Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 1 of 58 Page ID #:2251 1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Alex Spiro (admitted pro hac vice) 2 alexspiro@quinnemanuel.com 51 Madison Avenue, 22nd Floor 3 New York, New York 10010 Telephone: (212) 849-7000 4 5 QUINN EMANUEL URQUHART & SULLIVAN, LLP Robert M. Schwartz (Bar No. 117166) 6 robertschwartz@quinnemanuel.com Michael T. Lifrak (Bar No. 210846) 7 michaellifrak@quinnemanuel.com Jeanine M. Zalduendo (Bar No. 243374) 8 jeaninezalduendo@quinnemanuel.com 865 South Figueroa Street, 10th Floor 9 Los Angeles, California 90017-2543 Telephone: (213) 443-3000 10 Attorneys for Defendant Elon Musk 11 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA 14 15 VERNON UNSWORTH, 16 Plaintiff, 17 vs. 18 19 ELON MUSK, 20 Defendant. 21 22 23 Case No. 2:18-cv-08048 Judge: Hon. Stephen V. Wilson DECLARATION OF MICHAEL T. LIFRAK IN SUPPORT OF DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL Complaint Filed: September 17, 2018 Trial Date: December 2, 2019 24 25 26 27 28 DECLARATION OF MICHAEL T. LIFRAK ISO DEFENDANT’S OPPOSITION TO MOTION TO COMPEL Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 2 of 58 Page ID #:2252 1 I, Michael T. Lifrak, declare as follows: 2 1. I am a member of the bar of the State of California and a partner at 3 Quinn Emanuel Urquhart & Sullivan, LLP, attorneys for Defendant Elon Musk. I 4 make this declaration of personal, firsthand knowledge, and if called and sworn as a 5 witness, I could and would testify competently thereto. 2. 6 I submit this declaration in support of Mr. Musk’s Opposition to Vernon 7 Unsworth’s Motion to Compel. 3. 8 Mr. Unsworth’s Motion to Compel initially included a request that Mr. 9 Musk confirm that he has searched his iCloud account for responsive materials. 10 Attached hereto as Exhibit 1 is a true and correct copy of the declaration Alex 11 Stillings regarding the search of Mr. Musk’s iCloud account, that was provided to 12 Mr. Unsworth on October 2, 2019, and has resolved this issue. 13 4. Attached hereto as Exhibit 2 is a true and correct copy of a meet and 14 confer correspondence between my partner Alex Spiro, and counsel for Mr. 15 Unsworth, dated September 26, 2019. 5. 16 Based on a reasonable search and diligent inquiry, all documents and 17 communications in Mr. Musk’s possession, custody, or control regarding James 18 Howard’s investigation have been produced. No attorney-client privilege or attorney 19 work product privilege was claimed over these materials. 20 6. Attached hereto as Exhibit 3 is a true and correct copy of a document 21 produced by Mr. Musk, as MUSK000361, on July 17, 2019. 22 7. Attached hereto as Exhibit 4 is a true and correct copy of a tweet posted 23 by L. Lin Wood to Twitter on August 28, 2018, containing a demand letter to Mr. 24 Musk. 25 8. Attached hereto as Exhibit 5 is a true and correct copy of an email I 26 received from Mr. Unsworth’s counsel, Taylor Wilson, on September 23, 2019, 27 which provided access to an additional production of responsive materials by Mr. 28 Unsworth. -1- DECLARATION OF MICHAEL T. LIFRAK ISO DEFENDANT’S OPPOSITION TO MOTION TO COMPEL Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 3 of 58 Page ID #:2253 1 9. Attached hereto as Exhibit 6 is a true and correct copy of an excerpt 2 from the August 14, 2019 deposition of Vernon Unsworth. 3 10. Attached hereto as Exhibit 7 is a true and correct copy of portions of 4 document VU03314 produced on September 23, 2019. 5 6 7 8 9 10 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this document was executed in Los Angeles, California. DATED: October 2, 2019 11 12 13 By Michael T. Lifrak 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- DECLARATION OF MICHAEL T. LIFRAK ISO DEFENDANT’S OPPOSITION TO MOTION TO COMPEL Case Document 84-2 Filed 10/14/19 Page 4 of 58 Page ID #:2254 EXHIBIT 1 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 5 of 58 Page ID #:2255 Exhibit 1, Page 3 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 6 of 58 Page ID #:2256 Exhibit 1, Page 4 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 7 of 58 Page ID #:2257 Exhibit 1, Page 5 Case Document 84-2 Filed 10/14/19 Page 8 of 58 Page ID #:2258 EXHIBIT 2 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 9 of 58 Page ID #:2259 Jeanine Zalduendo From: Sent: To: Cc: Subject: Alex Spiro Thursday, September 26, 2019 12:40 PM Lin Wood Matt Wood; Nicole Wade; Jonathan Grunberg; Taylor Wilson; Chris Chatham; Mark Stephens, CBE; Adam Fellows; Alex Bergjans; Jeanine Zalduendo; Robert Schwartz; Michael Lifrak Re: Response to Musk MSJ Lin, I will respond to your questions and comments about the experts in due course but the recent production has created a pressing and significant issue. On Monday September 23, 2019, your firm served its third supplemental production of documents, well after the discovery cutoff and long after we’d deposed your client. In the email serving the production, Taylor represented that “[w]ith the production of these documents, Plaintiff has completed his production and responded to each of Defendant’s meet and confer requests.” That is not true. You continue to withhold responsive documents. They should be produced immediately. Moreover, given that these holes continue to exist after you represented that the production is complete, we are concerned about the preservation, collection, and review process that Mr. Unsworth and your firm have undertaken in this case. Perhaps most troubling and puzzling is the fact that despite the reality that it was your and Mr unsworth's decision to bring suit well over a year ago, no one bothered to collect responsive documents (or review them) at the outset. Mr. Unsworth Produced No Instant Messages Between Him and Tik Mr. Unsworth’s partner, Tik, testified in deposition that she and Mr. Unsworth communicate on WhatsApp and Line. Yet, we have not received any chat logs or documents related to their communications on either application. In fact, Mr. Unsworth has only produced three emails between him and his partner, Tik. He has produced no other electronic communications between the two of them. The absence of these chats from your production is concerning. As your production makes clear, Mr. Unsworth frequently uses these applications to chat with his friends and fellow rescue volunteers about the Thai Cave Rescue, opportunities arising from his role in the rescue, Mr. Musk, and this lawsuit. Mr. Unsworth has produced (belatedly) around 100 pages of chats between him and friends, and zero between him and his partner (even though we know they used them to communicate). Given the volume of responsive chats with other persons, Tik’s testimony, and the fact that Mr. Unsworth and Tik live apart for a substantial portion of the year, Mr. Unsworth appears to be withholding responsive communications between him and Tik. 1 Exhibit 2 Page 6 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 10 of 58 Page ID #:2260 Mr. Unsworth Produced 100 Pages of Key Documents Well After His Deposition and Eleven Days After the Discovery Cut-Off On Monday, you produced 100 pages of documents and communications, which should have been produced earlier and in advance of Mr. Unsworth’s deposition. For instance, the production included text messages between Mr. Unsworth and his estranged wife Vanessa. We requested a complete production of these messages in our August 7, 2019 meet and confer letter and you agreed to produce them on our August 9, 2019 call. It is unclear why it took nearly one-and-ahalf months to produce these documents. But as a result, we were unable to question either Mr. Unsworth or Vanessa about them at their depositions. Also on Monday, you produced 81 pages of chat logs between Mr. Unsworth and Thanet Natisri. These chats contain probative information relating to Mr. Unsworth’s reputation, credibility, and potential damages. The messages include numerous references to Mr. Musk and this lawsuit. They also identify financial opportunities Mr. Unsworth received after Mr. Musk’s statements that are relevant to testing the purported harm to Mr. Unsworth’s reputation. Again, there is no justification for your having withheld these relevant chats from Mr. Unsworth’s earlier productions. They could and should have been collected and produced with the other chat logs Mr. Unsworth produced in August, before his deposition. Additional Missing Documents Your last production also identifies relevant documents and communications that you have not produced. Mr. Unsworth’s chat log with Mr. Natisri shows that the two exchanged 632 photographs, 491 “stickers”, 12 video files, and 37 files. This media cannot be viewed in the format for which you produced the chat log. Please produce all chats in a format that