<table><tr><th>From:</th><th>Lawrence Krauss</th></tr><tr><td>Sent:</td><td>Wednesday, February 28, 2018 1:39 AM</td></tr><tr><td>To:</td><td>jeffrey E.</td></tr><tr><td>Subject:</td><td>Re: Private and Confidential, in response to our meeting.</td></tr></table>

So far probably slightly positive. Plus the= view the publicity benefit as very important.

=b class="""">Lawrence M. Krauss
Director, The Origins Project at ASU
Found=ion Professor
School of Earth & Space Exploration and Physics Department=/div> Arizona State University, P. O. Box 871404 <x-apple-data-detectors://1/1> Tempe, AZ 85287-1404 <x-apple-data-detectors://1/1> Research Office  Assistant
(Jessica)  <tel:  =span class=""" style="orphans: 2; widows: 2; background-color: rgba(255,=255, 255, 0);">Origins Office (Cynthia):  <tel: 
 =/div>
=rigins.asu.edu <http://origins.asu.edu/> | twitter.com/lkrauss1 <http://twitter.com/lkrauss1> | krauss.faculty.asu.edu <http://krauss.=aculty.asu.edu/>

=div>

## Sent from my iPhone

On Feb 27, 2018,=at 3:47 PM, jeffrey E. <mailtoa wrote:

is origins a net positve money wise for the university or a n=gative. ONIY money

## On Tue, Feb 27, 2018 at 6:43 PM, Lawrence Krauss

yes.. you are correct.. &=bsp;but even without the attorney I wanted to try and assert my rights.. I g=t shot down.. I expected to get shot down,

but nothing has change= in that regard. I have now dealt with this office twice, and they ar= aware of the ongoing thing with Buzzfeed, and

as I told you befo=e, the University attorney actually warned me this was likely to happen. &n=sp;

So, I think all is as it was with that office a=d they are going to do what they would have done anyway, which is to interv=ew my staff.. they

asked me on Friday before they got my no=e to send them the name of those who worked for Origins from 2015 -2016 and=l gave them the contact info for my business office manager at origins, and=they thanked me..

On Feb 27, 2018, at 4:38 PM, jeffrey E. <jeevacation@gmail.com> w=ote:

## On Tue, Feb 27, 2018 at 6:43 PM, Lawrence Krauss (cont.)

<=div>

=span style="font-size:11pt;font-family:Calibri,sans-seritcolor:rgb(31,73=125)">=/span> heres what this s=ys. i lawrence krauss will tell you how i thinkyou should=conduct your investigation , if at all. and I would like t= participate in it. repsonse. go fuck yourself.&nbs=; we will not share the file , all complaints are proteced from=defamation and you must continue to cooperate.

I wanted to add to his letter, to reiterate our concern about how your office was planning to follow up on the false and defamatory third-party allegations from Buzzfeed. Because this was initiated by an onl=ne entertainment news outlet with a clear agenda and established record of propagating false allegations about me, rather than by any of the individuals they refer to as sources, this should not b= considered a credible allegation worthy of investigation. I belie=e that our initial discussion was sufficient to settle this matter. Whether o= not you agree with this, there are two thin=s I think are important to establish. =/div>

First=y, that the University should not propagate what can be false allegations from such a source by presenting them directly to current and/or former employees or to others. To do so would be to further their libelous =agenda, as Mr Waldman has emphasized. In this regard,=I would appreciate seeing copies of the correspondence you might send to curr=nt or former employees about this in the process of carrying out and concluding your investigation.

your client, La=rence Krauss, copied me on his February 23rd email communication to the Office of Equity and Inclusion. I am writing to =convey the University's position on its responsibility to conduct =administrative investigations into allegations of conduct that would violate institutional policy, if true. Because Dr. Krauss has retained legal counsel, I am writing directly to you. You may forward my=20 communication on to your client. Without having first secured your permission, I did not think it was proper for me to copying him o= this reply. first secured your permission, I did not think it was proper for me to copying him o= this reply.

