defendant interrogatory request defamation

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Elder Abuse and Financial Exploitation through the use of Guardianship and Defamation suit. Janna Dutton of Dutton & Casey Elder Law, Josh Mitzen of Advocacy Services. Richard Block of Devon Bank. Sally Griffin. Profiting off the elderly utilizing court system. How an attorney sets up a will and Trust Account to become sole heir.

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  • 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