Duty to Make Meetings Convenient and Open to the Public

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Dear Ms. Schultz, Mr. Lee, Ms. Leftwich, and Ms. Henyard:

This binding opinion is issued by the Attorney General pursuant to section 3.5(e) of the Open Meetings Act (OMA) (5 ILCS 120/3.5(e) (West 2022)). For the reasons discussed below, this oCce concludes that the Village of Dolton (Village) Board of Trustees (Board) violated OMA by failing to make its June 3, 2024, and July 1, 2024, meetings convenient and open to the public.!

BACKGROUND

This oCce received three similar Requests for Review alleging that the Board failed to make its June 3, 2024, meeting convenient and open to the public. In a Request for Review (2024 PAC 81711) submitted to the Public Access Bureau on June 5, 2024, Mr. Dannie Lee alleged, in relevant part:

We have many senior citizens and a number of disabled taxpayers * * * We're VERY concerned with Mayor Henyards administration bringing in hired, out of town supporters and placing them strategically in a secured area to harass her opponents. Secondly Police Chief Lacey stalked the room and REPEATEDLY Threatens to Clear the room when he or his bosses perceive support such as applauding anything said that the administration doesn't approve of. * * * Also, despite several venues available in Dolton [t]he administration barricaded streets, set up entry blockages, made us stand in line for an hour to gain entry into the village hall they have limited to around 40 seats. There was a military like contingent of law enforcement both in and out of the building creating an intimidating atmosphere * * * . Some people had to wait outside because they [couldn't] get into the hall[,] which was totally unnecessary. They barricaded the parking lot forcing the * * * seniors and disabled to walk or hobble up to 2 blocks."!

Also on June 5, 2024, Ms. Peggy Kelly Schultz submitted a Request for Review (2024 PAC 81713) to the Public Access Bureau alleging:

I was refused access to the Village of Dolton Board of Trustees meeting due to inadequate space in the meeting room. No alternative accommodations were o?ered such as an additional room, live stream of meeting or moving the meeting to another location. At least 20 or 30 other members of the public were denied access into the building.

In addition, the public parking lot and public street parking were blocked with large plastic drums, traCc barricades and police People with disabilities parking spots were blocked also. There were many senior citizens and others in line with walkers, canes, etc. It was 86 degrees and they were forced to wait in the heat and refused entry into the building.!!

Finally, on June 14, 2024, Ms. Rosie Leftwich submitted a Request for Review (2024 PAC 81822) alleging that "Mayor Ti?any A Henyard provided seating for only 40 residents. Other residents including seniors and handicapped were turned away because she did not provide adequate space for all residents."* Ms. Leftwich also alleged that surrounding streets and the parking lot were blocked o?, inconveniencing residents.”

On June 10, 2024, the Public Access Bureau sent copies of Mr. Lee's and Ms. Schultz's Requests for Review to Ms. Henyard in her capacity as the head of the Board and to Village Administrator Keith Freeman. The Public Access Bureau also sent the Board a letter in each matter asking it to:

[P]lease provide this oCce with a copy of the agenda, open session minutes (in draft form if necessary), any recording of the open session of the meeting that may have been made by the Village, and any safety or accessibility plan the Village/its police created for the meeting. Please also provide a detailed written answer to the allegation that the Board did not make the meeting space convenient and open to the public, describing the size of the crowd that the Board anticipated would attend the meeting as well as any e?orts the Board made to enhance or ensure the convenience and openness of the meeting (such as, for example, additional seating, overPow capacity with working audio, consideration of a larger meeting room, making clear and short pathways to the meeting for elders and people with disabilities, etc.).!© In the inquiry letters related to Ms. Schultz's and Ms. Leftwich's Gles, this oCce also asked the Board to address the allegation that it impeded access to the meeting by having surrounding streets and parking spaces blocked o?.’ In the inquiry letter related to Mr. Lee's Gle, this oCce further asked the Board to "please address the allegation that the Board fostered a hostile environment at the meeting[.]"® On July 3, 2024, Mr. Lee and Ms. Leftwich each separately submitted a new Request for Review (2024 PAC 82032 and 82045 respectively) alleging that the Board again violated OMA by failing to make its July 1, 2024, meeting convenient and open to the public.’

