27. Identify and describe the expert opinions provided to you in December 2016 as alleged in paragraph 57 of your second amended complaint, including the identity of the expert, the opinions, and any other information provided by the expert which caused you to learn in the summer of 2016 and become reasonably aware that Mast and Popovich did not properly represent you. Original ANSWER: Dr. Landford is a chain saw expert who was retained by Dulberg. See documents produced. Supplemental Answer: The expert opinion was that of Dr Lanford. It was not in December of 2016 but rather in February of 2016. Dr Lanford's report was emailed to Dulberg by his counsel in July of 2016. Dulberg is unaware of any expert findings that took place in the summer of 2016 that would cause a reasonable awareness that Mast and Popovich did not properly represent him. Dulberg became reasonably aware in December 2016 when the mediation award exceeded what could be collected from Gagnon alone and coupled with Dr Lanford's earlier findings that found the McGuires also responsible. 1. December 2016 Mediation award (Dulberg 001308) 2. February, 2016: The expert, Dr Lanford's findings state: "Mr. and Mrs. McGuire who owned the saw apparently did not heed the warnings posted on page 2 of the owners manual which states “Allow persons only who understand this manual to operate your chainsaw.”" In Conclusion Dr Lanford wrote: "After the review of the above evidence, it is my opinion that Mr. Gagnon was fully responsible for this accident and his parents - the McGuires -were also somewhat responsible by letting their son, Mr. Gagnon, use their chainsaw - a potentially dangerous tool - without enforcing the warnings and instructions available in the owner's manual. Mr. Gagnon was in full control of the saw and Mr. Dulberg was his assistant. Mr. Gagnon could have prevented this accident by following the instructions given in the owner's manual. The instructions in the owner's manual are quite clear and unambiguous, and if followed, would have prevented this accident. Mr. Gagnon admits that he was relatively inexperienced in the use of chainsaws, and therefore, should have been more careful while using such a potentially dangerous tool." (Dulberg 001218, Dulberg 001219, Dulberg 001220) (Dulberg 000235 - Exhibit No. 2 of McGuire deposition Chainsaw Manual) (POP 000412) Dr Lanfords CURRICULUM VITAE (Dulberg 000328, Dulberg 000329, Dulberg 000330, Dulberg 000331, Dulberg 000332, Dulberg 000333, Dulberg 000334, Dulberg 000335, Dulberg 000336, Dulberg 000337, Dulberg 000338, Dulberg 000339, Dulberg 000340, Dulberg 000341, Dulberg 000342)