This document explains how Williams and Clinton created the pdf of 2598 discovery documents that they claim to have given to opposing counsel on May 29, 2019.


First, locate the case file they turned over around September, 2020 to Dulberg/Alphonse.


It is called "Dulberg Master File".

Note the folder sizes.  By far the 3 largest folders are: 


Dulberg Matter Ed Clinton (size = 3.27 Gb)

Dulberg Production JWC Working Folder (size 2.15 Gb)

Dulberg Documents to Be Produced 2020 June 25 (size 2.21 Gb)



Williams and Clinton followed the following 6 steps to create the May 29, 2019 document disclosure pdf:


1)  Williams creates a folder named "Dulberg Document JWC Working Folder" along side all existing folders in "Dulberg Master File".

2)  She goes through everything in "Dulberg Master File" and copies any folders that may contain potential discovery production documents into her working folder.

3)  She then creates 2 folders called "Dulberg JCW DRAFT to be Produced" and "Dulberg JCW DRAFT TAX RETURNS TO BE PRODUCED" inside her working folder.  The first folder is for everything non-IRS related and the second for everything IRS related.

4)  Inside "Dulberg JCW DRAFT to be Produced" she places a copy of every pdf file in her working folder from which she intends to extract the documents she'll put in the document disclosure.  This folder is a very well ordered list of pdfs. All pdfs are listed in alphabetical order. 

5)  From this list of pdfs she creates one large pdf called "1 Dulberg Documents to BE Produced NON TAX Complete JCW 2019 May 28".  It consists of 2580 pages.  The name of the file begins with "1" so that the file appears as the top pdf in the folder.

6)  From this pdf she filters out 121 pages and adds one page to create a new pdf called "1 Dulberg Documents to BE Produced NON TAX redacted Complete JCW 2019 May 28".  This pdf has 2460 pages.  These become the first 2460 Bates stamped documents (1-2460 bates).


...................................................................................................................



So a key question is:  Which pages were taken out during step 6 and which page was added?

The pages removed from "1 Dulberg Documents to BE Produced NON TAX Complete JCW 2019 May 28" to make the redacted version are listed:


1

1327-1333

1336

1341

1346-1347

1350-1391

1393

1399

1405

1413-1414

1426 (blank)

1451 (blank)

1524

1527

1528

1547-1548

1603 (blank)

1651 (blank)

1659

1661-1662

1664-1665

1667-1668

1671

1694

1714-1729

1752-1758

2053-2062




In addition, 16 pages containing large yellow reference numbers acting as file organizers were removed.  The 16 pages are:

2248 has a large yellow reference number "1" written on it.
2275 has "2"
2277 has "3"
2279 has "4"
2284 has "5"
2298 has "6"
2304 has "7"
2405 has "8"
2408 has "9"
2467 has "10"
2528 has "11"
2530 has "12"
2540 has "13"
2543 has "14"
2546 has "15"
2556 has "16"



There were 121 pages removed in total.  They are all listed above.

There was also 1 page added.  It is 1654.  This is just a copy of a different document which appears somewhere in the 1600s.




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Another key question is:  From the total number of documents Clinton and Williams had access to, how did they choose which to include in the final disclosure?


In this 6 stage process there are 2 different levels at which the available documents were filtered.


FILTER 1:  Deciding which pdfs to include in the folder "Dulberg JCW DRAFT to be Produced" and which to leave out.  This is done during steps 2, 3 and 4 of the 6 step process.


FILTER 2: Deciding which pages to remove from "1 Dulberg Documents to BE Produced NON TAX Complete JCW 2019 May 28" in order to create the final pdf called "1 Dulberg Documents to BE Produced NON TAX redacted Complete JCW 2019 May 28".  This is done during step 6. 



So this key question becomes:


How did Williams and Clinton choose what to reject or pass through FILTER 1?

How did Williams and Clinton choose what to reject or pass through FILTER 2?


I believe the answer shows overwhelming evidence of 'intentional tort' malpractice against Dulberg and is a true "smoking gun".  We can discuss this filtering process and I (or we) will answer these key questions in a different document that hasn't been written yet.