20160516 final for filing motion for leave to file...

Exhibit 1

Case 3:15-cv-00023-GEC Document 83-1 Filed 05/16/16 of 51 Pageid#: 1717

1

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA

Charlottesville Division

NICOLE P. ERAMO

Plaintiff

v.

ROLLING STONE LLC, SABRINA RUBIN ERDELY, and WENNER MEDIA LLC,

Defendants.

) ) ) ) ) ) ) ) ) ) ) )

Case No. 3:15-cv-00023-GEC

PLAINTIFF’S SUPPLEMENTAL BRIEF IN SUPPORT OF HER MOTION FOR AN

ORDER TO SHOW CAUSE AND TO COMPEL COMPLIANCE WITH RULE 45 SUBPOENA AND COURT ORDER

Movant Nicole Eramo, Plaintiff in the case of Eramo v. Rolling Stone LLC, et al., No.

3:15-cv-00023-GEC, hereby submits this Supplemental Brief in Support of her Motion for an

Order to Show Cause and to Compel Compliance with Rule 45 Subpoena and Court Order of

January 25, 2016 in order to notify this Court of relevant and conclusive additional evidence

obtained on April 23, 2016 to the instant motion. This new evidence received after Plaintiff had

filed her Reply Brief to this motion shows that nonparty Respondent “Jackie” (1) created the

pseudonym or alias “Haven Monahan;” (2) communicated with Ryan Duffin and other

individuals previously disclosed by Jackie to Rolling Stone about, and while posing as, the

fictitious “Haven Monahan;” (3) has or had possession, custody, or control over such

communications; and (4) has not been forthcoming with Plaintiff and this Court in asserting that

she has produced all responsive documents in her possession to Plaintiff in response to the Rule

45 Subpoena and this Court’s Order without at least providing an explanation for why she does


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not have possession of responsive documents. This new evidence, in addition to the compelling

justifications set forth by Plaintiff in her Memorandum of Law in Support of her Motion for an

Order to Show Cause and to Compel Compliance with Rule 45 Subpoena and Court Order of

January 25, 2016 [Dkt. 64] and her Reply Brief in Support of her Motion for an Order to Show

Cause and to Compel Compliance with Rule 45 Subpoena and Court Order of January 25, 2016

[Dkt. 78] (“Reply Brief”), leads to only one logical conclusion: that Jackie is “Haven Monahan”

and has either not produced all responsive documents to Plaintiff’s Rule 45 Subpoena in her

possession and therefore is not in compliance with this Court’s January 25, 2016 Order or owes

Plaintiff and this Court an explanation for why she is no longer in possession of responsive

documents.

PROCEDURAL AND FACTUAL BACKGROUND

“Jackie” was the central figure and main source for an article published in Rolling Stone

magazine in November 2014 entitled, “A Rape on Campus: A Brutal Assault and Struggle for

Justice at UVA.” Jackie claimed that she was sexually assaulted by someone named “Haven

Monahan.” On October 3, 2012, “Haven Monahan” sent an email to third-party Ryan Duffin,

with who “Haven” and Jackie had also been communicating via text message.

On February 16, 2016, Jackie produced some documents in response to Plaintiff’s Rule

45 Subpoena after this Court had ordered her to do so. (See Court Order, Eramo v. Rolling Stone

LLC, No. 3:15-MC-00011 (Jan. 25, 2016) (“Order”) [Dkt. 35]; See Mem. Op., No. 3:15-mc-

00011 (Jan. 25, 2016) [Dkt. 34]). After waiting a month for additional documents, counsel for

Plaintiff wrote to Jackie’s counsel, identifying “Haven Monahan” documents that are known to

exist but that Jackie has failed to produce, explaining that the Court’s order requires the

production of those documents, and citing evidence showing that Jackie was the author of these


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communications and thus is, or at one time had been, in possession of responsive documents.

(See Letter from Andrew Phillips to Rebecca Anzidei and Phil O’Beirne (Mar. 16, 2016) (“Mar.

16, 2016 Letter”) (Attached hereto as Ex. A)). Plaintiff’s counsel demanded that Jackie produce

documents responsive to Demand No. 15 as ordered by this Court. Plaintiff’s counsel further

demanded that if Jackie claimed to no longer be in possession of documents known to have been

in her custody, then her counsel needed to provide an explanation of the bases for the claim that

Jackie was no longer in possession of the documents, such as an explanation of the

circumstances of any deletion of the documents, and a description of the efforts undertaken to

search for and recover the documents. (See id.) Additionally, Plaintiff’s counsel requested that if

Jackie’s counsel contends that she was not the author of any of the “Haven Monahan”

communications sought in Demand No. 15 — despite the overwhelming evidence that she was

— then her counsel needed to provide some explanation of the basis for that belief. (See id.).

