DEFENDANT THE LAW OFFICES OF THOMAS J. POPOVICH, P.C.’S INTERROGATORIES TO PLAINTIFF PAUL DULBERG 1. Identify the person(s) answering and/or providing assistance in the answering of these interrogatories. ANSWER: Paul Dulberg, Thomas Kost (Family Member), Clinton Law Firm 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: Paul Dulberg Paul's Family; Barbara Dulberg (Mother) Thomas Kost (Brother) Scott Dulberg (Brother) Judy Murphy (Sister) Joseph Kost (Brother) Sue Parker (Sister) Janet Zingen (Sister) Sherry Hamrick (Sister) David Dulberg (Brother) Others; Micheal McArtor Anyone else Dulberg may have spoken with about what happened. Defendants of the underlying case; Carolyn McGuire William McGuire David Gagnon Liability Witness Dr Lanford Possible expert witnesses for malpractice case, here? Attorneys & Law firms; Clinton Law Firm Thomas W. Gooch Randal Baudin Sr Randal Baudin Jr Kelly Baudin Brad Balke Hans Mast Popovich Law Firm Many Attorneys and Law Firms were both interviewed and given details during consultations of both the underlying and current case to list. Bankruptcy Attorneys David Stretch Various trustees assigned at different times to the Bankruptcy case. All Opposing Lawyers including but not limited to; Allstate Insurance Attorneys Auto-Owners Insurance Attorneys George K Flynn (2 firms) Judges; Judge Meyer ADR Judge Bankruptcy Judge Doctors; Dr Ford Dr Sek Dr Levin Dr Talerico Dr Sagerman Dr Kujawa Dr Pilcher Dr McMasters 3. Identify the address of the McGuire’s property described in paragraph 6 of your second amended complaint, and your address identified in paragraph 7 of the second amended complaint. ANSWER: The McGuire address is in Pistakee Terrace Home Owners Association in McHenry Township at 1016 West Elder Avenue, McHenry Illinois 60051. Dulberg's address is in McHenry Township at 4606 Hayden Ct. McHenry, Illinois 60051 4. Identify and describe how you were invited to the McGuires’ property to see if you wanted any of the wood from the tree, as alleged in paragraph 12 of your second amended complaint. ANSWER: Dulberg received a phone call from Gagnon on June 27th, 2011. Gagnon asked Dulberg if he wanted the wood from a tree on the McGuires property and invited Dulberg to come see the wood. 5. Identify how William McGuire physically assisted in cutting down the tree, including the date, time, and location of his assistance, and describe how and when he supervised David Gagnon’s actions in cutting down the tree, as alleged in paragraph 13 of your second amended complaint. ANSWER: The tree was never cut down on June 28th 2011. Only some of the branches were removed. Date, Time, Location - Dulberg witnessed William McGuire work with Gagnon from the time Dulberg arrived (8:30-9:00 am) till around Noon on June 28th 2011 at 1016 West Elder Avenue, McHenry Illinois 60051. William and Caroline McGuire purchased and provided the chainsaw to Gagnon. William McGuire along with Caroline McGuire instructed Gagnon on where they wanted the tree to fall. William McGuire stood near the tree, watching Gagnon work. William McGuire dragged the branches that Gagnon had removed from the tree to a pile in the garden. Gagnon would lower the chainsaw with a rope and William McGuire would pull-start the chainsaw. William McGuire throughout the coarse of the day raked up the mess and burned some of the branches in the garden. William McGuire and Gagnon had many conversations about the work being performed throughout the day. 6. Identify and describe how Caroline McGuire supervised David Gagnon and William McGuire’s actions, as alleged in paragraph 14 of the second amended complaint. ANSWER: William and Caroline McGuire purchased and provided the chainsaw to Gagnon. Caroline McGuire had the chainsaw manual and was instructing Gagnon what fuel/oil ratio to use. William McGuire along with Caroline McGuire instructed Gagnon on where they wanted the tree to fall. Caroline McGuire provided the ropes and strap used by Gagnon for climbing the tree. Caroline McGuire stood outside and sat for periods in a patio chair and watched William McGuire and Gagnon work. Caroline McGuire repeatedly told Gagnon to be safe up in the tree. Caroline McGuire kept offering bottled water to William McGuire and Gagnon. Caroline had many conversations with William McGuire and Gagnon about the work being performed throughout the day. 7. Identify the date, time, the location, and the exact words exchanged between Gagnon and the McGuires on the one hand and you on the other as alleged in paragraph 15 of your second amended complaint, in which it is alleged that were asked to assist the trimming and removal of the tree. ANSWER: June 28, 2011 around noon at 1016 West Elder Avenue, McHenry Illinois 60051. Dulberg's recollection is; William McGuire said he was tired and was done working. He went inside and within minutes came out in swim trunks