Attachment to Miscellaneous_ Document - Pages 587 to 841

8/19/2019 Attachment to Miscellaneous_ Document - Pages 587 to 841

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CONFIDENTIAL

EXHIBIT 40-Cto the

JOINT OPPOSITION OF THE GAWKER DEFENDANTS AND THEIRCOUNSEL TO PLAINTIFF’S EMERGENCY MOTION TO CONDUCT

DISCOVERY CONCERNING POTENTIAL VIOLATION OFPROTECTIVE ORDER, TO COMPEL TURNOVER OF CONFIDENTIAL

DISCOVERY MATERIALS AND FOR ORDER TO SHOW CAUSE

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EXHIBIT 41-Cto theJOINT OPPOSITION OF THE GAWKER DEFENDANTS AND THEIRCOUNSEL TO PLAINTIFF’S EMERGENCY MOTION TO CONDUCT



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BOLLEA 001

CONFIDENTIAL-ATTORNEY'S EYES ONLY


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CONFIDENTIAL – FILED UNDER SEAL

SEALED APPENDIX TAB 20

(referred to as “Confidential Filing 17”during the October 1, 2015 Hearing)

DOCUMENT: The Gawker Defendants’ ConfidentialSupplemental Opposition to Plaintiff’s EmergencyMotion to Conduct Discovery Concerning PotentialViolations of Protective Order, to Compel Turnoverof Confidential Discovery Materials and For Order

to Show Cause, and Exhibits 1, 2, 4, 7, 8 and 9thereto, filed on August 25, 2015

ORDER: NOVEMBER 18, 2015 AMENDED ORDER*

PARAGRAPH: 10.D(15)

*These documents also were sealed under Paragraph 8.D(15) of the October27, 2015 Order.


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IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUITIN AND FOR PINELLAS COUNTY, FLORIDA

TERRY GENE BOLLEA professionallyknown as HULK HOGAN,

Plaintiff,vs.

HEATHER CLEM, et al. ,

Defendants. ______________________________________/

Case No. 12012447CI-011

CONFIDENTIAL SUPPLEMENTAL OPPOSITION TO PLAINTIFF’S EMERGENCYMOTION TO CONDUCT DISCOVERY CONCERNING POTENTIAL VIOLATION OF

PROTECTIVE ORDER, TO COMPEL TURNOVER OF CONFIDENTIALDISCOVERY MATERIALS AND FOR ORDER TO SHOW CAUSE

Undersigned counsel respectfully file this confidential supplemental opposition on behalf

of their clients – Gawker Media, LLC, Nick Denton, A.J. Daulerio (collectively, “Gawker”) –

and on behalf of themselves in order to bring to this Court’s attention newly discovered facts that

bear on the adjudication of Plaintiff’s Motion.

As explained below, documents produced by the FBI in the FOIA action since Gawker

and their counsel submitted their original opposition reveal additional facts that further

underscore why the Motion should be denied in its entirety. Because those documents are

provisionally designated as “CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (pending

plaintiff’s review and designation and pending further challenge by Gawker), they are described

in this confidential filing.

Specifically, documents produced by the FBI on August 17, 2015 indicate that, in

November 2012, after the video excerpts at issue in this case were published, Bubba the Love

Sponge Clem made complaints to the FBI about a group of people who were threatening to

release additional sex tape footage. Because the FBI redacted the names of any individuals who

Filing # 31288728 E-Filed 08/25/2015 02:46:13 PM


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2

did not sign privacy waivers, the names of the complaining parties have been redacted. Still, the

documents make clear that the complaints have to do with threats directed toward Mr. Clem. 1

A. Official FBI Statement of Mr. Clem

The FBI produced a Form FD-302 documenting a statement to the FBI interview by the

person principally complaining about the alleged threats. From the context, that person was

obviously Mr. Clem. For example, the FBI’s official statement identified him as someone with a

“radio show” that was at one time broadcast on “Sirius Radio.” Conf. Ex. 1-C at 1-2. According

to the statement, the FBI asked him “to explain his role in the filming and producing of the sex

tapes between his [redacted, presumably “wife”] HEATHER COLE (formerly CLEM) andTERRY BOLLEA, aka HULK HOGAN.” Id. at 1. In response, he stated that “COLE wanted to

sleep with BOLLEA while they were married and further advised COLE was into sleeping with

other men and taping the act.” Id. That same summary describes him as having stated “that he,

COLE and BOLLEA all knew that they were being filmed. . . . The camera was not concealed;

rather it was a security type camera in the room which fed to the master security unit.” Id. at 2.

He “again advised that the camera was obvious and everyone knew about the filming.” Id.

B. Official FBI Statement of Stephen Diaco, Mr. Clem’s Counsel

The FBI documents also contain another Form FD-302 documenting a statement to the

FBI by another person who accompanied Mr. Clem and who made similar complaints on his own

behalf to the Bureau. From the context, that person is obviously Stephen Diaco, Esq., widely

known to be one of Mr. Clem’s lawyers. Specifically, that official statement describes an

incident that occurred on “September 28, 2012” in which this person “and two other associates

1 Although the FBI has redacted the identities, Gawker currently has pending before thefederal court a request to provide unredacted versions of the documents produced. We have

provided the redacted versions now so that they are submitted promptly to the Court. Ifunredacted versions are ordered produced, we will submit them upon receipt.


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went” to an office in “St. Petersburg” for the purpose of asking someone employed there “to stop

posting threatening and intimidating messages on the internet.” Conf. Ex. 2-C at 1. According

to his statement to the FBI, the person confronted at his office later “created an entry on his

blog” that contained “information regarding the confrontation.” Id. The FBI’s latest document

production includes a blog post in which the author describes being “paid a visit by Bubba the

Love Sponge’s attorney and friend Stephen Diaco” at his “office in Saint Petersburg” on

September 28, 2012, and being confronted about alleged threats directed at Mr. Clem. Conf.

Ex. 3-C.

C. Mr. Clem’s Complaints Include Threats by the “Sixers” to ReleaseAdditional Sex Tape Footage

Mr. Clem’s complaints focused on a group of six people calling themselves the “sixers,”

whom Mr. Clem claimed were “harassing and threatening” him online. See Conf. Ex. 4-C. Mr.

Clem’s concerns about threats and harassment from his online critics have been well

documented. See, e.g. , Conf. Ex. 5-C (Nov. 23, 2013 Tampa Bay Times article describing Mr.

Clem’s complaints to law enforcement about those critics); Conf. Ex. 6 (Dec. 13, 2012 blog post

from one such critic referring to the “drama surrounding Bubba and the Sixers”). 2

D. Evidence that People Other than Gawker and Its Counsel Had Access to theFootage At Issue

As relevant here, the newly-produced FBI documents reveal that, among the threats Mr.

