UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF ILLINOIS

NEWSPAPER HOLDINGS, INC., )
)
Plaintiff, )
)
) Case No. 3:12-cv-01034-MJR-SCW
v. )
)
STEPHEN RAYMOND and ) Hon. Judge Michael J. Reagan
the EFFINGHAM & TEUTOPOLIS )
NEWS REPORT, INC., )
)
Defendants. )


COMPLAINT
Newspaper Holdings, Inc. (NHI), by counsel, for its complaint against Stephen Raymond
("Raymond") and the Effingham & Teutopolis News Report, Inc. (ETNR) states as follows:
INTRODUCTION
1. This is a claim for relief under the laws of the State of Illinois, seeking
compensatory and punitive damages against Raymond, a former executive of Plaintiff NHI, for
breaches of fiduciary duties to NHI and against both Raymond and the ETNR for tortious
interference with NHIs prospective economic advantages.
2. NHI was damaged when Raymond, the former publisher of the Effingham Daily
News (EDN), set up a competing publication, the ETNR, while still employed by NHI.
Raymond and the ETNR then acted to poach fellow NHI employees working at the EDN, divert
to the ETNR a prospective NHI employee who applied for an open position with the EDN, and
pursue NHI customers by using NHI informationall in secret and while Raymond was on
NHIs payroll.
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3. Market competition is encouraged under our free enterprise economic system.
But competitors must play by the rules. In this case, Defendants have failed to do so. All of
Defendants actions, described in detail below, were taken willfully, maliciously and with the
knowledge that NHIs business would be harmed.
4. Because of these wrongful acts, the ETNR was able to officially "open[] for
business" on July 16, 2012 just a few weeks after Raymond's departure from NHI, and to release
the ETNR's first publication on August 2, 2012. In that first edition, nearly every advertiser was
an existing advertiser with the EDN and an advertising client of former EDN employees now
working for the ETNR.
JURISDICTION AND VENUE
5. Plaintiff NHI is a Delaware corporation with a principal place of business located
at 445 Dexter Avenue, Suite 7000, Montgomery, Alabama.
6. Defendant Stephen Raymond is an Illinois citizen domiciled at 2001 Magnolia
Street, Effingham, Illinois.
7. Defendant the ETNR is an Illinois corporation with a principal place of business
located at 1901 S Fourth Street, Suite 223, Effingham, Illinois.
8. This Court has subject matter jurisdiction over this action under 28 U.S.C.
1332(a)(1). NHI and the Defendants are citizens of different states and the matter in controversy
exceeds the sum or value of $75,000, exclusive of interest and costs.
9. Venue is proper in this district pursuant to 28 U.S.C. 1391(b)(1) because each
defendant resides in the of the Southern District of Illinois.
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FACTUAL ALLEGATIONS
10. From October 4, 1999 until June 29, 2012, Raymond was employed by NHI.
Raymond started his career with NHI as the advertising manager for the EDN, a daily and
weekly newspaper serving Effingham, Illinois and surrounding communities. In May 2001,
Raymond was promoted to publisher of the EDN, and he remained in that position until he left to
run the ETNR.
11. In his role as publisher, Raymond was an executive and shareholder in NHI as
well as the single most senior employee of the EDN responsible for all aspects of the publication,
including operations, sales, marketing, news, editorial content, community relations and hiring
and firing the front-line staff and department heads. Raymond also supervised and managed all
other EDN staff.
12. Beginning in or before March 2012, Raymond put in motion a secret plan to start
a new newspaper to compete directly with the EDN. That newspaper, the ETNR, was opened
only two weeks after Raymond left NHI. The first print edition was distributed on August 2,
2012, a little over a month after Raymond left NHI. A true and correct copy of the first edition of
the ETNR is attached as Exhibit A.
13. As described in more detail below and as discovery will further show, in pursuit
of his secret plan, Raymond, while still employed by NHI and while owing NHI heightened
fiduciary duties, solicited other NHI employees to join him at the ETNR; diverted a prospective
employee from NHI to the new paper; utilized the EDN's equipment, facilities and employees to
set up his competing company and obtain necessary information and training to assist in his
efforts; appropriated NHIs business opportunities; and solicited at least one NHI customer in an
effort to move business to Raymond's new competing paper.
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A. Recruitment of NHI Current and Potential Employees
14. To date, in addition to Raymond, at least four former NHI employees who were
working under Raymond at the EDN are now working for him at the ETNR: Cheryl Westendorf,
Rae Printz, Tama Price, and Karen Mettendorf.
15. Mettendorf was the business manager for the EDN and the second most senior
employee responsible for the financial performance of the newspaper. When she quit,
Mettendorf had been with EDN for more than nineteen (19) years. She left her employ with NHI
on July 2, 2012, to work as the Office Manager for the ETNR.
16. Cheryl Westendorf, Rae Printz and Tama Price were each outside sales
representatives for the EDN. Westendorf worked at the EDN for twenty-eight (28) years, Printz
for twenty-six (26) years, and Price for seventeen (17) years, for a combined total of seventy-one
(71) years of history and experience with the EDN. Westendorf and Printz left their employment
the same day as Raymond, and Price left on July 5, 2012 all to work in sales for Raymond at
the ETNR.
17. As early as April 16, 2012, Raymond secured Tama Prices commitment to join
him at the ETNR. Raymond informed Price at that time that he was working that week to
finalize plans for the new venture and sought information from Price to assess health insurance
