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- Geraldine Hughes -

course, he charged them with slander and libelous statements
which he claimed exposed him to hatred, contempt, and ridi-
cule. He claimed to have suffered loss of reputation, shame,
mortification, embarrassment and humiliation.
Mr. Rothman was no match for Michael Jackson's new law
firm, Katten Machin & Zavis. During the course of his litiga-
tion efforts against the defendants, Mr. Rothman made a lot of
litigation errors which Michael Jackson's attorneys were quick
to point out and correct openly in court. At this time Mr.
Rothman was being represented by Wylie A. Aitken. The mo-
tion was taken off calendar pursuant to a request of the mov-
ing party on November 4, 1993.
Mr. Rothman failed and refused to attend his noticed depo-
sition repeatedly, thereby causing Michael Jackson's attorneys
to file a motion to compel the deposition of Mr. Rothman, as
well as request sanctions. Mr. Rothman claimed attorney/cli-
ent privilege as his basis for not attending the noticed deposi-
tion. Michael Jackson's attorneys admonished him that he
should have obtained a waiver of privilege before filing the
within action, and that he should either obtain the waiver or
dismiss the case.
On January 8, 1994, a Request for Judicial Notice was filed
and set for hearing on February 2, 1994, concurrently with a
Motion to Strike plaintiff's (Rothman's) second amended veri-
fied complaint. In a Stipulation re Taking Off Calendar Mo-
tion filed by Mr. Weitzman and Mr. Katten, the key points
stated that Michael Jackson had already dismissed Mr.
Weitzman and Mr. Katten from the case. It further stated that
the Motion to Strike was not the most desirable vehicle to bring
before the Court the parties' dispute regarding the meaning
and intent of the Agreement. Mr. Weitzman & Mr. Katten rec-
ommended that Mr. Rothman should file a Motion for Leave
to amend his Second Amended Verified Complaint if he
wanted to name Mr. Weitzman and Mr. Katten as Doe defen-
dants as the appropriate vehicle for presenting to the Court
the parties' dispute. The Court granted the Motion to Compel

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