Professional Documents
Culture Documents
IN
Civil Division
JENNIFER ROYLE
Plaintiff
Case
No
24C11001571
NASTY
1570
SPORTS LLC
Defendants
et
al
HEARING REQUESTED
DEFENDANT WNSTS MOTION TO COMPEL PLAINTIFF TO RESPOND TO WRITTEN DISCOVERY AND FOR AN AWARD OF COSTS AND INCORPORATED MEMORANDUM OF LAW
Defendant
WSNT
Sports
Media
LLC
WNST
or
Defendants
pursuant
Maryland
Rules
1-341
and 2-432
request
that
the
limiting Plaintiff
Jennifer
Royles
defamation
and
false
light
action
to
the
18
statements
she
listed
in
her
second
supplemental
interrogatory
responses
compelling
Plaintiff
to
provide
responding
to
certain
interrogatories
and
document
requests
to
which
she
has
failed
to
appropriately
respond
specifically requiring
Plaintiff
to
provide
complete access
to
all
of her
accounts
and
requiring
Plaintiff
to
furnish
privilege
documents
she
claims
protected
under
the
Maryland
journalists
shield
law
WNST
not
further
requests
that
Plaintiff
be prohibited
from entering
into
evidence
any documents
produced
and grant an
award
of costs
including
reasonable
attorneys
fees
as
sanctions
for
this
motion
WNST
requests
hearing
pursuant
to Rule
2-311f
In support
of this Motion
WNST
states
INTRODUCTION
For nearly three months Plaintiff
public personality
in
Baltimore sports
talk
radio has
failed
to
comply
with
written
discovery
served
May
the
2011
on
the
basic
issues
of
her
defamation
and
false
light
portrayal
claims
Despite
Courts
narrowing
of
this
case
in
granting
Defendants
partial
motion
to
dismiss
Plaintiffs
answers
to
basic
discovery
requests
are
evasive
and
incomplete
under
Rule
2-432
She
repeatedly
has
refused
to
provide
definitive
list
as
requested
of the
statements
she
claims
defamed
or
cast her
in
false
light
Indeed
her responses
evasive
with
each communication
between
counsel
and
their
current
positionif
actionable
statements
will
glean
this
in
the Plaintiffs
deposition
See July
18 2011
Letter
final
paragraph
attached
as
Exhibit
1is
utterly
untenable
Obviously
as with
any
other
litigation
the
Defendants
are
entitled
through
written
discovery
and before
her
deposition
to
notice
of the precise
wrongs
the
Plaintiff
alleges
In addition
despite
centering
her
claims
that
Defendants intimated
that
is
involved
in
personal sexual
and/or
inappropriate
relationships
with
professional
athletes
Complaint
athlete
21b
than
she
flatly
refuses
to
furnish
information
about
any
relationship
with
an
other
and one
New
York Yankee
Further
she
has
claimed
privilege
on her communications
with
athletes
under the
guise
of Marylands
reporters
shield
law
yet she
has
failed
to
provide
sort
Moreover
Plaintiff
refuses
to
produce
what
she
arbitrarily
has
deemed
her
personal
account
with
which
she
On
June
2001
the
Honorable
of private
dismissed
infliction light
Counts
of
II
and
IV
which
with
sounded
in
invasion
of
privacy claims
In
by publication
remaining
are for
and
intentional
distress
prejudice
The
only
defamation
for false
Count
light
and not
false
invasion the
Count III
meets the standard
false for
Maryland Pox
claim
may
stand
unless
claim
defamation
claim can
Crowley
only
Broad
Co
851
Supp
asserts
700 704
provably
Md
false
1994
As
in
defamation
claim
light
be maintained
106
where
plaintiff
statement
of fact
Bagwell
Peninsula
Regional
Med
CIr
Md
665
A.2d
297 318
1995
maintains
contact
with
nearly
1000
friends
including
number
of professional
athletes
Finally
Ms
Royle refuses
to
identify
individuals
denominated
in
her responses
as
colleagues
have
members
information
of the
public
professional
athletes
and
fans
all
of
whom
she
claims
As
Plaintiff
has
not
complied
under Maryland
law and
WNST
to
has
not
received
the
notice
to
which
it
is
entitled
this
Court should
limit
her
claims
the
18
statements
in
her
latest
discovery
response
require
that
she
furnish
all
additional
information
sought
in
this
motion
within
10
days
order
her
to
provide
access
to
her
entire
accounts
attorneys
fees
Procedural
Background
Leading
up
to this
Motion
Plaintiff
filed
four-count
Complaint
on March
10
2011
claiming
defamation
false
light
invasion
of privacy
by publication
of private facts
and intentional
infliction
of emotional
distress
Dkt No
The
The
entire
Complaint
arose
of words
allegedly
written
or spoken
by the
Defendants
Complaint
generally
alluded
to
12
written
or
oral
statements
While
