23 questions

Rhoads v. CPD – Discovery Correspondence & Interrogatories

Rhoads v. City of Chicago (16‑cv‑07621)

United States District Court – Northern District of Illinois

Letter from City of Chicago Department of Law

Date: March 22, 2017

To: Timothy Rhoads
3753 N. Francisco Ave.
Chicago, IL 61206
seth@solarblu.net

Re: Rhoads v. CPD, et al., 16 CV 07621

Dear Mr. Rhoads,

This letter is regarding your discovery request to Defendant Gonzales (filed Document #79). Your request for discovery contains 57 interrogatories. Pursuant to Rule 33 of the Federal Rules of Civil Procedure, unless you seek leave of court, you are limited to only 25 interrogatories. Please identify the 25 interrogatories for which you are requesting a response.

As a reference to the document referred to above, enclosed is a copy of your discovery request to Defendant Gonzales (Document #79).

Sincerely,

Jessica D. Ziswana
Assistant Corporation Counsel
30 N. LaSalle Street, Suite 900
Chicago, Illinois 60602
jessica.ziswana@cityofchicago.org

Interrogatories Submitted by Plaintiff

Case: 1:16‑cv‑07621   |   Document #79
Date Filed: March 13, 2017

First Set of Discovery Questions

Plaintiff Timothy Rhoads, under duress, requests Defendant Gonzales answer the following interrogatories:

  1. Is it common for you to feel threatened when dealing with a member of the LGBTQ community?
  2. Is it common for you to ask a person on the phone, “If I beat the shit out of you while you’re in cuffs, what do you call it?”
  3. Is it common for you to harass and intimidate the complainant?
  4. Is “Jackhammer” one of your clients, or do you have previous experience servicing them? List all interactions in your career.
  5. Is it common for you to see someone get attacked and tell them, “You were flailing like a faggot. You deserved to get your ass beat”?
  6. Is it common for you to come to someone’s house, arrest them, hold them for 7 hours, and tell them you are the judge and jury?
  7. How many times have you visited Mr. Rhoads’ websites, LinkedIn profile, or other social media?
  8. Is it common for you to submit perjurious comments to your supervisor to get charges on a civilian taxpayer?
  9. When was the last time you took a lie detector test? What was the case number and result? Provide technical details.
  10. What was the last phone harassment complaint before Mr. Rhoads? Provide details and status.
  11. Do you have any disabilities or mental disorders?
  12. Do you have a problem listening to others or interacting with those who disagree with you?
  13. Would your coworkers describe you as a nice person?
  14. Do you let your badge get to your head?
  15. Have you ever been accused of excessive force, domestic violence, or bullying?
  16. Do you have cases pertaining to such violent events in your lifetime?
  17. Are you recovering from any addictions?
  18. Can you run around the block without passing out? Are you physically fit for duty?
  19. Is it common for you to lie to cover your actions or bully a complainant?
  20. Have you ever been stripped of your duties or put on administrative duty? Why?
  21. Is it typical for you to suspend a case because a victim didn’t present “in a reasonable manner”?
  22. Do you receive any kickbacks or illegal money from bars or outside sources?
  23. Would your supervisor Emiliano Leal say you are fair and level-headed in dealing with the community?
  24. Do you provoke prisoners in lock-up?
  25. Do you have children or a family?
  26. Are you a closet homosexual or a gay-bashing homosexual? Do you gay-bash LGBTQ members?
  27. Do you retaliate against LGBTQ individuals because of personal issues?
  28. Are you currently on online dating? If so, which platforms?
  29. Did you know you spelled your name wrong on LinkedIn?
  30. What is your IQ, height, and weight? Have you been overweight long?
  31. Have you ever been arrested? What high school did you attend?
  32. Do you wear a body cam? Do you turn it off or coerce officers to believe your version of events?
  33. Do you use your position for personal favors?
  34. How would your family be affected if you lost your job, star, and licenses?
  35. Do you know Joe Starcher or anyone in the web hosting industry?
  36. Do you read Mr. Rhoads’ federal filings? How have they affected your fairness toward him?
  37. Have you arrested anyone related to Mr. Rhoads’ April 23, 2016 complaint? If not, why not?
  38. What type of job will you have if you lose your badge and certifications?