rates for the ETNR. In order to maintain the secrecy of his plan, Raymond instructed Price to
kill this e-mail.
18. As early as April 20, 2012, Raymond had also secured Rae Printz's commitment
to join him at the ETNR. On that date, Raymond informed Martins IGA that he was forming a
competing paper and that Printz would be joining him. A true and accurate copy of the email
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exchange between Raymond and Printz discussing the Martins IGA meeting is attached as
Exhibit B.
19. Some time before May 18, 2012, Raymond had further received Mettendorfs
commitment to join him at ETNR. On May 18, 2012, as stated above, Raymond informed
Mettendorf of his plans with regard to other EDN employees he was targeting to join his venture.
20. Upon information and belief and as discovery will further show, Raymond had
also secured the commitment of Westendorf to join him at ETNR prior to resigning his
employment with NHI.
21. Upon information and belief and as discovery will further show, Raymond made
offers or promises of employment to each of these employees while he was still publisher of the
EDN.
22. Raymond specifically wrote to Mettendorf stating that he also considered seeking,
or had already sought, to employ other NHI employees at the ETNR, including Gina Harris,
Michelle Sowell, and Sarah Williams, all while he was still employed by NHI and to NHI's
detriment. A true and correct copy of the email from Raymond to Mettendorf is attached as
Exhibit C.
23. In addition, upon information and belief, Raymond utilized his position as
publisher to review and divert to the ETNR resumes submitted for open positions with the EDN.
24. For instance, on June 18, 2012, Allan Lewis submitted his resume to the EDN to
specifically apply for the open position as the sports reporter for the EDN. However, Lewis was
never hired by the EDN. Instead, Raymond hired Lewis to work for the ETNR; when the first
edition of the ETNR was issued, Lewis's name appeared as part of the ETNR's editorial staff. A
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true and accurate copy of the email message from Allan Lewis to Raymond at his EDN email
address is attached as Exhibit D.
25. In the alternative, Raymond failed to consider qualified applicants, including
Lewis, for open positions with the EDN because of his competitive interest in ETNR.
B. Interference with the EDNs Advertising Customers
26. Prior to his resignation from NHI, in addition to recruiting NHI staff and potential
employees to join his new venture, Raymond and the ETNR also used NHIs resources to build
and begin to operate the ETNR business. When the ETNR went to press just weeks after
Raymond left the EDN, it was supported by approximately fifty-three (53) advertisers, nearly all
of whom were existing advertising clients of the EDN serviced by Price, Printz, or Westendorf.
27. On April 20, 2012, Raymond met with Martin's IGA. Martins IGA was a thirty-
plus year advertising customer of the EDN. Raymond shared with them his secret plan to launch
the ETNR in competition with the EDN and to take at least one key NHI employee, Printz, with
him.
28. At this meeting, Raymond also disclosed specific plans related to advertising,
circulation, and geographic coverage of the ETNR. Upon information and belief, Raymond
encouraged Martins IGA to move some or all of its advertising from the EDN to the ETNR.
29. Following the meeting, Printz and Raymond discussed via email undercutting the
EDNs advertising rates in order to secure Martins IGA as an ETNR advertiser. Although
Martins IGA representatives had expressed some initial reservation about the ETNR business
plan, Raymond expressed to Printz his confidence that we can put together a package for them
to consider. A true and accurate copy of the email exchange between Raymond and Printz is
attached as Exhibit E.
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30. Soon thereafter, on May 16, 2012, Raymond requested that an EDN employee,
Jane Herring, provide him with the prices charged to Martins IGA for printing their weekly
flyer, the insert in the weekly EDN, and the insert for the Weekly Advertiser. Herring provided
him with that information. Notably, Raymond did not normally ask for such detailed pricing
information. A true and accurate copy of the email exchange between Raymond and Herring is
attached as Exhibit F.
31. Upon information and belief, Raymond requested the Martins IGA pricing
information for the purpose of undercutting the EDN's prices, competing for the Martins IGA
advertising account and using this information to continue to strengthen his business plan.
32. Martin's IGA agreed to advertise with the ETNR. The first issue of the ETNR
included a full-page Martin's IGA advertisement. The owners of Martin's IGA also own Save A
Lot Foods, another good customer of the EDN who has advertised with the EDN for at least
fifteen years. Save A Lot Foods also advertised in the first issue of the ETNR.
33. Since the launch of the ETNR, the ETNR and Raymond continue to interfere with
the EDNs advertising relationship with Martins IGA. Martin's IGA has reduced its advertising
spend with the EDN, and although Save A Lot Foods continues to advertise in the EDN, it has
stopped advertising in the Weekly Advertiser altogether.
34. As a result of Raymonds and the ETNRs solicitations, other advertisers have
reduced their advertising spending with the EDN and have begun to advertise with the ETNR,
including Northside Ford and Effingham Tire.
35. Northside Ford was an advertising client of Rae Printz while she was employed
by NHI. Northside Ford has advertised in the EDN during the entire term of its current
ownership, since approximately October, 2006.
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36. Effingham Tire was an advertising client of Tama Price while she was employed
