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SEARCH WARRANTS

April 10, 2008

This manual is intended to assist Police Officers in obtaining and executing


search warrants for all types of criminal investigations. Lawfully executed
search warrants will lead to the recovery of evidence necessary to develop
strong prosecutable cases against offenders in the cases police officers are
assigned to investigate.

Philip J. Cline
Philip J. Cline
Retired Superintendent
Chicago Police Department

CONTENTS
PAGE

Supreme Court Cases Involving


Search Warrants

2-9

Illinois Complied Statutes Regarding


Search Warrants

10-11

General Guidelines on the Preparation


and Execution of Search Warrants.

12-15

Types of Search Warrants

16

Sample Search Warrants..

17-39

Sample Case Reports

40-41

SUPREME COURT CASES


INVOLVING SEARCH WARRANTS
ILLINOIS V. GATES (1983)
462 U.S. 213
The Supreme Court abandoned the Atwo-pronged test@ established in Aguilar v.
Texas, 378 U.S. 108 and Spinelli v. United States, 393 U.S. 410 and adopted the Atotality of
the circumstances approach.@
On May 3, 1978, the Bloomingdale, IL Police received an anonymous letter which
stated that Lance and Susan Gates were drug dealers; and that Susan Gates would drive
her car to Florida on May 3rd, to pick up drugs; and that her husband Lance would fly down
in a few days to drive the car back; and that the Gates currently had over $100,000 worth of
drugs in their basement. Acting on this tip, the police determined that Lance Gates had a
reservation to fly to Florida on May 5th. The Bloomingdale Police requested that DEA do
surveillance, and they observed Lance Gates take the flight to West Palm Beach, Florida,
check into a motel room registered in his wife=s name, and then leave the next day with a
woman in a car registered to Gates in Bloomingdale, IL.
Det. Mader of the Bloomingdale, IL Police signed an affidavit setting forth these
facts, and a DuPage County Judge issued a search warrant for the Gates= residence and
automobile. When the Gates arrived home, the police were waiting, and a search of their
car revealed 350 pounds of marijuana. A search of their home revealed additional
marijuana, weapons, and other contraband.
The trial court suppressed all the evidence, and the Illinois Supreme Court agreed
that the letter and affidavit were inadequate to sustain a determination of probable cause
for issuance of the search warrant under Aguilar v. Texas and Spinelli since they failed to
satisfy the Atwo-pronged test@ of revealing the informant=s Abasis of knowledge@ and
providing sufficient facts to establish either the informant=s Averacity@ or the Areliability@ of
the informant=s letter.
The Supreme Court abandoned the Atwo-pronged test@ established in Aguilar v.
Texas, 378 U.S. 108 and Spinelli v. United States, 393 U.S. 410 and adopted the Atotality of
the circumstances approach.@
The task of the issuing judge is simply to make a practical, common-sense decision
whether, given all the circumstances set forth in the affidavit before him, including the
veracity and basis of knowledge of persons supplying hearsay information, there is a fair
probability that contraband or evidence of a crime will be found in a particular place.

FRANKS V. DELAWARE (1978)


43 U.S. 154
The Supreme Court held that where the defendant makes a substantial
preliminary showing that a false statement knowingly and intentionally, or with reckless
disregard for the truth, was included by the affiant in the warrant affidavit, and if the
allegedly false statement is necessary to the finding of probable cause, the Fourth
Amendment requires that a hearing be held at the defendants request.
On March 5, 1976 an assailant broke into Cynthia Bailey's home in Dover,
Delaware, and sexually assaulted her at knife point. She described her assailant's age,
race, height, and a detailed description of his clothing to the police. The same day
Jerome Franks was taken into custody on a unrelated assault charge. While awaiting a
bail hearing, Franks told Youth Officer Robert.McClements that he was surprised the
bail hearing was about 'Brenda B......., I know her, I thought you said Bailey, I don't
know her."
Youth Officer McCIements told Det. Ronald Brooks, who was assigned to the
Cynthia Bailey sexual assault case, what Franks had said. Det. Brooks and Det. Larry
Gray submitted a sworn affidavit to a judge for a search warrant, and in the affidavit
they put Franks' conversation with Youth Officer McCIements and also that they had
contacted Franks' employer and that they verified that Franks wears the type of clothing
that Cynthia Bailey described. They obtained the search warrant and a search of
Franks' apartment revealed clothing and a knife.
The defense filed a motion to suppress the clothing and the knife on the grounds
that Det. Brooks made a false statement in the affidavit. Defense Counsel stated that
Det Brooks had never interviewed Franks' employers as he stated in the affidavit. The
motion was denied and Franks was convicted. Franks appealed and the Delaware
Supreme Court affirmed his conviction.
Franks appealed to the U.S. Supreme Court, and the Supreme Court held that
where the defendant makes a substantial preliminary showing that a false statement
knowingly and intentionally, or with reckless disregard for the truth, was included by the
affiant in the warrant affidavit, and if the allegedly false statement is necessary to the
finding of probable cause, the Fourth Amendment requires that a hearing be held at the
defendant's request. In the event that at that hearing the allegation of perjury or
reckless disregard is established by the defendant by a preponderance of the evidence
and with the affidavit's false material set to one side, the affidavit's remaining content is
insufficient to establish probable cause, the search warrant must be voided and the
fruits of the search excluded to the same extent as if probable cause was lacking on the
face of the affidavit.

RICHARDS v. WISCONSIN (1997)


The Supreme Court ruled that the Fourth Amendment does not permit a blanket
exception for the knock and announce requirement for felony drug investigations.
Officers in Madison, Wisconsin, obtained a search warrant for a hotel room for drugs
and related paraphernalia, and the judge refused to give advance authorization for a Ano
knock@ entry. The officer who knocked on the hotel room door was dressed and identified
himself as a maintenance man. Upon opening the door for the Amaintenance man,@
Richards saw a uniformed officer and quickly closed the door. The officers kicked down the
door, caught Richards trying to escape, and found cash and cocaine in the bathroom.
Richards sought to have the evidence from his hotel room suppressed on the ground that
the officers had failed to knock and announce their presence prior to forcing entry into the
room. The trial court denied the motion. Richards appealed and the Wisconsin State
Supreme Court ruled that the police do not need to knock and announce in felony drug
cases. The Wisconsin Supreme Court explained its blanket exception as necessitated by
the special circumstances of today=s drug culture.
Richards appealed to the U.S. Supreme Court and they ruled on April 28, 1997, that
the decision of the Wisconsin Supreme Court on the Richards case was affirmed, but that
the blanket exception to the knock and announce requirement for felony drug investigations
was rejected.
The U.S. Supreme Court said in order to justify a Ano knock@ entry the police must
have a reasonable suspicion that knocking and announcing their presence under the
particular circumstances would be dangerous or futile, or that it would inhibit the effective
investigation of the crime by allowing the destruction of evidence.

