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documents, I can take him at his word.

The problem is, before we were even defendants,

they agreed that Mr. Clem transfer everything to

Mr. Bollea.

Just no way for us to know.

Then there is this dismissal without prejudice.

Mr. Clem got out of this case with a promise to

testify to cooperate, to not disparage Mr. Bollea,

and to not help us, and paid what they called the

substantial sum of $5,000.

But at that point, if

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Mr. Clem testified differently in his deposition, if

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he comes into court come March 7th and testifies

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differently in this courtroom, Mr. Bollea can

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restart a hundred million dollar lawsuit against

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him.

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That is the problem.


The same prospects for incentivizing a lie on

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the stand, that the Supreme Court said made the Mary

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Carter agreements admissible at trial, is the same

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reason that this agreement with Mr. Clem should come

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in.

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Finally, with respect to Ms. Cole, Mr. Vogt

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mentioned that that's not on the exhibit list.

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never been provided to us.

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the extent the settlement agreement with Ms. Cole,

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with these same kind of provisions, which I don't

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know, then that should be turned over to us and

It's

I would argue that to

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