Defendants Interrogatory Answers

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

COUNTY DEPARTMENT, CHANCERY DIVISION

DEFENDANT RESPONSE TO JANNA DUTTON, JOSH MITZEN AND DEVON BANK’S FIRST SET OF INTERROGATORIES

NOW COMES Defendant, Tami Goldmann, pro se, responds as follows:

GENERAL ANSWERS AND OBJECTIONS

Defendant poses the following general objections to plaintiffs interrogatories and

incorporates each of these objections by reference to every answer provided hereafter:

1. The interrogatories request information going back six to seven years and the answers

given are based on the present facts known or believed by defendant at the time of its answer.

2. The defendant objects to any interrogatory that seeks information constituting or

containing information concerning communications between the defendant and anyone who

contacted her AFTER publication of her blog and website, spoken to her anonymously or with

local, state and federal government.

3. The defendant objects to these interrogatories to the extent that they are overly broad,

unduly burdensome, vague, ambiguous, confusing, require speculation to determine their

meaning (as presented by the plaintiffs’) or use imprecise specifications of the information

sought.

In the Estate of Joseph Ziarnik,

Plaintiff,

v.

Tami Goldmann,

Defendant.

No. 08 P 8140

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4. The defendant objects to any interrogatory the interferes with her First Amendment

Right of Free Speech, her personal experience and opinions which make up the entirety of her

blog and website.

5. The defendant objects any interrogatory to the extent that it does not seek information

that leads to the discovery of admissible evidence.

6. The defendant objects to any interrogatory as unduly and unnecessarily burdensome to

the extent that it seeks information that is matter of public record, already in the plaintiffs’

possession, can be read online or otherwise readily available to the plaintiffs‘, and, therefore,

may be accessed and obtained by the plaintiffs’ with less burden than the defendant can identify

and provide requested information.

7. None of the objections or responses contained herein is an admission concerning the

existence of any documents or materials, the relevance or admissibility of any documents,

materials or information, or the truth or accuracy of any statement or characterization contained

in Plaintiffs’ First Set of Interrogatories. The defendants’ written responses are made without

waiving, but, on the contrary, expressly reserving: (a) the right to object, on the grounds of

competency, privilege, relevancy, materiality or any other proper grounds, to the use of the

information provided herein, in whole or in part, in any subsequent proceeding in this action or

any other action; (b) the right to object on any and all grounds, at any time, to other discovery

requests involving or relating to the subject matter of these requests; and (c) the right at any time

to revise, correct, add or clarify any of the responses provided herein.

8. The defendant objects to any and most interrogatories that are beyond the one-year

statute of limitations but doesn’t mind being helpful in refreshing the Plaintiffs’ recollections.

SPECIFIC OBJECTIONS AND ANSWERS

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1. Please specifically state and describe all facts, documents, and bases supporting

your statements made on your personal website (http://josephludwigziarnik.blogspot.com) on or

about January 7, 2011 as set forth in ¶ 19 of the Complaint, including but not limited to the

identity of all documents and things referring or relating thereto, and the identity of the persons

with knowledge thereof.

ANSWER: Subject to and without waiving the General Answers and Objections set forth

above, the Responding Defendant answers this interrogatory as follows:

In June 2008, I wrote Dutton a letter stating Block was bragging about spending

Mr. Ziarnik’s half a million dollars. This was 7 years ago, I moved twice and no longer

have that computer. To the best of my knowledge, I also told Dutton (in that same letter)

Devon Bank absolutely refused to give Mr. Ziarnik money to buy diapers, food and other

necessities. Laurie Sherry from Elder Protective Services ordered Devon Bank to cut a

check in the amount of $200 and I have a copy of Mr. Ziarnik’s trust account proving this.

Sally Griffin came to the house a few days later apologizing, said she spoke to Dutton and

was issuing an ATM card. Dutton has this letter and Ms. Sherry is a witness.

In September 2008, Dutton went to meet with Mr. Ziarnik at his adult daycare with

court documents naming her colleague, Mitzen as guardian. Dutton explained to Mr.

