|A ELECTRONIC MAIL & REGULAR MAIL MartinD. Singer Lavely& Singer 2088 Century Park East Suite 2400, Los angeles, 90067 2906 Re: Response to your letter of December 19,2014 Dear Mr. Singer | eesponé to your letter of late Friday evening, December 19,2014. Vourlatters remaniable forts lchonesty. | howe reviewed the transcrots ofthe Burk and Gibble interviews ané they show that your characterization of CNN's conduct and the discussions themeelues is demonstrably fae, With respect to Mr. Burk, what becomes clear both fom the interview and from our cevearch i that 1) he had no specific nowledge of Ms. Johnson's claims and didnot know Bs. Johnson during the time periag when she climes she wae assaulted and 2) hes far from a disinterested observer. Mr. Burk essentially says he has no recollection of Ms. Johnson ever mentioning ay incidents {whim during the time he knew her. He offers generalized statements that Ms-lonnson spoke in support of many different prominent frean Americans in thelr business pursuits, Including sometimes Mr. Cosby. what you neglected t inform CRN about Mr. Burk was that he has ahistory of threatening and abusive behavior towards Mi. Johnson. Indeed, he is the subject of multiple restraining orders relating to her. This inchades choking Mis. Johnson and even threatening til her, fr which he led guilty, was convetes and a criminal protective order was issued. Burk suggested to CNN ‘that this conviction was subsequently vacated, but a review of the docket shows only that \Wasoffrmed several months later. CNN even had a California attorney search the docket for ‘anything that supported Burk’ chim. No record of the convetion being vacated was found, In assessing Bur’scrediblty alo notable that he filed a legal ation seeking “pallmony” payments fom Ms. Johnson. This lavrsurt was dlmissed beeause the cour found him tobe a ‘vexatious tigant. Aslam sure you already know, a vexatious litigant is someone who the court otermines repeatediy makes meritless or false cain‘We aso tale with Me. Glable and lacked into hc background. Ms. lohason says she has no ‘memory ofthis man who claims to have managed her from 1982-1994, Mr. Gibbie was unable to provide any documentary evidence that such a relationship existed. Mr Gible gave us the name ofa casting agent he sald could corroborate his claims bu, despite multiple attempts using multiple amiers over the past two days, CNN has been unable to reach her ‘Ac with Mr. Burk Me. Gibbe admits he didnot know Ms, Johnson at the time the alleged incident occurred. And ike Mr Burk our research shows that Mr. Gibble also has acriminal history. Indeed, he sa convicted felon ~a deal you agaln omitted in your prior correspondance. CNN learned that around the time period he dams he was managing Ms. Johason, Gibble was tied and convicted far receiving stolen property and conspicacy te commit ‘the robbery ofa former cent for which he spent two yearsin prison. In sum, at your request we contacted both fir. fur and Mr. Gibbla. Neither person had any specific kowledge about the claims Ms, Johnson is making. Both have a histor af criminal Dbehavior and engaging in cts involving dishonesty and moral turpitude. None of this Information wae disclosed by you Lastly, | must ask again ack that you refrain from engaging inex parte communications with ‘CNN employees. This includes your letter addressed to Jett Zucker and me, which somehow was leaked to TMZ. I also includes your previous leter, inappropriately addressed to two CNN staffers, and alate night email pestering one of those staffers. {trust this concludes our need to correspond, but f you fee you mus, please address your correspondence to me and me alone. Of cours, this letter is not intended to be an exhaustive recitation of CNN's hts, remedies et. allof which are reserved