The William McKinley Institute

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In his response to the subpoena Exoo makes some interesting claims. D’Ambly argues that Exoo’s public statements indicate that there may be further communications pertinent to discovery. Exoo’s response is 1) the tip about D’Ambly being fired wasn’t entirely accurate 2) the tip was anonymous 3) he’s never communicated with the Daily News or Insite Risk Management. If all of the above is true, why not just produce the proof? Second, Exoo never addresses any possible communications with Daryl Lamont Jenkins. He seems to have left that out entirely. Full filing below with all documents (PACER). Be advised that it’s one single document but it includes all documents in the filing.

But the declaration filed by Exoo in his response to this subpoena are interesting, and it’s hidden behind Pacer. I’ll post that entire filing below

For those wondering about discovery, Exoo appears to be stonewalling his communications. This is the April 1st filing by D’Ambly and I’ll link the most pertinent document. The attachments are just related proof of service. And since all are available and not entirely interesting I won’t post them all. D’Ambly’s argument is that these communications are directly related to the case and should be within scope. Exoo’s response is to try and quash the subpoena or file a protective order to remove them from the scope of discovery and keep them private. This includes communications with Daryl Lamont Jenkins as well. https://storage.courtlistener.com/recap/gov.uscourts.njd.445946/gov.uscourts.njd.445946.203.0.pdf

After lengthy discussions between the parties, no settlement can be agreed upon. https://storage.courtlistener.com/recap/gov.uscourts.njd.445946/gov.uscourts.njd.445946.206.0.pdf

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