and went in the pool. Gagnon went back to working. After a short while Gagnon started to complain to Caroline McGuire about having to do everything himself. William McGuire got out of the pool and went inside. Gagnon kept complaining to Caroline McGuire about having to work alone. Caroline McGuire went inside the house and came back out. Caroline McGuire said to Gagnon that “Bill” (William McGuire) was sore and tired and wouldn’t be back out. Gagnon said to Caroline McGuire that he needs help and this gets done today because he wasn’t coming back if it wasn't finished. Caroline McGuire turned to Dulberg and said; “Bills sore, can you please help?” Gagnon then said “Yeah, you could help, it’s real easy, look, I’ll show you what to do, you won't have to do much, Just hold stuff for me, C'mon, besides I remember helping you when you did your Dad's roof back in the 90's.” When finally Dulberg said "alright, show me what you need me to do", Caroline said "Thank you so much" and she went in the house. 8. Identify what safety information was readily available to Caroline and William McGuire as alleged in paragraph 18 of your second amended complaint, and how you know this information. ANSWER: The EFCO OPERATOR’S INSTRUCTION MANUAL that came with the chainsaw. Dulberg watched as Caroline read parts of it to Gagnon at the beginning of the work. Mast obtained a copy of the EFCO OPERATOR’S INSTRUCTION MANUAL during the McGuires Depositions. 9. Did you request any protective equipment or other safety devices from the McGuires or Gagnon while you provided assistance to Gagnon in operating the chainsaw? ANSWER: No, Gagnon instructed Dulberg and Dulberg never operated the chainsaw. 10. Did you assist Gagnon with trimming and removal of the tree? If so, describe each and every action you took in assisting Gagnon with the cutting down or removal of the tree. ANSWER: The tree was was never cut down on June 28th 2011. Only some of the branches were removed. When Dulberg assisted Gagnon the limbs were already removed from the tree. Dulberg only assisted Gagnon move and hold the limbs as Gagnon instructed. Dulberg lifted, moved and held the removed branches steady so Gagnon could cut off the smaller branches from the main branch. 11. Identify and describe each and every conversation between and David Gagnon while you were assisting him with trimming or cutting down the tree. ANSWER: Dulberg never assisted in trimming or cutting down the tree. Dulberg only assisted Gagnon in moving and holding the limbs that were already removed from the tree as Gagnon instructed. Below is Dulberg's recollection. Gagnon instructed Dulberg: Gagnon — Grab that end of the branch and lift it off the pile Dulberg — Here? Gagnon — Yes, Now pick it up and move it over there Dulberg — here? Gagnon — Perfect, Now lift it up a little higher Gagnon — Stop, Perfect, Now you just hold it there while I cut off the small branches Gagnon — After I’m done cutting off the small stuff let go and I’ll put it over here Dulberg — ok Gagnon — now we repeat the same thing with the next branch, got it? Dulberg — yes Gagnon — told ya it’s easy, see its hardly no work on your part Gagnon — Here grab this branch and lets start Once Gagnon started the chainsaw it was too noisy and there wasn't much talking, mostly eye contact hand gestures signaling to lift the branch higher or lower or pointing to the pile to get the next branch and start over. There were a few times when Gagnon wanted Dulberg to rotate the branch, Gagnon said this when the chainsaw was at idol. This went on till the accident. 12. Identify and describe each of your employers in the ten year period prior to the accident of June 28, 2011, including any self-employment. For each employer, identify your wage rate or salary, your title, your job description, your required duties, and your income for the ten year period prior to the accident in question. ANSWER: 1999-2011 - Sharp Printing Inc. Stockholder, President, Salesman, Graphic Designer, 8 Color Screen Print Pressman, Fulfillment, Shipping & Receiving and any other job that needed to be done. Dulberg financially backed Sharp Printing Inc with Dulberg's personal income and a line of credit from Dulberg's personal assets. Sharp Printing Inc operated out of the lower level of Dulberg's home for 13 years until the chainsaw accident. Dulberg never received wages from Sharp Printing Inc. Sharp Printing Inc was an investment for Dulberg. In return for Dulberg's financial help backing Sharp Printing Inc, donating his time to the corporation and allowing the corporation to utilize a whole floor of Dulberg's home, the corporation agreed not just to pay Dulberg back for his financial investment over time but also to immediately pay all the utility bills (Garbage, Water, Natural Gas, Electric, internet, phone and cable) for the entire home rather than just its own share of