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.

DEFENDANT RESPONSE TO JANNA DUTTON, JOSH MITZEN AND DEVON

BANKS FIRST SET OF INTERROGATORIES

NOW COMES Defendant, Tami Goldmann, pro se, responds as follows:

GENERAL ANSWERS AND OBJECTIONS
Defendant poses the following general objections to plaintiffs interrogatories and
incorporates each of these objections by reference to every answer provided hereafter:
1. The interrogatories request information going back six to seven years and the answers
given are based on the present facts known or believed by defendant at the time of its answer.
2. The defendant objects to any interrogatory that seeks information constituting or
containing information concerning communications between the defendant and anyone who
contacted her AFTER publication of her blog and website, spoken to her anonymously or with
local, state and federal government.
3. The defendant objects to these interrogatories to the extent that they are overly broad,
unduly burdensome, vague, ambiguous, confusing, require speculation to determine their
meaning (as presented by the plaintiffs) or use imprecise specifications of the information
sought.

4. The defendant objects to any interrogatory the interferes with her First Amendment
Right of Free Speech, her personal experience and opinions which make up the entirety of her
blog and website.
5. The defendant objects any interrogatory to the extent that it does not seek information
that leads to the discovery of admissible evidence.
6. The defendant objects to any interrogatory as unduly and unnecessarily burdensome to
the extent that it seeks information that is matter of public record, already in the plaintiffs
possession, can be read online or otherwise readily available to the plaintiffs, and, therefore,
may be accessed and obtained by the plaintiffs with less burden than the defendant can identify
and provide requested information.
7. None of the objections or responses contained herein is an admission concerning the
existence of any documents or materials, the relevance or admissibility of any documents,
materials or information, or the truth or accuracy of any statement or characterization contained
in Plaintiffs First Set of Interrogatories. The defendants written responses are made without
waiving, but, on the contrary, expressly reserving: (a) the right to object, on the grounds of
competency, privilege, relevancy, materiality or any other proper grounds, to the use of the
information provided herein, in whole or in part, in any subsequent proceeding in this action or
any other action; (b) the right to object on any and all grounds, at any time, to other discovery
requests involving or relating to the subject matter of these requests; and (c) the right at any time
to revise, correct, add or clarify any of the responses provided herein.
8. The defendant objects to any and most interrogatories that are beyond the one-year
statute of limitations but doesnt mind being helpful in refreshing the Plaintiffs recollections.
SPECIFIC OBJECTIONS AND ANSWERS
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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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
In June 2008, I wrote Dutton a letter stating Block was bragging about spending
Mr. Ziarniks half a million dollars. This was 7 years ago, I moved twice and no longer
have that computer. To the best of my knowledge, I also told Dutton (in that same letter)
Devon Bank absolutely refused to give Mr. Ziarnik money to buy diapers, food and other
necessities. Laurie Sherry from Elder Protective Services ordered Devon Bank to cut a
check in the amount of $200 and I have a copy of Mr. Ziarniks trust account proving this.
Sally Griffin came to the house a few days later apologizing, said she spoke to Dutton and
was issuing an ATM card. Dutton has this letter and Ms. Sherry is a witness.
In September 2008, Dutton went to meet with Mr. Ziarnik at his adult daycare with
court documents naming her colleague, Mitzen as guardian. Dutton explained to Mr.
Ziarnik that Im a gold digger and forced him to sign the paper, she wouldnt take no for
an answer. Melba Ristow, the director of the Japanese American Service Committee
(JASC) was in this meeting and is a witness.
See also Defendants Motion to Dismiss Exhibit B and F and Complaint Document
#1, Group Exhibit C for more details.
2. Please specifically state and describe all facts, documents, and bases supporting
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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, 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Laurie Sherry from Elder Protective Services is a witness. I called and reported
Devon Bank, Janna Dutton, Josh Mitzen and Home Instead Caregiving Agency abusive.
Ms. Sherry intervened many times between the dates of 2008-09 and was Mr. Ziarniks
only advocate. I dont have copies of my phone records from seven years ago but Elder
Protective Services has records of all clients. I also sent Laurie Sherry a very detailed
description of the abuse in March of 2009 that I no longer have a copy of. She may have it
in Mr. Ziarniks file. Also see Def. Motion to Dismiss Exhibit F. The eighteen other victims
that had the misfortune of coming into contact with Devon Bank, they are also witnesses to
this type of financial exploitation.
3. Please specifically state and describe all facts, documents, and bases supporting
your statements made your on personal website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled A Story of Elder Abuse
asset 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Devon Bank hired an organization in either 2008 or 2009 to clean out Mr. Ziarniks
4