They alleged that members of the public were again improperly turned away from the meeting because of the limited seating capacity of the room, with no apparent adjustments made by the Board to ensure that interested members of the public could attend the meeting despite the inadequacy of the meeting arrangements for the prior meeting.'° On July 5, 2024, the Public Access Bureau sent a copy of each new Request for Review to Ms. Henyard and Mr. Freeman and also sent them a new consolidated inquiry letter asking them to respond in writing to the slemanen that the Board did not make the July 1, 2024, meeting convenient and open to the public.

On July 8, 2024, the Board sent this oCce a written answer from the Acting Chief of Police of the Dolton Police Department, Lewis Lacey,'? and a copy of the police report and alleged piece of hate mail referenced therein.'? The Board also sent this oCce a copy of a letter from the Fire Chief of the Dolton Fire Department, Steven A. McCain, to Mr. Freeman about the occupancy of the meeting room.'* Because that letter was not addressed to this oCce, this oCce e-mailed Mr. Freeman and asked if the Board intended for it to be part of its answer that is required to be provided to Mr. Lee and Ms. Schultz,'° noting that this oCce has a duty to keep other records obtained from a public body pursuant to a Request for Review conGdential.'® Also on July 8, 2024, this oCce forwarded a copy of Mr. Lacey's answer to Mr. Lee and Ms. Schultz and notiGed them of their right to reply.'’ On July 9, 2024, Mr. Lee submitted a reply.!® On July 10, 2024, Ms. Schultz submitted a reply,'? in which she provided a link to a third-party video recording of the June 3, 2024, meeting.””? On July 11, 2024, this oCce e-mailed Ms. Henyard and Mr. Freeman to clarify if the Village's response in the other two Gles was also intended for Ms. Leftwich's Request for Review.”! On that same date, the Board re-sent the same materials and stated: "The Gre department letter serves as a document to address the occupancy and police department letter serves as a document to address barriers and street Incident Report, Dolton Police Department, Ofc. T Malone, Dolton, Illinois, Case No. D24- 16696, July 7, 2024, 6:32 p.m.

Letter from Steven A. McCain, Fire Chief, Dolton Fire Department, to Administrator Freeman On July 17, 2024, the Board forwarded to Mr. Lee, Ms. Schultz, and Ms. Leftwich the complete records it furnished to this oCce, including a copy of the police report referenced in Mr. Lacey's letter, a copy of the piece of alleged hate mail, and the Fire Chief's letter.2° On July 18, 2024, the Board conGrmed that those materials were also meant to serve as its response to the allegations concerning its July 1, 2024, meeting.”© On July 19, 2024, this oCce notiGed Mr. Lee and Ms. Leftwich of their respective opportunities to submit a reply concerning the July 1, 2024, meeting in response to the Board answer previously forwarded to them.?’ On July 19, 2024, Mr. Lee submitted a reply,?® and Ms. Leftwich submitted a reply the following day.”? On July 23, 2024, having since received the remainder of the materials comprising the Board's answer, Ms. Schultz submitted another reply.*° “E-mail from [email protected] to [Joshua Jones, Deputy Bureau Chief, Public Access Bureau, OCce of the Illinois Attorney General] (July 11, 2024).

23E-mail from Joshua Jones, Deputy Bureau Chief, Public Access Bureau, OCce of the Illinois Attorney General, to [Rosie] Leftwich (July 11, 2024).

4E-mail from Rosie Leftwich to [Joshua] Jones [Deputy Bureau Chief, Public Access Bureau, OCce of the Illinois Attorney General] (July 13, 2024).

5E-mail from [email protected] to [Joshua Jones, Deputy Bureau Chief, Public Access Bureau, OCce of the Illinois Attorney General, Dannie Lee, Peggy Schultz, and Rosie Leftwich] (July 17, 2024).

6E-mail from [email protected] to [Joshua Jones, Deputy Bureau Chief, Public Access Bureau, OCce of the Illinois Attorney General] (July 18, 2024).

27E-mail from Joshua Jones, Deputy Bureau Chief, Public Access Bureau, OCce of the Illinois Attorney General, to [Dannie] Lee and [Rosie] Leftwich (July 19, 2024).

8E-mail from Dannie Lee to [Joshua] Jones [Deputy Bureau Chief, Public Access Bureau, OCce of the Illinois Attorney General] (July 19, 2024).

°E-mail from Rosie Leftwich to [Joshua] Jones [Deputy Bureau Chief, Public Access Bureau, OCce of the Illinois Attorney General] (July 20, 2024).