by NHI. Effingham Tire is another long-standing advertising client of the EDN.
37. In addition to Martins IGA, Save A Lot Foods, Effingham Tire, and Northside
Ford, the inaugural issue of the ETNR included advertisements from approximately forty-nine
(49) other advertisers.
38. With only two exceptions, every advertiser who advertised in the first issue of the
ETNR had a previously-existing advertising relationship with the EDN through one of the three
advertising sales representatives who left the EDN with Raymond. Thus, fifty-one (51) of fifty-
three (53) advertisers in the first issue of the ETNR had been advertising clients of Price, Printz,
or Westendorf.
39. Nearly all of the clients Defendants took to the ETNR had been long-term,
regular advertisers of the EDN.
40. Raymond and the ETNR knew that nearly all of their advertisers had been long-
term EDN advertisers.
C. Additional Steps Taken by Raymond to Set His Secret Plan in Motion
41. Months before Raymond quit, he was taking all other steps, in secret, to
improperly launch a competing business while he was still an employee of NHI, working for the
EDN, and collecting an NHI paycheck.
42. Sometime in late March or early spring, Raymond asked Ruth Walk, an EDN
circulation clerk, to show him how to complete a postage report for a weekly advertiser
publication. Although the request was unusual because Raymond had never shown such interest
before and did not need such information to perform his duties as publisher of EDN, Walk, as his
subordinate, showed Raymond what to do and made him a copy of completed report statements.
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The ETNR is only distributed by mail. Upon information and belief, Raymond sought this
training and information from Ms. Walk for purposes of understanding how to properly
distribute the ETNR.
43. On April 18, 2012, Raymond confirmed in an email to Ruth Raymond that he was
working on his business plan. Later in the day he told Ruth he had finished the financial
statements for the business plan.
44. By April 23, 2012, Raymond had drafted his business plan and was in the process
of finalizing it.
45. On April 26, 2012, Raymond confided to Jeff Raymond that he was making
progress on his new venture. In secret, he was meeting with his accountant, working to secure
computer and IT services, and looking to contract for web site design and social media services.
46. Sometime before May 29, 2012, Raymond had secretly provided his business plan
to seven banks to fund the ETNR.
47. On June 14, 2012, Raymond incorporated the Effingham & Teutopolis News
Report, Inc., as an Illinois corporation with the Secretary of State of Illinois. A true and accurate
copy of the Corporation File Detail Report for Effingham & Teutopolis News Report, Inc. is
attached as Exhibit G.
48. On June 26, 2012, the internet domain www.etnewsreport.com was registered as
an internet address. A true and accurate copy of the home page of www.etnewsreport.com,
showing it as the home page of the ETNR, is attached as Exhibit H.
49. From day one, the ETNR intentionally interfered with the EDNs business, and it
benefited by actions taken by Raymond prior to the time he left his employ with NHI.
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50. At no time did Raymond inform NHI that he was engaged in a directly
competitive business, taking many of the EDN's staff with him, diverting an EDN prospective
employee, soliciting the EDNs advertisers, or undercutting the EDN's prices.
COUNT I BREACH OF FIDUCIARY DUTY
51. NHI realleges and incorporates by reference paragraphs 1 through 50 as if fully
set forth herein.
52. Raymond, as an employee and agent of NHI, owed fiduciary duties to NHI.
53. Raymond, even as a general employee, had a fiduciary obligation not to hinder
NHIs ability to continue its business, usurp its business opportunities, or compete with it during
the term of his employment. But Raymond did each of these things by, at least, soliciting other
EDN employees to leave the EDN and work for the ETNR, diverting a prospective employee to
the ETNR, and soliciting the EDN's customers, at least including Martin's IGA and Save A Lot
Foods, to advertise with the ETNR, all while still working at the EDN.
54. Moreover, Raymond owed a heightened fiduciary duty to NHI, including the duty
of loyalty, by virtue of his key position with the EDN. As such, Raymond was obliged to act
solely in NHIs interest and refrain from actively exploiting his position within the corporation
for his own personal benefit or hindering the ability of the corporation to operate its business.
55. Thus, Raymond breached his heightened fiduciary duties by engaging in the set
up of the ETNR and failing to inform NHI that he was forming a rival company or engaging in
other fiduciary breaches.
56. Raymond breached his heightened fiduciary duties when he actively solicited NHI
employees to quit their employment with NHI and join his competing business.
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57. Raymond breached his duties when he approached the EDN's customers such as
Martins IGA and Save A Lot Foods to discuss plans to compete with the EDN via the ETNR
and to solicit their business.
58. Raymond breached his fiduciary duties by using NHIs facilities, information, and
equipment to assist him in developing his new business. Specifically, Raymond learned the "ins-
and-outs" of the mailing processes so that he could know how to mail deliver his competing
paper.
59. Raymond breached his fiduciary duties when he inquired into, at least, the EDN's
advertising rates charged to Martins IGA for the purpose of undercutting it.
60. Raymond breached his fiduciary duties when he diverted the application of Allan
Lewis, a prospective and potential NHI employee, and hired him as an employee of the ETNR.
COUNT II TORTIOUS INTERFERENCE
WITH PROSPECTIVE ECONOMIC ADVANTAGE