ILLINOIS v. McARTHUR (2001)


000 U.S. 99-1132
Police Officers, with probable cause to believe that respondent McArthur had hidden
marijuana in his home, prevented from entering the home unaccompanied by an Officer for
about two hours while they obtained a search warrant. Once they did so, the Officers found
drug paraphernalia and marijuana, and arrested McArthur. He was subsequently charged
with misdemeanor possession of those items. He moved to suppress the evidence on the
ground that it was the Afruit@ of an unlawful police seizure, namely, the refusal to let him reenter his home unaccompanied. The Illinois trial court granted the motion, and the State
Appellate Court affirmed.
On April 2, 1997, Tera McArthur asked two Police Officers to accompany her to the
trailer where she lived with her husband, Charles, so that they could keep the peace while
she removed her belongings. The two Officers, Assistant Chief John Love and Officer
Richard Skidis, arrived with Tera at the trailer at about 3:15 p.m. Tera went inside, where
Charles was present. The Officers remained outside.
When Tera emerged after collecting her possessions, she spoke to Chief Love, who
was then on the porch. She suggested he check the trailer because AChuck had dope in
there.@ She added (in Love=s words) that she had seen Chuck Aslid(e) some dope
underneath the couch.@
Love knocked on the trailer door, told Charles what Tera had said, and asked for
permission to search the trailer, which Charles denied. Love then sent Officer Skidis with
Tera to get a search warrant.
Love told Charles, who by this time was also on the porch, the he could not re-enter
the trailer unless a Police Officer accompanied him. Charles subsequently re-entered the
trailer two or three times (to get cigarettes and to make phone calls), and each time Love
stood just inside the door to observe what Charles did.
Officer Skidis obtained the warrant by about 5:00 p.m. He returned to the trailer and,
along with other Officers, search it. The Officers found under the sofa a marijuana pipe, a
box for marijuana (called a Aone-hitter@ box), and a small amount of marijuana. They then
arrested Charles.
Illinois subsequently charged Charles McArthur with unlawfully possessing drug
paraphernalia and marijuana (less than 2.5 grams), both misdemeanors. McArthur moved
to suppress the pipe, box, and marijuana on the ground that they were the Afruit@ of an
unlawful police seizure, namely, the refusal to let him re-enter the trailer unaccompanied,
which would have permitted him, he said, to Ahave destroyed the marijuana.@
The trial court granted McArthur=s suppression motion. The Appellate Court of
Illinois affirmed, and the Illinois Supreme Court denied the State=s petition for leave to
appeal.
The case was then heard by the U.S. Supreme Court and the following is their
ruling.

We conclude that the restriction at issue was reasonable, and hence lawful, in light
of the following circumstances, which we consider in combination. First the police had
probable cause to believe that McArthur=s trailer home contained evidence of a crime and
contraband, namely, unlawful drugs. The police had had an opportunity to speak with Tera
McArthur and make at least a very rough assessment of her reliability. They knew she had
had a firsthand opportunity to observe her husband=s behavior, in particular with respect to
the drugs at issue. And they thought, with good reason, that her report to them reflected
that opportunity.
Second, the police had good reason to fear that, unless restrained, McArthur would
destroy the drugs before they could return with a warrant. They reasonably might have
thought that McArthur realized that his wife knew about his marijuana stash; observed that
she was angry or frightened enough to ask the police to accompany her; saw that after
leaving the trailer she had spoken with the police; and noticed that she had walked off with
one policeman while leaving the other outside to observe the trailer. They reasonably could
have concluded that McArthur, consequently suspecting an imminent search, would, if
given the chance, get rid of the drugs fast.
Third, the police made reasonable efforts to reconcile their law enforcement needs
with the demands of personal privacy. They neither searched the trailer nor arrested
McArthur before obtaining a warrant. Rather, they imposed a significantly less restrictive
restraint, preventing McArthur only from entering the trailer unaccompanied. They left his
home and his belongings intact B until a neutral Magistrate, finding probable cause, issued
a warrant.
Fourth, the police imposed the restraint for a limited period of time, namely, two
hours. As far as the record reveals, this time period was no longer than reasonably
necessary for the police, acting with diligence, to obtain the warrant. Given the nature of
the intrusion and law enforcement interest at stake, this brief seizure of the premises was
permissible.

U.S. v. BANKS (2003)


124 S.Ct. 521
Federal and local law enforcement agents went to Bank=s apartment mid-afternoon
to execute a search warrant for cocaine. The officers rapped loudly on the front door and
announced their office and intended warrant. After 15-20 seconds with no response, the
officers entered the apartment by force and recovered a large amount of cocaine and
weapons. Banks was in the shower at the time of entrance and did not hear the officers
until they had already entered his apartment.
Banks was convicted in U.S. District Court but the U.S. Court of Appeals reversed
and ordered a suppression of the evidence in that based on the circumstances, the length
of time waited was not long enough to justify a forced entry.
The U.S. Supreme Court reversed the appeals court ruling and upheld the conviction
and the admissibility of the seized evidence.
The court found that given the information available, the wait time was reasonable in
that if they had waited any longer, the potential for the destruction of evidence would have
increased. Absent exigent circumstances, the police must knock and receive an actual
refusal or wait out the time necessary to infer one. The fact that Banks was in the shower is
irrelevant. It is not unreasonable to believe that if there is no answer within 15-20 seconds
from a small apartment at mid-afternoon, the occupant may be in the process of destroying
evidence. In determining reasonableness, the court takes into consideration the evidence
sought, the time of day, the size of the location, etc. In a case like this, the officers knocked
and announced their presence, and forcibly entered after a reasonable suspicion of
exigency had ripened. Given the totality of the circumstances, the forced entry was not in
violation of the 4th Amendment.

MUEHLER v. MENA (2005)


125 S.Ct. 1465
During the course of executing a search warrant seeking weapons and evidence of
gang membership, officers detained and handcuffed the occupants of the property for
approximately 2 to 3 hours. The occupants filed suit and claimed a violation of the 4th
Amendment.
Both the U.S. District Court and the U.S. Court of Appeals held that the actions of
the officers violated the 4th Amendment.
The United States Supreme Court overturned the lower courts. The Court held that
the officers acted reasonable by detaining the occupants of the residence during the
execution of the search warrant.
In doing so, the U.S. Supreme Court noted that officers executing a search warrant
have the authority to detain any occupants upon the premises where the search is
conducted to ensure officer safety. Ensuring officer safety and the safety of the present
occupants outweighs the marginal intrusion of the detention of the occupants. In this case,
the use of handcuffs was especially justified in the warrant authorized a search for weapons
and the presence of gang members. The court also took into consideration the number of
occupants, as well as, the amount of time detained. In such a situation, the use of
handcuffs minimizes the risk of both officers and occupants.

GEORGIA v. RANDOLPH (2006)


The Supreme Court ruled that even if one occupant in a premise consents to a warrantless
search by police, a physically present co-occupants stated refusal to permit entry prevails,
rendering the warrantless search unreasonable and invalid as to him.
Argued: November 8, 2005

Decided: March 22, 2006

Facts of the Case :


Scott Randolph was arrested for drug possession after police found cocaine in his home.
The police did not have a warrant to search the home, but Randolph's wife consented to
the search. Randolph was also present at the time of the search, however, and objected to
the police request. At trial, his attorney argued that the search was unconstitutional
because of Randolph's objection, while the prosecution argued that the consent of his wife
was sufficient. The trial court ruled for the prosecution, but the appellate court and Georgia
Supreme Court both sided with Randolph, finding that a search is unconstitutional if one
resident objects, even if another resident consents.
Question Presented:
Can police search a home when one physically present resident consents and the other
physically present resident objects?
Conclusion:
No. In a 5 to 3 decision, the Supreme Court held that when two co-occupants are present
and one consents to a search while the other refuses, the search is not constitutional.
Justice David Souter, in the majority opinion, compared the reasonableness of such a
search to a more casual interaction. Souter wrote, "it is fair to say that a caller standing at
the door of shared premises would have no confidence that one occupant's invitation was a
sufficiently good reason to enter when a fellow tenant stood there saying, 'stay out.' Without
some very good reason, no sensible person would go inside under those conditions." A
police search in such circumstances, Souter wrote, would therefore not meet the
reasonableness requirement of the Fourth Amendment.

ILLINOIS COMPILED STATUTES


725 ILCS 108
SEARCH & SEIZURE
725/108-3 GROUNDS FOR SEARCH WARRANT
!

Upon the written complaint of any person under oath which states
facts sufficient to show probable cause and which particularly describe
the place or person to be searched and the things to be seized.

725/108-4 ISSUANCE OF SEARCH WARRANT


!

All Warrants Shall State the Time and Date of Issuance.