characterizing
them
however
the
Complaint
did
not
set
forth
the
words
dates
format
or
audience
for
any statement
On May
claims
2011
Defendants
moved
to
dismiss
the
private
facts
and emotional
distress
and answered
the
defamation
and
false
light
claims
At the
same
time
WNST
served
written
discovery
seeking
inter
alia
specific
list
of the statements
details
about
the timing
and
circumstances
under
which
each
allegedly
explanation
of
why
each
was
Defendants
his
also
requested
letter
Plaintiffs
complete
Twitter
that
history
are will
and
all
records
Plaintiffs
counsel
to
in
July
18 2011
upon
Ex.l
they
being not
at
promptly
this
and compel
will
be
provided
the of the
Defendants those
receipt
On
that
the Defendants
to
time
move
the
to
Plaintiffs to
production provide
items
Defendants
reserve
right
supplement
this
Motion should
Plaintiff
fail
timely
documents
allegedly
false
This
discovery
obviously
is
necessary
to
furnish
the Defendants
with
notice
and
to
enable
them
to
prepare
their
defense
At
June
hearing
Judge
Cannon
granted
Defendants
motion
dismissing
the
private
facts
and emotional
distress
counts
with prejudice
and without
leave
to
amend
See June
22
2011
Order
attached
as Exhibit
During
that
hearing Judge
Cannon
explicitly
stated
that
Ms
Royle
had not
plead
facts
sufficient
to
state
claims
under
either
of those
torts
copy
of the
transcript
of the June
2011 hearing
is
attached
as Exhibit
The
ruling
left
Plaintiff
with just
two
causes
of action
defamation
and
false
light
portrayal
Although
Judge
Cannon
in
half
when
Plaintiff
first
responded
to
the written
discovery
on June
and
she
attached
an Exhibit
to
her interrogatory
responses
that
listed
26 separate
statements
which
she
alleged
to
be
false
and defamatory
See
Ms
Royles
Initial
Responses
to
WNSTs
had no
Interrogatories
attached
as
Exhibit
number
of
these
statements
however
factual
content
at
all
and appear
related
to
the
emotional
distress
claim
that
the
Court dismissed
Moreover
number of
statements
were
not
even
attributed
to
the Defendants
at all
See ii
On
deficiencies
June
pursuant
to
Rule 2-432
Defendants
sent
Ms
Royle
letter
outlining
these
copy
of Defendants
June
letter
is
attached
as Exhibit
Counsel
for
the
parties
met by telephone
on June
counsel
reiterated
that
Plaintiff
needed
to
specify
which
statements
allegedly
the Defendants
that
she claims
or
portrayed
her
in
false
light
Following
that
call
Plaintiffagain
instead
of conforming
her
claim
to
the
causes
of action
she
has
pleadedexpanded
it
by serving
notice
of
more
than
50
independent
statements
many of which
again
contained
no
facts
and allegedly
were
made by
people
other
than
the
Defendants
See
Exhibit
to
Plaintiffs
Responses
to
WNSTs
Interrogatories
attached
as Exhibit
On
June
27 2011
to
Defendants
wrote two
letters
to
Plaintiffs
counsel
One
noted
her
continuing
failure
furnish
required
discovery
responses
copy
of this
letter
is
attached
as
Exhibit
The
other provided
notice
that
by continuing
to
mushroom
the
number of
allegedly
actionable
statements
Plaintiff
has
brought
herself within
the prohibitions
of Rule 1-341
as
she
is
forcing
Defendants
to
litigate
frivolous
claims
by
refusing
to
reasonably
conform
to
the
contours
of her defamation
and
false
light
counts
copy
of
this letter
is
attached
as
Exhibit
In response
Ms
Royle
again
supplemented
her
interrogatory
responses
The
text
of her
response
to
Interrogatory
No
33
listed
18
allegedly
false
statements
However
she
attached
another
Exhibit
listing
separate
statements
copy
of
Ms
Royles
Supplemental
Interrogatory
Responses
Exhibit
are attached
as Exhibit
In
July
15
telephone
conference
Defendants
counsel
sought
to
clarify
that
the
18
statements
in
the text
of
the
interrogatory
responses
constituted
all
statements
that
the
Plaintiff
has
placed
at
issue in the
lawsuit
Plaintiffs counsel
seemingly
provided
that
reassurance
However
following
written
confirmation
by Defendants
counsel
Exhibit
10
Plaintiffs counsel
instead
responded by
letter
Exhibit
stating
that
the Plaintiff
would
not provide
the complete
list
of her statements
until
her
deposition
there
are additional
actionable
statements
will
glean
this
in
Plaintiffs
deposition
Id emphasis
supplied
Thus
have asked
as to the
alleged
statements
around which
this
entire
lawsuit
is
framed
Defendants
on
at
least
five