allows us to view all photographs, videos, sticker, and other files that Mr. Unsworth received and exchanged in all of these chats. Mr. Unsworth’s chats with Mr. Natisri also reference other responsive documents and communications that you have not produced. For instance, on November 13, 2018, Mr. Unsworth told Mr. Natisri that he retained an agent/representative, Will Robinson, to assist him negotiate film rights. However, Mr. Unsworth has produced only one communication involving his agent (an email with an author in which Mr. Robinson is copied) and no other documents relating to this relationship. According to the chats, more communications exist that you have not produced. See VU03370 (“You should see the email I've just received from Dr Harry and Dr Craig book writer. They NEED ME SO SO MUCH. Sent it on to my agent”). Mr. Unsworth also describes emails he received from agents and studios relating to his role in the Thai Cave Rescue. On November 13, 2018, Mr. Unsworth told Mr. Natisri that he had received an email from CAA. You have failed to produce that email. On November 15, 2018, Mr. Unsworth messaged Mr. Natisri that he sent him an email to put him in contact with Mr. Robinson. Again, you have failed to produce that email. Mr. Unsworth also claims in these chats that he has had a number of meetings and communications with representatives from Warner Brothers, but again, you have failed to produce any documents constituting or relating to these communications. 2 Exhibit 2 Page 7 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 11 of 58 Page ID #:2261 All of these referenced communications and documents are responsive to Mr. Musk’s RFP No. 26 and should have been produced. The absence of a significant number of responsive documents (including communications between Mr. Unsworth and Tik) from your purportedly “complete” production suggests either that key documents were deleted or never collected in the first place. We ask that, consistent with your obligations under the Federal Rules of Civil Procedure and your responses to Mr. Musk’s document requests, all of these documents be produced promptly. Please let us know by tomorrow evening, Friday September 27, 2019, if you will be producing these documents and by when. Alex Sent from my BlackBerry - the most secure mobile device From: lwood@linwoodlaw.com Sent: September 26, 2019 10:33 AM To: alexspiro@quinnemanuel.com Cc: mwood@wshllp.com; nwade@linwoodlaw.com; jgrunberg@linwoodlaw.com; twilson@linwoodlaw.com; chris@chathamfirm.com; Mark.Stephens@howardkennedy.com; Adam.Fellows@howardkennedy.com; alexbergjans@quinnemanuel.com; jeaninezalduendo@quinnemanuel.com; robertschwartz@quinnemanuel.com; michaellifrak@quinnemanuel.com Subject: Re: Response to Musk MSJ Alex, One more quick question - given the detailed expert reports provided to you by Mr. Unsworth’s experts, how much time do you wish to block off for each deposition? Thanks. Lin L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw.com Sent from my iPhone 3 Exhibit 2 Page 8 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 12 of 58 Page ID #:2262 On Sep 26, 2019, at 10:33 AM, Lin Wood wrote: Alex, I have not refused to make these witnesses available to you. You first made the request at 9:30 pm last night. Give me reasonable time to work through your request in order to respond. I hope to do so later today. Plaintiff adhered to the scheduling order and the experts were timely identified. Any suggestion to the contrary is dead wrong. Unlike Musk, my client has adhered to the letter and spirit of the Federal Rules relating to discovery. As I speak with the experts in order to respond to your demand of last night, please confirm that Musk will be responsible for paying for any necessary travel expenses for the depositions incurred by the deponents. Please note that Mr. Jansen resides in Qatar. Also, please confirm that Musk will pay these experts for their time spent preparing for the requested depositions, traveling to and from the depositions, and for the time spent being deposed. Thanks. Lin L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw.com Sent from my iPhone On Sep 26, 2019, at 6:32 AM, Alex Spiro wrote: Lin, As in most cases, you disclosed your experts at the close of fact discovery. That made it impossible for us to depose them earlier. The court expects you to make them available for deposition (and rule 26b4a requires it). We’ve asked you to check with them for the weeks of October 21 and 28. Let us know when they are available during that period. 4 Exhibit 2 Page 9 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 13 of 58 Page ID #:2263 We will let you know by the October 14 deadline whether we intend to call experts. Of course we will cooperate with a request to depose them. I want to be clear. We remain willing to allow you the extension of time to oppose our summary judgment motion (as always so long as it doesn't throw off the whole schedule). I was merely questioning whether it was really necessary given the various timing issues which is neither of our faults. Our request that you present it to the Court in the form of an unopposed request is driven by our desire to not convey to the Court that we, as opposed to plaintiff, are asking to encroach into the 14-day period the local rule requires for review of the briefs. Thx Alex Sent from my BlackBerry - the most secure mobile device From: lwood@linwoodlaw.com Sent: September 25, 2019 11:01 PM To: alexspiro@quinnemanuel.com Cc: mwood@wshllp.com; nwade@linwoodlaw.com; jgrunberg@linwoodlaw.com; twilson@linwoodlaw.com; chris@chathamfirm.com; Mark.Stephens@howardkennedy.com; Adam.Fellows@howardkennedy.com; alexbergjans@quinnemanuel.com; jeaninezalduendo@quinnemanuel.com; robertschwartz@quinnemanuel.com; michaellifrak@quinnemanuel.com Subject: Re: Response to Musk MSJ Alex, I will provide a more fulsome response to you tomorrow. Suffice it for tonight to say that we will certainly accept subpoenas for dates we agree on with respect to any witness. Does Musk plan to identify experts? If so, am I correct that you will cooperate with requests for their depositions? You had earlier suggested you did not think you would be identifying experts but I could be mistaken on that point or you may have changed your mind. I wish this expert issue had been addressed before we did the consent stipulation. The order is somewhat inflexible on additional depositions beyond the discovery date. But I will be the first to say that the scheduling order has been a bit of a scheduling fiasco. I thought my request today for a 3 day extension of time by consent was entirely reasonable and fair yet you insist on putting me to the task of 5 Exhibit 2 Page 10 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 14 of 58 Page ID #:2264 filing a motion and getting a ruling because of the strict language of the Court’s rule and order. I will continue to work with you in good faith on scheduling issues provided the road goes in two directions going forward. Thanks. L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw.com Sent from my iPhone On Sep 25, 2019, at 9:36 PM, Alex Spiro wrote: LinIn terms of the msj schedule, we are not comfortable changing the requirement in the Local Rules that the judge have 14 days between the filing of our reply and the hearing. It cuts into the judge’s time to consider our motion. We are also are not willing to cut into our own time to respond or to change the hearing date. I think given that reality we should just leave it and not bother the court but if you file a motion to push the due dates on the opposition and reply by three days, we would not oppose so long as the above is understood. We just can't stipulate to it bc of the issues above. In terms of experts, please provide available dates for the depositions of Mr. Rose and Mr. Jansen, particularly the weeks of October 21 and October 28. Please also confirm that you will accept service of document subpoenas for these witnesses. Thx Alex Sent from my BlackBerry - the most secure mobile device From: lwood@linwoodlaw.com Sent: September 25, 2019 2:36 PM To: alexspiro@quinnemanuel.com Cc: mwood@wshllp.com; nwade@linwoodlaw.com; jgrunberg@linwoodlaw.com; twilson@linwoodlaw.com chris@chathamfirm.com; Mark.Stephens@howardkennedy.com; Adam.Fellows@howardkennedy.com; 6 Exhibit 2 Page 11 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 15 of 58 Page ID #:2265 alexbergjans@quinnemanuel.com; jeaninezalduendo@quinnemanuel.com; robertschwartz@quinnemanue michaellifrak@quinnemanuel.com Subject: Re: Response to Musk MSJ I may be overly optimistic but I think the Court would be wiling to cut us a couple days slack on the 14 day requirement if we present him with a consent order on the dates. Let me know if it works for