Return Date: No return date scheduled

Hearing Date: 3/19/2021 9:45 AM - 9:45 AM

Courtroom Number: 2508
Location: District 1 Court FILED
Cook County, IL 11/19/2020 3:56 PM
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS DOROTHY BROWN
COUNTY DEPARTMENT, CHANCERY DIVISION CIRCUIT CLERK
COOK COUNTY, IL
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

2020CH06888
KEN KLIPPENSTEIN, )
) 11204535
Plaintiff, )
)
v. )
) 2020CH06888
CHICAGO POLICE DEPARTMENT, )
ILLINOIS STATE POLICE, )
)
Defendants. )

COMPLAINT

NOW COMES Plaintiff KEN KLIPPENSTEIN and brings this suit to overturn

Defendants CHICAGO POLICE DEPARTMENT’s (“CPD”) and ILLINOIS STATE POLICE’s

(“ISP”) willful violation of the Illinois Freedom of Information Act. Defendants failed to

comply with KLIPPENSTEIN’s FOIA requests for various records pertaining to intelligence

products that were created by and are in possession of CPD and ISP regarding racial justice

protests following the police killing of George Floyd. In support of the Complaint,

KLIPPENSTEIN states as follows:

INTRODUCTION

1. Pursuant to the fundamental philosophy of the American constitutional form of

government, it is the public policy of the State of Illinois that all persons are entitled to full and

complete information regarding the affairs of government and the official acts and policies of

those who represent them as public officials and public employees consistent with the terms of

the Illinois Freedom of Information Act (“FOIA”). 5 ILCS 140/1.

2. Restraints on access to information, to the extent permitted by FOIA, are limited

exceptions to the principle that the people of this state have a right to full disclosure of
 information relating to the decisions, policies, procedures, rules, standards, and other aspects of

government activity that affect the conduct of government and the lives of the people. 5 ILCS
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

140/1.

3. Under FOIA Section 1.2, “[a]ll records in the custody or possession of a public

body are presumed to be open to inspection or copying. Any public body that asserts that a

record is exempt from disclosure has the burden of proving by clear and convincing evidence

that it is exempt.” 5 ILCS 140/1.2.

PARTIES

4. Plaintiff KEN KLIPPENSTEIN is a journalist and is currently the D.C.

correspondent of The Nation. His work has appeared in The Nation, The Daily Beast, Salon, The

Intercept and other national and international news publications. KLIPPENSTEIN made the

FOIA requests at issue in this case.

5. Defendant CHICAGO POLICE DEPARTMENT (“CPD”) is a public body

located in Cook County, Illinois.

6. Defendant ILLINOIS STATE POLICE (“ISP”) is a state agency and a public

body with offices in Cook County, Illinois.

OCTOBER 21, 2020, FIRST FOIA REQUEST TO CPD

(TITLES OF INTELLIGENCE PRODUCTS)

7. On October 21, 2020, KLIPPENSTEIN submitted a FOIA request to CPD for

“records sufficient to show the titles of all intelligence products received, produced, transmitted,

or otherwise in the possession of the Chicago Crime Prevention and Information Center

(“CPIC”) between May 1, 2020, and August 18, 2020.” Exhibit 1.

8. In order to help the search, KLIPPENSTEIN provided the definition of

“intelligence product” as documents such as “joint bulletin, a situational awareness report, a

-2-
 tactical intelligence report, a threat assessment, etc.” KLIPPENSTEIN included that an

intelligence product often “includes a title to that product that describes the nature and content of
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

that product.” Exhibit 1.

9. On October 22, 2020, CPD sent an automated message acknowledging receipt of

the request and assigned reference number P611463-102220 to the matter. Exhibit 2.

10. On October 22, 2020, CPD sought an extension of five business days. Exhibit 3.

11. On October 23, 2020, CPD denied the request in its entirety by stating there are

no responsive records as the search “has produced no records.” Exhibit 4.

12. CPD has not demonstrated that it conducted an adequate search for responsive

records.

13. CPD has not conducted an adequate search for responsive records.

14. As of the date of this filing, CPD has not conducted an adequate search for the

records, has produced no responsive records, and has not complied with FOIA.

OCTOBER 21, 2020, SECOND FOIA REQUEST TO CPD

(GEORGE FLOYD PROTESTS)

15. On October 21, 2020, KLIPPENSTEIN submitted the following FOIA request to

CPD:

I respectfully request all Chicago Crime Prevention and Information Center (CPIC)
intelligence products about or concerning the George Floyd protests and subsequent
civil unrest, including but not limited to all intelligence products that contain any of
the following keywords: “George Floyd”, “protest”/“protester”,
“demonstration”/“demonstrator”. “Antifa”, “anarchist”, “activist”, “civil unrest”,
“violent extremist”, “extremists”, “looting”/“looters”, “black lives matter”,
“monument”, “Covid”/“Covid-19”, “coronavirus,” “Operation Legend”, “National
Guard”, “pandemic”, and “riot”/“rioter”. You may limit your search to intelligence
products dated between May 25, 2020 and August 21, 2020.

Exhibit 5.

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 16. In order to help the search, KLIPPENSTEIN provided the definition of

“intelligence product” as documents such as “joint bulletin, a situational awareness report, a

FILED DATE: 11/19/2020 3:56 PM 2020CH06888

tactical intelligence report, a threat assessment, etc.” KLIPPENSTEIN included that an

intelligence product often “includes a title to that product that describes the nature and content of

that product.” Exhibit 5.

17. On October 22, 2020, CPD sent an automated message acknowledging receipt of

the request and assigned reference number P611464-102220 to the matter. Exhibit 6.

18. On October 22, 2020, CPD sought an extension of five business days. Exhibit 7.

19. On November 9, 2020, KLIPPENSTEIN asked CPD for a status update, but CPD

never responded. Exhibit 8.

20. On November 12, 2020, after its statutory deadline to respond, CPD granted the

request by producing some records with redactions pursuant to Sections 7(1)(b), 7(1)(c), and

7(1)(d)(iv) of FOIA. Exhibit 9.

21. CPD produced 45 pages of screenshots of various “Facebook Event” pages that

outline the location, time, and details of the protests around Chicago.

22. CPD produced “raw intelligence” in its initial form.

23. Office of the Director of National Intelligence defines “raw intelligence” as “a

colloquial term meaning collected intelligence information that has not yet been converted into

finished intelligence.” Office of the Director of National Intelligence, U.S National Intelligence:

An Overview 2013 at 76 (Apr. 10, 2013), https://www.dni.gov/index.php/newsroom/reports-

publications/reports-publications-2013/item/835-u-s-national-intelligence-an-overview-2013-

sponsored-by-the-intelligence-community-information-sharing-executive.

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 24. KLIPPENSTEIN requested “intelligence products,” such as “joint bulletin, a

situational awareness report, a tactical intelligence report, a threat assessment, etc.” Exhibit 5.
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

25. The produced records are not responsive to the request.

26. CPD’s Special Order S03-04-04 “outlines the functions of the Crime Prevention

and Information Center (“CPIC”), which serves as the Department’s Fusion Center.” Exhibit 10.

27. Special Order S03-04-04 defines fusion center’s primary focus as “intelligence

processes through which information is collected, integrated, evaluated, analyzed, and

disseminated.” Id.

28. Further, Special Order S03-04-04 Section III states that fusion centers

“disseminate federally generated alerts, warnings, and notifications regarding time-sensitive

threats, situational awareness reports, and analytical products” and “fulfill criminal-predicate-

based request for information from Chicago Police Department members and federal, state, and

local law enforcement agencies.” Id.

29. Upon information and belief, CPD analyzes the various raw intelligence and

creates an intelligence product that gets distributed to local law enforcement agencies.

30. CPD has not demonstrated that it conducted an adequate search.

31. CPD has not conducted an adequate search.

32. As of the date of this filing, CPD has not produced the responsive records and has

not complied with FOIA.

OCTOBER 21, 2020, FIRST FOIA REQUEST TO ISP

(TITLES OF INTELLIGENCE PRODUCTS)

33. On October 21, 2020, KLIPPENSTEIN submitted a FOIA request to ISP for

“records sufficient to show the titles of all intelligence products received, produced, transmitted,

-5-
 or otherwise in the possession of the Illinois Statewide Terrorism and Intelligence Center

(“STIC”) between May 1, 2020, and August 18, 2020.” Exhibit 11.
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

34. In order to help the search, KLIPPENSTEIN provided the definition of

“intelligence product” as documents such as “joint bulletin, a situational awareness report, a

tactical intelligence report, a threat assessment, etc.” KLIPPENSTEIN included that an

intelligence product often “includes a title to that product that describes the nature and content of

that product.” Exhibit 11.