61. NHI realleges and incorporates by reference paragraphs 1 through 50 as if fully
set forth herein.
62. NHI had an economic and business expectancy, based on past conduct with its
regular customers, such as Martins IGA, Save A Lot Foods, Northside Ford and Effingham Tire,
that they would continue to advertise in the EDN. None of the EDN's regular customers had
given any indication that they would reduce or stop advertising in the EDN before they started
advertising in the ETNR.
63. Defendants were aware of NHIs business expectancy in this respect.
64. Defendants intentionally and unjustifiably interfered with NHIs reasonable
business expectancy when Raymond, while still working for NHI, met with customers who
regularly advertised in the EDN, and pitched them on his new venture, the ETNR. Defendants
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12

continue to interfere with NHIs justified business expectancy as they continue to solicit
advertising business from the EDN's customers.
65. As a result of Raymonds secret meeting and the ETNRs continued solicitations
with the representatives for Martins IGA and Save A Lot Foods, Martins IGA and Save A Lot
Foods placed advertisements with ETNR that would have otherwise been placed with EDN.
66. Upon information and belief, Defendants also intentionally and unjustifiably
interfered with NHIs justified business expectancy when Defendants met with representatives of
other EDN advertisers to solicit their business for the ETNR.
67. Raymond and the ETNR interfered with NHIs business expectancy when
Raymond solicited then-current NHI employees, including but not limited to Cheryl Westendorf,
Rae Printz, Tama Price, and Karen Mettendorf, to join the ETNR.
68. Raymond and the ETNR further interfered with NHIs business expectancy when
Raymond solicited Allan Lewis, a prospective NHI employee, to join the ETNR or when
Raymond failed to consider Allan Lewis for an NHI position because he planned to solicit him to
join the ETNR.
69. NHI had a valid business expectancy of keeping its EDN staff and entering into a
business relationship with potential employees.
70. Raymond, as publisher of the EDN and principal of the ETNR, was aware of
NHIs valid business expectancy.
71. Raymond intentionally interfered with NHIs valid business expectancy when he
prevented NHI from considering and/or hiring prospective employee, Allan Lewis.
72. NHI was harmed by Defendants' interference with its valid business expectancies
with regard to its customers, and with regard to its employees and prospective employees.
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WHEREFORE, NHI respectfully requests that the Court award it compensatory and
punitive damages in an amount to be proven at trial for Raymond's breaches of his fiduciary
duties and for Raymonds and the ETNRs tortious interference with NHIs prospective
economic advantage; that it establish a constructive trust to the extent that Defendants have been
enriched by their activities; and that it award all other just and appropriate relief.

