defendant interrogatory request defamation

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, PROBATE DIVISION

COUNTY DEPARTMENT, CHANCERY DIVISION

DEFENDANTS FIRST SET OF INTERROGATORIES TO PLAINTIFFS

Now comes the defendant, Tami Goldmann, pro se, and pursuant to Rule 213 of the

Illinois Supreme Court, requests that Plaintiffs answer the interrogatories, under oath, 28 days

after services hereof:

Instructions

A. These interrogatories are deemed continuing. Plaintiffs are requested to provide, by

way of supplementary responses, such as additional information as may hereafter be obtained by

the Plaintiffs, or any person on Plaintiffs behalf, that will augment, supplement or otherwise

modify the answers now given in response to the following interrogatories.

B. If any of these interrogatories cannot be responded to in full, answer to the extent

possible, specifying the reasons for Plaintiffs inability to answer the remainder and stating what

information Plaintiffs have concerning the unanswered portions

C. Identify each and every document that once existed but which no longer exists, or

for which you cannot locate a copy in your possession or control.

D. For any interrogatory which is objected to on the ground of any privilege, including

attorney-client work product doctrine, please provide the following information:

In the Estate of Joseph Ziarnik, Plaintiff,

v.

Tami Goldmann, Defendant.

No. 08 P 8140

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1. approximate date;

2. type of document (e.g. letter, email, memo);

3. a general description of its subject matter;

4. identification of author and address, if applicable;

5. identification of all recipients;

6. present location and custodian;

7. any other description necessary to enable the custodian to locate the particular

document.

DEFINITIONS

A. Person or people include any natural person, corporation, partnership, sole

proprietorship, and any other form of business organization, and specifically includes (without

limitation) the parties to this action.

B. Plaintiff, you or your refers to Devon Bank and any representative, Janna

Dutton and Josh Mitzen personally and their agents, employees, and attorneys.

C. Document means the original and any non-identical copy (whether different

from the original by reason of notations or otherwise) of any written, printed, typed, recorded,

graphic or photographic matter, sound reproduction, tape, record, or other device, however

produced or reproduced. Document includes, but is not limited to, agreements, memoranda,

records, letters, correspondence, design drawing, blueprint, drafts, communications, diary entries,

reports, manuals, brochures, schedules, telephone logs, telephone toll records, telegrams

teletypes, computer printouts, and any data compilations. Document also means identical

copies of unavailable original documents and of available non-identical copies.

D. Identify, state or describe with respect to a document, means to state the

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name of or title of the document, the type of document, its date, the subject matter thereof and its

present location and to identify the person who authorized it, the person who signed it, the person

to whom it was addressed or sent, and its present custodian.

E. Identify, state or describe with respect to an oral communication, means

to state the date thereof and its substance, and to identify the person who made the

communication, the person to whom it was addressed, and any other person who heard the

communication.

F. Identify, state or describe with respect to a natural person, means to

provide identification sufficient to notice a deposition of such person and to serve such person

with legal process, to require their attendance at such an examination. Such identification

includes, but is not limited to name, occupation, title, address (business and personal) (including

zip codes), business and residential telephone numbers.

G. Identify, state or describe with respect to an incident, instances,

action, or actions, it should include, but not be limited to, the date, location, circumstances,

and any witnesses to such occasion.

H. The singular includes the plural and the plural includes the singular. The

masculine includes the feminine.

I. After answering each of the following Interrogatories, state the source, including

the name and job title of any natural person from whom information is obtained, and identify all

documents on which Plaintiff relied in answering that Interrogatory.

J. Whenever an Interrogatory requests the identity of a document, Plaintiff may, in

lieu of identifying the document, attach a copy thereof of his/her answer.

K. Where an objection is made to any Interrogatory on the grounds of privilege,

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specifically state the grounds on which the privilege is asserted. Describe any documents asserted

to be covered by the privilege and identify who prepared the document, when it was prepared,

and for whom it was prepared so that a court will be able to determine the validity of the asserted

privilege.

L. Defendants Action or Defendants Actions means Tami Goldmanns

statements made on her website and blog.

