On or around November 27, 2018 Williams and Clinton received a thumb drive from Thomas Gooch that contained 6 main folders. 4 of the folders contained documents from 17LA377. 2 of the folders contained documents that needed to be disclosed to opposing counsel. The 2 folders are called "Dulberg UNDERLYING CASE DOCS" and "Dulberg Paul Dulberg Files From Client". When preparing documents to turn over to opposing counsel on May 30, 2019 Williams used only 1 of the 2 relevant folders on the Gooch thumb drive. Williams combined only one folder from the Gooch thumb drive called "Dulberg UNDERLYING CASE DOCS" with 18 pdf documents she received directly from Dulberg as email attachments to make the document called "Dulberg Document Disclosure FINAL 2019 May 29.pdf". Williams did not inform Dulberg that one of the main folders of documents given to her by Gooch was not included with the documents in "Dulberg Document Disclosure FINAL 2019 May 29.pdf". Williams did not inform Dulberg that not all of the pdf documents she received as email attachments were included in "Dulberg Document Disclosure FINAL 2019 May 29.pdf". Williams also did not include any emails from the folder "Dulberg UNDERLYING CASE DOCS\Paul Dulberg Emails" with the word "Baudin" or "SSDI" in the file name and did not include 58 additional email documents from this folder which were in her possession in "Dulberg Document Disclosure FINAL 2019 May 29.pdf". The 58 additional email documents which were in Williams' possession but were not included in "Dulberg Document Disclosure FINAL 2019 May 29.pdf" are Hans Mast2-14 through Hans Mast2-19, Hans Mast2-21, Hans Mast2-24, Hans Mast2-29, Hans Mast2-32 through Hans Mast2-63, Hans Mast2-65, Hans Mast2-69, Hans Mast2-73, Hans Mast2-78, Hans Mast2-149, Hans Mast2-152, Hans Mast2-153, Hans Mast2-169, Hans Mast2-170, Hans Mast2-252, Hans Mast2-254, Hans Mast2-255, Hans Mast2-257, Hans Mast2-259, Hans Mast2-260, Hans Mast2-262, Hans Mast2-282. The 58 additional email documents that were not included in "Dulberg Document Disclosure FINAL 2019 May 29.pdf" cover the following topics: The lack of an electronic case file from Hans Mast and Brad Bulke, at least 40 email documents with communication between Dulberg and Brad Bulke, Dulberg's offer to buy out the lean, communication with or mentioning Saul Ferris, and email documents mentioning bankruptcy and SSDI. By not including these 58 email documents in "Dulberg Document Disclosure FINAL 2019 May 29.pdf" these topics were basically removed from or significantly altered the contents of the email threads in the documents disclosed to opposing counsel. A certified copy of Tilschner v Spangler sent as an email attachment to Williams from Dulberg was not included in "Dulberg Document Disclosure FINAL 2019 May 29.pdf". Williams also renamed 18 documents related to 17LA377 and which were not at all relevant to the request for production of documents to which she was responding and placed them in "Dulberg Document Disclosure FINAL 2019 May 29.pdf". On May 30 2019 Williams gave the file "Dulberg Document Disclosure FINAL 2019 May 29.pdf" to opposing counsel. Williams did not file a notsdd with the court when she gave bates-stamped documents 1 to 2598 to opposing counsel. Williams misled Dulberg into believing that all relevant documents that she received from both the Gooch thumb drive and from Dulberg were contained in the file "Dulberg Document Disclosure FINAL 2019 May 29.pdf" and were given to opposing counsel on May 30, 2019 with the only exception being documents protected by attorney-client privilege. On December 17, 2019 at 11:00 AM Williams sent an email to Flynn stating "In preparation for our call today, I am resending the all discovery as I don’t think you received some of them the first time." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg case, Clinton Subpoena Responsive to court order: None) "Dulberg BK Files Bates 2599", "Bates 2620", and "Dulberg Document Disclosure FINAL 2019 May 29.pdf" and 5 other files are attached to the email. A verification statement signed by Dulberg is also attached to the email. On December 17, 2019 at 6:30 PM Williams sent an email to Flynn stating "Dear George, Per our call today: Dulberg Discovery Responses: 1. You requested the attachments to the emails that were produced with Bates Stamp Dulberg 2620-2638. We will review those bates documents and determine the location of the attachments. If they were previously produced, we will provide the bates stamp for those documents. If they have not produced them, we will either produce or let you know we do not have possession or control. 2. Brad Balky. His name appears in some of the documents. You requested that we identify when he represented Mr. Dulberg and in what capacity. If he did represent Mr. Dulberg for any period, we will produce any records related to that that are in Mr. Dulberg’s possession and control. 3. Verification. We previously produced a verification page for the discovery requests. It is our intention that the verification be attached to all discovery answers. You requested an updated verification for the request to produce that complies strictly with 214. We will provide such compliant verification." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al, Clinton Subpoena Responsive to court order: None) Williams did not file a notsdd with the court when she gave bates-stamped documents 2599 to 2638 to opposing counsel. On December 18, 2019 at 3:32 PM Flynn sent an email to Williams stating "Thanks much Julia. Let this also acknowledge the 9 separate emails you sent, which included additional document productions." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al, Clinton Subpoena Responsive to court order: None) January 9, 2020 at 12:07 PM Williams sent an email to "ale" with no message, no subject and 2 attachments which are "Dulberg BK Files Bates 2599" and "Bates 2620" (Dulberg Master File\Dulberg Emails 2020 August 19\.pdf, Clinton Subpoena Responsive to court order: None) On January 29, 2020 Williams sent an email from the email address jwilliams@williamslawchicago.com to Dulberg stating "Dear Paul, Attached are the three sets of documents that we produced to opposing counsel. First Set “Dulberg Documents Disclosure FINAL 2019 May 29” contains Bates Stamp 1-2598 Second Set “Dulberg BK Files Bates 2599” contains Bates Stamp 2599-2619. Third Set “Dulberg Bates 2620” contains Bates Stamp 2620-2638. We have already provided the discovery documents that the other side provided to us. I am not producing them again here. You will need these documents to respond to my next email." (Dulberg Master File\Dulberg Emails 2020 August 19\Discovery Documents, Clinton Subpoena Responsive to court order: None) On January 30, 2020 at 10:27 AM Dulberg sent an email to Williams stating "Morning Julia, This Morning I looked up when Brad Balke filed his appearance and I found the attached document I named Balke Appearance.pdf It was March 19, 2015. This is what was filed in the public record. This should have been in the Gooch files. Looking back, I never received the digital Gooch files that were turned over to your office. Confirmed in email dated April 18,2019. The Gooch files should have included the entire case file that Mast turned over to me and the addition of the Balke and Baudin files as well as all communication records, bankruptcy documents, disability records, etc... Gooch took 6+ months to get all those records scanned in and I never was able to confirm he actually scanned in all of them. On another note, I found this: 05-08-15_Hans Mast2-56.pdf which is also attached. You may have this as, Hans Mast2-56.pdf This was provided to you on or around 11/17/2018 when I sent you all the communications I had. I did not find this in any of the bates numbered documents. It shows that the file was sent back to Saul Ferris and that I picked it up and delivered it to the firm named Danahu and Walsh at the direction of Balke." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg case, Clinton Subpoena Responsive to court order: None) On January 30, 2020 at 3:39 PM Williams sent an email to Dulberg stating "Dear Paul, Please find attached the file that we obtained from Thomas Gooch" (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich Gooch File, Clinton Subpoena Responsive to court order: None) On January 30, 2020 at 3:45 PM Dulberg sent an email to Williams stating "Hi Julia, I have attached a screen shot of the error I get when I try to access the Gooch file. Paul" (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich Gooch File, Clinton Subpoena Responsive to court order: None) On January 30, 2020 at 3:50 PM Williams sent an email to Dulberg stating "We will send you a flash drive instead." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich Gooch File, Clinton Subpoena Responsive to court order: None) On January 30, 2020 at 3:50 PM Flynn sent an email to Williams stating "Julia: I appreciate you forwarding the affidavit. The issue with it is that it is general, is not dated, and does not identify the instrument it is referencing (nor is it attached to the referenced instrument). I would prefer that it be attached to whatever document is referencing, should it need to be marked as an exhibit at a deposition, for example. My apologies, I am not trying to create additional work here, but it could become a bit unwieldy if I had to attach a discovery response, a general undated 214 affidavit, and an email from you explaining the document that it is intended to support, all as an exhibit. Please also let me know where we stand on the email attachments that were not previously produced. The “PDF” icon which shows in the subject lines of the emails, suggests that they would have still been in Mr. Dulberg’s possession when he produced the emails." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al, Clinton Subpoena Responsive to court order: None) On January 30, 2020 at 3:59 PM Williams sent an email to Flynn stating "Attached is the RTP answer with the verification in the document. I hope this will work." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al, Clinton Subpoena Responsive to court order: None) On January 31, 2020 at 9:37 AM Flynn sent an email to Williams stating "Popovich’s RFP numbers 4 and 5 ask for documents and engagement agreements regarding all counsel for Dulberg in the underlying matter. I agree that an amended interrogatory answer would not be required, but if this leads to the production of more responsive documents, please advise." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al, Clinton Subpoena Responsive to court order: None) On January 31, 2020 at 11:21 AM Williams sent an email to Flynn stating "As to RFP 4 and 5, yes, if we have further responsive documents we will produce them in a supplement. I believe we have produced everything in the client’s possession and control as he advised that he turned everything over to us. In my last email, I was specifically referring to the interrogatories only ." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al, Clinton Subpoena Responsive to court order: None) On Jan 31, 2020 at 1:30 PM Williams sent an email to Dulberg stating "We have a duty to produce everything that is in your possession and control, thus if there are email attachments that were not produced, we should produce them if you have them." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg case, Clinton Subpoena Responsive to court order: None) On February 6, 2020 Dulberg wrote an email to Williams stating "Hi Julia, Thought I’d let you know I just received the thumb drive with the files gooch sent you. There is a lot here but I should be able to go through these by early next week and see if he missed anything. Right away I found the attached Ehrmann Gehlback badger Fax 2.16.15.pdf Which was part of the correspondence between Mast and the original Bankruptcy Trustee Megan Heeg that I spoke of in my last email to you." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg case, Clinton Subpoena Responsive to court order: None) On February 7, 2020 Dulberg sent an email to Williams stating "Hi Julia, I worked at the gooch files almost all night and I’m shocked because it is very accurate. I have to say the six months it took for gooch to get everything scanned had me worried but it is very comprehensive and appears to be very accurate. I now know with confidence that you were given everything I have ever had on this. Thank you Paul" (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg case, Clinton Subpoena Responsive to court order: None) On March 6, 2020 Flynn sent an email to Williams stating "Julia: I write pursuant to 201(k). At Mr. Dulberg’s deposition, he testified at p. 38 that he met with attorney Saul Ferris, who would not take his case over from Popovich because “your decision to settle with the McGuire’s was a mistake and we don’t [sic] take it because of that.” From lines 15-19 on the same page, Dulberg testified that Ferris said it in a letter, on the phone, and sent him an email. Dulberg’s testimony at p. 95 also establishes that the communications with Ferris were prior to Popovich’s withdrawal in March 2015. These communications go directly to the issue of the discovery date of the alleged malpractice. I do not recall seeing an email or letter similar to what has been described. Please produce these communications, and perhaps we can avoid the necessity of combing through Mr. Dulberg’s or Mr. Ferris’ records to pinpoint the date of the phone call between the two. Please also produce any previously withheld documents that go to the issue of what standards of care were breached by Popovich, and when Dulberg became aware of it. As you may recall, there were several objections on the record regarding Dulberg’s communications with Tom Gooch, on and around December 16, 2016. It is our position that all such communications regarding the breach and date of discovery, including but not limited to those above, have been placed at issue. Since we will be presenting Hans Mast for his discovery deposition on March 26, 2020, and appearing in Woodstock for a status conference on April 3, 2020, we will need to have a resolution of all privilege issues and withheld documents before April 3. Accordingly, If any document responsive to any discovery request (at this stage) is being withheld, I believe that a privilege log must be produced. With respect to the objections to the “Gooch” communications, please confirm whether you still intend to raise the objection(s). For the record, we intend to utilize Dulberg’s testimony regarding his communications with Tom Gooch, in future pleadings and discovery. If the objection is not withdrawn, then we will need to tee up the issue for Judge Meyer. I will be happy to discuss these issue, but note that I will be on vacation next week, returning to the office on March 16. Best regards, George Flynn" (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich-2, Clinton Subpoena Responsive to court order: None) On Jun 4, 2020, at 11:57 AM Flynn sent an email to Williams stating "Any thoughts on what we want to tell the Judge on Friday?" (Dulberg Master File\Dulberg Emails 2020 August 19\Dilberg, Clinton Subpoena Responsive to court order: None) On June 4, 2020 at 12:05 PM Williams sent an email to Flynn stating "For Friday: f(1) and f(2): 1. We have a firm date for Hans Mast deposition. 