On March 17, 2016, counsel for Jackie responded to Plaintiff’s counsel’s letter asserting

simply that Jackie had produced all documents in her possession, custody, or control without any

explanation. (See Letter from Rebecca Anzidei to Andrew Phillips (Mar. 17, 2016) (“Mar. 17,

2016 Letter”) (Attached hereto as Ex. B)). Counsel for Plaintiff again requested a formal written

response describing the circumstances for withholding responsive documents and an explanation

for any claim that responsive documents are no longer in Jackie’s possession on March 17, 2016

and on March 21, 2016 (See Emails Between Andrew Phillips and Rebecca Anzidei (Mar. 17,

2016, 11:31 PM EDT, Mar. 21, 2016, 4:25 PM EDT, and Mar. 22, 2016, 7:51 PM EDT) (“March

17-22, 2016 Emails”) (Attached hereto as Ex. C)). Jackie’s counsel once again responded

simply that she had provided all responsive documents to the Subpoena in her possession without

further explanation. (See March 17-22, 2016 Emails). The instant motion followed.


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Jackie filed her Opposition to Plaintiff’s motion on April 12, 2016, in which she once

again stated and certified to this Court that she had produced all responsive documents to

Plaintiff’s Rule 45 Subpoena and this Court’s Order and without in any way addressing the

merits of the relevant question; whether Jackie authored the “Haven Monahan” communications

and if so, why she is unable to produce them. (See Non-party Resp.’s Opp’n to Mot. for Order to

Show Cause and to Compel Compliance with Rule 45 Subpoena and Court Order (“Jackie’s

Opp’n Brief”) [Dkt. 77]). On April 19, 2016, Plaintiff timely filed her Reply Brief to Nonparty

Respondent “Jackie’s” Opposition to Plaintiff’s Motion for an Order to Show Cause and to

Compel Compliance with the Rule 45 Subpoena and Court Order of January 25, 2016. (See Pl.’s

Reply Brief to Non-party Resp.’s Opp’n to Mot. for Order to Show Cause and to Compel

Compliance with Rule 45 Subpoena and Court Order (“Reply Brief”) [Dkt. 78]). Plaintiff’s

Reply Brief noted, among other things, that Jackie’s counsel had failed to offer any explanation

for their failure to produce the email Jackie authored using the email account

[email protected], despite the fact that producing the email should require no more

than simply accessing the account using the username and password Jackie used to create it. See

id. at 1-4.

On March 30, 2016, in order to obtain additional and conclusive evidence that Jackie is

currently or was at one time in possession of communications from “Haven Monahan,” Plaintiff

issued a subpoena to third party Yahoo! Inc. (“Yahoo”) requesting information associated with

the email account, “[email protected].” (See March 30, 2016 Yahoo Subpoena

(Attached hereto as Ex. D)). On April 23, 2016, four days after Plaintiff filed her Reply Brief,

Plaintiff received Yahoo’s production in response to the subpoena. (See April 20, 2016 Yahoo

Subpoena Response (“Yahoo Response”) (Attached hereto as Ex. E)). Yahoo’s response


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included information regarding the email account “[email protected],” including IP

addresses from which the email was accessed and dates and times on which the email was

accessed from those IP addresses. See id.

After reviewing the information in Yahoo’s response, Plaintiff sent a letter to Jackie’s

counsel on May 2, 2016 which included the documents produced by Yahoo and yet another

demand to comply with this Court’s Order and produce the “Haven Monahan” documents in

Jackie’s possession. (See Letter from Andrew Phillips to Rebecca Anzidei and Phil O’Beirne

(May 2, 2016) (Attached hereto as Ex. F)). Jackie’s counsel responded on May 6, 2016, once

again stating that they had “produced the documents responsive to the Court’s January 25, 2016,

Order and Opinion, that [Jackie] has in her possession, custody or control” and that “Respondent

is not withholding any responsive, non-privileged documents.” (See Letter from Rebecca

Anzidei to Andrew Phillips (May 6, 2016) (Attached hereto as Ex. G)). Plaintiff’s Motion for

Leave to file this Supplemental Brief followed.

ADDITIONAL EVIDENCE THAT PROVES THAT JACKIE IS “HAVEN MONAHAN”

Yahoo’s response to Plaintiff’s subpoena noted that the email

“[email protected]” was created on October 2, 2012 from the IP address

199.111.183.134. (See Yahoo Response). That IP address is “found in Charlottesville, Virginia”

and “is allocated to University of Virginia.” (See 199.111.183.134 IP address Information

(Attached hereto as Ex. H)).1 Ryan Duffin received an email from

“[email protected]” on October 3, 2012, just one (1) day after the email was created

by someone at the University of Virginia using a University of Virginia IP address. (See Email

1 Also available at http://www.speedguide.net/ip/199.111.183.134.


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from Haven Monahan to Ryan Duffin on October 3, 2012 8:33PM EDT) (Attached hereto as Ex.

I)).

Yahoo’s response also noted that, as of March 30, 2016, the email address

“[email protected]” was last accessed on March 18, 2016 from the IP address

199.119.116.162. (See Yahoo Response). That IP address is “found in Washington, District of

Columbia” and “is allocated to ALTG, Stein, Mitchell, Muse & Cipollone LLP.” (See

199.119.116.162 IP address Information (Attached hereto as Ex. J)).2 Someone at Stein,

Mitchell, Muse & Cipollone LLP, Jackie’s counsel, accessed the “[email protected]”

email account two (2) days after Plaintiff’s counsel sent a letter questioning why the email had

not been produced and one (1) day after Jackie’s counsel replied affirming that they had

produced all documents in Jackie’s possession responsive to Plaintiff’s Rule 45 Subpoena as

ordered by this Court. (See Mar. 16, 2016 Letter; see Mar. 17, 2016 Letter). And on March 22,

2016, four (4) days after accessing the “[email protected]” email account, Jackie’s

counsel once again asserted that Jackie was not in possession of these emails and that Jackie had

produced all responsive documents in her possession. (See Mar. 17-22, 2016 Emails).

