RFA's and interrogatory questions


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






2)  Never received Gagnon interrogatories

RFA:  Admit that you sent Gagnon interrogatories that were not answered.




3)  MISSING RX TIMESTAMPS

RFA:  Admit that this document was given to you by Dulberg

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



RFA:  Admit that this document was released to Scott Dulberg in the brown jacket file in August 2015

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

RFA:  Admit that this document was turned over to Attorney Brad Bulke





4)    MAST LEADS GAGNON AND MCGUIRE THROUGH DEPOSITIONS AND INTERROGATORIES



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


RFA:  Admit that McGuires admit to buying the chainsaw

RFA:  Admit that the McGuires testified that they paid Gagnon for the work

RFA:  Admit that the McGuires let gagnon use the new chainsaw

RFA:  Admit that the McGuires were in posession of the chainsaw manual

RFA:  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)





5)  2013-10-22 LETTER OFFERING TO SETTLE THE CASE FOR $7,500

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

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


Interrogatory:  Name each and every time you communicated with Dulberg between September 20, 2013 to October 23, 2013, and the topics that were discussed during each communication.

Interrogatory:  At a meeting between Mast and Dulberg on November 4, 2013, state the purpose of the meeting, who called the meeting and for what purpose,  who attended, each and every topic that was discussed and any documents that were exchanged.

Interrogatory:  At a meeting between Mast and Dulberg on November 20, 2013, state the purpose of the meeting, who called the meeting and for what purpose,  who attended, each and every topic that was discussed and any documents that were exchanged.





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

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

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

RFA:  Admit that you told Dulberg...

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

RFA:  Admit that you gave Dulberg...

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

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





7)  BANKRUPTCY

Interrogatory:  Explain why Mast did not notify the court at any time between #### and #####  that Dulberg declared bankruptcy.


Interrogatory:  When drafting the letter of settlement for the court in February 2015, please explain the amount Mast was seeking and the reasoning behind deciding on this amount in detail. 



9)  HIDING OCT 22 SETTLEMENT LETTER FROM DULBERG'S NEW ATTORNEY (TWICE) 



10)  HIDING GAGNON PHONE INTERVIEW AUDIO RECORDING




11)  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 ###



12)  DOCTORED SETTLEMENT LETTER