/s/ Timothy Rhoads
3753 Francisco Ave.
Chicago, IL 60618
Email: seth@solarblu.net
Dated: March 10, 2017

report for battery

On april 23rd i filed a report for battery. I contacted was contacted by officer Durant who met
me at the belmont and western station. He told me he would reivew my IPRA issue and get back
to me. He told me to call in a few days about my orginal case and find out who was assigned. As
after 3 months it was still “unassigned”.
____
I called and encountered serveral hostile police officers over the phone who harrassed me and
said nasty remarks. and hang up.
___
I finally got an officer who told me that tomorrow the case would be assigned to james gonzales
to call him and he will help me with my issue.
____
i called at 430 and the officer was not in yet. I called three hours later. I was informed “Did you
know they had video” click.
____
i called back to speak to the detective assigned to the case and he said “your not getting any
justice you deserved to get your ass beat.” click
____
I called to speak to the officer as i was confused about the status of the case and what was going
on. I had never been informed of the evidence the police officer said he had seen, and if he had
seen it he would have saw me defend myself from four different attackers.
_______
He said ” im not helping you and if you were in my custody and i beat the shit out of you i call
that fair game what do you call it? ” I stated “excessive force” he said “did you threaten me thats
it im coming over to your house to arrest you for threatening me you better be there when i get
there.” I waited in fear. My roomate was here the whole time and i said nothing threatening to
this officer.
________
The officer showed up with his cronies I emptied my pockets and explained to the cops ” i only
called him to check on the status of my complaint” one officer said im not here to discuss the
1
merits of your report.”
________
My neigherbor and roomate both outside. The officer who threatened me put cuffs on me the
last possible click restaringing my blood flow. My hands turned color. Then held me slightly to
the right while the officers started talking to my roomate and doing things out of earshot. While
holding me with his left hand the officer cupped my ass with his right. Four fingers on my ass…..
Then shoved me in the car and smothered me with his body pressed up on my and breathing
heavily in my face. I yelled “i am being harrassed get this guy away from me!” the officers looked
around stunned. I told them. “This officer will be driving me nowhere, this is unlawful arrest” he
was there under false pretenses as he made the other officers believe i had said something
inaapropriate. He said your going nowhere i have you for threatening me” I yelled please
remove this officer from contact with me he is invading my space and touching me
innapropriately. Slammed the door in my face and left me in the 100+ degree car that was off…
____
They called another car and an officer stated. “Get out of the car” i said i can’t get out im
buckeled in, are you paying attention?” He gave me some attitude and another officer said get
out of the car. i stated once again “i cant!” a third officer came to unbuckle me and a fourth and
fifith or sixth by then came to put me in another car.
________
They took me to the station. Im sure a few of the cops where wondering what was going on.
_______
The cops tried to talk to me i said i want an attorney they said “you dont need an attorney” and
slammed the door. A few minutes later “do you want water” i said nothing” they siad you need
to speak. I said i am not required to respond to you as you have falsely imprisoned me under
false pretenses. the officer then turned on a smile and said di you want some water. i said yes.
he brought me water.
______
The the cop said did i need anything i told him my hand was changing color can he untighten the
cuffs a tiny bit. “my hand is turning white, you cant see this, cutting off my circulation”. he
removed the cuffs and left me in the room.
______
Then the officer who was harrassing me took me downstairs. He started small talk with me and i
2
ignored him as he touched me innapropriately going to lockup…
____
when we got to lockup there were two officers escorting a juveline. one officer waiting to
process me. Tall and friendly. he waited on the otherside of the gate in front of me. officer
gonzalez on the right… i was on the left and let the juvy through with his two officers. that is
when mr gonzalez in front of officers said. ” i am the justice in the town, i will determine who is
allowed to have justice who the judge listens to. I am the one who determines justice”.
___
Sorry i didnt elect you.
____
also you viloated my cival rights. conspired with the bar and the police.
___
never informed me of new evidence in the case that I Timothy Rhoads filed.
____
falsely reporting i threatened you.
____
but not arresting people you actually see on video beating me to a pulp.
____
Timothy Rhoads
3