separate
occasions
for
an appropriately
narrowed
list
and
Plaintiff
repeatedly
has
expanded
contracted
and
expanded
her
response
The
Courts
intervention
therefore
is
unfortunately
necessary
to
assist
the
parties
in
defining
the
contours
of Plaintiffs
claim
As
to
the
remaining discovery
issues
the
parties
are
at
impasse despite
Defendants
efforts
to
resolve
them
without inconvenience
to
the Court
ARGUMENT
Ms
Obligations
Responding
Under
WNSTs
Discovery
in an
Evasive
or Incomplete
Manner
Rule 2-43
court
may compel
are
production
of discovery
if
the information
sought
is
discoverable
and
the
partys
responses
evasive
or
incomplete
which
under
the
rule
constitutes
failure
to
provide
discovery
Md
Rule 2-432
Marylands
discovery
rules
are
broad
and
comprehensive
in
scope
Baltimore
Transit
Co
Mezzanotti
227
Md
13
1961
and promote
liberal
disclosures
in
the
interest
of advancing
the
sound
and expeditious
administration
of justice
Id
E.I
du Pont de
Nemours
Co
Forma-Pack
Inc
is
351
Md
396 405
1998 Among
possible
the fundamental
of the rules
to
eliminate
as
far
as
the necessity
of any party
to
litigation
going
to
trial
in
confused or muddled
state
of
mind
concerning
the
facts
that
gave
rise
to
the
litigation
Mezzanotti
227
Md
at
13
sought
to
clarify
confused
or
muddled
discovery
responses
to
clarify
the
facts
that
gave
rise to
the litigation
The
responses
provided
however
continue
to
obfuscate
and magnify
the basic
issues
Ms
Royles Defamation
Provided
and
False
Light
18 Statements
in the
Latest
Discovery
Response
Following service
of the Complaint
vaguely
describing
12
allegedly
injurious
statements
WNST
statement
issued
the
following
simple
interrogatory
asking
Plaintiff
to
list
each
and
every
made by
WNST
she
alleges
was
false
INTERROGATORY NO.4
Interrogatory
identify
For each
reason
statement
identified
it
your
false
answer
to
each
the
that
on
which
claim
was
when made
persons
identified
known
you who
substance
have
knowledge persons of
such
state the
of that
knowledge
Royles
in
Due
interrogatory incorporated
to
the see
extreme
length
Ms
many
responses
to
this
please
Ms
Royles
responses
Exhibits
and
which
are
by reference
hereto
for
Ms
half of her
Royle
answered
this
question
the
first
time
shortly after
lawsuit
As noted
and throughout
the
successive
responses
outlined
in
this
motion
Plaintiff
appeared
to
have limited
and
false
light
claims
to
universe
of approximately
18
statements
Response
to
Interrogatory
No
but
she
also included
document
labeled
Supplemental
Exhibit
See
Ex
That document
contains
alleged
statements
that
to
either
remaining
tort
claim
such
as
Glenn
that
Ms
Royles
description
of an Orioles
she
analogizes
character
to
on the Jersey
Shore because
later that
Ex
Supp
Exhibit
000001
and are
Royle on
Exhibit
morning
now
calling
Ms
Royle Jen
Midol Ex
blogs that as
Supp
wont
000002
Royle
at
Drew
that
Forrester thinks
fans
get to
meet Jen
Exhibit
This
appears
to
be
joke
she
of herself
star
Ex
is
Supp
just
000006
Drew
at
Forrester tweets
that
Jen
Royle
tourist
in
Baltimore Ex
Supp
Exhibit
000009
initial
Despite
assurances
that
Plaintiff
had confined
herself
to
the
18
statements
in
her
the text
of her interrogatory
response
Plaintiffs
counsel
now
takes
the
position
that
the Plaintiff
will
not
disclose her
entire
factual
basis until
her
deposition
is
taken
there
are additional
actionable
statements
this
in
Royles
deposition
See
Ex
To
leave
the
basic
facts
of her
claim
confused
and muddled
until
her
deposition
violates
Plaintiffs
discovery
obligations
under
Rule 2-421
Moreover
this
conduct
is
additionally
sanctionable
states
In any
civil
action
if
the
court finds
that
the
faith
in
maintaining
justification
any
proceeding
the
to
was
in
bad
party
may
require
to
or the the
both
of them
pay
party
of the
proceeding
reasonable
expenses
it
including
reasonable
attorneys
party in opposing
Rule
1-341
can
be
an effective
tool
for
the
deterrence
of unnecessary
or
abusive
litigation
it
to
award
party
costs
including
reasonable
attorneys
fees
if
it
finds the
been maintaining
or defending
any proceeding
in
bad
faith
or without
substantial
justification
Zdravkovich
Bell Atlantic-Tricon
Leasing
323
Md
144
200
592 A.2d
498
503
1991
is
see
also Seney
Seney 97
Md App
544
631
A.2d
139
1993
bad
the
Rules
purpose
to
deter unnecessary
and abusive
litigation.
