VIRGINIA: IN THE CIRCUIT COURT OF THE CITY OF ALEXANDRIA
ERIC J. BONETTI,
Plaintiff, CIVIL ACTION NUMBER: CL 20002206
vs. ROBERT H. MALM Defendant
PLAINTIFF’S MOTION FOR RECONSIDERATION COMES NOW Plaintiff Eric J. Bonetti in the above-captioned matter, and motion for reconsideration following the court’s ruling of May 26, 2021, in which the court denied Plaintiff’s motion for sanctions/order to compel in discovery, and granted a protective order granting confidentiality for Defendant’s discovery responses. Plaintiff avers that the Circuit Court: 1. Ignored the evasive nature of Defendant’s discovery responses, which pursuant to Rule 4 are treated as a failure to answer. This denial of meaningful discovery will irreparably prejudice Plaintiff at trial and subverts the very basis for discovery, which is to assist the parties in factfinding prior to trial. 2. Disregarded the fact that, in the previous litigation, which is the subject of the present case, this court ordered Defendant to respond to the very same interrogatories — a court order that the Defendant ignored. 3. Ignored the Defendant’s manifest perjury and the fabrications of defense counsel, thus further prejudicing Plaintiff when the case goes to trial. 4. Violated Plaintiff’s First Amendment rights, and those of the public, by imposing confidentiality on the Defendant’s responses, with no showing of any present or future harm to the Defendant.