Clem faced were threats to release additional sex tape footage. For instance, on October 21,

2012, one of the members of this group apparently tweeted the following at Mr. Clem: “Tell you

a little secret. Depending on how tomorrow’s show goes down, you might get to hear about

2 Although published news reports are obviously not confidential, filing them publiclymight arguably reveal the substance of the confidential FBI documents discussed herein.Accordingly, we have filed them confidentially as well, while preserving our ability to challengethose designations.


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another sex tape.” Conf. Ex. 7-C; see also Conf. Ex. 8-C (timeline summarizing various

threatening communications). The next day, someone apparently tweeted a photograph of a

DVD at Mr. Clem, along with this message: “[Redacted] you want to tell you[r] public

audience you have more tapes or shall I? @TMZ.” Conf. Ex. 9-C (referencing TMZ, which

shortly before this tweet was sent had reported that it had seen a copy of another sex tape, which

turns out to have been the one with the racist language on it); see also Joint Opp. Ex. 17 at 1:50 –

2:15 (TMZ conceding it had been provided with and seen a copy of that footage). Mr. Clem and

his counsel apparently found these tweets concerning enough, at least in the context of the other

threats he had received, to bring them to the attention of the FBI.Mr. Clem and/or Mr. Diaco also prepared and provided to the FBI a timeline of events

related to his complaints concerning the threats and harassment he had received; as reflected

therein, it was centered around the possible disclosure of additional sex tape footage. See Conf.

Ex. 8-C. Thus, taken together, these documents reveal a group of six people who appear to have

had access to additional sex tapes and who threatened Mr. Clem with further release in a manner

that he and his counsel thought was serious enough to warrant involving the FBI.

In bringing this to the Court’s attention, neither Gawker nor its counsel intends to suggest

that this group of people was necessarily responsible for providing information to the National

Enquirer about Bollea’s racist and homophobic statements on one of the sex tapes. All Gawker

and its counsel know for certain about who provided that information is that it was not them.

The point in bringing this additional information to the Court’s attention is to underscore that, in

addition to the numerous other people identified in the Joint Opposition, there are even more

people, unconnected to this litigation, who knew about these additional tapes, had previously

threatened to release them, and, unlike Gawker and its counsel, actually had access to them.


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August 25, 2015 Respectfully submitted,

THOMAS & LOCICERO PL

By: /s/ Gregg D. ThomasGregg D. Thomas

Florida Bar No.: 223913Rachel E. FugateFlorida Bar No.: 0144029

601 South Boulevard P.O. Box 2602 (33601)Tampa, FL 33606Telephone: (813) 984-3060Facsimile: (813) [email protected]@tlolawfirm.com

Seth D. BerlinPro Hac Vice Number: 103440Michael D. SullivanPro Hac Vice Number: 53347Michael BerryPro Hac Vice Number: 108191Alia L. SmithPro Hac Vice Number: 104249Paul J. Safier Pro Hac Vice Number: 103437LEVINE SULLIVAN KOCH & SCHULZ, LLP1899 L Street, NW, Suite 200

Washington, DC 20036Telephone: (202) 508-1122Facsimile: (202) [email protected]@[email protected]@lskslaw.com

[email protected]

Attorneys for Defendants Gawker Media, LLC, Nick Denton and A.J. Daulerio and Their

Counsel


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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 25th day of August 2015, I caused a true and correct

copy of the foregoing to be served via the Florida Courts’ E-Filing Portal upon the following

counsel of record:

Kenneth G. Turkel, Esq. David Houston, [email protected] Law Office of David HoustonShane B. Vogt, Esq. [email protected]@BajoCuva.com 432 Court StreetBajo Cuva Cohen & Turkel, P.A. Reno, NV 89501100 N. Tampa Street, Suite 1900 Tel: (775) 786-4188Tampa, FL 33602Tel: (813) 443-2199

Fax: (813) 443-2193Charles J. Harder, [email protected] E. Mirell, [email protected] McGrath, Esq.

[email protected] Mirell & Abrams LLP132 South Rodeo Drive, Suite 301Beverly Hills, CA 90212-2406Tel: (424) 203-1600Fax: (424) 203-1601

Attorneys for Plaintiff

/s/ Gregg D. ThomasAttorney


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EXHIBIT 1-Cto the

CONFIDENTIAL SUPPLEMENTAL OPPOSITION TOPLAINTIFF’S EMERGENCY MOTION TO CONDUCTDISCOVERY CONCERNING POTENTIAL VIOLATION OF

PROTECTIVE ORDER, TO COMPEL TURNOVER OFCONFIDENTIAL DISCOVERY MATERIALS AND FOR ORDER

TO SHOW CAUSE

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TO SHOW CAUSE

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TO SHOW CAUSE

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TO SHOW CAUSE

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EXHIBIT 8-Cto the



TO SHOW CAUSE

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EXHIBIT 9-Cto the



TO SHOW CAUSE

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DOCUMENT: Transcript of the portion of the hearing held beforethe trial court on April 23, 2014, which wascontained in Confidential Exhibit 2-C of theGawker defendants’ motion to determine theconfidentiality of transcripts of closed court

proceedings


PARAGRAPH: 10.F(1)

*This document also was sealed under Paragraph 8.F(1) of the October 27,2015 Order.


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CONFIDENTIAL

EXHIBIT 2-Cto theGAWKER DEFENDANTS’ MOTION

TO DETERMINE CONFIDENTIALITY OFTRANSCRIPTS OF CLOSED COURT PROCEEDINGS

Filing # 31132561 E-Filed 08/20/2015 04:32:22 PM


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IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA

TERRY GENE BOLLEA professionally known as HULK HOGAN,

Plaintiff,

vs. Case No. 12012447 CI-011

HEATHER CLEM; GAWKER MEDIA, LLC a/k/a GAWKER MEDIA, et al.,

Defendants. /

TRANSCRIPT OF: CONFIDENTIAL PROCEEDINGS BEFORE: Honorable Pamela A.M. Campbell

DATE: April 23, 2014

TIME: 3:20 p.m.

PLACE: Pinellas County Courthouse 545 First Avenue North Room 300 St. Petersburg, Florida

REPORTED BY: Natalie W. Breaux, RPR, CRR Notary Public State of Florida at Large


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APPEARANCES:

KENNETH G. TURKEL, ESQUIRE Bajo Cuva Cohen & Turkel, P.A. 100 North Tampa Street Suite 1900

Tampa, Florida 33602 - and - CHARLES J. HARDER, ESQUIRE Harder Mirell & Abrams LLP 1801 Avenue of the Stars Suite 1120 Los Angeles, California 90057 Appeared for Plaintiff;

SETH D. BERLIN, ESQUIRE Levine Sullivan Koch & Schulz, LLP 1899 L Street Northwest Suite 200 Washington, DC 20036 - and -

PAUL J. SAFIER, ESQUIRE Levine Sullivan Koch & Schulz, LLP 1760 Market Street Suite 1001 Philadelphia, Pennsylvania 19103 - and - GREGG D. THOMAS, ESQUIRE Thomas & LoCicero PL 601 South Boulevard Tampa, Florida 33606 Appeared for Defendants Gawker Media, LLC, Nick Denton, A.J. Daulerio and for specially appearing Defendant Blogwire Hungary Szellemi Alkotast Hasznosito, KFT (now known as Kinja, KFT).


