Defendant Document Request Defamation
Defendant Document Request Defamation
These requests are deemed continuing. Plaintiffs are requested to provide, by way
to the extent possible, specifying the reasons for Plaintiffs inability to answer the remainder and
stating what information Plaintiffs have concerning the unproduced portion
C.
In the event a document is not produced because it no longer exists, is not presently
in the Plaintiffs possession, custody, or control or because of a claim of privilege, please identify
the document by providing the following information:
1. approximate date;
In responding to these requests, you are to furnish all information and documents in
the possession of the Plaintiffs agents, employees, and any other person acting their behalf and
under their control, and not merely such matter as is in her own personal possession.
E.
document, together with all non-identical copies and drafts of that document.
F.
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 eligible and bound or stapled in
the same manner as the original.
DEFINITIONS
A.
The terms Document or documents as used herein shall mean all materials
including without limitation the original, or absent any original, a copy, drafts, communications,
letters, written materials, reports, records, brochures, bulletins, newsletters, flyers, personal
calendars and diaries, minutes, contracts, agreements, memoranda, forecasts, invoices, or
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personal communications, tape recordings, films, negatives, stenographic notes, other data or
information compilations from which information can be obtained, and any written, printed,
recorded, or tangible matter of any character in the possession, custody, or control of you, your
attorneys, agents, or other persons, companies, or entities under your control.
B.
forth the following information regarding that individual: (a) name; (b) business address; (c)
business telephone number; (d) home address; and (e) home telephone number.
D.
means to set forth the following information regarding that business or other entity: (a) full name;
(b) address of its principal place of business or principal place of activity; (c) telephone number;
(d) the type of organization; (e) date of incorporation or establishment; and (f) chief executive or
operating officers name.
E.
The terms identify or identity when applied to documents means to set forth
the following information regarding that document to the extent possible: (a) the title and brief
description of the document; (b) the date of the document; (c) the identity of the writer of the
document; and (d) the identity of the recipient of the document. In lieu of itemization of the
information called for by subparagraphs (a)-(d), copies of documents of which identification is
sought may be attached to your answers to these interrogatories.
F.
The term Person as used herein shall be deemed to mean in the plural, as well
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as in the singular, any natural person, firm, company, association, partnership, proprietorship,
corporation, or other form of legal entity.
G.
The terms You, your, and yours, as used herein, are defined to mean and
refer to Plaintiffs, Janna Dutton, Josh Mitzen and Devon Bank, and any of either or both of its
employees, agents, representatives, attorneys, and other persons authorized to act on their behalf.
H.
I.
All words in any gender shall be deemed to include the masculine, feminine, or
neutral gender, all singular words shall include the plural, and all plural words shall include the
singular, as the context may require.
J.
DOCUMENTS TO BE PRODUCED
1.
2.
Produce a copy of Mr. Ziarniks will and Land Trust agreements, all deeds in
trust, all deeds and mortgages, and all correspondence relating to each such land trust and
properties.
3.
Produce all copies of Mr. Ziarniks bank statements, net worth, sale and inventory
Produce all documents in evidence of Mr. Ziarniks safe deposit boxes, value and
Produce the title and any other evidence of Mr. Ziarniks automobile.
6.
Produce copies of all bills the Plaintiffs submitted to Mr. Ziarniks estate for
7.
Produce copies of all bills Plaintiffs submitted for payment to Mr. Ziarnik
10.
Produce all copies of other applicants asked to be Mr. Ziarniks care manager
regard to withdrawing cash from Mr. Ziarniks trust account at Devon Bank. Including and not
limited to cash funneled through Home Instead Caregiving Agency.
12.
Produce all copies of receipts and cash payments from Home Instead Caregiving
14.
Produce copies of Home Instead logbook detailing Mr. Ziarniks daily activities,
Produce a copy of the check from Home Instead for repayment of $200 cash
stolen from Mr. Ziarnik (in the winter of 2008) by a caregiver in their employment.
16.
Produce a copy of the receipt from the diabetic testing meter the Japanese
American Service Committee requested to manage Mr. Ziarniks blood sugar after Mitzen was
awarded custody.
17.
Produce a copy (fax or email) of any documents firing Mr. Ziarniks Primary
Care Physician.
18.
Produce a copy of the receipt from the junkman ordered to clean out Mr. Ziarniks
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basement in 2009.
19.
Produce a copy of what the junkman inventoried in 2009 and placed into the vault
Produce a copy of the receipt and an inventory of the organization that cleaned out
Mr. Ziarniks home in 2008 (or 09) removing his gun, personal property and all other valuables
including those items Devon Bank didnt consider valuable.
21.
Produce a copy of the receipt of all assets Devon Bank sold in regard to Mr.
Ziarniks coin collection and anything removed from his safety deposit box at Bank of America
or the bank at Six Corners (Irving Park Rd. and Milwaukee Avenue).
22.
Produce a copy of the receipt from the sale of Mr. Ziarniks limited edition
oriental rug that he purchased thirty years ago for $600. The carpet Home Instead placed at Mr.
Ziarniks front door and utilized to wipe their feet.
23.
Produce a copy of the inventory list/or documents given to Mr. Ziarniks family
(niece and nephew) after his death. All family photos, communications, letters/correspondence
stored in his apartment and in several bankers boxes in the basement.
24.
Produce any and all written or recorded statements or reports in the care, custody
or control of you or any of your agents or representatives obtained from any person having
knowledge of facts taken prior to the filing of this lawsuit.
25.
Produce any and all records or documents pertaining to any economic losses
allegedly sustained by you as a result, in whole or in part, of the conduct and incidents at issue in
this lawsuit.
26.
Produce all correspondence and unprivileged documents between you and any
entity or person concerning any of the incidents, conduct or alleged damages which form the
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Produce all email and other correspondence between the Plaintiffs in regard to
the Defendant, her removal and plans to put Mr. Ziarnik under guardianship.
28.
Produce any and all documents upon which you have relied in answering
Any and all other documents upon which you may rely at the trial in this action.
Respectfully Submitted,
________________________________
Tami Goldmann
Tami Goldmann
Pro Se
3939 N Kostner Ave Chicago, Illinois 60641
Telephone: (773) 416-2965
#99500
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.