you and your team to present such a consent order. Then the Court will do what he wants with it. He will sign it or refuse to sign it. The consent order can include a reference to the fact that the hearing is presently set for October 28. Thanks. L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw.com Sent from my iPhone On Sep 25, 2019, at 2:32 PM, Alex Spiro wrote: Let me chat the team and circle back. Your proposal makes sense if it didn't back into the 14 day rule but I'll get back to you asap Sent from my BlackBerry - the most secure mobile device From: lwood@linwoodlaw.com Sent: September 25, 2019 2:25 PM To: alexspiro@quinnemanuel.com Cc: mwood@wshllp.com; nwade@linwoodlaw.com; jgrunberg@linwoodlaw.com; twilson@linwood chris@chathamfirm.com; Mark.Stephens@howardkennedy.com; Adam.Fellows@howardkennedy.c alexbergjans@quinnemanuel.com; jeaninezalduendo@quinnemanuel.com; robertschwartz@quinn michaellifrak@quinnemanuel.com Subject: Re: Response to Musk MSJ Don’t you think that since you have a weekend for your reply to what we file on the 7th that you will not really need any additional time for the reply? If not, I am fine with you adding reply by the 17th and us submitting a consent order to the Judge with those dates. He will either sign it or he will not. If not, we are stuck with the present dates. Is he signs it, we both have the same extra time. 7 Exhibit 2 Page 12 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 16 of 58 Page ID #:2266 L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw.com Sent from my iPhone On Sep 25, 2019, at 2:22 PM, Alex Spiro wrote: The 14th. So I'm genuinely trying to be helpful to your team but I'm boxed in a bit Sent from my BlackBerry - the most secure mobile device From: lwood@linwoodlaw.com Sent: September 25, 2019 2:14 PM To: alexspiro@quinnemanuel.com Cc: mwood@wshllp.com; nwade@linwoodlaw.com; jgrunberg@linwoodlaw.com; twilson@ chris@chathamfirm.com; Mark.Stephens@howardkennedy.com; Adam.Fellows@howardke alexbergjans@quinnemanuel.com; jeaninezalduendo@quinnemanuel.com; robertschwartz michaellifrak@quinnemanuel.com Subject: Re: Response to Musk MSJ Remind me - what is your present reply date? L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw.com Sent from my iPhone On Sep 25, 2019, at 2:11 PM, Alex Spiro wrote: 8 Exhibit 2 Page 13 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 17 of 58 Page ID #:2267 The other problem because of Wilson's rules is if we give you an extension then we have less time. We can't work in an extension Sent from my BlackBerry - the most secure mobile device From: alexspiro@quinnemanuel.com Sent: September 25, 2019 1:57 PM To: lwood@linwoodlaw.com Cc: mwood@wshllp.com; nwade@linwoodlaw.com; jgrunberg@linwoodlaw.com; chris@chathamfirm.com; Mark.Stephens@howardkennedy.com; Adam.Fellows@h alexbergjans@quinnemanuel.com; jeaninezalduendo@quinnemanuel.com; robert michaellifrak@quinnemanuel.com Subject: Re: Response to Musk MSJ Let me check and also check on our filing on Columbus day and get back to you Sent from my BlackBerry - the most secure mobile device From: lwood@linwoodlaw.com Sent: September 25, 2019 1:55 PM To: alexspiro@quinnemanuel.com Cc: mwood@wshllp.com; nwade@linwoodlaw.com; jgrunberg@linwoodlaw.com; chris@chathamfirm.com; Mark.Stephens@howardkennedy.com; Adam.Fellows@h alexbergjans@quinnemanuel.com; jeaninezalduendo@quinnemanuel.com; robert michaellifrak@quinnemanuel.com Subject: RE: Response to Musk MSJ [EXTERNAL EMAIL] Alex, Understood. We will file our response on or before October 7 and you will file your reply on or before October 14. 9 Exhibit 2 Page 14 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 18 of 58 Page ID #:2268 Given our agreement, do you think we are required to submit a consent order to Judge Wilson or can we simply proceed in reliance on our agreement as to those dates? Looks like we both may possibly need to supplement after the depositions of Glover, the resolution of Mac’s deposition and any ruling on our proposed discovery dispute stipulation (which I hope to send to you today or in the morning). But we can discuss and cross those bridges down the road if and when necessary, don’t you think? Thanks. Lin L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 10 Exhibit 2 Page 15 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 19 of 58 Page ID #:2269 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw. com NOTICE: This communication may contain privileged or other confidential information. If you are not the intended recipient, or believe that you have received this communication in error, please do not print, copy, retransmit, disseminate, or otherwise use the information. Also, please indicate to the sender that you have received this communication in error, and delete the copy you received. Thank you. 11 Exhibit 2 Page 16 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 20 of 58 Page ID #:2270 From: Alex Spiro Sent: Wednesday, September 25, 2019 1:38 PM To: Lin Wood Cc: Matt Wood ; Nicole Wade ; Jonathan Grunberg ; Taylor Wilson ; Chris Chatham ; Mark Stephens, CBE ; Adam Fellows ; Alex Bergjans ; Jeanine Zalduendo ; Robert Schwartz ; Michael Lifrak Subject: Re: Response to Musk MSJ We can use our office. I have my own personal ice machine just so you know. 12 Exhibit 2 Page 17 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 21 of 58 Page ID #:2271 What about Oct 7, and we respond on 14. Gives you the weekend. Under Wilson rules we have to file by 14 bc he requires 2 wks before hearing. Sent from my BlackBerry - the most secure mobile device From: lwood@linwoodlaw.com Sent: September 25, 2019 1:27 PM To: alexspiro@quinnemanuel.com Cc: mwood@wshllp.com; nwade@linwoodlaw.com; jgrunberg@linwoodlaw.com; chris@chathamfirm.com; Mark.Stephens@howardkennedy.com; Adam.Fellows@h alexbergjans@quinnemanuel.com; jeaninezalduendo@quinnemanuel.com; robert michaellifrak@quinnemanuel.com Subject: RE: Response to Musk MSJ [EXTERNAL EMAIL] Thanks, Alex. I will look to hear from you on the extension request. October 8 in NYC works for me for Ms. Glover’s depo. We can pin down location well in advance of that date. 13 Exhibit 2 Page 18 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 22 of 58 Page ID #:2272 Do you have any suggestions? Your law office would be fine with me. Lin L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw. com NOTICE: This communication may contain privileged or other confidential information. If you are not the intended recipient, or believe that you have received this communication in error, please do not print, copy, 14 Exhibit 2 Page 19 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 23 of 58 Page ID #:2273 retransmit, disseminate, or otherwise use the information. Also, please indicate to the sender that you have received this communication in error, and delete the copy you received. Thank you. From: Alex Spiro Sent: Wednesday, September 25, 2019 1:23 PM To: Lin Wood Cc: Matt Wood ; Nicole Wade ; Jonathan Grunberg ; Taylor Wilson ; Chris Chatham ; Mark Stephens, CBE ; Adam Fellows ; Alex Bergjans ; Jeanine Zalduendo ; Robert Schwartz ; Michael Lifrak Subject: Re: Response to Musk MSJ Lin- an extension shouldn't be a problem let us just check judge Wilson rules and let me confer w my team. Also- I heard back from Ms Glover who informed me she is in NY on Oct 8. Obviously I'm fine to do it in NY but wanted to check Sent from my BlackBerry - the most secure mobile device From: lwood@linwoodlaw.com Sent: September 25, 2019 1:08 PM To: alexspiro@quinnemanuel.com Cc: mwood@wshllp.com; nwade@linwoodlaw.com; jgrunberg@linwoodlaw.com; chris@chathamfirm.com; Mark.Stephens@howardkennedy.com; Adam.Fellows@h alexbergjans@quinnemanuel.com; jeaninezalduendo@quinnemanuel.com; robert michaellifrak@quinnemanuel.com Subject: RE: Response to Musk MSJ 16 Exhibit 2 Page 21 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 25 of 58 Page ID #:2275 [EXTERNAL EMAIL] Alex, My turn to admit hitting the send button inadvertently. Sorry. Will you agree to a consent order being submitted to Judge Wilson that extends Mr. Unsworth’s response date by one week, i.e., to October 11? We will certainly agree to any extension you request as to your reply due date and can include that in the consent order if you wish. The depos next week have simply put us in a time crunch to meet the present October 4 deadline. Can you let me know today if that is agreeable? Thank you, 17 Exhibit 2 Page 22 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 26 of 58 Page ID #:2276 Lin L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw. com NOTICE: This communication may contain privileged or other confidential information. If you are not the intended recipient, or believe that you have received this communication in error, please