Under
the
Rule
faith
exists
when
party
litigates
solely
with
the
intent
to
cause
harassment
or
unreasonable
delay
Barnes
Rosenthal
Toyota
Inc
126
Md App
litigants
97
727 A.2d
431
435
1999
debatable
And
lack
of substantial
justification
exists
when
position
is
not
fairly
and not
within
the
realm of legitimate
advocacy
Id
Conduct
the plaintiffs
lacks
substantial
justification
when
there
is
no basis
in
law and/or
in fact
to
support
claim
against
the
defendants
who
seek
fees
and
costs Johnson
Baker
84
Md App
521
581
A.2d
48
52
1990
Here
Plaintiff
skirted
all
debateand
the
law of
this
caseby
her
in
pressing
claims
for
numerous
statements
that
defamatory
nor
cast
false
light
Then
just
when
it
appeared
the
Plaintiff
was
willing
to
scale
her
lawsuit
back
to
reasonable
proportions
counsel
advised
that
her
claims
will
remain
undefined
until
her
deposition
when know
Defendants
can
glean
her
intent
Just as
breach of contract
defendant
is
entitled
to
what
contract
he
allegedly
breached
and
an
insurance
company
like
is
entitled
to
know
what
personal
injury
it
is
defending
defamation
defendant
WNST
to
is
entitled
to
know
with
specificity
the
allegedly
actionable
words
it
will
be called on
defend
WNST
therefore
asked
the
Court
to
enter an order
under Rules
2-432 and
1-34
limiting Plaintiffs
claims
to
the
18
statements
listed
in
her supplemental
response
to
Interrogatory
No
WNST
with
this
further requests
an
award
of
its
costs
including
reasonable
attorneys
fee
in
connection
request
Ms
Royle
Must
Fully
Answer that
Discovery
is
Relevant
to
Her
Allegation sexual
that
WNST Made
inappropriate
Statements
and/or
relationships
with
professional
Complaint
21b
WNST Ms
that Royles Complaint
is
entitled
to
discovery
related
to
the
absolute
defense of truth
includes
the
sweeping
allegation
that
Defendants made
statements
Royle
is
involved
in
personal
sexual
and/or
inappropriate
relationships
with
professional
athletes
Complaint
21b
Accordingly
WNST
facts
issued
requests
to
Ms
Royle
to
better understand
the nature
of her claim
and
to
discover
relevant to
its
defense
INTERROGATORY NO 21
athletes
Identify
all
former
in
or current
professional
with
whom
you
have
ever
been
inclined
personal
relationship but
staff not or the
sexual
limited
relationship
to
and/or
relationship or
including
the
any
current
in
or former
member
Hockey
of
coaching
management
National
Major
League
the
National
Football
League
Basketball
the
National
the of
League
the
Soccer
Arena
any
League
affiliate
PGA Tour
such
the
ATP
or any
NASCAR
professional
minor
leagues
minor
For
dates
league i.e
identified of any
AAA
baseball
and
American
each
person
name
address
such
relationship
contains of several single
Plaintiff
objects
to
this
Interrogatory issues
as
it
interrogatories interrogatory
each involving
in
separate
and
limits
distinct
contravention
of the
imposed by Rule
seeks
to
of the Maryland
to
The
interrogatory calculated
is
information lead
to
immaterial discovery
the
instant
and
is
not
reasonably
the
of admissible
evidence
Further
the
Interrogatory
overly
broad
vague
and
ambiguous
The
interrogatory
calls
for
speculation
and
conjecture
as
it
does
not
define
the
phrase
inclined
in
Defendants and
Brian
Supplemental Response
relationships responses
to
have
made
false
about
with these
Nick
Swisher
Matusz
Plaintiff
limits fails to
and
athletes
Furthermore have
as the not
Interrogatory
the phrase
to
inclined
the
in4
supplemented grounds
these or
that
the
this
Interrogatory Interrogatory
define
for
phrase
Plaintiff
object
on the
calls
speculation
Plaintiff
and conjecture
not
Without
waiving
objections
and subject
with
thereto
either
the
has
had
any
inappropriate
as
and
sexual
in
relationships
Plaintiffs
Nick
those words
are defined
Supplemental
Answer
Interrogatory
No 20
Identify
all
INTERROGATORY NO 22
with
former or sexual
or professional
relations of any
athletes
whom
you have
but not
nature
of the
including coaching
limited
any
in
current
or former
player
the
or
member
staff or the
management
Basketball
Major League
the the
Baseball National
National
Football
League
National
the
Association
Hockey
the
League Soccer
Arena
Football
League
of
PGA Tour
leagues
ATP
any
NASCAR
professional
any
minor
i.e
league
affiliate
such
the
or
minor For
dates
league
AAA
baseball
and
American
each
person
identified of any
state
their full
name
address
such relationship
several single
Plaintiff
objects
to
this
Interrogatory
distinct
as
it
contains
interrogatories interrogatory
each involving
in
separate of the
and
issues
of
contravention
limits
imposed
seeks
to
by Rule 2-421
of the Maryland
to
The
interrogatory calculated
is
information lead
to
immaterial discovery
the instant
and
is
not
reasonably
the
of admissible
evidence
overly
Supplemental
Response
See
Plaintiffs Supplemental
Interrogatory
No 21 Ms
New
Royles answers are evasive and incomplete
as she
arbitrarily limits
her responses
to
Swisher
and Baltimore
Oriole
Brian
Matusz
refusing
to
answer
the
interrogatories
with
regard
to
athlete
Ms
Royle cannot
escape
the
basic
allegation
of her
own
Complaintthat
she
stands
wrongly