Dated: September 27, 2012 Respectfully submitted,

/s/ Colby A. Kingsbury
Colby Anne Kingsbury (No. 6272842)
FAEGRE BAKER DANIELS LLP
311 South Wacker Drive, Suite 4400
Chicago, Illinois 60606
Telephone: 312-212-6500
Facsimile: 312-212-6501
Email: colby.kingsbury@FaegreBD.com

Attorney for Plaintiff, Newspaper Holdings, Inc.
Case 3:12-cv-01034-MJR-SCW Document 2 Filed 09/27/12 Page 13 of 13 Page ID #15
JS 44 (Rev. 09/11)
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RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
Newspaper Holdings, Inc.
445 Dexter Avenue, Suite 700
Montgomery, AL
Montgomery
Colby A. Kingsbury, Faegre Baker Daniels LLP
311 S. Wacker Drive, Suite 4400, Chicago, Illinois 60606-6622
(312) 212-6500
Stephen Raymond and the Effingham & Teutopolis News Report, Inc.
28 USC 1332
Breach of duty of loyalty and tortious interference with business expectancy
09/27/2012 /s/ Colby A. Kingsbury
Case 3:12-cv-01034-MJR-SCW Document 2-1 Filed 09/27/12 Page 1 of 2 Page ID #16
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the diIIerent parties must be checked. (See Section III below; Iederal question actions take precedence over diversity cases.)
III. Residence (citizenship) of Principal Parties. This section oI the JS 44 is to be completed iI divers ity oI citizenship was indicated above. Mark this section
Ior each principal party.
IV. Nature of Suit. Place an 'X in the appropri ate box. II the nature oI s uit cannot be determined, be sure the cause oI action, in Section VI below, is
suIIicient to enable the deputy clerk or the statistical clerks in the Administrative OIIice to determine the nature oI suit. II the cause Iits more than one nature oI
suit, select the most deIinitive.
V. Origin. Place an 'X in one oI the seven boxes.
Original Proceedings. (1) Cases which originate in the United States district courts.
Removed Irom State Court. (2) Proceedings initiated in state cour ts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the petition
Ior removal is granted, check this box.
Remanded Irom Appellate Court. (3) Check this box Ior cases remanded to the district court Ior Iurther action. Use the date oI remand as the Iiling date.
Reinstated or Reopened. (4) Check this box Ior cases reinstated or reopened in the district court. Use the reopening date as the Iiling date.
TransIerred Irom Another District. (5) For cases transIerred under Title 28 U.S.C. Section 1404(a). Do not use this Ior within district transIers or multidistrict
litigation transIers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transIerred into the district under authority oI Title 28 U.S.C. Section 1407. When this
box is checked, do not check (5) above.
Appeal to District Judge Irom Magistrate Judgment. (7) Check this box Ior an appeal Irom a magistrate judge`s decision.
VI. Cause of Action. Report the civil statute directly related to the cause oI action and give a brieI description oI the cause . Do not cite jurisdictional statutes
unless diversity. Example: U.S. Civil Statute: 47 USC 553
BrieI Description: Unauthorized reception oI cable service
VII. Requested in Complaint. Class Action. Place an 'X in this box iI you are Iiling a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the dollar amount (in thousands oI dollars) being demanded or indicate other demand such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section oI the JS 44 is used to reIerence related pending cases, iI any. II there are related pending cases, insert the docket numbers
and the corresponding judge names Ior such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Case 3:12-cv-01034-MJR-SCW Document 2-1 Filed 09/27/12 Page 2 of 2 Page ID #17
EXHIBIT A
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EXHIBIT B

