May 1, 2017

VIA ELECTRONIC MAIL: foia@chicagopolice.org

Chicago Police Department

Attn: Freedom of Information Officer
Records Inquiry Section, Unit 163
3510 S. Michigan Ave.
Chicago, IL 60653

Freedom of Information Act Request

Dear Freedom of Information Officer:

We are writing to you pursuant to the Illinois Freedom of Information Act, 5 ILCS 140/1
et seq., on behalf of our clients Organized Communities Against Deportation (OCAD) and
Black Youth Project 100 (BYP100), to request that copies of the documents described below
be made available for inspection and copying within five working days of your receipt of this
request.

Specifically, we are requesting the following information from the Chicago Police
Department:

1. All policies, procedures, training materials, or protocols, relating to information sharing with
Immigration and Customs Enforcement (ICE) or any other branch of the Department of
Homeland Security (DHS)including but not limited to the names, addresses, and other
identifying information of individuals who have come in contact with the CPDincluding
but not limited to the internal policies and procedures relating to individuals identified as
belonging to a gang, being a threat to public safety, and those convicted or charged with
felonies.

2. All protocol on communications and any contracts, memoranda of understanding, or

agreements with the federal government or federal agencies for the Chicago Police
Department to share information, including but not limited to the criminal records, names,
addresses, and other identifying information of individuals who have come in contact with
the CPD

3. All policies and procedures relating to the Chicago Police Departments participation and
maintenance of any database or log that includes the names of individuals who are suspected
 or confirmed members of street gangs. The CPD apparently defines street gangs as a group
of individuals who may or may not claim control over a certain territory in the community
and engage, either individually or collectively, in violent or other forms of illegal behavior.
However, one of the simplest and most functional definitions is that a gang is a group of
people who form an allegiance for a common purpose and engage in violent, unlawful, or
criminal activity.1

4. All policies, procedures, training materials, or protocols for determining the circumstances
under which Chicago Police Department officers identify an individual as belonging to a
street gang and list that individual in any gang database.

5. Documents sufficient to demonstrate the race and ethnicity of each person who is listed in
any gang database or who is identified as a gang member by the Chicago Police Department
through contact cards.

6. Documents sufficient to demonstrate the number of individuals whose identities the CPD has
shared with ICE because the individuals were listed in the CPD gang database.

7. All policies and procedures relating to the Chicago Police Departments use of the Strategic
Subject List. The CPD defines the Strategic Subject List as an assessment tool that looks at
a number of factors from a persons criminal record, including the record of violence among
the subjects criminal associates, gang membership, the degree to which the subjects
criminal activities are on the rise, and the types and intensity of criminal history.

8. All documents related to The RAND Corporations analysis of the Chicago Police
Departments use of data to target criminal suspects, including documents, data and
information provided to RAND, communications between CPD members and RAND
officials, drafts of the analysis and the final analysis.

9. Documents sufficient to demonstrate the race and ethnicity of each person who is listed on
the Strategic Subject List.

10. Documents sufficient to demonstrate the number of individuals who are in the Gang
Database, the Gang Book, and the Strategic Subject List.

11. All policies and procedures governing how individuals are notified of their inclusion in the
Gang Database, the Gang Book, and the Strategic Subject List.

12. All policies and procedures governing how individuals can be removed from or challenge
their inclusion in the Gang Database, the Gang Book, and the Strategic Subject List.

13. All documents that relate to civil rights or civil liberties investigations conducted by the City
of Chicago, the Chicago Police Department, or third parties regarding the City of Chicagos
participation and use of a gang database or list, including but not limited to complaints of

1
http://home.chicagopolice.org/community/gang-awareness/introduction-to-gangs/
2
 racial profiling, indiscriminate fingerprinting, sweeps, or unfair arrests.

14. All documents and memoranda that contain analyses of the accuracy of the information
contained in the gang database.

If you choose to deny this request, please provide a written explanation for the denial,
including a reference to the specific statutory exemption(s) upon which you rely. If some of
these records are disclosable and others are exempt, please provide the disclosable records and
let us know the exemption(s) preventing disclosure of the rest, as mandated by 5 ILCS 140/7(1).

As the production of these records is in the public interest, and not for personal or
commercial benefit, I am requesting that the fees associated with the FOIA application be
waived, pursuant to 5 ILCS 140/6(c).

Thank you for your prompt attention to this request. We will look forward to hearing
from you within five working days of your receipt of this correspondence. If you have questions,
please do not hesitate to contact us at (312) 503-5932 or vanessa.delvalle@law.northwestern.edu
or Sheila. Bedi@law.northwestern.edu

Sincerely,
/s/ Vanessa del Valle
/s/ Sheila Bedi_______
Roderick and Solange MacArthur Justice Center
Northwestern University School of Law School