news outlets as a serial fabricator and fraud.

had deleted critical financial documents as she was about to be exposed by various

the heart of defendant's defense that Spizzirri had a motive to claim that Melongo

These false statements are relevant not only to Spizzirri's credibility but go to

directors.

certain prominent politicians like Gerry Chico and his wife sat SALF's board of

interviews, and even sworn grant applications; and (3) she falsely claimed that

as a college graduate and Renal Transplant nurse in written materials, news

her non-for-profit Save A life Foundation; (2) she falsely represented her credentials

Spizzirri on whether: (1) she repeatedly lied and misrepresented the motivation of

1. To permit cross examination of the State's key witness Carol

BONJEANand moves this court in limine as to the following:

NOW COMES,ANNABELMELONGO,by and through her attorney, JENNIFER

OMNIBUS MOTION IN LIMINE

ANNABEL MELONGO

The HonorableSteven J. GoebelJudge Presiding.

-vs-

Plaintiff,

PEOPLE OF THE STATE OF ILLINOIS,

, I(08 CR 10502

))))))))))Defendant.

IN THE CIRCUIT COURT OF COOK COUNTYCRIMINAL DIVISION

was attempting to bring SALF national and was applying for federal money. Indeed,

investigative series by Chuck Goudie of ABC7 News. Also, around that time, Spizzirri

fabrications were uncovered by various news outlets, including a 4-part

Defendant (and another SALF) employee of computer tampering, Spizzirri's

Critically, in fall of 2006, exactly around the time that Spizzirri accused

registered nurse, and had never worked in a renal transplant unit.

Furthermore, records show that Spizzirri did not even graduate college, was not a

In other words, Spizzirri's entire foundation was premised on lie.

saving measures.

road and not as a result of first responders unwillingness or inability to conduct life

Further, these records show that Christina died in a hospital NOT on the side of the

result of a single-car accident in which she was the sale driver and intoxicated.

Christina's medical records and death certificate prove that Christina died as a

Specifically police reports, the findings from a coroner's inquest, and

and tax payers were complete fabrications.

unit. These misrepresentations which were designed to raise money from donors

Science and that she was a registered nurse who had worked in a renal transplant

sworn federal grant application that her highest level of education was a Bachelor of

Spizzirri repeatedly represented in SALF publications, articles, and even on a

The Save a Life Foundation ("SALF") '" was founded in 1993 by Carol Spizzirri, RN,after her 18 year old daughter, Christina Jean Spizzirri, bled to death following a hitand run incident on Labor Day, 1992. First responders were not trained in lifesupporting first aid skills, and consequently stood by helplessly waiting forEmergency Medical Service (EMS) arrive some 30 minutes later.

Specifically, SALF's Annual Reports and website states the following:

after the Chuck Goudie series ran, the Federal Homeland Security told Spizzirri that

she would have to respond to these claims before receiving any federal money.

This evidence is critical not only because it goes directly to Spizzirri's

credibility and bias but more importantly, supports Defendant's defense that

Spizzirri falsified the charges of computer tampering and actually deleted and

altered SALF's financial records HERSELF in an effort to destroy evidence of

malfeasance.

To this day, the Attorney General continues to investigate Spizzirri and

SALF's practices and for filing misleading annual reports. Indeed, Illinois State

Senator Tim Bivens has led the charge to see that Spizzirri and SALF exposed and

that tax payers money is returned.

2. To permit cross-examination of Spizzirri on whether she was forced

to undergo a psychological examination in a family court proceeding that resulted in

the findings that she is a paranoid schizophrenic, a pathological liar, and chronic

child abuser. And to cross-examine Spizzirri on whether she wrote a letter to her

ex-husband admitting to be a liar and threatening to kill herself and their children.

3. To permit cross-examination of Spizzirri on whether she failed to

return funds to the Village of Carpentsville that did not rightfully belong to her.

Former Fire Chief John A Schuldt is prepared to testify that despite numerous efforts

to have unused funds returned to Carpentsville, Spizzirri refused to return the fund

or provide any explanation for failure to return the funds.

JENNIFER ,BONJEAN

Respectfully Submitted,

7. To preclude the State from eliciting testimony from Detective Martin

that Ms. Melongo had been accused of sending "x-rated" emails to a Professor at the

University of Missouri in Kansas City. Such testimony is rank hearsay, was never

charged or proven and would be designed solely to prejudice Ms. Melongo.

4. To cross-examine Spizzirri on whether she wrote to her "close

personal friend" former Cook Count State's Attonrey that Schiller Park Police had

concluded that Melongo had stolen a SALF American Express credit card and made

unauthorized purchases on that card - a complete and utter false statement.

5. To cross examine Spizzirri about her prior shop lifting convictions and

any other convictions that the State has yet to provide to the defense.

6. To preclude the State from eliciting hearsay testimony from Detective

Martin.