Ziarnik that I’m a gold digger and forced him to sign the paper, she wouldn’t take no for

an answer. Melba Ristow, the director of the Japanese American Service Committee

(JASC) was in this meeting and is a witness.

See also Defendants Motion to Dismiss Exhibit B and F and Complaint Document

#1, Group Exhibit C for more details.


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your statements made on your personal website (http://josephludwigziarnik.blogspot.com) on or

about March 1, 2011 as set forth in ¶ 20 of the Complaint, including but not limited to the





Laurie Sherry from Elder Protective Services is a witness. I called and reported

Devon Bank, Janna Dutton, Josh Mitzen and Home Instead Caregiving Agency abusive.

Ms. Sherry intervened many times between the dates of 2008-09 and was Mr. Ziarnik’s

only advocate. I don’t have copies of my phone records from seven years ago but Elder

Protective Services has records of all clients. I also sent Laurie Sherry a very detailed

description of the abuse in March of 2009 that I no longer have a copy of. She may have it

in Mr. Ziarnik’s file. Also see Def. Motion to Dismiss Exhibit F. The eighteen other victims

that had the misfortune of coming into contact with Devon Bank, they are also witnesses to

this type of financial exploitation.


your statements made your on personal website

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled A Story of Elder Abuse

asset forth in ¶ 21 of the Complaint, including but not limited to the identity of all documents and

things referring or relating thereto, and the identity of the persons with knowledge thereof.



Devon Bank hired an organization in either 2008 or 2009 to clean out Mr. Ziarnik’s

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apartment removing all his personal possessions. Devon Bank should have all documents.

If not, Mr. Ziarnik was robbed because he was under their jurisdiction and the contents

removed from his apartment. In September of 2009, Lucy Atkins and Michael Douglas

witnessed a junkman taking all the contents from Mr. Ziarnik‘s basement. I sat on George

Weber’s porch but missed a good portion of the estate being looted and ransacked. See

Complaint Document #3, Group Exhibit C for further information in regard to this

particular snippet.


your statements made on your personal website

(http://sites.google.com/site/iosephludwigziarnik/) on the page entitled Janna Dutton, Sally

Griffin, and Josh Mitzen as set forth in ¶ 22 of the Complaint, including but not limited to the





In 2007, I contacted Elder Protective Services to protect Mr. Ziarnik from people

who were financially exploiting him. Laurie Sherry escorted me and Mr. Ziarnik to

Dutton’s office so he could write a will. We sat in the lobby. Both Elder Protective

Services and I did everything we could to try and protect Mr. Ziarnik from being

financially exploited by people who only wanted to utilize him as an ATM machine. We

didn’t fail him, Janna Dutton did.

Mitzen was also fired by Mr. Ziarnik and they were told he no longer wanted him to

come and he didn’t but still got paid. I have the document showing payment from Mr.

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Ziarnik’s account. I also have the cranberry juice bottle Mitzen fed Mr. Ziarnik and the

two cookies Home Instead dropped off and both cookies have the agencies logo on it. I

wrote Phelan (owner of Home Instead) an email reminding her of Mr. Ziarnik’s diabetes a

few days prior to the second cookie being dropped off. I no longer have this email nor can

I find the Xeroxed copies of Home Instead’s logbook proving it but I’m still tearing my

house upside down searching for these records. Phelan, the owner of Home Instead is a

witness and should have a copy of the email as well as the logbook where it’s written she

dropped a treat off to a diabetic immediately after I explained she was making him sick.

See Complaint Document #4, Group Exhibit C for all pertinent dates,

documentation and evidence. Also, see Defendants Motion to Dismiss Exhibit F. Eighteen

other victims that are also witnesses to this type of financial exploitation.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Sally Griffin Offers Bribe

Money as set forth in ¶ 23 of the Complaint, including but not limited to the identity of all

documents and things referring or relating thereto, and the identity of the persons with

knowledge thereof.



