“By refusing to comply with the Court-ordered procedures for commenting on Mr. Zeidman’s report, which required Angela to disclose ‘any additional evidence’ it had to challenge Mr. Zeidman’s findings and to raise its questions and concerns about Mr. Zeidman’s findings before Mr. Zeidman finalized his report, […] Angela is trying to ‘sandbag’ Mr. Zeidman and SWC by deposing Mr. Zeidman prematurely and on an incomplete record.”

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