accused
of having
personal
sexual
Ms
Royle
objects
in
to
the typographical
error inclined
in
in
Interrogatory
No
20
ignoring
to
the obvious
intended
meaning
apparent
Interrogatory not
relieve
No
21
which
indicates
inclined
in was
intended
be
involved
in
Ms
Royles objection
does
obligations
10
and/or
inappropriate
relationships
with
professional
athletes.5
Ms
Royle
cannot
pick
and
choose
among
the athletes
about
whom
law
she
will
answer
these questions
Indeed
under
Maryland
her
relationships
with
athlete
is
relevant
and
discoverable
whatever
the
nature
and
whoever
they
are
In
Maryland
statement
is
not
considered
false
unless
it
would
have
different
effect
from
that
which
the
pleaded
truth
would have
produced
Batson
Shfflett
325
Md
684
725
1992
citing
and Related
Problems
138
1980
footnote
omitted
Thus any
and
to
relationship
she
has
athlete
is
relevant
to
the
truth
or falsity
of her allegations
her
reputation
in
the
professional
athletic
community
Because
these
broad allegations
are at
issue
Defendants
are
permitted
to
discover
information
relevant
to
the
allegations
of her
Complaint
and the
Plaintiff
should be compelled
to
as
asked
Ms
Royle
Marylands
Law and
21
providing
Consistent
with
WNSTs
Interrogatory
Nos
and
22
regarding
the
nature
of
Ms
Royles
relationships
with
professional
athletes
WNST
with
also
served
number
of document
requests
intending
to
discover
the
universe
of
athletes
whom
Ms
to
Royle had
relationship
of any
kind
See
Ms
Royles
First
and
Supplemental
Responses
WNSTs
asserts
Requests
for
Production
attached
as Composite
Exhibit
11
However
Plaintiff
broadly
the
Maryland
Reporters
Shield
Law
Md
Code COURTS
and
to
JUDICIAL
PROC
9-112
flatly
refusing
to
produce
single
responsive
document
failing
provide
privilege
log
Notably
while
Plaintiff
attempts
to
limit
her responses
to
Interrogatory
Nos
and
21
and 22
to
Mr
Swisher and
Mr
Matusz
she
provides
no communications
between
her
either
of these
gentlemen
of
At the appropriate
juncture
Defendants
will
establish
that
they
made
no such
statement
Ill
brevity
WNST
which
includes
the
requests
at
issue
followed
by
Ms
to
Royles
generic
boilerplate
objection
she included
in
the exact
same
form responding
each request
at
issue
DOCUMENT
any current purposes current
the of this
REQUEST NO
professional
All
documents
and
to
communications
the
is
with
athlete
from 2000
includes
the
present
For
the
professional
in
athlete
but
or former
National
League
National
the
Basketball
Association
National
the of the
Hockey
League
the
Soccer
Arena
any
Football league
League
affiliate
PGA Tour
such leagues
ATP
or any
Tour
minor
NASCAR
professional
minor
and
All
League
with
in
documents
of the
communications
any
member
the All
coaching
staff
or management
present
DOCUMENT REQUEST NO 11
any player
documents
coaching
and
staff
communications
or
with
in
member
of the
management
the
baseball
organization
All
to the
DOCUMENT REQUEST NO 12
any
or former baseball
and
player
member
of the
coaching
to
staff or management
the
organization
from 2000
All
the
present
DOCUMENT
any current Baltimore
Orioles
REQUEST NO 13
player
baseball
documents
coaching
and
staff
communications
or
with
in
or former
member
of the
management
the
organization
All
from 2000
to the
DOCUMENT
any current Baltimore
REQUEST NO 14
player
football
documents
coaching
and
staff
or former
member
of the
Ravens
organization
from 2010
to the
present
Response
voluminous Request evidence
information as
Plaintiff
objects
to
the foregoing or
Request
as
it
as
it
is
overly
broad
to
and
ambiguous
to
requires
Plaintiff
are
unrelated
the
to
allegations lead
to
of the
Complaint
worded
which
is
not
reasonably objects
calculated
to
the
discovery seeks
State
of admissible disclosure of
Further
the
is
Plaintiff
the
extent
this
Request
protected
by the See
First
Amendment
of the United
Constitution
9-1
Shield
Law
or
Md
Code
297
Md
165465
be
A.2d 413
Ann 1983
the
Courts
Plaintiff in
Judicial
Proc
to
12
this
objects custody
the
extent of
Request
documents which
information obtained
already
the
or
control
the
less
Defendants
may
less
by
Defendants
more
conveniently
Supplemental
exist
Response
the
To
the
extent
non-privileged or control
responsive
documents
and are
in
immediate
possession
custody
been produced
herewith
First despite
her
supplemental
response
the
Plaintiff
has
produced
communications
12
between
her and
professional
athlete
Second
despite
her
assertion of reporte
privilege
Plaintiff has
refused
to
provide
states
privilege
the
identities
of the
individuals
with
whom
she
communicated
the
date
of
such
communications
and
the
nature
of those
communications
In
Maryland
the
burden
of
establishing
the
existence
of privilege
rests
with
the
party
seeking
to
assert
it
El
du Pont de
Nemours
Co
Forma-Pacl
Inc
351
Md
100
396
415
1998
441
the
see
also
Maxima
Corp
6933
Arlington
Development
Ltd
Partnership
Md.App
with
456
1994 Ms
Royles
general
assertion
of privilege
without
more
fails to
comply
requirement
of Rule 2-422
that
party
fully
state
with
specificity
to
produce
requested
document
In
considering
similarly general
assertions
