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There are many severities of punishment when it comes to murder or homicide in Illinois. For example, consider the two possible scenarios in which death could occur: 1) a driver carelessly text while driving and runs over a pedestrian in a crosswalk, and 2) a person plots and shoots their business partner over a business argument. In both scenarios the victims are equally dead, but one died of manslaughter while the other died of first degree murder. There are three general categories of homicide: first degree murder, second degree murder, and manslaughter.
When Does Second Degree Murder Occur and What Sets it Apart From First Degree Murder? First degree murder is a premeditated plot to kill, second degree murder is a murder in the “heat of the moment,” and manslaughter is unintentional but caused by reckless or careless behavior. Second degree murder “occurs when the defendant commits either intentional, knowing, or strong-probability first-degree murder and the defendant either acted under a sudden and intense passion resulting from serious provocation by the victim or in an unreasonable belief that his actions were justified by self-defense,” according to the September Illinois Criminal Law Digest. In some instances, murder charges are reduced during the appeals process when an argument can be made in favor of the defendant’s actions or thoughts at the time of the murder. Road Rage Incident Turns Deadly During Short Lived Fistfight In the summer of 2016, an appellate court reversed the original charges of second degree murder when a man killed another in a road rage incident, according to the June Illinois Criminal Law Digest. The defendant entered into an argument with another man regarding road rage and hit him in the face with his fist. The blow knocked the other man back, who hit his head on the ground and died of his injuries. The defendant was charged with second degree murder. Knowing That One’s Acts Create a Strong Probability of Death However, the appellate court ruled that because the defendant did not know that his acts created a strong probability of death or great bodily harm, the second degree murder charges should be reversed. To commit second degree murder, a reasonable person must have knowledge that their actions would result in another’s death. According to the Illinois Criminal Law Digest, “there is a general rule in Illinois law that death is not ordinarily contemplated as a natural consequence of a blow or blows from a bare fist,unless there is a great disparity in size and strength between the defendant and the victim.” Because the victim and the defendant were of similar size, and the defendant only struck the victim once, the appellate court concluded the “defendant could not have known that death or great bodily harm was practically certain to occur.” Call Chicago Criminal Appeals Attorneys Barney and Hourihane Today If you have been charged with homicide of any degree, or another crime that you were wrongly, or overly, punished for, do not hesitate to call the Chicago criminal appeals attorneys of Barney and Hourihane today at 312-854-0906. On July 4th of 2015, a Muslim woman was tackled to the ground by five Chicago police officers on the stairs of a subway station, according to The Washington Post. Her hijab (traditional headscarf) was ripped off, she was handcuffed and placed under arrest, then taken to jail. While she was being tackled and handcuffed, her shirt was pulled up and her pants were pulled down, exposing her midriff. This violent act was particularly embarrassing and humiliating to the victim because of her traditional Muslim upbringing.
Later, at the police station she was ordered to strip naked by a female officer and then put in a cell with the door open, while male officers looked in and laughed, according to the lawsuit. The victim, a 32-year-old student from Saudi Arabia, and a Chicago resident, was making her way home at the time of her arrest. She was charged with resisting arrest and reckless behavior. Clear surveillance footage shows her calmly walking up the stairs of the subway station with dozens of other passengers before she is tackled by the five officers. Both charges were later dropped. Lawsuit Filed in August of 2016 Against Chicago Police Department and Six Officers A federal lawsuit was filed this summer of 2016, claiming that the officers had acted with prejudice and malice. The lawsuit states that she “has suffered violations of her constitutional rights, emotional anxiety, fear, humiliation, monetary loss, embarrassment, fear, pain and suffering and future pain and suffering.” Furthermore, the lawsuit claims that she was the victim of false rarest, unlawful search, excessive force, malic prosecution, and that her rights to freedom of religious expression under the First and Fourth amendments were also violated. The police claim that they arrested her because they suspected she was a suicide bomber, because of the way she was dressed. Hate Crimes Surge Through 2015 and Beyond According to data compiled by the Federal Bureau of Investigation (FBI), hate crimes against Muslims increased by 67 percent in 2015, as reported by Mother Jones. FBI data reveals that there were 5,858 hate crimes in total for 2015, though that number is highly inaccurate. The FBI’s data on hate crimes is given by local, county, and state law enforcement agencies, and only data that is given at will is used in the FBI’s report. The Department of Justice (DOJ), on the other hand, estimated that there were 260,000 hate crimes in 2013. 92 percent of those hate crimes involved violence, according to the DOJ’s data, while the FBI reports that just 44 percent of hate crimes involved violence. Obviously, more accurate reporting is needed by local law enforcement agencies. Most hate crimes that get reported to the police never make their way into the FBI’s report, meaning that the extent of racism, xenophobia, Islamophobia, and other intolerances are not clearly seen by the federal government. Contact a Chicago Attorney Today If you have been the victim of a civil rights violation or police misconduct, contact the Chicago civil rights attorneys of Barney and Hourihane today at 312-854-0906 for immediate assistance. Stop and frisk programs began in the 1960s and were aimed, as they are today, at minorities, according to Time Magazine. While crime has seen a large decline in Chicago and the nation as a whole over the past few decades, stop and frisk programs are continuing to gain ground in large cities such as New York and Chicago, wreaking havoc on millions of people’s daily lives.