Our policy on th= Prohibition Against Discrimination, Harassment, and Retaliation (ACD 401 on th= Our policy Prohibition Against Discrimination, Harassment, and Retaliation (ACD 401 ht=ps://www.asu.edu/aad/manuals/acd/acd401.html <https://urldefense.proofpoint.com/v2/url?u==ttps-3A_www.asu.edu_aad_manuals_acd_acd401.html&d=DwMFaQ&c=l45=xH-kUV29SRQusp9vYR0n1GycN4_2jInuKy6zbqQ&r=IXvAt9Yyr2FDWivZF1A3iILTVn7=aKfvAPiXMR3ircA&m=znMdUaPvtHbuvy p0p1YIFvVS5vuv1LTTTDP94Oi4bm0&s==Gloe_z-tNcRUFiYCSoJmaBJXtQK1_SFbRg2AhDIdKs&e=> ) and its accompanying procedures (P20 — link to the procedures is =embedded in the policy document) directs the Office of Equity and Inclusion to conduct prompt and equitable investigations. Among the =points stated are that the Office accepts anonymous complai=ts as well as direct complaints. University employees are required to cooperate =with any investigation or allegations of violations of this policy. =Providing false or misleading information or failing to cooperate may result in disciplinary action. Individuals making a complaint or participating as a witness in an investigation cannot be retaliated against. Any employee who engages in retaliation will be disciplined.&=bsp; The Office of Equity and Inclusion does not make any findings until such time as it determines that it has completed its fact gathering.

=/div>

Our courts recognize that participants in an administrative investigation have a privilege ag=inst a defamation charge. In Paros v. Hoema=o Hospital, 140 Ariz. 335, 681 P.2d 918 (Ct. App. Div. 2 1984), the court recognized that the employer's response to a notice of charge of discrimination=20 filed with the Equal Employment Opportunity Commission was absolutely privileged. In Miller v. Servicemaster by Ree=, 174 Ariz. at 520, 851 P.2d 240, 243 (Ct. App. Div. 1 1993), the court recognized the existence of a conditional privilege for employees to report perceived acts of sexual harassment as public policy dictated that employees must be protected from workplace sexual harassment. Cited approvingly, Carey v. Maricopa County,

The Office of Equity and Inclusion will proceed with its investigation as outlined in ACD 401 and P20. The Office will not provide yo=r client with its investigative file. We look forward to Dr. Krauss =99s continuing cooperation. Regards,

=span style="font-size:11pt;font-family:Calibri,sans-serif;color:rgb(31,73=125)">

## On Tue, Feb 27, 2018 at 6:43 PM, Lawrence Krauss (cont.)

Dear=Naimah et al:

Attached you will find a letter from my attorney, along with a letter he sent to Buzzfeed earlier in this week regarding the defamatory and false story they were planning on printing. The story was then published yesterday=20 morning. I wanted to add to his letter, to reiterate our concern about how your office was planning to follow up on the false and defamatory third-party allegations from Buzzfeed. Because this was initiated by an onl=ne entertainment news outlet with a clear agenda and established record of propagating false allegations about me, rather than by any of the individuals they refer to as sources, this should not be considered a =credible allegation worthy of investigation. I believe that our initial discussion was sufficient to settle this matter. Whether or not y=u agree with this, there are two things I think a=e important to establish.

Firstly,&nbs=;that the University should not propagate what can be false allegations from such a source by presenting them directly to current and/or former employees or to others. To do so would be to further their libelous =agenda, as Mr Waldman has emphasized. In this regard, I would appreciate seeing copies of the correspondence you might send to current or former employees about this in the process of carrying out and concluding your investigation.

Secondly, I reiterate once again that the Origins Project environment is supportive, candid, frank, honest, and productive, with all employees being treated with respect, as well as being supported and mentored. I am proud of ourteam, and I believe they feel the same way. au>

Thanks for your attention=to these letters.
Thank y=u.

| Field | Extracted content |
|---|---|
| From | [REDACTED] (shown with "mailto" fragment) |
| Sent | [REDACTED] |
| To | Multiple recipients (several addresses heavily redacted; "mailto" fragments visible) |
| CC | [REDACTED] |
| Subject | Fwd: Private and Confidential, in response to our meeting. |
| Greeting / opening line | "Dear [REDACTED] et al:" |
| Visible artifacts / encoding | "<mailto" tags; HTML fragment "</div>"; encoded artifacts like "=u", "=nbsp", "=br" |
| Redaction note | Large black boxes obscure most names and email addresses.

