<table><tr><th>From:</th><th>Lawrence Krauss</th></tr><tr><td>Sent:
To:</td><td>Tuesday, February 27, 2018 11:38 PM
jeffrey E.</td></tr><tr><td>Cc:</td><td>Lawrence Krauss</td></tr><tr><td>Subject:</td><td>Re: Private and Confidential, in response to our meeting.</td></tr></table>

at =he airport and delayed for 3 hours so I can write. I have written =he university clarifyng this again. I understand your concern, =ut the University can only investigate what they =nterviewed me about, which is the buzzfeed allegations related to the =niversity.. And, in addition, the University has =treacly dispensed with all the others.. When I met the investigator she =imply handed me the document that buzzfeed had =ent to the university regarding the claims by former Origins =mployees.. and asked me to comment on them. That is the 'complaint' they are investigating, =nd the only complaint they received directly from buzzfeed after =ecember, when all the other complaints were dealt with. =nbsp;

In any =ase, I have made it quite clear to them that I am not being represented =y Adam..

So, I thank you for =etting me to clarify the situation for them, but happily at least your =ther concern is not relevant at this point.

Lawrence

On Feb 27, 2018, at 3:40 PM, jeffrey E. =lt;jeevacation@gmail.com <mailto:jeevacation@gmail.com» wrote:

you dont understand. AT ALL . =!! they dont need your permission to copy you. =hey now need your lawyers approval . to copy you her =etter is makes clear that your tellign them how to do their job is =ullshitk and they can investigate claims brought by anyone at =nytime. .. and complaints made to them =re protected from defamation claims. . They =ust do a new thorough investigation. . and dig =eeper. . and take every allegation from buzz =ed an run it down. . and anyone else now who decides to =oin the bandwagon. . sad!!! as most of this but =learly not all was self inflicted.

On Tue, Feb 27, 2018 at 3:55 PM, Lawrence Krauss wrote an email. The recipients and senders of the email are redacted with black boxes.

Dear Cynthia et al:

Adam forwarded me your note while on a plane. I wanted =o let you know that you can feel free to cc me on all communication or =mail me and cc Adam, as you wish. . Adam is advising me on =atters related to Buzzfeed, and so it is appropriate to communicate to =oth of us in this regard. I expect he will be writing to =ou. In any case, I wanted to assure you that I will continue to =ooperate with all your offices, as I have done thus far. I value the =ollegial relationship I have with all of my colleagues at ASU. I =t) hope Naimah's group has taken all of our concerns about =uzzfeed under advisement, but I also understand the requirements on the =niversity as well.

Thanks for your attention to =his.

Best

Lawrence Krauss

<tel

Lawrence M. =rauss
Director, The Origins Project at ASU
Co-Director, Cosmology Initiative
Foundation Professor
School of Earth & Space =xploration and Physics Department
Arizona State =iversity, P.O. Box 871404, Tempe, AZ 85287-1404
Research Office:  tel:  = Assistant (Jessica): 
Origins Office (Cynthia):  <tel: 
origins.asu.edu | twitter.com/lkrauss1 | krauss.faculty.asu.edu

Celebration-Be -Origins a part Project of something 10 Year 10 years in the making! April 5.9th 2018 — Visit for more =nfo <https://www.originsl0year.com/>

## <image002.png>

=/div>

Begin forwarded message:

From: Adam Waldman

Subject: FW: Private and =onfidential, in response to our meeting.

Date: February 27, 2018 at 12:28:21 PM =ST

To: Lawrence Krauss

Fyi
Just got back =n wifi and reading now

From: =ynthia Jewett <mailto.
Date: =uesday, February 27, 2018 at 3:21PM

## <image002.png> (cont.)

- Subject: "=W: Private and Confidential, in response to our meeting."
- To: 1 recipient (name and mailto redacted)
- Cc: multiple recipients (names and mailto(s) redacted)
- Visible text fragments: "<mailto" appears next to redacted email(s) indicating links to email addresses.

Subject: =W: Private and Confidential, in response to our meeting.