apartment removing all his personal possessions. Devon Bank should have all documents.
If not, Mr. Ziarnik was robbed because he was under their jurisdiction and the contents
removed from his apartment. In September of 2009, Lucy Atkins and Michael Douglas
witnessed a junkman taking all the contents from Mr. Ziarniks basement. I sat on George
Webers porch but missed a good portion of the estate being looted and ransacked. See
Complaint Document #3, Group Exhibit C for further information in regard to this
particular snippet.
4. Please specifically state and describe all facts, documents, and bases supporting
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, 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
In 2007, I contacted Elder Protective Services to protect Mr. Ziarnik from people
who were financially exploiting him. Laurie Sherry escorted me and Mr. Ziarnik to
Duttons office so he could write a will. We sat in the lobby. Both Elder Protective
Services and I did everything we could to try and protect Mr. Ziarnik from being
financially exploited by people who only wanted to utilize him as an ATM machine. We
didnt fail him, Janna Dutton did.
Mitzen was also fired by Mr. Ziarnik and they were told he no longer wanted him to
come and he didnt but still got paid. I have the document showing payment from Mr.
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Ziarniks account. I also have the cranberry juice bottle Mitzen fed Mr. Ziarnik and the
two cookies Home Instead dropped off and both cookies have the agencies logo on it. I
wrote Phelan (owner of Home Instead) an email reminding her of Mr. Ziarniks diabetes a
few days prior to the second cookie being dropped off. I no longer have this email nor can
I find the Xeroxed copies of Home Insteads logbook proving it but Im still tearing my
house upside down searching for these records. Phelan, the owner of Home Instead is a
witness and should have a copy of the email as well as the logbook where its written she
dropped a treat off to a diabetic immediately after I explained she was making him sick.
See Complaint Document #4, Group Exhibit C for all pertinent dates,
documentation and evidence. Also, see Defendants Motion to Dismiss Exhibit F. Eighteen
other victims that are also witnesses to this type of financial exploitation.
5. Please specifically state and describe all facts, documents, and bases supporting
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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
At the end of March or beginning of April 2009, I wrote Dutton a very detailed
description of the abuse her client was suffering at the hands of her colleagues. I cant find
the letter and no longer have that computer. I expected Dutton to do something to protect
her client but, instead, she gave me an eviction notice. She went to Mr. Ziarniks daycare
6

explaining to him that she was kicking me out. An employee from Devon Bank handed me
the notice without Duttons signature then she called later that same day. She stated she
was authorized by Devon Bank to make a payment of $500 if I moved by Friday. I called it
a bribe because no reasonable person could move out in five days and the apartment sat
empty for more than a year after I moved. I also called it crooked because how many
times did Devon Bank authorize those kinds of payments on behalf of their client and to
whom? Dutton is a witness, she has this letter and to the best of my knowledge, whats
written online was also written in that letter six years ago. An employee of Devon Bank
along with the staff at Japanese American Service Committee are witnesses. See Def
Motion to Dismiss Ex. C and Complaint Document #5, Group Exhibit C for a detailed
description, dates and further information on these snippets.
6. Please specifically state and describe all facts, documents, and bases supporting
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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
See Motion to Dismiss Exhibit F. Report of Devon Banks Guardianships. There
are Eighteen other examples of this type of financial exploitation and I have copies of all
the files on these victims. They are also witnesses. See also Complaint Document #6,
Group Exhibit C for even more facts.
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7. Please specifically state and describe all facts, documents, and bases supporting
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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
See Motion to Dismiss Exhibit F. Report of Devon Banks Guardianships. There
are Eighteen other examples of this type of financial exploitation and I have copies of all
the files of these victims and theyre witnesses to this type of abuse. See also Complaint
Document #7, Group Exhibit C.
8. Please specifically state and describe all facts, documents, and bases supporting
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
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
I called Laurie Sherry numerous times, she intervened and forced Mitzen to take
better care of his client. Again, she is a witness. Also, a nurse from Mr. Ziarniks adult
daycare contacted me (in 2009) alarmed because he was horribly constipated and they
needed to remove his stool manually. Although, I dont recall her name, JASC (Japanese
8