do not print, copy, retransmit, disseminate, or otherwise use the information. Also, please indicate to 18 Exhibit 2 Page 23 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 27 of 58 Page ID #:2277 the sender that you have received this communication in error, and delete the copy you received. Thank you. From: Lin Wood Sent: Wednesday, September 25, 2019 12:57 PM To: Alex Spiro Cc: Matt Wood ; Nicole Wade ; Jonathan Grunberg ; Taylor Wilson ; Chris Chatham ; Mark Stephens, CBE ; Adam Fellows ; Alex Bergjans ; Jeanine Zalduendo ; Robert Schwartz ; 19 Exhibit 2 Page 24 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 28 of 58 Page ID #:2278 Michael Lifrak Subject: Response to Musk MSJ Alex, Would you agree to a consent order to L. Lin Wood L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, GA 30309 Telephone: (404) 891-1402 Direct Dial: (404) 891-1406 Facsimile: (404) 506-9111 E-Mail: lwood@linwoodlaw. com NOTICE: This communication may contain privileged or other confidential information. If you are not the 20 Exhibit 2 Page 25 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 29 of 58 Page ID #:2279 intended recipient, or believe that you have received this communication in error, please do not print, copy, retransmit, disseminate, or otherwise use the information. Also, please indicate to the sender that you have received this communication in error, and delete the copy you received. Thank you. 21 Exhibit 2 Page 26 Case Document 84-2 Filed 10/14/19 Page 30 of 58 Page ID #:2280 EXHIBIT 3 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 31 of 58 Page ID #:2281 From: Sent: To: Cc: Bcc: Subject: James Brickhouse Tue 9/18/2018 4:39 PM (GMT-07:00) "Jupiter Private" Re: Project Rowena Update You mentioned several days ago that you would be sitting down with your embassy contact to get documented proof of Unsworth's travel over those 6 years that you indicated he spent time in Pattaya. Did that happen? That is an important piece of verification. On Tue, Sep 18, 2018 at 4: 16 AM Jupiter Private < info@jupiter-private.com> wrote: Jim, this is the info as it came to me from the female lead from our team who befriended the sister and mother. Obviously we now know the DOB was incorrect. They related to the investigator that he fust visited Thailand 29 yrs ago which would have been 1989. I have asked Steve to look at the Uk embassy records to verify. l.When did he fust move to Thailand? He fust moved to Thailand about 7 years ago. (He fust visited Thailand 29 years ago for his cave exploration project in the Southern of Thailand) = 2.Do we know if he was visiting in the years before he moved to Thailand? Before he met Kun Tik. He sometimes traveled to Thailand for cave exploration and came with his cave explorers. = 3.Why did he chose Chiang Rai, or was he based somewhere else previously - Pattaya etc? The reasons that he has chosen to live in Chiang Rai, because he loves studying about caves. ChianfRai has plenty of interesting caves, especially Tam Luang. He believes that he still can explore more about this cave. Secondly, Kun Tik., it is her hometown and also she has land and house here. Tik has to take care of her family i.e. her Father, Mother and daughter (with her exhusband) and she has a job here. So that it'd be a good reason for Vernon to live for his retirement here. = 4.We understand he may have a coffee shop in Chiang Rai - is this his source of income? = He opened a small coffee shop in 2016, named "Cha-Pa-Yom" which it is located in Mae Fha Luang district. It was a small coHee stand. It was not his source income. 5.Ifhe has the coffee shop, is it successful and what do his competitors think? = In the past he used to open this small coffee shop, there were a whole lot customers. So he didn't have competitors. 6.Where does he live and what lifestyle does he lead - expensive house/condo? For some period of time, they would come to stay with Tik's parents house. Her mother's house is also a small grocery shop. It has been on business since 2011 . "Wan dee" is the name of the shop, which located in Huai Krai sup-district, Maesai district, Chiang Rai Province. It's a one floor house and it is belong to her family. = Exhibit 3, Page 27 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 32 of 58 Page ID #:2282 7.1s he actually married to Khun Voranan? = They have not made the marriage registration but they had a wedding ceremony according to Tik's family traditional. 8.When did they meet and how did they meet? = They both met each other in England 8 years ago. Tik had a summer vacation and visited her friends there. A friend of her introduced Tik to Vernon. That was the beginning of their relationship. Additional information; I.Miss Woranan Ratrawiphukkun - Her previous name was Suvimon Chomkeaw - born on - Age 30 - Phone number - She used a car MG. Light blue color, plate no. - She's been working as a Secretary of Chief Executive of the SAO at Huai Krai SOA for 7 years. - She worked in a chemical company in Bangkok. - She quit the job in Bangkok then moved back to her hometown, in order to open the grocery shop. Her mother's now running the shop. - She was married with a Thai person. She has a daughter/ 13-14 years old. The reason that she divorced was her ex-husband had a another lover. - Tik has one younger sister. Her sister is married and moved to another provice. - She graduated in Bachelor degree in Chaing Mai Rajabhat University, in management major. - She has her business, is manicures salon "Elegant nails & Beauty Spa". There are 2 branches 1st Branch is located in front of Mae Fah Luang University Address: , Tha-Sud sub-district, Mae Fah Luang district, Chiang Rai province. 2nd Branch Address: Nang-Le sub-district, Mae Fah Luang district, Chiang Rai province. Open from 10.00 to 21.00 Hrs. - Her business is running well, there are a lot of customers. Because there is not much competition. And it is her main income. - She has open her business since 2013. The rentals cost 8,000 bahtlp month - He is fascinated in cave exploration all over the word and he has been doing it for over 40 years. He usually went with his team. He is planing about investing a tour business in Chaing Rai. Exhibit 3, Page 28 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 33 of 58 Page ID #:2283 -They also have another business is importing digital Coffee Tampers. Since 2016 Name: "Eazytamp Thai" it sells throughout the nation. They has opened this business since 2016, they're both visiting many coffee shops. - They recently bought a piece of land, which is close to Tik's mother house about 2 kIn. they are planing to build a house as well as a small resort there. Now it is a rice field. - Vernon has a cave exploration project again in Tam-Huang soon. As the same time, he will also explore a cave in Naan province with his team. - Vernon has left Thailand on the 18th July 2018 to England, then he will return on the 5 Sep 18 at the Suvarnabhumi Airport, Bangkok. His arrival at 3pm and Tik will fly to meet him at 4pm the airport. - They both will attend to the thanking party at 6pm-21pm the Dusit Palace, Bangkok. The party was held by the Thai Government. - Vernon stays in Thailand by a Tourist Visa from the beginning. He sometimes extended his visa by crossing the border in Maesai district, sometime he went to Vientiane. The Thai Government will renew a type of visa for him for a long term stay. - He will stay in Thailand about 1 or 2 months then he will return to England. - Vernon was marred to an English lady and they have one son. - Vernon is older than Tik for 23 years, they started dating in late 2009 Kind regards, James CEO - Qatar & UAE Jupiter Military & Tactical Systems Al Saad - Area 38 Street No. 893, Building No . 