them and the corporation did so for the full 13 years it operated at Dulberg's home. This saved Dulberg approximately $650 per month in utilities. This barter is all that Dulberg received in terms of money for working for Sharp Printing Inc. Dulberg did expect that one day he would be able to pull a salary from Sharp Printing Inc and be paid back for his financial investment in the company. After the chainsaw accident, Dulberg could not help with the operation of Sharp Printing Inc. The two other partners (Scott Dulberg, Micheal McArtor) of Sharp Printing Inc realized that Dulberg would never be back in any capacity that could be meaningful and did not want to carry on with the company without Dulberg's help. Dulberg lost his investment in Sharp Printing Inc of approximately $50,000 over the 13 year span and lost his barter of work and floor space for utilities with Sharp Printing Inc of approximately $650 per month for the foreseeable future. Sharp Printing Inc did sell the equipment to the highest purchasers it could find at the time and only received $9,000 for all of it. The $9,000 was then divided equally and paid to the investors/shareholders. Of this, Dulberg only received $3,000 back on his 13 year investment and the company was dissolved. More than just a simple barter of labor and floor space for utilities and a promise to pay back the investment Dulberg made, Dulberg lost his corporation. 1999-2006 - Barter — Juskie Printing 2007-2011 — Self Employment — Juskie Printing For wage information see 2011 Form 1099-MISC in taxes submitted in document request as well as Juskie Printing email also submitted in document request. Dulberg will attest that he did not receive 1099-MISC from Juskie Printing for any other year in time for the tax deadline and did not add it to the IRS form 1040 because it would have been a guess. The income was reported directly to the IRS by Juskie Printing and each year Dulberg's return was corrected and reduced accordingly by the IRS. Dulberg cannot find the IRS correction letters but is confident they will show up in the IRS records. Dulberg earned $18,000 per year from Juskie Printing. Duties and responsibilities - Graphic design and prepress functions. 1998-2002 - Offset Press Operator I, Intermatic Incorporated. For wage information see 2000 through 2002 W2 in taxes submitted in document request. Job Description and Duties see Intermatic Job Descriptions.pdf submitted in document request. 2002-2007 - Graphic Designer, Intermatic Incorporated. For wage information see 2002 through 2007 W2's in taxes submitted in document request. Job Description and Duties see Intermatic Job Descriptions.pdf submitted in document request. Dulberg had his return corrected for calculating the interest incorrectly by the IRS. See 2007-IRS Correction Letter. 2008-2009 Dulberg made several trips to Clearwater Florida and stayed there over extended periods of time to take care of Betty Dulberg, his Grandmother, till she passed. Dulberg had very little income during these years. 2009 - Dulberg is missing his 2009 Tax Return due to the accountant at H&R Block passing. She had Dulberg's paperwork. 2010 - Self Employment, Intermatic Incorporated. For Wage Information see 2010 Form 1099-MISC Duties and responsibilities were essentially the same as when Dulberg worked as a W2 employee at Intermatic and can be found in Intermatic Job Descriptions.pdf 2011 — Part Time — Art Material Services - Material Handler. For wage information see 2011 W2 in taxes submitted in document request. Dulberg filled in for an employee who needed time off for medical and vacation. Duties and responsibilities - load, check and empty thread roller with steel bars, move threaded bars and load screw machines, check the parts the machines made for tolerances and empty parts from machines to buckets. Clean out metal chips from machines as necessary and keep the areas clean. 13. Did you suffer any serious personal injury and/or illness within ten years prior to the date of the occurrence? If so, describe where and how you were injured and/or became ill and describe the injuries and/or illness suffered. ANSWER: Yes, depending on what is considered serious Once or twice a year Usually at home Migraines Went untreated since Dulberg was in his early 20's 2002 Intersection of Hayden Dr and Johnsburg/Wilmot Rd. McHenry IL. Dulberg was hit in the rear bumper by another automobile. Note: Refer to the Medical records provided from the SSDI file. Year??? I think it was 2004ish Chest infection - see Dr Seks medical records maybe, not sure if it was Sek. Was prescribed an inhaler and antibiotics is all I remember. 