STATE OF ILLINOIS ) )ss. COUNTY OF WILL) IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT. WILL COUNTY, ILLINOIS INSPRECTOR GENERAL FOR ) THE CITY OF JOLIET ) Plaintiff, ) v, ) 23 MR 079 ) ) ILLINOIS STATE POLICE ) Defendant. ) WILL COUNTY STATE’S ATTORNEY'S PETITION TO INTE! NOW COMES James W. Glasgow, Will County State’s Attorney, by and through his assistants, Scott Pyles and Kevin Meyers, and request this Honorable Court allow him to intervene in the above captioned matter; and in support of his motion, states as follows: 1. That Illinois Code of Civil Procedure Section 5/2-408 provides that a third party shall be permitted to intervene in an action when that third party’s right is not or may not be adequately represented by the existing parties; and the third party will or may be bound by an order in the case, 735 ILCS 5/2-408(a)(2). Under this subsection of Section 5/2-408, intervention is not permissive, but as of right. 3. On March 14, 2023, the Inspector General for the city of Joliet filed the above captioned lawsuit against the Ilinois State Police (ISP). 4, This lawsuit is premised, in summary, on ISP's failure to respond to a subpoena issued by the Inspector General to its satisfaction 5. Furthermore, the Inspector General alleges that it needs to obtain information, through subpoena, from ISP to conduct an investigation into a dispute between Joliet Mayor Robert O"Dekirk and Former Joliet Councilman Donald Dickinson. P1.’s Comp. $13.6. Subsequent to the filing of this suit, Inspector General Sean P. Connolly issued a letter to James W. Glasgow seeking to inter rw State’s Atlomey Glasgow regarding the O'Dekirk/Dickinson matter. Movant's Ex. A. 7. It is clear from the letter to Glasgow and subpoena issued to ISP, these allegations investigated by the AG are one in the same, as the letter references ISP reports regarding Dickinson. 8. State’s Attorney Glasgow does not to intend to comply with any request to be interviewed by the Inspector General which is based on a clearly unconstitutional ordinance. 9. Presumably, the Inspector General will not simply request an interview in the future but may attempt to subpoena State's Attomey Glasgow. 10. As set out in the lawsuit, the Inspector General asserts that when it issues a subpoena during the course of its investigations, it expects that it will be complied with. Pl.’s Comp. 18. 11, The State’s Attorney believes that the Inspector General ordinance is patently unconstitutional and that even if properly constituted, an inspector general has no authority to issue or enforce subpoenas outside its respective unit of local government, 12, Therefore, there is a potential and reasonably likely conflict between the Inspector General and the Will County State's Attorney. 13, Intervention would be proper as the State’s Attorney's Office's interest would not be properly represented by cither Party. The Plaintiff is seeking information from the State's, Attomey and therefore, cannot represent his interest, furthermore, the State’s Attorney is not similarly situated to the Defendant as those entities have distinct interests due to thedifference in information being sought from each entity, as well as potentially different aims and theories defending the above captioned case. 14, Additionally, any ruling by this Court confirming the asserted authority of the Inspector General to issue and enforce subpoenas against non-City of Joliet entities would necessarily implicate the rights of the State's Attorney. 15, Furthermore, the petition is timely because as of the time of this filing no appearance has been filed by ISP and the initial court appearance date has not occurred. 16, Finally, allowing the State's Attorney to intervene would promote judicial economy and stave off repeated litigation on this matter, 17, Absent intervention, the State’s Attorney would have to file a quo warranto action to challenge the infirmities of the Inspector General ordinance. 18, It would be more efficient and would promote the public interest to address these matters ina single case. 19, If allowed to intervene, the State’s Attorney has a meritorious claim namely that the City of Joliet Inspector General ordinance is unconstitutional and any actions taken under that ordinance are therefore void, as further laid out in the attached proposed motion and memorandum. Movant’s Ex. B. 20. Therefore, allowing the State’s Attorney to intervene in the above captioned case would be proper. WHEREFORE, the Will County State's Attorney prays this Honorable Court grant his motion and grant the following relief: 1, Allow the Will County State’s Attomey to intervene in Will County case 23 MR 