request for documents defamation

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

ESTATE OF

JOSEPH L. ZIARNIK

A Disabled Person

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,

Plaintiffs,

v.

Tammi Goldman,

Defendant.

No. 08 P 8140

P L A I N T I F F S ' F I R S T S E T O F R E Q U E S T S F O R D O C U M E N T 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 Illinois Supreme Court Rule 214, hereby requests

that Defendant, FERGUSON DEVELOPMENT, LLC, produce the following documents within 28

days, at the office of counsel for Plaintiff, Johnson & Bell, Ltd., 33 West Monroe Street, Suite 2700,

Chicago, Illinois 60603, Attn: Victor J. Pioli.

INSTRUCTIONS

A. In responding to these requests, you are to furnish all information and documents in

the possession of Defendant's agents, employees, and any other person acting on her behalf and

under her control, and not merely such matter as is in her own personal possession.

B. These requests are to be deemed continuing. Defendant is requested to provide, by

way of supplementary responses and production, such additional information and documentation 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 requests.

C. If any of these request cannot be responded to in full, answer or produce documents

to the extent possible, specifying the reasons for Defendant's inability to answer or produce the

remainder and stating what information or documents Defendant has concerning the unanswered or

unproduced portion.

D. In the event a document is not produced because it no longer exists, is not presently

in Defendant's possession, custody, or control or because of a claim of privilege, identify the

document by providing the following information:

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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E. In producing documents, you are requested to produce the original of each

document, together with all non-identical copies and drafts of that document.

F. In producing documents requested, indicate the specific request(s) pursuant to which

each document or group of documents is being produced.

G. Documents from any single file shall be produced in the same order they were found

in such file, and the files from which they are being produced shall be identified. If copies of

documents are produced in lieu of originals, such copies shall be legible and bound or stapled in the

same manner as the original.

DEFINITIONS

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:

electronically stored information (ESI), 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.

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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.

REQUESTS FOR DOCUMENTS

1. All documents which Defendant referred to or relied upon in responding to any

of the interrogatories in Plaintiffs' First Set of Interrogatories to Tammi Goldman.

2. All documents that support, refer, or relate to your statements made on your

personal website (http://josephludwigziarnik.blogspot.com) on or about January 7, 2011 as set forth

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i n 19 of the Complaint.


personal website (http://josephludwigziarnik.blogspot.com) on or about March 1, 2011 as set forth

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in 20 of the Complaint.

4. All documents that support, refer, or relate to 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.


personal website (http://sites.google.com/site/iosephludwigziarnik/) on the page entitled Janna

22 of the Complaint. Dutton, Sally Griffin, and Josh Mitzen as set forth in


personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Sally

Griffin Offers Bribe Money as set forth in 23 of the Complaint.


personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled

24 of the Complaint. Bequeathing Everything to Richard Loundy as set forth in


personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Devon

Bank Trust Scam as set forth in 25 of the Complaint.


personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh

26 of the Complaint. Mitzen = Sheer Pandemonium as set forth in



Mitzen as Guardian as set forth in 27 of the Complaint.

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personal website (http://sites.google.com/site/iosephludwigziamik/) on the page entitled Sally

Griffin and my "Aha Moment" as set forth in 28 of the Complaint.


personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Janna

29 of the Complaint. Dutton Races to the House as set forth in



Confirmation it's a Devon Bank Scam as set forth in 30 of the Complaint.



Competency Hearing as set forth in 31 of the Complaint


personal website (http://sites.google.com/site/iosephludwigziarnik/) on the page entitled Court

32 of the Complaint. Order for the Competency Hearing as set forth in


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

as set forth in 33 of the Complaint.


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

34 of the Complaint. Exploitation by Professionals as set forth in



Mitzen as set forth in 35 of the Complaint.

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personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Bank

36 of the Complaint. Trustees from Devon Bank as set forth in


personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Ludwig's

getting upset as set forth in 37 of the Complaint.


personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Sally

38 of the Complaint. Griffin - Devon Bank as set forth in


personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Writing

Janna Dutton as set forth in 39 of the Complaint.


personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Is it Life or

Death? as set forth in 40 of the Complaint.


personal website (http://josephludwigziarnik.blogspot.com) as set forth in 41 of the Complaint.

25. All documents that support, refer, or relate to 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.


page (http://josephludwigziarnik.blogspot.com/2011/08/janna-dutton) on the page entitled Janna

Dutton as set forth in 43 of the Complaint.

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page (http://josephludwigziarnik.blogspot.com/2011/06/janna-dutton-and-susan-phelan) on the page

entitled Janna Dutton and Susan Phelan as set forth in 44 of the Complaint.


page (http://josephludwigziarnik.blogspot.com/2011/06/sally-griffin-lookout.html') on the page

entitled Sally Griffin Lookout as set forth in 45 of the Complaint.


page (http://josephludwigziarnik.blogspot.com/2011/03/how-to-blow-l0- million-in-10-Years.html)

on the page entitled How to Blow 10 Million Dollars in 10 Years as set forth in

Complaint.

46 of the


page (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 as set forth in 47 of the Complaint.


page (http://josephludwigziamik.blogspot.com/2011/02/cook-county-pubic-private-guardians.html)

48 of the Complaint on the page entitled Cook County Public & Private Guardians as set forth in


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

Probate Sharks as set forth in 49 of the Complaint.


page (http://josephludwigziarnik.blogspot.com/2010/l1/devon-bank-trust-department.html) on the

page entitled Devon Bank Trust Department as set forth in 50 of the Complaint.


Respectfully submitted,

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

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page (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.


page (http://josephludwigzianik.blogspot.com/2011/12/devon-bank-trust-department-putting.html)

on the page entitled Devon Bank Trust Department - Putting Them Out of Business as set forth in

52 of the Complaint.

36. All documents that constitute, refer, or relate to any exhibit(s) that you plan to

use at any trial of this matter.

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 Requests for Documents to

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

identified below this 2 0 t h day of February 2015.

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

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