IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, PROBATE DIVISION

In the Estate of Joseph

Ziarnik, DEPARTMENT, CHANCERY DIVISION
COUNTY
Plaintiff,
v.
No. 08 P 8140
Tami Goldmann,
Defendant.

DEFENDANTS FIRST SET OF REQUESTS FOR DOCUMENTS

Now comes the defendant, Tami Goldmann, pro se, and pursuant to Supreme Court Rule
214, requests that Plaintiffs produce the following documents within 28 days, to her home
address at 3939 N Kostner Avenue, Chicago, Illinois, 60641.
Instructions
A.

These requests are deemed continuing. Plaintiffs are requested to provide, by way

of supplementary responses and production, such additional information and documentation as

may hereafter be obtained by the Plaintiffs, or any person on Plaintiffs behalf, that will augment,
supplement or otherwise modify the answers now given in response to the following requests.
B.

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

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;

2. type of document (e.g. letter, email, memo);

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.
D.

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.

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 requests 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 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
2

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.

"Communications" shall mean all inquiries, discussions, conversations,

negotiations, agreements, understandings, meetings, telephone conversations, letters,

correspondence, notes, telegrams, telexes, advertisements, facsimiles, e-mail, or other forms of
verbal and/or communicative intercourse.
C.

The terms identify or identity when applied to an individual means to set

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.

The terms identify or identity when applied to a business or other entity

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
3

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.

Defendant means Tami Goldmann

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.

For each document produced, identify the request to which it is responsive.

DOCUMENTS TO BE PRODUCED
1.

Produce a copy of Mr. Ziarniks death certificate.

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

of personal property and assets.

4.

Produce all documents in evidence of Mr. Ziarniks safe deposit boxes, value and

other depositories. Describe the contents and all property removed.

5.

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

payment in regard to this lawsuit.

4

7.

Produce copies of all bills Plaintiffs submitted for payment to Mr. Ziarnik

detailing the professional services performed on his behalf.

8.

Produce a copy of Mitzens employment application or contract with Devon Bank

(or Dutton, whomever hired him).

9.

Produce a copy of Mitzens formal education in geriatric care management.

10.

Produce all copies of other applicants asked to be Mr. Ziarniks care manager

along with their qualifications.

11.

Produce all copies of Mitzens receipts and a detailed list of expenditures in

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

Agency in regard to their cash expenditures.

13.

Produce a copy of Home Insteads contract with Mr. Ziarnik.

14.

Produce copies of Home Instead logbook detailing Mr. Ziarniks daily activities,

visitors, etc., in the years 2008 and through June of 2009.

15.

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
5

basement in 2009.
19.

Produce a copy of what the junkman inventoried in 2009 and placed into the vault

at Devon bank, whether or not it was sold or disposed of.

20.

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
6

basis of any of the claims asserted by you in this lawsuit.

27.

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

Defendant's Interrogatories; and

29.

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.

Johnson & Bell

33 West Monroe Street
Suite 2700
Chicago, IL 60603
Attn: Pioli & Marconi
____________________________