Here are the questions that attorney Robert Hanlon had propounded to Mary McClellan, who is a candidate for Circuit Court Clerk.
They relate to the discovery motion filed by McClellan.
Each statement asks McClellan to admit or deny its truthfulness.
SPECIFIC REQUESTS FOR ADMISSION OF FACTS
Pursuant to Illinois Supreme Court Rule 216 Admit the Truth of the Following Facts:
- The birth certificate attached hereto as Exhibit A is a true and accurate copy of the birth Certificate of Edward Joseph Ershbock.
- Edward Joseph Ershbock is your biological son.
- At the time you gave birth to Edward Joseph Ershbock, you were not married.
- Your son, Edward Joseph Ershbock, was raised by his grandmother in the greater Atlanta Georgia Metropolitan area.
- Your son, Edward Joseph Ershbock, began living with you and Edward Gil at a time when he was 12 years of age.
- Your son, Edward Joseph Ershbock, lived with you for a period not exceeding three years.
- During the period that Edward Joseph Ershbock lived with You and Edward Gil, You regularly witnessed Edward Gil physically abuse Edward Ershbock.
- At no time did you undertake any action to prevent Edward Gil from physically attacking Edward Joseph Ershbock.
- You are married to Edward Gil.
- During the period that Edward Joseph Ershbock lived with you and Edward Gil, Edward Gil on more than two occasions spat in the face of Edward Joseph Ershbock.
- During the period that Edward Joseph Ershbock lived with you and Edward Gil, Edward Gil broke a coffee cup on the head of Edward Joseph Ershbock.
- During the period that Edward Joseph Ershbock lived with you and Edward Gil, Edward Joseph Ershbock ran to a neighbor’s house to call police because blood was running down his face as a result of the coffee cup broken upon his head by Edward Gil.
- While you were the McHenry County Clerk you hired Edward Gil to be employed in the office of the County Clerk, without disclosing your relationship as his wife to anyone on the county board at the time of hire.
- You were sanctioned by the United States District Court in the matter of Martinez v City of Chicago et al, case number 1:09-cv-05938.
- The sanction imposed against you and the Cook County State’s Attorney’s Office in the matter of Martinez v City of Chicago, was directly related to your reckless conduct in attempting to prevent the delivery of evidence the opposing party was entitled to obtain.
- You are presently a candidate for Circuit Court Judge.
- You publicly announced your candidacy for Circuit Court Judge on or about September 6, 2019.
- Prior to August 1, 2019, you communicated with at least one other person that you were going to run to the position of Circuit Court Judge.