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ILLINOIS SCHOOL SYSTEM AUDITIllinois TIF Statewide Legal AuditBlight Fraud · Law Firm Conflicts · School District Losses · Who Got What

1,500+Active TIF districts in Illinois

~$1B+Annual property tax captured statewide

23 yearsMaximum TIF life — extended to 35 with legislation

5 of 14Factors required to declare IMPROVED area blighted

866-312-6456 | auditor@illinoisschooldistrict.org | IllinoisSchoolDistrict.org | May 2026

PART I: THE ILLINOIS TIF LEGAL FRAMEWORK — AND HOW IT IS ABUSED

The Core Legal Standard — What 'Blight' Actually RequiresIllinois TIF law (65 ILCS 5/11-74.4-1 et seq., the Tax Increment Allocation Redevelopment Act) requires a municipality to prove an area is BLIGHTED before creating a TIF. 'Blight' under the statute means the area shows conditions that are 'detrimental to the public safety, health, morals, or welfare.' The statute requires DOCUMENTED EVIDENCE — not the opinion of the mayor or his attorney. You cannot declare something blighted because it is 'underdeveloped,' 'has potential,' or 'would look nicer with new buildings.' Golf courses, cornfields, and perfectly functioning commercial corridors have all been declared 'blighted' in Illinois to create TIF districts. The courts have made judicial challenge virtually impossible. That is the problem.

The Statutory Blight Test — Improved Property (65 ILCS 5/11-74.4-3(a))

IMPROVED area requires 5 of these 14 factors — ALL must be DOCUMENTED, not assumedThis is the law. Not what KTJ told the village. Not what the consultant's eligibility study claimed. The actual statute requires each factor to be 'present, with that presence documented, to a meaningful extent so that a municipality may reasonably find that the factor is clearly present and reasonably distributed throughout the improved part of the area.'

#	Factor	What It Actually Means — Not What Consultants Claim
1	Dilapidation	Structures in advanced state of disrepair or deterioration — not 'could use updating'
2	Obsolescence	Buildings/structures that cannot be used for their intended purpose — not 'outdated aesthetic'
3	Deterioration	Damage, deterioration of surface coating, structure, or facility — requires physical evidence
4	Presence of structures below minimum code standards	Actual building code violations documented by inspection — not 'theoretical' violations
5	Illegal use of individual structures	Documented illegal uses — not speculation
6	Excessive vacancies in commercial structures	Documented vacancies — a 10% vacancy rate is NOT 'excessive'
7	Lack of ventilation, light or sanitary facilities	Physical deficiencies in buildings — not neighborhood-level claims
8	Inadequate utilities	Utilities of insufficient capacity, deteriorated, antiquated, or obsolete — not 'could be upgraded'
9	Excessive land coverage	Buildings covering excessive portion of land leaving no room for normal uses — rare in commercial areas
10	Deleterious land use or layout	Land uses that damage adjacent property values — documented harm required
11	Environmental clean-up	Sites requiring remediation — requires actual environmental assessment data
12	Lack of community planning	Area developed without comprehensive plan — almost universally claimed; rarely documented
13	Lagging EAV	5 consecutive years of EAV growth lagging city-wide — requires actual tax data
14	Flooding	Area subject to chronic flooding — requires engineering evidence

The BUT-FOR Test — The Second Legal Requirement

Municipalities MUST prove development would NOT occur without TIF. This is routinely fabricated.Under 65 ILCS 5/11-74.4-3, EVERY TIF declaration requires an affirmative finding that 'without the designation of the redevelopment project area and the adoption of a redevelopment plan for the area, it is unlikely that the area will be redeveloped.' This is the 'but for' test. In practice, municipalities routinely declare the but-for test satisfied for areas that major developers were ALREADY planning to develop — then give those developers millions in TIF subsidies. The Main Street Triangle in Orland Park is a textbook example: the area around 143rd and LaGrange is one of the most commercially active corridors in southwest Cook County. It was never 'blighted' by any rational application of the statute.

Vacant Land TIF — Lower Standard, More Abuse

Vacant land (as opposed to improved property) only requires 2 of 6 factors: (1) Obsolete platting; (2) Diversity of ownership making assembly difficult; (3) Tax delinquency; (4) Flooding/drainage problems; (5) Inadequate utilities; (6) Adjacent to or near a blighted area.

Abuse pattern: Municipalities routinely declare healthy vacant land as blighted by claiming 'diversity of ownership' (meaning it's owned by multiple private parties) or 'adjacent to a blighted area' — where the 'blighted area' was itself improperly designated.