079; and 2. Grant any other relief this Court may deem just.Respectfully Submitted, JAMES W, GLASGOW Will County State's Attorney ger Kevin J. Meyers Assistant State’s Attorney S7N, Ottawa St., Ste. 501 Joliet, Illinois 60432 (815) 727-8626 Kmeyers@willcountyillinois.com By:AFFIDAVIT Under penalties as provided by law pursuant to section 1-109 of the Ilinois Code of Civil Procedure (735 ILCS 5/1-109), I certify that the above statements are true to the best of my knowledge and belief. eee aes Kevin J. Meyers150 WEST JEFFERSON STREET JOLIET, ILLINOIS 60432-4158 March 23, 2023 VIAU.S. MAIL & Email (jglasgow@uillcountyilinois.com) James W. Glasgow Will County State's Attorney Office of the Will County State's Attorney 57 North Ottawa Street Joliet, Illinois 60432 RE: _ Joliet Inspector General Investigation of Allegation of Donald Dickinson by Mayor Robert O'Dekirk Dear Mr. Glasgow: The Office of the Joliet Inspector General is investigating allegations made by former Joliet Councilman Donald Dickinson against Joliet Mayor Robert O'Dekirk. During this investigation, | received redacted copies of documents from the Iilinois State Police relating to its investigation of Mr. Dickinson's allegations against Mayor O'Dekirk Included in these redacted documents was an Illinois State Police Investigative Report entitled “Review of the forensic extraction of Donald Dickinson's cellphone.” The reporting agents for this report are S/A M. Merritt and S/A N. Schramka. This document states, in part, “S/A Merritt and | completed the review of the forensic extraction of Dickinson's phone and the following information was located (see attached):...¢ Text messages between Dickinson and Jim Glasgow and phone call log.” The Illinois State Police did not attach any of the information in referenced above as “see attached," I know you are busy, however, would you agree to be interviewed regarding telephone conversations you had with Donald Dickinson and text messages you sent or received from Donald Dickinson? We can conduct the interview via Zoom on a date and time convenient to you. Your cooperation would be greatly appreciated. QJames W. Glasgow March 23, 2023 Page 2 Please feel free to contact me by telephone at (331) 401-3730 or by email at sconnolly@joliet.gov. Very respectfully, Sean P. Connolly Joliet Inspector GeneralSTATE OF ILLINOIS ) )SS. COUNTY OF WILL ) IN THE CIRCUIT COURT FOR THE TWELFTH JUDICIAL CIRCUIT WILL COUNTY, ILLINOIS INSPECTOR GENERAL FOR ) THE CITY OF JOLIET, ) ) Plaintisf, ) ) vs, ) Case No. 23 MR 079 ) ILLINOIS STATE POLICE, ) ) Defendant. ) INTERVENOR’S MOTION TO I NOW COMES the Intervenor, James W. Glasgow, State's Attomey of Will County, through his assistants, Scott Pyles and Kevin Meyers, and pursuant to Section 2-615 and Section 2-619 of the Illinois Code of Civil Procedure (735 ILCS 5) -619), pray that this Honorable Court strike and dismiss the complaint of the Plaintiff, INSPECTOR GENERAL FOR THE CITY OF JOLIET, and in support of said motion, state as follows: 1) The Plaintiff has filed a complaint requesting compliance with a subpoena directed to the Illinois State Police. 2) Under section 2-619.1 of the Code of Civil Procedure, @ complaint may be dismissed either because it is insufficient in law (see 735 ILCS 5/2-615(a) (West 2020) or because it is barred by affirmative matter that avoids the legal effect of the claim (see 735 ILCS 5/2-619(a) (West 2020)). 735 ILCS $/2-619.1 (West 2020). Here, the issue is both whether some affirmative matter bars plaintiffs claim but also whether the complaint itself states a cause of action. See Lee v. Findley, 359 Ill.App.3d 1130,1136, 296 IIL.Dec. 632, 835 N.E.2d 985 (2005). Therefore, we must decide whether the complaint's allegations, construed in the light most favorable to plaintiff, establish a valid claim for relief. Sibenaller v. Milschewski, 379 III. App.3d 717, 884 N.E.2d 1215 (2008). 3) For the reasons stated in Intervenor's memorandum, the Intervenor argues that the City of Joliet inspector general ordinance (Code of Ordinances, City of Joliet, Illinois 2-505 et.seq.) is unconstitutional as it attempts to modify the powers and duties of the city manager contrary to holding of Pechous v. Slawko (1976), 64 II1.2d 576. 