Mr. Waldman,

Your client, Lawrence Krauss, copied me on his February =3rd email =ommunication to the Office of Equity and Inclusion. I am writing =o convey the University's position on its responsibility to =onduct administrative investigations into allegations of conduct that =ould violate institutional policy, if true. Because Dr. Krauss =as retained legal counsel, I am writing directly to you. You may =orward my communication on to your client. Without having first =ecured your permission, I did not think it was proper for me to copying =im on this reply.

Our policy on the Prohibition Against Discrimination, =arassment, and Retaliation (ACD 401 https://www.asu.edutaad/manuals/acd/acd401.html) and its accompanying procedures =P20— link to the procedures is embedded in the policy =ocument) directs the Office of Equity and Inclusion to conduct prompt =nd equitable investigations. Among the points stated are that the =ffice accepts anonymous complaints as well as direct complaints. =niversity employees are required to cooperate with any investigation or =llegations of violations of this policy. Providing false or =isleading information or failing to cooperate may result in =isciplinary action. Individuals making a complaint or =articipating as a witness in an investigation cannot be retaliated =gainst. Any employee who engages in retaliation will be =isciplined. The Office of Equity and Inclusion does not make any =indings until such time as it determines that it has completed its fact =athering.

Our courts recognize that participants in an =dministrative investigation have a privilege against a defamation =harge. In Paros v. Hoemako Hospital, 140 =riz. 335, 681 P.2d 918 (Ct. App. Div. 2 1984), the court recognized =hat the employer's response to a notice of charge of =iscrimination filed with the Equal Employment Opportunity Commission =as absolutely privileged. In Miller v. Servicemaster by Rees, 174 =riz. at 520, 851 P.2d 240, 243 (Ct. App. Div. 1 1993), the court =ecognized the existence of a conditional privilege for employees to =eport perceived acts of sexual harassment as public policy dictated =hat employees must be protected from workplace sexual harassment. Cited =pprovingly, Carey v. Maricopa County, 2009 =L 750225 (D. Ariz. 2009). Both Paros and Miller were =ases concerning discrimination and harassment under Title VII. In =ddition to its obligations under Title VII, the University must also =perate its educational programs and activities to be free from gender =iscrimination under Title IX.

The Office of Equity and Inclusion will proceed with its =nvestigation as outlined in ACD 401 and P20. The Office will not =rovide your client with its investigative file. We look forward =o Dr. Krauss's continuing cooperation. Regards,

- Document type: Email header screenshot with heavy redactions.
- Sender (visible role): Senior Associate General Counsel, Arizona State University (name redacted).
- Date/time: Friday, February 23, 2018 — 4:19 PM.
- From/To/Cc: Multiple mailto: addresses shown; recipient and cc names/addresses are redacted.
- Visible organizational/entity references: Arizona State University; Office of Equity and Inclusion.
- Visible policy references / context (from surrounding text): ACD 401; P20; statement that the Office of Equity and Inclusion will proceed with its investigation and will not provide the investigative file; request for continued cooperation from the referenced doctor.
- Other notes: Several instances of "mailto:" and black redaction bars across names and addresses; personal names in the image are redacted and not disclosed.

## <image002.png> (cont.)

Subject: Private=and Confidential, in response to our meeting.

Dear Naimah et al: =nbsp;

Attached you will find a letter from my attorney, along with = letter he sent to Buzzfeed earlier in this week regarding the =efamatory and false story they were planning on printing. The =tory was then published yesterday morning. &=bsp; I wanted to add to his letter, to reiterate our concern =bout how your office was planning to follow up on the false and =efamatory third-party allegations from Buzzfeed. Because =his was initiated by an online entertainment news outlet with a clear =genda and established record of propagating false allegations about me, =ather than by any of the individuals they refer to as =ources, this should not be considered a credible allegation worthy =f investigation. I believe that our initial discussion was =ufficient to settle this matter. Whether or not you agree =ith this, there are two =hings I think are important to establish. =nbsp;

Firstly, that the University should =ot propagate what can be false allegations from such a source by =resenting them directly to current and/or former employees or to =thers. To do so would be to further their libelous agenda, as Mr =aldman has emphasized. In this regard, I would appreciate seeing =opies of the correspondence you might send to current or former =mployees about this in the process of carrying out and concluding your =nvestigation.