The Complaint on Which the Warrant Is Issued Need Not Be Filed


with the Clerk of the Court until the Warrant Has Been Executed or
Returned Not Executed.

The Search Warrant May Be Issued Electronically or by Facsimile


Machine.

725/108-6 EXECUTION OF SEARCH WARRANTS


!

Must Be Executed Within 96 Hours.

Copy must Be Left at Location Where Warrant Was Executed.

10

725/108-8 USE OF FORCE IN EXECUTION OF SEARCH WARRANT


!

All Necessary and Reasonable Force May Be Used to Effect an Entry


into Any Building or Part Thereof to Execute a Search Warrant.

The Court Issuing a Warrant May Authorize the Officer Executing the
Warrant to Make Entry Without First Knocking and Announcing His or
Her Office If it Finds, Based upon a Showing of Specific Facts, the
Existence of the Following Exigent Circumstances.

That the Officer Reasonably Believes That If Notice Were Given a


Weapon Would Be Used:
1) Against the Officer Executing the Search Warrant or
Another Person.
2) That If Notice Were Given There Is Imminent ADanger@ That
Evidence Will Be Destroyed.

725/108-9 DETENTION AND SEARCH OF PERSONS ON PREMISES


!

In the Execution of the Warrant the Person Executing the Warrant


May Reasonably Detain to Search Any Person in the Place at the
Time:

To Protect Himself from Attack;

To Prevent the Disposal or Concealment of Any Instruments, Articles


or Things Particularly Described in the Warrant.

11

GENERAL GUIDELINES ON THE PREPERATION


AND EXECUTION OF SEARCH WARRANTS
The following are general guidelines that should be followed by officers
prior to and during the execution of search warrants. Officers must also
comply with their Department Orders regarding the preparation and
execution of search warrants.
WRITING THE SEARCH WARRANT
!

Identify Yourself by Name, Rank, Unit.

State Your Experience as a Police Officer.

If Warrant Is Based on Informant Information, State When You Spoke


with the Informant, His past Reliability, and What Information He
Provided for this Warrant.

If Warrant Is for Evidence from a Previous Crime, State Details of


Crime (When, Where, What) Including Rd#.

Describe Your Investigation and What You Did to Corroborate Your


Informant=s Information.

Make Sure That the Complaint for Search Warrant and the Search
Warrant Are Identical in Describing the Person and Place to Be
Searched and the Things to Be Seized.

In People v Beck, the Illinois Appellate Court ruled that to establish


the nexus between defendant=s criminal activity and his home, the
affiant on a search warrant may rely on his own experience that drug
dealers ordinarily keep their supply, records, and profits at home. It is
not required to show facts to establish the nexus.

The following is suggested language for your affidavit:


Based on my experience and training as a narcotics officer, I
know that narcotics traffickers commonly keep records of
narcotics transactions and customers they provide drugs to,
and that those records are usually kept in a place that is readily
accessible, such as the individual=s residence.

12

PREPARATION
The affiant on the Search Warrant should physically look at the premise named in
the warrant prior to typing the warrant. After the warrant is typed, it should be presented to
a supervisor for his perusal.
The affiant will then take the Search Warrant and Complaint and confer with the
States Attorney according to the guidelines of their county.
The affiant will then present the Search Warrant and Complaint to a judge for his
signature. After the judge signs the Search Warrant and Complaint, the affiant should
make copies of each.
Prior to the execution of the Search Warrant, the supervisor and the affiant should
go over the assignment (perimeter coverage, evidence officer, entry team, prisoner guard
etc.) of the officers who will be going on the warrant.
EACH OFFICER SHOULD KNOW HIS ASSIGNMENT PRIOR TO LEAVING THE
OFFICE.
!

The supervisor should ensure that the proper equipment is brought to the
scene; e.g. sledge hammers, Chicago bar, bolt cutter, evidence envelopes,
contact cards, Consent to Search forms, flashlights, shotguns, camera.

The supervisor should inspect each officer to ensure that all members of the
raiding party are equipped with safety vests, Police raid jackets/vests and
Police baseball caps.

ENTRY
!

Upon arrival at the location each officer should go to his/her designated


location. All doors and windows should be under observation The
Communications Center should be notified of the address of the search
warrant..

Entry should be made at one location and all other doors and windows will be
contained by officers to prevent escape.

The supervisor should then knock on the door and announce "POLICE
OFFICERS, OPEN THE DOOR, WE HAVE A SEARCH WARRANT." The
officers should then wait a reasonable time (time necessary for an occupant
to get to the door and open it) before gaining a forcible entry.

If a forcible entry is necessary, the officers who used the forced entry equipment
should stand back once the door is opened, and the officers designated as the entry team
should gain entry while repeatedly announcing their office. As the entry team encounters
occupants, they should command the occupants to kneel down, cross their legs, and
interlock their fingers on top of their head. The officer should then conduct a quick frisk of
this subject for weapons.
13

The officer should remain with this subject until the supervisor announces that the
entry team has control of the premise. All occupants should then be searched for weapons
and contraband. An area of the premise should be searched thoroughly, and then the
occupants should be moved to that location and guarded by at least one officer.
THE SEARCH
The supervisor should then present a copy of the Search Warrant to the person
named in the warrant or the head of the household. The supervisor should inquire as to the
location of any USC or other valuables. The supervisor will recover the USC or valuables
and turn them over to the evidence officer or return them to the owner. If USC is
recovered, it will be counted at the scene in the presence of the owner. If the counting of
the currency recovered is not practical at the scene, the currency should be placed in a
sealed bag and counted according to your departments guidelines.
The supervisor should then assign officers to search rooms. After all the rooms
have been searched, the supervisor should have each room searched a second time by a
different officer.
When an item of evidence is recovered during the search, the officer who found it
will bring it to the evidence officer who will place it in an Evidence Envelope and record who
recovered it and the location of recovery. The evidence officer will maintain custody of the
recovered evidence until it is properly inventoried at the station.
!

Contact Cards should be completed for everyone present during the raid. A
name check should then be conducted either by radio, mobile computer or
telephone. This should be done prior to releasing anyone.

If the premise was fortified to delay entry by the police, a photo should be
taken of the fortifications and the owner/occupant should be charged with
CRIMINAL FORTIFICATION OF A BUILDING (720 ILCS 5/19-5).

If illegal contraband is found, the arrestee(s) should be advised of their


Miranda Warnings from a pre-printed source. Each occupant should then be
interviewed in an effort to determine who had knowledge of the contraband.

Proof of residency should then be established by documents, admissions,


presence of clothing, possession of door keys, interview of neighbors etc.

If a forcible entry was made, prior to leaving the supervisor should ensure
that the premise is secured or left in the custody of a responsible individual.

The arrestee(s) and the recovered evidence should then be transported to


the station for processing.

14

POST RAID PROCEDURES


The evidence officer should inventory all the recovered evidence. The proper case
and arrest reports should be prepared and any necessary notifications should be made.
The back of the original Search Warrant should be completed showing that the warrant was
executed and the evidence recovered should be listed.
!

The original Search Warrant and Complaint will then be attached to the court
papers of the arrestee.

After the prisoners have been processed, the supervisor should conduct a
critique of the raid with all members who participated.

INFORMANT FILES
.
$

Create a file folder with a code number for your informant.

Each time the informant provides you with information that leads to an arrest
or recovery of evidence, place a copy of the case report in the folder.

Each time you receive a lab report for evidence that your recovered based on
your informant=s information, place a copy of the lab report in the folder.

15

PAGE

! RELIABLE INFORMANT . 28-30


The person providing the information for the Search
Warrant Complaint has provided information in the
past which proved reliable.

! JOHN DOE.31-33
The prior reliability of the person providing the
information for the Search Warrant Complaint
is not necessary because the judge signing the
warrant will determine their credibility.