Adam forwarded me your note while on a plane. I wanted to let y=u know that you can feel free to cc me on all communication or email me and-cc Adam, as you wish. . Adam is advising me on matters related to Buz=feed, and so it is appropriate to communicate to both of us in this regard.=nbsp; I expect he will be writing to you. In any case, I wanted to as=ure you that I will continue to cooperate with all your offices, as I have d=ne thus far. I value the collegial relationship I have with all of my colle=gues at ASU. I do hope Naimah's group has taken all of our c=ncerns about Buzzfeed under advisement, but I also understand the requireme=ts on the University as well.

Thanks for your attention to this.

Best
=
Lawrence Krauss</=>

<=iv>

Lawrence M. Krauss Director, The Or=gins Project at ASU Co-Director, Cosmology Initiative Foundation Pr=fessor School of Earth & Space Exploration and Physics Department Ariz=na State University, P.O. Box 871404, Tempe, AZ 85287-1404

## On Tue, Feb 27, 2018 at 6:43 PM, Lawrence Krauss (cont.)

Res=arch Office:

ktel

| Assistant (Jessica):

<tel

O=igins Office (Cynthia)

<tel:

mailto:

| <https://urldefense.proofpoint.com/v2/url?u=http-

3A__ori=ins.asu.edu_&d=DQMFAG&c=AGbYxfJbXK67KfXyGqyv2Ejiz41FqQuZFk4A-1I=fAU&r=DB9LvLOlQiaqWcFOihHC0LZCntZCR8Xtq5BHKNVR5To&m=ciP97mEbO43=9G8_Nf9I5Up33Th7MWHYf6uw7yUBPZc&s=Gc-m4FUpqBmB-H8qg0HdYhSQN_hz8rHMdpP=HH3C6B0&e=> tw=tter.com/lkrauss1<https://urldefense.proofpoint.com/v=/url?u=http-

3A__twitter.com__lkrauss1&d=DQMFAg&c=AGbYxfJbXK67K=XyGqyv2Ejiz41FqQuZFk4A-1lxfAU&r=DB9LvLOlQiaqWcFOihHC0LZCntZCR8Xtq5BHK=VR5To&m=ciP97mEbO4349G8_Nf9I5Up33Th7MWHYf6uw7yUBPZc&s=mspp0SBZa=jp5BOPRbD2xX1zHCi4LgzTZ8KNgjNBBKg&e=> | krauss.faculty.asu.edu=/div>

-Origins Project 10 Y=ar Celebration-

Be a part of somet=ing 10 years in the making!

April 5-9th=nbsp;2018 – V=sit for more info <https://urldefense.proofpoint.com/v2=url?u=https-

3A__www.origins10year.com_&d=DwMFaQ&c=l45AxH-

kUV2=SRQusp9vYR0n1GycN4_2jlnuKy6zbqQ&r=IXvAt9Yyr2FDWivZF1A3ilLTvn7OaKfvAPi=MR3ircA&m=znMdUaPvtHbuvyp0pJYlFvVS5vuv1LTTTDP94Oi4bm0&s=FMel447=3RFSNukOF7jyDzfs036dHKE4NQdWMsfiMxk&e=>:

=span style="font-size:11pt;font-family:Calibri,sans-serif"> <=i>

<image001.png><u>

Begin forwarded message=

From: Adam Waldman

<mailto

Su=ject: FW: Private and Confidential, in response to our meeting.<=> Date: Just got back on wifi and r=ading now &nbs=;

████████████████████████████████Erin Ellison - ████████████████████████████████
Subject: FW: Private and Confid=ntial, in response to our meeting.

Our policy on the Prohibition Against Discrimination, Haras=ment, and Retaliation (ACD 401 https://www.asu.edu/aad/manuals/acd/acd401.htl <https://urldefen=e.proofpoint.com/v2/url?u=https- 3A__www.asu.edu_aad_manuals_acd_acd401.ht=l&d=DwMFaQ&c=l45AxH- kUV29SRQusp9vYR0n1GycN4_2jlnuKy6zbqQ&r==XvAt9Yyr2FDWivZF1A3ilLTVn7OaKfvAPiXMR3ircA&m=znMdUaPvtHbuv yp0pJYIFvVS=vuv1LTTTDP94Oi4bm0&s=fGloe_z-tNcRUFiYCS0JmaBJXtQKJ_SFbRq2AhDldKs&==>) and its accompanying procedures (P20 – link to the pr=cedures is embedded in the policy document) directs the Office of Equity an= Inclusion to conduct prompt and equitable investigations. Among the p=ints stated are that the Office accepts anonymous complaints as well as dir=ct complaints. University employees are required to cooperate with an= investigation or allegations of violations of this policy. Providing=false or misleading information or failing to cooperate may result in disci=inary action. Individuals making a complaint or participating as a w=tness in an investigation cannot be retaliated against. Any employee w=o engages in retaliation will be disciplined. The Office of Equity an= Inclusion does not make any findings until such time as it determines that=it has completed its fact gathering.

