August 22, 2016 CONFIDENTIAL COMMUNICATION VIA E-MAIL AND CERTIFIED U.S. MAIL Mr. Peter Gilhuly, Esq. Latham & Watkins LLP 355 South Grand Avenue Los Angeles, California 90071 peter.gilhuly@lw.com Re: International Sherick, Superstar Machine – Demand for Removal Dear Mr. Gilhuly: We write on behalf of International Sherick, LLC, which runs a personal improvement program called “Superstar Machine” (collectively, “Superstar”) in connection with a libelous story published by Jezebel.com on or about May 10, 2016 at http://jezebel.com/inside-superstarmachine-which-ex-members-say-is-a-cul-1775494367 bearing the headline, “Inside Superstar Machine, Which Ex-Members Say Is a Cult Preying on New York’s Creative Women” (the “Story”). We understand that UniModa LLC, Univision Holdings, Inc. and/or Fusion Media Group (“you”) recently agreed to purchase substantially all of the assets of Gawker Media LLC, including Jezebel.com. As the new owner of Jezebel.com, you will be subject to liability for the Story if it remains on Jezebel.com after the transaction closes. Accordingly, Superstar hereby demands that you immediately and permanently remove the Story from Jezebel.com or, in the alternative, immediately and permanently remove the following statements in the Story, which are false and defamatory: 1. The headline: “Inside Superstar Machine, Which Ex-Members Say Is a Cult Preying on New York’s Creative Women.” 2. “A lot of the women were aspiring actresses or involved in other creative fields, where the difference between personal and professional lives can be thin.” 3. “Many of the women involved in Superstar Machine are aspiring actresses, or else deeply involved in New York’s yoga and wellness communities.” {00070990;1} Mr. Peter Gilhuly, Esq. August 22, 2016 Re: International Sherick, Superstar Machine Page 2 4. “One by one, between 2011 and 2015, each of them were invited by a new female friend to join an exciting, secretive group, one that would promise to fix their relationships with men, draw rivers of money their way, and reveal the Divine’s plan for their lives.” 5. “Around 2009, a man then known both personally and professionally as Greg Scherick was living in Cotati, California, in a house he referred to as The Barn.” 6. “Every month, Sherick traveled to New York.” 7. “…Sherick would also stress that the women couldn’t do anything without his help.” 8. “But men were never allowed into The Process, which evolved into being called Starmaker Machine and then Superstar Machine.” 9. “The path for these women is twofold: tapping into the Divine’s plan for their lives, and learning to be subservient to their male romantic partners.” 10. “Despite all the bubbly positivity, Scherick and his helpers didn’t brook any dissent in the ranks.’” 11. “…there weren’t a lot of gay members in [Superstar].” 12. “’Dating women doesn’t support what [Superstar does] because they’re all about serving the masculine,’” [Poppy] says. ‘Even when very out women had come to [Superstar] with friends, they were never invited to really sign up.’” 13. “Scherick didn’t respond to two emails, a phone call, and a Facebook message requesting comment from Jezebel.” 14. “She promised to call again soon. She didn’t.” 15. International “convinces” members they are “having problems because there’s something wrong with [them], or that [they]’re not doing.” 16. “Lower-level members of [Superstar] are referred to as the ‘audience,’ and sit at events without speaking. Occasionally, they’re pulled onstage, where Scherick looks at them deeply and zeroes in on what he sees as their core issues.” 17. Any statement to the effect that Superstar “originated” from “The Process.” 18. An individual “was invited to talk during a Hot School call and describe her current romantic situation.” 19. “But she didn’t stick to the expected script and Scherick seemed irritated.” {00070990;1} Mr. Peter Gilhuly, Esq. August 22, 2016 Re: International Sherick, Superstar Machine Page 3 20. “Scherick disapproved of . . . casual sex with a couple people.” 21. International “has strict rules about how soon you should be having sex with someone you’re dating” and that he believes “a woman’s reasons for having sex is to get a relationship and a man’s is to get more sex.” 22. Superstar “pressures” its members for credit card information. 23. “If you properly relate to the masculine, all your problems will be solved.” 24. Members lose their group status if they “fail to recruit new members.” 25. The fact that “afterparties were ‘entirely sex-based.’” 