A senior Cook County Sheriff’s Office investigator has filed a lawsuit claiming she was illegally retaliated against after refusing to share certain information with superiors about a sweeping federal investigation into ghost payrolling, fraud, nepotism, and forgery at the agency.
Sgt. Nicole Pagani’s sixty-page lawsuit against Sheriff Tom Dart and his office includes multiple alleged violations of Illinois’ human rights and whistleblower protection acts, as well as federal sex discrimination and harassment claims.
In the lawsuit, Pagani claims she found proof of widespread official and criminal misconduct within the Sheriff’s Office while working on a joint FBI investigation, including evidence that the agency may have misappropriated millions of dollars in COVID relief funds and evidence implicating members of Dart’s inner circle in wrongdoing.
Her complaint alleges that members of Dart’s executive team manipulated job postings to secure positions at the agency for their close relatives, that one exchanged a racist image and comment with other executive team members on government-issued devices, and that several misused public resources by having agency staff pick up and train their personal dogs as well as the dog of one of the agency’s suppliers at the taxpayers’ expense.
Some county employees were also allegedly forced to work for Dart’s 2022 reelection campaign, her complaint says.
After Pagani detailed many of these allegations to her superiors, one of whom allegedly admitted to committing official misconduct in a meeting, she says she was told to suppress some of her findings and stop following certain leads. Her complaint alleges that she was pulled from her FBI assignment and transferred to a different unit in a different building after she refused to share information about the investigations with Dart.
A spokesperson for the Sheriff’s Office says the agency “cannot comment on pending litigation, but the Office strongly disputes the allegations in this lawsuit and intends to litigate the matter fully.”
According to her amended complaint, Pagani handled sensitive internal affairs cases for nearly a decade as a member of the agency’s “Criminal and Confidential Unit,” also known as Squad 4, before her “demotion” in January 2024. That unit, the complaint says, was specifically tasked with conducting high-profile and confidential investigations into the office’s more than 6,700 sworn and civilian employees, including, but not limited to, Dart’s closest lieutenants.
While still a member of Squad 4, Pagani’s complaint says she received a top-secret security clearance and was assigned to a joint FBI task force that was a part of the bureau’s public corruption and civil rights violations squad. The role came with benefits such as being granted FBI credentials and a badge, access to an undercover FBI vehicle and gas card, the opportunity to collect up to $17,000 in overtime pay, and the ability to work with the FBI after retiring from the sheriff’s office, among other perks.
In the summer of 2021, Pagani says she and other Squad 4 members were tipped off by a confidential informant that multiple Sheriff’s Office employees were committing ghost payroll fraud and had second jobs working for a security company.
Over the course of the next two and half years, Pagani helped uncover evidence that more than twenty employees were “clocking in and/or out employees other than themselves for their shifts.”
Squad 4 also found a range of potential criminal activities and misconduct by agency staff, including the falsification of three-months of schedules to receive hazard pay under the federal Cares Act and computer fraud by an employee that was used to obtain more than $9,000, according to the complaint.
In March 2022, news that the FBI had joined the office’s internal probe became public. Dart’s office refused to answer specific questions about the targets or scope of the investigation or whether any employee had been fired.
A spokesperson for Dart told the Tribune that the Sheriff’s Office “takes allegations of employee misconduct very seriously.”
That same month, Pagani claims Dart’s office de-deputized seventeen employees, including four salaried staffers. Her complaint alleges that Chief Legal Officer Helen Burke requested Pagani write a memo summarizing the evidence against those employees so that they could be fired.
According to the complaint, Burke was “very concerned that the documents that had already been submitted for reimbursement could expose the Cook County Sheriff’s Office to being responsible for paying back millions of dollars in COVID relief funds” and raised the issue repeatedly to the point where Chief of Staff Bradley Curry told her “to stop talking about the investigation.”
The investigation continued throughout 2022 and into 2023, and as the months passed Squad 4 began turning up evidence in email and text dumps obtained through grand jury subpoenas that Pagani claims increasingly implicated higher-ups in official misconduct.
According to the complaint, Pagani reported many of the allegations she was involved in investigating to her boss at the Office of Professional Review, Peter Lisuzzo. But she was limited in what she could tell him under the federal rules of criminal procedure, which set limits on who grand jury information can be disclosed to.
According to the complaint, Pagani briefed Lisuzzo that Jennifer Black, the first deputy chief of staff for administration, had manipulated job postings to secure positions for family members of high-ranking personnel, including two sons of Chief of Operations Tarry Williams and Black’s own niece.
These actions, according to the lawsuit, occurred despite a hiring freeze and during a period of alleged staffing shortages at the jail. Pagani claims she informed Lisuzzo that Williams’ sons and Black’s niece also received preferential treatment while employed at the agency, including receiving corrections officer certification without performing the required duties.
She also allegedly revealed to him that several executive staff members, along with the owner of a supply company, were having Sheriff’s Office personnel train their personal dogs, a potential misuse of public resources.