jackhammer bar on 6406 N Clark street

On April 22nd I went to the jackhammer bar on 6406 N Clark street. I was invited by a friend who
worked there and I had a few drinks, listened to some music. Had a good time until, On the way
to the bathroom the general manager of the bar supposedly the name of David Vuziak Scruffy
face, white about 5’7 165 pounds, wet. Approached me and started being sassy and I was sassy
back. He threw an unexpected punch to my face. My face is still sore.
Immediately following
Some other guy took a swing at me and I took him by his hair by my left arm. and a girl hit me on
my right side and I took her by her hair in my right hand. Continually fending off thier attacks as
they were punching and kicking me. The bouncer and employee came after me to pin me down
in a wrestingling move and I took all them bitches to the ground. Defending myself.
_____
When the police showed up witnesses claimed I had instigated it. They didn’t know I was
defending myself; that all these crazy people just attacked me at once. The police officer talked
to the general manager who took the initial sucker punch, first. and then the owner second.
Here I am bleeding from the mouth. Still have pictures to prove it. Blood gushing and no one
wants to know what happened to me?
Are you kidding?
So I asked them who is going to take my complaint this man hit me and I pointed right at the
manager guy who hit me first. They laughed at me and told me to go home. I asked a few more
times if they were going to refuse me services, and started talking to the cars in case they finally
did have a dashcam.
_______
I then go on my bike and biked down clark to mcdonalds where I saw two officers in a car. I
asked them if they could arrest the man who hit me and they started talking and then denied me
services. I asked for a supervisor, he came out of nowhere and refused to assit some more.
_______
I continued biking to Lakeview wher I thought I could safely make a complaint and still hurt and
sore, and blood gushing out of my lip.
______
On april 23rd 2016 I timothy Rhoads went to the addison police station to file a complaint of
battery. The officer behind the desk Officer Woods failed to provide services, got argumentatitve
1
and called me a Bitch. Threatened to kick my ass out front and I responded by asking him to
leave his badge and his gun on the counter. I just had to fend off three other poeple and why
does everyone want to beat me up tonight serioasly? I’m just tyring to file a report.
He left a few things on the counter and came towards the entrance.
____
I hearby request for all video footage of police squard cars at the time of the incient,
Jackhammer and nearby business footage, the inner and outer video footage of the police
station on Addison.
____
And I would like that guy arrested as what was suppose to happen on April 23 2016.
Timothy Rhoads
2

Overview of Case 16-cv-7621: Rhoads v. City of Chicago

Overview of Case 16-cv-7621: Rhoads v. City of Chicago

Case details

Full case name
Timothy Rhoads v. City of Chicago, et al.
Docket number
1:16-cv-07621 (sometimes shortened as “16-cv-7621”).
Court
U.S. District Court for the Northern District of Illinois (Eastern Division).
Presiding judge
Judge Robert M. Dow, Jr.
Nature of suit
Federal civil rights (42 U.S.C. § 1983), including Fourth and Fourteenth Amendment claims; alleged Monell liability.
Filing date
October 2016.
Status
Resolved via settlement; no trial verdict.

Note: The “116” in some references likely denotes the filing year (2016).

Allegations

  • Failure to assist after assault: Plaintiff alleges CPD officers declined to file a report or provide aid after an assault at a bar.
  • Station encounter: At a district station, an officer allegedly threatened and insulted the plaintiff, refusing assistance.
  • Follow‑up abuse: In a subsequent status call, another officer allegedly used homophobic slurs, issued threats, and appeared at the plaintiff’s home.
  • Discrimination & retaliation: Claims include bias based on perceived sexual orientation, retaliation for seeking police services, and failure to investigate.
  • Monell claims: Alleged pattern/practice within CPD, including inadequate training/supervision.

Timeline of key events

Approximate sequence based on public summaries and filings
Date / Event Description
Early 2016 (Birthday) Assault at bar; responding officers allegedly do not assist or take a report.
~1 hour later At a CPD station, officer allegedly threatens/insults plaintiff.
~5:30 a.m. (same night) Report ultimately taken at plaintiff’s apartment.
~2 months later Status call with another officer; alleged slurs, threats, and intimidation follow.
Oct. 2016 Federal lawsuit filed (1:16-cv-07621).
2016–2017 Discovery; City disputes liability.
2017 Case resolves via settlement (no admission of liability).

Outcome & settlement

  • Resolution: Settled out of court; amount not publicly itemized.
  • Criminal charges: None reported against involved officers.
  • Discipline: No public discipline identified in connection with this case.

Context & resource allocation

The case fits within a period of heightened scrutiny of CPD practices, broader civil rights litigation, and discussion about investigative resource allocation. Comparisons have been drawn between routine victims’ cases and high‑profile investigations that consumed significant time and overtime budgets.

Disclaimer: This page is an informational summary formatted for the web. For authoritative records, consult the federal docket (PACER) and official court filings.

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