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

Thanks for your attention to these letters.

Lawrence Krauss

Dear =s. Saadiq:

My =ame is Adam Waldman, and I am Professor Lawrence Krauss' =itigation counsel. Earlier this week, I sent the attached letter =o Buzzfeed via one of their reporters named Peter Aldhous. =nbsp;

I =m also in receipt of Mr. Aldhous' letter to ASU, which is a =ariation on defamation — both libel and slander — that =r. Aldhous and his colleagues have been manufacturing for at least 6 =onths (notably without any reporting) in a campaign with a purpose =nown only to them. Buzzfeed's first method is to call or =rite third parties, posit a list of fake, anonymous, recklessly false =nd malicious "allegations," and ask if the third party =as anything to add. Buzzfeed's second method is to seek =ortious interference with Professor Krauss' professional =ontracts, by writing third parties with whom Professor Krauss is in =rivity, present a similarly inflammatory series of anonymous, =ecklessly false and malicious accusations, and then question: how can =he email's recipient allow such a person to serve on their =oard, or speak at their conference? The letter from Buzzfeed to =he University falls into both categories. There will be appropriate =egal consequences for Buzzfeed's actions.

It is my understanding that your office believes it is =ompelled by the above to investigate false, defamatory, anonymous =ccusations posited by the online tabloid Buzzfeed by contacting third =arties and potentially rebroadcasting the tabloid Buzzfeed's =ccusations. To be clear, these accusations were not made to the =niversity by actual human beings who are alleging they were =ictims. There is no evidence they were presented to Buzzfeed by =ctual human beings. Moreover, no present or former employees of ASU =ave made any such allegations to your office, or to any office at ASU, =o our knowledge. They are simply alleged by a tabloid, and one that had =et published a "story" on the topic when they forwarded these =o you. You may propose to rebroadcast this tabloid's libel to =ther third parties who have also made no accusation against Professor =rauss. I suggest that you consult with the University's =ounsel before taking so rash a step as re-broadcasting hearsay =efamation that came to you via an online tabloid under these =ircumstances.

Professor Krauss and I both recognize the absolute need to =nvestigate real allegations. Some of the women who have bravely =ome forward with personal harassment allegations against Harvey =einstein are my clients and friends. Some of these victims have =een advised by me. Those actual allegations are entirely distinct =rom a tabloid attempting to manufacture allegations to create harm. =nbsp;

4

## <image002.png> (cont.)

Sincerely,
Adam =aldman
DISCLAIMER

Confidentiality Notice: This email, including any attachments, is being sent by =r on behalf of the Endeavor Group or Endeavor Law Firm; it is =onfidential and may contain information protected by the =ttorney-client and/or the attorney work-product privileges. If you are =ot the intended recipient, you are hereby notified that any review, =isclosure, copying, or distribution of this information is unauthorized =nd prohibited. If you have received this communication in error, please =dvise the sender immediately by reply email and delete this message and =ny attachments without retaining a copy.

IRS =ircular 230 Disclosure: Any statements regarding Federal tax law contained in =his e-mail are not intended or written to be used, and cannot be used, =or the purposes of avoiding penalties that may be imposed under federal =ax law or to market any entity, investment plan or =rrangement.