At the end of March or beginning of April 2009, I wrote Dutton a very detailed

description of the abuse her client was suffering at the hands of her colleagues. I can’t find

the letter and no longer have that computer. I expected Dutton to do something to protect

her client but, instead, she gave me an eviction notice. She went to Mr. Ziarnik’s daycare

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explaining to him that she was kicking me out. An employee from Devon Bank handed me

the notice without Dutton’s signature then she called later that same day. She stated she

was authorized by Devon Bank to make a payment of $500 if I moved by Friday. I called it

a “bribe” because no reasonable person could move out in five days and the apartment sat

empty for more than a year after I moved. I also called it “crooked” because how many

times did Devon Bank authorize those kinds of payments on behalf of their client and to

whom? Dutton is a witness, she has this letter and to the best of my knowledge, what’s

written online was also written in that letter six years ago. An employee of Devon Bank

along with the staff at Japanese American Service Committee are witnesses. See Def

Motion to Dismiss Ex. C and Complaint Document #5, Group Exhibit C for a detailed

description, dates and further information on these snippets.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Bequeathing Everything

to Richard Loundy as set forth in ¶ 24 of the Complaint, including but not limited to the identity

of all documents and things referring or relating thereto, and the identity of the persons with

knowledge thereof.



See Motion to Dismiss Exhibit F. Report of Devon Bank’s Guardianships. There

are Eighteen other examples of this type of financial exploitation and I have copies of all

the files on these victims. They are also witnesses. See also Complaint Document #6,

Group Exhibit C for even more facts.

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(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Devon Bank Trust Scam

as set forth in ¶ 25 of the Complaint, including but not limited to the identity of all documents

and things referring or relating thereto, and the identity of the persons with knowledge thereof.



See Motion to Dismiss Exhibit F. Report of Devon Bank’s Guardianships. There

are Eighteen other examples of this type of financial exploitation and I have copies of all

the files of these victims and they’re witnesses to this type of abuse. See also Complaint

Document #7, Group Exhibit C.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh Mitzen = Sheer

Pandemonium as set forth in ¶ 26 of the Complaint, including but not limited to the identity of all


knowledge thereof.



I called Laurie Sherry numerous times, she intervened and forced Mitzen to take

better care of his client. Again, she is a witness. Also, a nurse from Mr. Ziarnik’s adult

daycare contacted me (in 2009) alarmed because he was horribly constipated and they

needed to remove his stool manually. Although, I don’t recall her name, JASC (Japanese

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American Service Committee) is a witness and keeps impeccable records. I also called Mr.

Ziarnik’s home nurse to approve the stool softening medication ordered by his doctor (that

I purchased with my own money) and asked him to come over to put them into his

medication container. I think his name was Scott but the nursing agency has detailed

records, he is a witness. JASC also ordered a diabetic testing meter for Mr. Ziarnik

because his blood sugar levels were dangerously high and the caregivers from Home

Instead sent him to daycare in filthy clothes with a soiled diaper. The nurses have all

documentation in regard to Mr. Ziarnik’s blood sugar levels and how well he was doing

before and after Mitzen got involved in his care. See Motion to Dismiss Exhibit F. Report

of Devon Bank’s Guardianships and eighteen other examples of this type of financial

exploitation through the use of court.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh Mitzen as Guardian

as set forth in ¶ 27 of the Complaint, including but not limited to the identity of all documents

and things referring or relating thereto, and the identity of the persons with knowledge thereof.



The statement, “She did nothing to protect her client from being financially

exploited, abused and neglected.” The Plaintiff’s attorney (Mr. Pioli) keeps asking me to

remove my website. I told him that I don’t want it either. It was just set up to prove

Dutton would utilize it to sue me for defamation in order to profit. I wanted to prove she’s

not an advocate and I’ve accomplished my objective. I told Mr. Pioli I’d take it down if I

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got a letter asking but not anymore since Mr. Ziarnik is dead. She has no right to ask for

anything on his behalf. I made a commitment to Judge Atkins that I would work this out,

telling him that I’d remove the ‘alleged’ defamatory snippets IF I got a letter asking. See

Complaint Document #9, Group Exhibit C and the entire website and blog for further

information about the lack of protection in regard to Mr. Ziarnik including, and not

limited to, this very lawsuit. He’s being exploited for financial gain and Dutton is not his

advocate. Mr. Ziarnik is not even mentioned in these interrogatories.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Sally Griffin and my

Aha Moment" as set forth in ¶ 28 of the Complaint, including but not limited to the identity of

all documents and things referring or relating thereto, and the identity of the persons with

knowledge thereof.