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1 The transcript of confidential

2 proceedings, before Honorable Pamela A.M. Campbell,

3 beginning at 1:30 p.m., taken on the 23rd day of

4 April, 2014, at 545 First Avenue North, Room 300,

5 St. Petersburg, Florida, reported by Natalie W.

6 Breaux, Registered Professional Reporter, Certified

7 Realtime Reporter, and Notary Public in and for the

8 State of Florida at Large.

9 * * * * * *

10 MR. HARDER: It was an extortion attempt

11 where somebody who had the video or a video

12 wanted Mr. Bollea to pay them off, and so he

13 reported this to the FBI, and the FBI --

14 THE COURT: This is the same tape?

15 MR. HARDER: I don't know if it's the16 same tape.

17 THE COURT: Same time frame?

18 MR. HARDER: It's the same time frame.

19 MR. BERLIN: It's the same time frame

20 about an extortion, but it's a Sex Tape.

21 MR. HARDER: If I could just finish.

22 MR. BERLIN: I'm sorry. I thought you

23 were.

24 MR. HARDER: I wasn't. So he reported

25 it to the FBI. The FBI wanted to have a sting


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1 operation, and they set up a sting operation,

2 and there was an attorney from California

3 named Davidson and a person called Mr. X. And

4 Mr. X was supposed to show up with Mr.

5 Davidson. Well, Mr. X -- we didn't know the

6 identity of the person -- instead sent an

7 intermediary and Mr. Davidson, and there was

8 exchanges of information, there was a dummy

9 check for $150,000. And at the right moment,

10 the FBI had numerous officers go from one room

11 of the hotel into the room that Mr. Bollea and

12 Mr. Houston were in and made arrests at that

13 time.

14 The AUSA sent a letter to Mr. Berlin

15 saying that Gawker is not in any way being16 investigated and it seems like they're at the

17 end of the line in terms of the investigation

18 and there is not going to be a prosecution.

19 But these are documents that pertain to Mr. X

20 and his attorney Davidson, and there was an

21 intermediary who was present instead of Mr. X.

22 And so these communications are communications

23 between Mr. Houston and the FBI and the AUSA

24 pertaining to this investigation. I think

25 that if you look at this you'll see that it


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1 has nothing to do with Gawker.

2 THE COURT: But I think it still has

3 something to do with the tape.

4 MR. BERLIN: Your Honor, you asked us

5 earlier in today's hearing if we knew the

6 source of the tape, and I answered candidly,

7 which I wasn't -- I don't know. This obviously

8 seems like a useful piece of information for

9 both sides in the case about this -- you know,

10 in this hundred-million-dollar dispute to have

11 access to it so we can figure out if that's the

12 person who gave it to us and if that has

13 something to do with the case, meanwhile,

14 especially in a claim where they're otherwise

15 asserting that we got it from Heather Clem.16 THE COURT: You have other confidential

17 orders in regard to this particular case.

18 Right?

19 MR. BERLIN: We have other confidential

20 -- we have a confidentiality order in place,

21 and we've produced stuff in the confidence back

22 and forth. And notwithstanding Mr. Harder's,

23 you know, criticism of Gawker, Gawker has not

24 published anything and -- that it's gotten in

25 discovery in this case, not one thing.


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1 THE COURT: You even included that in

2 your papers. See, I do read them. So I think

3 that they are relevant, so I'm not going to

4 say that they're not relevant. I think they

5 are relevant because that's one of the

6 critical aspects I think of the case or at

7 least in resolving the case, is how did Gawker

8 get it and how did this all come about. So

9 I'm going to order that it be discovered but

10 that it be part of the confidentiality

11 agreement between the parties.

12 MR. BERLIN: They can certainly mark it

13 confidential and we will respect that.

14 MR. HARDER: I would request that Gawker

15 -- it be an attorneys' eyes only designation so16 that Gawker itself doesn't get these documents,

17 because it can post them.

18 THE COURT: If it posted them, what do

19 you think I'm going to do with that?

20 MR. BERLIN: I think we're going to be

21 in hot water.

22 MR. HARDER: I don't know what you're

23 going to do with it, but they'll take it to

24 the Court of Appeal and they'll say it's

25 newsworthy.


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1 THE COURT: I don't think so.

2 MR. BERLIN: I will say on the record

3 that there was no First Amendment right to

4 publish things that you got in discovery.

5 There is a U.S. Supreme Court case on that

6 called Seattle Times versus Rhinehart, and we

7 filed it. So we understand it.

8 But, Your Honor, what I'd like to do is

9 to get a -- I'd like to be not in a position

10 where my client -- my direct client is a lawyer

11 in the law department, is the general counsel

12 for Gawker, and I would like them to be

13 included in the attorneys' eyes only. We don't

14 share anything on this case with anybody else

15 at Gawker, precisely for the reason that if16 it's protected by a confidentiality order --

17 THE COURT: You're in trouble.

18 MR. BERLIN: -- they might do something.

19 No, but they as a client could get it, but we

20 don't do that. So I would like -- if she is

21 included in that, that would be fine. But I

22 would otherwise respect that.

23 THE COURT: I'm fine with that.

24 MR. HARDER: Okay.

25 THE COURT: Thank you.


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1 MR. BERLIN: And you would like us to --

2 THE COURT: So he gets two of those.

3 Those are your envelopes to take back. The

4 remainder of the people that aren't here, I'm

5 going to mail them.

6 MR. BERLIN: Okay. So just --

7 THE COURT: They get two of those.

8 MR. BERLIN: They get two and I have the

9 others. Thank you, Your Honor.

10 THE COURT: Great. Thank you.

11 (End of confidential proceedings.)

12

13

14

1516

17

18

19

20

21

22

23

24

25


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CERTIFICATE OF REPORTER

STATE OF FLORIDA:COUNTY OF HILLSBOROUGH:

I, Natalie W. Breaux, Notary Public in andfor the State of Florida at Large, do hereby certifythat I reported in shorthand the foregoingproceedings at the time and place therein designated;that the witness herein was duly sworn by me; that myshorthand notes were thereafter reduced totypewriting under my supervision; and that theforegoing pages are a true and correct, verbatimrecord of the aforesaid proceedings. Witness my hand and seal April 25, 2014, inthe city of Tampa, County of Hillsborough, State ofFlorida.

