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February 6. 2019

WA EMAIL.

U.S. MAIL

Re: Robbins Research lnt'l. lnc.l
Our File No.1470-281

Dear 

This letter is in furtherance of my prior correspondence to you concerning

our client,

You have failed to respond to my prior requests that Mr.

preserve an maintain all written and electronic communications with all

persons affiliated with BuzzFeed, including all emails. text messa es and social
media communications. Accordingly, I can only assume that Mr. intends to
destroy or delete evidence of his communications with BuzzFeed. As stated by
my prior correspondence, such conduct by Mr. -would violate California law.

In addition, we are informed that Mr. -met with BuzzFeed reporter,
Jane Bradley. last week in Florida. We have likewise demanded that BuzzFeed
maintain and retain all communications between Jane Bradley and Katie Baker of
BuzzFeed with Mr.- includin any recording of the communications that Ms.
Bradley may have made with Mr. during their meeting last week.

I trust that you will advise your client accordingly.

All rights, claims and remedies on behalf of our client are reserved.

 

LAV 
PR ESSIONALC RPORATION