RFA's


1)  222b AFFIDAVIT LIMITING RECOVERY TO $50,000



2)  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 2015

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

Admit that this document was turned over to Attorney Brad Bulke




3)    MAST LEADS GAGNON AND MCGUIRE THROUGH DEPOSITIONS AND INTERROGATORIES

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 
deposition page 13

led by mast around timestamp
helped by mast around dulbergs claim of making money

Gagnon exhibit 2 recorded phone conversation

Carolyn McGuire Deposition

page 44, 45, 52, 53, 54, 56, 57, 58, 60, 61, 66, 67, 73, 74, 86, 89, 90, 91, 92, 93, 94, 95, 101, 102

Timestamp perjury
enter house without blood perjury
pull tiller off trailer perjury
inside house the whole time perjury

Mast allows defense witnesses to place defamatory statements in the record about Dulberg with no challenge




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


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)




4)  2013-10-22 LETTER OFFERING TO SETTLE THE CASE FOR $7,500

Admit or deny you sent an offer of $7500 to McGuires attorney Barch on October 22, 2013

Admit or deny that you did not have Dulberg's permission to send the offer



5)  MAST PRESSURING DULBERG TO ACCEPT $5,000 'MED PAY' OFFER

Admit that (all email communication in Nov, Dec 2013) is authentic

(Nov 4th meeting with Paul, Barbara and Mast)

Admit that you told Dulberg...

(Nov 20th meeting with Paul, Tom and Mast)

Admit that you gave Dulberg...

Admit that you told Dulberg he cannot recover from McGuires because restatement of torts 217 doesn't apply in Illinois  

Admit that you told Dulberg he can still recover all even if he drops the McGuire case




6)  FORGED SAUL FERRIS LETTER




Admit that the Law Office of Thomas J. Popovich gave Attorney Brad Bulke the Mixed Brown Box Case File on or about ####

Admit that the Law Office of Thomas J Popovich received a package sent from Attorney Saul Ferris on or about ####

Admit that the Law Office of Thomas J. Popovich sent a package to Attorney Saul Ferris on or about ###