American Service Committee) is a witness and keeps impeccable records. I also called Mr.
Ziarniks home nurse to approve the stool softening medication ordered by his doctor (that
I purchased with my own money) and asked him to come over to put them into his
medication container. I think his name was Scott but the nursing agency has detailed
records, he is a witness. JASC also ordered a diabetic testing meter for Mr. Ziarnik
because his blood sugar levels were dangerously high and the caregivers from Home
Instead sent him to daycare in filthy clothes with a soiled diaper. The nurses have all
documentation in regard to Mr. Ziarniks blood sugar levels and how well he was doing
before and after Mitzen got involved in his care. See Motion to Dismiss Exhibit F. Report
of Devon Banks Guardianships and eighteen other examples of this type of financial
exploitation through the use of court.
9. Please specifically state and describe all facts, documents, and bases supporting
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, 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
The statement, She did nothing to protect her client from being financially
exploited, abused and neglected. The Plaintiffs attorney (Mr. Pioli) keeps asking me to
remove my website. I told him that I dont want it either. It was just set up to prove
Dutton would utilize it to sue me for defamation in order to profit. I wanted to prove shes
not an advocate and Ive accomplished my objective. I told Mr. Pioli Id take it down if I
9

got a letter asking but not anymore since Mr. Ziarnik is dead. She has no right to ask for
anything on his behalf. I made a commitment to Judge Atkins that I would work this out,
telling him that Id remove the alleged defamatory snippets IF I got a letter asking. See
Complaint Document #9, Group Exhibit C and the entire website and blog for further
information about the lack of protection in regard to Mr. Ziarnik including, and not
limited to, this very lawsuit. Hes being exploited for financial gain and Dutton is not his
advocate. Mr. Ziarnik is not even mentioned in these interrogatories.
10. Please specifically state and describe all facts, documents, and bases supporting
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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
See Def. Motion to Dismiss Exhibit G. All pertinent dates on that copy and
Complaint Document #10, Group Exhibit C. Sally Griffin resigned.
11. Please specifically state and describe all facts, documents, and bases supporting
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, 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.
10

ANSWER: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
I couldnt make that statement up. Block bragged about having free reign over Mr.
Ziarniks money many, many times. The first time he came to the house he said it to Sally
Griffin right in from of me. In June 2008 (I dont recall the exact date but Sally Griffin
mentioned it was her wedding anniversary), Block came over with contractors and people
who were going to manage the building. He bragged several times and shouted that
statement in front of Mr. Ziarniks tenant (Melinda Sepulveda) while we were looking at
her apartment. He said it again in Mr. Ziarniks apartment, then again in front of Sally
Griffin on the back porch. The defendant doesnt recall whether or not he said it again
after she showed him the garage but he couldnt stop talking about all the people he could
hire. His job as trustee is to preserve the estate not boast about spending it. Once again, I
wrote Dutton a letter in June of 2008. She didnt do anything about Blocks lack of selfcontrol and this lawsuit is further proof Devon Bank is not doing their jobs of preserving
the estate. Also see Def. Motion to Dismiss Ex. F and the full paragraph in the Complaint
Document #11, Group Exhibit C.
12. Please specifically state and describe all facts, documents, and bases supporting
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: Subject to and without waiving the General Answers and Objections set forth
11

above, the Responding Defendant answers this interrogatory as follows:

See Def. Motion to Dismiss Ex. F. Nineteen Cases of abuse, theyre witnesses and
Complaint Document #12, Group Exhibit C for a full description of this particular snippet.
13. Please specifically state and describe all facts, documents, and bases supporting
your statements made on your personal website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Competency Hearing as
set forth in 31 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Laurie Sherry, Sally Griffin, Lucy Atkins, Michael Douglas and the entire staff at
Japanese American Service Committee are witnesses to this financial abuse along with Mr.
Ziarniks friends and family members. The caregivers from Home Instead are also
witnesses. Some of them were very nice, they didnt like what was happening and I dont
recall all their names. In the report I wrote, theyre witnesses to this type of financial
abuse also. See Complaint Document #13, Group Exhibit C for further details.
14. Please specifically state and describe all facts, documents, and bases supporting
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 32 of the Complaint, including but not limited to the
documents and things referring or relating thereto, and the identity of the persons with
knowledge thereof.
ANSWER: Subject to and without waiving the General Answers and Objections set forth
12

above, the Responding Defendant answers this interrogatory as follows:

See question 1 above, the witnesses the same and Defendants Motion to Dismiss Ex.
C. See more details in their Complaint Document #14, Group Exhibit C.
15. Please specifically state and describe all facts, documents, and bases supporting
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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Mr. Ziarnik was complaining to everyone about how they were exploiting him. His
entire daycare knew of the abuse. Japanese American Service Committee staff are all
witnesses. See also Complaint Document #15, Group Exhibit C and the defendants website
and blog for full details of the abuse.
16. Please specifically state and describe all facts, documents, and bases supporting
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, 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
This interpretation is incorrect. Sally [Griffin] did warn us that the three of them
13

[Devon Bank employees Sally Griffin, Josh Mitzen and Janna Dutton. Unless Dutton is
suggesting shes also an employee of Devon Bank and not Mr. Ziarniks advocate] were
going to steal Ludwig's estate but I honestly didn't think they would result to criminal
behavior.
I truly believed the Plaintiffs hid Mr. Ziarniks will for an entire year to become
sole heirs and Im now living in that reality. Sally Griffin did warn me that everyone was
really good friends and I didnt understand what she meant until they surrounded Mr.
Ziarnik and spoke of lavishing his money on themselves, hiring their friends, riding around
in taxis and so on. See Exhibit F, this is what Sally Griffin is referring to about how
friendly they all are. Devon Banks Guardianships and this defamation suit 08 P 8140.
Laurie Sherry from Elder Protective Services is a witness. She ordered the documents be
given to Mr. Ziarnik. See also Complaint Document #16, Group Exhibit C for the exact
interpretation of this snippet.
17. Please specifically state and describe all facts, documents, and bases supporting
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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
From a Chicago Tribune article dated April 19, 2004; Most care managers have
master's degrees in social work, nursing, counseling or gerontology, or, in Mitzen's case,
law. Most also usually have some care management background, though there are no
14

licensing/regulatory requirements, experts say. It costs about $3,000 to start a care

management operation, including renting office space, joining professional organizations
and printing brochures. See Complaint Document #17, Group Exhibit C and Motion to
Dismiss Exhibit F and Mitzens ten other victims are witnesses.
18. Please specifically state and describe all facts, documents, and bases supporting 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, 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
The interpretation of this snippet is incorrect. The heading is Bank Trustees from
Devon Bank not Elder Protective Services: In walk Sally and Rick from Devon Bank.
Yes, they're [Devon Bank] hiring him for my position. Just setting Josh up in order to
slander me, gain control of Ludwig's estate then divvy it up amongst their friends. See
Complaint Document #18, Group Exhibit C. Elder Protective Services and I did our best
trying to protect Mr. Ziarnik from these types of financial predators.
19. Please specifically state and describe all facts, documents, and bases supporting
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 37 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: Subject to and without waiving the General Answers and Objections set forth
15

above, the Responding Defendant answers this interrogatory as follows:

I contacted Laurie Sherry in order to get a copy of Mr. Ziarniks trust account. She
is a witness. The snippet is also incorrect. At the time, I didn't know they [Devon Bank]
were just setting up these people [Sally Griffin Wendy Katten and Josh Mitzen] in order to
steal Ludwig's estate and truly have "free reign over the old man's half a million" with no
witnesses. See Complaint Document #19, Group Exhibit C for a correct interpretation.
20. Please specifically state and describe all facts, documents, and bases supporting
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, 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Without waiving objection, see Def. Motion Exhibit F. In particular, Heinz Lehner.
Sally Griffin also resigned. See Complaint Document #20, Group Exhibit C.
21. Please specifically state and describe all facts, documents, and bases supporting
your statements made on your personal website
(http://sites.google.com/site/josephludwigziarnik/) on the page entitled Writing Janna Dutton as
set forth in 39 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
16

Janna Dutton is financially exploiting her own client right now. All the plaintiffs
had to do is ask and the blog and website will be removed but they cant profit without it. See
Complaint Document, #21, Group Exhibit C for further details in regard to Duttons
character, her entire Complaint and Defendants Motion to Dismiss.
22. Please specifically state and describe all facts, documents, and bases supporting
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, 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Sally Griffin is a witness. Victor Pioli is my witness. He spoke of being good friends
with Dutton, how they give each other business and although, he doesnt look at this case as
financial exploitation, he doesnt mind it since hes being paid. See also Complaint
Document #22, Group Exhibit C for more details.
23. Please specifically state and describe all facts, documents, and bases supporting
your statements made on your personal website (http://josephludwigziarnik.blogspot.com) as set
forth in 41 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
See Def. Motion to Dismiss Exhibit F, Complaint Document #23, Group Exhibit C
and Case number 08 P 8140 for full details in regard to this snippet. The victims in my
17

report are witnesses to this type of financial abuse by professionals.

