IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, PROBATE DIVISION

In the Estate of Joseph Ziarnik,
Plaintiff,
v.

No. 08 P 8140

Tami Goldmann,
Defendant.

DEFENDANT RESPONSE TO JANNA DUTTON, JOSH MITZEN AND DEVON

BANKS FIRST SET OF DOCUMENTS
NOW COMES Defendant, Tami Goldmann, pro se, responds as follows:
GENERAL ANSWERS AND OBJECTIONS
Defendant poses the following general objections to plaintiffs document request
and incorporates each of these objections by reference to every answer provided hereafter:
1. The documents requested are in the plaintiffs possession.
2. The documents 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.
3. The defendant objects to any document 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.
4. The defendant objects to these documents 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.

5. The defendant objects to any document request 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.
6. The defendant objects any document request to the extent that it does not seek
information that leads to the discovery of admissible evidence.
7. The defendant objects to any document request 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.
8. 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 Documents. 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.
9. The defendant objects to any document request that seeks information that is

already in the plaintiffs possession.

10. The defendant objects to any and all documents that are beyond the one-year
statute of limitations but doesnt mind being helpful in refreshing the Plaintiffs
recollections.
SPECIFIC OBJECTIONS AND ANSWERS
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.
ANSWER: See Defendants Motion to Dismiss Exhibit A, B, C, D, E, F, G, H, I, J, K,
L, M, Complaints exhibits and attached statement of Mr. Ziarniks trust account.
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.
ANSWER: See Defendants Motion to Dismiss Exhibit B, F for supporting
statements made and Mr. Ziarniks trust account.
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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements
made.
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.
ANSWER: A copy of Mr. Ziarniks trust account proving Mitzen was being paid

although, he was fired. I did a diligent search for Home Insteads logbook I
Xeroxed and cant find it. The plaintiffs have copies.
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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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.
ANSWER: See Defendants Motion to Dismiss Ex. C for supporting statements.
7. 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
Bequeathing Everything to Richard Loundy as set forth in 24 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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 25 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
9. 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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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.
ANSWER: See Defendants Motion to Dismiss Exhibit G for supporting statements.
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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
13. 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
Confirmation it's a Devon Bank Scam as set forth in 30 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
14. 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
Competency Hearing as set forth in 31 of the Complaint
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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 32 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit C for supporting statements.

16. 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 Lineas set forth in 33 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
17. 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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements
and attached Tribune Article.
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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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 37 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
21. 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.

ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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 39 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
23. 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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
25. All documents that support, refer, or relate to 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.

ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
26. 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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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-susanphelan) on the page entitled Janna Dutton and Susan Phelan as set forth in 44 of the
Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements,
entire Complaint and Complaint Exhibit B.
28. All documents that support, refer, or relate to your statements made on your
blog page (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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
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-in10-Years.html) on the page entitled How to Blow 10 Million Dollars in 10 Years as set
forth in 46 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
30. All documents that support, refer, or relate to your statements made on your
blog page (http://josephludwigziarnik.blogspot.com/2011/03/elder-protectie-servicesscam-run-bycatholic-charities.html) on the page entitled "Elder Protective Services
Scam? Run by Catholic Charities as set forth in 47 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
31. All documents that support, refer, or relate to your statements made on your
blog page (http://josephludwigziamik.blogspot.com/2011/02/cook-county-pubic-privateguardians.html) on the page entitled Cook County Public & Private Guardians as set
forth in 48 of the Complaint

ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.

No document in regard to the sexual comment he made toward me.
32. 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.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
33. All documents that support, refer, or relate to your statements made on your
blog page (http://josephludwigziarnik.blogspot.com/2010/l1/devon-bank-trustdepartment.html) on the page entitled Devon Bank Trust Department as set forth in 50
of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
34. All documents that support, refer, or relate to your statements made on your
blog page (http://josephludwigziarnik.blogspot.com/2010/10/devon-bank-twelve-seniorresidences.html) on the page entitled Devon Bank - Twelve Senior residence Facilities as
set forth in 51 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
35. All documents that support, refer, or relate to your statements made on your
blog page (http://josephludwigzianik.blogspot.com/2011/12/devon-bank-trustdepartment-putting.html) on the page entitled Devon Bank Trust Department - Putting
Them Out of Business as set forth in 52 of the Complaint.
ANSWER: See Defendants Motion to Dismiss Exhibit F for supporting statements.
36. All documents that constitute, refer, or relate to any exhibit(s) that you plan to
use at any trial of this matter.

ANSWER: See Defendants Motion to Dismiss Exhibits A, B, C, D, E, F, G, H, I, J,

K, L, M, Complaints exhibits and Mr. Ziarniks trust account. All documents
requested by me from the plaintiffs.

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

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.

_______________________