AT LEAST 3 DIFFERENT TYPES OF CASCADING EFFECTS ARE EXPECTED: 1) CASCADING EFFECTS FROM THE 10 DEPOSITION LOOK-ALIKES ON THE $5,000 SETTLEMENT BETWEEN DULBERG AND MCGUIRES: Private attorneys negotiating for both Dulberg and McGuires knowingly forged 10 deposition look-alikes and 10 certification pages. The $5,000 dollar agreement between Dulburg and McGuires relied on using the forged, artificially crafted deposition look-alikes as authentic depositions. So the agreement made under these conditions should be declared invalid effective immediately. What would be the effects from this? Is it possible to continue the case against the McGuires as if the agreement never happened? No, because the discovery was too damaged. Can the judge then reopen discovery in the Dulberg vs McGuires case and allow new depositions to be taken in a way that is fair to Dulberg? My opinion is no, he cannot. He can try but it is not possible to do it in a way which is fair to Dulberg because the original testimony was given but was never recorded as evidence. It was done intentionally do weaken or destroy Dulberg's cases. How can it be taken again at this time with what the witnesses now know in a way that won't be disadvantageous to Dulberg? If it cannot, then the effect from Mast, Popovich and Barch participating in the forgery of the 10 deposition look-alikes was to destroy the Dulberg case beyond repair in a way that can never be recovered in the future. What can be done about this by the court at this late stage? Can the case be considered so destroyed that the case is thrown out and no award is issued? Affected parties are then given leave to file new complaints within a certain time limit? 2) CASCADING EFFECTS FROM THE 10 DEPOSITION LOOK-ALIKES ON THE ARBITRATION AGREEMENT BETWEEN DULBERG AND GAGNON: Private attorneys negotiating for both Dulberg and Gagnon knowingly presented 10 forged deposition look-alikes to an arbitration judge as if they were authentic. The judge made a decision assuming the forged documents were actual testimony of witnesses. The arbitration agreement between Dulburg and McGuires relied on presenting and using the forged, artificially crafted deposition look-alikes as authentic depositions. So the agreement made under these conditions should be declared invalid effective immediately. What would be the effects from this? Is it possible to continue the case against Gagnon as if the arbitration agreement never happened? No, because the discovery was too damaged. Can the judge then reopen discovery in the Dulberg vs Gagnon case and allow new depositions to be taken in a way that is fair to Dulberg? My opinion is no, he cannot. He can try but it is not possible to do it in a way which is fair to Dulberg because the original testimony was given but was never recorded as evidence. It was done intentionally to weaken or destroy Dulberg's cases. How can it be taken again at this time with what the witnesses now know in a way that won't be disadvantageous to Dulberg? If it cannot, then the effect from Mast, Popovich and Accardo participating in the forgery of the 10 deposition look-alikes was to destroy the Dulberg case beyond repair in a way that can never be recovered in the future. What can be done about this by the court at this late stage? Can the case be considered so destroyed that the case is thrown out and no award is issued? Affected parties are then given leave to file new complaints within a certain time limit? Is the new complaint then based on fraud on the court by officers of the court, naming all offending parties as defendants? The complaint will state that the defendents destroyed Dulberg's case completely beyond repair? Or, can the judge issue a summary judgement for Dulberg based on the new evidence of intentional discovery abuse in the underlying cases? In the current case? If he can, based on what? Based on what testimony, since none of the forged deposition testimony actually exists in a legal sense. Or can he based only on extreme discovery abuse? In short, if an attorney is caught in the act of extreme discovery abuse, does he automatically lose his case based on that alone? 3) CASCADING EFFECTS FROM THE MAST EXHIBIT 12 FORGERY AND THE CONTRADICTIONS IN THE BARBARA G. SMITH FILES The documents provided by Barbara G. Smith demonstrate that she does not have a copy of any of the exhibits that Flynn currently possesses and that Williams provided to Dulberg. The exhibits Barbara G. Smith did provide were intentionally manipulated to appear like they are authentic by placing an exhibit tag on a special layer which overlays the document but is not digitally attached to it. The exhibit tags are also in different locations on each document than the exhibits that Flynn possesses and that Williams provided to Dulberg. Barbara G Smith claims she was not in possession of exhibit 12 when she certified and issued the original deposition transcript. She claims in a note that her copy of exhibit 12 contains only 5 pages... But her files