! BOLENDER18-21, 25-27, 34-36


The person providing the information for the Search
Warrant Complaint is deemed credible because they
are making a statement against their penal interest.

! POLICE INVESTIGATION...22-24, 37-39


In the complaint for the Search Warrant you show
why evidence of a crime can probably be found at
a particular location based on your investigation.

16

SAMPLE SEARCH WARRANTS

17

(3-81) CCMC-1-220
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
The People of the State of Illinois to all peace officers of the state

SEARCH WARRANT
On this day, Detective John Biggs #29999 , Chicago Police Department, Detective Division,
Complainant has subscribed and sworn to a complaint for search warrant before me. Upon examination
of the complaint, I find that it states facts sufficient to show probable cause.

I therefore command that you search:


Richard Little, M/WH/20, 6'0", 180 Ibs., IDOC Inmate #SO0123

and the premises:

and seize the following instruments, articles and things:


Genetic Material through the use of an oral "Buccal Swab" for DNA testing

which have been used in the commission of, or which constitute evidence of the offense of:
Aggravated Sexual Assault with a Handgun 720 ILCS 5/12 -14
and
Armed Robbery 720 ILCS 511 8-2

I further command that a return of anything so seized shall be made without necessary delay before me or before:

Judge ................................................. or before any court of competent jurisdiction.

................................................... .................
JUDGE
Judge's No.
Date and time of issuance:
..

18

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

Det. John Biggs #29999,Chicago Police Department, Detective Division, Complainant now appears
before the undersigned judge of the Circuit Court of Cook County and requests the issuance of a
search warrant to search:
Richard Little, M/WH/20, 6'0", 180 lbs., IDOC Inmate #S00123

and the premises:


and seize the following instruments, articles and things:
to wit Genetic Material through the use of an oral ABuccal Swab@ for DNA testing.

which have been used in the commission of, or which constitute evidence of the
offense of:
AGGRAVATED SEXUAL ASSAULT WITH A HANDGUN 720 ILCS 5/12-14
AND
ARMED ROBBERY 720 ILCS 5/18-2

Complainant says that he has probable cause to believe, based upon the following facts,
that the above listed things to be seized are now located upon the person and premises
set forth above:
Detective John Biggs #29999, Chicago Police Department, Complainant now appears before the
undersigned Judge of Circuit Court of Cook County and requests the issuance of a Search Warrant to
seize and search the following: The person of Richard Little in order to obtain a genetic material through
the use of an oral ABuccal Swab@ for DNA testing which constitutes evidence of offense of Aggravated
Criminal Sexual Assault and Armed Robbery. Complainant says that he has probable cause to believe,
based upon the following facts, that the above listed things to be seized are in and on the body of Little.
I, Detective John Biggs #29999, Chicago Police Department have been a Police Officer for the
past 172 years. I have been assigned to the Chicago Police Department, Area Six for the
............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

19

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

past eight years. I am presently investigating a series of Aggravated Criminal Sexual Assault and
Armed Robberies which have occurred during the past 22 years in the Chicagoland area (Alsip and
Oak Lawn, IL). These assaults are being referred to as the ABus Stop Rapist@ in the media. Several of
these assaults have been linked together by DNA left at the crime scenes.
During the course of the investigation, it was learned that during the last known assault on (date of
occurrence), the victim=s (Mary Kelly) cellular telephone was taken during the armed robbery and
criminal sexual assault. This Criminal Sexual Assault is report under R.D. #G-000000. A computerized
study of the cellular telephone revealed that several telephone calls were placed after the telephone
was stolen. One such telephone call was placed to a Robert Small=s (M/B, DOB: 11/11/82) residence,
(693-824-3124), 24 W. 127th Street, Chicago, IL, on (date of occurrence), at approximately 4:30 p.m.
Through investigation it was learned that Small=s physical description was similar to one of the
subjects involved with the assaults. On (date of occurrence), at approximately 3:00 p.m., Small was
located at his residence. Small was given his Constitutional Rights. Small agreed to speak to
investigators. Small admitted to his involvement in several of the series of aggravated sexual assaults
and armed robberies. Small stated that a Robert Little (M/H, DOB: 11/15/81) and a ABob Ung@
committed and participated in these assaults with Small. Richard Little=s physical description of 6 foot,
180 lbs. matches the physical descriptions given by victims of the assaults.
Small stated that Little was just sentenced on (date of sentence) and was an inmate in custody of
the Illinois Department of Corrections for an Aggravated Battery conviction. Small only knew ABob Ung@
as being an associate of Little.
Small stated that he, Little and ABob Ung@ would follow young black females from bus stops and
then force them into remote dark areas where the females were robbed, disrobed, and sexually
assaulted. Small stated that the victim=s jewelry which was taken was sold on the street or in a pawn
shop in the area of Second Street, Chicago. Small added that during one of the assault/robberies a
ACinderella@ wrist watch was taken. Through investigation, it was learned that during the last known
assault on (date of occurrence), the victim (Mary Kelly) reported that her ACinderella@ wrist watch was
stolen during the assault.
Small stated he has known Little throughout his life and they went to grammar school together. Small
was shown a picture of Little from his last arrest in Maywood for Aggravated Battery (date of arrest) and
positively identified Little.
............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

20

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

Through investigation it was learned that Little, in fact, was sentenced on (date of sentence) and
confined in the Illinois Department of Corrections (Inmate #S00123).
Based on the aforementioned facts, I believe that the oral Buccal Swab of Little contains
pertinent evidence of the offense of Aggravated Criminal Sexual Assault based on the fact that DNA
evidence was recovered from some of the victims in this series of criminal sexual assaults. Little is
presently confined in the Illinois Department of Corrections (Inmate #S00123).

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

21

Judge's No.

(3-81) CCMC-1-220
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
The People of the State of Illinois to all peace officers of the state

SEARCH WARRANT
On this day, Det. Thomas Right #00002 , Chicago Police Department, Detective Division, Complainant
has subscribed and sworn to a complaint for search warrant before me. Upon examination of the
complaint, I find that it states facts sufficient to show probable cause.

I therefore command that you search:


Roger Wrong, M/W/29, 6'02", weighing 350 lbs., brown hair, blue eyes, with D.O.B. 31 August 1972,
having an Illinois State ID card of 5007-28-0284W

and the premises:


123 W. First Street, Apt. 1201, Chicago, Cook County, Illinois

and seize the following instruments, articles and things:


Any computer equipment and accessories used in the commission of transmitting or perpetrating false bomb
threats, including but not limited to laptop computers, PC computers, hard drives, floppy drives, CD Rom Drives,
tape drives, floppy discs, CD Rom discs, any components located within or outside these computers capable of
storing information.

which have been used in the commission of, or which constitute evidence of the
offense of:
720ILCS5/26-1(a)(3) Disorderly Conduct

I further command that a return of anything so seized shall be made without necessary delay before me or before:

Judge ................................................. or before any court of competent jurisdiction.

................................................... .................
JUDGE
Judge's No.
Date and time of
issuance:

..