Begin forwarded message:

<u>From: Adam =aldman</u>

<mailto:

Date: Tuesday, February 20, 2018 at =:42 PM To: Peter Aldous Subject: Cease and Desist/Professor Lawrence =rauss

Dear =r. Aldous:

I =m writing as litigation counsel to Professor Lawrence Krauss. It =as come to my attention that you and Buzzfeed have engaged in an =utrageous and protracted defamation campaign against Professor Krauss, =ncluding both libel and slander. Buzzfeed's campaign has =een malicious, undertaken with absolute reckless disregard for the =ruth, and despite repeated disprovals of the falsehoods you continue to =armfully disseminate. Your defamatory efforts have also been =ndertaken, for reasons known only to you and your colleagues, with the =ntention of tortiously interfering with the contracts of Professor =rauss, and Buzzfeed has unfortunately succeeded in this malignant =urpose. We have both testimony and documents from a litany of =ell respected third parties that provide overwhelming evidence of your =nd Buzzfeed's malfeasant attacks on Professor Krauss. We =re still tallying the damage.

You and Buzzfeed will immediately cease and desist from =urther defamatory statements regarding Professor Krauss, and you and =uzzfeed will immediately cease and desist from any further efforts to =ortiously interfere with Professor Krauss' contracts. If =ou and Buzzfeed are unwise enough to ignore this notice to cease and =esist from the actions described above, the appropriate legal response =ill be swift. Notwithstanding the foregoing, all legal rights are =eserved.

If you have more harassing emails or any prospective =ommunication you wish to transmit to Professor Krauss, you are =nstructed to send them to me as he is now represented by counsel. =f your or Buzzfeed's counsel, whomever they may be, wish to send me a =etter in response to the above, be aware that I may, depending on its =ontents and because I would be obligated to forward it to my client, =onsider such letter to also constitute a trigger of the above and react =ccordingly. Professor Krauss has suffered enough abuse at your =ands without commensurate consequences.

Sincerely,
Adam =aldman

## <image002.png> (cont.)

## DISCLAIMER

Confidentiality Notice: This email, including any attachments, is being sent by =r on behalf of the Endeavor Group or Endeavor Law Firm; it is =onfidential and may contain information protected by the =ttorney-client and/or the attorney work-product privileges. If you are =ot the intended recipient, you are hereby notified that any review, =isclosure, copying, or distribution of this information is unauthorized =nd prohibited. If you have received this communication in error, please =dvise the sender immediately by reply email and delete this message and =ny attachments without retaining a copy.

IRS =ircular 230 Disclosure: Any statements regarding Federal tax law contained in =his e-mail are not intended or written to be used, and cannot be used, =or the purposes of avoiding penalties that may be imposed under federal =ax law or to market any entity, investment plan or arrangement.

Lawrence M. Krauss
Director, The Origins =roject at ASU
Co-Director, Cosmology =nitiative
Foundation Professor
School =f Earth & Space Exploration and Physics Department
Arizona State <u>Universit P.O. Box</u> 871404, Tempe, <u>=Z 85287-1404</u>
Research Office <u>| Assistant</u> (Jessica)
Origins Office (Cynthia
<mailto

origins.asu.edu | twitter.com/lkrauss1 | krauss.faculty.asu.edu

Celebration-Be -Origins a part Project of something 10 =ear 10 years in the making! April =-9th 2018 — Visit for more info

<image002.png>

<image002.png>

please note

The information contained in this =ommunication is confidential, may be attorney-client =rivileged, may constitute inside information, and is =ntended only for the use of the addressee. It is the =roperty of JEE

Unauthorized use, disclosure =r copying of this communication or any part thereof is =trictly prohibited and may be unlawful. If you have =eceived this communication in error, please notify us =mmediately by return e-mail or by e-mail to jeevacation@gmail.com, and

## DISCLAIMER (cont.)

destroy this =ommunication and all copies thereof, including all =ttachments. copyright -all rights reserved

Lawrence M. =rauss
Director, The Origins Project at ASU
Co-Director, Cosmology Initiative
Foundation Professor
School of Earth & Space Exploration and Physics =epartment
Arizona State University, P.O. Box =71404, Tempe, AZ 85287-1404
Research Office:  | Assistant (Jessica): 
Origins Office (Cynthia): 
<mailto

origins.asu.edu | twitter.com/lkrauss1 | krauss.faculty.asu.edu

Celebration-Be a part of =omething 10 years in the making! -Origins Project =0 Year April 5-9th 2018 — Visit for more info <https://www.originsl0year.com/>