Interrogatories

1. Please state the names of the Plaintiffs and third party defendants that claim that

they are entitled to relief for any alleged defamatory statements.

2. For each individual Plaintiff, please state at length the facts upon which you will

rely to establish that you have standing to claim that you are entitled to your requested relief.

3. Identify all persons who you believe may have discoverable information relevant to

this litigation and describe the nature of the information possessed by any such persons.

4. Identify any and all persons you expect to call as a witness at trial, including expert

witnesses. Please describe the substance of the facts or opinions about which such persons,

including expert(s), intend to testify. Please state whether each expert will provide a written

expert report.

5. Please provide the names of clients (past and present) that you share(d) a business

relationship with. Devon Bank/Mitzen/Dutton and Devon Bank/Mitzen and Devon Bank/Dutton

and Dutton/Mitzen. Including and not limited to where the client was in guardianship and their

expenses didnt need to be approved by a Judge and clients where Mitzen was care manager.

6. Please state all facts that support any contention that persons were deterred from

associating with you as a result of Defendants Action. In answering this interrogatory, please

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identify all persons who were deterred from associating with you as a result of Defendants

Action.

7. Please provide all names, addresses and phone numbers of Mr. Ziarniks

caregivers.

8. Please state all facts that support any contention that Defendants Action is in

violation of Mr. Ziarniks privacy.

9. Please provide all facts that support your contention that Defendants Actions

were made in a reckless disregard of the truth.

10. Are there any statements in 19 false?

she [Janna] forced Ludwig into guardianship with Josh. So, I have Rick Block (bank trustee) bragging about wasting Ludwigs estate, hiring

Josh (private guardian) to help him steal it... Devon Bank had a plan in place to steal Ludwigs entire estate even before he transferred his money. Janna... knew she set Ludwig up with a Predatory Trust and the predators were circling in June of 2008. Devon Bank... tossed all his [Ludwig's] property and personal possessions. three months later Devon Bank will hire a doctor and make the move to adjudicate their clients totally disabled so they can gain complete control over their estates and person only to squander it.

a. If so, please state which Plaintiff is making the assertion that the statement is false.

b. Describe in detail how these statements are false and state at length the factual basis

underlying your assertion that these statements are false.

c. Please state what evidence you have to support your claim that these statements are

false.

d. Please identify all documents that support your claim that these statements are false.

e. Please provide all facts that your reputation was lowered as a result of these statements

and identify all persons who can compare your reputation before and after the alleged defamatory

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statement was made.

f. Please provide the name and address of each person who ridiculed you or held you in

contempt as a result of any statements contained in this paragraph which you claim to be

defamatory.

g. Please state in detail how you were ridiculed or held in contempt and in what manner

your reputation has been injured as a result of these statements.

h. Please provide all facts that your professional or business relationship suffered as a

result of these statements and please identify each person who can compare your professional or

business reputation before and after the alleged defamatory statement was made.

i. Please provide all facts that that support your contention that you suffered a loss of

earnings as a result of the Defendants Actions.

j. Please state the total amount of damages that you are claiming as a result of this

occurrence including an itemization of each specific element of damage that you are claiming

and the corresponding monetary amount that you are attributing to each specific element of

damage.

ANSWER:

11. Are any of the statements made in 21 false?

Devon Bank ransacked his home and stole his personal possessions.


b. Describe in detail how these statements are false and state, at length, the factual basis



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false.




statement was made.



defamatory.







earnings as a result of the Defendants website and blog.




damage.

ANSWER:


To get her [Janna Dutton] to stop setting him up to be financially raped.