The location of the IP addresses used to create and access the

“[email protected]” email account, as well as the timing of access leads to only one

logical conclusion: Jackie is “Haven Monahan.” Jackie created the email account

“[email protected]” at the University of Virginia one day before she sent her email

pretending to be “Haven” to Ryan Duffin. Jackie’s counsel, knowing full-well that Jackie is

“Haven Monahan” and has access to the account herself, also knew how to access the account

themselves and did so on March 18, 2016. Despite this, Jackie’s counsel continues to assert on

2 Also available at http://www.speedguide.net/ip/199.119.116.162.


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behalf of their client to Plaintiff’s counsel and in documents they submitted to this Court that

Jackie has complied with this Court’s Order. Jackie’s counsel has asserted and affirmed to

Plaintiff and this Court that Jackie produced all documents responsive to her Rule 45 Subpoena

on at least five (5) separate occasions in writing: (1) Jackie’s initial certification on February 16,

2016 that she had produced all responsive documents in her possession; (2) Jackie’s counsel’s

March 17, 2016 response to Plaintiff’s letter; (3) Jackie’s counsel’s March 22, 2016 response to

Plaintiff’s email; (4) Jackie’s Opposition Brief filed with this Court on April 12, 2016; and (5)

Jackie’s counsel’s May 6, 2016 response to Plaintiff’s letter. Because Jackie is “Haven

Monahan” and both she and her counsel currently have access to the

“[email protected]” email account, she must stop the charade that she has complied

with Plaintiff’s Rule 45 Subpoena and this Court’s Order and finally produce documents

responsive to Plaintiff’s requests, or at minimum, explain why she is no longer in possession of

those documents.

CONCLUSION

For the forgoing reasons, Plaintiff respectfully repeats its request that this Court grant

Plaintiff Nicole Eramo’s Motion for an Order to Show Cause and to Compel Compliance with

Rule 45 Subpoena and Court Order of January 25, 2016.

Dated: May 16, 2016 Respectfully submitted,

By: /s/ Thomas A. Clare_____________ Thomas A. Clare (VA Bar No. 39299) Elizabeth M. Locke (VA Bar No. 71784) Andrew C. Phillips (VA Bar No. 88880) CLARE LOCKE LLP 902 Prince Street Alexandria, Virginia 22314


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Telephone: (202) 628-7400 [email protected] [email protected] [email protected]

ATTORNEYS FOR PLAINTIFF NICOLE ERAMO


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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of Nicole Eramo’s Reply Brief in Support of

Her Motion for an Order to Show Cause and to Compel Compliance with Rule 45 Subpoena and

Court Order of May 16, 2016 was served on the below counsel of record on May 16, 2016 via

ECF (for those attorneys that have registered), or by email and Federal Express (for those

attorneys that have not).

Pat A. Cipollone Rebecca R. Anzidei Philip J. O’Beirne Stein Mitchell Cipollone Beato & Missner LLP 1100 Connecticut Avenue N.W., Suite 1100 Washington, D.C. 20036 Telephone: (202) 737-7777 Fax: (202) 296-8312 Email: [email protected] [email protected] Email: [email protected] Palma Pustilnik Staff Attorney Central Virginia Legal Aid Society 1000 Preston Avenue, Suite B Charlottesville, VA 22903 Telephone: (434) 327-1443 Fax: (434) 296-5731 Email: [email protected] Attorneys for Nonparty Respondent “Jackie” Michael John Finney William David Paxton Gentry Locke Rakes & Moore P.O. Box 40013 Roanoke, VA 24022-0013 Telephone: (540) 983-9373 Telephone: (540) 983-9334 Fax: (540) 983-9400 Email: [email protected] Email: [email protected] Elizabeth A. McNamara


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Samuel M. Bayard Davis Wright Tremaine LLP 1251 Avenue of the Americas 21st Floor New York, New York 10020 Telephone: (212) 489-8230 Fax: (212) 489-8340 Email: [email protected] Email: [email protected] Alison B. Schary DAVIS WRIGHT TREMAINE LLP 1919 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006-3401 Telephone: (202) 973-4248 Fax: (202) 973-4448 E-mail: [email protected] Attorneys for Defendants Rolling Stone LLC, Sabrina Rubin Erdely, and Wenner Media LLC Benjamin Gaillard Chew MANATT, PHELPS & PHILLIPS, LLP 1050 Connecticut Avenue, NW, Suite 600 Washington, DC 20036-5303 Telephone: (202) 585-6511 Email: [email protected] Attorney for Defendant Sabrina Rubin Erdely

Dated: May 16, 2016 By: /s/ Thomas A. Clare______ Thomas A. Clare


Exhibit A


ANDREW C. PHILLIPS [email protected]

(202) 628-7404

902 Prince Street Alexandria, Virginia 22314

(202) 628-7400

www.clarelocke.com

!! March 16, 2016 !