7 P.O. Box 22509 Doha State of Qatar +44 (0) 7917 401601 This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately bye-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are Exhibit 3, Page 29 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 34 of 58 Page ID #:2284 not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents ofthis information is strictly prohibited. On 17 Sep 2018, at 23:49, James Brickhouse < jbrickhouse11@gmail.com> wrote: I'm available whenever you are. Also, what was the information source that suggested Unsworth has been going to Thailand since the 80's? On Mon, Sep 17,2018 at 10:59 AM Jupiter Private wrote: Jim, I'm still here in Thailand and I am have not diverted my efforts away from the task or I would have informed you. I have been working hard with my Thai team as we last discussed. The time zones don't make it easy to communicate and as I had not heard from you I had presumed you where away with the principle. Disappointed you would think me so ready to abandon my post. I am on route back to Chiang Mai tomorrow and suggest we communicate at 1700 GMT for a de-brief Kind regards, James CEO - Qatar & UAE Jupiter Military & Tactical Systems Al Saad - Area 38 Street No. 893, Building No.7 P.O. Box 22509 Doha State of Qatar +44 (0) 7917 401601 info@jupiter-private.com www.jupiter-private.com Jupiter Executive Protection 43 Berkeley Square Mayfair, London WlJ 5FJ +44 (0) 7917 401601 This email and any files transmitted with it are confidential and intended solely for the use of Exhibit 3, Page 30 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 35 of 58 Page ID #:2285 the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately bye-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. On 17 Sep 2018, at 18:50, James Brickhouse < jbrickhousell@gmail.com> wrote: James, It appears you have decided to focus on other efforts that don't include the Rowenta related work. Your last email was 5 days ago and it contained nothing relevant to this project. Only a reference to your efforts to getting the birth record, which I obtained on my own accord. If you have decided to focus elsewhere, that is fme, but I will expect funds to be returned. Thank you. On Fri, Sep 14, 2018 at \0:29 AM Jupiter Private < info@jupiter-private.com> wrote: Jim in transit I'll call when I am free a little later. Kind regards, James CEO - Qatar & U AE Jupiter Military & Tactical Systems Al Saad - Area 38 Street No. 893 , Building No. 7 P.O. Box 22509 Doha State of Qatar +44 (0) 7917 401601 info@jupiter-private.com www.jupiter-private.com This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. Tfyou have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by email if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in rcliancc on thc contcnts of this information is strictly prohibitcd. Exhibit 3, Page 31 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 36 of 58 Page ID #:2286 On 14 Sep 2018, at 18:19, James Brickhouse wrote: Any news? On Wed, Sep 12, 2018 at 7:49 AM Jupiter Military & Tactical Systems wrote: Jim , Yes Ive been on the ground these past five days. I apologise for the lack of comms, my UK cell reception is not great and I have been in transit between Chiang Rai, Bangkok and PaUaya. Unsworth was not a liked man on the ground during the dive rescue . A number of the Dive centres in Pattaya have divers that assisted with logistics in the rescue and have mentioned to me over a few beer that Unsworth was difficult and that he's attracted negative press to the rescue efforts. Everyone knows that his comments where initially inflammatory and that it was his initial outburst that riled the principle. When asked if they thought or knew anything about Unsworth's past they all said that they had no proof and had not heard anything specific. Just that he is not an easy man to like. The update is that I am waiting this evening to meet with the Thai investigator and see if she has been able to secure a copy of the birth certificate that verifies the partner details one way or another. The dust has settled and its allot easier to move around the hotels and bars of Pattaya asking if they know Unsworth etc. I have met with one hotel owner and the records for the hotels which are a simple check in book are held by the previous hotel owner for the dates that interest us. I am meeting with him tomorrow as he is now retired but on the phone he has confirmed that he does have the old hotel registration books and will allow me to copy them. I will be staying in Thailand until we have exhausted all avenues and have completed the task. Update on Unsworth is that he is returning to the UK next week and has confirmed meetings with his legal team Howard Kennedy on Tuesday and Wednesday. I will keep you updated when I have further information . Kind regards, James CEO - Qatar & UAE Jupiter Military & Tactical Systems AI Saad - Area 38 Street No. 893, Building NO.7 P.O. Box 22509 Doha State of Qatar +44 (0) 7917 401601 info@jupiter-private.com www.jupiter-private.com Jupiter Executive Protection 43 Berkeley Square Mayfair, London W1J 5FJ +44 (0) 7917 401601 ~ CJ Exhibit 3, Page 32 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 37 of 58 Page ID #:2287 This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately bye-mail if you have received this e-mail by mistake and delete this e-mail from your system . If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. On 12 Sep 201S, at 04:33 , James Brickhouse < jbrickhousell@gmail.com> wrote: Also, I can help but think that after his random and unprovoked initial attack on our principle, he has made enemies. They will likely know his dirt. On Tue, Sep II, 20lS at 7:52 PM James Brickhouse wrote: James, I didn't hear from you today. I suppose you've made it to Thailand by now? I look forward to an update. Clearly we'd like to gather as much relevant information as possible, but we of course need to ensure it is done carefully and legally. Has there been any progress in Pattaya? On Fri, Sep 7, 20lS at 2:21 AM Jupiter Military & Tactical Systems < info@jupiterprivate.com> wrote: Jim, Let me clear up the marriage issue. All the papers after the fIrst Twitter fall out in the UK reported that Unsworth was marred. It was not until the investigation team spoke to her sister that we learnt that they have had a wedding but, they did not complete the necessary registration with the local authorities. They regards themselves as a husband and wife, this however is not legal in Thailand. If her age is 30 then they met when she was IS/ 19. If she is in fact she is 40 then its they met when she was 2S/29. The lead Thai investigator has arrived in Chiang Rai this morning to go to the town hall to obtain a copy ofthe birth certificate so we have proof you requested. What I am doing now is reviewing all the evidence as its collected and then verifying this myself. I am also flying to Bangkok tomorrow morning to take charge of the investigation in Pattaya. T feel now that this is where the results will be found ifthey exists and I want to control the flow of information. I will report further developments later today. Kind regards, James Howard Exhibit 3, Page 33 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 38 of 58 Page ID #:2288 CEO - Qatar & UAE Jupiter Military & Tactical Systems AI Saad - Area 38 Street No. 893, Building No.7 P.O. Box 22509 Doha State of Qatar +44 (0) 7917 401601 info@jupiter-private.com www.jupiter-private.com Jupiter Executive Protection 43 Berkeley Square Mayfair, London W1J 5FJ +44 (0) 7917 401601 ~ CJ This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed . If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately bye-mail if you have received this e-mail by mistake and delete this e-mail from your system . If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. On 6 Sep 2018, at 20:00, James Brickhouse < jbrickhousell@gmail.com> wrote: Please assure your source that we will not expose him or his information. Please understand that as of this moment much of what you have told us can't be verified. Our request for actual documentation is to confirm that we are being given legitimate information. The info that you said was leaked to the press wasn't actually leaked to the press. It was an off the record comment (which disgracefully was not respected as such and instead published) meant to encourage the journalist to actually do some due diligence rather than simply make assumptions. It doesn't seem too difficult to get something verifying her age, a document confirming travel records or a copy of a newspaper article. These things are vital simply for us to know that we are getting legitimate information. Regarding your follow up comment, we were told numerous times that they were 'married' (or formed a relationship) in her late teens (you said 18), but that she was quoted in a newspaper saying they met 7 years prior. Does a copy of that article exist? Can you send it along? It appears this narrative has changed, or information was relayed based on broad assumption and that's what has us asking for legit verification. Because based on that original narrative she would have actually been a child/young teenager when they first met. Exhibit 3, Page 34 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 39 of 58 Page ID #:2289 With that said, let's focus on what we can do now to be productive, move toward the objective and verify some of the key data. Do you have a definitive way to confirm her age? Have the guys found anything new in Pattaya? On Thu, Sep 6, 2018 at 10: 14 AM Jupiter Military & Tactical Systems wrote: Jim, Just to clarify the points you made. The investigation team in Chiang Rai was able to establish a number of important information. I made the assumption based on what was reported back to me that