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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 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.
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
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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
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 website and blog.
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:
12. Are any of the statements made in 22 false?
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.
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
statement was made.
f. Please provide the name and address of each person who
ridiculed you or held you in
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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 Action.
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:
13. Are any of the statements made in 23 false?
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]
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
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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
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 Action.
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:
14. Are any of the statements made in 23 false?
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.
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
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.
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i. Please provide all facts that that support your contention
that you suffered a loss of
earnings as a result of the Defendants Action.
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:
15. Are any of the statements made in 24 false?
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]
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
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
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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 Action.
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:
16. Are any of the statements made in 25 false?
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.
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.
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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
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 Action.
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:
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17. Are any of the statements made in 26 false?
Devon bank is going to kill someone - probably already have.
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
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 Action.
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
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and the corresponding monetary amount that you are attributing
to each specific element of
damage.
ANSWER:
18. Are any of the statements made in 27 false?
his attorney [Janna Dutton] . . . Shes running this scam. She
[Janna Dutton] did nothing to protect her client from being
financially exploited, abused and neglected.
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
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
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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 Action.
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:
19. Are any of the statements made in 28 false?
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?!
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
statement was made.
f. Please provide the name and address of each person who
ridiculed you or held you in
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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 Action.
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:
20. Are any of the statements made in 29 false?
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.
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
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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
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 Action.
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:
21. Are any of the statements made in 30 false?
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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.
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
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 Action.
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
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and the corresponding monetary amount that you are attributing
to each specific element of
damage.
ANSWER:
22. Are any of the statements made in 31 false?
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.
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
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.
-
22
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 Action.
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:
23. Are any of the statements made in 32 false?
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.
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
-
23
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 Action.
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:
24. Are any of the statements made in 33 false?
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.
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
-
24
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
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 Action.
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:
-
25
25. Are any of the statements made in 34 false?
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.
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 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
-
26
made.
i. Please provide all facts that that support your contention
that you suffered a loss of
earnings as a result of the Defendants Action.
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:
26. Are any of the statements made in 35 false?
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.
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
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
-
27
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 Action.
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:
27. Are any of the statements made in 36 false?
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.
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
-
28
and identify all persons who can compare your reputation before
and after the alleged defamatory
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 Action.
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:
28. Are any of the statements made in 37 false?
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.
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
-
29
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
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 Action.
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:
-
30
29. Are any of the statements made in 38 false?
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.
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
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
-
31
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 Action.
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:
30. Are any of the statements made in 39 false?
Janna Dutton... she's running this Senior scam.
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
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.
-
32
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 Action.
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:
Respectfully submitted
_______________________________
Tami Goldmann
Tami Goldmann Pro Se 3939 N Kostner Ave Chicago, Illinois 60641
Telephone: (773) 416-2965 #99500
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33
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
____________________________