22

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

Det. Thomas Right #00002,Chicago Police Department, Detective Division, Complainant now appears before the
undersigned judge of the Circuit Court of Cook County and requests the issuance of a search warrant

I therefore command that you search:


Roger Wrong, M/W/29, 6'02", weighing 350 lbs., brown hair, blue eyes, with D.O.B. 31 August 1972, having
an Illinois State ID card of 5007-28-02284W

and the premises:


123 W. First Street, Apt. 1201, Chicago, Cook County, Illinois

and seize the following instruments, articles and things:


Any computer equipment and accessories used in the commission of transmitting or perpetrating false
bomb threats, including but not limited to laptop computers, PC computers, hard drives, floppy drives,
CD Rom Drives, tape drives, floppy discs, CD Rom discs, any components located within or outside
these computers capable of storing information.
which have been used in the commission of, or which constitute evidence of the offense of:
720 ILCS 5/26-1(a)(3) Disorderly Conduct

Complainant says that he has probable cause to believe, based upon the following
facts, that the above listed things to be seized are now located upon the person and premises set forth
above:
I, Detective Tom Right #00002, am employed by the Chicago Police Department
and have been so employed for the past eight years. You affiant is currently assigned to the Central
Homicide Unit and since 11 September 2001 has assisted the Bomb and Arson Unit in investigating
Bomb threats. For the past several days your affiant has been involved in an investigation pertaining to
the transmission of false bomb threats perpetrated against the Sears Tower located at 233 S. Wacker
Dr. in Chicago, Cook County, IL. These false threats were received on 11 September 2001 at the
Office of Emergency Communications (911 Center). Sixteen calls were received between the hours of
3:30 p.m. and 7:30 p.m. These calls were initiated from a cellular telephone bearing the number of 812337-0112. The subject initiating the calls portrayed himself as a Middle East Terrorist
I further command that a return of anything so seized shall be made without necessary delay before me
or before:
............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

23

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page
of
Pages
by the name of Mustaffa Almar Olandium (phonetic) and related in part that he and his organization, Assadin
Beddon had hijacked a 747 jetliner leaving Los Angeles, California. The caller additionally stated that Flight
205" was bound for Chicago, IL and would be flown into the Sears Tower thus blowing it up. The caller used an
Arabic accent and continued calling the 911 Center making additional threats.

Further investigation by your affiant through the use of telephone records revealed that the telephone used to
perpetrate these threats originated from a company located in Forever, IL. It was discovered that this cellular
telephone (812-337-0112). These subscriber records led your affiant to a subject named Charles Twinkle.
Twinkle related to your affiant that he had a friend by the name of Roger Wrong who had erroneously obtained a
lost cellular telephone. Twinkle went onto explain that the calls received on his phone from (812-337-0112) were
from his friend Roger Wrong. Twinkle additionally related that he frequently communicated with Roger Wrong
over the Internet via a Yahoo Chat Room. Twinkle stated Wrong frequently used the handle Cook_CPD.
Charles Twinkle subsequently supplied your affiant with pertinent information regarding the identity and location
of Roger Wrong.
Roger Wrong was subsequently located at his residence at 123 W. First Street, Apt. 1201 Chicago, IL.
After further investigation, Wrong was placed under arrest and taken to the Homan Square Facility of the
Chicago Police Department for processing. Roger Wrong, voluntarily gave an oral statement and handwritten
statement in which he related that he frequently talked over chat rooms on the Internet about various things
including material included in bomb threats made on 11 September 2001. Wrong additionally stated that while
he was making these false threats he was on the Internet connected to a Chat Room. Wrong stated that while
he was perpetrating the threats over the cellular phone he put the receiver of the phone next to the microphone
used to communicate on the Chat Room. This enabled all of the subjects on line to hear what was transpiring.
Wrong additionally stated that many of the subjects on line were involved telling him things to say and giving
him names to use while perpetrating these false terrorist bomb threat calls. Roger Wrong was subsequently
charged with a felony for perpetrating these false threats.
Based on the above listed facts, your affiant believes that the computer equipment located inside the
residence of Roger Wrong, 123 W. First Street, Apt. 1201, Chicago, Cook County, IL, was used in the
commission of the above listed crime and contains evidence of this crime. Your affiant additionally believes that
this computer equipment possibly contains evidence of other crimes committed against the People of the State of
Illinois via bomb threats falsely transmitted.5007-3802-284W, and his residence located at 123 W. First Street,
Apt. 1201, Chicago, Cook County, IL.
Therefore, you affiant, respectfully requests that a search warrant be issued for Roger Wrong at 123 W.
First Street, Apt. 1201, Chicago, Cook County, IL.
I further command that a return of anything so seized shall be made without necessary delay before me or before:

Judge ................................................. or before any court of competent jurisdiction.

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

24

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

SEARCH WARRANT
On this day, Det. John Law #20000 Area 5 Property Crimes, Chicago Police Department, Detective
Division, Complainant has subscribed and sworn to a complaint for search warrant before me. Upon
examination of the complaint, I find that it states facts sufficient to show probable cause.

I therefore command that you search:


Bill Burglar M/WH/32, 5-8 tall, 175 lbs, IR#0000000

and the premises:


2150 E. Chicago Ave. Apt#2E, Chicago, Cook County, IL.

and seize the following instruments, articles and things:


Gold Rolex watch, 2 15" string of pearls, a gold ring with blue and white stones, a black crow bar approximately
12 inches long, any identifiable stolen property, United States Currency and any documents showing residency.

which have been used in the commission of, or which constitute evidence of the offense of:
720 ILCS 5/19-1 Burglary and 720 ILCS 5/16-1 Theft (possession of stolen property)

I further command that a return of anything so seized shall be made without necessary delay before me or before:

Judge ................................................. or before any court of competent jurisdiction.

................................................... .................
JUDGE
Judge's No.
Date and time of
issuance:

..

25

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

Det. John Law #20000, Area 5 Property Crimes, Chicago Police Department, Organized Crime Division,
Narcotics Section, Complainant now appears before the undersigned judge of the Circuit Court of
Cook County and requests the issuance of a search warrant to search:
Bill Burglar M/WH/32, 5-8 tall, 175 lbs, IR#0000000

and the premises:


2150 E. Chicago Ave. Apt#2E, Chicago, Cook County, IL.

and seize the following instruments, articles and things:


Gold Rolex watch, 2 15" string of pearls, a gold ring with blue and white stones, a black crow bar
approximately 12 inches long, any identifiable stolen property, United States Currency and any documents
showing residency.

which have been used in the commission of, or which constitute evidence of the
offense of:
720 ILCS 5/19-1 Burglary and 720 ILCS 5/16-1 Theft (possession of stolen property)

Complainant says that he has probable cause to believe, based upon the following facts,
that the above listed things to be seized are now located upon the person and premises
set forth above:
I, Det. John Law am a police officer of the city of Chicago for the past 22 years, I am currently assigned to
Area 5 Property Crimes. On (date you were assigned) I was assigned to investigate the burglary of the residence
at 5555 W. Grand Ave. Chicago, IL. Which occurred on (date of burglary) and is reported under RD#B-000000.
During an interview with the victim Joe Victim, I learned that on (date of burglary) unknown offenders broke into
the residence at 5555 W. Grand Chicago, IL by forcing open the rear door and taking jewelry and cash. The list
of property taken is contained in General Offense Case Report RD#B-000000 which is attached to this search
warrant.
During my investigation I arrested Phil Prowler M/W/35 IR#000000 for this burglary. After advising him of
his constitutional rights he admitted that on (date of burglary) he and Bill Burglar broke into the residence at 5555
W. Grand Ave. By forcing open the rear door with a crow bar and then entering the residence and taking jewelry
and cash. Phil Prowler stated that after the burglary he and Bill Burglar went

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... , 19 ....................
................................................... .................
JUDGE

26

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

to Burglars apartment #2E at 2150 E. Chicago Ave. Chicago, IL and that Burglar took the proceeds from the
burglary and put them in the closet of his bedroom. Phil Prowler stated that he and Bill Burglar planned to sell
the jewelry to a fence who Phil Prowler says he only knows as Frank. Prowler says that they had not yet met
with Frank to sell him the jewelry.
I Det. Law checked the Identification Section of the Chicago Police Dept. And found that Bill Burglar has
IR#000000 and has been arrested 3 times for burglary. Phil Prowler has IR#000000 and has 4 arrests for
burglary. On (date of arrest) I observed that Burglar and Prowler were arrested together for the same burglary.
Based on the aforementioned, the affiant believes that there are sufficient facts for the issuance of a
search warrant for Bill Burglar and apartment #2E at 2150 E. Chicago Ave. Chicago, IL.