Natalie W. Breaux Notary Public State of Florida at Large


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DOCUMENT: Transcript of the hearing held before the SpecialDiscovery Magistrate on July 18, 2014, which wascontained in Confidential Exhibit 3-C of theGawker defendants’ motion to determine theconfidentiality of transcripts of closed court

proceedings


PARAGRAPH: 10.F(2)

*This document also was sealed under Paragraph 8.F(2) of the October 27,2015 Order.


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CONFIDENTIAL

EXHIBIT 3-Cto the

GAWKER DEFENDANTS’ MOTIONTO DETERMINE CONFIDENTIALITY OF

TRANSCRIPTS OF CLOSED COURT PROCEEDINGS

Filing # 31132561 E-Filed 08/20/2015 04:32:22 PM


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(referred to as “Confidential Filing 16”during the October 1, 2015 Hearing)

DOCUMENT: Exhibits 3-C, 5-C, and 8-C to the Motion for anOrder Declaring that Plaintiff Has ImproperlyDesignated Certain Discovery Materials as“Attorneys’ Eyes Only,” filed on August 20, 2015

ORDER: NOVEMBER 18, 2015 ORDER ON MOTION TODETERMINE CONFIDENTIALITY

PARAGRAPH: 3


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CONFIDENTIAL

EXHIBIT 3-Cto the

MOTION FOR AN ORDER DECLARING THATPLAINTIFF HAS IMPROPERLY DESIGNATED CERTAIN

DISCOVERY MATERIALS AS “ATTORNEYS’ EYES ONLY”

Filing # 31131053 E-Filed 08/20/2015 04:19:56 PM


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IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA

TERRY GENE BOLLEA professionally known as HULK HOGAN,

Plaintiff,

vs. Case No. 12012447 CI-011

HEATHER CLEM; GAWKER MEDIA, LLC a/k/a GAWKER MEDIA, et al.,

Defendants. /

TRANSCRIPT OF: CONFIDENTIAL PROCEEDINGS BEFORE: Honorable Pamela A.M. Campbell

DATE: April 23, 2014

TIME: 3:20 p.m.

PLACE: Pinellas County Courthouse 545 First Avenue North Room 300 St. Petersburg, Florida

REPORTED BY: Natalie W. Breaux, RPR, CRR Notary Public State of Florida at Large


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APPEARANCES:

KENNETH G. TURKEL, ESQUIRE Bajo Cuva Cohen & Turkel, P.A. 100 North Tampa Street Suite 1900

Tampa, Florida 33602 - and - CHARLES J. HARDER, ESQUIRE Harder Mirell & Abrams LLP 1801 Avenue of the Stars Suite 1120 Los Angeles, California 90057 Appeared for Plaintiff;

SETH D. BERLIN, ESQUIRE Levine Sullivan Koch & Schulz, LLP 1899 L Street Northwest Suite 200 Washington, DC 20036 - and -

PAUL J. SAFIER, ESQUIRE Levine Sullivan Koch & Schulz, LLP 1760 Market Street Suite 1001 Philadelphia, Pennsylvania 19103 - and - GREGG D. THOMAS, ESQUIRE Thomas & LoCicero PL 601 South Boulevard Tampa, Florida 33606 Appeared for Defendants Gawker Media, LLC, Nick Denton, A.J. Daulerio and for specially appearing Defendant Blogwire Hungary Szellemi Alkotast Hasznosito, KFT (now known as Kinja, KFT).


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1 The transcript of confidential

2 proceedings, before Honorable Pamela A.M. Campbell,

3 beginning at 1:30 p.m., taken on the 23rd day of

4 April, 2014, at 545 First Avenue North, Room 300,

5 St. Petersburg, Florida, reported by Natalie W.

6 Breaux, Registered Professional Reporter, Certified

7 Realtime Reporter, and Notary Public in and for the

8 State of Florida at Large.

9 * * * * * *

10 MR. HARDER: It was an extortion attempt

11 where somebody who had the video or a video

12 wanted Mr. Bollea to pay them off, and so he

13 reported this to the FBI, and the FBI --

14 THE COURT: This is the same tape?

15 MR. HARDER: I don't know if it's the16 same tape.

17 THE COURT: Same time frame?

18 MR. HARDER: It's the same time frame.

19 MR. BERLIN: It's the same time frame

20 about an extortion, but it's a Sex Tape.

21 MR. HARDER: If I could just finish.

22 MR. BERLIN: I'm sorry. I thought you

23 were.

24 MR. HARDER: I wasn't. So he reported

25 it to the FBI. The FBI wanted to have a sting


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1 operation, and they set up a sting operation,

2 and there was an attorney from California

3 named Davidson and a person called Mr. X. And

4 Mr. X was supposed to show up with Mr.

5 Davidson. Well, Mr. X -- we didn't know the

6 identity of the person -- instead sent an

7 intermediary and Mr. Davidson, and there was

8 exchanges of information, there was a dummy

9 check for $150,000. And at the right moment,

10 the FBI had numerous officers go from one room

11 of the hotel into the room that Mr. Bollea and

12 Mr. Houston were in and made arrests at that

13 time.

14 The AUSA sent a letter to Mr. Berlin

15 saying that Gawker is not in any way being16 investigated and it seems like they're at the

17 end of the line in terms of the investigation

18 and there is not going to be a prosecution.

19 But these are documents that pertain to Mr. X

20 and his attorney Davidson, and there was an

21 intermediary who was present instead of Mr. X.

22 And so these communications are communications

23 between Mr. Houston and the FBI and the AUSA

24 pertaining to this investigation. I think

25 that if you look at this you'll see that it


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1 has nothing to do with Gawker.

2 THE COURT: But I think it still has

3 something to do with the tape.

4 MR. BERLIN: Your Honor, you asked us

5 earlier in today's hearing if we knew the

6 source of the tape, and I answered candidly,

7 which I wasn't -- I don't know. This obviously

8 seems like a useful piece of information for

9 both sides in the case about this -- you know,

10 in this hundred-million-dollar dispute to have

11 access to it so we can figure out if that's the

12 person who gave it to us and if that has

13 something to do with the case, meanwhile,

14 especially in a claim where they're otherwise

15 asserting that we got it from Heather Clem.16 THE COURT: You have other confidential

17 orders in regard to this particular case.

18 Right?

19 MR. BERLIN: We have other confidential

20 -- we have a confidentiality order in place,

21 and we've produced stuff in the confidence back

22 and forth. And notwithstanding Mr. Harder's,

23 you know, criticism of Gawker, Gawker has not

24 published anything and -- that it's gotten in

25 discovery in this case, not one thing.


