Popovich Document Disclosures (pop) - Flynn submitted to Clinton - table of contents 3 memo of Nov 20, 2013 meeting with tom and paul 48 list of doctor depositions 56 email: Let's begin lawsuit - should I have surgury? 83 bankruptcy atty to Mast: interested in retaining Mast, claims authority to settle the case 125 mention of 100,000 in Gagnon coverage (feb, 23, 2015) 143 notice to paul of a pre-trial settlement conference on april 9, 2015. dated feb 16, 2015 175 Mast cover letter for sending Gagnon's deposition to Dulberg (Dec 10, 2013) 176 Mast cover letter for sending dulberg's deposition to dulberg (Dec 2, 2013) 177 email about possible neighbor witness (Nov 20, 2013) 181 5,000 offer made Nov 18, 2013 184 Mast offers to settle with Gagnon through Perry 192 7,500 OFFER BY MAST TO BARCH MADE OCT 22, 2013 195 Mast email to Dulberg. Mast's thoughts on the case expressing doubt (October 30, 2013) 212 Mast letter with Sagerman, Levin, Talerico deposition dates (Oct 1 to 16, 2013) 268 Letter from Mast to Perry saying he has yet to respond to interrogatory or production request on October 30, 2012. Perry has yet to reply. Letter dated Feb 7, 2013. 288 Bill McGuire's answers to interrogatory from Gagnon - disclosure of policy and limits 297 certificate of service for McGuire deposition by Gagnon. Note certificate states document was also served on Perry and Mast with date served. 346 from Mast to hospital - answering request for insurance info of "adverse homeowner" 358 Dulberg nervous about surgury being covered. Mast answers about many policies have only 100,000 limit (May, 18, 2012) 361 Dulberg got home owner policy number from Gagnon (May 15, 2012) 365 Mast advises Dulberg to file suit (May 16, 2012) 367 Paul email describing Gagnon getting letter from Mast 371 letter to Gagnon from Mast requesting insurance info (April 11, 2012) 379 McGuire's first claim acknowledgement sent to Mast 384 first letter from Mast to McGuire insurance company 400 recorded Gagnon statement to Mast 560 Barch interrogatories to Gagnon (no insurance info requested) 569 Barch request to produce to Gagnon (nothing about insurance) 594 Gagnon deposition receipt - $770 (ordered 12-9-2013) 593 Dulberg deposition receipt - $453 (ordered 11-21-2013) 639 Receipt for McArtor and Carolyn and Bill McGuire depositions (popovich paid) 668 Mast to McGuire's insurance agent informing him of claim (Dec 7, 2011) 670 Mast notice of acceptance to Barch (Dec 26, 2013) 803 email from paul requesting Mast electronic case file. Claims Balke says he turned over everything he got from Mast. dated July 20, 2015. 804 Scott dulberg note: Picked up case file materials 8-17-15 876 Mast to bankruptcy atty - recovery expectation 879 bankruptcy atty first contact with Mast (Jan 6, 2015) 884 Mast memo - first evidence of paul agreeing to settlement (Dec 18, 2013) 885 Memo to Mast: Overview of Talerco deposition from a guy named "bob". It seems mast himself doesn't read the testimony. He just gets "cliff's notes" from bob. 886 "bob" about segerman 887 memo from Hans on Dr Ford's depo dated November 20, 2013 888 "bob" on Kajawa 909 "bob" on segerman 952 Mast memo. Met with Paul and Barb to answer interrogatories. July 24, 2012 955 Mast memo. Met with Barb and Paul. Discussed medical treatment and work history. June 5, 2012 961 Mast new client memo - note by popovich about McGuires being liable for medical bills 964 Mast memo of first meeting with Paul and Barb. Dec 1, 2011 972 Motion to withdraw filed March 13, 2015 988 order of dismissal of McGuires dated Jan 22, 2014 996 McGuire motion to file cross-claim for contribution (against Gagnon) 999 cross-claim complaint 1014 McGuire's affirmative defense - Dulberg guilty of contributory negligence 1179 Perry files appearance on Sept 5, 2012 1189 Barch files appearance on June 12, 2012 1204 barch confirms he is authorized to make offer of 5,000 on Nov 18, 2013 1207 Memo to Jen 1210 Carolyn McGuire deposition 1245 Gagnon deposition 1320 Gagnon answers to interrogatory submitted by Barch 1327 Dulberg deposition 1392 Dulberg interrogatories 1416 McArtor deposition 1437 William McGuire deposition notes: first mention of bankruptcy by Dulberg Sept 13, 2013 Mast first expresses doubt about Gagnon case on October 30, 2013 - or October 22, 2013 nothing between Mast and grayslake lawyer nothing between Mast and Baudin what about Mast work product list? April 14, 2014 - Mast email that he isn't interested in taking Gagnon case to trial, suggests Dulberg seek new counsel. Saul Ferris refused on March 6, 2015 because of 5,000 settlement which he sees as a mistake Baudin also sees it as a mistake Bankruptcy atty suggests getting new lawyer Mast advice in how to answer deposition questions: (email: folder 2013 01, file Mast2-250)