“Plaintiff’s determination to attend greater than 20 years to file her Grievance has prejudiced Defendant, as he has misplaced the flexibility to defend himself absolutely and pretty on this motion,” his response continued. “Some or all proof that in any other case would have been accessible if the motion had been promptly commenced could also be unavailable, misplaced, or compromised.”
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Pierre, in his personal response, declared that he by no means assaulted Doe nor did he ever witness anybody else doing so.