Professional Documents
Culture Documents
Interrogatories Defamation
Interrogatories Defamation
No. 08 P 8140
A Disabled Person
Tammi Goldman,
Defendant.
PLAINTIFFS' FIRST SET OF INTERROGATORIES TO TAMMI GOLDMAN
requests that Defendant, TAMMI GOLDMAN, answer in accordance with the definitions and
instructions set forth below, the following interrogatories, under oath, 28 days after service
hereof.
INSTRUCTIONS
A.
possible, specifying the reasons for Defendant's inability to answer the remainder and stating
what information Defendant has concerning the unanswered portion.
C.
Identify each and every document that once existed but which no longer exists, or
including attorney-client or the work product doctrine, please provide the following information:
1.
approximate date;
2.
3.
4.
5.
6.
7.
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:
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.
information between two or more persons orally or in writing, including but not limited to
written contact by letter, memorandum, e-mail, telefax, telegraph, telex, or otherwise, and
conversations in face-to-face meetings, telephone conversations or otherwise.
C.
The terms "refer to" or "relate to" shall mean consist of, reflect, or in any way be
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
As used herein, the singular shall be deemed to include the plural, and the plural
shall be deemed to include the singular; the masculine, feminine, or neuter pronouns shall be
deemed to include each other; the disjunctive "or" shall be deemed to include the conjunctive
"and"; the conjunctive "and" shall be deemed to include the disjunctive "or"; and each of the
functional words "each," "every," "any," and "all" shall be deemed to include all of the other
functional words, as necessary to bring within the scope of this request any documents that might
otherwise be construed to be outside the scope.
INTERROGATORIES
1.
Please specifically state and describe all facts, documents, and bases supporting
identity of all documents and things referring or relating thereto, and the identity of the persons
with knowledge thereof.
ANSWER:
2.
Please specifically state and describe all facts, documents, and bases supporting
identity of all documents and things referring or relating thereto, and the identity of the persons
with knowledge thereof.
ANSWER:
3.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
your
on
personal
website
21 of the Complaint, including but not limited to the identity of all documents and
things referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
4.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
identity of all documents and things referring or relating thereto, and the identity of the persons
with knowledge thereof.
ANSWER:
5.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
6.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
of all documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
7.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
25 of the Complaint, including but not limited to the identity of all documents
and things referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
8.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
9.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
27 of the Complaint, including but not limited to the identity of all documents
and things referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
10.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
all documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
11.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
12.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
of all documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
13.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
31 of the Complaint, including but not limited to the identity of all documents and
things referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
14.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
identity of all documents and things referring or relating thereto, and the identity of the persons
with knowledge thereof.
ANSWER:
15.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
16.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
17.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
35 of the Complaint, including but not limited to the identity of all documents and things
referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
18.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
19.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
37 of the Complaint, including but not limited to the identity of all documents and
things referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
20.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
10
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof
ANSWER:
21.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
39 of the Complaint, including but not limited to the identity of all documents and
things referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
22.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
personal
website
40 of the Complaint, including but not limited to the identity of all documents and
things referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
23.
Please specifically state and describe all facts, documents, and bases supporting
41 of the Complaint, including but not limited to the identity of all documents and
things referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
11
24.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
blog
page
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
25.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
blog
page
43 of the
Complaint, including but not limited to the identity of all documents and things referring or
relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
26.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
(http://josephludwigziamik.blogspot.com/20ll/06/sally-griffin-lookout.html)
entitled Sally Griffin Lookout as set forth in
blog
on
page
the
page
the identity of all documents and things referring or relating thereto, and the identity of the
persons with knowledge thereof.
ANSWER:
12
27.
Please specifically state and describe all facts, documents, and bases supporting
your statements made on your blog page (http://josephludwigziarnik.blogspot.com/2011/03/howto-blow-10- million-in-10-Years.html) on the page entitled How to Blow 10 Million Dollars in
10 Years as set forth in
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER:
28.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
blog
page
(http://josephludwigziarnik.blogspot.com/2011/03/elder-protectie-services-scam-run-by-catholiccharities.html) on the page entitled "Elder Protective Services Scam? Run by Catholic Charities
as set forth in
47 of the Complaint, including but not limited to the identity of all documents
and things referring or relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
29.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
(http://josephludwigziarnik.blogspot.com/2010/12/probate-sharks.html)
Probate Sharks as set forth in
blog
page
all documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
13
ANSWER:
30.
your
Please specifically state and describe all facts, documents, and bases supporting
statements
made
on
your
blog
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, including but not limited to the identity of all documents and things referring or
relating thereto, and the identity of the persons with knowledge thereof.
ANSWER:
Respectfully submitted,
DEVON BANK, ADVOCACY
GUARDIANSHIP SERVICES NFP,
JOSH MITZEN, and JANNA DUTTON
Victor J. Pioli
JOHNSON & BELL, LTD.
CERTIFICATE OF SERVICE
I hereby certify that a true copy of Plaintiffs First Set of Interrogatories to Tammi
Goldman was served via United States Mail (postage prepaid) upon all counsel of record,
th