📧 Communication

This document is a page from a court transcript filed on March 22, 2022. In it, an attorney argues to a judge that an opposing counsel's failure to investigate a matter was not a strategic choice to "sandbag" the court, but rather a result of incompetence, described as being "careless" and "inept." The speaker references a standard from the Second Circuit and the judge's own prior findings to argue that the other counsel "dropped the ball."