Northridge submits that the mourning ceremony narrative was created for the first time in the June 2017 trial dates. It was never pleaded. It was never put to Gurdev or Dalwir in contravention of the rule in Brown v. Dunn. It was never disclosed in any earlier affidavits and as a result of all of the evidentiary deficits relating to that issue no weight ought to be given to that argument. I agree. Sood’s testimony on this issue is not credible or reliable.
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