See Def. Motion to Dismiss Exhibit G. All pertinent dates on that copy and

Complaint Document #10, Group Exhibit C. Sally Griffin resigned.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Janna Dutton Races to

the House as set forth in ¶ 29 of the Complaint, including but not limited to the identity of all


knowledge thereof.

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I couldn’t make that statement up. Block bragged about having free reign over Mr.

Ziarnik’s money many, many times. The first time he came to the house he said it to Sally

Griffin right in from of me. In June 2008 (I don’t recall the exact date but Sally Griffin

mentioned it was her wedding anniversary), Block came over with contractors and people

who were going to manage the building. He bragged several times and shouted that

statement in front of Mr. Ziarnik’s tenant (Melinda Sepulveda) while we were looking at

her apartment. He said it again in Mr. Ziarnik’s apartment, then again in front of Sally

Griffin on the back porch. The defendant doesn’t recall whether or not he said it again

after she showed him the garage but he couldn’t stop talking about all the people he could

hire. His job as trustee is to preserve the estate not boast about spending it. Once again, I

wrote Dutton a letter in June of 2008. She didn’t do anything about Block’s lack of self-

control and this lawsuit is further proof Devon Bank is not doing their jobs of preserving

the estate. Also see Def. Motion to Dismiss Ex. F and the full paragraph in the Complaint

Document #11, Group Exhibit C.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Confirmation it's a

Devon Bank Scam as set forth in ¶ 30 of the Complaint, including but not limited to the identity

of all documents and things referring or relating thereto, and the identity of the persons with

knowledge thereof.


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See Def. Motion to Dismiss Ex. F. Nineteen Cases of abuse, they’re witnesses and

Complaint Document #12, Group Exhibit C for a full description of this particular snippet.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Competency Hearing as

set forth in ¶ 31 of the Complaint, including but not limited to the identity of all documents and




Laurie Sherry, Sally Griffin, Lucy Atkins, Michael Douglas and the entire staff at

Japanese American Service Committee are witnesses to this financial abuse along with Mr.

Ziarnik’s friends and family members. The caregivers from Home Instead are also

witnesses. Some of them were very nice, they didn’t like what was happening and I don’t

recall all their names. In the report I wrote, they’re witnesses to this type of financial

abuse also. See Complaint Document #13, Group Exhibit C for further details.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Court Order for the

Competency Hearing as set forth in ¶ 32 of the Complaint, including but not limited to the


knowledge thereof.


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See question 1 above, the witnesses the same and Defendants Motion to Dismiss Ex.

C. See more details in their Complaint Document #14, Group Exhibit C.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Moral Line as set forth in

¶ 33 of the Complaint, including but not limited to the identity of all documents and things

referring or relating thereto, and the identity of the persons with knowledge thereof



Mr. Ziarnik was complaining to everyone about how they were exploiting him. His

entire daycare knew of the abuse. Japanese American Service Committee staff are all

witnesses. See also Complaint Document #15, Group Exhibit C and the defendants website

and blog for full details of the abuse.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled, Financial Exploitation

by Professionals as set forth in ¶ 34 of the Complaint, including but not limited to the identity of


knowledge thereof.



This interpretation is incorrect. “Sally [Griffin] did warn us that the three of them

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[Devon Bank employees Sally Griffin, Josh Mitzen and Janna Dutton. Unless Dutton is

suggesting she’s also an employee of Devon Bank and not Mr. Ziarnik’s advocate] were

going to steal Ludwig's estate but I honestly didn't think they would result to criminal

behavior.”

I truly believed the Plaintiff’s hid Mr. Ziarnik’s will for an entire year to become

sole heirs and I’m now living in that reality. Sally Griffin did warn me that everyone was

‘really good friends’ and I didn’t understand what she meant until they surrounded Mr.