At a later meeting where Pagani provided evidence of this misconduct directly to Dart’s top leadership, Burke “became upset and admitted to having her dog trained by Cook County Sheriff’s Office employees[,] claiming Tarry Williams approved of employees having their personal dogs trained by CCSO employees,” according to the complaint.
Pagani also raised concerns with Lisuzzo about the executive director of electronic monitoring, alleging the official may have engaged in ghost payrolling while attending the Chicago Metro Police Academy. According to the complaint, this individual remained on the Sheriff’s Office payroll, used a county-issued vehicle, and falsely logged work hours remotely—all while possibly submitting fraudulent documentation to the state’s law enforcement training board.
Shortly after that meeting, Pagani claims Lisuzzo told her that the information about CCSO staff improperly using county resources to have their dogs trained “should never be brought up again.”
Lisuzzo also later related that Curry had told him that they were “to leave” the electronic monitoring official “alone” and “were not to continue investigating the information we were receiving,” according to the complaint.
Pagani also alleges to have told Lisuzzo that the Chief Deputy Sheriff distributed a racist image and comment via a county-issued device. Her complaint claims she heard that Lisuzzo had closed “numerous” cases brought before him “without doing any kind of an investigation.”
According to the complaint, Lisuzzo instructed Pagani to brief him on grand jury warrants—even if they implicated CCSO employees—so he could update Dart and Curry directly. He allegedly told her, “The Sheriff is our boss and if he asks questions and wants to know about a case we are going to tell him.”
In mid-October 2023, when Lisuzzo allegedly demanded copies of a signed grand jury warrant and affidavit, Pagani refused and reported the request to her FBI supervisor, who confirmed the documents were protected and would remain with the FBI.
Pagani contends that her refusal triggered immediate retaliation. Lisuzzo allegedly screamed at her for being “secretive” and demanded the documents be placed on his desk. She claims he warned her not to report misconduct by CCSO employees to the FBI or she would “be in trouble.”
Two months later, in December 2023, she went to the Cook County State’s Attorney’s Office (CCSAO) to provide evidence of crimes she “reasonably believed” had been committed by Sheriff’s Office employees, but according to her complaint, “the representative from Kim Foxx’s [CCSAO] took no notes and appeared to be very disinterested in prosecuting these crimes.”
Weeks later in January 2024, Lisuzzo removed her from her position as an FBI Task Force Officer and “demoted” her to Squad 3, the complaint alleges. Pagani says a male employee soon took over her office and assignments, and she was barred from further contact with the FBI, thereby losing her ability to have extensive overtime reimbursed and future career opportunities with the FBI, among other benefits. She claims Lisuzzo later filed a “false, pretextual, and phony” disciplinary complaint against her to block her from transferring positions.
Pagani’s complaint points to past comments Dart made as proof that his office will retaliate against employees who refuse to comply with his directives.
“If [my employees are] not doing what I need them to do, they either get fired, or I can make their life tricky by transferring them to a different location to make their drives longer, things like that,” Dart said in a 2014 interview on the Live from the Heartland radio show. “There’s many, many things you can do to send a message.”
Pagani is seeking more than $2 million in damages and reinstatement in Squad 4 and as an FBI task force officer.
In an April court filing, the Sheriff’s office said the decisions to remove Pagani from the joint FBI task force, to reassign her to Squad 3, and to open an OPR investigation against her are not retaliatory, that they are all “discretionary policy decisions,” and are therefore lawful.
“The allegations in the complaint speak for themselves,” says Brian Graber, one of Pagani’s attorneys, in a statement to the Weekly. “We look forward to aggressively proving Ms. Pagani’s case in court.”
In response to the Weekly’s questions, a spokesperson for the FBI provided a statement that read: “Department of Justice policy prohibits the FBI from confirming or denying the existence of investigations, Additionally, it is FBI policy not to comment on personnel matters or ongoing litigation.”
The U.S. Attorney General’s Office did not respond to the Weekly’s request for comment.
Separate lawsuit alleged Dart made employees campaign for him
In a separate lawsuit, two former high-ranking county jail employees claim they were put on administrative leave in March 2022 but “were not told the nature of the investigation.”
One was later interviewed by the FBI “about high-level CCSO operations, as well as policies and procedures related to COVID-19 spending” but “did not get the impression that she was the target of the investigation.”
Drake Carpenter and Aracelis Gotay, who were the assistant executive director and director for incident command respectively, claim the Sheriff’s Office abruptly fired them two years later only after they raised allegations in their third amended complaint that “Sheriff Dart forced employees at the DOC [Department of Corrections], including plaintiffs, to volunteer without pay for his reelection campaign to give him an unfair advantage over his opponents.”
In November, the court ruled that their claims of retaliation for protected speech could proceed. According to court records, their case is pending settlement approval by the Cook County Board of Commissioners. The terms of the settlement have not been publicly disclosed.
Pagani’s complaint, which was initially filed in December 2024, raises similar allegations about employees forced to work for Dart’s 2022 reelection campaign.
In March, Dart kicked off his fifth bid for reelection.
Max Blaisdell is a fellow with the Invisible Institute and a staff writer for the Hyde Park Herald.