35. On October 29, 2020, ISP acknowledged receipt of the request, assigned reference

number FOIA # 20-3020 to the matter, and sought an extension of five business days. Exhibit

12.

36. On November 9, 2020, KLIPPENSTEIN asked ISP for a status update, but ISP

never responded. Exhibit 13.

37. ISP’s statutory deadline to respond was November 6, 2020.

38. Section 3(d) of FOIA states:

Each public body shall, promptly, either comply with or deny a request for public
records within 5 business days after its receipt of the request, unless the time for
response is properly extended under subsection (e) of this Section. Denial shall be in
writing as provided in Section 9 of this Act. Failure to comply with a written request,
extend the time for response, or deny a request within 5 business days after its receipt
shall be considered a denial of the request. A public body that fails to respond to a
request within the requisite periods in this Section but thereafter provides the
requester with copies of the requested public records may not impose a fee for such
copies. A public body that fails to respond to a request received may not treat the
request as unduly burdensome under subsection (g).

5 ILCS 140/3(d). (Emphasis added).

39. Section 3(e) of FOIA allows the public body to take an extension for “not more

than 5 business days from the original due date.” Section 3(e) also states that the requester and

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 the public body “may agree in writing to extend the time for compliance for a time period to be

determined by the parties.” 5 ILCS 140/3(e).

FILED DATE: 11/19/2020 3:56 PM 2020CH06888

40. ISP never sought KLIPPENSTEIN’s consent to take any extensions beyond the

single statutory extension.

41. KLIPPENSTEIN also never agreed to such extensions, in writing or otherwise.

42. As of the date of this filing, ISP has produced no responsive records and has not

complied with FOIA.

OCTOBER 21, 2020, SECOND FOIA REQUEST TO ISP

(GEORGE FLOYD PROTESTS)

43. On October 21, 2020, KLIPPENSTEIN submitted the following FOIA request to

ISP:

I respectfully request all Illinois Statewide Terrorism and Intelligence Center (STIC)
intelligence products about or concerning the George Floyd protests and subsequent
civil unrest, including but not limited to all intelligence products that contain any of
the following keywords: “George Floyd”, “protest”/“protester”,
“demonstration”/“demonstrator”. “Antifa”, “anarchist”, “activist”, “civil unrest”,
“violent extremist”, “extremists”, “looting”/“looters”, “black lives matter”,
“monument”, “Covid”/“Covid-19”, “coronavirus,” “Operation Legend”, “National
Guard”, “pandemic”, and “riot”/“rioter”. You may limit your search to intelligence
products dated between May 25, 2020 and August 21, 2020.

Exhibit 14.

44. In order to help the search, KLIPPENSTEIN provided the definition of

“intelligence product” as documents such as “joint bulletin, a situational awareness report, a

tactical intelligence report, a threat assessment, etc.” KLIPPENSTEIN included that an

intelligence product often “includes a title to that product that describes the nature and content of

that product.” Exhibit 14.

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 45. On October 29, 2020, ISP acknowledged receipt of the request, assigned reference

number FOIA # 20-3021 to the matter, and sought an extension of five business days. Exhibit
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

15.

46. On November 9, 2020, KLIPPENSTEIN asked ISP for a status update, but ISP

never responded. Exhibit 16.

47. ISP’s statutory deadline to respond was November 6, 2020.

48. In violation of Sections 3(d) and 3(e) of FOIA, ISP never sought

KLIPPENSTEIN’s consent to take any extensions beyond the single statutory extension.

49. KLIPPENSTEIN also never agreed to such extensions, in writing or otherwise.

50. As of the date of this filing, ISP has produced no responsive records and has not

complied with FOIA.

COUNT I – OCTOBER 21, 2020, FIRST FOIA REQUEST TO CPD

(TITLES OF INTELLIGENCE PRODUCTS),
FAILURE TO PRODUCE RECORDS

51. The above paragraphs are incorporated by reference.

52. CPD is a public body under FOIA.

53. The records sought in the FOIA request are non-exempt public records of CPD.

54. CPD violated FOIA by failing to produce the requested records.

COUNT II – OCTOBER 21, 2020, FIRST FOIA REQUEST TO CPD

(TITLES OF INTELLIGENCE PRODUCTS),
FAILURE TO PERFORM AN ADEQUATE SEARCH

55. The above paragraphs are incorporated by reference.

56. CPD is a public body under FOIA.

57. CPD bears the burden of proving beyond material doubt that it performed an

adequate search for responsive records.

58. CPD has failed to come forward with sufficient evidence to carry this burden.

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 59. CPD has violated FOIA by failing to adequately search for responsive records.

COUNT III – OCTOBER 21, 2020, FIRST FOIA REQUEST TO CPD

FILED DATE: 11/19/2020 3:56 PM 2020CH06888

(TITLES OF INTELLIGENCE PRODUCTS),

WILLFUL AND INTENTIONAL VIOLATION OF FOIA

60. The above paragraphs are incorporated by reference.

61. CPD is a public body under FOIA.

62. The records sought in the FOIA request are non-exempt public records of CPD.

63. CPD willfully and intentionally, or otherwise in bad faith failed to comply with

FOIA.

COUNT IV – OCTOBER 21, 2020, SECOND FOIA REQUEST TO CPD

(GEORGE FLOYD PROTESTS),
FAILURE TO PRODUCE RECORDS

64. The above paragraphs are incorporated by reference.

65. CPD is a public body under FOIA.

66. The records sought in the FOIA request are non-exempt public records of CPD.

67. CPD violated FOIA by failing to produce the requested records.

COUNT V – OCTOBER 21, 2020, SECOND FOIA REQUEST TO CPD

(GEORGE FLOYD PROTESTS),
FAILURE TO PERFORM AN ADEQUATE SEARCH

68. The above paragraphs are incorporated by reference.

69. CPD is a public body under FOIA.

70. CPD bears the burden of proving beyond material doubt that it performed an

adequate search for responsive records.

71. CPD has failed to come forward with sufficient evidence to carry this burden.

72. CPD has violated FOIA by failing to adequately search for responsive records.

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 COUNT VI – OCTOBER 21, 2020, SECOND FOIA REQUEST TO CPD
(GEORGE FLOYD PROTESTS),
WILLFUL AND INTENTIONAL VIOLATION OF FOIA
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

73. The above paragraphs are incorporated by reference.

74. CPD is a public body under FOIA.

75. The records sought in the FOIA request are non-exempt public records of CPD.

76. CPD willfully and intentionally, or otherwise in bad faith failed to comply with

FOIA.

COUNT VII – OCTOBER 21, 2020, FIRST FOIA REQUEST TO ISP

(TITLES OF INTELLIGENCE PRODUCTS),
FAILURE TO PRODUCE RECORDS

77. The above paragraphs are incorporated by reference.

78. ISP is a public body under FOIA.

79. The records sought in the FOIA request are non-exempt public records of ISP.

80. ISP violated FOIA by failing to produce the requested records.

COUNT VIII – OCTOBER 21, 2020, FIRST FOIA REQUEST TO ISP

(TITLES OF INTELLIGENCE PRODUCTS),
FAILURE TO PERFORM AN ADEQUATE SEARCH

81. The above paragraphs are incorporated by reference.

82. ISP is a public body under FOIA.

83. ISP bears the burden of proving beyond material doubt that it performed an

adequate search for responsive records.

84. ISP has failed to come forward with sufficient evidence to carry this burden.

85. ISP has violated FOIA by failing to adequately search for responsive records.

COUNT IX – OCTOBER 21, 2020, FIRST FOIA REQUEST TO ISP

(TITLES OF INTELLIGENCE PRODUCTS),
WILLFUL AND INTENTIONAL VIOLATION OF FOIA

86. The above paragraphs are incorporated by reference.

- 10 -
 87. ISP is a public body under FOIA.

