RFA's

Major pillars

222b affidavit limiting recovery to $50,000



Missing RX timestamps
Admit that this document was given to you by Dulberg

Admit that this document was sent by you to McGuires attorney Barch

Admit that this document was Released to Scott Dulberg in the brown jacket file in august of 2015

Admit that this document was turned over in your document disclosure in the instant case


Gagnon Interrogatories - all documents (POP 000268, POP 000505, POP 001298, POP 002094, POP 004476, POP 004481)
Admit that you sent Gagnon interrogatories that were not answered.

Mast Leading witness Gagnon - Admit that you 
*add quotes from gagnon deposition.
Hospital to Mcguire home without stopping at pharmacy
Gagnon exhibit 2 recorded phone conversation

Admit that Gagnon stated he was paid by the hour by the McGuires

Mast Leading witness Caroline McGuire
*add Quotes from deposition
Admit that McGuires admit to buying the chainsaw
Admit that the McGuires testified that they paid Gagnon for the work
Admit that the McGuires let gagnon use the new chainsaw
Admit that the McGuires were in posession of the chainsaw manual

Admit that McGuires purchased the chainsaw
2011-05-22 Bill and Caroline McGuire purchase a chainsaw
(POP 000467)
(Dulberg 001725)
- Stamped Exhibit No. 3 3/20/13)




2013-10-22 Letter Mast-Barch $7500
Adit or deny you sent an offer of $7500 to McGuires attorney Barch on October 22, 2013


Mixed Brown Box Case File