Gliniewicz - Lake Zurich

March 24, 2021

To Whom It May Concern:

Pursuant to the Illinois Freedom of Information Act, (5 ILCS 140/1), I respectfully request access to and a copy of the following records:

All records created and collected by Shaun Knight in connection with Lake County Major Crimes Task Force Case #15-07 of Joe Gliniewicz, which is a closed case.

-The responsive records should come from September 1st - November 4th, 2015.
-This should include any such records that were provided to the named agents in connection with their investigation from other law enforcement, any outside agency, or any individual.
-The records should include audio, video, photographs, databases, and any paper or digital records.
-I request the above items in a digital format, preferably as a .wav file format for the audio, .pdf for the documents, .mov for the videos, their native format for databases, and .tiff for photos. Please send these files via email or FTP upload to save time and resources.
-If a digital machine readable format is not available, please notify me of my options ahead of fulfilling the record’s request

I also draw your attention to (5 ILCS 140/1), which states that it is a “fundamental obligation of government to operate openly and provide public records as expediently and efficiently as possible in compliance with this Act.” In accordance with that principle please assist in making a focused and effective request by:
1. Identifying records and information responsive to the request,
2. Describing the information technology and physical location in which the records exist, and
3. Providing suggestions for overcoming any practical basis for denying access to the records or information sought.

In accordance with (5 ILCS 140/9) the agency always bears the burden of justifying non-disclosure, therefore if you determine that any fields are exempt from disclosure, please identify those fields, specify the statues which exempt them, and release all other segregable parts.

Please waive any applicable FEES, as this IS NOT BEING MADE FOR COMMERCIAL PURPOSES. Through this request, I am gathering information as the basis for a six-part audio documentary about the Gliniewicz case, which has already been covered by local, national and international news outlets extensively. Additionally, I have already done extensive reporting and interviews for the documentary.

This information is of crucial importance to maintaining a relationship of trust with the larger community and is vital for the public good. This information is for journalistic dissemination to the general public, furthermore it is likely to contribute significantly to public understanding law enforcement and the use of taxpayer resources.

As I am making this request as a journalist and this information is of timely value, I would appreciate your communicating by email, rather than by mail, if you have questions regarding this request. You can see some of my work here:

https://art19.com/shows/dr-death-s2

https://www.propublica.org/article/the-price-of-americas-inability-to-track-child-deaths-from-abuse-and-neglect-sometimes-more-lives

https://www.chicagotribune.com/news/breaking/ct-funeral-three-bodies-eric-morse-20170324-story.html

If you determine that you must charge a fee, I agree to pay any reasonable copying and postage costs of not more than $5. If the cost would be greater than this amount, please notify me by email before incurring any expenses. Please provide a receipt indicating the charges for each document.

Please be advised that (5 ILCS 140/11) states that, “Any person denied access to inspect or copy any public record by a public body may file suit for injunctive or declaratory relief.” And I am prepared to pursue whatever legal remedy necessary to obtain access to the requested records. I would also note that willful violation of the open records law can result in the award of court costs and reasonable attorney fees. See (5 ILCS 140/11, i-j).

As provided in the open records law, (5 ILCS 140/3), I will expect your response within 5 business days as the statute requires, starting today, March 24, 2021.

Thank you for your assistance.

Sincerely,

Heather Schröering