A REPORT (ROUGH OUTLINE) FROM PAUL DULBERG (FROM MEMORY) OF EVENTS THAT TOOK PLACE WHEN PREPARING THE SUPREME OURT PETITION. (Report was prepared on 2023-01-13 at around 9:00AM. More will be added in updated versions.)


PAUL DULBERG WROTE:

Below is a quick outline of what transpired - from memory since we already have a detailed outline - It will take considerable time for me to go over the timeline and match up my memory with the exact dates and times.

A day or two before the petition was due I found out by phone that Mr Talarico hadn’t done any work authoring the petition.
Said all the time in the past 35 days was spent on the Tiff and the other cases.
I said we need to get this done.
We agreed he would author the document and I should do the formatting.
I told him I would need something to look at to build a template for the petition.
He did not have anything for me to see.
I went online and downloaded a petition that I found and asked if that would work as a template.
He said it should.
Over the next couple hours I created an INDD file using the form I found as a template, even threw in section headers and some wording as placeholders till he provided the copy.
I sent him it as a PDF and called him back and said I am ready to drop in the text that he was authoring. He said he had to do some research with Thompson Reuters west law.
He did provide a few things that I dropped in the template and said he was working another section and asked if I would have Tom do the history section.
I said I would call Tom and see. Tom agreed to help. I told Talarico that tom would help but needed an idea of what all it encompassed.

Mr Talarico provided what he called a preface and I dropped in the template.

------Etc… ( I would need more time to go over the emails to build exactly how we came to the next partI

When I inquired about how to do the appendix with so many documents referenced I was told by Talarico that we could use hyperlinks to the documents. Tom, you spent a whole day and stayed up all night in a marathon creating those hyperlinks.

Talarico filed the petition as is because time was up.

When I noticed the petition filed had the hyperlinks removed or disabled I contacted Talarico.

Talarico said he would contact the clerk.

The petition was rejected.

Talarico said that hyperlinks were not allowed and that all the documents had to be attached in the appendix.

A discussion was had over what the appendix had to look like and how the documents were to be differentiated. Ex, like exhibit tags at the start of each document? Talarico said he didn’t know

I attempted to amend the petition turning all the hyperlinked documents in an appendix without any clear idea of what it was to look like. I built in bookmarks in the PDF that acted as the identifier and as the separator - the sheer amount of pages took days

Talarico said he loved the bookmarks and said I should have an identifier on the first page of each document like an exhibit tag identifies each document.

I added A1, A2, etc in Large red font to the first page of each document.

Talarico said he was in communication with the clerk and they won’t accept all those documents in the appendix and that they were not needed.

At this point I had been trying my best to follow Talarico's instruction and everything to date was done wrong and he blamed me for not following his instructions and things just got weird from this point forward.