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1 THE COURT: You even included that in

2 your papers. See, I do read them. So I think

3 that they are relevant, so I'm not going to

4 say that they're not relevant. I think they

5 are relevant because that's one of the

6 critical aspects I think of the case or at

7 least in resolving the case, is how did Gawker

8 get it and how did this all come about. So

9 I'm going to order that it be discovered but

10 that it be part of the confidentiality

11 agreement between the parties.

12 MR. BERLIN: They can certainly mark it

13 confidential and we will respect that.

14 MR. HARDER: I would request that Gawker

15 -- it be an attorneys' eyes only designation so16 that Gawker itself doesn't get these documents,

17 because it can post them.

18 THE COURT: If it posted them, what do

19 you think I'm going to do with that?

20 MR. BERLIN: I think we're going to be

21 in hot water.

22 MR. HARDER: I don't know what you're

23 going to do with it, but they'll take it to

24 the Court of Appeal and they'll say it's

25 newsworthy.


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1 THE COURT: I don't think so.

2 MR. BERLIN: I will say on the record

3 that there was no First Amendment right to

4 publish things that you got in discovery.

5 There is a U.S. Supreme Court case on that

6 called Seattle Times versus Rhinehart, and we

7 filed it. So we understand it.

8 But, Your Honor, what I'd like to do is

9 to get a -- I'd like to be not in a position

10 where my client -- my direct client is a lawyer

11 in the law department, is the general counsel

12 for Gawker, and I would like them to be

13 included in the attorneys' eyes only. We don't

14 share anything on this case with anybody else

15 at Gawker, precisely for the reason that if16 it's protected by a confidentiality order --

17 THE COURT: You're in trouble.

18 MR. BERLIN: -- they might do something.

19 No, but they as a client could get it, but we

20 don't do that. So I would like -- if she is

21 included in that, that would be fine. But I

22 would otherwise respect that.

23 THE COURT: I'm fine with that.

24 MR. HARDER: Okay.

25 THE COURT: Thank you.


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1 MR. BERLIN: And you would like us to --

2 THE COURT: So he gets two of those.

3 Those are your envelopes to take back. The

4 remainder of the people that aren't here, I'm

5 going to mail them.

6 MR. BERLIN: Okay. So just --

7 THE COURT: They get two of those.

8 MR. BERLIN: They get two and I have the

9 others. Thank you, Your Honor.

10 THE COURT: Great. Thank you.

11 (End of confidential proceedings.)

12

13

14

1516

17

18

19

20

21

22

23

24

25


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CERTIFICATE OF REPORTER

STATE OF FLORIDA:COUNTY OF HILLSBOROUGH:

I, Natalie W. Breaux, Notary Public in andfor the State of Florida at Large, do hereby certifythat I reported in shorthand the foregoingproceedings at the time and place therein designated;that the witness herein was duly sworn by me; that myshorthand notes were thereafter reduced totypewriting under my supervision; and that theforegoing pages are a true and correct, verbatimrecord of the aforesaid proceedings. Witness my hand and seal April 25, 2014, inthe city of Tampa, County of Hillsborough, State ofFlorida.

Natalie W. Breaux Notary Public State of Florida at Large


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CONFIDENTIAL

EXHIBIT 5-Cto the



Filing # 31131053 E-Filed 08/20/2015 04:19:56 PM


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CONFIDENTIAL

EXHIBIT 8-Cto the



Filing # 31131053 E-Filed 08/20/2015 04:19:56 PM


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INDEX OF MATERIALS DESIGNATED BY PLAINTIFF AS“ATTORNEYS’ EYES ONLY” THAT ARE BEING CHALLENGED

DOCUMENTS PRODUCED BY PLAINTIFF

DOCUMENT DESCRIPTION

BOLLEA 001068-1145 Emails to/from K. Davidson, V. Duarte, K. Rosser, and/or D.Houston from October, November, and December 2012

BOLLEA 001145-90Emails to/from D. Houston, K. Rosser, J. Shearn, S. Sweeney,and/or other people from October, November, and December2012; and January, July, and September 2013

BOLLEA 001191-92 September 3, 2013 letter from S. Sweeney to D. Houston

BOLLEA 001193-1216 November 8, 2013 letter from S. Sweeney to D. Houston, withenclosures

BOLLEA 001217-32 November 6, 2012 email from K. Davidson to K. Rosser/D.Houston, with draft settlement agreement and mutual release

BOLLEA 001233-53 November 21 and 26, 2012 emails to/from K. Davidson and D.Houston, with draft settlement agreement and mutual release

BOLLEA 001254-66 November 29 and 30, 2012 emails to/from K. Davidson and D.Houston, with draft settlement agreement and mutual release

BOLLEA 001267-79 December 4, 2012 email from K. Rosser/D. Houston to K.Davidson, with draft settlement agreement and mutual release

BOLLEA 001280-92 December 5, 2012 email from K. Rosser/D. Houston to K.Davidson, with draft settlement agreement and mutual release

BOLLEA 001293-1319 December 10, 2012 email from V. Duarte to K. Davidson and K.Rosser, with draft settlement agreement and mutual release

BOLLEA 001320-49December 10 and 11, 2012 emails to/from D. Houston/K. Rosser,K. Davidson, and V. Duarte, with partially executed settlement

agreement and mutual release

BOLLEA 001350-52 September 3, 2013 emails from S. Sweeney and J. Shearn to D.Houston, with letter attached

BOLLEA 001353-54 September 3, 2013 letter from D. Houston to S. Sweeney

BOLLEA 002654-67 Text messages between T. Bollea and B. Clem


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2

DOCUMENTS PRODUCED BY DAVID HOUSTON


DH 001-14 Various Emails to/from D. Houston, K. Rosser, J. Shearn, K.

Davidson, and V. Duarte from November and December 2012

DH 015 Check from D. Houston

DH 0018-21 Various Emails to/from D. Houston, K. Rosser, J. Shearn, K.Davidson, and V. Duarte from December 2012

DOCUMENTS PRODUCED BY DON BUCHWALD AGENCY 1


DBA 0053-54, 326-27 Emails to T. Burton from M. Calta dated March 13, 2012, forwardingemail from R. Peirce, with attachment

DEPOSITION TRANSCRIPTS

DEPOSITION PAGES

Deposition of Terry Bollea,April 8, 2013 Pages 760-70, 786-832

Deposition of Richard Peirce,January 27, 2015 Pages 95-114

Deposition of Tony Burton,March 2, 2015 2 Pages 26-29, 34, 43, 52-53, 57-61

Deposition of David D. Houston,April 10, 2015 Full Transcript

1 The Don Buchwald Agency designated these documents as “Confidential” and then plaintiff designated them as “Attorneys’ Eyes Only.” Counsel for the Gawker Defendants arenot challenging the Agency’s designation as “Confidential,” and ask only that plaintiff’s“Attorneys’ Eyes Only” designation be removed.

