UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------)( ROWE ENTERTAINMENT, et al.,

Plaintiffs, 98 Civ. 8272

-against-ORDER FINDING LEONARD

THE WILLIAM MORRIS AGENCY INC., et aI., ROWE IN CONTEMPT OF COURT

Defendants. ---------------------------------------------------------------J( ROBERT P. PATTERSON, JR., U.S.D.J.

This Order is being issued pursuant to the Court's inherent powers, the All Writs Act (28

U.S.C. 1651), and Local Civil Rule 83.6.

Having considered the motions and documents filed in support of the motions by William

Morris Endeavor Entertainment, LLC ("WME") and by Dentons US LLP ("Dentons"),

individually and on behalf of current and former Dentons attorneys, to hold Leonard Rowe

("Rowe") in contempt of Court, (Letter from Edward J. Reich re Mot. for Contempt, Feb. 11,

2014, ECF No. 915; Letter from Tal E. Dickstein re Mot. for Contempt, Feb. 11,2014, ECF No.

916; Decl. of Michael P. Zweig in Supp. of Dickstein Letter, Feb. 11,2014, ECF No. 917; Decl.

of Tal E. Dickstein in Supp. of Dickstein Letter, Feb. 11,2014, ECF No. 918); and Rowe's

response and opposition to the motions, (Letter to Judge Patterson from Leonard Rowe, Feb. 5,

2014, ECF No. 910; Letter to Judge Patterson from Leonard Rowe, Feb. 13,2014, ECF No.

925); and

The Court convened a hearing on the motions on February 14,2014 at 2 p.m., at which

time Rowe was to have an opportunity to be heard by telephone in opposition to the motions, but

Rowe did not call the Courtroom or the Judge's chambers, and due to jury selection in a different 1

case, was not called until 3:20 p.m. At that time, Rowe did not respond to multiple calls to his

home phone and his cell phone j although messages were left; and

IT APPEARING TO THE COURT that Rowe, a party to the above-captioned action, in

which Rowe's claims brought in 1998 against WME and two other booking agents were

dismissed on summary judgment, Rowe Entm't, Inc. v. William Morris Agencv, Inc., No. 98

Civ. 8272, 2005 U.S. Dist. LEXIS 75 (S.D.N.Y. Jan. 5,2005), was no longer interested in being

heard; and

IT APPEARING TO THE COURT that judgment was entered against Rowe and the

other Plaintiffs on February 7, 2005 (J. of Dismissal, ECF No. 676) and that the United States

Court of Appeals for the Second Circuit affirmed this Court's dismissal of Rowe's claims against

WME and the other booking agents, Rowe Entm't, Inc. v. William Morris Agencv, Inc., 167 F.

App'x 227 (2d Cir. 2005), and that the United States Supreme Court denied Rowe's petition for

certiorari, 549 U.S. 887 (2006); and

IT APPEARING TO THE COURT that on March 2,2012, Rowe filed a Rule 60(b)

motion for relief from the Court's February 7, 2005 judgment, on the grounds that his former

attorneys at Sonnenschein Nath & Rosenthal LLP (now Dentons) conspired with attorneys for

William Morris Agency, Creative Artists Agency, Inc., and Renaissance Entertainment, Inc., to

conceal and destroy vital evidence, thereby committing a fraud on the Court; Rowe also filed the

Rule 60(b) motion on the grounds that Exhibit 31 was newly discovered evidence, but, in fact, it

had been presented by Rowe's attorneys replacing his Sonnenschein attorneys in support of its

opposition to the summary judgment motion. Exhibit 31 appears to be a printout drawn from the

Plaintiffs' e-discovery from searches of emails to or from all the employees of the defendant

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booking agents. In response to Exhibit 31 offered by Plaintiffs, the Defendants demanded that

the underlying emails be produced, but received no response. The Rule 60(b) motion was denied

in a 42-page opinion by this Court, Rowe Entm't v. William Morris Agency, Inc., No. 98 Civ.

