Date: Mon, 27 Nov 2017 09:25:23 -0600 (CST) From: Paul Dulberg Reply-To: Paul Dulberg To: Office Office Message-ID: <190621277.221620.1511796323475@connect.xfinity.com> In-Reply-To: <157881480.129053.1511368349326@connect.xfinity.com> References: <157881480.129053.1511368349326@connect.xfinity.com> Subject: Re: Filing Fees needed prior to filing suit MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="----=_Part_221619_878754116.1511796323467" X-Priority: 3 Importance: Medium X-Mailer: Open-Xchange Mailer v7.8.4-Rev12 X-Originating-IP: 2601:245:4000:2206:641b:ff6b:7976:722c X-Originating-Client: open-xchange-appsuite X-OX-Marker: 7bfd51e6-6ddb-42da-86d0-8926c2343747 ------=_Part_221619_878754116.1511796323467 MIME-Version: 1.0 Content-Type: text/plain; charset=UTF-8 Content-Transfer-Encoding: quoted-printable Hi Margret, In addition to the corrections listed in last Wednesdays email, I'd like to= know what Tom thinks about changing number 20 where it says, "DULBERG real= ized for the first time" to perhaps DULBERG fully realized for the first ti= me. My thinking is this, I started to get hints that things were wrong first fr= om the treating Dr's, one of them, Dr Kujawa who came out and said the firm= I had handling the case was asking all the Dr's the wrong questions during= their depositions, then from the first bankruptcy trustee when she said th= at the lawyer I had handling the personal injury case was wrong about the a= mount the case was worth, how they handled it so far and that I should find= a new lawyer, then from an attorney that I was interviewing after the Popo= vich firm withdrew who wrote me a letter saying he wouldn't take the case b= ecause of the way the Popovich firm released the McGuires insurance, then w= hen I read the chainsaw liability expert's report just before the ADR heari= ng where in his report he clearly put negligence on the McGuires, then I fi= nally and fully understood the extent of the damages of Popovich's negligen= ce after the ADR Binding Mediation Hearing and thats when The Baudin Firm s= ent me to see Tom Gooch. I'd suppose that if the Popovich insurance lawyer fights one of the key thi= ngs they will try to get out of me in a deposition is when I first realized= there was a problem hoping to get off on some technicality. But things are= not always black and white. I was getting hints there was a problem the wh= ole way but it only fully revealed itself to me once I met with Tom Gooch. I'm available for Tom to reach me about this anytime Thanks, Paul 847-497-4250 > On November 22, 2017 at 10:32 AM Paul Dulberg wrot= e: >=20 >=20 > Hi Margret, >=20 > I can stop in today with a check for the filing fee. >=20 > Will you be there till 5pm today or are you closing earlier due to th= e holiday? >=20 >=20 > On another note; >=20 > Tom asked me to read over the complaint and email you with any correc= tions or concerns. the following items are what I have found at first glanc= e. >=20 >=20 > On page 2, 6th item it says; "having been called by his neighbors Car= oline McGuire and William McGuire..." >=20 > To be correct it could simply read "having been asked" rather than "h= aving been called" >=20 > Explanation: Their son David Gagnon called me on the phone the day be= fore and asked if I wanted the wood from a tree he was cutting down at his = (moms) Caroline and William McGuies home and I told David Gagnon I would st= op by the next day to see what he had. Caroline McGuire asked me to help he= r son David once I was already there because her husband was tired and went= into the house and David Gagnon was complaining to her that he needed help= . Thats when Caroline McGuire asked me to help. >=20 >=20 > Page 2, 6th item it says "Dulberg was an adjoining property owner." >=20 > This is False, I live 2 roads over from the McGuires property and can= not even see their property from my property. >=20 >=20 > Thats about it at first glance. I will email more if I find anything = else. >=20 >=20 > Thanks, >=20 > Paul >=20 > > > On November 22, 2017 at 9:44 AM Office Office wrote: > >=20 > >=20 > > Hi Paul, > >=20 > > Tom asked me to obtain the filing fees from you (which I mentio= ned in my earlier email) prior to filing suit. I am not certain if he remem= bered to ask you for these when you were in last night, and I was gone befo= re your appointment ended. These costs for the filing & service fees are m= entioned in your retainer agreement, paragraph 3, as expenses the client mu= st pay in addition to the attorney=E2=80=99s retainer fee. My instruction f= rom Tom yesterday was that we cannot file the suit until we have these fees= from you.=20 > >=20 > > =20 > >=20 > > The breakdown is as follows: > >=20 > > =20 > >=20 > > McHenry County Court Filing Fee: $ 464.50 (252.00 Court Fees, = $212.50 Jury of 12 Demanded) > >=20 > > Service fees $ 130.0= 0 (two separate defendants, $65 each) > >=20 > > =20 > >=20 > > Total needed: $594.50 > >=20 > > =20 > >=20 > > We look forward to receiving your check as soon as possible. If= sending a check you may make this payable to: The Gooch Firm and note Fili= ng & Service Fees in the memo section. If you pay by credit card we can acc= ept a payment over the phone. > >=20 > >=20 > > Thank you and happy holidays, > >=20 > > =20 > >=20 > > Margaret G. Buckley > > Paralegal > >=20 > > The Gooch Firm > > 209 South Main Street > > Wauconda, Illinois 60084 > > (847) 526-0110 (phone) > > (847) 526-0603 (fax) > >=20 > > This communication is covered by the Electronic Communications = Privacy Act, found at 18 U.S.C. 2510 et. seq. and is intended to remain con= fidential and is subject to applicable attorney/client and/or work product = privileges. If you are not the intended recipient of this message, or if th= is message has been addressed to you in error, please immediately alert the= sender by reply e-mail and then delete this message and all attachments. D= o not deliver, distribute or copy this message and/or any attachments and i= f you are not the intended recipient, do not disclose the contents or take = any action in reliance upon the information contained in this communication= or any attachments. > >=20 > > =20 > >=20 > > =20 > >=20 > > >=20 =20 ------=_Part_221619_878754116.1511796323467 MIME-Version: 1.0 Content-Type: text/html; charset=UTF-8 Content-Transfer-Encoding: quoted-printable Hi Margret,

