Wednesday, November 25, 2020 7:57:05 AM
Should look something like this
“ Had defendants participated in the litigation in any meaningful capacity they would have been well prepared for the possibility of an unfavorable judgement on their defense and being subject to the incidental damages sought by Plaintiff” ......... “in addition defendants have been aware of the damages as presented by plaintiff at the very latest since June 12th when they suddenly reappeared with new counsel at which time they could have complied under discovery orders and submitted their expert report at that time or any time since they chose not to”............
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