88. The records sought in the FOIA request are non-exempt public records of ISP.
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

89. ISP willfully and intentionally, or otherwise in bad faith failed to comply with

FOIA

COUNT X – OCTOBER 21, 2020, SECOND FOIA REQUEST TO ISP

(GEORGE FLOYD PROTESTS),
FAILURE TO PRODUCE RECORDS

90. The above paragraphs are incorporated by reference.

91. ISP is a public body under FOIA.

92. The records sought in the FOIA request are non-exempt public records of ISP.

93. ISP violated FOIA by failing to produce the requested records.

COUNT XI – OCTOBER 21, 2020, SECOND FOIA REQUEST TO ISP

(GEORGE FLOYD PROTESTS),
FAILURE TO PERFORM AN ADEQUATE SEARCH

94. The above paragraphs are incorporated by reference.

95. ISP is a public body under FOIA.

96. ISP bears the burden of proving beyond material doubt that it performed an

adequate search for responsive records.

97. ISP has failed to come forward with sufficient evidence to carry this burden.

98. ISP has violated FOIA by failing to adequately search for responsive records.

COUNT XII – OCTOBER 21, 2020, SECOND FOIA REQUEST TO ISP

(GEORGE FLOYD PROTESTS),
WILLFUL AND INTENTIONAL VIOLATION OF FOIA

99. The above paragraphs are incorporated by reference.

100. ISP is a public body under FOIA.

101. The records sought in the FOIA request are non-exempt public records of ISP.

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 102. ISP willfully and intentionally, or otherwise in bad faith failed to comply with

FOIA
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

WHEREFORE, KLIPPENSTEIN asks that the Court:

i. declare that Defendants have violated FOIA;

ii. order Defendants to conduct an adequate search for the requested records;

iii. order Defendants to produce the requested records;

iv. enjoin Defendants from withholding non-exempt public records under FOIA;

v. order Defendants to pay civil penalties;

vi. award KLIPPENSTEIN reasonable attorneys’ fees and costs; and

vii. award such other relief the Court considers appropriate.

Dated: November 19, 2020

RESPECTFULLY SUBMITTED,
/s/ Matthew V. Topic

Attorneys for Plaintiff,

KEN KLIPPENSTEIN

Matthew Topic
Joshua Burday
Merrick Wayne
LOEVY & LOEVY
311 North Aberdeen, 3rd Floor
Chicago, IL 60607
312-243-5900
foia@loevy.com
Atty. No. 41295

- 12 -
 Fwd: IL FOIA Request 1
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

1 message

---------- Forwarded message ----------

From: Ken Klippenstein <kenjklippenstein@gmail.com>
Date: Oct 21, 2020, 8:45 PM -0400
To: FOIA <foia@chicagopolice.org>
Subject: IL FOIA Request 1

Greetings:

Attached please find my first of two FOIA requests, dated October 21, 2020.

Thank you for your time and attention in this matter.

Sincerely,
Ken Klippenstein
DC Correspondent/The Nation
(202) 510-1268

IL FOIA CPIC 1.pdf

75K

Exhibit 1
 Chicago Crime Prevention and Information Center (CPIC)
Chicago Police Department
Attn: Freedom of Information Officer
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

Freedom of Information Section Unit 114

3510 S. Michigan Ave.
Chicago, IL 60653
Email: foia@chicagopolice.org

October 21, 2020

Dear Custodian of Records,

This message constitutes a request under the Illinois Freedom of Information Act.

REQUESTER INFORMATION
Name: Ken Klippenstein
Position: DC Correspondent/The Nation
Address: 360 W Washington Ave Unit 1114, Madison, WI 53703
Email: kenjklippenstein@gmail.com
Phone: (202) 510-1268

RECORDS SOUGHT

I respectfully request records sufficient to show the titles of all intelligence products received,
produced, transmitted, or otherwise in the possession of the Chicago Crime Prevention and
Information Center (CPIC) between May 1, 2020 and August 18, 2020.

BACKGROUND

“Intelligence products” is a common term used by all intelligence agencies. In the intelligence
cycle, intelligence is collected and then processed by analysts into a manner suitable for
production that becomes a finished intelligence product. A finished intelligence product could
be a joint bulletin, a situational awareness report, a tactical intelligence report, a threat
assessment, etc. The finished intelligence product includes a title to that product that describes
the nature and content of that product. A fusion center has an objective, such as to determine
potential threats related to the protests and then begin collecting data on those threats, analyze
the data related to protests, and create a finished intelligence product from that collected data.

As part of a good faith effort to ensure that my request is as narrow as possible and will not be
unduly burdensome for you, please note that my request seeks only the titles of intelligence
products, not the contents of the intelligence products.

Please include records generated by CPIC and those received or otherwise acquired from
other agencies, including state and federal partners (e.g., the Federal Bureau of Investigation,
the Department of Homeland Security, etc.) My request includes but is not limited to
Suspicious Activity Reports, Joint Intelligence Bulletins or any other intelligence bulletins,
Situational Awareness Reports or any other situation reports, and threat assessments.

Please preserve all records related to this request that may be subject to deletion.
 FEE CATEGORY AND REQUEST FOR A FEE WAIVER

As a reporter and DC correspondent for The Nation magazine, I am a representative of the

FILED DATE: 11/19/2020 3:56 PM 2020CH06888

news media. Disclosure of the requested information to me is in the public interest because it
is likely to contribute significantly to public understanding of the operations or activities of the
government and is not primarily in my commercial interest. Intelligence product titles would
provide the general public with information about what kinds of intelligence the government is
using their tax dollars to generate or access. It would also provide the general public with
document titles that they can use to subsequently request any of the documents they may
wish to learn more about. I have written extensively about national security matters and will
do the same here. My work has been referenced by The New York Times, The Washington
Post, The Los Angeles Times, The Atlantic, and other major media outlets.

EXEMPTIONS AND SEGREGABILITY

If any responsive record or portion thereof is claimed to be exempt from production, the
Illinois Freedom of Information Act provides that even if some of the requested material is
properly exempt from mandatory disclosure, all segregable portions must be released.

If documents are denied in part or in whole, please specify which exemption(s) is (are) claimed
for each passage or whole document denied. Please provide a complete itemized inventory and
a detailed factual justification of total or partial denial of documents. Specify the number of
pages in each document and the total number of pages pertaining to this request. In excising
material, please “black out” the material rather than “white out” or “cut out.” I expect, as
provided by FOIA, that the remaining non-exempt portions of documents will be released.

Please release all pages regardless of the extent of excising, even if all that remains are
stationary headings or administrative markings. In addition, I ask that your agency exercise its
discretion to release records which may be technically exempt, but where withholding serves
no important public interest.

Thank you for your time and attention in this matter.

Ken Klippenstein
 Fwd: Non-Commercial FOIA Request :: P611463-102220
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

1 message

---------- Forwarded message ----------

From: Chicago Public Safety <chicagops@mycusthelp.net>
Date: Oct 22, 2020, 4:30 AM -0400
To: kenjklippenstein@gmail.com <kenjklippenstein@gmail.com>
Subject: Non-Commercial FOIA Request :: P611463-102220

Dear Ken:
Thank you for your interest in information from the Chicago Police Department. Your FOIA request has been
received and is being processed. Your FOIA Center reference number for tracking purposes is: P611463-102220
You have requested the following records: I respectfully request records sufficient to show the titles of all
intelligence products received, produced, transmitted, or otherwise in the possession of the Chicago
Crime Prevention and Information Center (CPIC) between May 1, 2020 and August 18, 2020.
Chicago Police Department (CPD) responds to all public records requests in accordance with the Illinois Freedom
of Information Act (FOIA), 5 ILCS 140/1 et seq. If further time is needed to assemble and copy all documents
responsive to your FOIA request, we will contact you with a time estimate and a request to extend.
You can monitor the progress of your request at the link below and you’ll receive an email when your
request has been completed. Thank you for using the Chicago FOIA Center.

To monitor the progress or update this request please log into the Chicago Public Safety Record System.

Exhibit 2
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

10/22/2020

Ken Klippenstein

RE: FOIA REQUEST of October 22, 2020, Reference # P611463-102220

Dear Ken:

The Chicago Police Department is in receipt of your Freedom of Information Act (FOIA)
request. On October 22, 2020, the following request was received.

I respectfully request records sufficient to show the titles of all intelligence products received,
produced, transmitted, or otherwise in the possession of the Chicago Crime Prevention and
Information Center (CPIC) between May 1, 2020 and August 18, 2020.

FOIA requires each public body to promptly respond to a request for public records, either by
complying or denying the request, within 5 business days after the public body has received the
request. Under the Freedom of Information Act, a public body may extend the time to respond
to a FOIA request by up to 5 business days.