PART II: THE MONEY FLOW — WHO GETS WHAT IN EVERY TIF

The TIF Money Distribution ChainWhen a TIF is created, property taxes from the ENTIRE designated area are frozen at the base year value. ALL increase in property tax revenue — the 'increment' — goes to the TIF fund for up to 23 years (extendable to 35). The schools, parks, libraries, and other taxing bodies get NOTHING from any new development in that area for 23 years. That money flows to: (1) The TIF fund administrator (the municipality); (2) Developers who receive TIF subsidies via Redevelopment Agreements; (3) Law firms who draft those agreements; (4) Engineering consultants who write the eligibility studies; (5) Construction contractors who build the TIF-funded improvements.

Who Gets Paid	What They Get Paid For	Who Controls the Contract	Conflicts
Developers	TIF subsidy via Redevelopment Agreement — can be tens of millions	Municipality (mayor/board)	Developer donates to mayor who approved TIF
Law firms (KTJ etc.)	TIF creation, eligibility study legal work, Redevelopment Agreement drafting, ongoing administration	Municipality attorney — same firm	Same firm represents village + school district + library + fire district in same TIF
Consulting firm (Moran, SB Friedman, Kane McKenna)	Eligibility study — writes the 'blight' finding	Mayor selects consultant	Consultants paid by municipality; incentivized to find blight that enables TIF
Construction contractors (Ozinga, Curran, Walsh, RC Wegman)	Infrastructure improvements within TIF — roads, sewers, utilities	Municipality awards contract	Contractor donates to politician who approved TIF and awards contracts
Insurance brokers	TIF-funded project insurance	Same broker as village/school insurance — no RFP	Same broker for all entities in same municipality
School districts	NOTHING — property tax increment denied for 23 years	Statute requires 'intergovernmental agreement' to share — rarely honored	Same law firm (KTJ) represented school district that SIGNED agreement AND village that created the TIF

PART III: KLEIN, THORPE & JENKINS — THE CONFLICT AT THE CENTER

KTJ Claims to Be 'The' Illinois Municipal Law Firm — But Who Are All Their Clients?Klein, Thorpe & Jenkins, Ltd. (KTJ) was founded in 1935 and claims to represent 'more local governments in Illinois than any other law firm.' Their Orland Park attorney Dennis Walsh personally represented: (1) Village of Orland Park as Village Attorney; (2) Village of Tinley Park; (3) Village of Riverside; (4) Village of Romeoville; (5) Village of Wilmette; (6) City of Oak Forest; (7) City of Palos Heights. Other KTJ attorneys simultaneously represented school districts, library districts, fire protection districts, and park districts in the same geographic areas. When the SAME law firm represents EVERY government entity in a TIF transaction — the village that creates the TIF, the school district that loses property tax revenue, the library district, the fire protection district — there is a structural conflict of interest at every negotiation.

The Orland Park TIF Conflict — KTJ on All Sides

Entity	KTJ Representation	The Conflict
Village of Orland Park	Dennis Walsh = Village Attorney since at least the original TIF creation (2004 Main Street Triangle TIF) through Pekau era	KTJ drafted the original TIF ordinance, the intergovernmental agreements with schools, and all related documents
Orland School District 135	KTJ represented and advised D135 on school law matters	KTJ represented BOTH the village creating the TIF AND the school district being asked to sign the intergovernmental payment agreement
High School District 230	KTJ has represented D230 on school law matters	Same dual representation — KTJ was on both sides of the TIF payment agreement
25 years later	Pekau uses KTJ opinion to call the TIF school payment agreement 'illegal'	The firm that DRAFTED the original agreement is now providing the legal opinion that it was illegal — representing the village in disputing an agreement they themselves wrote

THE SPECIFIC CONFLICT — MICHAEL F. HENRY'S FINDINGYou identified this directly: 25 years ago, KTJ represented D135, D230, AND the Village of Orland Park when the original Main Street Triangle TIF was created and the intergovernmental school payment agreement was signed. Now Mayor Pekau — using KTJ's opinion letter — claims the school payment agreement is illegal. KTJ is providing a legal opinion to invalidate an agreement KTJ itself drafted. This is: (1) A potential conflict of interest under Illinois Rules of Professional Conduct Rule 1.9 (duties to former clients); (2) A potential violation of Rule 1.7 (concurrent conflicts); (3) Potentially fraudulent if KTJ knew at the time of drafting that the agreement was legally questionable and said nothing.

