Interrogatories Defamation

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

ESTATE OF
JOSEPH L. ZIARNIK
No. 08 P 8140
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.
PLAINTIFFS' FIRST SET OF INTERROGATORIES TO TAMMI GOLDMAN
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 Supreme Court Rule 213
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.
These interrogatories are to be deemed continuing. Defendant is requested to
provide, by way of supplementary responses, such additional information 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 interrogatories.
B.
If any of these interrogatories cannot be responded to in full, answer to the extent
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
for which you cannot locate a copy in your possession or control.

D.
For any interrogatory which is objected to on the ground of any privilege,
including attorney-client or the work product doctrine, please provide 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.
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.
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.
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.
INTERROGATORIES
1.
Please specifically state and describe all facts, documents, and bases supporting
your statements made on your personal website (http://josephludwigziarnik.blogspot.com) on or

about January 7, 2011 as set forth in
19 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:
2.
your statements made on your personal website (http://josephludwigziarnik.blogspot.com) on or

about March 1, 2011 as set forth in
ANSWER:
3.
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, 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
statements
made
on
your
personal
website
(http://sites.google.com/site/iosephludwigziarnik/) on the page entitled Janna Dutton, Sally

Griffin, and Josh Mitzen as set forth in
ANSWER:
5.
your
statements
made
on
your
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, 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:
6.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Bequeathing Everything

to Richard Loundy as set forth in
24 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:
7.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Devon Bank Trust Scam

as set forth in
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
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh Mitzen = Sheer

Pandemonium as set forth in 26 of the Complaint, including but not limited to the identity of all
knowledge thereof.
ANSWER:
9.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh Mitzen as Guardian

as set forth in
ANSWER:
10.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Sally Griffin and my

Aha Moment" as set forth in
28 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.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Janna Dutton Races to

the House as set forth in
knowledge thereof.
ANSWER:
12.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Confirmation it's a

Devon Bank Scam as set forth in
30 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:
13.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Competency Hearing as

set forth in
ANSWER:
14.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Court Order for the

Competency Hearing as set forth in
ANSWER:
15.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Moral Line as set forth in

33 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:
16.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Financial Exploitation by

Professionals as set forth in
knowledge thereof.
ANSWER:
17.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh Mitzen as set forth in
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
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Bank Trustees from

Devon Bank as set forth in
knowledge thereof.
ANSWER:
19.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Ludwig's getting upset as

set forth in
ANSWER:
20.
your
statements
made
on
your
personal
website
(http;//sites.google.com/site/josephludwigziarnik/) on the page entitled Sally Griffin - Devon

Bank as set forth in
10
knowledge thereof
ANSWER:
21.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Writing Janna Dutton as

set forth in
ANSWER:
22.
your
statements
made
on
your
personal
website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Is it Life or Death? as set

forth in
ANSWER:
23.
your statements made on your personal website (http://josephludwigziarnik.blogspot.com) as set

forth in
ANSWER:
11
24.
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
knowledge thereof.
ANSWER:
25.
your
statements
made
on
your
blog
page
(http://josephludwigziarnik.blogspot.com/2011/08/ianna-dutton) as set forth in
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
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
45 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:
12
27.
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
knowledge thereof.
ANSWER:
28.
your
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
ANSWER:
29.
your
statements
made
on
your
(http://josephludwigziarnik.blogspot.com/2010/12/probate-sharks.html)
Probate Sharks as set forth in
blog
page
on the page entitled
49 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.
13
ANSWER:
30.
your
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.
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 Interrogatories to Tammi
Goldman was served via United States Mail (postage prepaid) upon all counsel of record,
th
identified below this 20 day of February, 2015.

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

Interrogatories Defamation

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Interrogatories Defamation

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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT - PROBATE DIVISION

Advocacy Guardianship Services, NFP,

Plaintiffs, Advocacy Guardianship Services, NFP, as Limited Guardian of the Person of

JOHNSON & BELL, LTD.,

pursuant to Supreme Court Rule 213

These interrogatories are to be deemed continuing. Defendant is requested to

provide, by way of supplementary responses, such additional information as may hereafter be

If any of these interrogatories cannot be responded to in full, answer to the extent

for which you cannot locate a copy in your possession or control.

For any interrogatory which is objected to on the ground of any privilege,

type of document (e.g., letter, memorandum);

a general description of its subject matter;

identification of author and address, if applicable;

identification of all recipients;

present location and custodian;

any other description necessary to enable the custodian to locate the

The term "communication" shall mean any transmission or exchange of

legally, logically, or functionally in connection with the matter discussed.

filed by Plaintiffs on May 1, 2012.

your statements made on your personal website (http://josephludwigziarnik.blogspot.com) on or

19 of the Complaint, including but not limited to the

your statements made on your personal website (http://josephludwigziarnik.blogspot.com) on or

20 of the Complaint, including but not limited to the

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled A Story of Elder Abuse as

(http://sites.google.com/site/iosephludwigziarnik/) on the page entitled Janna Dutton, Sally

22 of the Complaint, including but not limited to the

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Sally Griffin Offers Bribe

23 of the Complaint, including but not limited to the identity of all

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Bequeathing Everything

24 of the Complaint, including but not limited to the identity

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Devon Bank Trust Scam

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh Mitzen = Sheer

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh Mitzen as Guardian

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Sally Griffin and my

28 of the Complaint, including but not limited to the identity of

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Janna Dutton Races to

29 of the Complaint, including but not limited to the identity of all

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Confirmation it's a

30 of the Complaint, including but not limited to the identity

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Competency Hearing as

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Court Order for the

32 of the Complaint, including but not limited to the

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Moral Line as set forth in

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

34 of the Complaint, including but not limited to the identity of all

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Josh Mitzen as set forth in

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

36 of the Complaint, including but not limited to the identity of all

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Ludwig's getting upset as

(http;//sites.google.com/site/josephludwigziarnik/) on the page entitled Sally Griffin - Devon

38 of the Complaint, including but not limited to the identity of all

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Writing Janna Dutton as

(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Is it Life or Death? as set

your statements made on your personal website (http://josephludwigziarnik.blogspot.com) as set

(http://josephludwigziarnik.blogspot.com/2011/08/dorothy-c-tyse) on the page entitled Dorothy

42 of the Complaint, including but not limited to the identity of all

(http://josephludwigziarnik.blogspot.com/2011/08/ianna-dutton) as set forth in

45 of the Complaint, including but not limited to

46 of the Complaint, including but not limited to the identity of all

on the page entitled

49 of the Complaint, including but not limited to the identity of

33 West Monroe Street

identified below this 20 day of February, 2015.