Throughout its history, stop and frisk has been used not to decrease crime, which it does not actually succeed in doing, but as a crutch for politicians looking to gain votes through fear mongering. The sole reason that stop and frisk still exists is due to the fact that politicians are so adept at feed on their constituents’ racist belief systems. While, according to ABC 7 News, stop and frisks fell by 80 percent in 2015, there has been talk among politicians, including president-elect Donald Trump, to reinvigorate efforts. Right to Remain Silent, and Ask to See Search Warrant If a police officer stops you while you are walking along the sidewalk, there are certain steps you must take to protect yourself, as described by the New York Civil Liberties Union. First and foremost, you should remember that you have the right to remain silent. You do not have to answer the officer’s questions. Many people get in trouble down the road because of things they said to an officer that they did not legally have to omit. And, if the officer attempts to search yourself or your belongings, they must ask consent. If they have a search warrant, you should ask to see it. If they do not have a warrant, make sore to say that you do not consent to this search. The search may happen regardless, and you should cooperate fully if so, as it is a crime to interfere. Stop and Frisk Procedure Police may stop you if they have “reason to believe” that you are currently committing a crime, are about to commit a crime, or have committed a crime in the past. First, ask if you are under arrest or are allowed to leave. Do not use foul language or insult the officer, no matter what they say or do or how insulting they are being to you. Do not run from, resist, or touch touch the officer. Try to use calm rationale to deescalate the situation. You do not have to agree with the officer’s accusations, and remember that you can always remain silent if you so choose. Take the additional steps as well:
Contact a Chicago Attorney If your civil rights have been violated by stop and frisk, contact the experienced Chicago civil rights attorneys with Barney and Hourihane law firm today at 312-854-0906 for immediate assistance. How a judge and prosecutor come to their decisions may well be swayed by preconceived notions. If a judge has a grudge against a type of person or has strongly irrational feelings about the type of crime that a defendant allegedly committed, unfortunately there is not a lot that can be done about that. However, what a judge or prosecutor say and how those beliefs are represented in the courtroom does matter. A judge cannot pass down sentencing by slandering the defendant before the jury has reached a decision, for example.
