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 REQUESTS FOR DOCUMENTS 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 Illinois Supreme Court Rule 214, hereby requests

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.

These requests are to be deemed continuing. Defendant is requested to provide, by

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.

If any of these request cannot be responded to in full, answer or produce documents

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

in Defendant's possession, custody, or control or because of a claim of privilege, identify the

document by providing 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.

E.

In producing documents, you are requested to produce the original of each

document, together with all non-identical copies and drafts of that document.
F.

In producing documents requested, indicate the specific request(s) pursuant to which

each document or group of documents is being produced.

G.

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.

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-toface 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.
REQUESTS FOR DOCUMENTS

1.

All documents which Defendant referred to or relied upon in responding to any

of the interrogatories in Plaintiffs' First Set of Interrogatories to Tammi Goldman.

2.

All documents that support, refer, or relate to 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.

3.

All documents that support, refer, or relate to your statements made on your

personal website (http://josephludwigziarnik.blogspot.com) on or about March 1, 2011 as set forth

in 20 of the Complaint.
4.

All documents that support, refer, or relate to 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.
5.

All documents that support, refer, or relate to 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 22 of the Complaint.
6.

All documents that support, refer, or relate to 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.
7.
personal

All documents that support, refer, or relate to your statements made on your
website

(http://sites.google.com/site/josephludwigziarnik/)

on

the

page

entitled

Bequeathing Everything to Richard Loundy as set forth in 24 of the Complaint.

8.

All documents that support, refer, or relate to 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
9.

25 of the Complaint.

All documents that support, refer, or relate to 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.
10.

All documents that support, refer, or relate to 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

27 of the Complaint.

11.

All documents that support, refer, or relate to your statements made on your

personal website (http://sites.google.com/site/iosephludwigziamik/) on the page entitled Sally

Griffin and my "Aha Moment" as set forth in 28 of the Complaint.
12.

All documents that support, refer, or relate to 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 29 of the Complaint.
13.
personal

All documents that support, refer, or relate to your statements made on your
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.

14.
personal

All documents that support, refer, or relate to your statements made on your
website

(http://sites.google.com/site/josephludwigziarnik/)

on

the

page

entitled

Competency Hearing as set forth in 31 of the Complaint

15.

All documents that support, refer, or relate to your statements made on your

personal website (http://sites.google.com/site/iosephludwigziarnik/) on the page entitled Court

Order for the Competency Hearing as set forth in
16.

32 of the Complaint.

All documents that support, refer, or relate to your statements made on your

personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Moral Line

as set forth in
17.

33 of the Complaint.
All documents that support, refer, or relate to 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 34 of the Complaint.
18.

All documents that support, refer, or relate to 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.

19.

All documents that support, refer, or relate to 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 36 of the Complaint.
20.

All documents that support, refer, or relate to 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
21.

37 of the Complaint.

All documents that support, refer, or relate to 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 38 of the Complaint.
22.

All documents that support, refer, or relate to your statements made on your

personal website (http://sites.google.com/site/josephludwigziarnik/) on the page entitled Writing

Janna Dutton as set forth in
23.

39 of the Complaint.

All documents that support, refer, or relate to 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 40 of the Complaint.
24.

All documents that support, refer, or relate to your statements made on your

personal website (http://josephludwigziarnik.blogspot.com) as set forth in 41 of the Complaint.

25.
page

All documents that support, refer, or relate to your statements made on your blog

(http://josephludwigziarnik.blogspot.com/2011/08/dorothy-c-tyse)

Dorothy C. Tyse as set forth in

26.

on the page entitled

42 of the Complaint.

All documents that support, refer, or relate to your statements made on your blog

page (http://josephludwigziarnik.blogspot.com/2011/08/janna-dutton) on the page entitled Janna

Dutton as set forth in 43 of the Complaint.

27.

All documents that support, refer, or relate to your statements made on your blog

page (http://josephludwigziarnik.blogspot.com/2011/06/janna-dutton-and-susan-phelan) on the page

entitled Janna Dutton and Susan Phelan as set forth in
28.
page

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

entitled Sally Griffin Lookout as set forth in 45 of the Complaint.

29.

All documents that support, refer, or relate to your statements made on your blog

page (http://josephludwigziarnik.blogspot.com/2011/03/how-to-blow-l0- million-in-10-Years.html)

on the page entitled How to Blow 10 Million Dollars in 10 Years as set forth in

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

page (http://iosephludwigziarnik.blogspot.com/2010/12/probate-sharks.html) on the page entitled

Probate Sharks as set forth in 49 of the Complaint.
33.

All documents that support, refer, or relate to your statements made on your blog

page (http://josephludwigziarnik.blogspot.com/2010/l1/devon-bank-trust-department.html) on the

page entitled Devon Bank Trust Department as set forth in

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

use at any trial of this matter.

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 Requests for Documents to
Tammi Goldman was served via United States Mail (postage prepaid) upon all counsel of record,
identified below this 2

0th

day of February 2015.

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

10