYe'"
SoLIs said: "okaY' alright'
10' 2oL5' at approximately 2:14 p'm'
135 - on or about
September
(Session#18553),soLISp}aced.anoutgoingcallonTargetPhone2 that
During the call' the fundraiser told SOLIS
to his fundraiser'
shewantedtocheckinabout,thatnight,inreferencetoS0I,IS,STaste
ofthe25t,hWardfundraisingevent',andalsoaboutt.henextWednesday.
Sollsinformedthefundraiserthat'hejusthadlunchwithBRIANHYNES,
whosaidhesentanemailouttohisnetworkandwouldfollowupwith
calls,ioreferencetosolicitingdonations.Sol,lsandt'he
fundraiserthendiscussedwhowasgoingtoattendSo],IS,sfundraising
eventthratnight,,andthefundraiserinformed.soI,lsthatthemayor
wouldnotbethere'ThefundraiserinformedSOLlsthat'shewould
90
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Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 7 of 26 PageID #:116
Waid Reg Dem Org," in reference to Lhe 25'n Ward Regular Democrat.ic
Organizat,ion (the "Ward Credit Card Account"). Statements for the
Ward Credit Card Account reflect that there are at least three
authorized users associated with the account,, SOLIS, GRACE PERALES
and Robert Klunk. InLerceptions over Target Phone 2 confirm that
GRACE PERALES is SOLfS's sister, and that Klunk works in some
91
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- a- - a
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funds
I believe SOLIS is utilizing
138 ' Based on the
foregoing'
organization to pay for his
Democratic
from 25th Ward Regular
personal expenses
statements
F. solrs,s False Exculpatory
fort'h below'" during the course of "" .n-person
l-39. As set l
meetingwithCs-].and.interceptionsoverTargetPhone2,solls,at
Limes,madereferenceLohisunwi}lingnesstoconducti}legal
activity.Asdiscussedbelow,Ibelievet'hesestatementsare
with or in
pretextua},astheyhaveoccurredduringthecourseofthecrimina}
Moreover' t'hey often occurred
conduct discussed above'
Lhecontextofind'ividualsaboutwhomsol,IsexpresseddistrusLand,
according}y,anunwillingnesstoengageincriminalactivitywiLh
them- SOLIS met
example' ofl or about October L7' 20L4'
l-40' For
privatelywithCs_].andBusinessman2,aChinesebusinessmanand
propertyd.eveloper.Duringthismeeting,sol,ls,CS-].andBusinessman
2discussedBusinessman2,srelationshipwithsol,Is,sformer
girlfriend.AformermemberofSoT,ls,sStaffactedasanEnglish
transfatorforBusinessman2d.uringthemeeting.Sol,lscJaimedduring
t:ll^:::t:,:j:"
that his former sirlfriend *"
the conversation
2. solrs also indicared durins ::"
the
,,"r,,essman
":: "":"J;r:], ,r, t.'"11 estate development
oII,
raxen--aJJi;; ; ii, ii ;*:;lqrrsr*i$lr:
,"rJ*rs Nadhmi
HyNEs
marrer"r"orhar s"r=i-"_.ir""
ffi ;; ;, 1 r. r: -is T
g1s, ooo-
f f"1"*";, ir*:ili
-
;='?""r"'*r -:::' : ;:
-"
".h"tl l.".orrrrr"non or "ooi,t 2/a6/2oLL-:^..;;. si""a 9n, the
,i|li\ZiJTir3;;;*ii'q;rh."-Ie',t.,'XXi.fu'f.TL""o,p","o,,aritems
i s- t::uti:tt.t".
f inanc iaf @LLs*r
trnartcrar anarYs-:ss
$l-5,000.