2 Tony Burton designated his deposition transcript as “Confidential” and then plaintiffdesignated it as “Attorneys’ Eyes Only.” Counsel for the Gawker Defendants are notchallenging Mr. Burton’s designation as “Confidential,” and ask only that plaintiff’s “Attorneys’Eyes Only” designation be removed.


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PLAINTIFF’S DISCOVERY RESPONSES

DISCOVERY RESPONSE DATE

Plaintiff’s Supplemental Response to A.J.Daulerio Interrogatory No. 9 May 9, 2014

Plaintiff’s Second SupplementalResponse to A.J. Daulerio Interrogatory

No. 9May 16, 2014

AUDIO FOOTAGE PRODUCED BY FEDERAL GOVERNMENT

FOOTAGE DESCRIPTION

Audio track “E-3 10-22-2012” Audio of an October 22, 2012 telephone call between D.Houston and K. Davidson.

Audio track “E-4 10-25-2012” Audio of an October 28, 2012 telephone call between D.Houston and K. Davidson

Audio track “E-5 11-02-2012” Audio of a November 2, 2012 telephone call between D.Houston and K. Davidson.

Audio track “Item D BubbaApology” Audio of the on-air apology read by B. Clem.

Audio track “WORKING_FinalTRACK 5” Audio of the December 14, 2012 sting operation

DOCUMENTS PRODUCED BY FEDERAL GOVERNMENT


May 27, 2015 EOUSAProduction

November 12, 2012 Gawker article “Here Is a List of People BubbaThe Love Sponge’s Ex-Wife Is Also Rumored To Have Had Sex With

On Camera”

May 27, 2015 EOUSAProduction

Redacted February 23, 2015 emails from unknown USAFLM senderto unknown USAFLM recipient

EOUSA 001-2 June 26, 2015 letter from S. Gerson to G. Thomas


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EOUSA 003-12 Plaintiff T. Bollea’s Privilege Log – Correspondence re FBI CriminalInvestigation

EOUSA 013-14 September 3, 2013 letter from D. Houston to S. Sweeney

EOUSA 015 Redacted September 3, 2013 email from unknown USAFLM sender toD. Houston

EOUSA 016-17 September 3, 2013 letter from A. Bentley to D. Houston

EOUSA 018 March 18, 2014 letter from A. Bentley to S. Berlin

EOUSA 019-21 November 8, 2013 letter from A. Bentley to D. Houston enclosingcheck

EOUSA 022-24 Redacted September 8 and 15, 2014 emails to/from D. Houston

GAWKER 1-2 FBI Form FD-1057, dated October 16, 2012

GAWKER 3-4 Form Noting Document(s) Withheld as Duplicative

GAWKER 5 Photocopy of Tampa Bay Times article “Hogan files two suits oversex tape”

GAWKER 6-7 FBI Form FD-302, dated October 16, 2012, interview with D.Houston and T. Bollea

GAWKER 8-11 October 10 to October 12, 2012 redacted emails with handwritten

notes

GAWKER 12-14 Handwritten notes, dated October 15, 2012, regarding D. Houston and T. Bollea interview

GAWKER 15-16 FBI Form FD-302, dated October 16, 2012, interview of T. Bollea

GAWKER 17 FBI Form FD-302, dated October 22, 2012, interview of D. Houston

GAWKER 18 FBI Form FD-1087a, dated October 23, 2012, telephone call involvingD. Houston

GAWKER 19-20 FBI Form FD-302 , dated October 24, 2012, interview with T. Bolleaand D. Houston

GAWKER 21-23 Handwritten notes, dated October 22, 2012, regarding D. Houston andT. Bollea interview

GAWKER 24-71 Text messages between B. Clem and T. Bollea


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GAWKER 72-85 Redacted emails involving D. Houston dated October 10-12, 2012

GAWKER 86 FBI Form FD-302, dated October 24, 2012, interview with D.Houston

GAWKER 87-92 Draft settlement agreement between B. Clem and T. Bollea

GAWKER 93 FBI Form FD-302, dated October 26, 2012, interview with D.Houston

GAWKER 94-117 Unredacted information regarding K. Davidson

GAWKER 118 FBI Form FD-1057, dated November 1, 2012 regarding B. Clemapology media file

GAWKER 119 FBI Form FD-1036, dated November 1, 2012 regarding search for K.Davidson information with California bar

GAWKER 120 FBI Form FD-1087, dated November 5, 2012 regarding October 25,2012 taped telephone call

GAWKER 121 FBI Form FD-1087, dated November 5, 2012 regarding November 2,2012 taped telephone call

GAWKER 122-23 Redacted in Full

GAWKER 124-25 November 5, 2012 Fax cover page from FBI to GoDaddy.com

GAWKER 126-40 Draft Settlement Agreement and Mutual Release

GAWKER 141 FBI Form FD-1036, dated November 5, 2012, regarding preservationletter on Godaddy for email account

GAWKER 142 FBI Form FD-302, dated November 6, 2012, regarding tapedtelephone call involving D. D. Houston

GAWKER 143 FBI Form FD-302, dated November 16, 2012, interview with D.Houston

GAWKER 144Redacted November 10, 2012 and November 13, 2012 emails to/fromD. Houston

GAWKER 145 Redacted November 6, 2012 emails to/from D. Houston and K.Davidson

GAWKER 146 Form Noting Document(s) Withheld as Duplicative


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GAWKER 147 FBI Form FD-302, dated November 14, 2012, communication with D.Houston

GAWKER 148-50 Redacted November 14 and 15, 2012 emails to/from D. Houston


GAWKER 166 FBI Form FD-302, dated November 23, 2012, regarding emailforwarded from D. Houston’s business manager

GAWKER 167 FBI Form FD-302, dated November 28, 2012, regardingcommunication with D. Houston



GAWKER 175-79 Exhibit B to Settlement Agreement


GAWKER 195 FBI Form FD-302, dated November 28, 2012, regarding emailsto/from D. Houston


GAWKER 208 FBI Form FD-302, dated December 3, 2012, regarding email to D.Houston

GAWKER 209 FBI Form FD-1087, dated December 4, 2012, regarding November27, 2012 taped telephone call


GAWKER 211 Redacted November 29, 2012 and December 3, 2012 emails to/fromD. Houston

GAWKER 212 FBI Form FD-302, dated December 4, 2012, regarding interview withD. Houston

GAWKER 213-15 Redacted DMV information

GAWKER 216-18 eAgent report


GAWKER 221-22 Form Noting Document(s) Withheld in Full


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GAWKER 223 Redacted Report

GAWKER 224-25 Redacted Law Enforcement Report, dated December 4, 2012

GAWKER 226 Redacted FBI Form FD-1036, dated December 4, 2012, regarding

California driver’s license and NCIC information

GAWKER 227 FBI Form FD-1087, dated December 6, 2012, regarding tapedtelephone call from December 5, 2012