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

27

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

SEARCH WARRANT
On this day, P.O. John Law #55555 026th District, Chicago Police Department, Complainant has
subscribed and sworn to a complaint for search warrant before me. Upon examination of the complaint,
I find that it states facts sufficient to show probable cause.

I therefore command that you search:


John Smith aka Mouse M/B/20, 5-9, 150 lbs, medium complexion IR#000000

and the premises:


1st floor apartment at 3999 W. Roosevelt Rd., Chicago, Cook County, IL

and seize the following instruments, articles and things:


Cocaine, to wit a controlled substance and any documents showing residency, and any paraphernalia used in the
weighing, cutting or mixing of illegal drugs. Any money, any records detailing illegal drug transactions. Any
stored electronic information.

which have been used in the commission of, or which constitute evidence of the offense of:
720 ILCS 570/402 Possession of a Controlled Substance

I further command that a return of anything so seized shall be made without necessary delay before me or before:

Judge ................................................. or before any court of competent jurisdiction.

................................................... .................
JUDGE
Judge's No.
Date and time of
issuance:

..

28

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

P.O. John Law #55555 026th District, Chicago Police Department, Complainant now appears before the
undersigned judge of the Circuit Court of Cook County and requests the issuance of a search warrant
to search:
John Smith aka Mouse M/B/20, 5-9, 150 lbs, medium complexion IR#000000

and the premises:


st

1 floor apartment at 3999 W. Roosevelt Rd., Chicago, Cook County, IL

and seize the following instruments, articles and things:


Cocaine, to wit a controlled substance and any documents showing residency, and any paraphernalia used in
the weighing, cutting or mixing of illegal drugs. Any money, any records detailing illegal drug transactions.
Any stored electronic information.

which have been used in the commission of, or which constitute evidence of the
offense of:
720 ILCS 570/402 Possession of a Controlled Substance

Complainant says that he has probable cause to believe, based upon the following facts,
that the above listed things to be seized are now located upon the person and premises
set forth above:
I, P.O. John Law am a police officer of the City of Chicago for the past 15 years. I am currently
assigned to the 026th District Tactical Unit. On (date of conversation) I had a conversation with a
reliable informant whom I have known for the past 6 months. During the past 6 months this informant
has given me information on 6 occasions regarding drug trafficking. As a result of these conversations,
I made arrests all 6 occasions and recovered drug contraband on each occasion. The drug contraband
was submitted to the Illinois State Police Forensic Science Center at Chicago and I have received
results showing that drug contraband submitted in four of the cases were in fact controlled substances.
The other two cases are awaiting analysis. Two of these criminal cases have resulted in convictions
and 4 are still pending in court.
............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

29

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

On (date of conversation) this informant stated to me that of (date of activity he is describing) he


was in the 1st floor apartment at 3999 W. Roosevelt Rd. Chicago, IL. While in the apartment he
observed John Smith had 3 plastic bags containing numerous smaller plastic bags containing a white
rock substance. The informant said that John Smith took one of the smaller plastic bags from one of
the larger plastic bags and took the white rock from the small plastic bag and put it in a glass pipe and lit
it with a lighter and smoked the glass pipe. John Smith then offered the pipe to the informant the
informant said he smoked the glass pipe and received the same reaction as he has in the past two
years when he smoked cocaine.
The informant said as he was leaving the 1st floor apartment at 3999 W. Roosevelt Rd. Chicago, IL.
On (date he was in apartment) John Smith still had the 3 large plastic bags containing the numerous smaller
plastic bags containing the white rocks in his possession.
On (date that this occurred) the informant took me to 3999 W. Roosevelt and pointed out the 1st Floor
apartment as the apartment where John Smith had the 3 plastic bags containing the smaller plastic bags
containing the white rocks.
I, P.O. Law, checked the Identification Section of the Chicago Police Department and found that John Smith
has IR#000000 and was sentenced on (date sentenced) to 4 yrs in the Illinois Dept. of Corrections for
Possession with intent to Deliver Controlled Substance.
Based on the aforementioned, the affiant believes that there are sufficient facts for the issuance of a search
warrant for John Smith and the 1st floor apartment at 3999 W. Roosevelt Rd. Chicago, IL.

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

30

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

SEARCH WARRANT
On this day, P.O. John Law #55555 026th District, Chicago Police Department, & John Doe,
Complainant has subscribed and sworn to a complaint for search warrant before me. Upon
examination of the complaint, I find that it states facts sufficient to show probable cause.

I therefore command that you search:


Carl Dope Dealer, M/W/22, 5-2, 200 lbs., black hair with designs cut in his short hair cut.

and the premises:


House at 834 N. Street Name, Chicago, Cook County, IL

and seize the following instruments, articles and things:


Heroin and Cocaine, to wit a controlled substance and any documents showing residency, any paraphernalia
used in the weighing, cutting or mixing of illegal drugs. Any money or records detailing illegal transactions. A
blue steel .380 caliber pistol and a black 9mm Glock pistol.

which have been used in the commission of, or which constitute evidence of the offense of:
720 ILCS 570/402 Possession of a Controlled Substance

I further command that a return of anything so seized shall be made without necessary delay before me or before:

Judge ................................................. or before any court of competent jurisdiction.

................................................... .................
JUDGE
Judge's No.
Date and time of
issuance:

..

31

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

P.O. John Law #55555 026th District, Chicago Police Department and John Doe, Complainant now
appears before the undersigned judge of the Circuit Court of Cook County and requests the issuance
of a search warrant to search:
Carl Dope Dealer, M/W/22, 5-2, 200 lbs., black hair with designs cut in his short hair cut.

and the premises:


House at 834 N. Street Name, Chicago, Cook County, IL

and seize the following instruments, articles and things:


Heroin and Cocaine, to wit a controlled substance and any documents showing residency, any paraphernalia
used in the weighing, cutting or mixing of illegal drugs. Any money or records detailing illegal transactions. A
blue steel .380 caliber pistol and a black 9mm Glock pistol.

which have been used in the commission of, or which constitute evidence of the
offense of:
720 ILCS 570/402 Possession of a Controlled Substance

Complainant says that he has probable cause to believe, based upon the following facts,
that the above listed things to be seized are now located upon the person and premises
set forth above:
I, P.O. John Law am a police officer of the city of Chicago for the past 12 years, I am currently assigned to
the 026th District. I and a citizen of Chicago whom I will refer to as John Doe in this affidavit state the following.
John Doe stated that for approximately the last 4 years he has been selling heroin and cocaine as a member of
the Conservative Vice Lords street gang on the 800 blocks of N. Street name and N. Street Name. John Doe
states that this narcotics operation was run by Carl Dope Dealer. John Doe states that during the last 4 years
approximately twice a week John Doe would sell tin foil packets containing white heroin and small self sealing
plastic bags containing a white rock of crack cocaine. During these 4 years in the price of the heroin ranged from
$10 to $25 per packet. During these 4 years the price of crack cocaine ranged form $5 to $15 per bag.

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

32

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

John Doe states that on a typical day he would show up at about 10:00 AM on the 800 block of Street
Name and Carl Dope Dealer would hand out a plastic bag containing 50 tin foil packets of heroin and another
plastic bag containing 20 bags of crack cocaine. After selling the narcotics, John Doe stated that Carl Dope
Dealer would pay him $50.00.
John Doe states that on (date he was in the house) he was in the house located at 834 N. Street name,
Chicago, IL and also present was Car Dope Dealer. John Doe states that Carl Dope Dealer was taking
numerous pink tinted plastic bags containing rocks of crack cocaine. John Doe states that Carl Dope Dealer also
had 18 plastic bags containing tin foil packets of heroin. John Doe said he also saw a blue steel .038 caliber
pistol and a black steel 9mm pistol and a large quantity of United States Currency.
I, P.O. Law check with the Identification Section of the Chicago Police Department and found that Carl Dope
Dealer has IR #000000 and has been arrested 7 times for Possession of a Controlled Substance.
Based on the aforementioned, the affiant believes that there are sufficient facts for the issuance of a search
warrant for Carl Dope Dealer and the house at 834 N. Street name, Chicago, IL.