In addition to the corrections listed in la= st Wednesdays email, I'd like to know what Tom thinks about changing nu= mber 20 where it says, "DULBERG realized for the first time" to per= haps DULBERG fully realized for the first time.

My thinking is this,= I started to get hints that things were wrong first from the treating Dr&#= 39;s, one of them, Dr Kujawa who came out and said the firm I had handling = the case was asking all the Dr's the wrong questions during their depos= itions, then from the first bankruptcy trustee when she said that the lawye= r I had handling the personal injury case was wrong about the amount the ca= se was worth, how they handled it so far and that I should find a new lawye= r, then from an attorney that I was interviewing after the Popovich firm wi= thdrew who wrote me a letter saying he wouldn't take the case because o= f the way the Popovich firm released the McGuires insurance, then when I re= ad the chainsaw liability expert's report just before the ADR hearing w= here in his report he clearly put negligence on the McGuires, then I finall= y and fully understood the extent of the damages of Popovich's negligen= ce after the ADR Binding Mediation Hearing and thats when The Baudin Firm s= ent me to see Tom Gooch.

I'd suppose that if the Popovich insura= nce lawyer fights one of the key things they will try to get out of me in a= deposition is when I first realized there was a problem hoping to get off = on some technicality. But things are not always black and white. I was gett= ing hints there was a problem the whole way but it only fully revealed itse= lf to me once I met with Tom Gooch.

I'm available for Tom to rea= ch me about this anytime

Thanks,
Paul

847-497-4250

=20 On November 22, 2017 at 10:32 AM Paul Dulberg <pdulberg@comcast.net>= ; wrote:

Hi Margret,

= I can stop in today with a check for the filing fee.

Will you be there till 5pm today or are you closing earlier due to the= holiday?


On another= note;

Tom asked me to read over the complaint a= nd email you with any corrections or concerns. the following items are what= I have found at first glance.


On page 2, 6th item it says; "having been called by his nei= ghbors Caroline McGuire and William McGuire..."

To be correct it could simply read "having been asked" rather than= "having been called"

Explanation: Their= son David Gagnon called me on the phone the day before and asked if I want= ed the wood from a tree he was cutting down at his (moms) Caroline and Will= iam McGuies home and I told David Gagnon I would stop by the next day to se= e what he had. Caroline McGuire asked me to help her son David once I was a= lready there because her husband was tired and went into the house and Davi= d Gagnon was complaining to her that he needed help. Thats when Caroline Mc= Guire asked me to help.


Page 2, 6th item it says "Dulberg was an adjoining property owner.&= #34;

This is False, I live 2 roads over from the= McGuires property and cannot even see their property from my property.
=


Thats about it at first= glance. I will email more if I find anything else.


Thanks,

Paul

On November 22, 2017 at 9:44 AM Office O= ffice <office@goochfirm.com> wrote:

Hi Paul,

Tom asked me to obtain the filing fees from yo= u (which I mentioned in my earlier email) prior to filing suit. I am not ce= rtain if he remembered to ask you for these when you were in last night, an= d I was gone before your appointment ended.  These costs for the filin= g & service fees are mentioned in your retainer agreement, paragraph 3,= as expenses the client must pay in addition to the attorney’s retain= er fee. My instruction from Tom yesterday was that we cannot file the suit = until we have these fees from you. 

 

The breakdown is as fo= llows:

 

McHenry County Court Filing Fee: $ 464.50  (252.00 = Court Fees, $212.50 Jury of 12 Demanded)

Service fees          &#= 160;            = ;            &#= 160;        $ 130.00 (two separate defen= dants, $65 each)

 

Total needed:     = 60;            =             = 60;         $594.50

=

 

We look forward to receiving your check as soon as possible. If se= nding a check you may make this payable to: The Gooch Firm and note Filing = & Service Fees in the memo section. If you pay by credit card we can ac= cept a payment over the phone.


= Thank you and happy holidays,

= 0;

Margaret G. Buckley<= br> Paralegal

The Gooch Firm
209 South Main Street
Wauconda, Illinois 60084
= (847) 526-0110 (phone)
(847) 526-0603 (fax)

This communication= is covered by the Electronic Communications Privacy Act, found at 18 U.S.C= . 2510 et. seq. and is intended to remain confidential and is subject to ap= plicable attorney/client and/or work product privileges. If you are not the= intended recipient of this message, or if this message has been addressed = to you in error, please immediately alert the sender by reply e-mail and th= en delete this message and all attachments. Do not deliver, distribute or c= opy this message and/or any attachments and if you are not the intended rec= ipient, do not disclose the contents or take any action in reliance upon th= e information contained in this communication or any attachments.

 

 


  =20 ------=_Part_221619_878754116.1511796323467--