Due to the COVID-19 pandemic and the Governor’s issuance of a disaster proclamation, the
Chicago Police Department (CPD) is taking preventive measures in attempt to control the spread
of the virus. Therefore, the CPD has chosen to allow Department members assigned to the
Freedom of Information Act (FOIA) Unit to work remotely and has partially closed its office due
to sworn members assigned to administrative duties being deployed to the field for public safety.
In addition, as more and more individuals become ill or come into contact with someone infected
with COVID-19 and are isolated or quarantined, members of CPD FOIA Unit may be unable to
report to work. In such circumstances, CPD may assert exceptions outlined in 5 ILCS 140/3(e),
particularly if responding to the request is unduly burdensome in the circumstances, requires
review by an unavailable staff member, or requires resources to obtain records located off-site.

Exhibit 3
 Please keep in mind that FOIA allows CPD and the requester to come to a mutually agreeable
response period to comply with a FOIA request. Members of the public and media are asked to
keep these considerations in mind and are strongly encouraged to work with public bodies to
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

agree on reasonable and appropriate response times in light of the public health concerns we all
face. Given that the length of the pandemic remains unknown and that staffing levels have been
reduced, during this statewide emergency declaration, CPD may treat a FOIA request as unduly
burdensome, in the event that it is not feasible for CPD to comply with or deny a request for
public records within 5 business days after its receipt of the request or the time for response was
properly extended under 5 ILCS 140/3(e) because it would unduly burden CPD's operations
during the COVID-19 pandemic.

At this time, we are extending the time to respond to your request by an additional 5 business
days.

If you have any questions, please contact our office at 312-745-5308 or at the following address:

Chicago Police Department

Attention: Freedom of Information Officer
Office of Legal Affairs, Unit 114
3510 S. Michigan Ave.
Chicago, IL 60653

Sincerely,

Kristen Regalado
Freedom of Information Officer
Chicago Police Department
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

10/22/2020

Ken Klippenstein

RE: FOIA REQUEST of October 22, 2020, Reference # P611463-102220

Dear Ken:

The Chicago Police Department is in receipt of your Freedom of Information Act (FOIA)
request. On October 22, 2020, the following request was received.

I respectfully request records sufficient to show the titles of all intelligence products received,
produced, transmitted, or otherwise in the possession of the Chicago Crime Prevention and
Information Center (CPIC) between May 1, 2020 and August 18, 2020.

A search, based on the information provided in the request, has produced no records. Therefore,
there is no responsive record(s) to your request.

If you have any questions, please contact our office at 312-745-5308 or at the following address:

Chicago Police Department

Attention: Freedom of Information Officer
Office of Legal Affairs, Unit 114
3510 S. Michigan Ave.
Chicago, IL 60653

Sincerely,

Kristen Regalado
Freedom of Information Officer
Chicago Police Department

Exhibit 4
 Fwd: IL FOIA Request 2
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

1 message

---------- Forwarded message ----------

From: Ken Klippenstein <kenjklippenstein@gmail.com>
Date: Oct 21, 2020, 8:48 PM -0400
To: FOIA <foia@chicagopolice.org>
Subject: IL FOIA Request 2

Greetings:

Attached please find my second of two FOIA requests, dated October 21, 2020.

Thank you for your time and attention in this matter.

Sincerely,
Ken Klippenstein
DC Correspondent/The Nation
(202) 510-1268

IL FOIA CPIC 2.pdf

75K

Exhibit 5
 Chicago Crime Prevention and Information Center (CPIC)
Chicago Police Department
Attn: Freedom of Information Officer
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

Freedom of Information Section Unit 114

3510 S. Michigan Ave.
Chicago, IL 60653
Email: foia@chicagopolice.org

October 21, 2020

Dear Custodian of Records,

This message constitutes a request under the Illinois Freedom of Information Act.

REQUESTER INFORMATION
Name: Ken Klippenstein
Position: DC Correspondent / The Nation
Address: 360 W Washington Ave Unit 1114, Madison, WI 53703
Email: kenjklippenstein@gmail.com
Phone: (202) 510-1268

RECORDS SOUGHT

I respectfully request all Chicago Crime Prevention and Information Center (CPIC) intelligence
products about or concerning the George Floyd protests and subsequent civil unrest, including
but not limited to all intelligence products that contain any of the following keywords: “George
Floyd”, “protest”/“protester”, “demonstration”/“demonstrator”. “Antifa”, “anarchist”, “activist”,
“civil unrest”, “violent extremist”, “extremists”, “looting”/“looters”, “black lives matter”,
“monument”, “Covid”/“Covid-19”, “coronavirus,” “Operation Legend”, “National Guard”,
“pandemic”, and “riot”/“rioter”. You may limit your search to intelligence products dated
between May 25, 2020 and August 21, 2020.

BACKGROUND

“Intelligence products” is a common term used by all intelligence agencies. In the intelligence
cycle, intelligence is collected and then processed by analysts into a manner suitable for
production that becomes a finished intelligence product. A finished intelligence product could
be a joint bulletin, a situational awareness report, a tactical intelligence report, a threat
assessment, etc. The finished intelligence product includes a title to that product that describes
the nature and content of that product. A fusion center has an objective, such as to determine
potential threats related to the protests and then begin collecting data on those threats, analyze
the data related to protests, and create a finished intelligence product from that collected data.

Please include records generated by CPIC and those received or otherwise acquired by CPIC
from other agencies, including state and federal partners (e.g., the Federal Bureau of
Investigation, the Department of Homeland Security, etc.) My request includes but is not limited
to Suspicious Activity Reports, Joint Intelligence Bulletins or any other intelligence bulletins,
Situational Awareness Reports or any other situation reports, and threat assessments. Please
preserve all records related to this request that may be subject to deletion.
 FEE CATEGORY AND REQUEST FOR A FEE WAIVER

As a reporter and DC correspondent for The Nation magazine, I am a representative of the news
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

media. Disclosure of the requested information to me is in the public interest because it is likely
to contribute significantly to public understanding of the operations or activities of the
government and is not primarily in my commercial interest. Intelligence product titles would
provide the general public with information about what kinds of intelligence the government is
using their tax dollars to generate or access. It would also provide the general public with
document titles that they can use to subsequently request any of the documents they may wish
to learn more about. I have written extensively about national security matters and will do the
same here. My work has been referenced by The New York Times, The Washington Post, The
Los Angeles Times, The Atlantic, and other major media outlets.

EXEMPTIONS AND SEGREGABILITY

If any responsive record or portion thereof is claimed to be exempt from production, the Illinois
Freedom of Information Act provides that even if some of the requested material is properly
exempt from mandatory disclosure, all segregable portions must be released.

If documents are denied in part or in whole, please specify which exemption(s) is (are) claimed
for each passage or whole document denied. Please provide a complete itemized inventory and a
detailed factual justification of total or partial denial of documents. Specify the number of pages
in each document and the total number of pages pertaining to this request. In excising material,
please “black out” the material rather than “white out” or “cut out.” I expect, as provided by the
FOIA, that the remaining non-exempt portions of documents will be released.

Please release all pages regardless of the extent of excising, even if all that remains are stationary
headings or administrative markings. In addition, I ask that your agency exercise its discretion to
release records which may be technically exempt, but where withholding serves no important
public interest.

Thank you for your time and attention in this matter.

Ken Klippenstein
 Fwd: Non-Commercial FOIA Request :: P611464-102220
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

1 message

---------- Forwarded message ----------

From: Chicago Public Safety <chicagops@mycusthelp.net>
Date: Oct 22, 2020, 4:34 AM -0400
To: kenjklippenstein@gmail.com <kenjklippenstein@gmail.com>
Subject: Non-Commercial FOIA Request :: P611464-102220

Dear Ken:
Thank you for your interest in information from the Chicago Police Department. Your FOIA request has been
received and is being processed. Your FOIA Center reference number for tracking purposes is: P611464-102220
You have requested the following records: I respectfully request all Chicago Crime Prevention and
Information Center (CPIC) intelligence products about or concerning the George Floyd protests and
subsequent civil unrest, including but not limited to all intelligence products that contain any of the
following keywords: “George Floyd”, “protest”/“protester”, “demonstration”/“demonstrator”. “Antifa”,
“anarchist”, “activist”, “civil unrest”, “violent extremist”, “extremists”, “looting”/“looters”, “black lives
matter”, “monument”, “Covid”/“Covid-19”, “coronavirus,” “Operation Legend”, “National Guard”,
“pandemic”, and “riot”/“rioter”. You may limit your search to intelligence products dated between May 25,
2020 and August 21, 2020.
Chicago Police Department (CPD) responds to all public records requests in accordance with the Illinois Freedom
of Information Act (FOIA), 5 ILCS 140/1 et seq. If further time is needed to assemble and copy all documents
responsive to your FOIA request, we will contact you with a time estimate and a request to extend.
You can monitor the progress of your request at the link below and you’ll receive an email when your
request has been completed. Thank you for using the Chicago FOIA Center.