If a judge or prosecutor is found to have behaved inappropriately and that behavior could have intentionally or unintentionally swayed the outcome of the decision, a retrial may be necessary. Or, if it can be proven at a later time, an appeal may be granted. The criminal appeals attorneys of Barney and Hourihane can be reached at 312-854-0906 for experienced, aggressive, and immediate assistance. Cook County Judge Comments Found “Highly Offensive” Recently, a Cook county judge was found to have said highly offensive remarks by a three-judge appellate court, according to the Chicago Tribune. The judge has a prior history of using profane language and making improper comments, and has been reassigned and disciplined before in the past. In this instance, the judge’s remarks have lead to a retrial. The defendant, accused of being part of an attempted murder of three Chicago police officers, apologized for his actions to his children at the sentencing. Right afterwards, the judge said "I don't believe they thought about their kids in the slightest on that day. If someone said, 'Hey, man, how are your kids doing?' their response would be 'What kids? I got kids somewhere?'" The appellate decision claimed that the judge’s comments “leave little doubt that they were derisive and intended to malign an entire class of criminal defendants. ...The court's sarcasm was unwarranted and wholly inappropriate." Additionally, the prosecutor described the defendant as a “criminal” in her opening statements back in 2013, which the appellate panel also condemned. Personal Bias is Cause for Serious Concern Whenever a judge is in the position to make an impartial decision, there is great reason for alarm. The defendant’s future lies partially in the hands of that judge, and to make anything but an unbiased ruling is one of the greatest pillars of the U.S. justice system. According to 28 U.S. Code § 455, “Any justice, judge, or magistrate judge of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably be questioned.” Personal bias should not have a place in the courtroom. It is impossible for any person to be completely unbiased in every scenario, even a judge. However, when there is reason to believe, through their actions or words, they a judge has such a bias, you must take swift action. Call the experienced Chicago criminal appeals attorneys of the Barney and Hourihane law firm today at 312-854-0906 for, aggressive and experienced representation. For over a decade agents from The Bureau of Alcohol, Tobacco, and Firearms (ATF) have been conducting sting operations. In many of these operations, an undercover agent will act as an upset drug dealer and recruit, sometimes even coerce, young men in the neighborhood to help him rob a stash house. A stash house is where drugs, weapons, and occasionally people are hidden. However, in these sting operations the stash house is a fictitious house made up by ATF agents themselves. The young men caught up in these fake robbery attempts and are convicted of drug conspiracy and often violent crimes for brandishing weapons, many times provided by ATF agents.
Racial Discrimination This past September a newly released investigation from USA Today put these sting operations in the spotlight, accusing them of discriminating based on race, as they are most often in poor African American neighborhoods. The research, performed by a Ph.D. professor from Columbia University, was filed in a federal court in Chicago. As a result of his findings, Fagan is an expert witness in several court cases in Illinois. All Defendants are Either Black or Hispanic Looking across the cases presented by the Bureau, almost all of the defendants are either black or hispanic. Fagan’s report shows that statistically there is only a 0.1 percent chance that the Bureau could have unbiasedly picked a population so racially skewed as they did, even when solely looking at those who already have a criminal record. Often, small-time criminals were being caught up in the fictitious robberies, at times provided with guns by the ATF, and then charged with having committed serious crimes that comes with sentences such as life in prison. Dismissal of Federal Charges With this new report the University of Chicago’s legal clinic filed three motions to dismiss federal drug and weapons cases that targeted minority males. The clinic is expected to file motions for at least seven more cases within the next month. Since the report, several charges among other defendants were dropped without explanation. The local Chicago police are not the only ones who are causing racial profiling concerns. The Bureau of Alcohol, Tobacco, and Firearms is a federal agency that operates throughout the country. We are waiting to see the outcome of these upcoming cases. It is possible the defendants will be granted new trials. It is also possible that these cases will go all the way to the Supreme Court. If your civil liberties have been violated in any way, call the experienced Chicago civil rights violations attorneys of Barney and Hourihane today at 312-854-0906. Lawyer Argues for Exclusion of Canine Evidence A criminal appeals lawyer for an Aurora man is appealing his 2013 conviction for murder, arguing that the trial court should not have allowed some of the evidence in the trial, The Chicago Tribune reports. A jury convicted the man, Aurelio Montano, of murdering his wife. The wife, Maria Guadalupe, died in 1990. Montano’s lawyer argues that the trial judge should have excluded testimony about the use of dogs to search for the wife’s