contain 3 copies of exhibit 12 intact without any missing pages. WILLIAMS intentionally participated in the manipulation (forgery) of exhibit 12 to weaken Dulberg's case in the Mast deposition. This can be proved by looking at how the exhibit tag was connected to the exhibit and how the exhibit tag was digitally constructed. Williams let the opposing counsel Flynn claim they had no way to upload the exhibits and look at them, or any documents in general, during an online deposition. She must have entered into some type of secret agreement or plan with the opposing counsel to weaken or destroy Dulberg's case since both these actions require coordination between opposing attorneys and weaken the case of one particular client (Dulberg). Williams left out key evidence favorable to Dulberg from the bates-stamped documents. Williams intentionally wasted at least 3 of Dulberg's interrogatory questions to Mast about expert witnesses to weaken his case. (What she did in legal terms: Malpractice, concealment of evidence, document forgery, alteration of evidence, lying to client, made some secret agreement or plan (conspiracy) with opposing counsel without Dulberg's knowledge or consent and against the interests of Dulberg, discovery abuse.) FLYNN knowingly accepted a forged document from the opposing attorney (Williams) and presented it to the court as authentic. This is proven because the exhibit tag on Flynn's exhibit 12 has "Hans Mast" mis-spelled as "Hans Mist". This is a very unique mistake in the tag that only appears on exhibit 12 and on no other exhibit tags. The same mis-spelling of "Hans Mist" also appears on the version of exhibit 12 that Williams gave to Dulberg. These are the only 2 places the uniquely mis-spelled exhibit tag can be found. Flynn also presented the Saul Ferris forged document to the court as authentic. (What he did in legal terms: Document forgery, discovery abuse, professional misconduct) There is evidence that both opposing attorneys, Flynn and Williams, have already conspired to abuse the discovery process intentionally to Dulberg's disadvantage in the current case. Both the current defense attorney and the previous plaintiff attorney are in possession of similar forged documents. Flynn has already presented these forged documents to the court as exhibits as if they are authentic. Williams has presented exhibit 12 to Dulberg as if it is authentic. And the court reporter, Barbara G. Smith, has no exhibits which are copies of what Flynn and Williams possess and no exhibits that are authentically tagged at all. Williams and Flynn are the only 2 possible sources for having created the forgery. Both have presented the forgery as authentic, which is an act of forgery in itself. The Mast deposition cannot be admitted to the court as authentic. This legal condition was either accidentally brought about or intentionally brought about. Mast exhibit 12 is a forgery. The only 2 possible soures of the forgery are Flynn and Williams. The only 2 individuals that were in possession of the forgery were Flynn and Williams. Dulberg demands that Flynn explain how he came into possession of a forged document and why he presented it to the court as an exhibit. Dulberg demands that Flynn explain to the court how he could lack the ability to upload documents during a remote deposition being live-streamed over the internet. How is that technically possible? Flynn must explain if he received exhibit 12 with the rest of the deposition transcript directly from the court reporter or if it came to him separately from the transcript he ordered. In the malpractice case against Popovich and Mast, Dulberg is accusing them of artificially crafting (forging) 10 different deposition look-alikes and presenting them as authentic depositions. There is overwhelming evidence for a similar type of concealment of evidence, alteration of evidence and forging of documents by Flynn, the attorney of Popovich and Mast, during and after the Mast deposition. This is evidence of a fraud being committed in the current proceedings of this court during and after the Mast deposition. In the Mast deposition there is evidence of a similar type of fraud against court proceedings that Dulberg is accusing Popovich and Mast of committing in the underlying cases. We are proving that fraud has already been committed on these court processes by Flynn. Flynn has entered forged documents as exhibits in the court record. The court has been misled. Can the problem be rectified so the case can proceed to trial in good faith? Or have the current proceedings already become so damaged by the admission of forged documents as evidence, the inability to explain how forged documents came into Flynn's possession and the inability to authenticate the Mast deposition with legal sufficiency that the problems can't be rectified? If the integrity of the proceedings can be restored after this sharing of forged documents between 2 opposing attorneys to the disadvantage of Dulberg, How do we proceed? A new, legally