To monitor the progress or update this request please log into the Chicago Public Safety Record System.

Exhibit 6
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

10/22/2020

Ken Klippenstein

RE: FOIA REQUEST of October 22, 2020, Reference # P611464-102220

Dear Ken:

The Chicago Police Department is in receipt of your Freedom of Information Act (FOIA)
request. On October 22, 2020, the following request was received.

I respectfully request all Chicago Crime Prevention and Information Center (CPIC) intelligence
products about or concerning the George Floyd protests and subsequent civil unrest, including
but not limited to all intelligence products that contain any of the following keywords:
“George Floyd”, “protest”/“protester”,
“demonstration”/“demonstrator”. “Antifa”, “anarchist”,
“activist”, “civil unrest”, “violent extremist”, “extremists”,
“looting”/“looters”, “black lives matter”, “monument”,
“Covid”/“Covid-19”, “coronavirus,” “Operation Legend”, “National
Guard”, “pandemic”, and “riot”/“rioter”. You may limit your search to
intelligence products dated between May 25, 2020 and August 21, 2020.

FOIA requires each public body to promptly respond to a request for public records, either by
complying or denying the request, within 5 business days after the public body has received the
request. Under the Freedom of Information Act, a public body may extend the time to respond
to a FOIA request by up to 5 business days.

Due to the COVID-19 pandemic and the Governor’s issuance of a disaster proclamation, the
Chicago Police Department (CPD) is taking preventive measures in attempt to control the spread
of the virus. Therefore, the CPD has chosen to allow Department members assigned to the
Freedom of Information Act (FOIA) Unit to work remotely and has partially closed its office due
to sworn members assigned to administrative duties being deployed to the field for public safety.

Exhibit 7
 In addition, as more and more individuals become ill or come into contact with someone infected
with COVID-19 and are isolated or quarantined, members of CPD FOIA Unit may be unable to
report to work. In such circumstances, CPD may assert exceptions outlined in 5 ILCS 140/3(e),
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

particularly if responding to the request is unduly burdensome in the circumstances, requires

review by an unavailable staff member, or requires resources to obtain records located off-site.

Please keep in mind that FOIA allows CPD and the requester to come to a mutually agreeable
response period to comply with a FOIA request. Members of the public and media are asked to
keep these considerations in mind and are strongly encouraged to work with public bodies to
agree on reasonable and appropriate response times in light of the public health concerns we all
face. Given that the length of the pandemic remains unknown and that staffing levels have been
reduced, during this statewide emergency declaration, CPD may treat a FOIA request as unduly
burdensome, in the event that it is not feasible for CPD to comply with or deny a request for
public records within 5 business days after its receipt of the request or the time for response was
properly extended under 5 ILCS 140/3(e) because it would unduly burden CPD's operations
during the COVID-19 pandemic.

At this time, we are extending the time to respond to your request by an additional 5 business
days.

If you have any questions, please contact our office at 312-745-5308 or at the following address:

Chicago Police Department

Attention: Freedom of Information Officer
Office of Legal Affairs, Unit 114
3510 S. Michigan Ave.
Chicago, IL 60653

Sincerely,

Robert Earnshaw
Freedom of Information Officer
Chicago Police Department
 Fwd: Non-Commercial Police FOIA Request :: P611464-102220
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

---------- Forwarded message ---------

From: Ken Klippenstein <kenjklippenstein@gmail.com>
Date: Mon, Nov 9, 2020 at 12:21 PM
Subject: Re: Non-Commercial Police FOIA Request :: P611464-102220
To: Chicago Public Safety <chicagops@mycusthelp.net>

Greetings:

Can you please provide me with a status regarding my request, as well as an estimated completion date?

Thank you for your time and consideration.

Sincerely,
Ken Klippenstein
DC Correspondent/The Nation
(202) 510-1268
[Quoted text hidden]

Exhibit 8
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

Lori E. Lightfoot Department of Police · City of Chicago David O. Brown

Mayor 3510 S. Michigan Avenue ​·​ Chicago, Illinois 60653 Superintendent of Police

Nov. 12, 2020

Ken Klippenstein
kenjklippenstein@gmail.com

Re: NOTICE OF RESPONSE TO FOIA REQUEST

FOIA FILE NO.: P611464

Dear Ken Klippenstein:

The Chicago Police Department (CPD) is in receipt of your Freedom of Information Act (FOIA) request. In it, you request:

I respectfully request all Chicago Crime Prevention and Information Center (CPIC) intelligence products about or
concerning the George Floyd protests and subsequent civil unrest, including but not limited to all intelligence products
that contain any of the following keywords: “George Floyd”, “protest”/“protester”, “demonstration”/“demonstrator”.
“Antifa”, “anarchist”, “activist”, “civil unrest”, “violent extremist”, “extremists”, “looting”/“looters”, “black lives matter”,
“monument”, “Covid”/“Covid-19”, “coronavirus,” “Operation Legend”, “National Guard”, “pandemic”, and
“riot”/“rioter”. You may limit your search to intelligence products dated between May 25, 2020 and August 21, 2020.

Your request was reviewed by CPD and a search of records was conducted utilizing the provided search parameters.
Records are being provided. Please be advised that the Department has redacted certain information, as explained
below.

Section 7(1)(b) exempts from disclosure “[p]rivate information, unless disclosure is required by another provision of this
Act, a State or federal law or a court order.” 5 ILCS 140/7(1)(b). The FOIA, in 5 ILCS 140/2(c-5), defines “private
information” as follows:

“‘Private information’ means unique identifiers, including a person’s social security number, driver’s license number,
employee identification number, biometric identifiers, personal financial information, passwords or other access codes,
medical records, home or personal telephone numbers, and personal email addresses. Private information also includes
home address and personal license plates, except as otherwise provided by law or when compiled without possibility of
attribution to any person.”

Therefore, personal addresses, personal telephone numbers, personal license plate numbers, driver’s license numbers,
vehicle identification numbers, social security numbers, internal record numbers, SID numbers, FBI numbers, signatures,
medical information, and employee user codes/numbers are exempt and were properly redacted pursuant to Section
7(1)(b).

In addition, dates of birth, medical information, victim names and identifying information, and other third party names
and identifying information of persons such as friends, relatives, neighbors, and suspects who were never arrested or

Emergency and TTY:​ 9-1-1 ​· Non Emergency and TTY: ​(within city limits)​ ​3-1-1 ​· Non Emergency and TTY: ​(outside city limits) (312) 746-6000
E-mail:​ police@cityofchicago.org ​· Website:​ www.cityofchicago.org/police
Exhibit 9
 charged were also redacted as the public interest is not great while the privacy interests are considerable; therefore, this
information is exempt and protected from disclosure pursuant to 5 ILCS 140/7(1)(c) of FOIA. Section 7(1)(c) exempts
from inspection and copying the following:
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

“[P]ersonal information contained within public records, the disclosure of which would constitute a clearly unwarranted
invasion of personal privacy… ‘Unwarranted invasion of personal privacy’ means the disclosure of information is that
highly personal or objectionable to reasonable person and in which the subject’s right to privacy outweighs any
legitimate public interest in obtaining the information.” Id.

Also, the names, addresses and other information that could be used to identify the victim and /or witnesses, or
others who provided information to the police have been redacted. The redacted information is exempt from disclosure
under 5 ILCS 140/7(1)(d)(iv), which enables a public body to redact information that would “unavoidably disclose the
identity of a confidential source, confidential information furnished only by the confidential source, or persons who file
complaints with or provide information to administrative, investigative law enforcement, or penal agencies; except that
the identities of witnesses to traffic accidents, traffic accident reports, and rescue reports shall be provided by agencies
of local government, except when disclosure would interfere with an active criminal investigation conducted by the
agency that is the recipient of the request."

