Dulberg Answers to Thomas Popovich Expert Interrogatories SKELETON DRAFT 2019 March 23.docx 1. A. Lay Witnesses Add: Barbara Dulberg 4606 Hayden Ct. McHenry IL. 60051 Retired Barbara is expected to testify as to the November 4th 2013 meeting with Hans Mast. Thomas Kost 423 Dempster St Mt. Prospect, IL. 60056 Electrician Thomas Kost is expected to testify as to the legal advice given to Dulberg from Mast and the Popovich Firm on the McGuires liability, or lack of it, and how the Judge would rule when the McGuires moved the court for Summary Judgement and the urgency of how fast this would happen if Dulberg did not accept the paltry offer of the McGuires during the December meeting between Mast and Dulberg in 2013. See Thomas Kost's handwritten notes taken during the December 2013 meeting. B or C. Independent Expert Witnesses, Retained Expert Witness or Controlled Expert Witness? Note: Dr Lanford was paid for his report prior to the Gagnon Binding Mediation but I'm not sure if that means he has been retained for this trial. Nor do I know exactly which category he fits into. Add: Dr. Bobby Lanford - See Dr Lanfords report for address and occupation. Dr Lanford is a Chainsaw Liability Expert. Dr Lanford's Cirriculm Vitae accompanies his report. See Dr Lanfords report for his liability findings/opinions and what would be expected from his testimony. 3. (a) Dr Lanford - Chainsaw Operator (Gagnon) and Chainsaw Owners/Home Owners (McGuires) shared liability. (b) Dr Lanford - That both the McGuires and Gagnon shared the liability. 5. The date Dr Lanford first formed his opinion can be either found in his report or asked of him directly. 6. See Dr Lanford's report 7. See Dr Lanford's report Dulberg's Answers to Hans Mast's Interrogatories to Plaintiff 2019 March 24 SKELETON DRAFT.docx 1. Answer: Remove the word "likely" Second sentence should read; Mast advised Dulberg that the judge would rule in favor of the McGuires on a motion for summary judgement. 2. Answer: Remove the word "likely" Second Paragraph, Second sentence should read; Mast advised Dulberg that the judge would rule in favor of the McGuires on a motion of summary judgement. Dulberg's Answers to Popovich Interrogatories to Plaintiff 2019 March 24 SKELETON DRAFT.docx 2. Identify all persons who have knowledge of any matters relating to any of the facts, claims, damages, or defenses at issue in this case. ANSWER: Add; Thomas Kost has knowledge expected to testify as to the legal advice given to Dulberg from Mast and the Popovich Firm on the McGuires liability, or lack of it, and how the Judge would rule when the McGuires moved the court for Summary Judgement and the urgency of how fast this would happen if Dulberg did not accept the paltry offer of the McGuires during the December meeting between Mast and Dulberg in 2013. See Thomas Kost's handwritten notes taken during the December 2013 meeting. Remove; Judy Murphy Joseph Kost Sue Parker Janet Zingen Sherry Hamrick David Dulberg They live too far away and do not see Dulberg often enough to testify as to the effects of Dulberg's injuries. Add; Mike McArtor who does live at the same address as Dulberg, was Dulberg's business partner in Sharp Printing Inc., and can testify as to the effects of Dulberg's injuries. Also, The line: Barbara, Thomas, Scott, Judy, Joseph, Sue, Janet, Sherry, and David have knowledge of the effects of Dulberg’s injuries, including his loss of movement and pain and suffering. Should read: Barbara, Thomas, Scott, and Mike have knowledge of the effects of Dulberg’s injuries, including his loss of use and pain and suffering. Note: there is some loss of movement particularly in the wrist but these people see the loss of use better because they all knew Dulberg on a weekly if not daily basis before and after the accident and witnessed for themselves the difference in Dulberg's abilities. 4. Answer: Why is the Date highlighted in yellow? 5. Answer: 9th paragraph last sentence says: Gagnon would then tell Dulberg where to place the branches after they were broken down into smaller pieces. This is not True Gagnon placed the larger limb, which was now stripped of the smaller branches, in a pile and instructed Dulberg to grab the next limb, which still had the smaller branches, to start the process again. 8. Answer: Add; The Owners manual contained the warnings and safety instruction information that would have completely prevented the accident. 12. Answer: 3. Remove "and press operator" from the 3rd line Should read; 2010 Intermatic Incorporated, Independent Contractor for Graphic Design. 14. Answer: 1. Remove "Dr. Kujawa" - she does not treat migraines. Add Dr. Terrance Lee 20. Answer: Note, Should "loss of use" or "Permanent Disability resulting from injuries" be included here? 21. Answer: Note, Should we list the efco chainsaw operators instruction manual that was copied during William McGuire's deposition here because it has photographs of the equipment used?