Subject: Re: Filing Fees needed prior to filing suit
From: Paul Dulberg <[email-masked]>
To: Office Office <[email-masked]>
Date: Mon, 27 Nov 2017 09:25:23 -0600 (CST)

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 realized for the first time" to perhaps 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'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 that the lawyer I had handling the personal injury case was wrong about the amount 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 Popovich firm withdrew who wrote me a letter saying he wouldn't take the case because of the way the Popovich firm released the McGuires insurance, then when I read the chainsaw liability expert's report just before the ADR hearing where in his report he clearly put negligence on the McGuires, then I finally and fully understood the extent of the damages of Popovich's negligence after the ADR Binding Mediation Hearing and thats when The Baudin Firm sent me to see Tom Gooch.

I'd suppose that if the Popovich insurance 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 getting hints there was a problem the whole 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 <[email-masked]> 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 and 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 neighbors 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 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 stop by the next day to see what he had. Caroline McGuire asked me to help her 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.
> 
> 
>     Page 2, 6th item it says "Dulberg was an adjoining property owner."
> 
>     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 Office <[email-masked]> wrote:
> > 
> > 
> >         Hi Paul,
> > 
> >         Tom asked me to obtain the filing fees from you (which I mentioned in my earlier email) prior to filing suit. I am not certain if he remembered to ask you for these when you were in last night, and I was gone before your appointment ended.  These costs for the filing & service fees are mentioned in your retainer agreement, paragraph 3, as expenses the client must pay in addition to the attorney’s retainer fee. My instruction from Tom yesterday was that we cannot file the suit until we have these fees from you. 
> > 
> >          
> > 
> >         The breakdown is as follows:
> > 
> >          
> > 
> >         McHenry County Court Filing Fee: $ 464.50  (252.00 Court Fees, $212.50 Jury of 12 Demanded)
> > 
> >         Service fees                                            $ 130.00 (two separate defendants, $65 each)
> > 
> >          
> > 
> >         Total needed:                                        $594.50
> > 
> >          
> > 
> >         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 Filing & Service Fees in the memo section. If you pay by credit card we can accept a payment over the phone.
> > 
> > 
> >         Thank you and happy holidays,
> > 
> >          
> > 
> >         Margaret G. Buckley
> >         Paralegal
> > 
> >         The Gooch Firm
> >         209 South Main Street
> >         Wauconda, Illinois 60084
> >         (847) 526-0110 (phone)
> >         (847) 526-0603 (fax)
> > 
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> > 
> >          
> > 
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