You have the right to have a denial reviewed by the Public Access Counselor (PAC) at the Office of the Illinois Attorney
General, 500 S. 2nd Street, Springfield, Illinois 62706, (877) 299-3642. You also have the right to seek judicial review by
filing a lawsuit in Cook County Circuit Court.

Sincerely,

R Earnshaw
Freedom of Information Officer
Chicago Police Department
Attention Freedom of Information
Legal Affairs Unit
3510 S. Michigan Ave
Chicago, IL 60653
 Chicago Police Department Special Order S03-04-04
CRIME PREVENTION AND INFORMATION CENTER (CPIC)
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

ISSUE DATE: 10 August 2020 EFFECTIVE DATE: 10 August 2020

RESCINDS: 30 November 2017 Version
INDEX CATEGORY: Field Operations

I. PURPOSE
This directive:

A. outlines the functions of the the Crime Prevention and Information Center (CPIC), which serves as
the Department's Fusion Center.

NOTE: CPIC has assumed the functions of the former Operations Command.

B. satisfies CALEA Law Enforcement Standard Chapters 11,15, and 42.

II. FUSION CENTER DEFINITION

The Department's Crime Prevention and Information Center is one of over seventy-five fusion centers in the
United States. A fusion center is a collaborative effort of two or more agencies that provide resources,
expertise, and information to the center with the goal of maximizing their ability to detect, prevent, investigate,
and respond to criminal and terrorists activity. Intelligence processes through which information is collected,
integrated, evaluated, analyzed, and disseminated are a primary focus. Data fusion involves the exchange of
information from different sources including law enforcement, public safety and the private sector, and
relevant and actionable intelligence results from analysis and data fusion. The fusion process helps agencies
be proactive and protect communities.

III. ROLE OF FUSION CENTERS

State and regional fusion centers enable local, state, and tribal governments to gather, process, analyze, and
share information and intelligence relating to all crimes and hazards while protecting civil liberties and privacy
interests of persons throughout the intelligence process. Fusion centers communicate, cooperate, and
coordinate with each other and with the federal government. They disseminate federally generated alerts,
warnings, and notifications regarding time-sensitive threats, situational awareness reports, and analytical
products and they fulfill criminal-predicate-based requests for information from Chicago Police Department
members and federal, state, and local law enforcement agencies.

IV. CRIME PREVENTION AND INFORMATION CENTER (CPIC)

CPIC is under the command of the Chicago Police Department's Deployment Operations Center, is located in
the Public Safety Headquarters building, and is staffed at all times by Department members. Personnel from
the Federal Bureau of Investigation, U.S. Department of Homeland Security (DHS), and the Illinois State
Police are assigned full time to the CPIC. Personnel from other agencies including, but not limited to, the
Illinois Department of Corrections, Cook County Sheriff's Police, DHS Homeland Security Investigations, U.S.
State Department, Metra Police, DHS Customs and Border Protection, U.S. Secret Service, U.S. Attorney's
Northern District of Indiana, Transportation and Security Administration, and various suburban police
departments work in the CPIC on a rotational basis.

CPIC will:

A. be staffed at all times.

B. issue replacement stars and shields.

Exhibit 10
S03-04-04 Crime Prevention and Information Center (CPIC) Current as of 10 August 2020:1312 hrs
© Chicago Police Department, August 2020 Page 1 of 5
 C. issue equipment on a temporary basis to include safety vests, flashlights, and expandable batons.
D. take appropriate action on communications received from within and outside the Department.
E. monitor anonymous citizen crime reporting via telephone, web, and text and disseminate information
for appropriate follow up.
F. monitor available camera feeds to provide information to field and investigative personnel.
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

G. receive notifications of:

1. any significant or newsworthy event occurring within the city;

2. implementation of any "Immediate Emergency" or "Special Response" plans;
3. reports of missing persons of any age where unusual circumstances exist or are potentially
newsworthy;
4. hate crimes/human rights incidents;
5. major thefts and/or burglaries;
6. any incident involving elected officials and/or their employees;
7. any incident concerning a diplomatic officer, consular officer, member of the family of a
diplomatic officer or a consular officer, honorary consul, and/or their employees;
8. information concerning strikes, labor-management incidents, or union controversies or the
possibility thereof;
9. incidents involving homeland security issues (locations, security breaches, etc.);
10. SWAT- related incidents;
11. bomb threats;
12. bombing and arson incidents, including attempts;
13. suspicious or unattended package found;
14. level 2 or higher hazmat incidents;
15. police facility power/phone/computer outage;
16. major power outage;
17. fatal fire incidents;
18. fatal traffic crashes;
19. any incident where a person sustains a gunshot wound, regardless of circumstances;
20. major incidents reported to police such as murders and aggravated batteries resulting in
serious injuries;
21. death investigations where the possibility of natural causes is not likely or cannot be
determined at the time;
22. arrest of a City of Chicago or Department employee;
23. killed, injured, or hospitalized Department employee;
24. shots fired at or by police personnel (with or without hits);
25. citizen is seriously injured or dies as a result of actions taken by a Department member;
26. any extraordinary or unusual occurrence that takes place within a lockup facility (as defined in
the Department directive titled "Required Lockup Standards and Reporting");
27. suicide or attempted suicide in police custody;
28. prisoner escape;
29. notification of units leaving the City for official police purposes;

S03-04-04 Crime Prevention and Information Center (CPIC) Current as of 10 August 2020:1312 hrs
© Chicago Police Department, August 2020 Page 2 of 5
 30. notifications and/or requests for the following units to be notified and/or dispatched:

a. Bureau of Internal Affairs

b. Civilian Office of Police Accountability (COPA)
c. Peer Support Section
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

d. Civil Rights Section

e. Computer and Electronic Data Seizures/Bureau of Detectives
f. Marine/Helicopter Unit
g. Chaplains Section
h. Facilities Management Division
i. Special Activities Section
31. request for use of Department special weapons/equipment;
32. request for an interpreter;
33. all notifications regarding possible homeland-security-related incidents to include notification
and/or request for the CPD/FBI Joint Terrorism Task Force (JTTF).
H. be the point of contact for the Street Deputy consistent with the Department directive titled "Deputy
Chief Assigned to the Street Operations Unit."
I. maintain a log of significant events on a 24-hour-per-day basis.
J. notify COPA in accordance with all applicable Department and unit-level directives.
K. provide services which include, but are not limited to:

1. receiving requests for emergency Facilities Management Division services pertaining to

outlying facilities during other than normal business hours.
2. receiving the required notification from Department members:

a. on the medical roll during the hours the Medical Section is closed.
b. arriving and departing at a court appearance (after 1600 hours) in a court where no
court sergeant or court officer is assigned or there is no court assembly room.
3. notifying the Special Activities Section as well as the Chaplains Section when a situation
indicates their services may be needed.
4. informing other governmental agencies (e.g., FBI, Secret Service, Bureau of Alcohol,
Tobacco, Firearms and Explosives) of certain incidents.
5. receiving requests for an ILEAS response into the City of Chicago consistent with the
Department directive titled "Illinois Law Enforcement Alarm System."
6. providing personnel information on an emergency basis when the Human Resources Division
is not operational.
7. performing such additional services as specified in Department directives.
L. notify the Safety Division of the Illinois Department of Labor (IDOL) if: one or more on-duty
Department members die of a heart attack or incur an injury on-duty that requires hospitalization or is
fatal.

1. The following information must be reported for each fatality or hospitalization incident:

a. the establishment name;

b. the location of the incident;
c. the time of the incident;
d. the number of fatalities or hospitalized employees;

S03-04-04 Crime Prevention and Information Center (CPIC) Current as of 10 August 2020:1312 hrs
© Chicago Police Department, August 2020 Page 3 of 5
 e. the names of any injured employees;
f. the reporter's contact person and his or her phone number; and
g. a brief description of the incident.
2. All work-related fatalities must be reported to IDOL within 8 hours.
3. All work-related inpatient hospitalizations, all amputations and all losses of an eye must be
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

reported to IDOL within 24 hours.

4. Notifications to IDOL will be made by telephone twenty-four hours per day, seven days a
week. If an IDOL representative is not available, the notification will be left on the IDOL voice-
mail system.
M. notify the Superintendent or his designee

1. of any injury or fatality of an on-duty Department member.

2. of any incidents where there may be a question of Department liability or those which may
result in heightened community interest.