8272,2012 U.S. Disi. LEXIS 161313 (S.D.K.Y. Nov. 8,2012), in which the Court denied

Rowe's charges of conspiracy among the booking agents and their attorneys and Plaintiffs

former attorneys, holding that Rowe's charges were "denied as based on nothing more than hot

air and paranoid suspicions, the truth or falsity of which he has had the power and the

opportunity to investigate for the past seven years," id. at *13; and

IT APPEARING TO THE COURT that in November 2013 Rowe, inter alia, threatened

to file more than a billion dollars in commercial liens against WME and its attorneys, and against

Dentons and Dentons current and former attorneys, notwithstanding the Court's entry of a

judgment against him on February 7, 2005 and the Court's decision of November 8, 2012,

described above; and

IT APPEARING TO THE COURT that an application was filed by declaration of

Michael P. Zweig dated November 20,2013 (DecL of Michael P. Zweig, Nov. 20,2013, ECF

No. 867), attaching as exhibits demand letters from Rowe dated November 13,2013 to Michael

Zweig, Helen Gavaris, Michael Beck, among others, which stated that Rowe would be filing

commercial liens of $500,000,000.00 against Loeb & Loeb and WME, and liens of

$100,000,000.00 each against Michael Zweig and Helen Gavaris, and that Rowe would place

public advertisements stating that their creditworthiness is suspect, and demanding a substantial

sum in recompense/settlement of the damages; and

3

IT APPEARING TO THE COURT that an application was filed by declaration of

Edward J. Reich dated November 27,2013 (Decl. of Edward J. Reich, Nov. 27,2013, ECF No.

872), attaching as exhibits demand letters from Rowe dated November 13,2013 to Elliott

Portnoy, Joseph Andrew, Martin Gold, Raymond Heslin, Christine Lepera, and Richard Primoff,

among others, which stated that Rowe would be filing commercial liens of $500,000,000.00

against Dentons LLP and WME, and liens of $1 00,000,000.00 each against Elliott Portnoy,

Joseph Andrew, Martin Gold, Raymond Heslin, Christine Lepera, and Richard Primoff, and that

Rowe would place public advertisements stating that their creditworthiness is suspect, and

demanding a substantial sum in recompense/settlement of the damages; and

IT APPEARING TO THE COURT that a show cause hearing was held on December 6,

2013, upon the application ofWME through the declaration of Michael P. Zweig dated

November 20,2013, referenced above, and upon the application of Dentons through the

declaration of Edward J. Reich dated November 27,2013, referenced above, and Rowe was duly

served and on notice of the date and time of the hearing, and would have an opportunity to be

heard by telephone or otherwise, and that Rowe filed an opposition to the applications, (Pl.'s

Mot. to Vacate Temp. Restraining Order, ECF. No. 878), but failed to present any evidence to

show that he was owed any money by any of the applicants seeking an Order of Permanent

Injunction before the Court; and

IT APPEARING TO THE COURT that after a hearing held on December 6, 2013, at

which Rowe did not appear, this Court entered an Order for a Permanent Injunction (Order, Dec.

6, 20l3, ECF No. 883) that, among other things, prohibits Rowe from:

4

(I) filing in any state or federal court, or in the public records of any state, county, or municipality, any lien, financing statement, UCC-I statement, security agreement, finance agreement, affidavit, instrument or other document purporting to attach, encumber, or otherwise affect the property or assets ofWME and the William Morris Agency, Inc. (together, "WME"); any WME partner, agent or employee; Loeb; Dentons; and/or any current or former Loeb attorney or any current or former Dentons attorney, including but not limited to Michael P. Zweig, Helen Gavaris, Michael Beck, Christian D. Carbone, Tal Dickstein, Michael Barnett, Martin R. Gold, Raymond J. Heslin, Christine Lepera, Richard Primoff, Elliott Portnoy, Edward 1. Reich and Joseph Andrew (collectively, "the Attorneys"); ...

(4) taking any action that is intended or likely to interfere with, harm, injure or damage the property or assets, whether real or personal, of WME; any WME partner, agent or employee; Loeb; Dentons; and/or any of the Attorneys;

(5) communicating with or attempting to contact WME; any WME partner, agent or employee; Loeb; Dentons; and/or any of the Attorneys, relating in any way to this action; ...