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

33

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

SEARCH WARRANT
On this day, P.O. John Law #55555 026th District, Chicago Police Department, Complainant has subscribed and
a complaint for search warrant before me. Upon examination of the complaint, I find that it states facts sufficient
to show probable cause.

I therefore command that you search:


Junebug M/B/ approximately 25 years old, 5-7 tall, 155 lbs, black hair

and the premises:


2nd Floor apartment at 3340 W. Fillmore Ave., Chicago Cook County, IL

and seize the following instruments, articles and things:


Cocaine, to wit a controlled substance and any documents showing residency, any paraphernalia used in
weighing, cutting or mixing of illegal drugs. Any money, any records detailing illegal drug transactions. Any
stored electronic information.

which have been used in the commission of, or which constitute evidence of the offense of:
720 ILCS 570/402 Possession of Controlled Substance

I further command that a return of anything so seized shall be made without necessary delay before me or before:

Judge ................................................. or before any court of competent jurisdiction.

................................................... .................
JUDGE
Judge's No.
Date and time of
issuance:

..

34

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

P.O. John Law #55555 026th District, Chicago Police Department, Complainant now appears before
the undersigned judge of the Circuit Court of Cook County and requests the issuance of a search
warrant to search:
Junebug M/B/ approximately 25 years old, 5-7 tall, 155 lbs, black hair

and the premises:


nd

2 Floor apartment at 3340 W. Fillmore Ave., Chicago Cook County, IL

and seize the following instruments, articles and things:


Cocaine, to wit a controlled substance and any documents showing residency, any paraphernalia used in
weighing, cutting or mixing of illegal drugs. Any money, any records detailing illegal drug transactions. Any
stored electronic information.

which have been used in the commission of, or which constitute evidence of the
offense of:
720 ILCS 570/402 Possession of Controlled Substance

Complainant says that he has probable cause to believe, based upon the following facts,
that the above listed things to be seized are now located upon the person and premises
set forth above:
I, P.O. John Law am a police officer of the City of Chicago for the past 8 years. I am currently assigned to
the 026th District Tactical Unit. On (date assigned) I was assigned Hot Line Complaint #888888 which stated that
crack cocaine was being sold from the 2nd floor apartment at 3340 W. Fillmore, Chicago. This complaint was
phoned in on (date of call). On (date & time) my partner P.O. Joe Friday and I established a surveillance of 3340
W. Fillmore. During our surveillance we observed several M/Bs and M/Ws walk up to the doorway leading to the
2nd floor apartment at 3340 W. Fillmore and have a transaction with a M/B approximately 25 years old, 5-7 tall,
155 lbs, black hair. After the transaction the M/Bs and M/Ws would walk away. At (time of observation) we
observed a M/W now known as Tom Customer walk up to the doorway leading to the 2nd floor apartment at 3340
W. Fillmore and have a transaction with a M/B approximately 25 years old, 5-7 tall, 155 lbs black hair.

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

35

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

After the transaction, Customer began walking eastbound on Fillmore. At Fillmore and Kedzie we
stopped Customer and found him to be in possession of 2 blue tinted self sealing plastic bags which contained
white rock substance. Customer was placed under arrest and advised of his rights from the FOP book.
Customer stated that he had just bought the crack cocaine from Junebug who lives in the 2nd floor apartment at
3340 W. Fillmore. Customer described Junebug as a M/B approximately 25 years old, 5-7 tall, 155 lbs, black
hair. Customer said he paid $20.00 for the two bags of crack cocaine and has been purchasing crack cocaine
from Junebug for the past month at 3340 W. Fillmore. Customer said that when he bought crack cocaine from
Junebug today, Junebug took the two bags of crack cocaine from a larger plastic bag which contained additional
bags containing more crack cocaine. Customer stated that he has purchased crack cocaine on approximately 30
occasions in the last month and that Junebug always had crack cocaine available. The arrest of Customer is
reported under RD #C-999999.
I, P.O. Law, then conducted a field test on one of the packets recovered from Customer and received a
positive reaction for the presence of cocaine.
Based on the aforementioned, the affiant believes that there are sufficient facts for the issuance of a
search warrant for Junebug and the 2nd floor apartment at 3340 W. Fillmore, Chicago, IL.

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

36

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

SEARCH WARRANT
On this day, Detective Joe Friday #20000 Area Five Detective Division, Chicago Police Department,
Complainant has subscribed and sworn to a complaint for search warrant before me. Upon
examination of the complaint, I find that it states facts sufficient to show probable cause.

I therefore command that you search:


Joe Criminal M/W/33, 5-5, 150 lbs, blue eyes, blonde hair, fair complexion

and the premises:


1st Floor apartment at 6023 N.Purple, Chicago, Cook County, IL

and seize the following instruments, articles and things:


Light colored sweat pants, dark sweat shirt, black ski mask, .38cal and 9mm ammunition a nickel plated 9mm
handgun, forensic and patent items of evidentiary value, including but not limited to firearm evidence, trace
evidence including blood, gunshot residue, hair, saliva, fibers and documents showing residency.

which have been used in the commission of, or which constitute evidence of the offense of:
720 ILCS 5/9-1 First Degree Murder

I further command that a return of anything so seized shall be made without necessary delay before me or before:

Judge ................................................. or before any court of competent jurisdiction.

................................................... .................
JUDGE
Judge's No.
Date and time of
issuance:

..

37

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

Detective Joe Friday #20000, Area Five Detective Division, Chicago Police Department, Complainant
now appears before the undersigned judge of the Circuit Court of Cook County and requests the
issuance of a search warrant to search:
Joe Criminal M/W/33, 5-5, 150 lbs, blue eyes, blonde hair, fair complexion

and the premises:


1st Floor apartment at 6023 N. Purple, Chicago, Cook County, IL

and seize the following instruments, articles and things:


Light colored sweat pants, dark sweat shirt, black ski mask, .38cal and 9mm ammunition, a nickel plated 9mm
handgun, forensic and patent items of evidentiary value, including but not limited to firearm evidence, trace
evidence including blood, gunshot residue, hair, saliva, fibers and documents showing residency.

which have been used in the commission of, or which constitute evidence of the
offense of:
720 ILCS 5/9-1 First Degree Murder

Complainant says that he has probable cause to believe, based upon the following facts,
that the above listed things to be seized are now located upon the person and premises
set forth above:
I, Det. Joe Friday#20000 have been a Chicago Police Officer for the past ten years. I am currently
assigned as a Detective at Area Five Violent Crimes. On (date of assignment) I was assigned to conduct a
follow-up investigation of the homicide of Phillip Victim who was shot to death at the Sandwich Shop 2247 N.
Pink Chicago, IL on (date of homicide). My investigation has revealed that Phillip Victim was an employee of the
Sandwich Shop and that at approximately 8:30 AM on (date of homicide) a lone male white offender with a black
ski mask, approximately 5-7 tall, 150 lbs, blue eyes, blondish color hair, wearing light sweat pants and a dark
sweat shirt bearing an unknown logo entered the back door of the Sandwich Shop and asked for Phil. The man
with the ski mask then walked to the bottom of the stairs to the basement and shot Phillip Victim several times
with a handgun. The man with the ski mask then fled upstairs, out the back door and northbound through the
alley toward Orange Ave.
While processing the crime scene, the Mobile Crime Lab recovered a blue steel Rossi .38 caliber model
68, serial #AA00000 with a 2" barrel in a garbage can near the Sandwich Shop in the alley at 2347 W. Orange.

