Whether it would have been advisable to move forward at some earlier time may be debatable and is a different subject, but to say that there was an absence of any facts and/or "evidence", or that reasonable suspicion did not exist, long before August 2010, is simply erroneous.

Finally, recognition that without the proverbial "smoking gun", or damaged automobile, mere suspicion is just that and hardly the basis to commence costly litigation, and it is the prime subject under discussion, not "different".

Weren't the papers filed April 22? Which makes the closing comment, "long before August 2010" "simply erroneous", and misleading, at best.

I therefore humbly suggest that had PTSC filed earlier than when they did, any "Discovery" could have been dismissed as a "fishing expedition", of which you are no doubt aware.

Thank you yet again for sharing your legal knowledge. to better understand the obvious complexities which could so easily be overlooked, it is much appreciated.

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Be well