30E-mail from Peggy Kelly Schultz to Joshua [Jones, Deputy Bureau Chief, Public Access Bureau, OCce of the Illinois Attorney General] (July 23, 2024).

OCce of the Illinois Attorney General On August 2, 2024, the Public Access Bureau extended the time in which to issue a binding opinion by 21 business days, to September 3, 2024, pursuant to section 3.5(e) of OMA.?!

ANALYSIS

Section 1 of OMA (5 ILCS 120/1 (West 2022)) declares:

It is the public policy of this State that public bodies exist to aid in the conduct of the people's business and that the people have a right to be informed as to the conduct of their business. In order that the people shall be informed, the General Assembly Gnds and declares that it is the intent of this Act to ensure that the actions of public bodies be taken openly and that their deliberations be conducted openly.

To e?ectuate this public policy, section 2.01 of OMA (5 ILCS 120/2.01 (West 2022)) provides that "[a]ll meetings required by this Act to be public shall be held at speciGed times and places which are convenient and open to the public." "By its plain terms, section 2.01 requires a venue that is not only 'open,' but 'convenient,' to the public." Gerwin v. Livingston County Board, 345 Ill. App. 3d 352, 359 (2003). Thus, "an open meeting in an inconvenient place violates the Act." Gerwin, 345 Ill. App. 3d at 359.

In Gerwin, the plainti?s alleged that a county board violated section 2.01 of OMA by holding a meeting in an inconvenient place. Gerwin, 345 Ill. App. 3d at 353. The board was on notice that there was heightened public interest in attending its meetings because of its consideration of a controversial landGll expansion plan, but the meeting was not moved to a larger location or reconGgured to provide additional capacity. Gerwin, 345 Ill. App. 3d at 355. Dozens of members of the public were relegated to the area outside the meeting room, which the plainti?s alleged was "close, hot, airless, and uncomfortable.'" Gerwin, 345 Ill. App. 3d at 356. The plainti?s also alleged that despite several available alternatives, the board "made no arrangements to accommodate them." Gerwin, 345 Ill. App. 3d at 356.

Addressing the meaning of "convenient," the court stated that "[a] meeting can be open in the sense that no one is prohibited from attending it, but it can be held in such an ill- suited, unaccommodating, unadvantageous place that members of the public, as a practical matter, would be deterred from attending it." Gerwin, 345 Ill. App. 3d at 361. Still, the court found that "[i]t would be unreasonable to suppose the legislature intended * * * that public bodies hold their meetings 'at such locations as are suCcient to accommodate a// interested members of the public, such that they may see and hear all proceedings in reasonable comfort and safety." (Emphasis in original.) Gerwin, 345 Ill. App. 3d at 361. Accordingly, what section 2.01 requires instead is "reasonable accessibility.’ [Citation.].". Gerwin, 345 Ill. App. 3d at 362 ("Renting a football stadium for public meetings might be inconvenient, or unadvantageous, to the public as a whole because of the cost. By the same token, holding public meetings in a small room might be inconvenient to the public because persons wanting to attend would have diCculty gaining admittance."). Because the reasonableness of the meeting space was a question of fact that needed to be explored, the court held that the trial court had improperly dismissed the plainti?s' claims. Gerwin, 345 Ill. App. 3d at 362.

Like the public body in Gerwin, the Board had ample advance notice that its regular meeting space would be insuCcient to reasonably accommodate the public. In the days before the Board's June 3, 2024, meeting, it was publicly reported that the Board might take action to override Ms. Henyard's May 6, 2024, veto of the Board's vote to hire former Chicago Mayor Lori Lightfoot to investigate the Village administration for alleged misconduct.” Previously, the Board had found it necessary to adjourn shortly after its April 1, 2024, meeting commenced because there was not enough space in Village Hall to accommodate the members of the public who arrived to attend the meeting.*? Again at the May 6, 2024, Board meeting at Village Hall, the news media reported that "[m]any who wanted to speak were forced to wait outside, because the room was completely full."*4 The meeting agenda for the ensuing June 3, 2024, meeting at Village Hall, posted June 1, 2024, notiGed the public that the Board intended to consider, among other items of signiGcant public interest: "Override of Mayoral Veto issued on May 6, 2024[.]"° In the Board's written answer, Acting Police Chief Lacey stated:

Since taking oCce, critics of Mayor Henyard have made it extremely diCcult to maintain an orderly Pow at Village of Dolton Board meetings and informative events held at Village Hall. These her term at events and at the end of board meetings held on June 3, 2024 and July 1, 2024. As a result, individuals have been removed, cited, arrested and meetings forced to end prematurely by law enforcement.