Ziarnik and spoke of lavishing his money on themselves, hiring their friends, riding around

in taxis and so on. See Exhibit F, this is what Sally Griffin is referring to about how

friendly they all are. Devon Bank’s Guardianships and this defamation suit 08 P 8140.

Laurie Sherry from Elder Protective Services is a witness. She ordered the documents be

given to Mr. Ziarnik. See also Complaint Document #16, Group Exhibit C for the exact

interpretation of this snippet.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh Mitzen as set forth in

¶ 35 of the Complaint, including but not limited to the identity of all documents and things

referring or relating thereto, and the identity of the persons with knowledge thereof.



From a Chicago Tribune article dated April 19, 2004; “Most care managers have

master's degrees in social work, nursing, counseling or gerontology, or, in Mitzen's case,

law. Most also usually have some care management background, though there are no

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licensing/regulatory requirements, experts say. It costs about $3,000 to start a care

management operation, including renting office space, joining professional organizations

and printing brochures.” See Complaint Document #17, Group Exhibit C and Motion to

Dismiss Exhibit F and Mitzen’s ten other victims are witnesses.

18. Please specifically state and describe all facts, documents, and bases supporting your

statements made on your personal website (http://sites.google.com/site/josephludwigziarnik/) on

the page entitled Bank Trustees from Devon Bank as set forth in ¶ 36 of the Complaint, including

but not limited to the identity of all documents and things referring or relating thereto, and the

identity of the persons with knowledge thereof.



The interpretation of this snippet is incorrect. The heading is “Bank Trustees from

Devon Bank” not Elder Protective Services: “In walk Sally and Rick from Devon Bank…….

Yes, they're [Devon Bank] hiring him for my position. Just setting Josh up in order to

slander me, gain control of Ludwig's estate then divvy it up amongst their friends.” See

Complaint Document #18, Group Exhibit C. Elder Protective Services and I did our best

trying to protect Mr. Ziarnik from these types of financial predators.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Ludwig's getting upset as




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I contacted Laurie Sherry in order to get a copy of Mr. Ziarnik’s trust account. She

is a witness. The snippet is also incorrect. “At the time, I didn't know they [Devon Bank]

were just setting up these people [Sally Griffin Wendy Katten and Josh Mitzen] in order to

steal Ludwig's estate and truly have "free reign over the old man's half a million" with no

witnesses. See Complaint Document #19, Group Exhibit C for a correct interpretation.



(http;//sites.google.com/site/josephludwigziarnik/) on the page entitled Sally Griffin - Devon

Bank as set forth in ¶ 38 of the Complaint, including but not limited to the identity of all


knowledge thereof



Without waiving objection, see Def. Motion Exhibit F. In particular, Heinz Lehner.

Sally Griffin also resigned. See Complaint Document #20, Group Exhibit C.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Writing Janna Dutton as





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Janna Dutton is financially exploiting her own client right now. All the plaintiffs’

had to do is ask and the blog and website will be removed but they can’t profit without it. See

Complaint Document, #21, Group Exhibit C for further details in regard to Dutton’s

character, her entire Complaint and Defendants Motion to Dismiss.



(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Is it Life or Death? as set

forth in ¶ 40 of the Complaint, including but not limited to the identity of all documents and




Sally Griffin is a witness. Victor Pioli is my witness. He spoke of being good friends

with Dutton, how they give each other business and although, he doesn’t look at this case as

financial exploitation, he doesn’t mind it since he’s being paid. See also Complaint

Document #22, Group Exhibit C for more details.


your statements made on your personal website (http://josephludwigziarnik.blogspot.com) as set

forth in ¶ 41 of the Complaint, including but not limited to the identity of all documents and




See Def. Motion to Dismiss Exhibit F, Complaint Document #23, Group Exhibit C

and Case number 08 P 8140 for full details in regard to this snippet. The victims in my

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report are witnesses to this type of financial abuse by professionals.


your statements made on your blog page

(http://josephludwigziarnik.blogspot.com/2011/08/dorothy-c-tyse) on the page entitled Dorothy

C. Tyse as set forth in ¶ 42 of the Complaint, including but not limited to the identity of all


knowledge thereof.



