Professional Documents
Culture Documents
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 any interrogatory which is objected to on the ground of any privilege, including
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.
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.
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.
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.
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.
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
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.
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.
Please state the names of the Plaintiffs and third party defendants that claim that
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
Please provide all facts that support your contention that Defendants Actions
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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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:
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
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:
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:
all the lives Devon Bank destroyed for a little bit of money.'
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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:
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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:
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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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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:
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:
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
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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:
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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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:
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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:
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
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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ANSWER:
ANSWER:
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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:
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:
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
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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:
ANSWER:
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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:
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.
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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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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.
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