The disorderly conduct displayed at board meetings has been compounded by countless threats and racial and sexual derogortory [sic] communication Mayor Henyard has received through mail, phone calls and social media since taking oCce. In fact, Mayor Henyard received hate mail at her mother's residence on 7/7/24 (see attached police report #D24-16696 and mail). These actions have placed Mayor Henyard in reasonable fear for her safety. To address this substantiated fear, protocols were put in place for board meetings to prevent potential perpetrators of wrongdoing and ill-will towards the Mayor from having easy access to her.

Despite these safety precautions, members of law enforcement at the July 1, 2024 board meeting were diligent in providing a path for the elderly and disabled to enter the board meeting Grst and by ensuing [sic] their seating followed by members of the media and the general public. While the Dolton Police Department supports the 1S* Amendment and the diversity of thought, those expressions must be communicated in a civil manner and must not interfere or disrupt public meetings or breach the peace. 3°!

The enclosed police report is from July 7, 2024—after both the June 3, 2024, and July 1, 2024, Board meetings—and it documents Ms. Henyard approaching police about alleged hate mail she received. The report states: "[T]he letter was received on Friday, July 5, 2024 and in the letter that was written in blue marker stated ' See you in prison your mother raised a Loser!! Your mother is a Loser! ['] * * * [T]he envelope indicated that it was processed in Providence, RI on June 22, 2024."37 Additionally, the Fire Chief's letter stated the following concerning the capacity of the meeting at Village Hall where the meetings in question were held:

[T]he occupancy number of "43" persons pertains to the assigned seating area designated inside the Village Hall meeting area located at 14122 S. Martin Luther King, Jr. Drive, Dolton, Illinois. The assigned seating area was created after the Dolton Police Department administration described as "credible threats" that were made toward representatives of the Village of Dolton.

The occupancy number of 43 of the assigned seating area is based on the square footage calculations of the area referencing NFPA 101, Life Safety Code Table 7.3.1.2 The occupancy number only rePects the designated assigned seating area, excluding the remaining space of assembly located within the main Poor inside the Village Hall meeting area. (Emphasis added.)°*!

This answer on behalf of the Board failed to furnish copies of the records this oCce requested and failed to address this oCce's speciGc and unambiguous questions concerning the size of the crowd that the Board anticipated would attend the meeting, the alleged improper blocking of streets and parking spaces, the alleged fostering of a hostile meeting environment, and any e?orts the Board made to ensure the convenience and openness of the meeting (such as additional seating, overPow capacity with working audio, consideration of a larger meeting room, etc.). The answer did address the question about whether the Board ensured short and clear pathways for seniors and people with disabilities to enter the meeting, but only by claiming that it did so without providing evidence or explanatory details concerning the measures it took to accommodate those members of the public.

In reply, Mr. Lee argued as follows:

[T]he Gre chiefs letter CLEARLY supports our claim that the current restrictions are completely inadequate and have been arbitrarily applied for the purpose of limiting dissent and/or discussion of village issues. A seating capacity of 43 people conGrms the fact that a larger space is needed or a return to standing room crowds as has been the case for decades needed. (Emphasis in original.)*!

Ms. Leftwich replied by noting that the Board did not answer this oCce's questions concerning its June 3, 2024, meeting, and that it continued to use the same inadequate meeting room for its July 1, 2024, meeting.*? Ms. Leftwich additionally asserted: "The letter from Chief of Police claims that residents were disruptive during Village of Dolton Board meetings. I disagree with this accusation. When residents clap in response to resident | comment(s], he call[s] that disruptive and threatens to clear the room."*! Ms. Leftwich also argued that seating capacity of 43 people is insuCcient for the Village's population of about 20,000 residents.*”