2005 4606 Hayden Ct. McHenry IL. Scott Dulberg stepped on Paul Dulberg’s bare right foot. Broken bone in foot. X-rays taken at Centegra Hospital - McHenry Follow up was with a dr in crystal lake whom Dulberg cannot recall the name of. 14. Have you suffered any serious personal injury and/or illness since the date of the occurrence? If so, state when, where, and how you were injured and/or became ill and describe the injury and/or illness suffered. ANSWER: Yes 2011 Shortly after the chainsaw injury, See Dr Levins Medical records for exact date. Location: Home Migraine frequency picked up to a few times a month. Dulberg Talked to Dr. Levin about it since he was in to see her shortly after having a migraine and she gave Dulberg a Zomig inhaler and sumatriptan and said he should be seeing a Dr about them and said she can treat them. There was a falling out with Dr Levin shortly after Dr Sagerman sent Dulberg to be treated by Dr Kujawa for dystonia. Dr Levin was angry and told Dulberg that since she wasn't handling the dystonia, even though she was the first to diagnose it, that Dulberg should go see Dr Kujawa for the migraines as well and not to come back. Dr Kujawa doesn't treat migraines and Dulberg was just trying to follow the surgeons instructions. Dulberg did not intend to hurt Dr Levin by going to see Dr Kujawa whom Dr Sagerman told Dulberg to go see. The Migraines became stronger and more frequent over the next couple of years. Dulberg remembers waking up at Centegra in McHenry on September 25th 2014 from a migraine after his brother Scott Dulberg walked in and saw him on the floor, couldn't get Dulberg up, and called an ambulance. This was the first daytime migraine Dulberg ever had. On follow up from the hospital, Dr Zaide with McHenry Community Health Center sent Dulberg to see a migraine specialist that accepted Dulberg's insurance and Dulberg did follow up with that Specialist over the next year but Dulberg cannot recall his name. That Dr asked Dulberg many questions about what is going on in Dulberg's life and said to Dulberg that it sounds like stress is a main cause. That specialist also prescribed migraine medication. Note: Dr Zaide with McHenry Community health Center should have the Migraine Specialists name he referred Dulberg to on file. Dulberg had to stop seeing the migraine specialist Dr Zaide referred him to when the specialists company Changed their policy and no longer accepted Dulberg's medical insurance. Luckily, Dulberg's migraines eventually went back to their normal frequency of once or twice a year after dissolving the relationship with Mast and the Popovich Firm and hiring the Boudins. However, more recently this malpractice suit causes Dulberg to continuously reevaluate and relive the chainsaw accident and the horrible relationship with Mast and the Popovich law firm. Again, Dulberg has noticed an increase in the frequency at which he suffers migraines but not nearly as bad as it was between the years of the chain saw accident and parting with Mast and the Popovich Firm. Early 2013 Location - Home Dulberg mention an issue to Dr Sagerman during their visit and Dr Sagerman referred Dulberg to an Internist who's name Dulberg cannot recall. The Internist referred Dulberg to Dr. Conway. A Hemorrhoid was butterfly cut by Dr Conway. Dr Conway said to Dulberg the hemorrhoid was likely caused by stress because they don't usually come on till after 50 years of age and Dulberg was 43 at the time. 2013 Location: Home An enlarged prostrate was found by Dr Conway during the colonoscopy following the hemorrhoid procedure. Insurance referred Dulberg to Dr Berger at the Uro Center for prostrate treatment. Dr Berger prescribed meds for the prostrate and suggested Dulberg start a vitamin D supplement as well as a list of foods to eat. Dulberg followed up with Dr Berger several times over the next few years. Dr Berger retired and Dulberg now follows up twice a year with Dr Elterman in Skokie IL who keeps Dulberg on medication for the prostrate and checks to make sure it doesn't grow again. Late 2015 or early 2016 Location Home Dulberg broke out in hives and couldn't stop scratching for over three days Allergic reaction to unknown agent or substance Dr Zaide - upon seeing Dulberg, sent Dulberg immediately across the street to Centegra. Northern Illinois Medical Center/Centegra gave Dulberg a prescription dose of Benadryl in the Emergency Room and upon examination noted that Dulberg had a chest infection/Flu. Follow up was with Dr. Zaide. Dulberg was prescribed antibiotics and something in an inhaler. 2016 Home Dog Bite to left leg. Neighbors Dog came over and started a vicious fight with Dulberg's dogs. Dulberg tried to pull his dog off. When Dulberg got his dog off, the neighbors dog bit Dulberg in the left leg. Dulberg was treated and released from Centegra in McHenry and followed up with Dr Zaide Animal Control was notified and the neighbors dog was quarantined for possible rabies which turned out negative 2018 During the regular prostrate checkup, Dr Elterman noted a growth on Dulberg's genitals. Dr Elterman set up another appointment and removed the growth. 