Public record and see Complaint Document #24, Group Exhibit C for further

information.



(http://josephludwigziarnik.blogspot.com/2011/08/ianna-dutton) as set forth in ¶ 43 of the

Complaint, including but not limited to the identity of all documents and things referring or

relating thereto, and the identity of the persons with knowledge thereof.



Ms. Dutton gives law firms a lot of business so, they vote for her. She just secured

herself more votes with this lawsuit. This snippet, “If you hire Janna Dutton, she's got a lot

of hidden fees.” Mr. Pioli is a witness since he’s another hidden fee that an elder wouldn’t

expect when hiring her to set up their end of life matters. See Complaint Document #25,

Group Exhibit C.

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(http://josephludwigziamik.blogspot.com/20ll/06/sally-griffin-lookout.html) on the page

entitled Sally Griffin Lookout as set forth in ¶ 45 of the Complaint, including but not limited to

the identity of all documents and things referring or relating thereto, and the identity of the

persons with knowledge thereof.



An elder law attorney explained to one of my victims (in the report I wrote) that

Sally Griffin owed her a favor. I’m not revealing my sources. See Complaint Document

#27, Group Exhibit C for more information in regard to this buddy system Devon Bank has

with elder law attorneys.



(http://josephludwigziarnik.blogspot.com/2011/03/howto-blow-10- million-in-10-Years.html) on

the page entitled How to Blow 10 Million Dollars in 10 Years as set forth in ¶ 46 of the





Block can verify investments and see Def. Motion to Dis. Exhibit F and Complaint

Document #28, Group Exhibit C. Nineteen victims families are witnesses.


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(http://josephludwigziarnik.blogspot.com/2011/03/elder-protectie-services-scam-run-by-

catholiccharities.html) on the page entitled "Elder Protective Services Scam? Run by Catholic

Charities as set forth in ¶ 47 of the Complaint, including but not limited to the identity of all


knowledge thereof.



This has been removed. See Def. Motion to Dismiss Ex. F and full details in

Complaint Document #29, Group Exhibit C. Laurie Sherry from Elder Protective Services

is a witness. She did her best in trying to preserve Mr. Ziarnik’s estate and protect him

from this type of financial exploitation.



(http://josephludwigziarnik.blogspot.com/2010/12/probate-sharks.html) on the page entitled

Probate Sharks as set forth in ¶ 49 of the Complaint, including but not limited to the identity of


knowledge thereof.



Dutton would not give Mr. Ziarnik a copy of his will. She behaved as if it were hers

to inherit and it is. She set up Mr. Ziarnik’s estate for her own benefit then implemented

this lawsuit while he was on his deathbed. His main caregiver is a witness to the fact he

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was on his deathbed when this lawsuit was filed, I don’t know her name. None of these

interrogatories are about him either, they’re merely utilizing his name to profit. There is a

reference to Probatesharks that it’s a felony not to give someone a copy of their will. See

also Complaint Document #31, Group Exhibit C for full details into this type of abuse.



(http://josephludwigziarnik.blogspot.com/2010/10/devon-bank-twelve-senior-residences.html)

on the page entitled Devon Bank - Twelve Senior residence Facilities as set forth in ¶ 51 of the





See Motion to Dismiss Exhibit F and Complaint Document #33 Group Exhibit C. for

further details. The entire staff at Japanese American Service Committee are witnesses as

well as some caregivers from Home Instead Caregiving agency. The plaintiffs weren’t

discrete in their abuse or neglect.

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VERIFICATION

I have read the foregoing Responses, which are based on a diligent and reasonable effort

by me to obtain information currently available. I reserve the right to make changes in or

additions to any of these answers if it appears at any time that errors or omissions have been

made or if more accurate or complete information becomes available. Subject to these

limitations, these Responses are true to the best of my present knowledge, information, and

belief.

Subscribed and sworn to under the pains and penalties of perjury this 28 day of May,

2015.

________________________________

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 the above document was served upon all counsel of

record by first-class mail on May 28, 2015.

_______________________

Documents

Defendants Interrogatory Answers