Case: 1:23-cv-04658 Document #: 1 Filed: 07/19/23 Page 1 of 17 PagelD #:1 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS MUDRON, JIM MCFARLAND, and JOSEPH HOSEY, SHAW MEDIA NANCY ROECHNER, CITY OF JOLIET, Defendarts. EASTERN DIVISION ROBERT O'DEKIRK, REBECCA) MARIE as individual and as Guardian) for MASON PALACIOS, ) Plaintiff, ) ) . ) Case No. 23 CV 4658 > AL ROECHNER, MARC REID, PAT) ) ) ) ) cor! Now come the Plitifs, ROBERT O'DEKIRK, REBECCA MARIE, as individual and as Guardian for MASON PALACIOS, by snd through their ttomeys, Michae Enger and Alexander Michael of Michael D. Ettinger and Associates P.C, and Denis Berkson ofthe Law Office of Denis Burkeson and complains of defendants, AL ROECHNER, MARC REID, PAT MUDRON, JIM MCFARLAND, JOSEPH HOSEY, SHAW MEDIA, NANCY ROECHNER, and CITY OF JOLIET. In suppor of such Complaint, Plaintiff hereby alleges as follows: JURISDICTION AND VE |. This ation arises under 42 U.S.C. §§ 1983 in which police officers ofthe CITY OF JOLIET (Hereinafter “CITY") acting under color of law, deprived Plaintiff, ROBERT O°DEKIRK ( Hereinafter “O"DEKIRK" or “Plaintiff” of his civil and constitutional rights and IS US, Code § 1964(a) (jurisdiction over civil RICO claims), wherein the CCITY ctedas an enterprise by the Defendants to further deliberate ilegal conduct agtinst O°DEKIRK.(Case: 1:23-cv-04658 Document #: 1 Filed: 07/18/23 Paye 2 of 17 PagelD #2 ‘This Cour has orginal junction over these federal claims pursuant 028 US. §§ 1331 and 1343 “The Court as supplemental jurisdiction to hear pendent state claims under 28 US.C § 1367 ‘ewe inthis dist is proper under 2 US.C §1391(). All events occured within the Northern District of Minois and all partes reside or have offices within the Noro Distt of Tinos. PARTIES “The Plinff, ROBERT O'DEKIRK, is resident ofthe state of Hlinos, nd resides in the Northern Distt of ios. CO’DEKIRK is the former mayor of defendant, CITY OF JOLIET. REBECCA MARIE isthe wife of O’DEKIRK. MASON PALACIOS i the special needs son of REBECCA MARIE and the stepson of O'DEKIRK. REBECCA MARIE isthe legelly appointed guardian of MASON PALACIOS. CCETY OF JOLIET isa municipality located within the Northern District of Mlinois and incorporated in Minos. a resident ofthe sate of Ilinois and resides within [AL ROECHNER ("ROECHNER" the stat of nos. Ths individual is being sued in his individual and official capacity. ROECHNER served on the Joliet Police Department since 1991 and was the Police Chief of the CITY between 2018-2021 MARC REID (“REID") i a resident of the state of Iino and resides within the tate of Winois, This individual is being sued in his individual and official capacity.Case: 1:28-cv-04888 Document i: 1 Filed: 07/18/23 Page 3 of 17 PagelD #.3 14 REID was the former Deputy Chie of Operations forthe CITY of Joli rom 2018-2031 and.a veteran police officer REID was previously employed with the City of Joliet internal affirs prior to becoming » Deputy Chef He left the Joliet police dept Jan 2021 ‘with many yar of police experience 15, PAT MUDRON ("MUDRON’)is a resident ofthe state of Minos and resides within the state of Ios. This individual is being sued in bs individual and oficial capacity 16, MUDRON i councilman for Dist 2 in Joliet since 2015. 17.JIM MCFARLAND (°MCFARLAND") is resident of the sate of Ilinois and resides ‘within the sate of Minos. This individual is being sued in his individual and offca, capaci 18. MCFARLAND is former councilman for oiet between 2013-2016 19, JOSEPH HOSEY (HOSEY") isa resident ofthe stat of Illinois and resides within the state of thio. 20, HOSEY was until May of 2022 the managing editor of the Herald News which isa pat of Defendant SHAW MEDIA. 