of attorney-client
privilege
the
Court
of
Special
Appeals
has
held
that
blanket
assertion
is
generally
extremely
disfavored
and
ordinarily
the
privilege
must
be raised
as
to
each
record
so
that
the
court
can
rule
with
specificity
Maximma
failure to
100
Md
App.at
457
Indeed
Maryland
that
partys
provide
privilege
log
may
constitute
forfeiture
of any
claims
of
privilege
Victor
Stanley
Inc
Creative
Pipe
Md
2008
to
Maryland
courts
have
not
specifically
addressed
the
reporters
privilege in responding
civil
written
discovery
However
in
assessing
the
invocation
of the
reporters
privilege
in
depositions
that
such
to
the Rules
Guidelines
See Forensic
Advisors
Inc
Matrixx
initiatives
Inc
170
Md App
520 536-37
2006
the
In particular
Discovery
Guideline
5c
identify
provides
that
where
claim of privilege
is
asserted
party invoking
the privilege
must
with
specificity
the
nature
of the privilege
together
with
the type
of document
the
general
subject
matter
the
date
of the
document
and
such
other
information
as
is
sufficient
to
identify
the
13
document
for
subpoena
where
appropriate
the
any
other
recipient
of the
document
and
where
not
apparent
the
relationship
of the
author
to
each other
Discovery
Guideline
5c
fails to
In this
case
Plaintiffs
boilerplate
assertion
of reporters
privilege
provide
this
particularized
justification
for asserting
privilege
See Mezu
Morgan
State
University
269
Md 2010
challenge
With
no privilege log
WNST
directly
has
been denied
the opportunity
to
meaningful
concerning
information
relevant to
her claims
and
WNSTs
requested
defenses
For these
reasons
this
Court
should
compel
Plaintiff
to
produce
the
documents
or
alternatively
to
produce
privilege
log
containing
the
information
called
for
in
Discovery
Guideline
5c
Royle Must Provide
Ms
WNST
inspection
WNST
provide
Account
requested
that
Ms
Royle
access
to
all
accounts
for
and copying
DOCUMENT
mutually
REQUEST NO 33
place
Produce
for access
inspection
to all
agreeable
and
Response
burdensome evidence
in
Plaintiff
to
this
Request
to
as
to
is
it
is
overly discovery
broad
unduly
and
is
not
calculated information
lead
the not
of admissible
the allegations
which
relevant to
the
Complaint
Supplemental
are in
Response
To
the
extent or
non-privileged controL
the
immediate herewith
possession
custody
of the
produced
Instead
Plaintiff
reinterprets
this
straightforward
request
by
applying
an
arbitrary
distinction
She produced
complete copy
of her professional
fan
page
on Facebook
but flatly
refuses
to
provide
any information
regarding
her
personal Facebook
page
has
See
Ex
Despite
the
fact
that
her
counsel
has
represented
that
Plaintiffs
personal page
been download9d
14
that
information
is
being
withheld
without
any
cognizable
objection
Plaintiffs
arbitrary
distinction between
professional
activities
is
misplaced
brief view
of
Ms
Royles
publicly
available
personal
profile
demonstrates
that
she
maintains
friendships
on Facebook
with
professional
athletes
such
as
Major
League
Baseball
players
Robinson
Cano
Nick
Swisher
and
Wil
Nieves
and
National
Football
League
players
Ben
Grubbs
and Brendon
Ayanbadejo
current
listing
of
Ms
Royles
friends
on her personal
profile
is
attached
as Exhibit
12
Thus
to
the
extent
that
she
has
used
to
communicate
with
these
athletes
and
any others
who
might have
privacy
settings
hiding
them
from
view
is
as
well
as photos
status
updates
or other
information
evidences
such relationships
WNST
any
entitled
to
discover
that
information
Moreover
if
Ms
Royle has
communicated
with
of her
colleagues
or
friends
on
her
personal
she
page
about
her
work
as
journalist
or
other
issues
relevant
to
her
lawsuit
has
no
greater
right
to
protect
such
communications
because
they
were
made
through
her
personal
page
rather
than
of communication
Additionally
Plaintiff
alleges
that
Defendants
have
damaged
her
professional
and
personal
reputation
among members of
See
the
public
professional
athletes
she
covers
Plaintiffs
Response
to
Interrogatory
No
10
at
Exs
and
To
this
end
the communications
with
and about
Plaintiff
on Facebook
of her
friends deems
are highly
relevant
to
her
reputation
and credibility
in
the
community
even
if
she
the
site
personal
Finally
the communications
Plaintiff
makes
are
all
highly
relevant to
her frame of
to
the emotional
damages
she
claims
Complaint
between
35
and
55
and
For
all
these
reasons
Ms
is
Royles
arbitrary
distinction
her
personal
professional
pages
inappropriate
This
Court should
therefore
compel
Ms
Royle
15
to
comply
WNST
an opportunity
to
inspect
she
deems
to
be her personal
page
or alternatively
order
Ms
Royle
to
produce
in
electronic
form
all
documents
she
has
already
obtained
from Facebook
Ms
All Individuals
Referenced
In Her Discovery
Responses
In
number
of her discovery
responses
Plaintiff
vaguely
refers
to
numerous
individuals
with
knowledge
of information
relevant
to
the
issues
raised
by
her
Complaint
but
fails
to
identify
them
by
name
has
Plaintiff
also refers
to
documents
and communications
with
identified
individuals
but
refused
to
produce those
documents
Plaintiffs
responses
therefore
remain
evasive
vague