Via Email

Rebecca Anzidei Phil O’Beirne Stein Mitchell Cipollone Beato & Missner LLP [email protected] [email protected]

Re: Eramo v. Rolling Stone LLC, et al., No. 3:15-mc-00011

!Dear Rebecca and Phil:

I write to meet and confer with respect to deficiencies in your client “Jackie’s” document production to Plaintiff Nicole Eramo in the above-referenced case. It appears that Jackie has not complied with Plaintiff’s Rule 45 document subpoena or the Court’s Order regarding same.

As you know, following extensive briefing on Plaintiff’s Motion to Compel Nonparty Respondent “Jackie” to Comply with Rule 45 Subpoena, Judge Conrad issued an Order directing Jackie and her counsel to produce certain documents to Plaintiff. (See Jan. 25, 2015 Order, No. 3:15-mc-00011 [Dkt. 35] (“Order”); and Jan. 25, 2016 Memorandum Opinion, No. 3:15-mc-00011 [Dkt. 34] (“Memorandum Opinion”).) Specifically, Judge Conrad ordered Jackie to produce “communications between ‘Haven Monahan’ and Ryan Duffin, communications between ‘Haven Monahan’ and any other individual whose name was previously disclosed to defendants, and communications between Jackie and any disclosed individual that mentions ‘Haven Monahan…’” (Order at 1.) In the Memorandum Opinion, Judge Conrad specifically held that any communications authored by Jackie under the pseudonym “Haven Monahan” with Ryan Duffin, as well as any communications between “Haven Monahan” and any other individual whose name Jackie provided to Rolling Stone, “are within a reasonable scope of discovery.” (Mem. Op. at 10.)

At the time of the Order, Jackie and her counsel were well aware that Plaintiff is in possession of documents showing voluminous text messages between Ryan Duffin and an individual claiming to be “Haven Monahan” — indeed, these exchanges were attached as exhibits


2!

to documents filed with the Court. Contemporaneous text message exchanges between Mr. Duffin and Jackie — also filed with the Court — show that Jackie repeatedly claimed to Mr. Duffin that she was also engaged in exchanging text messaged with a “Haven Monahan” during the same time period that Mr. Duffin was texting with the purported “Haven Monahan.”

Without belaboring the point, Jackie and her counsel are plainly aware that Plaintiff has presented compelling evidence to the Court — corroborated by the investigative findings of the Charlottesville Police Department, innumerable media reports, and statements by Mr. Duffin, Alex Stock, and Kathryn Hendley — that no person by the name of “Haven Monahan” exists, and that Jackie herself sent these text messages to Mr. Duffin while posing as the fictitious “Haven Monahan.” Plaintiff has also provided to the Court an email from a yahoo.com email address that was purportedly sent to Mr. Duffin by “Haven Monahan,” attaching an email that Jackie supposedly sent to “Haven Monahan.” Mr. Duffin has produced conclusive records of all of these communications in response to a subpoena.

Glaringly absent from Jackie’s document production are any “Haven Monahan” documents whatsoever. Jackie has not produced her text messages with Mr. Duffin referencing “Haven Monahan” that are known to exist, despite the unambiguous Court Order directing her to do so. Jackie has not produced the communications she authored posing as “Haven Monahan” while communicating with Mr. Duffin; again, in direct defiance of the Court’s Order. Jackie has not produced any of the texts she claimed to Mr. Duffin she was exchanging with “Haven Monahan.” And Jackie has not produced the email that she purportedly sent to “Haven Monahan,” or the subsequent email she sent to Mr. Duffin while posing as “Haven Monahan.”

The Court’s Order was unambiguous in requiring that these documents be produced. Their existence has been confirmed by productions from other nonparties. The only conclusion that can be drawn from the failure to produce these documents is that Jackie is in open defiance of the Court’s mandate. We have received no communication from you, Jackie’s counsel, stating that these documents are being withheld for any reason, or that they have been deleted, or otherwise offering any explanation for failing to produce them.

In light of these facts, we must demand that you immediately comply with the Court’s Order and produce any and all such documents. If the documents in question have been deleted or discarded for any reason, or are for any other reason no longer accessible to Jackie, please inform us of that fact immediately and explain the circumstances under which these documents were deleted or discarded. If you claim that any such documents are not in Jackie’s possession, custody, or control, please explain the basis for this belief and the efforts you have undertaken to search for and recover these documents. Finally, if you contend that Jackie did not author any communications under the pseudonym “Haven Monahan” despite overwhelming evidence that she did, please so state explicitly and explain, as an officer of the Court, your basis for this belief.

Please consider this correspondence an attempt to meet and confer regarding this issue. Considering the short time period before Jackie’s deposition, and especially considering the outrageous attacks you have lobbed at Dean Eramo and her counsel before the Court — despite all of our efforts to cooperate with and accommodate Jackie — I request that you provide a meaningful


3!

response to this correspondence no later than this Thursday, March 17. Failure to do so will leave us with no choice but to file a motion with the Court. If we must file a motion regarding this issue, we will specifically demand a finding of contempt under Federal Rule of Civil Procedure 45(g), as well as reimbursement of all costs and fees that are compulsory under Rule 37(b).

I look forward to your prompt response.