4) Furthermore, Intervenor submits that the complaint fails as it is brought by a non-entity and further fails to plead a valid claim as demonstrated by intervenor’s Memorandum. WHEREFORE, the Intervenor, prays that the complaint of the Plaintiff be stricken and dismissed. Assistant State's Attorney JAMES W. GLASGOW Will County State’s Attomey By: Scott Pyles #6208185 Assistant State’s Attorney 57 N. Ottawa Street Joliet, IL 60432 (815) 724-1318 spyles@willcountyillinois.comSTATE OF ILLINOIS } }SS. COUNTY OF WILL. ) IN THE CIRCUIT COURT FOR THE TWELFTH JUDICIAL CIRCUIT WILL COUNTY, ILLINOIS INSPECTOR GENERAL FOR THE CITY OF JOLIET, Plaintiff, vs Case No. 23 MR 079 ILLINOIS STATE POLICE, Defendant, INTERVENOR’S MEMORANDUM IN SUPPORT OF ITS MOTION TO DISMISS NOW COMES the Intervenor. James W. Glasgow, State's Attorney of Will County. through his assistants, Scott Pyles and Kevin Meyers, and pursuant to Section 2-615 and Section 2-619 of the Illinois Code of Civil Procedure (735 ILCS 5/2-619), pray that this Honorable Court strike and dismiss the complaint of the Plaintiff, INSPECTOR GENERAL FOR THE CITY OF JOLIET, and in support of said motion, state as follows: The Plaintiff has filed a complaint requesting compliance with a subpoena directed to the Illinois State Police. In large part, the Plaintiff is alleging that as Inspector General he has the power to issue 2 subpoena in this instance and is attempting to enforce compliance with a subpoena issued to the Illinois State Police. However, as more fully laid out below, the subpoena itself is invalid and thus unenforceable. This is because the involved Joliet ordinance unconstitutionally changes the form of government for Joliet by allowing the Mayor to appoint, supervise, and recommend removal of the Inspector General, rather than the City Manager as required by state law. Under section 2-619.1 of the Code of Civil Procedure, a complaint may be dismissed either because it is insufficient in law (see 735 ILCS 5/2-615(a) (West 2020)) or because it is barred byaffirmative matter that avoids the legal effect of the claim (see 735 ILCS 5/2-619(a) (West 2020)). 735 ILCS 5/2-619.1 (West 2020). Here, the issue is both whether some affirmative matter bars plaintiff's claim but also whether the complaint itself states a cause of action. See Lee » Findley, 359 Il.App.34 1130, 1136, 296 II]. Dec, 632, 835 N.E.2d 985 (2005). Therefore, we must decide whether the complaint’s allegations, construed in the light most favorable to plaintiff, establish a valid claim for relief. Sibenaller v. Milschewski, 379 Il. App.3d 717, 884 N.E.2d 1215 (2008). The Plaintiff, as alleged in this complaint, is investigating “accusations made by a Joliet councilman against the Joliet Mayor”. Putting aside the difficulties of the Inspector General investigating the official that appointed him (and can remove him) and also investigating the official that the Inspector General reports to as well, along with the fact the investigation concems accusations of a “former” council member, this matter is brought by an alleged official created by an unconstitutional ordinance, Finally, it should be noted that it appears that most if not all of the reports have been tendered via FOIA request, further showing the impropriety of this suit. THE ORDINANCE RELIED ON TO BRING THIS MATTER VIOLATES ILLINOIS LAW AND IS UNCONSTITUTIONAL The threshold issue is whether the Inspector General scheme, as put forth by the City of Toliet ordinances, is a valid exercise of power under the Illinois Municipal Code. The City of Joliet operates under the couneil-manager form of government. Any change to that form of government is governed by Article VII, Section 6(1) of the Illinois Constitution and must go through referendum. The City of Joliet ordinances recognize this form of government Sec. 2-22, - Form of govemment, corporate authorities. (a)Pursuant to referendum, the City of Joliet is organized as a council-manager form of local government as set forth in Article 5 of the Illinois Municipal Code (65 ILCS $/1-1-1 et seq.) as amended. The form of government of the city may be altered according to the will of the people in accordance with the Constitution of the State of Ilinois. the Illinois Municipal Code and theIlinois Election Code. Under the council-manager form of government, the city manager is the administrative head of government and is tasked with the enforcement of ordinances. The Illinois Municipal code provides as follows § 5-3-7. The council or board of trustees, as the case may be, shall appoint a municipal manager. who shall be the administrative head of the municipal government and who shall be responsible for the efficient administration of all departments. He shall be appointed without regard to his political beliefs and need not be a resident of the city or village when appointed. The manager shall be appointed for an indefinite term, and the conditions of the manager's employment may be set forth in an agreement, In the case of the absence or disability of the manager, the council or village board may designate a qualified administrative