MAST INTERROGATORY NOTES 1) Mast did not answer the question. The question was concerning "the underlying matter" which Mast rephrased as "the accident" or the 'moment the injury occurred'. "The underlying matter" is clearly involves much more than "the accident" This is a deliberate attempt to avoid answering the question as stated. Mast should be compelled the answer the stated question. 2) The first sentence is meaningless. In the second sentence the phrase "I likely reviewed.." means he does not know for sure if he reviewed any or not. He also cannot recall any specific case verdict or settlement reviewed. 3) Mast never answers the question of whether the settlement offer documents cited were made with Dulberg's permission and knowledge. Mast should be compelled to answer either yes or no explicitly as to whether Dulberg approved each offer cited. 4) Mast cited case law and gave Dulberg case law documents which Mast claims supported his legal advice on November 20, 2013 at a meeting with witness Thomas Kost, Paul's brother, present. Paul Dulberg asked Mast to cite the case law that supported his legal advice in an email before the meeting on the same day. Mast also cited the case of Ticher vs Spangler (?) and stated that the McGuires are not liable for Dulberg's injury because Restatement of Torts 218(?) is not applicable in Illinois. 5) 6) Mast reported this at 2 meetings with Dulberg. There was a third person at each of these meetings. Barbara Dulberg, Paul's mother, was present at the November 4, 2013 meeting. Mast reported this to Barbara Dulberg. Mast also reported this to Thomas Kost, Paul's brother, at a meeting on November 20, 2013. 7) POPOVICH INTERROGATORY NOTES 1) 2) He refuses to state whether anyone was directly supervising Mast and who it was. He implies that Mast worked unsupervised without explicitly stating so. He should be compelled to state clearly whether he was working supervised or unsupervised and if supervised, who explicitly was supervising him on the Dulberg case. 3) MAST REQUEST FOR PRODUCTION NOTES 1) 2) Questions 2 and 3 are asked as a pair. In question 2 Mast is explicitly asked what discovery he initiated. In question 3 Mast is asked which discovery was initiated by other parties. Mast avoids answering either question by listing all discovery initiated by all parties without distinguishing who initiated each discovery motion. By doing this he intentionally gives us no new information that we didn't have before. We could have looked up this information ourselves. 3) See 2 4) We are explicitly asking for any investigations into the net worth and assets of the defendents McGuires and Gagnon. He does not answer the question. He only refers to the depositions of the McGuires and Gagnon. Having read each deposition again I cannot find any mention of the net worth or assets of any defendent anywhere in the transcripts. Mast should be compelled to cite page numbers and examples in the depositions where he asked any defendent about assets or net worth and if he cannot cite any, he should be compelled to answer explicitly that he conducted no investigation into the assets and net worth of any defendent. 5) Sentence #1 is correct. Sentence #2 is a statement that is easy to prove untrue. Anyone can look at a record of meetings between Mast and Dulberg from August 2013 to February 2014 (the period in question) and see that Dulberg and Mast rarely met in person during this period (they met twice) and Mast never met Dulberg alone during that time, meaning there is a 3rd party witness during each meeting who directly heard what was discussed. Both witnesses can verify there was no discussion of any litigation risk analysis at any face to face meeting. During this same period there is a record of many, many text and email exchanges. Both Mast and ourselves have definitive proof that the statement "most of my communications with Mr Dulberg regarding settlement were in face to face meetings" is deliberately false. 6) POPOVICH REQUEST FOR PRODUCTION NOTES 1) 2) 3) Anyone who looks at the documents cited can see there is no available copy of the back of the check, yet Popovich answers "see front and back of settlement check contained in documents previously produced...". The answer is obviously designed to deceive the reader on a very superficial level that a copy of the back of the check exists in his documents. 4) This answer and the court transcripts of January 2022 are the first time Flynn or Julia Williams stated there were additional documents in the office of Popovich that Williams chose not to copy and give to Dulberg. That is quite an admission. Dulberg was never informed by either Julia Williams or Flynn that additional documents existed in the possession of Popovich. Dulberg clearly has a right to all documents in the possession of Popovich and he has the right to know if additional documents exist. Yet Flynn never included this information in any document produced and Williams never included this information in any document produced. It does not exist in any court transcript before January 2022. This is a clear intent to conceal this information from Dulberg by both Williams and Flynn. Flynn cannot use this information in the answer if he cannot produce a single document or court record which demonstrates that Dulberg was informed these extra documents existed before 2022. He also cites an agreement with Julia Williams but there is no evidence that any such agreement existed and he has not produced any. He cannot cite an agreement that anybody else other that Flynn and Williams are allowed to see. This is a pretty clear 'bait and switch' logic game that FLynn is playing. All court records clearly show that the court and Dulberg were informed that the purpose of the Williams inspection of records in the office of Popovich was to address the issue of the blackened out pages in the Popovich document disclosure. The reason for the blackened out document pages was clearly given as being caused by "red folder dividers" to the court and to Dulberg. Williams, amazingly, informed Dulberg that the claim about the red file dividers was true. "Red folder dividers" were the bait, and now for the first time in 2022 the bait is switched to "additional documents that Williams chose not to request". We are not told what these additional documents are. We are not shown any document or evidence that Williams agreed to this. Williams refuses to communicate with Dulberg. The Judge doesn't allow Williams to be deposed even though we need to know about any agreement between Williams and Flynn made on behalf of Dulberg. The result? Dulberg is not allowed to see or understand the specifics of an agreement Williams made on his behalf. Dulberg cannot communicate with Williams. Dulberg is not allowed to depose Williams. Dulberg is not allowed to see email communication between Flynn and Williams which are claimed by Flynn to contain an agreement that Dulberg is supposedly bound to but not allowed to see. In this instance both the court and Dulberg are to be bound to an agreement that neither is allowed to see. In short, both the court and Dulberg are asked to completely trust Flynn's claim with no evidence whatsoever. And strangely, the court prohibits Dulberg from obtaining any evidence that the agreement exists.