body. Montano, who is 60 years old, was already serving a prison sentence for two other murders in Aurora in 1996. Police Dogs Found Rug with Scent of Cadaver, but No Body Prosecutors charged Montano in 2008 with murdering his wife, Montano family members found a rug buried on the farm where they Aurelio Montano and his wife had lived and worked. Police investigators connected interviews with different family members that seemed to indicate that Montano had disposed of Maria Guadalupe’s body after she vanished. During the trial, the prosecutors also introduced testimony regarding dogs that police used to search for Maria Guadalupe’s body. They testified that the dogs found the scent of a human cadaver on a rug and in the hole where the rug was buried. Testimony from the family indicated that Aurelio Montano may have wrapped Guadalupe’s body in the rug before burying her. Montano’s lawyer argues that the judge should not have allowed the testimony about the dogs to come before the jury because there was not enough scientific evidence to show that the dogs were able to detect the scent of a dead body. Without such scientific evidence, the lawyer argues, the canine testimony is “unduly prejudicial”—that is, it distorts the jury’s perception of events without really proving anything. He also argued that, because police never found a dead body, there was not sufficient evidence to prove that anyone killed Maria Guadalupe. The state criminal appeals prosecutor argues in response that scientific research has established the ability of trained canines to locate the scent of a cadaver. According to The Guardian, the kind of dogs used to investigate Maria Guadalupe Montano’s disappearance cannot naturally detect the scent of a cadaver; police canine trainers must teach them how to do it. When Courts Allow Prejudicial Evidence, Defendants can Appeal Rule 403 of the Illinois Rules of Evidence states: “Although relevant, evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.” In Illinois, a defendant may appeal a criminal conviction to the Illinois Appellate Court. On appeal, the convicted person’s lawyer may point out any errors that may have significantly affected the defendant’s rights in the original trial. This includes occasions where the trial judge violated rules of evidence by allowing testimony which the judge should have excluded. If the judge determines that the judge should have excluded the evidence and that the inclusion of the evidence seriously changed the outcome of the trial, the judge can order the trial court to retry the case, or even reverse the conviction. Contact a Chicago Criminal Appeals Lawyer If you or someone you know has been wrongfully convicted of a crime, you need expert legal help. Get in touch with an experienced criminal appeals lawyer at Barney & Hourihane today to find out more about your options. See Related Blog Posts State’s Attorney Drops Murder Charges on Appeal
In what may be a case of false imprisonment, two men are free after 23 years in prison, after Chicago prosecutors dropped murder charges against them, The Chicago Tribune reports. The men are Armando Serrano and Jose Montanez. The Cook County State’s Attorney’s Office decided to drop the charges because prosecutors could no longer carry the burden of proof necessary to uphold the conviction. The decision came after an appeals court judge issued a ruling which found that “profoundly alarming acts of misconduct” had led to the arrest. Investigating Officer Pays Out in Wrongful Conviction Lawsuit Over two decades ago, prosecutors convicted the two of the 1993 murder of Rodrigo Vargas in Humboldt Park. The conviction rested on evidence provided by former Detective Reynaldo Guevara. Guevara was a West Side police officer whose work has attracted increasing criticism from the courts. Guevara allegedly arrested Serrano and Montanez on the basis of a tip he received from an informant, who later confessed that Guevara provided the story to the informant. The informant says that Guevara threatened and intimidated him to force him to give false testimony, according to ABC 7 Chicago. Authorities have previously released another person, Juan Johnson, that Guevara investigated for a 1989 murder. Johnson won a $21 million dollar wrongful conviction lawsuit against Guevara. Kimberly Foxx will take over the State’s Attorney’s Office in December, and plans to review the cases of at least two other men in prison for crimes that Guevara investigated. Illinois Appeals Courts Can Reverse Trial Court Convictions Under Illinois Law, all appeals of criminal verdicts go to the Illinois Appellate Court. The State can appeal when a court dismisses a charge, or effectively does so by suppressing evidence from an arrest, quashing a warrant, etc. If the state appeals, the defendant usually goes free from jail during the appeal. The time that passes during the appeal doesn’t count toward time served for the purposes of obtaining discharge if a court later convicts the defendant. If a defendant pleads guilty, they can appeal the sentence, or try to withdraw the plea. If the defendant appeals a guilty verdict, they do not go free during the appeal process. During the appeal, the defendant’s attorney can bring to the attention of the Appellate Court any errors in the trial that substantially affected the defendant’s rights. The Appellate Court has a wide variety of options if they find that important mistakes occurred at the trial court level. The Appellate Court can reverse the judgment of the trial court, reduce the conviction to a