officer of the municipality to perform the duties of the manager during such absence or disability. The manager may at any time be removed from office by a majority vote of the members of the council or the board ‘The powers and duties of the manager shall be (1) To enforce the laws and ordinances within the municipality; (2) To appoint and remove all directors of departments. No appointment shal! be made upon any basis other than that of merit and fitness except that if the chief of the fire department or the chief of the police department or both of them are appointed in the manner as, provided by ordinance under Section 10-2.1-4 of this code, they may be removed or discharged by the appointing authority. In such case the appointing authority shall file with the corporate authorities the reasons for such removal or discharge, which removal or discharge shail not become effective unless confirmed by a majority vote of the corporate authorities; (3) To exercise control of all departments and divisions thereof created in this Article 5, or that may be created by the council or board of trustees; . 65 ILCS 5/5-3-7 (2020 as amended) As recognized in Illinois law, the city manager is the official tasked with the enforcement of ordinances and with the appointments of all officers of departments in the city. In addition, the city manager is empowered to remove said officials as well. The ordinances of the City of Joliet attempt to disrupt that statutory scheme. The Inspector General in this matter owes its existencetoa City of Joliet ordinance. Sec. 2-505. - Appointment. ‘The mayor, with the advice and consent of the city council, shall be authorized to appoint an inspector general. This position may be full time, subject to the parameters as set forth in this article or may be ad hoe for a specific purpose. Sec. 2-506, - Duties enumerated (a) The inspector general shall have the following powers and duties: (G) To report to the mayor concerning results of investigations undertaken by the office of inspector general; (c) The powers and duties of the inspector general shall extend to the conduct of the following:(1) Except as limited in this article, all employees and all elected and appointed officers of the city government in the performance of their official duties: Sec. 2-511. - Inspector general—Removal. (a) The inspector general may be removed in accordance with the provisions of this section, The mayor shall give written notice: (1) To the city council of his intent to remove the inspector general; and (2) To the inspector general Code of Ordinances, City of Joliet, Illinois 2-505,506,511 Under the above ordinances, the mayor appoints the inspector general, the inspector ‘general reports to the mayor and it is the mayor that recommends the inspector general’s removal That runs counter to the Illinois Municipal code insofar as the city manager is the appointing and removal authority and that the city manager is responsible for the enforcement of ordinances. 65 ILCS 5/5-3-7. In fact, the City of Joliet’s own ordinances confirms this basic principle: Sec. 2-29, - Powers and duties enumerated. ‘The powers and duties of the city manager shall be: (a) To enforce the laws and ordinances within the city. (b) To appoint and remove all directors of departments. No appointment shall be made upon any basis other than that of merit and fitness. (c) To exercise control of all departments and divisions thereof created in this Code, or that may be created by the city council. Code of Ordinanees, City of Joliet, Illinois 2-29 ‘The most significant characteristic of the managerial form of municipal government is that the ‘municipal manager * * * shall be the administrative head of the municipal government.” 65ILCS 5/5-3-7. The city council (with the mayor as a member) has no powers with respect to administration. he statute provides: “Ihe powers of the council or board shall be purely legislative except as may be otherwise provided by any other act or by any article of this Code other than Articles 3 or 4." 65 ILCS 5/5-3-6 (2020 as amended). These statutory characteristics of the ‘city manager’ form of government are not unique to Illinois. “It is basic to the city manager form of government that the council shall be the policy-making body, and the manager the chief administrator. Unless otherwise provided for by statute or charter, the council does not and should not attempt to dictate or confirm appointments of city officers and employees, nor importune the manager on appointments, or indeed on any other administrative matter.” 