and incomplete
INTERROGATORY NO
other
Identify
all
communications
to the
between
persons
including
in
but
not
limited
to
Defendants
relating
statements
date
identified
your answer
by
Interrogatory
No
was
For each
authored the the
identify
of the
the
communication communication
whom
the
communication
all
or
made
whom
those or
who
in
received
communication of the
whether
the
communication
orally
writing
substance
communication
the
communication
Response
interrogatories interrogatory
in
Plaintiff
objects
to
this
Interrogatory
distinct
as
it
contains
several single
each
involving
separate
and
limits
issues
of
contravention
of the
imposed
as
by Rule 2-421
is
Maryland vague
the
it
The
interrogatory
as
worded
overly does
to
broad
define
and
as unduly
burdensome
the Interrogatory
to this
not the
term
seeks
communications
information doctrine
Further by
Plaintiff
objects
Interrogatory
extent
protected
the
attorney-client
privilege
to
and the
attorney
work-product
prepared
Without
to
waiving
the
and
subject
said
objections
Plaintiff
correspondence
Plaintiff
Baltimore Ravens
with colleagues
organization
on or about
at
August and
14 2010
exchanged
telephone the
emails
and management on
is
MASN
CBS
13
as
well
as
conversations
beginning
approximately
January reserves
2011
regarding
to
Defendants
or
conduct
As
discovery
to this
ongoing
Plaintiff
the right
supplement and
amend
her response
Interrogatory
Supplemental
objections control
to
Response
the
Without
waiving
is
and
the
subject
to
Plaintiffs
original
in
immediate
custody
possession
or
of the
copies
provided
to
See
PRDR
000070-000071
staff
000076-000078 The
included
to
recipients Patrick
the
Raven
Public
RelationsMedia exchanged
Chad
Steele
Byrne
Plaintiff
emails
16
with
Jim Cuddihy
Plaintiff
of
MASN
Bader
the
for
on or about
January
13 2011
regarding
the
Defendants on or
to
conduct
about
emailed Greg
refers
Greg
Orioles
Organization
directly
6/11/2011
Plaintiff to
responded Defendants
the
with
an email and
Ms
Royle
Plaintiffs
Original
Supplemental
Responses
Requests
Production
of Documents
and Exhibit
Here
her
supplemental
response
fails
to
provide
documents
and supporting
information
about the
e-mails with
colleagues
and management
at
MASN Ms
and
CBS
as
well
as telephone
conversations.
.regarding
Defendants
conduct
Although
Royles
counsel
advised
that
the
only
correspondence with
MASN py
was one
to
has
been provided
Ms
her
Royle
failed
to
provide
correspondence
or
information
regarding
conversations
with
colleagues
at
CBS
including
the
names
of the individuals
with
whom
she
spoke
or the
of those communications
INTERROGATORY NO 10
have
in
Describe
as
in
detail
any
to
suffered
to
your reputation
to the
proximate
result
of the for
identified those
Interrogatory proximate
of
No
loss
the
reasons
loss
your
all
identify
persons
who
state
you
the
knowledge
such
and
for
each
person
identified
substance
of that
persons knowledge
contains several single
Response
interrogatories interrogatory
Plaintiff
objects
to
this
Interrogatory
distinct
as
it
each involving
in
separate
and
limits
issues
of
contravention
of the
imposed
as
it
by Rule 2-421
is
Maryland vague
all
Rules
of Civil Procedure
as
The
Interrogatory as
worded
for
overly
to
broad
identify
and
ambiguous
with
well
as unduly
burdensome
facts
seeks
to
Plaintiff in
personal
knowledge of
their
of the existence
relevant
the issues
the case
to
even
if
no knowledge Defendants
called into
that
Without
Plaintiffs
waiving
and subject
actions
have
caused
professional
and personal
be
question Defendants
caused
members of
the public
believe or
she
is
bitch
by these
result
liar
and has
with Nick
she
to
Swisher and/
covers has
Brian
Matusz
Plaintiffs credibility
false
athletes
been
to
endangered
others as
assertions
and
she
been
forced
explain
herself
of the Defendants
false
statements
Similarly
here
despite
multiple
requests
Ms
Royle
refuses
to
identify
the
individuals
into
question
her
professional
and personal
reputation
the
members
is
of the
public
who
believe
that
WNSTs
actions
caused them
to
believe
that
Ms
Royle
bitch
or
liar
or
whom
believe
that
she
has
had
sexual
relationship
with
Nick
Swisher
and/or
Brian
Matusz
Ms
Royle has
also failed
to
identify the
professional
athletes
she
covers
with
whom
her
credibility
has
been endangered
others who
Ms
Royle
contends
that
she
to
explain
herself
to
in detail
INTERROGATORY NO 12
identified in
Describe
any
those as
response
of the
to
the
preceding
interrogatories in
by
you
proximate
the
result for
statements
belief that
all
identified the
reasons loss
your
any
such
identify
persons
who you
knowledge
persons
of such
loss
and
for each
person
identified
state the
substance
of that
knowledge
Response
Plaintiff
refeis
to
and
incorporates
her
Answers
to
Interrogatories
Nos
10
and 11
First to
Supplemental
Response
10
Plaintiff
refers
to
Interrogatories
in
Nos
to
and
11
Plaintiff
refers for
the
documents
Plaintiff
attached reserves
response
to
Defendants
her
Request
Production
of Documents
the right
supplement
Answer
Second
supported
Supplemental by the
Response comments
Plaintiff
has