Very truly yours,

Andrew C. Phillips


Exhibit B


1100 Connecticut Avenue, NW Suite 1100 Washington, DC 20036

P 202.737.7777F 202.296.8312

www.steinmitchell.com

REBECCA R. ANZIDEI [email protected] | Direct 202.661.0921

March 17, 2016 Andrew Phillips Clare Locke LLP 902 Prince Street Alexandria, VA 22314 Re: Eramo v. Rolling Stone LLC, et al., No. 3:15-mc-00011 Dear Andrew, I write in response to your letter from yesterday regarding the scope of the production that we completed on February 16, 2016, and demanding a response by today. As an initial matter, we disagree with your characterization of your conduct to date. We are not aware of any good faith efforts on your part to cooperate with or accommodate Jackie, including the most recent examples of refusing to move the deposition date when you were aware that counsel was not available on the requested date, or agreeing to hold the deposition in a mutually convenient location requested by third-party Respondent, despite agreeing to travel thousands of miles for the depositions of other third parties.

Further, your threat of contempt is outrageous and improper. You have

absolutely no good faith basis to allege that Respondent has failed to comply with the Court’s January 25, 2016, Order and Opinion. Your letter is the first time Plaintiff even raised a question about the production, and makes this baseless threat without even giving us an opportunity to respond. In addition, there has been no attempt to have a conversation about the content of our production prior to this letter, despite you having parts of our production for over six weeks, and all of our production for a month. Frankly, these bullying tactics are part of a disturbing pattern, are unnecessary and have no place in the professional environment. With regard to the substance of your letter, we have taken the necessary and appropriate steps to collect, maintain and produce documents consistent with our discovery obligations. Respondent has produced the documents responsive to the Court’s January 25, 2016, Order and Opinion, that she has in her possession. To be


Stein Mitchell Cipollone Beato & Missner LLP Andrew Phillips March 17, 2016 Page 2 of 2 clear, Respondent is not withholding any responsive documents relating to the category identified in your letter. Respondent has complied with her discovery obligations. There is no good faith basis to file a motion to compel or seek contempt and any such motion would be frivolous and a waste of the Court’s time and resources, as well as ours. We are available to discuss this further if you would like to meet and confer on these issues.

Sincerely, /s/ Rebecca Ruby Anzidei

Rebecca Ruby Anzidei


Exhibit C


From: Rebecca Anzidei [email protected]: Re: Eramo v. Rolling Stone LLC, at al.: Mot for Additional Time to Depose Jackie

Date: March 22, 2016 at 7:51 PMTo: Andy Phillips [email protected]: Phil O'Beirne [email protected]

Andy,

To(be(clear,(I(never(stated(that(I(was(seeking(a(nego8a8on.((I(simply(thought(that(a(phone(conversa8on(would(

be(more(produc8ve(and(efficient.((Given(you(refusal(to(talk,(I(will(respond(in(wri8ng.((Contrary(to(your(

statements(otherwise,(we(answered(your(ques8ons(in(a(leBer(sent(on(March(17th.((Respondent(has(produced(

the(relevant,(responsive(documents(in(her(possession,(custody,(and(control.((She(has(fully(complied(with(the(

Court’s(Order(and(Opinion(regarding(the(Rule(45(document(subpoena(issued(by(Plain8ff.((As(we(have(already(

explained,(Respondent(is(not(withholding(any(responsive,(nonOprivileged,(documents.((

We(con8nue(to(believe(that(any(mo8on(filed(with(the(Court(would(be(baseless(and(a(waste(of(8me(and(

resources.

Thank(you,

Rebecca

Rebecca Ruby AnzideiStein Mitchell Cipollone Beato & Missner LLP1100 Connecticut Ave, NW Suite 1100Washington, DC 20036D 202.661.0921 C 202.489.7182F [email protected]


(

***********************************************************The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Stein Mitchell Cipollone Beato & Missner LLP. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by reply or by telephone at (202) 737-7777, and immediately destroy this communication and all copies thereof, including all attachments. IRS Circular 230 Disclosure:To ensure compliance with requirements imposed by the U.S. Internal Revenue Service, we inform you that any tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding tax-related penalties under the U.S. Internal Revenue Code or (2) promoting, marketing or recommending to another party any tax-related matters addressed herein.***********************************************************

From:&Andy(Phillips(<[email protected]>

Date:&Monday,(March(21,(2016(at(4:25(PM

To:&Rebecca(Anzidei(<[email protected]>

Cc:&Phil(O'Beirne(<[email protected]>

Subject:&Re:(Eramo(v.(Rolling(Stone(LLC,(at(al.:(Mot(for(Addi8onal(Time(to(Depose(Jackie


mailto:[email protected]




mailto:O'[email protected]

mailto:O'[email protected]


http://www.steinmitchell.com/





Rebecca,

There(is(no(requirement(that(a(meet(and(confer(occur(by(telephone.((This(is(now(the(third(message(I’ve(had(to(

write(you(asking(for(simple(answers(to(the(straigh`orward(ques8ons(I(have(raised(about(your(compliance(with(

the(Court’s(order.((I(want(to(note(that(this(is(not(just(a(standard(discovery(dispute(about(the(scope(of(an(RFP(or(

whether(certain(documents(are(relevant.((I(am(mee8ng(and(conferring(in(the(sense(that(I(have(to,(and(I(want(