KTJ's Known Client Conflicts in the Southwest Suburbs

Municipality	KTJ Attorney	Overlapping Clients in Same TIF Geography
Village of Orland Park	Dennis Walsh — Village Attorney	D135 and D230 school districts; Orland Fire Protection District; Orland Library District
Village of Tinley Park	Dennis Walsh — same attorney as Orland Park	Bremen HS District 228; School District 146/159; Tinley Park Library; Mokena/Frankfort districts in same TIF
Village of Riverside	Dennis Walsh	Riverside schools, park district, library — all potentially KTJ clients
City of Oak Forest	Dennis Walsh	School districts overlapping Oak Forest TIF geography
Multiple school districts	Various KTJ attorneys — statewide	School districts whose TIF revenue is being captured by KTJ-represented municipalities
Village of La Grange Park	Michael Jurusik (Village Attorney)	'Economic development, zoning and TIF matters' per press release — same geographic area as other KTJ municipal clients

PART IV: HARMONY SQUARE (TINLEY PARK) vs. MAIN STREET TRIANGLE (ORLAND PARK)

A: Orland Park Main Street Triangle — 20+ Years of Failure

Item	Detail
TIF created	2004 — original Main Street Triangle TIF
Location	9 acres northwest of LaGrange Road and 143rd Street, Orland Park
Blight declaration	Area around 143rd/LaGrange in Orland Park — ONE OF THE MOST COMMERCIALLY ACTIVE CORNERS IN SOUTHWEST COOK COUNTY. This is a high-traffic, fully functional commercial area. Blight declaration is facially questionable.
Village investment	$100+ million over 20+ years — Pekau himself called it 'a disaster we sunk $100 million into'
School payment agreement	Original intergovernmental agreement promised D135 and D230 extra funds during TIF lifetime — payments were NOT generated
Pekau era	Hired Edwards Realty (top donor) for six-figure consulting contract; created SECOND new TIF covering same geography; extended TIF instead of letting it expire
KTJ opinion	Pekau used KTJ's opinion to claim the original school payment agreement is 'illegal' — KTJ drafted that agreement 25 years ago
D230 President Zeder	Defended Pekau's TIF expansion; silenced D230 Trustee Mohammed Jaber who raised concerns; had secret 'sensitive proceedings' with village about TIFs per Ray Hanania reporting
D230 Trustee O'Sullivan	ALSO served as Orland Park Village Clerk simultaneously — had inside knowledge of both the school district's TIF concerns AND the village's TIF plans
New TIF	Pekau created NEW TIF covering same geography before leaving office; Dodge administration eliminated old Triangle TIF in 2025 — schools get $2.5M; NEW Pekau TIF still in place
Edwards Realty (Hassan) plan	$87M total development; developer to receive up to $70M through TIF and other funding; village on 'glide path to $271M in debt'
Current status	Weber Grill as first tenant; Dodge administration reconsidering all Pekau-era TIF commitments; second Pekau TIF still active

B: Tinley Park Harmony Square — Glotz + Rizza + Bremen TIF

Item	Detail
TIF	Bremen Redevelopment Tax Increment Financing District — Downtown Tinley Park
Project	Harmony Square: 1.6 acres at Oak Park Ave and North Street; $37M+ total investment; concert stage, ice rink, splash pad, artificial turf, new road (Festival Street), infrastructure
Designer	Lakota Group (Scott Freres) — same firm involved in multiple southwest suburban TIF-funded projects
Contractor	Curran Contracting + RC Wegman — excavation, foundation, hardscape; Curran simultaneously won $100M IDOT contract
Eminent domain	Village sought eminent domain for 3 private properties (6706, 6712, 6724 North Street) — residents refused to sell; village asked Illinois General Assembly for authorization
Joe Rizza connection	Rizza is CO-OWNER of Boulevard Development LLC with Robert Hansen — $37M development at South St and 67th Court adjacent to Harmony Square; Hansen SUED Rizza for refusing to finance Phase 2; dispute in court
The lawsuit	Hansen v. Rizza: Hansen claims Rizza 'refused to authorize seeking financing for second phase, proceed with construction or retain a general contractor' — leaving one building built and second in limbo
Glotz TIF authority	As mayor, Glotz controls the Bremen TIF fund allocation; approves all Redevelopment Agreements; controls which developers receive TIF subsidies
Rizza + Glotz connection	Rizza (auto dealer + TIF developer) operates in Tinley Park under Glotz's gaming licensing AND TIF development authority simultaneously
School district impact	Bremen High School District 228 and elementary districts in the TIF geography lose 23 years of property tax increment from downtown Tinley Park development

THE CRITICAL QUESTION ON HARMONY SQUAREJoe Rizza is simultaneously: (1) An auto dealer on the 159th St corridor whose dealerships generate millions in municipal sales tax for Tinley Park and Orland Park; (2) A TIF developer inside Glotz's Bremen TIF district; (3) Being sued by his own development partner. Did Rizza donate to Glotz? Did Rizza receive any TIF incentive payments or favorable treatment on the Boulevard development? Did Glotz approve any TIF-funded public improvements that directly benefited the Boulevard Development LLC property? These are the questions that need FOIA answers.