Case 3:12-cv-01034-MJR-SCW Document 2-2 Filed 09/27/12 Page 18 of 36 Page ID #35
WorldClient
From:
To:
Date:
Subject:
steve.raymond@effinghamdailynews.com III
rae. printz@effinghamdailynews.com
04/20/201201 :07 PM
Re: Re:
Page 1 of2
The meeting went about like I expected. They think its a good idea but don't know if
it will work for them. Really concerned about not hitting Altamont and Dieterich.
Thursday was also a concern.
They know you will be joining me and may mention it to you.
We had a good discussion. Newlin said he wasn't surprised I'd leave the EON .
Steve
Sent from my Verizon Wireless BlackBerry
From: Rae Printz <rae.printz@effinghamdailynews.com>
Date: Fri, 20 Apr 2012 10:50:20 -0500
To: <steve.raymond@effinghamdailynews.com>
ReplyTo: rae. printz@effinghamdailynews.com
Subject: Re: Re:
I've made the corrections and sent the ad over to Norma but Tama says I will regret
that in the worst way. Hopefully there will not be many changes since this is in
Monday's paper.
I'm interested in how the meeting goes.
On Apr 20,2012, at 10:14 AM, steve. rayrnond@effinghamdailynews. com wrote:
Rae:
I think the ad looks fine. Will Norma have a chance to proof it? I'd like for her to if at all possible.
I'm just ready to walk into Martin's. Going to meet with Newlin and Donnie.
Steve
Sent from my Verizon Wireless BlackBerry
From: Rae Printz <rae. printz@effinghamdailynews . com>
Date: Fri, 20 Apr 201208:59:41 -0500
To: Steve Raymond<publisher@effinghamdailynews. com>
ReplyTo: rae.printz@effinghamdailynews.com
Subject:
Steve,
I just sent you the first proof of the Rotary Ad .. .. . hope it is what you wanted. There are some
corrections to make but I didn't want to send any of those until I got your reaction to it. We had a
bad day here yesterday not being able to enter any ads into the system between maybe 10 am and
4: 30 pm so Mt. Vernon is really backed up today. Let me know!
Rae Printz
http://webmail.nhimidwest.comlW or IdClient. dll ?Session=CHSJKAS& View= Message&N... 7/26/2012
Case 3:12-cv-01034-MJR-SCW Document 2-2 Filed 09/27/12 Page 19 of 36 Page ID #36
WorldClient
Effingham Daily News
201 N. Banker
Effingham, IL 62401
217-347-7151 ext. 145
rae.print z @effinghamdail vnews.com
Rae Printz
Effingham Daily News
201 N. Banker
Effingham, IL 62401
217-347-7151 ext. 145
rae.printz@effinghamdailynews.com

Page 2 of2
x .
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EXHIBIT C
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EXHIBIT D
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EXHIBIT E
Case 3:12-cv-01034-MJR-SCW Document 2-2 Filed 09/27/12 Page 28 of 36 Page ID #45
W orldClient