if her age is in-fact 30 and not 40 and that she has been married (not legally) but in a religious context for 7 years plus we also know that she was dating Unsworth for at least a further 3 years prior to this then she would have been in her late teenage years when they met. I believe I told you that I thought this would have been about 19. There is a big difference between 19 and 29 I agree, and an even bigger leap to being a child rapist. I do not know how anyone could come to that conclusion as neither of us have ever mentioned children or rape in our conversations. Today is the Thai Governments big celebration with over 60,000 expected in Bangkok. Our source at the Embassy is naturally extremely concerned about his information being used by the 3rd parties in further exchanges with the media. What assurances can I give him? You require evidence that can be used by the foreign press to show Unsworth was a regular visitor to Pattaya which is a well known haunt for sex tourists. Yes, the team are in Pattaya and developing the best strategy to qualify the information we have and then hopefully finding someone who knows unsworth and will give a statement. The UK Embassy will be back to normal staffing tomorrow as it was closed this afternoon in preparation for this evenings event. I have taken onboard what you have said and if! thought the information I gave you would be leaked to the press then we would have triple checked everything. This is not how we normally work. We would normally gather all the data we need to make our case findings and then go over it in fine detail and then present it. I am am gathering the information you require as quickly as humanly possible. Kind regards. James +44 (0) 7917 401601 info@jupiter-private.com www.jupiter-private.com nfidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate. distribute or copy this e-mail. Please notify the sender immediately bye-mail if you have received this e-mail by mistake and delete this e-mail from Exhibit 3, Page 35 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 40 of 58 Page ID #:2290 your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited . On 6 Sep 2018, at 17:53, James Brickhouse < jbrickhousell@gmail.com> wrote: James - I hope to receive additional information today. I assume the team is still engaged inPattaya? Also, as you may expect, I have spent time over the last 24 hours compiling the information you've provided. Not to beat a dead horse, but to briefly revisit the point below, you never did report that the target is a child rapist. However you undoubtedly understand where the principal was drawing this conclusion from. You reported in multiple phone conversations that the age of the target's girlfriend (believed to be his wife at the time) would have put her in her teens when they 'married' and that she was quoted in a Thai news article saying they first met 7 years prior to that - which would have made her a very young teenager at the time. Some (all?) of this information has now proven to be wrong. They aren't married and her age is unconfirmed. I also haven't seen the Thai article you referenced. So while I agree that the comments by the principal were ill advised, you can understand that using the data you provided would have allowed him to draw this conclusion without you explicitly reporting it as fact. J On Wed, Sep 5, 2018 at 7:51 AM James Brickhouse < jbrickhousell@gmail.com> wrote: There is no confusion where this is concerned. You have not reported this and I have not communicated it either. I understand your concern about self sabotage. A concern of mine as well. On Wed, Sep 5, 2018 at 2:00 AM Jupiter Private < info@jupiter-private.com> wrote: Jared, I would like to state the following. At no time have have I reported that the target is a child rapist. We need to be clear about what we are looking for. The target had a traveling pattern that shows he spent time before he moved to Northern Thailand in Pattaya. We are qualifying what the target did on his travels and will report back as soon as we have that information. What I can confirm is that he is about to launch libel action and we are working as quickly as possible to defuse that action by clearing showing a behavioural pattern that replicates a sex tourist. That task is now difficult time complete in a Exhibit 3, Page 36 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 41 of 58 Page ID #:2291 covert way. The recent buzznews comments will be big news in Thailand. Tomorrow is the national celebration ofthe rescue & is still big news in Thailand. I feel that an appropriate course of action is to try to avoid the public circus & instruct Kieth Oliver to meet with Marc Stephens to open a channel of cOl11l11unication whilst we attempt to continue our investigations. Every effort is being made to ensure accuracy & we know this now may required as evidence in a UK court & I would have to show how the evidence was collated. I suggest a telephone call to discuss the strategy & impact. Kind regards, James CEO - Qatar & UAE Jupiter Military & Tactical Systems Al Saad - Area 38 Street No. 893, Building NO.7 P.O. Box 22509 Doha State of Qatar +44 (0) 7917 401601 info@jupiter-private.com www.jupiter-private.com Jupiter Executive Protection 43 Berkeley Square Mayfair, London WlJ 5FJ +44 (0) 7917 401601 This email and any files transmitted with it are confidential and intended solely for the use ofthe individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately bye-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. Exhibit 3, Page 37 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 42 of 58 Page ID #:2292 On 5 Sep 2018, at 01:20, Jared Birchall < jaredbirchall@gmail.com> wrote: So are you saying you don't have the data gathered? On Tue, Sep 4, 2018 at 3:53 PM Jupiter Military & Tactical Systems wrote: Jim, I appreciate that you need quick results. I am very confident that we will get what we need from Pattaya. I appreciate its open season on "the principle" holds the moral high ground and right now the less said is more. Elon has nothing to prove to anyone!! Unsworth made this happen, not Elon. We know Vernon is a a'bad boy' and we are close to having the evidence we need. Jim I cannot stress enough that we need some time to qualify the data. We will have one shot to get this right and I intent to do so, Kind regards, James CEO - Qatar & UAE Jupiter Military & Tactical Systems AI Saad - Area 38 Street No. 893, Building NO.7 P.O. Box 22509 Doha State of Qatar +44 (0) 7917 401601 info@jupiter-private.com WWN.jupiter-private.com Jupiter Executive Protection 43 Berkeley Square Mayfair, London W1J 5FJ +44 (0) 7917 401601 ~ CJ This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately bye-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying. distributing or taking any action in reliance on the contents of this information is strictly prohibited . Exhibit 3, Page 38 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 43 of 58 Page ID #:2293 Exhibit 3, Page 39 Case Document 84-2 Filed 10/14/19 Page 44 of 58 Page ID #:2294 EXHIBIT 4 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 45 of 58 Page ID #:2295 Exhibit 4, Page 40 Case Document 84-2 Filed 10/14/19 Page 46 of 58 Page ID #:2296 EXHIBIT 5 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 47 of 58 Page ID #:2297 Jeanine Zalduendo From: Sent: To: Cc: Subject: Taylor Wilson Monday, September 23, 2019 1:15 PM Alex Spiro; Robert Schwartz; Alex Bergjans; Jeanine Zalduendo; Michael Lifrak Lin Wood; Matt Wood; Jonathan Grunberg; Nicole Wade; Chris Chatham; Kimmy Hart Bennett Unsworth v. Musk - Plaintiff Supplemental Production [EXTERNAL EMAIL] Counsel: Below please find a link to download Plaintiff’s supplemental production for documents bates labeled VU03314-3414. With the production of these documents, Plaintiff has completed his production and responded to each of Defendant’s meet and confer requests. Please let me know if you have any trouble accessing the documents. Thank you. https://www.dropbox.com/sh/5c5ozya7hsq8ghp/AAD52mHUxPAk8Yzxe7gLT9sOa?dl=0 ______________________ G. Taylor Wilson Partner L. LIN WOOD, P.C. 1180 West Peachtree Street Suite 2040 Atlanta, Georgia 30309 Telephone: (404) 891-1402 Direct Dial: (678) 365-4107 Facsimile: (404) 506-9111 E-mail: twilson@linwoodlaw.com *** PLEASE NOTE OUR NEW SUITE NUMBER 1 Exhibit 5, Page 41 Case Document 84-2 Filed 10/14/19 Page 48 of 58 Page ID #:2298 EXHIBIT 6 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 49 of 58 Page ID #:2299 Exhibit 6, Page 42 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 50 of 58 Page ID #:2300 Exhibit 6, Page 43 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 51 of 58 Page ID #:2301 Exhibit 6, Page 44 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 52 of 58 Page ID #:2302 Exhibit 6, Page 45 Case Document 84-2 Filed 10/14/19 Page 53 of 58 Page ID #:2303 EXHIBIT 7 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 54 of 58 Page ID #:2304 Chat history with Thanet Saved on : 2019/08/1013:16 2018 /07/01 (Sun) 7:34 Vern [Sticker] 7:34 Thanet [Photo] Thanet [Photo] 7:37 7:37 Thanet [Photo] Thanet [Photo] 7:37 Thanet [Photo] 7:37 8:05 Thanet [Photo] 8:06 Thanet [Photo] 12:17 Vern How are you doing in Phamee? VERY 12:21 Thanet Call time 3:24 12:22 Thanet [Photo] 12:22 Thanet What do you think about this map 12:24 Thanet It show the possibility flow rate of the water to the cave system. They base on information we have so far 12:30 Vern We don't know as we have never been in the cave when both streams are flowing . The passage at the downstream end of Monk's Series are considerably smaller than those in the main passage. 