valid deposition of Mast can be taken but what assurances do we have that Flynn will not try to undermine the integrity of the proceedings again? If the integrity of the proceedings cannot be restored in any way that is fair to Dulberg, Dulberg asks for a summary judgement in his favor on the accusations of malpractice against Popovich and Mast contained in the complaint in this case. Flynn's reply may be: The forgery was given to me by Dulberg's own attorney! Williams is responsible so Dulberg should hold her responsible, not Flynn, Popovich or Mast. If Dulberg's own attorney weakened or destroyed his case, that is his problem. Dulberg's answer to this can be: Williams was clearly not working in Dulberg's interest when she forged the document. She was intentionally working against the interest of Dulberg. She was cooperating with Flynn and acting together with him in a way that weakens or destroys Dulberg's case to Popovich's and Mast's advantage. Accepting and passing on a forged document as if it is authentic is also forgery according to law so even if Williams created the forged document Flynn is still guilty of forgery. Knowingly presenting a forgery as an exhibit is a fraud committed against the court and against Dulberg no matter who created the forged document. The point is Flynn and Williams were clearly cooperating in a way that acted against Dulberg's interests. It is not credible that while Williams and Flynn were secretly and intentionally cooperating to weaken or destroy Dulberg's case, Williams forged exhibit 12, shared her forgery secretly with Flynn, yet Flynn was not aware exhibit 12 was a forgery. It is not credible that Flynn was deceived by Williams and unwittingly accepted a forgery from her since they were working together to intentionally weaken or destroy Dulberg's case at the time. Flynn must have known exhibit 12 was a forgery from the time he created it or received it. POSSIBILITY OF 3 CASCADING SUMMARY JUDGEMENTS FOR DULBERG Another path to summary judgement for Dulberg... Provide proof that there are no originals or copies of certified depositions in Barch's, Accardo's or Popovich's case files (prove that none exist). Provide proof that the certification pages of all 10 depositions in the underlying cases are intentionally manipulated. That there are no authentic certification pages. Provide proof that Flynn and Williams are in possession of Mast exhibit 12 which is a forgery Provide proof that the file subpoenaed from Barbara G. Smith has no authentic originals or authentic copies of any of the exhibits File a motion for summary judgement against Popovich and Mast for discovery abuse in the current case based on this new information. File a motion for the court to declare that the $5,000 settlement agreement between Dulberg and McGuires is unenforceable and immediately invalid since it was based on the 10 forged deposition look-alikes being presented as authentic to Dulberg and to the court. Private attorneys on both opposing sides, both Popovich, Mast and Barch, were in on the deception so this is settlement fraud. File a motion for summary judgement for Dulberg in the underlying case against the McGuires based on this new information File a motion for the court to declare that the arbitration agreement between Dulberg and Gagnon is unenforceable and immediately invalid since it was based on the 10 forged deposition look-alikes being presented as authentic to the arbitration judge. File a motion for summary judgement for Dulberg in the underlying case against Gagnon based on this new information. Perhaps the result could be: Summary judgement for Dulberg in the current case against Mast and Popovich, summary judgement for Dulberg in the underlying case against the McGuires, and summary judgement for Dulberg in the underlying case against Gagnon. (3 cascading summary judgements for Dulberg) IN SUMMARY, THE WIDE RANGE OF POSSIBLE CASCADING EFFECTS INCLUDE: Everything from summary judgement for Dulberg in the current case and both underlying cases to all cases being dismissed with no judgement or award issued based on the fact that the cases are destroyed beyond recovery. Other possibilities: A finding that both Flynn and Williams committed a fraud against the court and against Dulberg. A finding that Williams created the exhibit 12 forgery, Flynn wasn't aware and accidentally presented it to the court as an authentic exhibit. It was actually Williams that destroyed Dulberg's current case, which is so badly damaged it cannot be continued, and Dulberg is free to file a suit against Williams and Clinton. Case thrown out with no award issued. If the case is thrown out with no award issued based on it being too badly damaged to be continued, the new complaint will have to be 'fraud on the court by officers of the court'. The court would have by then already ruled that Dulberg's current and underlying cases are destroyed too badly to take to trial or to receive any judgement for or against and no award for or against.