56 Am.Jur.2d Municipal Corporations sec. 186 (1971). Pechous v. Slawko is factually analogous to this case. It concerned ordinances passed by the City of Berwyn and the Village of Oak Lawn. In each case, the ordinances were enacted by the municipality's legislative body to transfer to itself the power to appoint certain municipal officials. Illinois courts have interpreted this to be an unconstitutional effort to change the form of government of a city without a referendum: Questions regarding whether certain actions taken by governing boards constitute a change in the form of government have been answered by our Supreme Court in two cases: Pechous », Slawko (1976), 64 I.2d $76: Dunne v. Cook Cnty., 108 Il 2d 161 (1985). In Pechous. our Supreme Court found that attempts by the governing bodies of two home rule municipalities to transfer to themselves the power to appoint certain municipal officials without referendum to be improper. In the first controversy considered in Pechous, defendants, the aldermen of Berwyn, enacted an ordinance removing from office the superintendent of streets, the commissioner of public works, the city collector, and the city attomey and appointing replacements for them, State statute and the municipal code of Berwyn provided for appointment of these officials by the mayorwith the approval of the council, while removal of these appointees was in the diseretion of the mayor. The mayor of Berwyn and the city clerk challenged the power of the aldermen to exercise powers of appointment and removal. In the other case considered by the Pechous court, the defendant members of the board of trustees of the Village of Oak Lawn enacted an ordinance eliminating the office of village attorney from the list of officers to be appointed by the village manager and provided that the village attomey shall be appointed by the board of trustees. The village code authorized the city manager to appoint certain officers, including the village attorney. The supreme court in Pechous invalidated the ordinances in question finding they “form a part of a continuing effort on the part of the council to encroach upon the statutory authority of the city manager and to appropriate to themselves, without a referendum, the power to appoint the legal advisor for the village.” 64 I1I.2d at 588. In Dunne v. County of Cook, as noted earlier, the court invalidated a resolution by which the Cook County board attempted to reduce the percentage of votes required to override the president's veto. In Dunne, it was held that such an incursion by the legislative branch into the powers of the chief executive officer constituted a change in the form of government, which, in the absence of referendum approval, violated the Illinois Constitution, Likewise in this case, the Mayor in the Inspector General ordinance is tasked not, only with the appointment of the Inspector General but also with enforcement of the ordinances by virtue of the Inspector General reporting to the Mayor. In both instances, under the council- manager form of government, those tasks are given to the city manager As in Pechous and Dunne, defendants in the present case have attempted to take power given by statute to the city manager and improperly transfer it to a member of the legislative body of the government (the mayor). Absent submission for approval by referendum, enactment of thisordinance is improper. Intervenors submit that the holdings in Pechous and Dunne are controlling in the present case and based on these holdings we find that the ordinances at issue are unconstitutional attempts to alter the form of government and are therefore invalid, PLAINTIFF ONLY PLEADS CONCLUSIONS TO SUPPOR’ 'S CLAI IS Ilinois is a fact pleading state, Knox College v. Celetex Corp., 8 Ill.2d 407, 430 N.E.2d 976, 58 Ill.Dec. 725 (1981), appeal after remand, 117 IllApp.3d 304, 453 N.E.2d 8, 72 UL.Dec. 703 (1983). Plaintif?'s complaint also fails to allege facts necessary to state a cause of action. Also, it fails to allege facts that show the conduct was intentional. Knox College v. Celetex Corp, 88 {11.2d 407, 430 N.E.2d 976, 58 Uh.Dec. 725 (1981), appeal after remand 117 I1LApp.3d 304, 453 N.E.2d 8, 72 I1l.Dee. 703 (1983). Further, Plaintiff's complaint is defective because it fails to plead facts regarding Plaintiff's authority to issue subpoenas outside of the universe of city officials and employees within the City of Joliet, Plaintiff merely pleads conclusory statements concerning the nature of the power it purports to have in this instance, In ruling upon a motion to dismiss, a trial court accepts as true all well-pled facts, as well as all reasonable inferences favorable to the party opposing the motion which may be drawn from, the facts. The court does not, however, accept as true mere conclusions of law or fact. Lane ¥. Anderson, 345 IlApp.3d 256, 263. 