good faith basis for Plaintiffs lack of credibility. To hold otherwise would be to sanction “virtually no limits on discovery once a party invokes the mantra of ‘credibility’ as the basis for a discovery request.” Barrington, 2007 WL 4370647, at *5; see also Chamberlain, 2007 WL 2786421, at *3 (“[T]he Defendant has not alleged any reason to believe that the Plaintiff has misrepresented information during the course of this litigation with regard to his previous employment to substantiate such a broad search of his employment records on this ground.”); Premer v. Corestaff to prove specific instances of a witness’s conduct in order to attack or support the witness’s character for truthfulness.” Fed. R.Evid. 608(b); see also Hango v. Royall, 466 Fed.Appx. 30, 34 (2d Cir.2012) (<HOLDING>). Additionally, before admitting any such
holding that apparel cleaners submission of false statements of their receipts a percentage of which were to be paid to the united states did not constitute false claims within the meaning of the federal false claims act holding both that a defendants prior disciplinary history was properly precluded because it did not involve an element of deceit or falsification and that defendants earlier allegedly false statements could not be admitted because proving their falsehood would have required the introduction of extrinsic evidence showing the statements made to be false recognizing that evidence of government knowledge of the defendants conduct could be part of a defendants argument that it did not knowingly submit false claims holding that false statements are constitutionally protected holding that an attorney who made false representations to a court did not violate okla rpc 33 because that rule addresses professional misconduct as an advocate for making false statements to a tribunal not false statements by a lawyer as a witness