lesser offense, reduce the defendant’s sentence, or order a new trial. United States federal law allows individuals who have suffered from wrongful imprisonment to sue those responsible for money damages, including attorney’s fees. Serrano and Montanez Could Sue for Wrongful Conviction Because the trial court convicted Serrano and Montanez of murder, they went to prison while their appeal was taking place. The fact that the only evidence against them at the trial court turned out to be a perjury would probably be a big enough error for the Appellate Court to reverse their convictions. The State’s Attorney probably decided to drop the charges rather than waste any more time in court awaiting a reversal. In cases like that of Serrano and Montanez, a lawsuit against the Chicago Police Department for wrongful imprisonment could succeed, since the actions of the detective deprived them of significant rights. Get Legal Help If you or someone you know has been wrongfully convicted, you need expert legal help. Contact an experienced criminal appeals attorney at Barney & Hourihane today to get the justice you deserve. See Related Blog Posts Chicago Police Officer Kills Teen and Grandmother
The family of a dead Chicago teen are suing the Chicago Police Department for wrongful death and the commission of a hate crime, according to Reuters. The victim, Quintonio LeGrier, died on December 26, 2015, after Chicago Police Officer Robert Rialmo shot him. Officer Rialmo also accidentally killed 55-year-old Bettie Jones during the confrontation. LeGrier was 19 years old. Officer Rialmo Text Conversations Included Racial Language The family argues that Officer Rialmo had a racial motive in killing LeGrier. Quintonio LeGrier and Bettie Jones were both African American. The lawsuit alleges that before the shooting, Officer Rialmo exchanged texts with other officers that included racist language. The family is seeking damages under Illinois’ hate crime act, The Chicago Tribune reports. Rialmo’s lawyer argues that other officers used racist terms in the text messages, but that Rialmo did not. Rialmo also argues that LeGrier attacked him with a baseball bat, and that the use of lethal force was necessary under the circumstances. The lawyer characterized the racial terms in the text messages as “hip-hop language.” In addition, Rialmo is counter-suing the city for failing to properly train him on how to de-escalate violent confrontations with mentally ill persons. According to Rialmo, the shooting occurred after he responded to a call about domestic violence. Jones answered the door and pointed Rialmo toward an apartment. Then, LeGrier appeared in the doorway wielding a baseball bat. Rialmo fired his gun at LeGrier three or four times, killing LeGrier. He then discovered that Jones had received fatal wounds as well. Illinois Law Punishes Hate-motivated Crime Although numerous wrongful death lawsuits are ongoing in relation to police shootings across the country, the inclusion of a hate crime claim is unusual. The Illinois Criminal Code defines a hate crime as an assault, battery or criminal trespass, property damage, or harassment committed because of a person’s race, color, religion, religion, ancestry, gender, sexual orientation, or physical or mental disability. These are criminal laws. But to sue someone, there must be a civil law basis. The Illinois Code also provides that anyone suffering from a hate crime may bring a lawsuit against the person responsible if there has been physical damage to someone’s health or property. It provides that the victim can receive actual damages (money to compensate them for their injuries) as well as punitive damages (additional awards designed to discourage other potential offenders in the future). LeGrier Shooting May Be a Hate Crime In a lawsuit like the one against Officer Rialmo and the Chicago Police Department, it’s possible that the victim’s family could convince the court that the officer committed a hate crime. Because Officer Rialmo aimed a gun at LeGrier, the victims may argue that the officer committed an assault (threatening action) and battery (contact that causes an injury) against LeGrier. The more difficult questions is whether the officer had a racial motive in shooting LeGrier. This may depend on whether the jury believes that Rialmo had racist views based on evidence like his text message conversations with other officers. The court would also need to decide whether any racist views Rialmo held led to his decision to shoot LeGrier. Rialmo will likely argue that his real motive for shooting LeGrier was not the color of LeGrier’s skin, but the perceived threat of LeGrier hitting Rialmo with a baseball bat. If the court concludes that racism motivated LeGrier’s death, then the surviving family may receive both money to compensate them for the value of LeGrier’s life plus additional damages to discourage other possible offenders. Contact a Chicago Civil Rights Lawyer If you have been the victim of police misconduct, you will need expert help. Get in contact with an experienced civil rights lawyer at Barney Hourihane today to get the compensation you deserve. See Related Blog Posts Police Shooting Cases Change Use of Force