15. Have you filed any claim for workers compensation benefits in the ten years prior to the underlying accident of June 28, 2011? If so, state the name and address of your employer, the date(s) of the accidents, the identity of the insurance company that paid you such benefits and the case nos. and jurisdictions where filed. ANSWER: No 16. State the personal injuries sustained by you as the result of the underlying occurrence. ANSWER: Chainsaw injury to right arm - see medical records 17. With regard to your injuries, state: (a) The name and address of each attending physician and/or health care professional; (b) The name and address of each consulting physician and/or health care professional; (c) The name and address of each person and/or laboratory taking an x-ray, MRI and/or other radiological tests of you; (d) The date or inclusive dates on which each of them rendered you service; (e) The amounts to date of respective bills for services; and (f) From which of them you have written reports ANSWER: (a)(b)(c)(d)(e)(f) - See medical documents submitted for this information 18. As a result of your personal injuries from the underlying case, were you a patient or outpatient at any hospital and/or clinic? If so, state the names and addresses of all hospitals and/or clinics, the amounts of their respective bills and the date or inclusive dates of their services. ANSWER: Yes, see medical documents submitted 19. As a result of your personal injuries from the underlying case, were you unable to work? If so, state: (a) The name and address of your employer, if any, at the time of the occurrence, your wage and/or salary, and the name of your supervisor and/or foreperson; (b) The date or inclusive dates on which you were unable to work; (c) The amount of wage and/or income lost by you; and (d) The name and address of your present employer and/or wage and/or salary. ANSWER: Yes (a) Self Employed - see Tax Documents disclosed. See the previous 10 year tax returns disclosed. (b) See SSDI judgement for Permanent Disability as a result of the accident on June 28, 2011 disclosed. (c) See Gagnon case ADR judgement award for lost wages disclosed. Note: loss of future earning capacity was not listed in the ADR award probably because Social Security Disability had not yet made the determination of permeant disability. This event happened several months after the ADR hearing (d) There is no present employer, see SSDI Award for Permanent Disability as a result of the accident on June 28, 2011 disclosed. 20. State any and all other expenses and/or losses you claim as a result of the occurrence in the underlying case or resulting from any alleged legal malpractice committed by Popovich or Mast. As to each expense and/or loss, state the date or dates it was incurred, the name of the person, firm, and/or company to whom such amounts are owed, whether the expense and/or loss in question has been paid, and if so, by whom it was so paid and describe the reason and/or purpose for each expense and/or loss. ANSWER: Medical, Lost wages, Pain and suffering as spelled out in Gagnon ADR award disclosed. Costs incurred due to solvent bankruptcy Attorney fees to David Stretch (Dulberg's Bankruptcy Attorney) Bankruptcy Trustee fees and percentages they collected on Bankruptcy Court fees Costs of Gagnon ADR Costs of Gooch/Clinton Firms for Malpractice suit — Gooch 15K, Clinton 5k plus 33.33% of any possible recovery. Cost of expert witness fees for Malpractice suit - Unknown at this time Cost of expert witness for loss of housekeeping capacity, lifestyle change and depression - all unknown at this time. The loss of probable increase in ADR award due to permeant disability, loss of housekeeping capacity and lifestyle change from active to inactive. 21. Were any photographs, movies, and/or videotapes taken of the scene of the occurrence or the persons and/or equipment involved? If so, state the date or dates on which such photographs, movies and/or videotapes were taken, the subject thereof, who now has custody of them, and the name, address, occupation and employer of the person taking them. ANSWER: Picture of Gagnon, when Mast sent Dulberg to Gagnon home to collect insurance information. Mast has custody of the photo, Dulberg took photo. Note: I'm not entirely sure on this but I thought Mast photographed the chainsaw during the McGuires deposition 22. Had you consumed any alcoholic beverage within the 12 hours immediately prior to the occurrence or had you used any drugs or medications within 24 hours immediately prior to the occurrence. If so, state the name(s) and address(es) of those from whom it was obtained, where it was used, the particular kind and amount of drug, medication, or alcohol so used by you, and the names and current residence addresses of all persons known by you to have knowledge concerning the use of said drug