12:43 Thanet I see 12:43 Thanet Tomorrow we will try to push the survey to close all small sink hole on the west side of Pa Mee like you suggest 12:43 Vern [Sticker] 13:19 Thanet Ok we got green light to survey, and man power, Do you think that we can have someone that assist us 13:19 Thanet To assist us as advisor 13:19 Thanet The west side of pa mee like you suggest 15:21 Thanet Ok we got green light to survey, and man power, Do you think that you can spare someone that can assist us in the survey? The west side of pa mee like you suggest 15:21 Thanet [Photo] 15:22 Thanet Parameter area that our team will survey tomorrow is in red circle. 17:07 Vern My friend 's British Divers get to the junction tonight. Water from Monks Series clear and water feel warmer than water from far end which is cloudy and colder. This means water in Monks Series has not travelled a long way underground? 18:00 Thanet Yes 18:00 Thanet Water from monk series is closer to recharge area on north side 18:02 Thanet Which mean it has to be recharge from close by sin k hole or crack 18:05 Thanet I have my team working on the possible recharge area map on pa mee area for survey tomorrow I will send you copy when it done 2018/07102(Mon) 1:01 Thanet [Photo] Thanet [Photo] 1:01 1:01 Thanet Ok here it is 1:02 Thanet 1. 589 ,371.418 2,254,893.748 Meters 2. 589 ,255.662 2,254,814.373 Meters 3. 589 ,206.053 2,254,771 .378 Meters 4.589 ,030.766 2,254 ,774.686 Meters 5.588,971.235 2,254,599.399 Meters 6.589,483.866 2,254,179.372 Meters 7.589 ,067.146 2,254,162.836 Meters 8.588,743.031 2,254,083.460 Meters 9.589 ,004.307 2,253,726.272 Meters 10.588,547.900 2,253,964.398 Meters 11.588,779.411 2,253,679.970 Meters 12.588,759.567 2,253,613.824 Meters 13.588 ,544 .593 2,253,593.980 Meters 14.589,060.532 2,253,504.683 Meters 15.589,040 .688 2,253,375.699 Meters 16.588,640.505 2,253,250.021 Meters 17.588,4 75 .140 2,253,226.870 Meters 18.589,457.407 2,254,023.929 Meters 19.588,580.973 2,254,959.894 Meters 20.588,653 .734 2,255,095.494 Meters 21 .589 ,649.231 2,254,070.231 Meters 22.589 ,725.299 2,254,880.519 Meters 23.589 ,817.903 2,254,635.779 Meters 24.589.900.585 2.254.314.971 Meters Exhibit 7, Page 46 VU03314 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 55 of 58 Page ID #:2305 5:19 Vern Not an easy caving trip and so much more to find in Monks Series. It's an interesting part of Tham Luang . May even have an upper series 5:19 Thanet Wow Thanet That will be new discovery 5:20 5:20 Vern Let me have the info when convenient Vern [Sticker] 5:20 5:20 Thanet Sure, will do 5:20 Vern Lot's of new passages to find 5:20 Thanet Being a caver must be very excited 5:21 Thanet Discover thing, go to the unknown Vern [Sticker] 6:07 Vern [Photo] 9:36 9:49 Vern Where Monks Series Ends the passage then heads west for circa 400metres not yet surveyed. Most of the 400metres is crawling some flat out. It ends in a very low section which requires digging but you can see the passage continuing with still a strong draught Vern Effectively it runs up the valley between the 2 large blocks of limestone 9:50 2018/11/11(Sun) 20 18/11/13(Tue) 3:05 Thanet [Sticker] 3:05 Thanet Hi Vern 3:05 Thanet Sorry for late reply 3:05 Thanet Quite busy with work and stuff Thanet [Photo] 3:05 3:05 Thanet [Photo] Thanet They said he went to chamber 3 3:05 3:06 Thanet And also there is drama behind thus as well 3:06 Thanet The person who took musk and his team inside the cave should ask permission from the central command first 3:07 Thanet But instead they going in without permission but using influence to Prime minister to go in 3:08 Thanet Next day they were also fighting over this as many people specially Narongsak is very upset Thanet Because of the rescue operation is undertaking that why they so stick with regulation at that time 3:09 3:09 Vern [Sticker] 3:10 Thanet No problem 3:10 Vern Howru 3:11 Thanet Good little busy with work here and coordinated with my team in Thailand that doing water work 3:11 Thanet What about you? 3:11 Vern Busy and Tired Thanet 555 you should take some time off 3:12 3:12 Thanet I heard that Matt's book is on sale tomorrow Vern Have a meeting with Head of National Parks tomorrow morning at Tham Luang. Will be interesting (exclamation) 3:12 Vern Dr Harry and Dr Craig are asking for my help with the book they are doing 3:13 3:13 Thanet Ah great I!! 3:13 Vern https:l/www.smh.com .au/world/asia/richard-harris-craig-challen-Iand-6m-book-movie-deal-on-thai-cave-201811 05p50e6r.html 3:13 Thanet It will be wonderful for sure 3:14 Vern I now have an agent/representative 3:15 Thanet 555 3:15 Thanet That good , at least I'm sure they will have to pay you for permission 3:15 Vern You also need one (exclamation) 3:15 Thanet I wish they will be people pay me for my story 555 3:16 Vern You have gone out too soon with your daily diary Thanet No one have seen it only you and Martin 3:16 Thanet Not even Matt 3:17 3:18 Thanet Did Matt have to pay you for the story and your corporation? 3:18 Vern I can try help through my agent but not sure he needs it. He's a British Music Producer and Promoter very well comnected throughout the film and music industry. He's 51 and doesn't neef to work. Lives in Chiangmai at the moment 3:19 Thanet Cool , that be great Vern Not a £$ from Matt (crazy) very stupid of us 3:21 3:21 Thanet 5555 same here 3:22 Thanet You know , we all should get together and write the book invloved our role in it in very detail 3:22 Thanet I'm sure many agency will love to pay us for our story 3:22 Thanet That's what Capt Dan recommend Vern We have gone about it in the wrong way but some are only in it for themselves £££ 3:23 3:23 Vern People can get greedy Thanet 555 3:25 3:25 Thanet Too bad 3:26 Thanet Well I'm sure if John Chu movie will included our role, they will may give us some compensate or royalty fee Exhibit 7, Page 47 VU03369 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 56 of 58 Page ID #:2306 3:27 Vern You should see the email I've just received from Dr Harry and Dr Craig book writer. They NEED ME SO SO MUCH . Sent it on to my agent 3:27 Vern My agent is in touch with John Chu 3:28 Thanet I think they will pay you for your help 3:28 Thanet That nice, everyone know are very important in this rescue 3:29 Thanet You are ** 3:29 Vern I'm good to play hardball had enough of book writers and film companies taking the piss 3:30 Thanet [Sticker] 3:31 Thanet Well , if there is anything I could help you or Dr Harris, just let me know 3:32 Vern I will mate let me speak to my agent. I have also put him in touch with Josh 3:35 Thanet Cool. 3:36 Thanet Josh contact me the other day 3:36 Thanet He ask if I have any video of him on July 6 Thanet He mention about he writing his involvement in diary? 3:37 Thanet And almost done 3:37 3:38 Thanet And also said he will try to connect me with the UTA who is working with Ivanhoe production 3:55 Vern Will is seeing Josh later this morning in Chiangmai 4:07 Vern Don't jump in let them swet 4:10 Thanet Sure, no one contact me yet 4:10 Thanet Beside josh 4:11 Thanet I think all of us should stick together on this Vern 4:11 Vern [Sticker] Thanet It might be better to present our story as a package 4:11 4:12 Thanet It will more valuable , most interesting story front and behind the scene that people don't know and if we can get British divers in with us it even better Vern Leave the British Divers they are trying to do there own thing leave others out (exclamation) 4:15 4:15 Thanet Really? 