802 N.E.2d 1278, 1284 (2004), In this case, the Plaintiff simply pleads conclusions and pleads very little facts in support of his pleading. The Plaintiff has no standing to bring this matter and further no authority to issue a subpoena to an Illinois law enforcement agency. As such, this case should be dismissed pursuant to 735 ILCS 2-615 (2020). PLAINTIFF MUST FILE AS A PROPER ENTITY The Plaintiff has sued as the “Inspector General of the City of Joliet”. Although there is aCity of Joliet, there is no legal entity named Inspector General. Furthermore, the Joliet ordinance does not provide that the inspector general may sue or be sued. Code of Ordinanees, City of Joliet, Ilinois 2-506. Where a suit is brought by an entity which has no legal existence, the proceedings are void ab initio. Lewis v. West Side Trust & Savings Bank, (1941), 377 Ill, 384, 385, 36 N.E.2d 573; Tyler v JC Penney Co., (1986), 145 Ill.App.3d 967, 972, 99 Ill.Dec. 748, 496 N.E.2d 323. ‘Thus, the legal existence of the entity being sued may be brought into question at any time Lewis, 377 Ill. at 385, 36 N.E.2d 573; Tyler. 143 IILApp.3d at 972, 99 IIl.Dec. 748, 496 N.E.2d 323 Further as discussed infra, the ordinance creating the office of Inspector General is unconstitutional as such has no legal force. As the Plaintiff has sued as non-entity, Intervenor moves to have Plaintiff's complaint dismissed PLAINTIFF MADE NO REASONABLE OR CURSORY INVESTIGATION OF ITS CLAIM PURSUANT TO ILLINOIS SUPREME COURT RULE 137 ‘The Illinois Supreme Court 137 imposes requirements upon litigants in filing lawsuits. Rule 137(a) provides, in relevant part: “Every pleading, motion or other document of a party represented by an attorney shall be signed by at least one attomey of record in his individual name, whose address shall be stated. * * * The signature of an attorney or party constitutes a certificate by him that he has read the pleading. motion, or other document; that to the best of his knowledge, information, and belief formed alter reasonable inquiry it is well grounded in fact and is warranted by existing law or in a good-faith argument for the extension, modification, or reversal of existing law. and that itis not interposed for any improper purpose. such as to harass or to cause unnecessary delay or needless increase in the cost of litigation. * * * /f a pleading, motion, or other document is signed in violation of this rule, the court, upon motion or upon its own initiative, may impose upon the person who signed it, a represented party, or both, an appropriate sanction, which may include an order to pay to the other party or parties the amount of reasonable expenses incurred because of the filing of the pleading, motion or other document, including a reasonable attorney fee.” (Emphasis added.) Ill S. Ct. R. 137(a) (eff. July 1. 2013). The plain language of Rule 137 authorizes a court to impose sanctions against a party or counsel for filing a motion or pleading that is not well grounded in fact; that is not supported by existing,law or lacks a good-faith basis for the modification, reversal, or extension of the law; or that is interposed for any improper purpose. It is settled that “{tJhe purpose of Rule 137 is to prevent abuse of the judicial process by penalizing claimants who bring vexatious and harassing actions.” Supreme Court Rule 137 permits the trial court to impose sanctions against a party or its counsel where a motion or pleading is filed that is “not well grounded in fact, not supported by existing law, or lacks @ good-faith basis for modification, reversal, or extension of the law, or is interposed for any improper purpose.” Whitmer v. Munson, 335 Ill.App.3d 501, 513-14, 269 Ill.Dec. 821, 781 N.E.2d 618, 628 (2002), citing Peterson v. Randhava, 313 Ill.App.3d 1, 6-7, 246 IlL.Dee. 75, 729 N.E.2d 75, 79 (2000). The purpose of Rule 137 is to prevent the filing of false and frivolous lawsuits. Yurtker v. Farmers Auto. Mgmt. Corp, 404 Ill. App.3d 816, 935 N.E.2d 630 (2010). Here the Plaintiff appears to have done no investigation or research conceming the authority to bring this claim, As such, the Plaintiff should be sanctioned for bringing this case without a factual investigation of the claim or the legal basis with to proceed. WHEREFORE, the Intervenor, prays that the complaint of the Plaintiff be stricken and dismissed Respectfully submitted, By: Scott Assistant State’s Attorney JAMES W. GLASGOW Will County State’s Attorney By: Scott Pyles #6208183 Assistant State's Attomey 57 N. Ottawa Street Joliet, IL 60432 (815) 724-1318 spyles@willcountyillinois.com