Professional Documents
Culture Documents
No. 08 P 8140
A Disabled Person
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.
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.
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
approximate date;
2.
3.
4.
5.
6.
7.
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 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.
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-toface 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 filed
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 that support, refer, or relate to your statements made on your
19 of the Complaint.
3.
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made your on
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your
website
(http://sites.google.com/site/josephludwigziarnik/)
on
the
page
entitled
All documents that support, refer, or relate to your statements made on your
25 of the Complaint.
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your
27 of the Complaint.
11.
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your
website
(http://sites.google.com/site/josephludwigziarnik/)
on
the
page
entitled
All documents that support, refer, or relate to your statements made on your
website
(http://sites.google.com/site/josephludwigziarnik/)
on
the
page
entitled
All documents that support, refer, or relate to your statements made on your
32 of the Complaint.
All documents that support, refer, or relate to your statements made on your
33 of the Complaint.
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your
35 of the Complaint.
19.
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your
37 of the Complaint.
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your
39 of the Complaint.
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your
All documents that support, refer, or relate to your statements made on your blog
(http://josephludwigziarnik.blogspot.com/2011/08/dorothy-c-tyse)
42 of the Complaint.
All documents that support, refer, or relate to your statements made on your blog
27.
All documents that support, refer, or relate to your statements made on your blog
44 of the Complaint.
All documents that support, refer, or relate to your statements made on your blog
(http://josephludwigziarnik.blogspot.com/2011/06/sally-griffin-lookout.html')
on the page
All documents that support, refer, or relate to your statements made on your blog
46 of the
Complaint.
30.
page
All documents that support, refer, or relate to your statements made on your blog
(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
31.
page
47 of the Complaint.
All documents that support, refer, or relate to your statements made on your blog
(http://josephludwigziamik.blogspot.com/2011/02/cook-county-pubic-private-guardians.html)
on the page entitled Cook County Public & Private Guardians as set forth in
32.
48 of the Complaint
All documents that support, refer, or relate to your statements made on your blog
All documents that support, refer, or relate to your statements made on your blog
50 of the Complaint.
34.
page
All documents that support, refer, or relate to your statements made on your blog
(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.
35.
page
All documents that support, refer, or relate to your statements made on your blog
(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
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 Requests for Documents to
Tammi Goldman was served via United States Mail (postage prepaid) upon all counsel of record,
identified below this 2
0th
Tammy Goldman
3939 N. Kostner Ave.
Chicago, IL 60641
10