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Sally and Josh... [are] liars and just out to steal Ludwigs estate. Someone from Devon Bank was telling Josh exactly what to do to Ludwig in order to steal his estate. Sally... was obsessed with stealing Ludwigs money from day one. She told both me and Ludwig ... that she was out to rip him and his heirs off. That's when Josh came over with the bottle of cranberry juice, drugged Ludwig and told him that the caregiver is now a housekeeper then forced him into afternoon and overnight care at $19 an hour. Josh also makes you regret ever telling her [Dutton] by abusing Ludwig. Josh sent a manager over to humiliate Ludwig in front of me by stripping him naked in his own living room. Josh came over with the juice to abuse him with it. Both Josh and Sally send the message that if you talk to Ludwigs attorney, their abuse gets worse. Theyre [Josh and Sally] going to kill someone. Janna Dutton is in on the take. Dutton... run[s] around doing all the legwork for their filthy scam. Dutton is crooked so you don't tell her anything. If you take the chance and contact her [Dutton], they [Josh and Sally] abuse her client until you never go to her again. When Dutton forced Ludwig into guardianship with Josh, she forced him into a lifetime of abuse, neglect, abandonment, isolation and financial exploitation. She [Dutton] signed his own death certificate. Sally Griffin... associates with and hires riffraff in order to steal estates.





false.




statement was made.


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defamatory.







earnings as a result of the Defendants Action.




damage.

ANSWER:


Janna Dutton (Elder Law Attorney) offered the bribe money on Sally Griffins (bank trustee at Devon Bank's) behalf. It is not his fault {Ludwig] his banker and attorney are crooked [Sally Griffin and Janna Dutton, respectively]





10

false.




statement was made.



defamatory.











damage.

ANSWER:


all the lives Devon Bank destroyed for a little bit of money.'

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Josh Mitzen (guardian to destroy Ludwigs health) Root Realty (to neglect and destroy Ludwigs property) After she [Sally Griffin] won custody of her client by lying and abusing him. They [Devon Bank] took his money, his property and tossed priceless family heirlooms in the trash. They [Devon Bank] showered Ludwig's money on their employees, set him up to be

robbed, raped and assaulted for the rest of his life. Senior citizens get abused for their estates (Sally Griffin). Sally Griffin is going to be the biggest embarrassment in the history of Devon Bank.





false.




statement was made.



defamatory.






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damage.

ANSWER:


Janna Dutton (Elder Law Attorney) offered the bribe money on Sally Griffins (bank trustee at Devon Bank's) behalf. It is not his fault {Ludwig] his banker and attorney are crooked [Sally Griffin and Janna Dutton, respectively]





false.




statement was made.



13

defamatory.











damage.

ANSWER:


Shortly after you or your loved one open a trust account at this bank, the bank trustees (Richard Block and Sally Griffin) will hire one of their friends to pt their client (your loved one) under temporary guardianship, deem them incompetent (by a doctor on their payroll), a guardianship hearing will ensue and you'll be fighting for custody. Mr. Mitzen is getting set up with 25% of the clients who open a trust account at Devon Bank. That bank (Devon Bank) owes a lot of money to a lot of people.




14


false.




statement was made.



defamatory.











damage.

ANSWER:

15


Devon bank is going to kill someone - probably already have.





false.




statement was made.



defamatory.










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damage.

ANSWER:


his attorney [Janna Dutton] . . . Shes running this scam. She [Janna Dutton] did nothing to protect her client from being financially exploited, abused and neglected.





false.




statement was made.



defamatory.





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damage.

ANSWER:


Sally [Griffin]... How can she possibly get up and look herself in the mirror every morning knowing that shes cheating and abusing an elderly Senior Citizen?

Sally [Griffin]... They're going to continue to make me watch as they rape the poor soul and ransack his estate?!





false.




statement was made.


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defamatory.











damage.

ANSWER:


The exact phrasing of what Rick Block (bank trustee at Devon Bank) had to say about Ludwig's money was, "I've got free reign over the old man's half a million dollars! No courts to go through!" I know it's an attorney's M.O. to lie and deny but Dutton goes overboard with this expression.





19

false.




statement was made.



defamatory.











damage.

ANSWER:


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Devon Bank scam... They're abusing their positions, their patrons with their own money, hiring their friends only to ransack estates.





false.




statement was made.



defamatory.










21


damage.