IT APPEARTI\lG TO THE COURT that Rowe continued to communicate with, and

threaten to file liens against, Dentons, Dentons current and former attorneys, and Loeb attorneys;

IT APPEARWG TO THE COURT that on January 24, 2014, upon the applications of

WME, Dentons, and the Dentons attorneys, and following a hearing at which Rowe was

extensively heard, this Court found Rowe to be in contempt of page four, paragraph five of the

Court's December 6, 2013 Order for a Permanent Injunction, but found that there was

insufficient evidence presented to show that Rowe had violated paragraphs one and four, above;

IT APPEARWG TO THE COURT that Rowe has violated the December 6,2013 Order

of Permanent Injunction by taking the following actions, copies of which were submitted to the

Court by Dentons and Loeb & Loeb and duly served on Rowe in advance of the February 14,

2014 hearing:

5

1. On February 4, 2014, filed with the Clerk of the Superior Court of DeKalb County,

Georgia a "UCC Financing Statement," naming Dentons a "Lien Debtor" for a debt

claimed by Rowe;

2. On February 5, 20l4, filed with the Clerk of the Superior Court of DeKalb County,

Georgia a "UCC Financing Statement," naming Loeb attorney Michael P. Zweig a

"Lien Debtor" for a debt claimed by Rowe;

3. On February 5, 2014, filed with the Clerk of the Superior Court of DeKalb County,

Georgia a "UCC Financing Statement," naming Loeb attorney Helen Gavaris a "Lien

Debtor" for a debt claimed by Rowe;

4. On February 5, 2014, tiled with the Clerk of the Superior Court of DeKalb County,

Georgia a "UCC Financing Statement," naming Dentons attorney Martin R. Gold a

"Lien Debtor" for a debt claimed by Rowe;

5. On February 7, 2014, filed with the Clerk of the Superior Court of DeKalb County,

Georgia a "UCC Financing Statement," naming Dentons attorney Christine Lepera a

"Lien Debtor" for a debt claimed by Rowe;

6. Sent various email communications to Dentons attorneys and Loeb attorneys

attaching copies of the items listed in paragraphs 1 through 5 above, and some of

these email communications stated that similar UCC Financing Statements, together

with their affidavits and exhibits, are being filed in various other jurisdictions across

the United States;

IT APPEARING TO THE COURT that its December 6,2013 Order for a Permanent

Injunction is clear and unambiguous;

6

IT APPEARING TO THE COURT that Rowe's noncompliance with the December 6,

2013 Order for a Permanent Injunction is clear and convincing, that he has not diligently

attempted to comply with the Order in any manner, and has, in fact, demonstrated an intent to

continue to violate it and thereby threaten financial harm to the targets of his conduct, including

individuals and entities specifically identified in the Permanent Injunction Order;

IT APPEARING TO THE COURT that Rowe's actions improperly attempt to undermine

the finality of this Court's February 7, 2005 judgment against him and of this Court's decision of

November 8, 2012;

IT APPEARING TO THE COURT that pursuant to its inherent authority, the All Writs

Act (28 U.S.C. 1651) and Local Civil Rule 83.6, the Court may issue an order holding Rowe in

civil contempt of the Court's December 6,2013 Order for a Permanent Injunction; and

UPON THE MOTIONS of WME and Dentons, individually and on behalf of current and

former Dentons attorneys and on behalf of Loeb & Loeb and its attorneys;

IT IS HEREBY ORDERED AND ADJUDGED that Rowe has been found to be in

contempt of page three, paragraph one, page four, paragraph four, and page four, paragraph five

of the Court's December 6, 2013 Order for a Permanent Injunction; and

IT APPEARING TO THE COURT that Rowe has filed or threatened to file commercial

liens or claims of debts and UCC Financing Statements and documents pertaining thereto, on the

grounds he sets forth in his application and affidavits, against the parties described above, and

could cause to those parties irreparable harm; and

IT IS HEREBY ORDERED AND ADJUDGED that said commercial liens, claims of

debt, and UCC Financing Statements are deemed null and void and ordered expunged as

7

expeditiously as possible from the records of any county clerks' otlices or the records of any

clerks of courts in which they have been filed or are hereafter filed; and

IT IS HEREBY ORDERED that Rowe demonstrate to this Court, through the filing with

this Court of the Atlidavit of Leonard Rowe in the form attached hereto by Februarv 21, 2014,

that he has withdrawn any and all UCC Financing Statements, along with accompanying

affidavits and exhibits, filed against Dentons, current and former Dentons attorneys, WME, Loeb