4:16 Vern [Sticker] 4:17 Vern What is your LINE ID 4:18 Vern Forget about the divers OK 4:19 Thanet Sure, 4:19 Vern What is your LINE ID 4:19 Thanet Line ID: thanetnatisri 4:20 Vern I have sent to my agent his name Will Robinson 4:24 Thanet Cool , thank you Hollywood CM want to meet with me in Maesai (exclamation) 4:28 Vern 4:31 Thanet Wow 4:31 Thanet That great I!! 4:31 Thanet [Sticker] 4:32 Vern Let them swet 4:33 Vern You sent me 3 videos in the war room on the 6th can send to me again 4:34 Thanet Sure, let me find it 4:34 Thanet It long time ago 5555 4:35 Vern I have them but cannot open say no longer available 4:35 Thanet There also a picture of private meeting between king guard, me, Lt Governor, Deputy General in there early July 6 4:35 Thanet In my diary, have you see it? Vern What page 4:35 4:36 Thanet That meeting is the starting point on the whole July 6 4:36 Thanet I can't remember 4:36 Vern July 6 is such a key day 4:38 Thanet [Photo] 4:39 Thanet [Photo] Thanet The first one is late July 6, 4:39 4:39 Thanet The second is morning July 6 4:40 Vern I got these already need the videos 3 4:40 Thanet [Photo] 4:41 Thanet This is how decision were made early July 6 4:42 Thanet At around 12:30 pm, the Minister of interior is on speak phone in middle of the table give us order to go head and start prepare dive rescue plan 4:42 Thanet I was not suppose to take this photo 4:43 Vern What is the map for 4:43 Thanet [Video] 4:43 Thanet [Video] 4:44 Thanet Map is for divert water on pamee area 4:44 Thanet [Video] 4:44 Thanet None of these video suppose to be taken 4:45 Thanet They are under strict order not to leak any of this out, But Colonel did take video anyway 4:46 Thanet *meeting BRILLIANT 4:48 Vern Exhibit 7, Page 48 VU03370 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 57 of 58 Page ID #:2307 4:48 Vern [Sticker] If I tell true story I risk being told to leave Thailand 4:49 Vern 4:49 Thanet Not really, 4:49 Thanet Not they are ok with it 4:49 Thanet Now 4:49 Thanet Now they ok, since many story had already been told by the American 4:50 Vern Your story My story Josh story VERY POWERFUL Thanet So I ask them if that ok to show may video , they said is ok. 4:50 4:51 Thanet Yes!!! That why I think we should put our story together. And present as a package 4:51 Thanet It probably one of the most important piece that made this mission accomplish. 4:52 Thanet With out you on June 26 meeting, without me and josh on July 5-6. None of this would never happened . They kid will dies for sure 4:55 Vern The email I received from Hollywood CM first line say: you that's me) very much top of the list. Were it not for your experience, knowledge of the cave and swift response, it no exaggeration to say those boys would most likely not be alive today. Vern I have not replied. Will my agent will control £££$$$ 4:55 Thanet That great !! 4:56 4:56 Vern Sit tight 4:56 Thanet I'm happy for you. You truly deserved it. 4:57 Thanet [Sticker] Vern I will make the divers sugger for leaving us out of the loop 4:57 4:57 Vern Suffer 4:57 Thanet 5555 4:57 Thanet They really shouldn 't do that Vern You and Josh also deserve 4:57 4:58 Thanet We are the one that fight hard, made decision happed . We set thing up for them to do the job Vern Events happened because of certain people coming together sometimes by chance meeting 555 4:58 4:59 Thanet I think it because the divers, doctor are on spotlight 4:59 Thanet Many people, media know them. 5:00 Thanet But we are behind the scene don 't get much chance to present ourself to the media while we were working 5:00 Vern I'm ready to stick the boot in 555 5:01 Vern I accept without the divers the kids wouldn't be alive 5:02 Thanet But from 3 of us, I think you probably well know to public and media more. Since you were there in beginning and made the important decision meeting on June 26 and get divers in 5:02 Thanet But story on behind on July 6 no one know Vern I know but I not the only one and yes July 6 no one knows 5:02 Vern If they don't meet me the story is not worth anything £££$$$ 5:04 5:05 Thanet Yes, Well let me know if there is any news developments regarding movie deal. It would be awesome if my part will be in it 5555 .. I'm really appreated you look out for me Vern , that mean a lot 5:06 Thanet And if there is anything I can help you. Please do not hesitate. Let me know , it alway an honor to meet and work with you 5:06 Thanet **Appreciated Vern I will my friend. Don't worry I will keep you informed on what is happening. 5:07 5:08 Thanet Thank you , I'm off to bed now. Will talk to you later 5:08 Vern An honor for me also to know and work with you 5:08 Thanet [Sticker] Vern [Sticker] 5:08 8:08 Vern [Photo] 8:08 Vern My agent with Head of Wild Boars Committee Khun Sirisak 8:09 Vern https://youtu .be/trGm2-qPXcE Vern Produced by my agent Will Robinson 8:09 17:32 Thanet [Sticker] 17:33 Thanet That's wonderful 2018/11/14(Wed) 24:28 Thanet Just finish read some part of Matt's book 24:28 Thanet It look wonderful 1:10 Thanet He got a good story of Col. On decision making on July 6 too Vern I hope he will send me a copy 555 1:11 1:12 ThanetYes , lhopetoo 1:12 Thanet I was impatient so I bought digital copy today for $12 1:12 Thanet Online 1:12 Thanet [Sticker] 1:13 Thanet He did get a few fact but not whole story from us specially details on July 5-6 Thanet And there are so many part of story invloved you 1:14 1:18 Vern [Sticker] 1:38 Thanet [Photo] Thanet [Video] 2:31 2018/11/15(Thu) Exhibit 7, Page 49 VU03371 Case 2:18-cv-08048-SVW-JC Document 84-2 Filed 10/14/19 Page 58 of 58 Page ID #:2308 8:28 Vern p50e6r.html 14:47 Thanet 14:47 Thanet 14:47 Thanet 14:49 Thanet 14:50 Thanet https:lIwww.smh.com.au/world/asia/richard-harris-craig-challen-land-6m-book-movie-deal-on-thai-cave-20 181105- [Sticker] Wow I just read your email It is funny that, people wanted you to help them out. While they making fortune for themself... Ellis don 't even mention about the offer they willing to give you on your cooperation 2018/11/16(Fri) 1:12 Vern Will Robinson my agent will contact you if ok with you 1:19 Vern They want everything FREE. That's why no one should have helped Matt Guttman (exclamation) he will make a fortune . We have been very naieve not just you and me but Josh and everyone else 3:48 Thanet [Sticker] 3:48 Thanet Yes 3:51 Thanet Sure Vern , you can have will contact me anytime Vern Just sent you an email and copied in Josh 3:56 4:09 Thanet [Sticker] 4:09 Thanet It is good that all of us can stick together 4:11 Vern Ellis has done a book deal with Ballantine. But he cannot interview Coach Ekk or the boys or me so the deal is dead in the water 555 4:11 Vern https:/Iwww.google.com/amp/s/deadline .com/20 18/1 O/ballantine-books-thai-cave-rescue-into-the-dark-universal-worldenglish-rights-full-accou nt-1202490327 lampl 4:15 Thanet First, no film or book will complete without the guy who know the cave better than anyone and pull everyone together, get diver in , push official to do the right thing on June 26 2) the guy who did water work, partial in charge and divert water section in rescue, that made dive rescue possible and help turn decision around on July 6 3) the guy who work inside negotiating between Thai and goverment and help push official to dive rescue on July 6 4:15 Thanet Yes 55555 Thanet I think we have bargaining power, 4:16 Vern [Sticker] 4:16 4:45 Thanet [Photo] 4:46 Thanet [Photo] 4:46 Thanet Significant player hah? 4:47 Thanet Obviously it won't complete without your role !! 4:48 Thanet Like you said, it dead in the water 4:48 Vern [Sticker] 4:49 Thanet Some time I do wonder how come they made deal with driver, give them money and not the same to us? 4:49 Thanet 5555 4:49 Thanet It like they just over look us and looking for free pass 4:51 Vern He cannot interview Coach Ekk or the boys Wild Boars Committee not allow 4:55 Thanet Why would he announce it then Thanet That crazy 4:55 5:30 Vern [Sticker] 22: 38 Tha net https:llwww.thetimes.co.uk/article/thai-fil m-maker-will-beat-ho lIywood-with-sto ry-of-cave-rescue-hs3xh8q 59 2018/11/17(Sat) 24:40 Vern The Cave film will not be shooting in Chiang Rai now they want to shoot in Sa Kaew province North East 24:40 Vern He's only including 1 diver Jim Warny who arrived on the 7th and has excluded everyone else (exclamation) Waller is a W R 24 :53 Thanet 5555 24:54 Thanet [Photo] 24:55 Thanet Seem like he will also play the actor too, very interesting to see how it will turn out Vern This is a low budget film and 1:00 I wish him the best. Our platform is "from Local To Global" and was well received by the selection committee. 1:00 Vern Message from the Warner Bros guy (exclamation) 1:02 Thanet [Sticker] 1:03 Vern He will get very little cooporation by the government and they are monitoring his activities closely and to make certain that he and his team will not violate any rights. 1:20 Vern He will not and can only write his script with readily available news Ipublic information only . 1:22 Thanet I see Thanet This is very tricky to deal with government agency indeed 1:22 3:15 Vern [Photo] Vern [Photo] 3:16 3:16 Vern [Photo] 3:16 Vern [Photo] 3:16 Vern [Photol Exhibit 7, Page 50 VU03372