or medication or alcohol. ANSWER: Possibly, it is common but not necessarily daily that Dulberg consumes Naproxin sodium tablets. Available without prescription. Dulberg usually purchases it at Meijer in Mchenry or Walmart in Johnsburg. Taken at Home. 2x220 mg Naproxin sodium tablets consumed in the evening and morning. At home, Barbara Dulberg (Mother) knew. The naproxen was prescribed to Dulberg by several different Dr's for a few years after the auto accident until it became available over the counter at which time Dr. Sek told Dulberg it was now available over the counter and that I should get it there to save a trip to see him every few months just for for a new prescription. Dulberg was advised back then by several Dr's that naproxen works best if it is in the system before the pain starts to be most effective and that Dulberg would most likely be on Naproxen for the rest of his life. Since then much has been learned about long term daily use of naproxen and it's side effects to the stomach lining so now Dulberg only takes it on the days he feels pain coming on. Dulberg has no memory of taking Naproxen the day before or morning of June 28th, 2011 but it is possible. 23. Describe why you agreed to a binding mediation in the summer of 2016 as alleged in paragraph 52 of your second amended complaint. ANSWER: Dulberg did not agree, The bankruptcy trustee filed a motion in bankruptcy court to have the case put into ADR for binding mediation and the judge agreed. 24. Identify the date on which you provided any settlement authority to Hans Mast or the Popovich firm, and the amount of any specific settlement authority to make any settlement demand upon the defendants in the underlying case. ANSWER: No Settlement authority was given to Mast. On November 4th, 2013, at a meeting in Masts office, per Mast’s request, Dulberg verbally gave Mast authority to look into a possible settlement. No specific dollar amount was discussed. Dulberg requested that the amount should pay for all expenses and loss. 25. Identify and describe the date on which you received a copy of the settlement agreement from Mast in the underlying case, the date on which you executed the settlement agreement and the date on which you mailed the executed settlement agreement to Mast. ANSWER: January 29th, 2014 Received, Signed and Mailed 26. Identify and describe the false and misleading information Mast and Popovich provided to you, and explain how you realized for the first time in December of 2016 that the information was false and misleading and the dismissal of the McGuires was a serious and substantial mistake, as alleged in paragraph 56 of your second amended complaint ANSWER: MAST told DULBERG at a meeting in which DULBERG was trying to decide whether to accept the MCGUIRE's offer of $5,000 that because the restatement of torts 318 is not applicable in Illinois, DULBERG had no case against the MCGUIRES and that the MCGUIRES did not have to offer any settlement at all. DULBERG asked MAST to cite case law that shows why the MCGUIRES were not at least partially liable for DULBERG'S injury, and MAST cited Tilscher v Spangler, a case which confirms that restatement of torts 318 is not applicable in Illinois. Mast also gave Dulberg information on some other cases. Those papers are included in the documents being given to opposing counsel. At the same meeting MAST also informed DULBERG that the MCGUIRES made an offer of $5,000 to be nice (they did not have to offer anything) and if DULBERG did not accept the offer it would be withdrawn and the MCGUIRES will ask for summary judgement. MAST informed DULBERG that the presiding judge would grant the MCGUIRES a summary judgement dismissing the case against them, leaving DULBERG with no settlement at all from the MCGUIRES. Mast also told Dulberg that settling with the McGuires would not affect his ability to recover the full amount for his injuries since he could recover the full amount from the Gagnon lawsuit alone. The dates of these exchanges are given in Dulberg's answer to the next question. Dulberg first became aware that Mast's plan of action could be incorrect when he contacted other law firms while terminating his relationship with Mast. Dulberg was informed by other law firms that their opinion is that dropping the lawsuit against the McGuires was a mistake. When Dulberg hired the Baudin Law firm they also informed him that they believe that settling the lawsuit against the McGuires was a mistake. Dulberg first learned that Mast's plan of action resulted in a loss of what Dulberg was finally able to recover when the arbitration judge awarded Dulberg much more than he was able to collect through the Gagnon lawsuit alone. 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. ANSWER: Dr Landford's report which contains Dr Lanford's opinions is in the documents being released to the opposing counsel.