ANSWER:


He [Josh Mitzen] was hired by Devon Bank to put Ludwig on a diabetic sugar high so Sally Griffin (bank trustee) could steal his estate. His [Joseph Ludwig Ziarnik] life was over. Josh Mitzen, Janna Dutton, and the "Griffin Bank" [a reference to Sally Griffin and Devon Bank] were out to destroy it for a "little bit of money".

Sally Griffin who was using his half a million dollars to gain control of his estate.





false.




statement was made.



defamatory.



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damage.

ANSWER:


His [Joseph Ziarnik] attorney [Janna Dutton] forced him to sign those documents. He [Joseph Ziarnik] is now being raped by his own lawyer. [Janna Dutton]. If Dutton has her way, Ludwig is going to be financially raped until the day he

dies.





false.




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statement was made.



defamatory.











damage.

ANSWER:


I sat there and watched a man I loved and cared about get raped, feel raped, cry rape...to describe this daily onslaught of attacks (orchestrated by Devon Bank).

If you say, 'You're hurting my grandmother,' Devon Bank sends someone over and they unzip their pants right in front of you to rape her again.



24



false.




statement was made.



defamatory.











damage.

ANSWER:

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I truly honestly believed Devon Bank hid his will, his trust account then hired someone to kill him in order to steal his estate

Sally [Griffin] did warn us that the three of them [Devon Bank employees Sally Griffin, Josh Mitzen and Janna Dutton. Unless Dutton is suggesting shes also an employee of Devon Bank and not Mr. Ziarniks advocate] were going to steal Ludwig's estate but I honestly didn't think they would result to criminal behavior.





false.



and identify all persons who can compare your reputation before and after the alleged

defamatory statement was made.



defamatory.




result of these statements and please identify each person who can compare your

professional or business reputation before and after the alleged defamatory statement was

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made.




occurrence including an itemization of each specific element of damage that you are

claiming and the corresponding monetary amount that you are attributing to each specific

element of damage.

ANSWER:


Josh Mitzen is NOT even qualified to be a Care Manager. It was all a ruse set up by Rick Block and Sally Griffin, the two bank trustees at Devon Bank to steal Ludwig's million dollar estate.





false.




statement was made.



27

defamatory.











damage.

ANSWER:


Elder Protective Services [Devon Bank] setting Josh up in order to slander me, gain control of Ludwig's estate and then divvy it up amongst their friends.





false.



28


statement was made.



defamatory.











damage.

ANSWER:


Devon Bank... trust account. They hid it along with his will. At the time, I didn't know they [Devon Bank] were just setting up these people [Sally Griffin and Josh Mitzen and Wendy Katten] in order to steal Ludwig's estate and truly have "free reign over the old man's half a million" with no witnesses.



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false.




statement was made.



defamatory.











damage.

ANSWER:

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Sally [Griffin] kicked me out...she then got together with Josh Mitzen and Janna Dutton, to slander me, put Ludwig on a diabetic sugar high then force him into guardianship with Mr. Mitzen and a court competency hearing so she could steal and ransack his entire estate. Sally [Griffin] mismanaged Ludwig's money, threw out his property and hired thieves. She [Sally Griffin] hid Ludwig's will and trust account from him and his family, this woman [Sally Griffin] is STILL abusing the elderly. She's [Sally Griffin] slap-happy with her authority and abusing the elderly with it. Block [Richard Block]... he's looting estates.





false.




statement was made.



defamatory.





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damage.

ANSWER:


Janna Dutton... she's running this Senior scam.





false.




statement was made.



defamatory.

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damage.

ANSWER:

Respectfully submitted

_______________________________

Tami Goldmann

Tami Goldmann Pro Se 3939 N Kostner Ave Chicago, Illinois 60641 Telephone: (773) 416-2965 #99500

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CERTIFICATE OF SERVICE

I hereby certify that a true copy of Defendants First Set of Interrogatories to Plaintiffs was served via USPS upon all counsel of record, identified below this 7th day of May, 2015.

Johnson & Bell 33 West Monroe Street Suite 2700 Chicago, IL 60603 Attn: Pioli and Marconi

____________________________

defendant interrogatory request defamation

Documents

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particular document

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plaintiffs behalf

natural person

following interrogatories

set of interrogatories