Interrogatories Defamation

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

No. 08 P 8140

ESTATE OF

Advocacy Guardianship Services, NFP, as Limited Guardian of the Person of Joseph L. Ziarnik and individually, Josh Mitzen as Director, Advocacy Guardianship Services NFP and individually; Devon Bank, as agent for Joseph L. Ziarnik under Power of Attorney for Property dated April 1, 2008, as Trustee of the Joseph Ziarnik Trust dated April 1, 2008 and individually, and Janna Dutton, as attorney for the Estate of Joseph Ziarnik and individually,

JOSEPH L. ZIARNIK

A Disabled Person

Plaintiffs,

V.

Tammi Goldman,

Defendant.

P L A I N T I F F S ' F I R S T S E T O F I N T E R R O G A T O R I E S T O T A M M I G O L D M A N

Plaintiffs, Advocacy Guardianship Services, NFP, as Limited Guardian of the Person of

Joseph L. Ziarnik and individually, Josh Mitzen as Director, Advocacy Guardianship Services

NFP and individually; Devon Bank, as agent for Joseph L. Ziarnik under Power of Attorney for

Property dated April 1, 2008, as Trustee of the Joseph Ziarnik Trust dated April 1, 2008 and

individually, and Janna Dutton, as attorney for the Estate of Joseph Ziarnik and individually, by

and through their attorneys, JOHNSON & BELL, LTD., pursuant to Supreme Court Rule 213

requests that Defendant, TAMMI GOLDMAN, answer in accordance with the definitions and

instructions set forth below, the following interrogatories, under oath, 28 days after service

hereof.

A. These interrogatories are to be deemed continuing. Defendant is requested to

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

obtained by Defendant, or any person on Defendant's 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 Defendant's inability to answer the remainder and stating

what information Defendant has concerning the unanswered portion.

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 or the work product doctrine, please provide the following information:

INSTRUCTIONS

1. approximate date;

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

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.

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DEFINITIONS

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A. As used herein the term "documents" shall mean and include, without limitation,

the original and all copies of any written and any other tangible things including the following:

any handwritten, typed, oral, visual, or electronic communications or representation, computer

disks or input or output of any kind, agreements, letters, telegrams, telexes, e-mails, bulletins,

circulars, notices, specifications, instructions, literature, books, magazines, newspapers, booklets,

work assignments, reports, motion picture films, videotapes, sound recordings, photographs,

studies, analyses, surveys, memoranda, memoranda of conversations, notes, notebooks, diaries,

data sheets, work sheets, calculations, drafts of the aforesaid upon which have been placed any

additional marks or notations, or any other physical objects subject to inspection under the

Illinois Rules of Civil Procedure or the Illinois Supreme Court Rules.

B. The term "communication" shall mean any transmission or exchange of

information between two or more persons orally or in writing, including but not limited to

written contact by letter, memorandum, e-mail, telefax, telegraph, telex, or otherwise, and

conversations in face-to-face meetings, telephone conversations or otherwise.

C. The terms "refer to" or "relate to" shall mean consist of, reflect, or in any way be

legally, logically, or functionally in connection with the matter discussed.

D. The term "identify," when used with respect to a natural person, means to state his

or her full name, present or last known employer and job title, present or last known business

address, and present or last known home and work telephone numbers.

E. The term "identify," when used with respect to a document (as previously

defined) means to state the date, subject matter, author, recipient, and type of document (e.g.,

letter, memorandum, computer printout, sound reproduction, chart, etc.), the author and

recipients.

F. The term "Complaint" shall mean the First Amended Complaint in this matter

filed by Plaintiffs on May 1, 2012.

G. As used herein, the singular shall be deemed to include the plural, and the plural

shall be deemed to include the singular; the masculine, feminine, or neuter pronouns shall be

deemed to include each other; the disjunctive "or" shall be deemed to include the conjunctive

"and"; the conjunctive "and" shall be deemed to include the disjunctive "or"; and each of the

functional words "each," "every," "any," and "all" shall be deemed to include all of the other

functional words, as necessary to bring within the scope of this request any documents that might

otherwise be construed to be outside the scope.

INTERROGATORIES

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.

A N S W E R :


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

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A N S W E R :


your statements made your on personal website

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

set 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.

A N S W E R :


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



A N S W E R :



(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

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

knowledge thereof.

A N S W E R :



(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.

A N S W E R :



(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.

A N S W E R :



(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

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knowledge thereof.

A N S W E R :



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



A N S W E R :



(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.

A N S W E R :



(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.

A N S W E R :



(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.

A N S W E R :



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



A N S W E R :



(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

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knowledge thereof.

A N S W E R :



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

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

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

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

A N S W E R :



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



A N S W E R :



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

A N S W E R :



(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


knowledge thereof.

A N S W E R :



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



A N S W E R :



(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

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knowledge thereof

A N S W E R :



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



A N S W E R :



(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


A N S W E R :


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


A N S W E R :

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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.

A N S W E R :



(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.

A N S W E R :



(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.

A N S W E R :

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your statements made on your blog page (http://josephludwigziarnik.blogspot.com/2011/03/how-

to-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 Complaint, including but not limited to the identity of all


knowledge thereof.

A N S W E R :



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

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



A N S W E R :



(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

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

knowledge thereof.

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A N S W E R :



(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

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.

A N S W E R :

Respectfully submitted,

DEVON BANK, ADVOCACY GUARDIANSHIP SERVICES NFP, JOSH MITZEN, and JANNA DUTTON

Victor J. Pioli JOHNSON & BELL, LTD.

33 West Monroe Street Suite 2700 Chicago, Illinois 60603 312-372-0770 312-372-9818 (fax)

Attorneys for Plaintiffs, Devon Bank, Advocacy Guardianship Services NFP, Josh Mitzen, and Janna Dutton

CERTIFICATE OF SERVICE

I hereby certify that a true copy of Plaintiffs First Set of Interrogatories to Tammi

Goldman was served via United States Mail (postage prepaid) upon all counsel of record,

identified below this 20 t h day of February, 2015.

Tammy Goldman 3939 N. Kostner Ave. Chicago, IL 60641

Documents

Interrogatories Defamation