26. “Scherick had specific ideas about what type of sex was best.” 27. “Having anal sex was a marker of being a true, fierce powerful woman. The length of your orgasms were also markers of how intense your feminine power was.” 28. “We had phone calls having to share how long our orgasms were, the positions we masturbated in.” 29. International told women “’to do stuff like get down on the floor,’ or instructed them to go home and ‘stick fingers up their asses, or stick, like, a carrot up your ass.’” 30. “[U]nder International’s guidance, [a woman] ‘recovered’ a memory of having been sexually abused by a family member.” 31. “Besides mandatory meetings and phone calls each week, which the former members say ate up much of their time, they were also expected to post lengthy missives on a group message board, praising ‘The Machine’ for its positive impacts on their lives.” 32. “The posts are read by Shana Kuhn-Siegel or another top administrator named Lisa Paris before they go up, the women say, and if they’re not sufficiently adulatory, they are edited and the women are scolded.” 33. “…there’s punishment for falling out of line.” 34. “Members might also be made to stay home from the events . . . or be allowed to attend but forbidden from speaking.” 35. International stresses that women should “becom[e] submissive to men.” 36. “…it’s a fact that [Superstar] members are subject to an exceedingly strict set of behavioral rules regarding communication, including restrictions on when they’re allowed to talk to other members of the group.” {00070990;1} Mr. Peter Gilhuly, Esq. August 22, 2016 Re: International Sherick, Superstar Machine Page 4 37. “Members have to get permission to call or text each other . . . from Shana . . . Members had to get permission to ‘connect,’ as phone calls or texts were referred to, and then tell Shana what had been discussed.” 38. “Members also aren’t exactly encouraged to talk to outsiders about [Superstar], unless they seem interested in joining.” 39. “…the members are also encouraged to rat each other out for infractions.” 40. “If you thought anything somebody said wasn’t in line with International’s teachings, you were required to go back and tell International about it.” 41. That members of Superstar would “get in trouble.” 42. A member “was punished by being placed on an ‘intense’ group phone call with other members, where all of them told her in turn how badly she’d messed up.” 43. “…[Superstar] members occasionally attend OA meetings for the purpose of recruiting new people.” 44. “Therapy is also not encouraged.” 45. Members are “not permitted to talk about anything but The Machine, meaning that women who could have helped each other benefit professionally weren’t allowed to do so.” 46. Superstar “was financially interested in [its members] feeling helpless.” 47. “International’s dream is to be rich, have great sex, make movies, come back to Hollywood and own it.” 48. International has “compared himself to Jesus.” In reality, Superstar is a life-coaching and personal improvement program, guided by Mr. Sherick. The program welcomes men and women of any sexual orientation and demographic to participate, and includes male members, as well as homosexual members, contrary to the statements in the Story. The program does not force its members to do anything, and does not make promises to “fix relationships,” increase wealth or solve its members’ problems. There are no set “rules” in Superstar as stated in the Story, nor are “punishments” given to members of the program. The Story quotes anonymous, disgruntled “sources” who claim they were former members of Superstar. These “sources” state numerous incorrect “facts” that are relied upon by the Story. The author of the Story reached out to Superstar’s representative Ms. Shana KuhnSiegel for comment, but then published the Story before Ms. Siegel had an opportunity to send her comments to the author. The Story has caused Superstar to become the subject of ridicule. The Story also has caused Superstar to suffer a significant loss of business, clients and partnerships. {00070990;1} Mr. Peter Gilhuly, Esq. August 22, 2016 Re: International Sherick, Superstar Machine Page 5 The continued publication of the Story constitutes, among other claims, libel, false light invasion of privacy and intentional infliction of emotional distress. Please confirm in writing within forty-eight (48) hours of your receipt of this letter that the foregoing demand will be, and is being, complied with. This letter is not intended, and should not be construed, as a complete expression of my client’s factual or legal positions with respect to this matter. Nothing contained in or omitted from this letter is intended, and should not be construed, as a waiver, relinquishment, release or other limitation upon any legal or equitable claims, causes of action, rights and/or remedies available to Superstar, all of which are hereby expressly reserved. We look forward to your immediate response to this letter. Very truly yours, CHARLES J. HARDER Of HARDER MIRELL & ABRAMS LLP {00070990;1}