V. ADDITIONAL RESPONSIBILITIES OF CPIC

CPIC is also responsible for the following:

A. Preparing and disseminating Gang Violence Reduction Strategy informational packets on victims of
murders or shootings.
B. Fulfilling "Requests for Information" (RFI) from sworn members of the Chicago Police Department
and other law enforcement agency personnel. In accordance with the CPIC Privacy Policy, the
request must have a criminal predicate and the requester must have a law enforcement purpose for
the requested information.
C. Making the initial entry into the Major Incident Notification System (MINS) when notified by field
personnel of a murder or a shooting.
D. Engaging in real time monitoring of criminal activity to assist in investigations and to inform field
personnel so that proactive measures can be considered. The following systems are monitored:

1. Anonymous community member reporting via Internet, text, and telephone;

2. Global Position System (GPS) based theft deterrent technology employed by commercial
entities;
3. Cameras in the City of Chicago including, but not limited to;

a. Transportation Security Administration (TSA) cameras;

b. Chicago Transit Authority (CTA) cameras;
c. Police Observational Device (POD) cameras;
d. Office of Emergency Management and Communication (OEMC) cameras;
e. Chicago Public Schools (CPS) cameras;
f. Red Light Violation cameras.
g. Speed Violation cameras.
4. Monitoring calls dispatched to the field via the 911 system;
5. Federal government informational portals;
E. Annual Audit

Annually conduct an audit per the CPIC privacy policy section N.2.(5).The goal of the audit is to
review a random sampling of CPIC records and provide appropriate recommendations to support the
CPIC leadership in ensuring the protection of community members' privacy, civil rights, and civil

S03-04-04 Crime Prevention and Information Center (CPIC) Current as of 10 August 2020:1312 hrs
© Chicago Police Department, August 2020 Page 4 of 5
 liberties in the CPIC's intelligence-related activities, including intelligence collection, analysis, and
dissemination.
F. Disseminating information by the following means;

1. Broadcast over police zone and citywide frequencies;

2. Portable Data Terminal (PDT) Messages;
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

3. E-mail Messages;
4. Information Bulletins;
5. Officer Safety Alerts;
6. All-Call Messages;
7. District Intelligence Bulletin (DIBS);
8. Telephone communication;
9. Facility Information Management System (FIMS).

(Items indicated by italics/double underline have been added or revised.)

Authenticated by: KC

David O. Brown
Superintendent of Police

20-061 JJR

S03-04-04 Crime Prevention and Information Center (CPIC) Current as of 10 August 2020:1312 hrs
© Chicago Police Department, August 2020 Page 5 of 5
 Fwd: IL FOIA Request 1
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

1 message

---------- Forwarded message ----------

From: Ken Klippenstein <kenjklippenstein@gmail.com>
Date: Oct 21, 2020, 8:46 PM -0400
To: ISP.FOIA.officer@illinois.gov
Subject: IL FOIA Request 1

Greetings:

Attached please find my first of two FOIA requests, dated October 21, 2020.

Thank you for your time and attention in this matter.

Sincerely,
Ken Klippenstein
DC Correspondent/The Nation
(202) 510-1268

IL FOIA STIC 1.pdf

74K

Exhibit 11
 Illinois Statewide Terrorism and Intelligence Center (STIC)
Bruce Kugler
Illinois State Police
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

Freedom of Information Officer

801 South 7th Street, Suite 1000-S
Springfield, Illinois 62703
Email: ISP.FOIA.officer@illinois.gov

October 21, 2020

Dear Custodian of Records,

This message constitutes a request under the Illinois Freedom of Information Act.

REQUESTER INFORMATION
Name: Ken Klippenstein
Position: DC Correspondent/The Nation
Address: 360 W Washington Ave Unit 1114, Madison, WI 53703
Email: kenjklippenstein@gmail.com
Phone: (202) 510-1268

RECORDS SOUGHT

I respectfully request records sufficient to show the titles of all intelligence products received,
produced, transmitted, or otherwise in the possession of the Illinois Statewide Terrorism and
Intelligence Center (STIC) between May 1, 2020 and August 18, 2020.

BACKGROUND

“Intelligence products” is a common term used by all intelligence agencies. In the intelligence
cycle, intelligence is collected and then processed by analysts into a manner suitable for
production that becomes a finished intelligence product. A finished intelligence product could
be a joint bulletin, a situational awareness report, a tactical intelligence report, a threat
assessment, etc. The finished intelligence product includes a title to that product that describes
the nature and content of that product. A fusion center has an objective, such as to determine
potential threats related to the protests and then begin collecting data on those threats, analyze
the data related to protests, and create a finished intelligence product from that collected data.

As part of a good faith effort to ensure that my request is as narrow as possible and will not be
unduly burdensome for you, please note that my request seeks only the titles of intelligence
products, not the contents of the intelligence products.

Please include records generated by STIC and those received or otherwise acquired from
other agencies, including state and federal partners (e.g., the Federal Bureau of Investigation,
the Department of Homeland Security, etc.) My request includes but is not limited to
Suspicious Activity Reports, Joint Intelligence Bulletins or any other intelligence bulletins,
Situational Awareness Reports or any other situation reports, and threat assessments.

Please preserve all records related to this request that may be subject to deletion.
 FEE CATEGORY AND REQUEST FOR A FEE WAIVER

As a reporter and DC correspondent for The Nation magazine, I am a representative of the

FILED DATE: 11/19/2020 3:56 PM 2020CH06888

news media. Disclosure of the requested information to me is in the public interest because it
is likely to contribute significantly to public understanding of the operations or activities of the
government and is not primarily in my commercial interest. Intelligence product titles would
provide the general public with information about what kinds of intelligence the government is
using their tax dollars to generate or access. It would also provide the general public with
document titles that they can use to subsequently request any of the documents they may
wish to learn more about. I have written extensively about national security matters and will
do the same here. My work has been referenced by The New York Times, The Washington
Post, The Los Angeles Times, The Atlantic, and other major media outlets.

EXEMPTIONS AND SEGREGABILITY

If any responsive record or portion thereof is claimed to be exempt from production, the
Illinois Freedom of Information Act provides that even if some of the requested material is
properly exempt from mandatory disclosure, all segregable portions must be released.

If documents are denied in part or in whole, please specify which exemption(s) is (are) claimed
for each passage or whole document denied. Please provide a complete itemized inventory and
a detailed factual justification of total or partial denial of documents. Specify the number of
pages in each document and the total number of pages pertaining to this request. In excising
material, please “black out” the material rather than “white out” or “cut out.” I expect, as
provided by FOIA, that the remaining non-exempt portions of documents will be released.

Please release all pages regardless of the extent of excising, even if all that remains are
stationary headings or administrative markings. In addition, I ask that your agency exercise its
discretion to release records which may be technically exempt, but where withholding serves
no important public interest.

Thank you for your time and attention in this matter.

Ken Klippenstein
 Fwd: FOIA # 20-3020 EXTENSION
1 message
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

---------- Forwarded message ----------

From: ISP.FOIA.Officer <ISP.FOIA.Officer@illinois.gov>
Date: Oct 29, 2020, 8:38 AM -0400
To: kenjklippenstein@gmail.com <kenjklippenstein@gmail.com>
Subject: FOIA # 20-3020 EXTENSION

Re: FOIR # 20-3020 Extension

Ken Klippenstein

The Illinois State Police acknowledges receipt of your FOIA request. (See attached request). A response to your request is due 10/29/2020.
However, additional time is needed to respond to your request. In accordance with Section 3(e) of the Freedom of Information Act (5 ILCS 140/3
(e)), the response due date is being unilaterally extended to 11/5/2020. The basis for this extension is as follows:

_____ The requested records are stored in whole or in part at another location.

_____ The request requires the collection of a substantial number of records.

_____ The request is stated in categorical terms which requires an extensive search for the records requested.

__X __ The requested records have not yet been located and additional time is needed to complete the search.

__X__ The requested records require examination and evaluation to determine if the documents are exempt from disclosure and/or must be
redacted.

__X__ The requested records cannot be provided within the prescribed time frame without causing an undue burden or interfering with the
operation of the Department.

_____ Consultation is needed with another public body in order to respond to the request.

Note – Extending the deadline to the above-referenced date does not necessarily mean a response and/or public records will be provided to you
by that date. FOIA requests are reviewed in the order in which they are received. Your patience is appreciated

Dawn M. Beckman

Illinois State Police

Legal Office/FOIA Coordinator

State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is confidential, may be attorney-client privileged
or attorney work product, may constitute inside information or internal deliberative staff communication, and is intended only for the use of the
addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you
have received this communication in error, please notify the sender immediately by return e-mail and destroy this communication and all copies
thereof, including all attachments. Receipt by an unintended recipient does not waive attorney-client privilege, attorney work product privilege, or
any other exemption from disclosure.