Ms. Schultz likewise replied to the Board's answer by noting that the Board did not answer this oCce's questions and by asserting that meeting arrangements are inadequate to accommodate the public.*? She also similarly alleged that the silencing of dissent during the meeting, such as threats to clear the room in response to applause of criticism of the administration,“ "ESCALATES the tension in the room, deliberately creates chaos, instills fear, and intimidates the residents." (Emphasis in original.)** Ms. Schultz argued that the video recording of the meeting "[d]emonstrates how a small room Glled with members of the board, the administration, the police, and members of the public in conPict for several years, It is apparent from the available information that the Board did not make its June 3, 2024, and July 1, 2024, meetings convenient and open to the public. It was clearly foreseeable that large crowds would attend the Board's meetings due to the array of controversies and conPicts involving the Village administration and Board. Moreover, there were multiple reports of the inadequacy of the Village Hall meeting space at the preceding Board meetings in April and May. Yet, the Board again and again held meetings in the same space without taking measures to accommodate more than a maximum of 43 individuals who wished to attend. In addition, the Board created impediments to public attendance at the June 3, 2024, and July 1, 2024, meetings. News media reported on July 14, 2024: "It's become more diCcult for residents of south suburban Dolton to attend village board meetings. They now face roadblocks, barricades, long lines, capacity limits, metal detectors and a heavy police presence that some say is being deployed to discourage opposition to Mayor Ti?any Henyard."

The Board argued, in Chief Lacey's letter, that heightened security concerns justiGed such extensive restrictions. This assertion is unpersuasive. Although prior Board meetings had been contentious due to the division within the Board and public displeasure with the allegations of misconduct against Village oCcials, the letter mailed from Rhode Island was the only evidence that the Board provided in support of the manner in which it conducted the meetings in question. The letter was critical and insulting, but it did not implicitly or explicitly threaten violence. More importantly, the letter did not arrive until after the two meetings occurred. While it was not unreasonable for the Board to have a metal detector at the entrance to the meeting room as a standard security measure and to have a visible police presence in light of the emotionally-charged atmosphere at previous meetings, even assuming there were bona Gde threats to Ms. Henyard's safety, the Board did not illustrate that security concerns justiGed so heavily curtailing public attendance at the meeting. This oCce received no facts suggesting that it was reasonable or appropriate to block o? the parking lot and surrounding street parking spaces for the building, especially spots designated for people with disabilities. Moreover, it is uncontested that many interested members of the public were excluded from each meeting due to the tight restrictions on attendance, and the Board did not claim that those individuals acted in a The Board's failure to move the July 1, 2024, meeting to a larger meeting room, to o?er standing room or overPow capacity (i.e. another room in the building for the attendees unable to Gt into the main meeting room with a remote meeting set-up), or to otherwise attempt to make the meeting reasonably accessible to the public is exacerbated by the fact that the Board had clear notice from, among other things, (1) the three Requests for Review about the previous meeting, (2) public comments during that meeting, and (3) news media reporting that the meeting set-up was incommensurate with the ongoing public interest in attending and participating in Board meetings. Although the "reasonable accessibility" standard does not require the Board to ensure that every single person who wishes to attend a Board meeting is able to do so in full comfort, that standard did require the Board to implement measures to better accommodate the public. The Board's failure to do so violated section 2.01 of OMA.

FINDINGS AND CONCLUSIONS

After full examination and giving due consideration to the arguments presented, the Public Access Counselor's review, and the applicable law, the Attorney General Gnds that:

1) On June 5, 2024, Mr. Dannie Lee and Ms. Peggy Kelly Schultz each separately submitted a Request for Review to the Public Access Bureau alleging that the Board failed to make its June 3, 2024, meeting convenient and open to the public. On June 14, 2024, Ms. Rosie Leftwich submitted a Request for Review alleging the same violation. On July 3, 2024, Mr. Lee and Ms. Leftwich each separately submitted a new Request for Review alleging that the Board again violated OMA by failing to make its July 1, 2024, meeting convenient and open to the public. It is undisputed that the Requests for Review were timely Gled and otherwise comply with the requirements of section 3.5(a) of OMA.

2) Within seven business days after receipt of each Request for Review, the Public Access Bureau forwarded a copy to the Board. The Public Access Bureau also sent the Board a letter in each matter concerning the June 3, 2024, meeting requesting a copy of the agenda, open session minutes (in draft form if necessary), any recording of the open session of the meeting that may have been made, and any safety or accessibility plan the Village/its police department created for the meeting. In those inquiry letters as well as the consolidated inquiry letter concerning the July 1, 2024, meeting, this oCce asked the Board to provide a detailed written answer to the allegation that it failed to make the meetings convenient and open to the public.

3) On July 8, 2024, the Board sent this oCce a written answer from the Acting Chief of Police of the Dolton Police Department, and a copy of the police report and alleged piece of hate mail referenced therein. The Board also sent this oCce a copy of a letter from the Fire Chief of the Dolton Fire Department to the Village Administrator about the occupancy of the meeting room.