2. That after that deposition, Plaintiff will determine whether he wants to take Thomas Popovich’s deposition or a representative of the Popovich firm (I can only imagine that it would be Thomas Popovich). I don’t believe that there will be any other depositions from our side, but I would like f(1) and f(2)s to stay open through the summer. 3. Let me know if you think you’ll have any more folks you want to depose. Written Matters: There is some outstanding updated written discovery that you requested and needs to be addressed after Plaintiff’s deposition. It was put on the back burner due to the COVID crisis. But I will get on top of that. If there are any issues, we can address them before the next court date. Next Date: Early August? Early September? We should be ready to close f(1) and f(2) at that point." (Dulberg Master File\Dulberg Emails 2020 August 19\Dilberg, Clinton Subpoena Responsive to court order: 581) On June 4, 2020 at 12:09 PM Flynn sent an email to Williams stating "Thanks Julia. I agree on all of your points. I will make a determination after Hans’ dep about whether to take any other f 1’s. Talk to you tomorrow." (Dulberg Master File\Dulberg Emails 2020 August 19\Dilberg, Clinton Subpoena Responsive to court order: 581) On June 19 2020 Flynn sent an email to Williams stating "Julia: I just received your notice of attorney lien. Will you still be taking the dep next week? My experience with receiving liens at this stage of litigation(in a high percentage of cases) is that a withdrawal shortly follows. Hopefully not the case here, but just making sure we are still on for Mast’s dep." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg -2, Clinton Subpoena Responsive to court order: None) On June 25 2020 at 10:00 AM the deposition of Hans Mast began. On June 25 2020 at 12:31 PM Flynn sent an email to Williams stating "Just wanted to write while it is fresh in my mind, but I’d like to close the dangling issues from your client’s deposition, including the production of communications with Mr. Gooch in view of the “discovery rule” issues." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg -3, Clinton Subpoena Responsive to court order: None) On June 26 2020 at 9:40 AM Williams sent an email to Dulberg stating "Dear Paul, I am working to produce more documents to the other side as we indicated in your deposition and pursuant to our duty to continually update discovery. There appear to be some documents from the Gooch file that were not produced in discovery in the legal malpractice case and I want to make sure we have produced everything required to the other side. We are going to produce those now. Many appear to be duplicates. I am continuing to work on the total supplemental production, but for now, I need your help with some files that I have attached. 1. David Gagnon Dep with Notes. Who wrote the notes on the deposition transcript? 2. Michael McArtor Dep with Notes. Who wrote the notes on the deposition transcript? 3. Paul Dulberg Dep with Notes. Who wrote the notes on the deposition transcript? 4. William McGuire Dep with Notes. Who wrote the notes on the deposition transcript? 5. Notes 1-5. Who wrote the handwritten notes from the five files of handwritten notes attached? We appreciate your help with this." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich Documents, Dulberg Master File\Dulberg Emails 2020 August 19\-2, Clinton Subpoena Responsive to court order: None) There were 6 attachments with this email. None of them were related to Gooch emails. On June 26 2020 at 12:13 PM Williams sent an email to Flynn stating "Thank you for the follow up. I am working on the production today. Are you around on Monday—can we chat then?" (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg -3, Clinton Subpoena Responsive to court order: None) On July 2 2020 Flynn sent supplimental discovery production request On July 7, 2020 at 11:00 AM Williams sent an email with the subject "Dulberg withdrawal letter" to Ed Clinton stating "Dear Ed, Look at this letter. If you want to revise and sign—that is fine. I am also happy to sign. Let me know." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg withdrawal letter, Clinton Subpoena Responsive to court order: None) On July 9, 2020 at 11:42 AM Williams sent an email to Flynn stating "Attached are more documents. As I stated on the phone, many are duplicative of what has already been produced but some are not. Because they came from a difference source, I could not determine what had been produced previously and what had not, thus, to be safe, I am producing everything. The documents should be searchable. The documents are in four files as follows: 1. 2646-2649 2. 2650-7892 3. 7893-8551 4. 8552-8708 I may need to send them in separate emails due to the size." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al Documents-2, Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al Documents, Clinton Subpoena Responsive to court order: FILE NAME) On July 9, 2020 at 11:44 AM Williams sent an email to Dulberg stating "Dear Paul, More documents were sent to George Flynn today to ensure that Gooch’s entire file on the underlying case was sent as well as communications from your subsequent counsel in the underlying case. There are two emails. This is the first with three files attached." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al Documents, Clinton Subpoena Responsive to court order: None) On Jul 9, 2020 Williams sent an email to Flynn stating "George, Here is the final file." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al Documents-2, Clinton Subpoena Responsive to court order: 649) The email had one attachment called "Dulberg 2650-7892.pdf" On Jul 10, 2020, at 10:46 AM Williams sent an email to Flynn stating: "Dear George, I believe there may have been three, but simply because the first email took forever to send as the documents attached were so large. The first contained all four of the files. The second contained three files and the third contained one file. There are only four files total—so the emails are duplicative as originally I did not believe the first email would send. Thus, you should have these four files: 1. Dulberg Stamped 2646-2649 2. Dulberg 2650-7892 3. Dulberg 7893-8551 4. Dulberg 8552-8708. Please let me know if you did not receive all of the documents." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich et al Documents-2, Clinton Subpoena Responsive to court order: 648) The document disclosure on July 9, 2020 contained more than 6000 documents which is more than double the amount of all documents Williams disclosed to the opposing counsel before that date. It consisted of both main folders on the Gooch thumb drive including the folder which was omitted from the May 29, 2019 disclosure. It still did not contain all the documents Dulberg sent to Williams as email attachments. Williams did not file a notsdd with the court when she gave bates-stamped documents 2646 to 8708 to opposing counsel. On July 27, 2020 at 1:31 PM Williams sent an email to Ed Clinton with the subject "Dulberg withdrawal letter" stating "Ed, Here is the Dulberg letter." (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg withdrawal letter, Clinton Subpoena Responsive to court order: None) On July 27, 2020 at 2:05 PM Williams sent an email from "williamslawchicago.com" to Julia Williams @clintonlaw.net with no subject and 1 attachment. The attachment is called "Dulberg Draft Letter r...7.docx". (Dulberg Master File\Dulberg Emails 2020 August 19\-3, Dulberg Clinton Subpoena Work Product privilege000013) On July 27, 2020 at 2:24 PM Ed Clinton sent an email to Dulberg stating "Dear Paul, Please see the attached letter. Best Regards" (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg v Popovich 2017 L 377, Clinton Subpoena Responsive to court order: None) On July 30, 2020 at 10:05 AM Williams sent an email to Dulberg which contained the following answers to Dulberg's questions: In response to Dulberg's question: Did you send a demand letter? If so, did we receive a response and may I get copies the demand letter and the response? Williams replied "I sent you the email earlier today." In response to Dulberg's question: What happened with the objections raised during Dulberg's deposition when Dulberg was questioned about conversations with Dulberg's former counsel Gooch? Did you get a ruling or does that still need to be argued before judge Meyer? Williams replied "There has been no motion practice on the issue and thus, there is no ruling. Your future counsel will need to bring that before the Judge at some point." In response to Dulberg's question: Similar to the last question, Have the objections in the Mast deposition been worked out or ruled on by judge Meyer? Williams replied "There has been no motion practice on the issue and thus, there is no ruling. Your future counsel will need to bring that before the Judge at some point." In response to Dulberg's question: Did you find out who Gooch was using for an expert witness and did you contact any possible expert witnesses? If so, may I get a copy of their reports and contact information? Williams replied "To the best of our knowledge, Attorney Gooch did not obtain or contact any expert witness. We do not have any copies of reports or contact information." In response to Dulberg's question: After you withdraw from this case would you be interested in some sort of limited scope representation or unbundled legal services type of role until I find new counsel and get them up to speed? Williams replied "We are not interested in being involved further for the reasons outlined in our letter to you. We are happy to help provide any information necessary to get future counsel up to speed." (Dulberg Master File\Dulberg Emails 2020 August 19\Need clarification on outstanding issues before your departure, Dulberg Clinton Subpoena privileged communication 276) On July 30, 2020 at 10:21 AM Williams sent an email to Dulberg stating "Dear Paul, These document requests are due today. We have obtained a 28 day extension so the responses are now due August 27, 2020. We anticipate filing our motion to withdraw. Thus, you will need your new counsel to respond or prepare your own response. Best Regards" (Dulberg Master File\Dulberg Emails 2020 August 19\Dulberg case, Clinton Subpoena Responsive to court order: FILE NAME)