GAWKER 240-49 Redacted November 29 – December 5, 2012 emails to/from D.Houston


GAWKER 262 FBI Form FD-302, dated December 7, 2012, interview with D.Houston

GAWKER 263-65 Redacted December 10, 2012 emails to/from D. Houston


GAWKER 280 FBI Form FD-302, dated December 13, 2012, regarding emailsforwarded from D. Houston’s assistant

GAWKER 281-82 Redacted December 10 – 11, 2012 emails to/from D. Houston


GAWKER 297 FBI Form FD-302, dated December 13, 2012, regarding telephone callfrom D. Houston

GAWKER 298-312 Redacted December 12, 2012 emails to/from D. Houston, withexecuted settlement agreement

GAWKER 313 FBI Form FD-1036, dated December 18, 2012, regarding polygraphreport

GAWKER 314 FBI Form FD-302, dated December 13, 2012, regarding telephone callwith D. Houston

GAWKER 315-16 FBI Form FD-1087, dated December 17, 2012, regarding disc withDecember 14, 2012 recorded meeting

GAWKER 317 Copy of D. Houston check dated December 14, 2012


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GAWKER 318-19 FBI Form FD-1087, dated December 17, 2012, regarding disc withDecember 14, 2012 recorded meeting

GAWKER 320-21 FBI Form FD-1087 dated December 17, 2012, regarding D. Houstoncheck

GAWKER 322 FBI Form FD-1036, dated December 18, 2012, regarding D. Houstoncheck

GAWKER 323-24 FBI Form FD-1087, dated December 17, 2012, regarding case withthree DVDs and settlement agreement

GAWKER 325-27 December 14, 2012 polygraph report

GAWKER 328-30 Assignment and Transfer of Copyright


GAWKER 344 FBI Form FD-1036, dated December 18, 2012, regarding signedagreements dated December 14, 2012

GAWKER 345 FBI Form FD-302, dated December 17, 2012, regarding telephone callwith D. Houston

GAWKER 346 Redacted FBI Form FD-302, dated December 17, 2012


GAWKER 348-49 Redacted Florida Driver and Vehicle Information Database

GAWKER 350 Form Noting Document(s) Withheld in Full







GAWKER 363 FBI Form FD-1036, dated December 18, 2012, regarding driver’slicense and NCIC information


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GAWKER 364-82 Search and seizure warrant, attachments and affidavits

GAWKER 383 FBI Form FD-1036, dated December 18, 2012, regarding searchwarrant and application

GAWKER 384 FBI Form FD-302, dated December 20, 2012, regarding searchwarrant and seized evidence

GAWKER 385 FBI Form FD-302, dated December 18, 2012, regarding T. Bolleainterview

GAWKER 386 Handwritten notes dated December 17, 2012

GAWKER 387 FBI Form FD-302, dated December 18, 2012, regarding telephone callwith unknown female

GAWKER 388FBI Form FD-302, dated December 21, 2012, regarding telephone callwith unknown female

GAWKER 389-90 Completed search and seizure warrant

GAWKER 391 FBI Form FD-1036, dated December 21, 2012, regarding completedsearch warrant

GAWKER 392 Undated handwritten notes

GAWKER 393 Redacted FBI Form FD-302, dated December 17, 2012, regardinginterview

GAWKER 394-400 Redacted handwritten notes, dated December 14, 2012, of interview

GAWKER 401 FBI Form FD-302, dated January 9, 2013, regarding telephone callwith D. Houston

GAWKER 402-03 Consent to search and advice of rights, dated December 14, 2012

GAWKER 404-08 Redacted handwritten notes

GAWKER 409-14 FBI Form FD-302, dated December 17, 2012, regarding interview

GAWKER 415 FBI Form FD-302, dated January 3, 2013, regarding signed letter andside agreement received from D. Houston

GAWKER 416-19 Redacted handwritten notes dated January 8, 2013


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GAWKER 420-21FBI Form FD-1057, dated January 3, 2013, enclosing handwrittennotes from sex tape, TMZ check, letter showing absence from work,and FBI Form FD-597

GAWKER 422-23 FBI Form FD-1057, dated January 10, 2013, documenting meeting

GAWKER 424-26 FBI Form FD-302, dated January 10, 2013, regarding interview

GAWKER 427 Handwritten interview notes, dated February 4, 2013

GAWKER 428-29 FBI Form FD-302, dated February 6, 2013, regarding interview withT. Bollea


GAWKER 446 FBI Form FD-1036, dated March 5, 2013, regarding memo written byAUSA regarding the investigation

GAWKER 447 FBI Form FD-302, dated February 28, 2013, regarding FBI agentsreviewing discs

GAWKER 448 FBI Form FD-1057, dated March 19, 2013, regarding tolls uploading

GAWKER 449 FBI Form FD-1057, dated May 7, 2013, regarding tolls uploading



GAWKER 452 FBI Form FD-1057, dated May 14, 2013, regarding telephone callwith T. Bollea and D. Houston

GAWKER 453-55 FBI Form FD-1057 and notes regarding May 15, 2013 FBI Office ofSpecial Technology

GAWKER 456-57 FBI Form FD-1057, dated July 23, 2013, regarding case update forcase declination

GAWKER 458-61 D. Houston expenses and FBI Form FD-794, dated July 23, 2013, forD. Houston expenses paid for by FBI

GAWKER 462-63FBI Form FD-1057, dated August 1, 2013, regarding updating casefor Federal Grand Jury document return, case placed in pendinginactive status

GAWKER 464-65 FBI Form FD-1057, dated August 6, 2013, regarding payment to D.Houston for expenses


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GAWKER 466-67 August 13, 2013, expense payment forms signed by D. Houston

GAWKER 468 FBI Form FD-302, dated August 14, 2013, regarding payment to D.Houston

GAWKER 469 FBI Form FD-302, dated November 4, 2013 regarding, unsealing andcopying of D. Houston check

GAWKER 470 Email dated March 5, 2014 from D. Houston to FBI regardingGawker’s FOIA request

GAWKER 471 FBI Form FD-1036, dated March 6, 2014, regarding March 5, 2014email from D. Houston

GAWKER 472-73 FBI Form FD-999, dated January 16, 2015, regarding discussion withunknown Tampa Police Department Detective

GAWKER 474-76 FBI Form FD-999, dated January 21, 2015, regarding dissemination ofdocuments to Tampa Police Department

GAWKER 477 February 9, 2015 email from AUSA to FBI regarding release ofmaterials to local authorities

GAWKER 478 FBI Form FD-1036, dated February 11, 2015, regarding email withAUSA

GAWKER 479 FBI Form FD-302, dated February 12, 2015, regarding evidence provided to Tampa Police Department