to,(give(you(an(opportunity(to(explain(the(deficiency(or(how(soon(you(intend(to(correct(it.((But(to(be(clear,(this(

isn’t(a(nego8a8on.((There(is(an(outstanding,(unambiguous(court(order(that(requires(you(to(produce(certain(

documents(that(you(and(I((and(the(Court)(know(exist.((You(have(not(produced(those(documents.((You(have(not(

told(me(why(you(have(not(produced(those(documents.((You(have(not(told(me(when(you(expect(to(produce(

those(documents.((Short(of(you(answering(the(very(simple(ques8ons(I(have(posed(to(you(in(now(three(

leBers/emails,(there(really(isn’t(much(to(confer(about.((I(don’t(need(a(long(leBer.((I(just(need(some(answers(

that(I(haven’t(goBen.((So(again,(I(respec`ully(request(that(you(address(these(issues(in(wri8ng(so(that(there(is(

no(ambiguity(with(respect(to(your(posi8on(and(so(that(the(Court(has(a(proper(record(to(consider(that(posi8on(

should(a(mo8on(be(necessary.((We(intend(to(file(a(mo8on(with(the(Court(this(week(unless(I(hear(from(you.(

Thanks.

Andy Phillips | Senior AssociateC L A R E L O C K E L L P902 Prince Street | Alexandria, Virginia 22314(202) 628-7404 - direct | (847) 951-7093 - [email protected] | www.clarelocke.comAdmitted to practice in the Commonwealth of Virginia, the District of Columbia and the State of Illinois.

On(Mar(21,(2016,(at(4:03(PM,(Rebecca(Anzidei(<[email protected]>(wrote:

Andy,

It’s(disappoin8ng(that(you(will(not(make(the(8me(to(meet(and(confer(over(the(phone.((I(ohen(find(that(it(is(

much(more(produc8ve(than(having(to(write(leBers(or(emails(back(and(forth.((I(ask(that(you(reconsider,(as(I(do(

not(think(it(will(take(very(long.

Thanks(so(much,

Rebecca



(

***********************************************************The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Stein Mitchell Cipollone Beato & Missner LLP. If the reader of this message is not the


tel:%28202%29%20628-7403

tel:%28202%29%20280-4454


http://www.clarelocke.com/




property of Stein Mitchell Cipollone Beato & Missner LLP. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by reply or by telephone at (202) 737-7777, and immediately destroy this communication and all copies thereof, including all attachments. IRS Circular 230 Disclosure:To ensure compliance with requirements imposed by the U.S. Internal Revenue Service, we inform you that any tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding tax-related penalties under the U.S. Internal Revenue Code or (2) promoting, marketing or recommending to another party any tax-related matters addressed herein.***********************************************************


Date:&Sunday,(March(20,(2016(at(12:26(PM


Cc:&Phil(O'Beirne(<[email protected]>


Rebecca,

I(am(very(busy(tomorrow(preparing(for(upcoming(deposi8ons.((And(I(would(prefer(that(you(respond(to(my(

leBer(and(email(in(wri8ng(so(that(there(is(no(ambiguity(regarding(your(posi8on(on(this,(and(so(that(there(is(a(

clear(record(of(it.((Thanks.



Andy,

I(understand(you’re(traveling(today.((What(8me(on(Monday(are(you(available(to(talk?

Thanks,

Rebecca







tel:%28202%29%20628-7403

tel:%28202%29%20280-4454







(

***********************************************************The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Stein Mitchell Cipollone Beato & Missner LLP. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by reply or by telephone at (202) 737-7777, and immediately destroy this communication and all copies thereof, including all attachments. IRS Circular 230 Disclosure:To ensure compliance with requirements imposed by the U.S. Internal Revenue Service, we inform you that any tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding tax-related penalties under the U.S. Internal Revenue Code or (2) promoting, marketing or recommending to another party any tax-related matters addressed herein.***********************************************************


Date:&Thursday,(March(17,(2016(at(11:31(PM


Cc:&Phil(O'Beirne(<[email protected]>,(Tom(Clare(<[email protected]>,(Libby(

Locke(<[email protected]>


Rebecca,

I(am(simply(not(going(to(par8cipate(in(your(campaign(of(vitriol(and(recrimina8ons.((That(is(not(how(I(

prac8ce.((I(am(going(to(s8ck(to(the(facts(and(the(requirements(of(an(outstanding(order(from(a(federal(court.((

Respec`ully,(this(leBer(strikes(me(as(a(transparent(aBempt(at(burdenOshihing(and(deflec8ng.((It(is(not(our(

obliga8on(to(discover(deficiencies(in(Jackie’s(produc8on;(rather,(it(is(your(obliga8on(to(comply(with(the(

Court’s(Order.((The(Order(is(clear.((ALL(communica8ons(between(Jackie(and(Ryan(Duffin(rela8ng(to(“Haven(

Monahan”(must(be(produced.((We(know(such(communica8ons(exist,(because(Mr.(Duffin(has(produced(such(

communica8ons(between(he(and(Jackie.((ALL(communica8ons(authored(by(Jackie(using(the(pseudonym(

“Haven(Monahan”(must(be(produced.((We(know(such(communica8ons(exist(because(Mr.(Duffin(has(

produced(them(and(all(available(evidence(leaves(liBle(room(for(doubt(that(there(is(no(Haven(Monahan(—(

these(texts(and(emails(were(clearly(authored(by(Jackie.((We(also(know(that(Jackie(told(Mr.(Duffin(via(text(

messages(that(she(was(herself(exchanging(text(messages(with(Haven(Monahan.((And(we(know(that(Jackie(

sent(an(email(to(the(purported(“Haven(Monahan,”(which(“Haven(Monahan”(then(forwarded(to(Mr.(Duffin(

from(a(yahoo.com(email(account.((Again,(Mr.(Duffin(produced(this(communica8on(and(we(aBached(it(in(a(

filing(with(the(Court(that(you(received.((But(you(have(not(produced(any(of(these(documents.