Recent headlines could change the way police use force during arrests, according to the Chicago Tribune. Criticism of perceived racism and police brutality in the high-profile shootings in St. Paul, Minnesota and Baton Rouge, Louisiana has added tension to already strained police-community relations in Chicago. The video of the fatal shooting of Laquan Davis late last year led to protests and lingering anger against police. Some police officers believe the critical attitude toward police has lead to less “proactive” policing, such as traffic stops. Tension May Lead to Police Brutality However, today’s shooting of five police officers at a protest in Dallas, Texas underlines the danger facing on-duty police. In the past few days, several other attacks have occurred against police in Georgia, Tennessee, and Missouri, possibly in response to the accusations of police brutality in Louisiana and Minnesota, the Huffington Post reports. It’s possible for this perceived threat to lead to more use of force in arrests if police overestimate the danger of the situation. This could lead, ironically, to more incidents of police brutality. The Law on Deadly Force in Illinois Even if the social and political environment has changed, the law still lays down strict rules on the use of deadly force by police officers. In Tennessee v. Gardner, the Supreme Court held that police may only use deadly force when the suspect poses a threat of serious physical harm to the officer or others. The Illinois Criminal Code repeats this rule on the use of force and elaborates on the type of situations that might pose a threat of serious physical harm. One specific situation is where the person the officer wishes to arrest has attempted or committed a violent felony that involved serious physical harm to someone, and where that person is attempting to escape. The statute specifically states that the use of a chokehold during an arrest should be considered deadly force. A chokehold is any contact with the neck or throat that is meant to reduce the intake of air. No Unreasonable Use of Deadly Force But when is a police officer justified in concluding that the suspect poses a threat of serious physical harm to the officer? In general, a court will evaluate whether the police officer’s decision was reasonable in the context of the facts as they appeared to him or her at the time of the use of force. For example, if a suspect reaches into their pocket, the police officer may only conclude that this justifies the use of lethal force if the circumstances at the time justify it, according to what a reasonable person would think. Since there is no hard and fast rule about what a reasonable person might perceive as a threat of physical injury, there’s no clear line between justified and unjustified use of force during an arrest. Get Legal Help Have you or someone you know been the victims of police brutality? If so, you’ll need expert legal guidance to help you get justice. Contact a police brutality lawyer at Barney & Hourihane in Chicago today to get the help you deserve. See Related Blog Posts Chicago Man Arrested on Basis of Eyewitness Identification
A Chicago man was arrested today for a shooting in Evanston, according to the Chicago Tribune.The shooting took place in the parking lot of an IHOP this past Sunday morning. The suspect, Cornelius Jones, is accused of shooting a Beach Park man multiple times. Jones was identified from a lineup by the shooting victim. Police identified Jones as a suspect based on distinctive tattoos on his forehead. When the shooting occurred, police had an active narcotics investigation involving Jones. Police executed a search warrant at his apartment on Wednesday night. Jones was taken into custody. During the search, they discovered a .40 caliber Smith & Wesson semi-automatic handgun with ammunition. They also discovered a small amount of marijuana. Jones is charged with aggravated battery with a firearm, aggravated discharge of a firearm, unlawful use of a weapon by a felon, and unlawful possession of cannabis. Bail was set at $250,000, according to the Chicago Sun-Times. When Lineup Evidence is Admissible at Trial Jones was identified using a lineup. Suspect lineups are subject to strict rules under Illinois law. The Illinois Code of Criminal Procedure sets out rules for several different types of lineups:
The person administering the lineup is not supposed to know who the suspect is and who the filler are. Otherwise, they might influence the process to bias the witness. If there are multiple eyewitnesses, they are not allowed to confer with one another. When identifying a member of the lineup, no two eyewitnesses should be present at the same time. Otherwise, they might influence one another’s judgment. The fillers must not be substantially different in appearance from the suspect. Otherwise, the witness might pick the suspect simply because he or she is the only person in the lineup that resembles the perpetrator. What to do when Lineup Evidence is Unfair Violating any of these rules could prevent the use of the lineup procedure as evidence. If some violation occurred, a defendant’s attorney may file a motion to suppress the identification. If the judge decides that the way the lineup was conducted was too suggestive and that it may have produced an unreliable identification, the results of the identification can be kept away from the jury. If the results of the identification are allowed into evidence, the attorney can attempt to convince the jury that they should disregard the results, since they were produced by a biased process. Contact a Chicago Civil Rights Lawyer If you or someone you know has been arrested, you need immediate legal help. Contact an experienced criminal defense attorney at Barney & Hourihane in Chicago today, and defend your rights. See Related Blog Posts |
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