20-3020 request (10-22-20).pdf

196K

Exhibit 12
 Fwd: FOIA # 20-3020 EXTENSION
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

---------- Forwarded message ---------

From: Ken Klippenstein <kenjklippenstein@gmail.com>
Date: Mon, Nov 9, 2020 at 12:26 PM
Subject: Re: FOIA # 20-3020 EXTENSION
To: ISP.FOIA.Officer <ISP.FOIA.Officer@illinois.gov>

Greetings:

Can you please provide me with the status of my request, as well as an estimated completion date now that the
November 5 date has passed?

Thank you for your assistance in this matter.

Sincerely,
Ken Klippenstein
DC Correspondent/The Nation
(202) 510-1268
[Quoted text hidden]

Exhibit 13
 Fwd: IL FOIA Request 2
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

1 message

---------- Forwarded message ----------

From: Ken Klippenstein <kenjklippenstein@gmail.com>
Date: Oct 21, 2020, 8:47 PM -0400
To: ISP.FOIA.officer@illinois.gov
Subject: IL FOIA Request 2

Greetings:

Attached please find my second of two FOIA requests, dated October 21, 2020.

Thank you for your time and attention in this matter.

Sincerely,
Ken Klippenstein
DC Correspondent/The Nation
(202) 510-1268

IL FOIA STIC 2.pdf

75K

Exhibit 14
 Illinois Statewide Terrorism and Intelligence Center (STIC)
Bruce Kugler
Illinois State Police
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

Freedom of Information Officer

801 South 7th Street, Suite 1000-S
Springfield, Illinois 62703
Email: ISP.FOIA.officer@illinois.gov

October 21, 2020

Dear Custodian of Records,

This message constitutes a request under the Illinois Freedom of Information Act.

REQUESTER INFORMATION
Name: Ken Klippenstein
Position: DC Correspondent / The Nation
Address: 360 W Washington Ave Unit 1114, Madison, WI 53703
Email: kenjklippenstein@gmail.com
Phone: (202) 510-1268

RECORDS SOUGHT

I respectfully request all Illinois Statewide Terrorism and Intelligence Center (STIC) intelligence
products about or concerning the George Floyd protests and subsequent civil unrest, including
but not limited to all intelligence products that contain any of the following keywords: “George
Floyd”, “protest”/“protester”, “demonstration”/“demonstrator”. “Antifa”, “anarchist”, “activist”,
“civil unrest”, “violent extremist”, “extremists”, “looting”/“looters”, “black lives matter”,
“monument”, “Covid”/“Covid-19”, “coronavirus,” “Operation Legend”, “National Guard”,
“pandemic”, and “riot”/“rioter”. You may limit your search to intelligence products dated
between May 25, 2020 and August 21, 2020.

BACKGROUND

“Intelligence products” is a common term used by all intelligence agencies. In the intelligence
cycle, intelligence is collected and then processed by analysts into a manner suitable for
production that becomes a finished intelligence product. A finished intelligence product could
be a joint bulletin, a situational awareness report, a tactical intelligence report, a threat
assessment, etc. The finished intelligence product includes a title to that product that describes
the nature and content of that product. A fusion center has an objective, such as to determine
potential threats related to the protests and then begin collecting data on those threats, analyze
the data related to protests, and create a finished intelligence product from that collected data.

Please include records generated by STIC and those received or otherwise acquired by STIC
from other agencies, including state and federal partners (e.g., the Federal Bureau of
Investigation, the Department of Homeland Security, etc.) My request includes but is not limited
to Suspicious Activity Reports, Joint Intelligence Bulletins or any other intelligence bulletins,
Situational Awareness Reports or any other situation reports, and threat assessments. Please
preserve all records related to this request that may be subject to deletion.
 FEE CATEGORY AND REQUEST FOR A FEE WAIVER

As a reporter and DC correspondent for The Nation magazine, I am a representative of the news
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

media. Disclosure of the requested information to me is in the public interest because it is likely
to contribute significantly to public understanding of the operations or activities of the
government and is not primarily in my commercial interest. Intelligence product titles would
provide the general public with information about what kinds of intelligence the government is
using their tax dollars to generate or access. It would also provide the general public with
document titles that they can use to subsequently request any of the documents they may wish
to learn more about. I have written extensively about national security matters and will do the
same here. My work has been referenced by The New York Times, The Washington Post, The
Los Angeles Times, The Atlantic, and other major media outlets.

EXEMPTIONS AND SEGREGABILITY

If any responsive record or portion thereof is claimed to be exempt from production, the Illinois
Freedom of Information Act provides that even if some of the requested material is properly
exempt from mandatory disclosure, all segregable portions must be released.

If documents are denied in part or in whole, please specify which exemption(s) is (are) claimed
for each passage or whole document denied. Please provide a complete itemized inventory and a
detailed factual justification of total or partial denial of documents. Specify the number of pages
in each document and the total number of pages pertaining to this request. In excising material,
please “black out” the material rather than “white out” or “cut out.” I expect, as provided by the
FOIA, that the remaining non-exempt portions of documents will be released.

Please release all pages regardless of the extent of excising, even if all that remains are stationary
headings or administrative markings. In addition, I ask that your agency exercise its discretion to
release records which may be technically exempt, but where withholding serves no important
public interest.

Thank you for your time and attention in this matter.

Ken Klippenstein
 Fwd: FOIA # 20-3021 EXTENSION
1 message
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

---------- Forwarded message ----------

From: ISP.FOIA.Officer <ISP.FOIA.Officer@illinois.gov>
Date: Oct 29, 2020, 8:38 AM -0400
To: kenjklippenstein@gmail.com <kenjklippenstein@gmail.com>
Subject: FOIA # 20-3021 EXTENSION

Re: FOIR # 20-3021 Extension

Ken Klippenstein

The Illinois State Police acknowledges receipt of your FOIA request. (See attached request). A response to your request is due 10/29/2020.
However, additional time is needed to respond to your request. In accordance with Section 3(e) of the Freedom of Information Act (5 ILCS 140/3
(e)), the response due date is being unilaterally extended to 11/5/2020. The basis for this extension is as follows:

_____ The requested records are stored in whole or in part at another location.

_____ The request requires the collection of a substantial number of records.

_____ The request is stated in categorical terms which requires an extensive search for the records requested.

__X __ The requested records have not yet been located and additional time is needed to complete the search.

__X__ The requested records require examination and evaluation to determine if the documents are exempt from disclosure and/or must be
redacted.

__X__ The requested records cannot be provided within the prescribed time frame without causing an undue burden or interfering with the
operation of the Department.

_____ Consultation is needed with another public body in order to respond to the request.

Note – Extending the deadline to the above-referenced date does not necessarily mean a response and/or public records will be provided to you
by that date. FOIA requests are reviewed in the order in which they are received. Your patience is appreciated

Dawn M. Beckman

Illinois State Police

Legal Office/FOIA Coordinator

State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is confidential, may be attorney-client privileged
or attorney work product, may constitute inside information or internal deliberative staff communication, and is intended only for the use of the
addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you
have received this communication in error, please notify the sender immediately by return e-mail and destroy this communication and all copies
thereof, including all attachments. Receipt by an unintended recipient does not waive attorney-client privilege, attorney work product privilege, or
any other exemption from disclosure.

20-3021 request (10-22-20).pdf

195K

Exhibit 15
 Fwd: FOIA # 20-3021 EXTENSION
FILED DATE: 11/19/2020 3:56 PM 2020CH06888

---------- Forwarded message ---------

From: Ken Klippenstein <kenjklippenstein@gmail.com>
Date: Mon, Nov 9, 2020 at 12:27 PM
Subject: Re: FOIA # 20-3021 EXTENSION
To: ISP.FOIA.Officer <ISP.FOIA.Officer@illinois.gov>

Greetings:

Can you please provide me with the status of my request, as well as an estimated completion date now that the
November 5 date has passed?

Thank you for your assistance in this matter.

Sincerely,
Ken Klippenstein
DC Correspondent/The Nation
(202) 510-1268
[Quoted text hidden]

Exhibit 16