21, Defendant SHAW MEDIA has contol over the publications of Herald News 22, SHAW MEDIA approved ll articles by HOSEY, knowing they wee fs, relevant to this ation, published in the Heald News. 23, Herald News isa news publication that in part, eves the Jolie, Hinos area. 24, NANCY ROECHNER (NANC isthe wife of ROECHINER. THE SOCIATION IN FACT 25. On or about November 1, 2020, Defendants, ROECHNER, NANCY, REID, MUDRON, MCFARLAND, and HOSEY, met with then Councilman Donald Dickinson(case: 1:23-cv-04658 Document #: 1 Filed: 07/19/23 Page 4 of 17 PagelD #4. Dickinson”) at ROECHNER’s home fora meeting. (Hereinafter this Novernber 1, 2020 shal be referenced at “Meeting” or “the Meeting 26. ROECHNER, NANCY, REID, MUDRON, MCFARLAND, and HOSEY form a cabal thats an Assocation in Fact. 27. Te Assocation in Fact had a purpose to devise plan o strategy in which ROBCHNER, NANCY, REID, MUDRON, MCFARLAND, and HOSEY could create a pubic poitial backlash against O>DEKIRK withthe gol of hr losing his poston as mayor of Jit and being charged erminally 28. ROECHNER, NANCY, REID, MUDRON, MCFARLAND, and HOSEY all dsiked or bated O’DEKIRK and throughout O"DEKIRKS's time as mayor, routinely opposed (O°DEKIRK on votes, goals, and interests of the CITY in the course of O'DEKIRK, ‘cary out his duties as mayor. 29. ROECHINER, NANCY, REID, MUDRON, MCFARLAND, and HOSEY each had an ongoing relationship with eachother wherein hey had bepun planning O'DEKIRK's demise since the summer of 2019 30. The Assocation in fac cared ot thir purpose through the predicete acts described below. ‘THE SCHEME 31. Knowing orbliving that Dickinson was the sot of ndvidual who could easily be manipulated, ROECHINER, NANCY, REID, MUDRON, MCFARLAND, and HOSEY use Dickinson as ther puppet to hatch their conspiracy and further ther scheme 32. During the Mestng, ROECHINER, NANCY, REID, MUDRON, MCFARLAND, and LHOSEY, had a lengthy discussion. During such conversation the five of them eachCase: 1:23-cv-04688 Document #: 1 Filed: 07/19/23 Page § of 17 PagelO #5. ‘agreed and conspired to fabricate false claims against Plaintif O'DEKIRK, with the sole intention of having O'DEKIRK charged with crime in order to damage his politcal standing and reputation inthe community of Joliet. 33. ROECHNER, NANCY, REID, MUDRON, MCFARLAND and HOSEY di this with the intent of advancing their own politcal and carer goals and agendas ithe CITY OF JOLIET, and with the intention of damaging the political prospects of O'DEKIRK. 4, Itwas imperative for ROECHNER, NANCY, REID, MUDRON, MCFARLAND, and HOSEY to damage the repuation of O'DEKIRK because he vas ther political opponent in Joliet and they saw him a a politcal obstacle to their career and politcal goals in Joliet 35. ROECHNER, NANCY, REID, MUDRON, MCFARLAND and HOSEY, during the ‘meeting, conspired and concocted a false allegation of itimication against O’DEKIRK. 36, ROECHNER, NANCY, REID, MUDRON, MCFARLAND, and HOSEY, convinced 0. 38 3% Donald Dickinson (" ckinson") trough coersion,itimidatin, and undve influence, to make a fle police report agsinst O"DEKIRK. Dickinson had sent photos of is genitals to an individual with whom be had been romantically involved wit ROECHNER, NANCY, REID, MUDRON, MCFARLAND, snd HOSEY came into possession a these photos. Specifically, ROECHNER, NANCY, REID, MUDRON, MCFARLAND, and HOSEY threatened to reveal the photographs of Dickinson to ruin is politi carcer in Joliet and Will County, Ilinois.‘Case: 1:23-cv-04658 Document #: 1 Filed: 07/19/23 Page 6 of 17 PagelD #6 40, Dickinson, feling compelled under treat ofthese photos being released andthe treat of fale criminal charge being brought against hm bythe other atendees of the mesting, ‘made ‘report’ to REID falsely claiming O"DEKIRK intimidated him, 41. The ‘statements’ Dickinson made to REID alleged in sumsmary that O"DEKIRK had ‘ome into postession of photos of Dickinson's genital 42, Dickinson’s statement was tht O°DEKIRK threstened him to publi release the nude ‘Photographs of Dickinson to rin Dickinson’ carer 43. O‘DEKIRK in reaty never had possession of Dickinson's nude photos, ordi he even ‘now oftheir existence until this scheme became public. 44, REID created police report based on Dickinson flee statements ALTERNATIVE ENTERPRISE: CITY OF JOLIET 45. In the altemative tothe enterprise of Association in Fact, Plaintiff pleads the CITY OF JOLIET as an alterative enterprise 46, Phat night, atthe Meeting, REID, acting in his official capacity as an Officer ofthe CITY OF JOLIET, documented these false allegation using an obsolete police form fom the cry. 47, REID’s report was handwritten which was ouside the routine practice ofthe Joliet Police 48, REID's report being on an outdated form was alo ouside the routine practice of Joliet Police 49, REID, having just conspired with ROECHNER, MUDRON, MCFARLAND, and HOSEY to fricate these false allepations and coering Dickinson, made the report knowing the allegations against O"DEKIRK were false