<iv style="margin:0in 0in 0.0001pt;font-size:12pt;font-family:"Times New Roman",serif">

4

## On Tue, Feb 27, 2018 at 6:43 PM, Lawrence Krauss (cont.)

Our courts recognize that participants in an adm=nistrative investigation have a privilege against a defamation charge. In Paros v. Hoemako Hospital, 140 Ariz.=335, 681 P.2d 918 (Ct. App. Div. 2 1984), the court recognized that the emp=oyer's response to a notice of charge of discrimination filed with t=e Equal Employment Opportunity Commission was absolutely privileged. 1= Miller v. Servicemaster by Rees, =74 Ariz. at 520, 851P.2d 240, 243 (Ct. App. Div. 1 1993), the court recogn=zed the existence of a conditional privilege for employees to report percei=ed acts of sexual harassment as public policy dictated that employees must b= protected from workplace sexual harassment. Cited approvingly, Carey v. Maricopa County, 2009 WL 750225 (D. Ari=. 2009). Both Paros and=nbsp;Miller were cases concerning discrimina=ion and harassment under Title VII. In addition to its obligations un=er Title VII, the University must also operate its educational programs and=activities to be free from gender discrimination under Title IX.<=u>

<=>:

The Office of Equit= and Inclusion will proceed with its investigation as outlined in ACD 401a=d P20. The Office will not provide your client with its investigative file.=nbsp; We look forward to Dr. Krauss's continuing cooperation. =Regards,

=nbsp;
&=bsp;
Cynthia L= Jewett
=enior Associate General Counsel
Arizona State <u>Universit to</u>  =u>
mailto: /div>
c=div
mailto
S=nt: Friday, February 23, 2018 4:19 PM
To:Dear Naimah et al:

Attached you will f=nd a letter from my attorney, along with a letter he sent to Buzzfeed earli=r in this week regarding the defamatory and false story they were planning o= printing. The story was then published yesterday morning.&nb=p; I wanted to add to his letter, to rei=erate our concern about how your office was planning to follow up on the fa=se and defamatory third-party allegations from Buzzfeed. Becaus= this was initiated by an online entertainment news outlet with a clear age=da and established record of propagating false allegations about me, rather=than by any of the individuals they refer to as sources, this should n=t be considered a credible allegation worthy of investigation. I believe th=t our initial discussion was sufficient to settle this matter. W=ether or not you agree with this, there are two thi=gs I think are important to establish.

Firstly, that the University should not propagate what can be=false allegations from such a source by presenting them directly to current=and/or former employees or to others. To do so would be to further th=ir libelous agenda, as Mr Waldman has emphasized. In this regard, I w=uld appreciate seeing copies of the correspondence you might send to curren= or former employees about this in the process of carrying out and concludi=g your investigation.

Secondly, I reiterate once=again that the Origins Project environment is supportive, candid, frank, ho=est, and productive, with all employees being treated with respect, as well=as being supported and mentored. I am proud of our team, and I believe they=feel the same way.

Thanks for your attention to these letters.
4=iv>

=div>
Lawrence Krauss</=pan>
=div>

Dear Ms. Saadiq:

## On Tue, Feb 27, 2018 at 6:43 PM, Lawrence Krauss (cont.)

My name is Adam Waldman, and I am Professor Lawrence=Krauss' litigation counsel. Earlier this week, I sent the att=ched letter to Buzzfeed via one of their reporters named Peter Aldhous. &nb=p; I am also in receip= of Mr. Aldhous' letter to ASU, which is a variation on defamation =80 both libel and slander — that Mr. Aldhous and his colleagues h=ve been manufacturing for at least 6 months (notably without any reporting)=in a campaign with a purpose known only to them. Buzzfeed's f=rst method is to call or write third parties, posit a list of fake, anonymo=s, recklessly false and malicious "allegations," and ask if=the third party has anything to add. Buzzfeed's second method=is to seek tortious interference with Professor Krauss' professiona= contracts, by writing third parties with whom Professor Krauss is in privi=y, present a similarly inflammatory series of anonymous, recklessly false a=d malicious accusations, and then question: how can the email's rec=pient allow such a person to serve on their board, or speak at their confer=nce? The letter from Buzzfeed to the University falls into both categ=ries. There will be appropriate legal consequences for Buzzfeed's a=tions.