GAWKER 480-82 FBI Form FD-999, dated February 13, 2015, regarding information provided to Tampa Police Department

GAWKER 483 FBI Form FD-1057, dated February 24, 2015, regarding addingenvelope received from Tampa Police Department

GAWKER 484 FBI Form FD-340a, Evidence Log

GAWKER 485 Redacted FBI Form FD-340, dated October 15, 2012, regardingreceipt of evidence


GAWKER 490 Redacted FBI Form FD-340, dated October 15, 2012 regarding receiptof evidence



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GAWKER 494 Redacted FBI Form FD-340, dated October 22, 2012, regardingreceipt of evidence


GAWKER 509 Blank sheet with case file header




GAWKER 562 Redacted FBI Form FD-340, regarding receipt of evidence


GAWKER 564 Redacted FBI Form FD-340, regarding receipt of evidence



GAWKER 567 Redacted FBI Form FD-340 regarding receipt of evidence




GAWKER 571 Redacted Advice of Rights form dated December 14, 2012


GAWKER 573 Redacted Consent to Search form dated December 14, 2012

GAWKER 574 Unsigned, incomplete Certification of Search



GAWKER 583 Redacted December 17, 2012 letter from D. Houston to FBI




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GAWKER 588 Envelope from D. Houston to FBI




GAWKER 593 Redacted FBI Form FD-597, dated December 20, 2012, regardingreceipt for property received.


GAWKER 595 Blank page dated December 20, 2012



GAWKER 599 Blank page dated December 20, 2012


GAWKER 601 Blank page dated December 20, 2012 with case file number

GAWKER 602 Page “original - envelop (sic) that REDACTED handed me with note

from attny for work” with case file number


GAWKER 604 Blank page dated December 20, 2012 with case file number

GAWKER 605 Redacted FBI Form FD-340a evidence sheet

GAWKER 606 Redacted FBI Form FD-340a regarding receipt of evidence

GAWKER 607Redacted December 17, 2012 cover for draft transcript of recording ofDecember 14, 2012 meeting between D. Houston, T. Bollea, andothers

GAWKER 608-721 Redacted transcript of December 14, 2012 meeting with D. Houston,T. Bollea, and others



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GAWKER 723 Redacted December 13, 2012 letter scheduling deposition

GAWKER 724 Redacted October 22, 2012 cover for draft transcript of recording ofOctober 22, 2012

GAWKER 725-44 Redacted transcript of October 22, 2012 D. Houston telephone call


GAWKER 746 Redacted December 6, 2012 cover for draft transcript of recording ofOctober 28, 2012

GAWKER 747-50 Redacted transcript of October 28, 2012 D. Houston telephone call


GAWKER 752Redacted November 2, 2012 cover for draft transcript of recording of

November 2, 2012

GAWKER 753-73 Redacted transcript of November 2, 2012 D. Houston telephone call

GAWKER 774 Redacted December 7, 2012 cover for draft transcript of recording ofDecember 5, 2012

GAWKER 775-87 Redacted transcript of December 5, 2012 D. Houston telephone call






GAWKER 800 Redacted FBI Form FD-340A regarding receipt of evidence



GAWKER 803 - 917

Redacted December 17, 2012 cover for draft transcript of meeting ofDecember 14, 2012, signed by T. Bollea on February 4, 2013, andredacted transcript of December 14, 2012 meeting with D. Houston, T.Bollea, and others, with T. Bollea notes


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GAWKER 919 Redacted FBI Form FD-340 regarding destroyed FBI Form FD-192A’s

GAWKER 920 Redacted FBI Form FD-192A, dated February 19, 2013, regardingdestroyed grand jury material

GAWKER 921 Redacted FBI Form FD-192A, dated January 31, 2013, regardingdestroyed grand jury material

GAWKER 922 Redacted FBI Form FD-192, dated January 17, 2013, regardingdestroyed grand jury material






GAWKER 928 Redacted FBI Form FD-340A, evidence log

GAWKER 929 Redacted FBI Form FD-340A regarding receipt of evidence

GAWKER 930-32 Redacted handwritten notes dated November 14, 2012


GAWKER 934-39 Redacted handwritten notes dated November 9, 2012


GAWKER 941 Redacted FBI Form FD-340A, evidence log


GAWKER 943-44 Redacted FBI Form FD-472, dated December 13, 2012, for recordingdevice on D. Houston

GAWKER 945-46 Redacted FBI Form FD-472, dated December 13, 2012, authorizingCCTV recording of Sand Pearl meeting signed by T. Bollea


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GAWKER 947-48 Redacted FBI Form FD-472, dated December 13, 2012, authorizingCCTV recording of Sand Pearl meeting signed by D. Houston

GAWKER 949-50 Redacted FBI Form FD-472, dated December 13, 2012, authorizingCCTV recording of Sand Pearl meeting


GAWKER 975 Redacted FBI Form FD-340A evidence log







GAWKER 983-84 Subpoena to testify before grand jury




GAWKER 988 Redacted envelope addressed to FBI

GAWKER 989 Redacted subpoena to testify before grand jury




GAWKER 995 Redacted Envelope addressed to FBI





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GAWKER 1006 Redacted FedEx label to FBI address



GAWKER 1009 Redacted subpoena to testify before grand jury




GAWKER 1018 Redacted envelope addressed to FBI




GAWKER 1022 Form Noting Document(s) Withheld in FullGAWKER 1023 Redacted FBI Form FD-340 regarding receipt of evidence










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GAWKER 1038 FBI Form FD-340A, evidence log


GAWKER 1040 Redacted, undated handwritten notes of interview with C. Harder

GAWKER 1041 Redacted November 13, 2012 email

GAWKER 1042 Redacted November 13, 2012 email


GAWKER 1044 Redacted page 2 of signed settlement agreement


GAWKER 1079-80 Redacted December 11, 2012 emails to/from D. Houston

GAWKER 1081 Redacted November 10, 2012 email to D. Houston, and November 13,2012 forward of email


GAWKER 1097 Redacted Second page of email with no information

GAWKER 1098 Redacted November 6, 2012 emails to/from D. Houston

GAWKER 1099 Redacted November 6, 2012 email from D. Houston

GAWKER 1100 Redacted October 30, 2012 emails to/from D. Houston

GAWKER 1101 Redacted November 2, 2012 email to/from D. Houston


GAWKER 1108 Redacted second page of email with no information

GAWKER 1109 Redacted October 25, 2012 email to/from D. Houston


GAWKER 1111 Redacted October 19, 2012 email from D. Houston


GAWKER 1119 Redacted October 19, 2012 email from D. Houston

GAWKER 1120 Blank “Sentinel Workin

Documents

Attachment to Miscellaneous_ Document - Pages 587 to 841