PART V: THE STATEWIDE TIF ABUSE PATTERN — WHAT TO INVESTIGATE

Illinois Has 1,500+ TIF Districts — Most Were Created by the Same Network of Law Firms and ConsultantsThe Illinois Comptroller's office requires annual TIF reports from all districts. The statewide picture is: 1,500+ TIF districts from 500+ municipalities. Nearly $1 billion in annual property tax increment captured. The same handful of law firms (KTJ, Ancel Glink, Robbins Schwartz, Franczek, Ice Miller) drafted the enabling ordinances. The same handful of consulting firms (Moran Economic Development, SB Friedman, Kane McKenna) wrote the eligibility studies finding 'blight.' The same handful of construction dynasties (Ozinga, Curran, Walsh, RC Wegman) built the TIF-funded infrastructure. The same campaign finance patterns — consultant and contractor donations to politicians who approved the TIFs — repeat across the state.

The Consulting Firm Problem — They Get Paid to Find Blight

Firm	What They Do and Why It's Corrupt
Moran Economic Development	Writes TIF eligibility studies for municipalities — paid BY the municipality; never finds that an area DOESN'T qualify; routinely finds 'blight' in fully functioning commercial areas
SB Friedman & Company	Same business model — TIF consultants paid to find blight; also does economic impact studies that show massive job creation that often never materializes
Kane McKenna	TIF consulting and administration — paid by the municipality they advise; revolving door with municipal government
Layne Christensen / Teska Associates	TIF planning consultants — paid per project to design TIF redevelopment plans
The structural corruption	Every consulting firm is hired BY and paid BY the municipality. Their business model depends on finding areas to be 'blighted.' A consultant who finds that proposed TIF areas DON'T qualify loses the client. There is no financial incentive to ever say no.

The Construction Dynasty Problem — Same Contractors in Every TIF

Dynasty	TIF Connection
Ozinga Bros. (concrete/materials)	Materials supplier to virtually every major TIF infrastructure project in northeast IL; Tim Ozinga was state rep for geography where Ozinga plants are located; voted on TIF-related legislation
Curran Contracting	Built Harmony Square TIF infrastructure in Tinley Park; simultaneously won $100M IDOT contract; RC Wegman partner; work in multiple IL TIF districts
RC Wegman	Curran partner on Harmony Square; general contractor on multiple IL TIF-funded projects; operates across Cook, Will, DuPage counties
Walsh Construction	Walsh Group — major TIF-funded public works contractor statewide; donated to politicians who controlled TIF funding allocation
The pattern	Contractors donate to aldermen, mayors, and trustees who approve TIF Redevelopment Agreements and award public works contracts within TIF districts. TIF-funded projects are not always subject to normal competitive bidding requirements when structured as Redevelopment Agreements.

What to FOIA — The Complete Statewide TIF Audit

Illinois Comptroller: Annual TIF reports for every district in IL — available at illinoiscomptroller.gov; request download of full database for all years 2000-2025

Every municipality with a TIF: The original Eligibility Study — who wrote it? Was it Moran, SB Friedman, or Kane McKenna? Cross-reference consultant against municipality's campaign donors

Every municipality with a TIF: The Joint Review Board minutes — did the school districts object? Did the law firm advising the school district also represent the municipality?

Every municipality with a TIF: The Redevelopment Agreement(s) — who is the developer? What is the TIF subsidy amount? Cross-reference developer against campaign donors

Every TIF with a school payment agreement: Was the agreement honored? If not, why not? Who was the law firm that drafted it?

Illinois ARDC (Attorney Registration and Disciplinary Commission): Any complaints against KTJ or other firms for representing conflicting parties in TIF transactions

Orland Park specifically: Original 2004 TIF ordinance and all supporting documents — who signed, who was the attorney, what was the blight finding

Orland Park: The KTJ opinion letter claiming the school payment agreement is illegal — obtain the full text; was KTJ disclosed as former counsel to D135/D230?

Tinley Park: All Redevelopment Agreements in the Bremen TIF; all TIF fund expenditures; Joe Rizza's Boulevard Development LLC — any TIF subsidies paid?

Statewide: Cross-reference all TIF Redevelopment Agreement recipients against IL Sunshine campaign finance donors to the approving politicians

Illinois School System Audit | 866-312-6456 | auditor@illinoisschooldistrict.org | May 2026

Illinois Statewide School District Compliance and Equity Audit 2026 | auditor@illinoisschooldistrict.org | IllinoisSchoolDistrict.org

◆ Investigation Network — Connected Pages

⚡ Active Investigation Leads 🔗 Statewide Conflict Analysis ⚙ Claar Machine 💰 Financial Anomalies 📊 Bond Database 🗺 Cook/Will/DuPage Network

⚡ New Lead / UpdateKEY FIGURE: $18B+ excluded statewide from school district tax base via TIF districts. Cooperative purchasing exemptions allow districts to bypass competitive bid — creates vendor capture pathway identical to insurance pool structure.