It is my under=tanding that your office believes it is compelled by the above to investiga=e false, defamatory, anonymous accusations posited by the online tabloid Bu=zfeed by contacting third parties and potentially rebroadcasting the tabloi= Buzzfeed's accusations. To be clear, these accusations were n=t made to the University by actual human beings who are alleging they were v=ctims. There is no evidence they were presented to Buzzfeed by actual=human beings. Moreover, no present or former employees of ASU have made any=such allegations to your office, or to any office at ASU, to our knowledge.=They are simply alleged by a tabloid, and one that had yet published a =9Cstory" on the topic when they forwarded these to you. You may propo=e to rebroadcast this tabloid's libel to other third parties who have also m=de no accusation against Professor Krauss. I suggest that you consult=with the University's counsel before taking so rash a step as re-br=adcasting hearsay defamation that came to you via an online tabloid under t=ese circumstances.

Profess=r Krauss and I both recognize the absolute need to investigate real allegat=ons. Some of the women who have bravely come forward with personal ha=assment allegations against Harvey Weinstein are my clients and friends.&nb=p; Some of these victims have been advised by me. Those actual allega=ions are entirely distinct from a tabloid attempting to manufacture allegat=ons to create harm.

IRS Circular 230 D=sclosure: Any statements regarding Federal tax law contained in this e•ma=I are not intended or written to be used, and cannot be used, for the purpo=es of avoiding penalties that may be imposed under federal tax law or to ma=ket any entity, investment plan or arrangement.

<=div>

Begin forwarded message:

Begin forwarded message:

- From: [REDACTED]
- Date: Tuesday, February 20, 2018 — 5:42 PM
- To: [REDACTED] (mailto link partially shown/redacted)
- Subject: Cease and Desist/[REDACTED]
- First line of message body: "Dear M=. [REDACTED]:"

Note: multiple fields are blacked out with redaction bars.

=

I am writing a= litigation counsel to Professor Lawrence Krauss. It has come to my a=tention that you and Buzzfeed have engaged in an outrageous and protracted d=famation campaign against Professor Krauss, including both libel and slande=. Buzzfeed's campaign has been malicious, undertaken with abs=lute reckless disregard for the truth, and despite repeated disprovals of t=e falsehoods you continue to harmfully disseminate. Your defamatory e=forts have also been undertaken, for reasons known only to you and your col=eagues, with the intention of tortiously interfering with the contracts of P=ofessor Krauss, and Buzzfeed has unfortunately succeeded in this malignant p=rpose. We have both testimony and documents from a litany of well res=ected third parties that provide overwhelming evidence of your and Buzzfeed=E2 s malfeasant attacks on Professor Krauss. We are still tallyi=g the damage.

=div style="margin:0in 0in 0.0001pt;font-size:12pt;font-family:"Times=New Roman",serif">

## On Tue, Feb 27, 2018 at 6:43 PM, Lawrence Krauss (cont.)

You and Buzzfeed will immediately cease and desist from further defamator= statements regarding Professor Krauss, and you and Buzzfeed will immediate=y cease and desist from any further efforts to tortiously interfere with Pr=fessor Krauss' contracts. If you and Buzzfeed are unwise enou=h to ignore this notice to cease and desist from the actions described abov=, the appropriate legal response will be swift. Notwithstanding the f=regoing, all legal rights are reserved. </=iv>

If you have more harassing emails or any prospe=tive communication you wish to transmit to Professor Krauss, you are instru=ted to send them to me as he is now represented by counsel. If your o= Buzzfeed's counsel, whomever they may be, wish to send me a letter in resp=nse to the above, be aware that I may, depending on its contents and becaus= I would be obligated to forward it to my client, consider such letter to a=so constitute a trigger of the above and react accordingly. Professor=Krauss has suffered enough abuse at your hands without commensurate consequ=nces.

Sincerely,

Adam W=Idman

<=div>

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Visit for more info

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=/blockquote>

## DISCLAIMER (cont.)

Assistant (Jessica); ktell
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Be a part of something=10 years in the making!

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