4) The Public Access Bureau forwarded a copy of the Acting Police Chief's letter to Mr. Lee, Ms. Schultz, and Ms. Leftwich and notiGed them of their opportunity to reply. Between July 9, 2024, and July 13, 2024, they each submitted a reply. The Board then sent them its complete response on July 17, 2024, including a copy of the police report, a copy of the alleged piece of hate mail, and the Fire Chief's letter. The following day, the Board conGrmed that these materials were intended to apply to the July 1, 2024, meeting as well. On July 19, 2024, the Public Access Bureau notiGed Mr. Lee and Ms. Leftwich of their right to reply about the July 1, 2024, meeting. On that same date, Mr. Lee submitted a reply, and the next day, Ms. Leftwich submitted a reply. On July 23, 2024, Ms. Schultz submitted a Gnal reply.

5) On August 2, 2024, this oCce extended the time in which to issue a binding opinion by 21 business days, to September 3, 2024, pursuant to section 3.5(e) of OMA. Therefore, the Attorney General may properly issue a binding opinion with respect to this matter.

6) Section 2.01 of OMA (5 ILCS 120/2.01 (West 2022)) provides that "[a]]1 meetings required by this Act to be public shall be held at speciGed times and places which are convenient and open to the public." Section 2.01 requires public bodies to take measures to ensure that they a?ord the public reasonable access to their meetings.

7) Despite having advance notice that the location and set-up of the Board's June 3, 2024, and July 1, 2024, meetings was insuCcient to accommodate many interested members of the public, the Board made no adjustments to a?ord reasonable access to the meetings, and many members of the public were prohibited from entering the meeting space. The Board added restrictions such as parking barricades without justiGcation, which further impeded public access to the meetings.

8) Accordingly, the Attorney General concludes that the Board violated section 2.01 of OMA by failing to make its June 3, 2024, and July 1, 2024, meetings convenient and open to the public.

In accordance with these Gndings of fact and conclusions of law, the Board is directed to take immediate and appropriate action to comply with this opinion by taking measures to make all future meetings convenient and open to the public, including holding meetings at a location with enough space to be reasonably accessible and conGguring the meeting set-up to accommodate the public. Although the Board is permitted to take reasonable and appropriate measures to ensure the safety of members of the public and public oCcials, it is directed to refrain from unnecessary security measures such as street closures, parking barricades, and an excessive police presence that physically impedes members of the public from attending meetings. As required by section 3.5(e) of OMA, the Board shall either take necessary action as soon as practical to comply with the directives of this opinion or shall initiate administrative review under section 7.5 of OMA. 5 ILCS 120/7.5 (West 2022).

This opinion shall be considered a Gnal decision of an administrative agency for the purpose of administrative review under the Administrative Review Law. 735 ILCS 5/3-101 et seq. (West 2022). An aggrieved party may obtain judicial review of the decision by Gling a complaint for administrative review in the Circuit Court of Cook County or Sangamon County within 35 days of the date of this decision, naming the Attorney General of Illinois and Mr. Dannie Lee, Ms. Peggy Kelly Schultz, and Ms. Rosie Leftwich as defendants. See 5 ILCS 120/7.5 (West 2022).

Very truly yours,

KWAME RAOUL ATTORNEY GENERAL

Brent Stratton / Chief Deputy Attorney General served a copy of the foregoing Binding Opinion (Public Access Opinion 24-010) upon:

Ms. Peggy Kelly Schultz 1259 Heather Road Homewood, Illinois 60430 peggy.schultz1 [email protected] Mr. Dannie Lee 15249 Dante Avenue Dolton, Illinois 60419 [email protected] Ms. Rosie Leftwich 15230 Irving Avenue Dolton, Illinois 60419 [email protected] The Honorable Ti?any A. Henyard Mayor Village of Dolton 14122 Martin Luther King Jr. Drive Dolton, Illinois 60419 [email protected] by causing a true copy thereof to be sent electronically to the addresses as listed above and by causing to be mailed a true copy thereof in correctly addressed, prepaid envelopes to be deposited in the United States mail at Chicago, Mlinois on Septem rhas1w1yd vis a ¢ — Steve Silverman Bureau Chief Steve Silverman Bureau Chief Public Access Bureau OCce of the Attorney General 115 South LaSalle Street Chicago, Illinois 60603 (312) 814-6756