ARGUMENT

            The Court should hold defendant in contempt a second time for continuing to willfully disobey discovery orders, falsify sworn financial statements, and conceal assets of great value from the plaintiff and the Court.  Plaintiff’s second Complaint for civil contempt is based on three (3) categories of assets which the defendant continues to intentionally conceal from the Court: (1) scholarships, grants, and tax credits substantially reducing the tuition costs at issue in the underlying litigation; (2) bank statements; and (3) real property.