)< .
From:
To:
Date:
steve.raymond@effinghamdailynews.com m
rae. printz@effinghamdailynews.com
04/20/2012 02:39 PM
Subject: Re: Re:
I'm confident we can put together a package for them to consider.
Sent from my Verizon Wireless BlackBerry
From: Rae Printz <rae.printz@effinghamdailynews.com>
Date: Fri, 20 Apr 201213:24:51 -0500
To: <steve.raymond@effinghamdailynews.com>
ReplyTo: rae.printz@effinghamdailynews.com
Subject: Re: Re:
Page 1 of2
I gave you the wrong price .... it's currently $770 for the Daily and $440 for the
weekly. I can't think that their" new money" ( which Donnie hates passionately
investment in those 2 communities would be greater than that. That would leave us
with only the Thursday obstacle which could be turned into a positive, I think.
On Apr 20,2012, at 1 :08 PM, steve. raymond@effinghamdailynews. com wrote:
I am thinking the same thing. Once I get a printing price I can then put a package together.
Steve
Sent from my Verizon Wireless BlackBerry
From: Rae Printz <rae. printz@effinghamdailynews. com>
Date: Fri, 20 Apr 2012 13:00:23 -0500
To: Steve Raymond<publisher@effinghamdailynews. com>
ReplyTo:rae.printz@effinghamdailynews.com
Subject:
I understand the concerns regarding Altamont and Dieterich but I was thinking that since our current
cost of inserting ( $672 for Daily & $440 for Weekly) is rather high it might take the sting out of the
cost of inserting into those small communities.
Rae Printz
Effingham Daily News
201 N. Banker
Effingham, IL 62401
217-347-7151 ext. 145
rae.printz@effinghamdailynews.com
Rae Printz .
Effingham Daily News
201 N. Banker
Effingham, IL 62401
217-347-7151 ext. 145
rae.printz@effinghamdailynews.com
http://webmail.nhimidwest.com/WorldClient.dll ?Session=CHSJKAS& View=Message&N... 7/26/2012
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WorldClient Page 2 of2
712612012
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EXHIBIT F
Case 3:12-cv-01034-MJR-SCW Document 2-2 Filed 09/27/12 Page 31 of 36 Page ID #48
WorldClient
From:
To:
Date:
Subject:
Thanks.
steve.raymond@effinghamdailynews.com m
jane. herring@effinghamdailynews.com
05/16/201204:48 PM
Re: Martin's IGA
Sent from my Verizon Wireless BlackBerry
From: "Jane Herring" <jane.herring@effinghamdailynews.com>
Date: Wed, 16 May 2012 15:31:43 -0500
To: <steve.raymond@effinghamdailynews.com>
ReplyTo: jane.herring@effinghamdailynews.com

Yes.
Each week we charge EDN insert - $770; Wkly insert $440; commercial print $1970
Jane
From: Steve Raymond [mailto:steve.raymond@effinghamdailynews.com]
Sent: Wednesday, May 16, 2012 3:28 PM
To: jane.herring@effinghamdailynews.com
Subject: Martin's IGA
Jane:
Page 1 of 1
What do we charge Martin's IGA each week to have their flyer printed? What do we charge them for the insert in
the EDN? The Weekly Advertiser? Please let me know. Thanks.
Steve
http;/lwebmail.nhimidwest.comlWorldClient.dll ?Session=CHSJKAS& View= Message&N... 7/26/2012
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EXHIBIT G
Case 3:12-cv-01034-MJR-SCW Document 2-2 Filed 09/27/12 Page 33 of 36 Page ID #50
CORPORATI ON FI LE DETAI L REPORT
Entity Name
EFFINGHAM &
TEUTOPOLIS NEWS
REPORT, INC.
File Number 68365783
Status ACTIVE
Entity Type CORPORATION Type of Corp DOMESTIC BCA
Incorporation Date
(Domestic)
06/14/2012 State ILLINOIS
Agent Name STEPHEN R RAYMOND Agent Change Date 06/14/2012
Agent Street
Address
2001 MAGNOLIA ST President Name & Address
Agent City EFFINGHAM Secretary Name & Address
Agent Zip 62401 Duration Date PERPETUAL
Annual Report Filing
Date
00/00/0000 For Year
Return to the Search Screen

(One Certificate per Transaction)
Purchase Certificate of Good Standing

BACK TO CYBERDRIVEILLINOIS.COM HOME PAGE
Page 1 of 1 CORP/LLC - File Detail Report
9/26/2012 http://www.ilsos.gov/corporatellc/CorporateLlcController
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EXHIBIT H
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Under Construction.
Website coming soon.
1901 S Fourth Street, Suite 223
Effingham, IL 62401
Phone: (217) 342-5583
Page 1 of 1
9/26/2012 http://www.etnewsreport.com/
Case 3:12-cv-01034-MJR-SCW Document 2-2 Filed 09/27/12 Page 36 of 36 Page ID #53