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... , 19 ....................
................................................... .................
JUDGE

38

Judge's No.

COURT BRANCH

COURT DATE

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


(3-81) CCMC-1-219

STATE OF ILLINOIS
COUNTY OF COOK

THE CIRCUIT COURT OF COOK COUNTY

COMPLAINT FOR SEARCH WARRANT


Page

of

Pages

This garbage can is in the direct route in which the offender fled. An examination of this gun revealed that
it had five expended shell casings.
My investigation further revealed that Phillip Victims girlfriend Sue Sweetheart had dated Joe Criminal for
the past five years and that she broke up with Criminal approximately five weeks ago. Since that time, Criminal
has harassed and threatened Sweetheart about going out with Phillip Victim, and that she tried to hide her
relationship with Victim from Criminal because Criminal threatened to kill Victim if he dated her.
Further investigation revealed that prior to the shooting, Victim told witnesses that (1) He had been shot at
on (7 days before homicide) and that the girl he was seeing had a jealous ex-boyfriend who was after him and (2)
He was in a mess because he got a girl pregnant and her ex-boyfriend was gunning for him and that the guy was
crazy and knew where he worked.
My investigation revealed that on (9 days before homicide) Sue Sweetheart filed a police report under
RD#B-000000 because someone fired three bullets through her apartment window at 2103 N. Pink at
approximately 4:06 AM. Criminal is named as the offender in the shooting which left a hole in Sweethearts
kitchen wall from one of the shots. Crime Lab Unit 9603 responded and recovered a bullet from the wall.
My investigation revealed Criminal had given Sweetheart a .38 caliber blue steel five shot revolver
approximately 1 years ago for her to protect herself when he was not around. Sweetheart then gave this gun
back to Criminal shortly before Halloween (YEAR). The gun was described as a blue steel five shot revolver with
distinctive black grips. Sweetheart positively identified the gun that was recovered from the garbage can in the
alley at 2347 W. Orange, as the same gun that Criminal had given to her 1 years ago and that she returned to
him shortly before Halloween(YEAR).
Jerry Accomplice stated that he has known both Phillip Victim and Sue Sweetheart since xxxx and Joe
Criminal since xxxx. On (3 days before homicide) Accomplice said that Criminal picked him up at his residence
at 4259 W. Yellow Pk Rd at about 6:30 PM. Accomplice said that he and Criminal drove around the area of
Holstein Park drinking beer. During this time Criminal told Accomplice that Phillip Victim was fucking him around
by fucking Sue. Criminal said he was going to kick Victims ass. At approximately 7:00 PM, Accomplice said that
he and Criminal observed Victim park his van on Pink Ave and walk into Terrys Liquors. Accomplice said that
Criminal made a U-turn and parked on Pink Ave. At this time Accomplice observed Criminal remove a 9mm
handgun from under his seat and hold it in his lap. When Victim exited Terrys Liquor, Accomplice said that
Criminal called for Victim to come to the car. When Victim looked into the car, he took off running. Criminal told
Accomplice, dont worry hes going to get it. Accomplice said that Criminal then took the 9mm and hid it under
the hood of a Chevy Blazer and then entered the Blazer and drove away. Accomplice said that Criminal was
extremely jealous of Sue and would kill Victim over it.
My investigation revealed that Joe Criminal is the lease holder for the first floor apartment at 6023 N.
Purple. Based on the aforementioned, the affiant believes that there is sufficient facts for the issuance of a
search warrant for Joe Criminal and the first floor apartment at 6023 N. Purple, Chicago Cook County, IL.

............................................................
COMPLAINANT

Subscribed and sworn to before me on

........................................................................... ,

19 ....................

................................................... .................
JUDGE

39

Judge's No.

EVENT #

INCIDENT #

RAID #

R.D. #

OFFENDER(S):

# - LAST NAME, FIRST NAME, MIDDLE INITIAL, ALIAS (AKA),


ADDRESS, TELEPHONE #, SEX, RACE CODE, AGE, DOB:,
HEIGHT, WEIGHT, EYES, HAIR, COMPLEXION, SCARS
AND/OR DISTINGUISHING FEATURES, CLOTHING
DESCRIPTION, IN CUSTODY / WANTED, CB #, IR #, GANG
AFFILIATION, RELATION CODE:

CHARGE(S):

(LIST OFFENDER # FIRST AND SPELL OUT NAME OF


CHARGE(S) WHICH APPLY TO THAT OFFENDER, DO NOT
WRITE IN CHAPTER NUMBER.)

COURT BRANCH, DATE & COURT OFFICER:


SEARCH WARRANT #:
ASA APPROVING SEARCH WARRANT:
JUDGE APPROVING SEARCH WARRANT:
PERSON(S) PRESENT NOT ARRESTED:

LAST NAME, FIRST NAME, MIDDLE INITIAL,


SEX, RACE CODE, AGE ADDRESS,
TELEPHONE #

POLICE PERSONNEL ON SCENE:

RANK

40

NAME

STAR #

BEAT #

EVIDENCE RECOVERED:

INVENTORY # - ONE SMITH & WESSON .38 CAL. BLUE STEEL


REVOLVER SERIAL #123456 LOADED WITH 6 LIVE
CARTRIDGES RECOVERED BY P.O. GOODCOP #12345 FROM
THE PERSON OF ISA CRIMINAL. GUN IS CLEAR AND NOT
REGISTERED PER P.O. BLUEMAN #54321 - GUN
REGISTRATION.
INVENTORY # - ONE CLEAR PLASTIC BAG CONTAINING
WHITE POWDER SUBSTANCE (SUSPECT COCAINE)
RECOVERED BY P.O. SEARCHMAN #9876 UNDER THE OVEN
IN THE KITCHEN.
INVENTORY # - $320.00 USC CO-MINGLED WITH $20.00 USC
PRE-RECORDED CPD 1505 FUNDS RECOVERED BY P.O.
SMARTGUY #45678 FROM OFFENDER #1 RIGHT FRONT
PANTS POCKET.

EVIDENCE OFFICER:

RANK
NAME
STAR #
(THIS SHOULD BE THE OFFICER THAT THE EVIDENCE WAS
TURNED OVER TO AT THE SCENE ON SEARCH WARRANT
CASES, AND THIS OFFICER SHOULD INVENTORY ALL OF
THE EVIDENCE.)

VEHICLE SEIZED:

YEAR, MAKE, MODEL, COLOR, VIN, LICENSE PLATE #,


CITY STICKER #

PROOF OF RESIDENCE:

TYPE OF MAIL, ORAL ADMISSION, INTERVIEW OF


NEIGHBOR, ARRESTEE HAD KEYS TO DOOR, ETC...
(ANYTHING THAT PROVES THAT THE ARRESTEE LIVED
THERE.)

TOTAL WEIGHT & STREET VALUE:

NOTIFICATIONS:

RANK

COCAINE
MARIJUANA

NAME

HISTORY OF INVESTIGATION:

41

8.0 GRAMS
25.0 GRAMS

STAR #

$1,344.00
100.00
$1.444.00
UNIT

POLICE WORK:
It is not the critic who counts; not the man who points out how
the strong man stumbles, or where the doer of deeds could have
done them better. The credit belongs to the man who is actually
in the arena, whose face is marred by dust and sweat and blood,
who strives valiantly; who errs and comes short again and again;
because there is not effort without error and shortcomings; but
who does actually strive to do the deed; who knows the great
enthusiasm, the great devotion, who spends himself in a worthy
cause, who at the best knows in the end the triumph of high
achievement and who at the worst, if he fails, at least he fails
while daring greatly. So that his place shall never be with those
cold and timid souls who know neither victory nor defeat.

Theodore Roosevelt
Former Police Commissioner of NYPD
26th President of the United States

42

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