Again,(respec`ully,(your(leBer(addresses(none(of(my(ques8ons.((It(quite(conspicuously(avoids(men8oning(

“Haven(Monahan”(altogether.((So(I(ask(again:(Why(have(you(not(produced(these(communica8ons(that(are(

known(to(exist(and(that(are(required(to(be(produced(by(the(Court’s(Order?((Has(Jackie(deleted(them?((If(so,(

when?((If(so,(what(efforts(have(you(undertaken(to(discover(and/or(recover(them?((It(is(not(difficult(to(

recover(deleted(iPhone(messages(—(I(have(done(it(myself(many(8mes(in(discovery.((Or,(do(you(contend(as(

an(officer(of(the(court(that(Jackie(did(not(author(the(“Haven(Monahan”(texts(and(emails?((If(so,(what(is(

your(basis(for(that(conten8on(in(the(face(of(a(mountain(of(contrary(evidence?








http://yahoo.com/

your(basis(for(that(conten8on(in(the(face(of(a(mountain(of(contrary(evidence?

The(Court’s(Order(on(these(issues(is(crystal(clear.((Unless(you(provide(a(meaningful(response(to(these(very(

straigh`orward(ques8ons,(you(leave(us(with(no(choice(but(to(file(a(mo8on(with(the(Court(to(enforce(the(

outstanding(order(that(I(absolutely(believe(you(are(not(in(compliance(with.((If(we(must(do(so,(we(will(

request(that(we(reimbursed(the(costs(and(fees(associated(with(such(a(mo8on.((And(we(will(request(any(and(

all(other(appropriate(relief.((I(am(trying(my(best(to(confer(with(you(in(good(faith(but(frankly(the(deficiency(is(

glaring(and(you(cannot(avoid(it(simply(by(making(unwarranted(and(uncalled(for(aBacks.((I(would(really(

prefer(not(to(bother(the(Court(with(this,(so(please(just(address(the(actual(issues(at(hand(so(we(can(resolve(

this.

Thanks,(



Andy,

Please(see(the(aBached(leBer.

Thanks,

Rebecca



(

***********************************************************The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Stein Mitchell Cipollone Beato & Missner LLP. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by reply or by telephone at (202) 737-7777, and immediately destroy this communication and all copies thereof, including all attachments. IRS Circular 230 Disclosure:To ensure compliance with requirements imposed by the U.S. Internal Revenue Service, we inform you that any tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, by any


tel:%28202%29%20628-7403

tel:%28202%29%20280-4454






taxpayer for the purpose of (1) avoiding tax-related penalties under the U.S. Internal Revenue Code or (2) promoting, marketing or recommending to another party any tax-related matters addressed herein.***********************************************************


Date:&Tuesday,(March(15,(2016(at(12:37(PM

To:&Rebecca(Anzidei(<[email protected]>,(Phil(O'Beirne(

<[email protected]>,(Palma(Pus8lnik(<[email protected]>

Subject:&Service:(Eramo(v.(Rolling(Stone(LLC,(at(al.:(Mot(for(Addi8onal(Time(to(Depose(Jackie

Counsel,

Plain8ff(filed(the(aBached(mo8on(and(memorandum(today(in(the(US(District(Court(for(the(Western(

District(of(Virginia.

<2016.03.17(RRA(Ltr(to(A.(Phillips.pdf>






Exhibit D


Exhibit E


Exhibit F


ANDREW C. PHILLIPS [email protected]

(202) 628-7404

902 Prince Street Alexandria, Virginia 22314

(202) 628-7400

www.clarelocke.com

May 2, 2016

Via Email

Rebecca Anzidei Phil O’Beirne Stein Mitchell Cipollone Beato & Missner LLP [email protected] [email protected]

Re: Eramo v. Rolling Stone LLC, et al., No. 3:15-cv-00023

Dear Rebecca and Phil:

I write to follow up on Plaintiff’s pending Motion for an Order to Show Cause and to Compel Compliance with Rule 45 Subpoena and Court Order. As you know, Plaintiff’s Motion and accompanying Memorandum assert that Respondent has failed to comply with the Court’s January 25, 2016 Order requiring Jackie to produce certain documents relating to the fictitious “Haven Monahan.” In both the Memorandum and related correspondence, Plaintiff has repeatedly noted that, among other things, you have not produced text and email communications Jackie sent while posing as “Haven Monahan,” even though the Court’s Order requires that such documents be produced. In particular, Plaintiff has noted that Respondent has not produced the email she sent to Ryan Duffin on October 3, 2012 from a [email protected] email account, even though collecting and producing this document would require no more than simply accessing this account using the password Jackie used to create it. Notably, at no time has Respondent ever denied that she sent this email while posing as Haven Monahan.

