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:

Pregame.com, RJ Bell – Demand for Removal

Dear Mr. Gilhuly:
This law firm is litigation counsel for Pregame.com (“Pregame”) and its majority owner
Randall James Busack, professionally known as RJ Bell (“Bell”), in connection with a libelous
story published by Deadspin.com on or about June 23, 2016 at http://deadspin.com/how-americas-favorite-sports-betting-expert-turned-a-s-1782438574 and bearing the headline, “How
America’s Favorite Sports Betting Expert Turned a Sucker’s Game Into An Industry” (the
“Story”). On June 27, 2016, Bell and Pregame sent Gawker Media, LLC (“Gawker”) a letter
demanding a retraction of the Story and an apology. Gawker failed to comply with this demand.
A copy of the demand letter is enclosed.
We understand that UniModa LLC, Univision Holdings, Inc. and/or Fusion Media Group
(collectively, “you”) recently agreed to purchase substantially all of the assets of Gawker,
including Deadspin.com. As the new owner of Deadspin.com, Bell and Pregame will have
causes of action against you if the Story remains on Deadspin.com after the transaction closes.
Accordingly, we hereby demand that you immediately and permanently remove the false
and defamatory Story from Deadspin.com. Your 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.

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 Mr. Peter Gilhuly, Esq.
August 22, 2016
Re: Pregame.com, RJ Bell
Page 2
We look forward to your immediate response to this letter.
Very truly yours,

CHARLES J. HARDER Of
HARDER MIRELL & ABRAMS LLP

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