24. Please specifically state and describe all facts, documents, and bases supporting
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 42 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Public record and see Complaint Document #24, Group Exhibit C for further
information.
25. Please specifically state and describe all facts, documents, and bases supporting
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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Ms. Dutton gives law firms a lot of business so, they vote for her. She just secured
herself more votes with this lawsuit. This snippet, If you hire Janna Dutton, she's got a lot
of hidden fees. Mr. Pioli is a witness since hes another hidden fee that an elder wouldnt
expect when hiring her to set up their end of life matters. See Complaint Document #25,
Group Exhibit C.
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26. Please specifically state and describe all facts, documents, and bases supporting
your statements made on your blog page
(http://josephludwigziamik.blogspot.com/20ll/06/sally-griffin-lookout.html) on the page
entitled Sally Griffin Lookout as set forth in 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
An elder law attorney explained to one of my victims (in the report I wrote) that
Sally Griffin owed her a favor. Im not revealing my sources. See Complaint Document
#27, Group Exhibit C for more information in regard to this buddy system Devon Bank has
with elder law attorneys.
27. Please specifically state and describe all facts, documents, and bases supporting
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 46 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Block can verify investments and see Def. Motion to Dis. Exhibit F and Complaint
Document #28, Group Exhibit C. Nineteen victims families are witnesses.
28. Please specifically state and describe all facts, documents, and bases supporting
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your statements made on your blog page

(http://josephludwigziarnik.blogspot.com/2011/03/elder-protectie-services-scam-run-bycatholiccharities.html) on the page entitled "Elder Protective Services Scam? Run by Catholic
Charities as set forth in 47 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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
This has been removed. See Def. Motion to Dismiss Ex. F and full details in
Complaint Document #29, Group Exhibit C. Laurie Sherry from Elder Protective Services
is a witness. She did her best in trying to preserve Mr. Ziarniks estate and protect him
from this type of financial exploitation.
29. Please specifically state and describe all facts, documents, and bases supporting
your statements made on your blog page
(http://josephludwigziarnik.blogspot.com/2010/12/probate-sharks.html) on the page entitled
Probate Sharks as set forth in 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.
ANSWER: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
Dutton would not give Mr. Ziarnik a copy of his will. She behaved as if it were hers
to inherit and it is. She set up Mr. Ziarniks estate for her own benefit then implemented
this lawsuit while he was on his deathbed. His main caregiver is a witness to the fact he
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was on his deathbed when this lawsuit was filed, I dont know her name. None of these
interrogatories are about him either, theyre merely utilizing his name to profit. There is a
reference to Probatesharks that its a felony not to give someone a copy of their will. See
also Complaint Document #31, Group Exhibit C for full details into this type of abuse.
30. Please specifically state and describe all facts, documents, and bases supporting
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: Subject to and without waiving the General Answers and Objections set forth
above, the Responding Defendant answers this interrogatory as follows:
See Motion to Dismiss Exhibit F and Complaint Document #33 Group Exhibit C. for
further details. The entire staff at Japanese American Service Committee are witnesses as
well as some caregivers from Home Instead Caregiving agency. The plaintiffs werent
discrete in their abuse or neglect.

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VERIFICATION
I have read the foregoing Responses, which are based on a diligent and reasonable effort
by me to obtain information currently available. I reserve the right to make changes in or
additions to any of these answers if it appears at any time that errors or omissions have been
made or if more accurate or complete information becomes available. Subject to these
limitations, these Responses are true to the best of my present knowledge, information, and
belief.
Subscribed and sworn to under the pains and penalties of perjury this 28 day of May,
2015.
________________________________
Tami Goldmann

Tami Goldmann
Pro Se
3939 N Kostner Ave Chicago, Illinois 60641
Telephone: (773) 416-2965
#99500

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CERTIFICATE OF SERVICE
I hereby certify that a true copy of the above document was served upon all counsel of
record by first-class mail on May 28, 2015.

_______________________

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