& Loeb, and Loeb attorneys; and

IT IS FURTHER HEREBY ORDERED that Rowe shall pay damages to which the

complainants are entitled, including the costs of attorneys fees, in an amount to be determined by

the Court pursuant to Local Rule 83 .6( c); and

IT IS HEREBY ORDERED that the motion made by Dentons and by WME, through the

attorneys at Loeb & Loeb, requesting the Courter order the United States Marshal to arrest Rowe

and to hold Rowe in civil confinement at an institution within its jurisdiction be held in abeyance

until such time as the Court may hear argument on the motion at a hearing on March 7, 2014 at

10:00 a.m.; and

IT IS HEREBY ORDERED that the motion made by the Dentons and Loeb & Loeb

attorneys requesting that the Court refer this matter to the United States Attorneys Office for the

Southern District of New York and the Northern District of Georgia is denied since the Dentons

and Loeb & Loeb attorneys can make such submissions by themsel ves if they wish to do so and

they have not shown any need for the Court's imprimatur.

SO ORDERED.

8

Dated: New York, New York February 18,2014

Robert P. Patterson, Jr., U.S.DJ.

Copies of this Order Sent Via Email to:

Leonard Rowe 5805 State Bridge Road Suite 119 Johns Creek, GA 30097 RoweEntertain@aol.com

Attorneys for Dentons LLP: Edward J. Reich Dentons LLP 1221 Avenue of the Americas New York, NY 10020 (212) 768-6700 Edward.reich@dentons.com

Attorneysfor W;UE and Loeb & Loeb LLP: Tal Efriam Dickstein Loeb & Loeb LLP 345 Park Avenue New York, NY 10154 (212) 407-4963 tdickstein@loeb.com

9

1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------X ROWE ENTERTAINMENT, et al.,

Plaintiffs,

-against-

THE WILLIAM MORRIS AGENCY INC., et al.,

Defendants.

: : : : : : : : : : :

Case No. 98-8272-RPP AFFIDAVIT OF LEONARD ROWE

---------------------------------------------------------------X

STATE OF GEORGIA ) ) ss: COUNTY OF GWINNETT )

LEONARD ROWE, being duly sworn, deposes and says:

1. On or about the dates set forth below, I filed, or caused to be filed, with the

following federal, state, local or municipal authority or agency (Jurisdiction), a UCC

Financing Statement or other document or instrument purporting to evidence, advertise or

publicize a debt or lien (Lien Notice), against the following entities and/or individuals

(Alleged Debtor):

Alleged Debtor Jurisdiction Date of Filing Lien Notice

1.

2.

3.

4.

5.

2

Alleged Debtor Jurisdiction Date of Filing Lien Notice

6.

7.

8.

9.

10.

[ATTACH ADDITIONAL PAGES IF NECESSARY]

2. The information set forth in paragraph 1 above includes (i) any and all of William

Morris Endeavor Entertainment, LLC, William Morris Agency, Inc. (together WME), Loeb &

Loeb LLP (Loeb), Dentons LLP (Dentons), and any current or former affiliate, attorney,

agent or employee of WME, Loeb or Dentons, against whom I have filed, or caused to be filed,

any Lien Notice, (ii) each and every date of filing of any such Lien Notice, and (iii) each and

every Jurisdiction in which any such Lien Notice has been filed.

3. With respect to each and every Lien Notice set forth in paragraph 1 above, I have

filed, or caused to be filed, a UCC-3 Termination Statement, in the form of Exhibit A hereto

(UCC Termination), with the Jurisdiction in which the Lien Notice was filed, stating that the

Lien Notice is terminated, and further stating that:

The lien or financing statement to which this document relates, does not, and never has, evidenced a valid debt or security interest. The lien or financing statement to which this document relates is, and always has been, null and void and without any effect whatsoever.

4. Attached as Exhibit B hereto are true and correct file-stamped copies of each of

the UCC Terminations that I have filed or caused to be filed.

3

5. I represent and warrant to each and every one of the Alleged Debtors set forth in

paragraph 1 above, that the Lien Notice that I have filed, or caused to be filed, against them, has

been withdrawn and terminated, and is of no further force or effect.

______________________________ Leonard Rowe

Sworn before me this ___ day of February, 2014

__________________________ Notary Public

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