Plaintiff has recently received the attached response to a subpoena Plaintiff served on Yahoo! Inc. that makes it abundantly clear that Jackie created this email account, and also makes it clear that Respondent and/or her counsel still have the ability to access this account. According to Yahoo!, the [email protected] account was created from an IP Address associated with the University of Virginia on October 2, 2012 — just one day before “Haven Monahan” sent the email in question to Ryan Duffin. Moreover, the account was last accessed from an IP Address in


2

the District of Columbia on March 18, 2016 — just one day after I sent an email to Rebecca Anzidei questioning why the email sent from this account had not been produced. Given these facts, it seems apparent that Respondent and her counsel have the ability to access this account and produce the email that the Court has ordered her to produce, yet have deliberately chosen not to do so. I must again demand that you comply with the Court’s Order, or Plaintiff will have no choice but to file a supplement to the Motion to Show Cause to alert the Court to this information.

I look forward to your prompt response.

Very truly yours,

Andrew C. Phillips


Exhibit G


1100 Connecticut Avenue, NW Suite 1100 Washington, DC 20036

P 202.737.7777F 202.296.8312


REBECCA R. ANZIDEI [email protected] | Direct 202.661.0921

May 6, 2016 Andrew Phillips Clare Locke LLP 902 Prince Street Alexandria, VA 22314 Re: Eramo v. Rolling Stone LLC, et al., No. 3:15-mc-00011 Dear Andrew, I write in response to your May 2, 2016 letter regarding the scope of the production that we completed on February 16, 2016, and that is the subject of a motion to compel that has been fully briefed since April 19, 2016. As we have now explained multiple times, in both correspondence and in pleadings filed with the Court, we have taken the necessary and appropriate steps to collect, maintain and produce documents consistent with our discovery obligations. Respondent has produced the documents responsive to the Court’s January 25, 2016, Order and Opinion, that she has in her possession, custody or control. Respondent is not withholding any responsive, non-privileged documents. Respondent has complied with her discovery obligations and the Court’s Order in every way.

The subpoena response provided with your letter does not alter or change the above facts in any way. As we have repeatedly explained, there is no good faith basis for Plaintiff’s motion and the subpoena response does not justify the submission of any supplement to the Court because it does not contain any new or relevant information. Any such supplement would be frivolous and a waste of the Court’s time and resources, as well as ours, just like your original motion to compel was.

Finally, your letter states that you intend to file a supplement to Plaintiff’s Motion to Show Cause, but Local Rule 11(c)(1) is quite clear that no such filing is appropriate without first obtaining leave of Court. We are not aware of such leave being granted, and will oppose any such request for the reasons stated above. We are available to meet and confer on these issues.

Sincerely, /s/ Rebecca Ruby Anzidei

Rebecca Ruby Anzidei


Exhibit H


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Home » IP lookup » 199.111.183.x » 199.111.183.134

Search IP address or hostname: 199.111.183.134 Your IP address: 50.246.100.194

199.111.183.134 IP address InformationThe IP address 199.111.183.134 was found in Charlottesville, Virginia, United States. It is allocated to University ofVirginia. Additional IP location information, as well as network tools are available below.

IP address: 199.111.183.134hostname: d199183134.bootp.virginia.edu

ISP: University of VirginiaCity: Charlottesville

Region: VirginiaCountry: United States (US)

Postal code: 22901Area code: 434Metro code: 584

latitude: 38.0888longitude: 78.5592

199.111.183.134 Location Map

Notes: Computers connected to a network are assigned a unique number known as Internet Protocol (IP) Address. IP (version 4) addresses consist of four numbers in the range 0255 separated by periods (i.e. 127.0.0.1). A computer may have either a permanent (static) IP address, or one that is dynamically assigned/leased to it.

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Exhibit J


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Home » IP lookup » 199.119.116.x » 199.119.116.162

Search IP address or hostname: 199.119.116.162 Your IP address: 50.246.100.194

199.119.116.162 IP address InformationThe IP address 199.119.116.162 was found in Washington, District of Columbia, United States. It is allocated toALTG, Stein, Mitchell, Muse & Cipollone LLP. Additional IP location information, as well as network tools are availablebelow.

IP address: 199.119.116.162ISP: ALTG

Organization: Stein, Mitchell, Muse & Cipollone LLPCity: Washington

Region: District of ColumbiaCountry: United States (US)

Postal code: 20001Area code: 202Metro code: 511

latitude: 38.9085longitude: 77.0177

199.119.116.162 Location Map

(39.1085, 77.01769999999999)Notes: Computers connected to a network are assigned a unique number known as Internet Protocol (IP) Address. IP (version 4) addresses consist of four numbers in the range 0255 separated by periods (i.e. 127.0.0.1). A computer may have either a permanent (static) IP address, or one that is dynamically assigned/leased to it.

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Miele HEPA AirClean 30 …(116)

$94.88

20%off

Sauder Harvest Mill …(172)

$138.99 $110.46

Southern Enterprises …

$218.36

199.119.116.162 lat: 38.9085 lon: 77.0177

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