are well in exct "f
94
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Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 11 of 26 PageID #:120
solls did not want anything to d.o with his former girlfriend and
another individual. Businessman 2 informed soLIS that Businessman
2 had paid $100,000 to soLIS',s former girlfriend. solfs responded:
..wow., soLIS explained that he understood his former girlfriend was
me' And that
'.se11ing access to me, t.hat she would. bring people Lo
is true because she was my girlfriend, but I didn't know whether she
was being paid. she t.old me nobody was paying her anything'" soLIS
explained that it was "very common" for such pa)rments to occur (and
that. CS-1 had paid SOLIS's ex-chief of staff) but that such pa)rments
just me'
had t.o be disclosed publicly: "So that happens a lot, not
with everybody, but you can'L Iie about it'"'
95
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Uh, for some t,hese investors that are coming f rom China.,, The
prospective consultant said: "Yep." SOLIS continued: "But I would
never get any compensation for that, either directly or indirectly'"
The prospective consultant said: "okay. " soLIS continued: "Because
you, T, think when you guestioned'fs this legal?" I' you know'
absolutely, Uh, it probably would. not be legal, but even if it was
1egal and, it would be unethical. " The prospective consultant said:
.'Okay.,, SOLIS continued to note that "I geL compensation f or stuf f
I d.o be connected in washington, but not in chicago'" The
that may
prospective consultant asked. soLIS what the "nexL step" was' and
SOLIS replled.: "WefI, You know what'? Uh' you mentioned [name
redactedl . That's, LhaL's a possibility' The other possibility is
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Case: 1:16-mc-00261 Document #: 1-2 Filed: 05/27/16 Page 16 of 26 PageID #:125
yeah, right.,, SoLIS said: ..And' then [first name of SoLIS,s former
girlf riendJ t'ried to give iL over to her boyf riend?,, I{YNES
responded.,"Right."SoLISsaid:"Andah'sonowthey're'he'sback
in t.he picture on it. And..." HYNES interjected, "who is?
The
SOLIS continued'
HYNES said: " [Businessman 2] . Okay' Fine' Good"'
int,hecityand.Iwasgoingtotalktoyoubecauselwanttomake
thing
sure that if r go ahead and do this, LL, s t.he, it's the right
to do and thaL none of this...because tcs-1], he was involved,
involved in both, with both sides. weII, he was involved" ' with
when they
Ifirst name of sol]s's former girlfriendl and her friends
tried to recruit ICS-1] to get investors from China to take it away
from[Businessman2]andnowwhenhecouldn'Lraiseit'nowhe's
involved with [Businessman 2] ' But when tCS-11 was involved with
.[firstnameofSol,ls,sformergirlfriend]andherfriends,I
hadnot,YoUknow,Iwasn,tsupport.ingit'.Ithinklfirst,nameof
SOLIS, s former girlfriendl was just counting that I was going to be
I
able to do it, Eh, even though we weren,t together or whatever.
don,t know...But it just, it looks, it sounds fishy and I'mnoL sure
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I should go along with it. and that's why I wanted to talk to you about
it." HYNES said: "Okay. No, definitely." SOLIS said: "So, anYway
101
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records/Iedgers or receiPts;
g. Employee palrment records, to include IRS reporting
documents such as forms L099 or W2;
items.
i. Subject Location 1
L47. As further described in Attachment A-1, Subject Location
1 is SOLIS's Cit.y HaII office. On March 8, 20L6, CS-t visited SOLfS's
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andhisparticipationintheaffairsoft'heCityCouncifitis
reasonabletobelievethat,soI,lsmainLainswithinhisCityHall
that wilr be heard
office documents rerating to deveropment. projects
and have been heard.by the Zoning Committee,
inc}uding those projects
possession of documents
that are discussed in this affidavit. SoLIs, s
withrespecttothoseprojectsonwhichhehasagreedtotakeorhas
taken official action on is itself proof of
his participation in the
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105
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Democraticorganizationasapoliticalorganizationwithwhichhe
wasinvolvedandfromwhichhereceivesincomeinexcessof$1.000
theprecedingyear.so],]sident'ifiedSubjeeEl,ocation2asthe
ad.dress. of the 2Sth Ward Regular
Democratic organization'
Regular Democratic
154. As noted' above' tkre 25xn Ward'
organizationhasmaderegularreportstothel}linoisStateBoard
ofElecLionsconcerningmonetaryContributionsreceivedbythe2sth
Under law' reporting
Ward Regular DemocraLic Organization'
Democractic organizat'ion are
entities such as the 25t.h ward Regular
requiredLomainLain,fortwoyears,record.sconcerning(1)thetotal
contributionsmadetoorforthecommitLee,Q)thefullnameand
mailingaddressofeverypersonmakingacontributionandthedate
andamountLhereof,(3)thetotalexpendituresbyoronbehalfof
Lhecommittee,Glthefullnameandmailingaddressofeveryperson
towhomanyexpenditureismade'andLhedateandamount'thereof;
particulars' for every
and (5) proof of payment' stating the
expendituremadebyoronbehalfofthecommittee.Itherefore
amounLs of money and other
believe that documents detailing the
benefitsreceivedbySo}isand'theorganizaLion,theidentityof
iontributors,andthet'imingofthereceiptofsuchcontributions
and benefits witl be found within
subject Location 2' together with
1-46 above '
the other items specified in paragraph
155.Inaddit'ion,asnotedinparagraphs]-36throughl38,there
isreasontobelievethatsol,lshasLakenfundsfromthebankaccount
usedbythe25LnWardRegularDemocraticorganizationforhis
106
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ward Regular
personal use. It is reasonable to believe that the 25th
Democrat ic organization will- maintain records
concerning IegitimaLe
expensesincurredbytheorganizationinthecarryingonofits
politica}activities.Thisinformationisrelevanttothis
what are
investigation, because these records wilI tend to establish
permissible
permissible expendit.ures (and the reasons for those
expenditures)asopposed'tothepersonalexpensesofsoI,lsand
PERALES' that have been paid through the
use of organization funds '
156.AsfurtherdescribedinAt'tachmentC-l,SubjectLocation
3 is soLIS, s personal residence. The residence
is identified by the
number,,522,,affixed.tothewalladjacent.tot'hedoor'According
toutilityrecordsreceivedonoraboutAprilLg,2Ot6,.sOllsis
ident,if ied as the resident of record f or Sulrj ect
l,ocation 3 .
Location
According to lllinois secretary of state records, subject
26, 2o'l-5, as
3 is identified as solrs,s residence. on April 25 and
registered
welI as May 11-, 20:6, surveillance observed t',he vehicle
in which
to soLIS parked. in the front turnaround area of the building
Subject Location 3 is located'
l,5T.Basedonmytrainingandexperience,individualsmaintain
documenLsregardingtheirpersonalfinances,Ioans,andexpenditures
journals or
within their residences, Lo include (a) books, records'
records'of
other records of original entry; (b) Iedgers and other
assets, Iiabilities, oI capitat account balances; (c) records of
j-nvoices and receipts; (d) records of
income or expenses including
107
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records/ledgers or receipts.
158. Records concerning SOLIS's personal finances are relevant
to the investigation of the Subject Offenees for multiple reasons.
Among them are the following. First,, ds noted earlier in t.he
affidavit, thus far no evidence has been found to demonstraLe that
SOT,IS has paid for the benefits lavished upon him by others. Records
108
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109
t*a
:' '.1
at approximately B:55
at approximately g:05 a.m., on May 12, 201-6,
a'm' ' on May 25' 20A6
d.In., on May 17, 2015 at approximately 9:00
at approximately 8 :28
at approximately 8 :14 a 'm' ' and on May 26 ' 2016
d.ITI.,FBIsurveillanceobservedavehicleregistered.toSoI,lS}eaving
theparkinggarageatsubjectLocation4.FBlsurvei}lanceobserved
soLISaSthedriverofthisvehicleonApril25,20l.6andMayll,
20.,6,.and on other occasions was not able
to positivety identify the
driver.Althoughsurveillancewasunabletodeterminethedriver
oftheseotheroccasions,nooneelseotherthanSol,Ishasbeen
observeddrivingthisvehicleduringsurveillance.Withthe
observed
exception of May L2, May 17 and May 25' FBI surveillance
t,hevehic}eproceedtosubjectl,ocation3.Basedonintercepted
ConversationsinJutyandAugustof2ol-5,so],lsand.hiswifewere
workingtoresolvemaritalissuesandhadbegunlivingtogetheragain
afteraperiodofseparation.Atthesametime,so],lscontinuesto
maintainhisresidenceatsrrbjectLocation3.
and experience'
1-60. As discussed above' based on my training
individua].smaintaindocumentsregardingtheirpersonalfinances,
loans,andexpenditureswithint'heirresidences.Asnotedabove,
theWardCredit'CardAccounthasbeenusedforexpendituresthat
appeartobeassociated.withSolls,sfamily,toincludeschool
tuitionpaymentst'oSOLIS'sson'sschool'palrmenttoanorthodontist'
and.paymenLsforcookwareandchildren,sclothing.BecauseSoLlS,s
that at Subject
wife and son live at Subject Location 4, it is expected
that certain
I,ocation 4, there wilt be documenLs confirming
110