suffered
reputational held
damages by fans
has
as
negative
tweets
and
general
opinions
who
been
have heard
called
and believe
the statements
Plaintiff
slut
bitch
who
have heard
or read the
Defendants
statements Exhibit
See Responses
to
Requests
for
Production
of Documents
and
Supplemental
Finally
here
Ms
Royle
fails
to
identify
the
fans
who
have
heard
and
believe
the
statements
identified
herein
and
fans
who
have
statements
who
allegedly
called
Ms
Royle
slut bitch
Interrogatory
or
other
insulting
names
refusal
Similar
to
the
deficiencies
with
her answers to
Nos
and 10
Ms
Royles
to
specifically
identify
these individuals
creates
virtually
universe
of witnesses
from
which
she
might
call
upon
to
testify
18
II
In Addition Within 10
to Ordering
Ms
WNSTs
Discovery
Requests Attorneys
Days
This
Court
Award Costs
Including
Reasonable
Fees
Ms
litigation
Royles
continued
reftisal
to
provide
documents
and information
at
the
core
of this
has
set
back
WNSTs
made
evaluation
of her claims
of
its
defense
As
detailed
above
WNST
the
numerous
efforts
to
amicably
resolve
these
discovery
disputes
inconveniencing
Court
Since
WNST
with
has
been forced
to
seek
redress
from
this
Court
Ms
Royles
continued
failure
to
comply
her
discovery
obligations
inhibits
the
trial
courts
inherent
authority
to
manage
its
affairs
and achieve
an orderly
and expeditious
disposition
of
Gebrehiwot
143
Md App
courts
716 728
2002
to
After
granting
motion
to
compel
determine
appropriate
sanctions
River
Ins
Co
Mayor 391
396-97
City
Council of Baltimore
343
Md
trial
34
47
1996
Braxton
Faber
91
Md App
1992
In imposing
sanctions
courts
have considered
or substantial
the timing
of the ultimate
disclosure
the
reason
if
any
for
the
violation
the
degree
of
prejudice
to
the
parties
respectively
offering
and
opposing
the
evidence
and
whether
any
resulting prejudice
might be cured
by
postponement
and
if
so
the
overall
desirability
of
continuance
Hossainkhail
143
Md App
at
725-26
see
also Sindler
Litman 166
Md
App
90 124
2005
Here
Plaintiffs failures
of discovery
are substantial
and deliberate
She
has
stubbornly
refused
to
define
the basic
contours
of her defamation
and
false
light
claims
She
flatly
reftises
to
page based on an
arbitrary
distinction that
it
is
personal
She dodges
question
directed
to
her
claim
that
Defendants
accused
her
of
inappropriate
or
sexual
relationships
with professional
athletes
by denying
relationship
with
two
professional
baseball
19
players
but
conspicuously
naming
no
others
She
improperly
invokes
privilege
over
an
enormous
subset
of relevant
information
evidencing
her relationship
with professional
athletes
And
she
refuses
to
name numerous
witnesses
apparently
with knowledge
of the facts
giving
rise
to
her claims
These
failures
are not
accidental
and
WNST
to
continues
to
be prejudiced
by them
Accordingly
sanction
of some
kind
is
necessary
prevent
Plaintiff
from
continuing
to
frustrate
WNSTs
To
begin
defense
of her lawsuit
with
pursuant
to
Rule
2-43
the
Court
should
issue
an order
prohibiting
Plaintiff
from introducing
into
evidence
any materials
she
has
not provided
for
Defendants
Rule
2-433a2
See
also Attorney
Grievance
Commn
of Maryland
James
385
Md
637
659-
612005exclusion
of evidence
as
sanction
was warranted
where
partys
failure
to
provide
timely
discovery
failed
to
give
opposing
party
adequate
time
to
review
and
prepare
37
Storetrax.com
Inc
Gurland 168
Md
App
50
the
89-90
895
2006
affd
397
Md
to
2007
is
the
damage
in
withholding
evidence
despite
remedy
available
in
motion
compel
unfair
surprise
Ms
Royles
failure
to
provide
documents
and
information
material
to
her
claims
including
the
identity
of the
fans
and professional
athletes
whom
she
alleges have
information
substantiating
her
reputational
damage
deprives
WNST
43-44
of
its
ability
to
reasonably
mount
Mendelson 138
Md App
29
2001
costs
Irrespective
of the
relief
it
WNST
to
and fees
If
the
Court finds
failure
of discovery
it
to pay
the
moving
party
the
reasonable
expenses
incurred
in
obtaining
the
order
including
attorneys
fees unless
the
court
finds
that
the
opposition
to
the
motion
was
substantially
justified
or
that
other
circumstances
make
an award
of expenses
unjust 2-433
evasive
or incomplete
answer
is
to
be
treated as
failure
to
The
imposition
of sanctions
for
failure
to
20
comply
by awarding
2-433c
633
is
within
the sound
discretion
of the
trial
Aude
126
Md.App 639
Her
1999
responses
to
Here
Plaintiffs
responses
were
plainly
inappropriate
deficient
interrogatories
even
as
supplemented
as well
as her evasive
document
production
and improper
invocation
of privilege
clearly violate
requiring
the disclosure
of relevant
information
so
that
the
eventual
resolution
of
lawsuit
is
based
on
ftll
and
accurate
understanding
of the
true
facts
Plaintiffs
continuing
acts
of delay
amount
to
an
open
and
obvious
attempt
to
impede
and
obstruct
the
Defendants
right
to
discovery
matters
that
go
directly
to
As such
WNST
respectfully
requests
that
this
Court issue
an order
to
reimburse
WNST
for
its
attorneys
in
preparing
this
motion
CONCLUSION
For these reasons
WNST
requests
its
Motion
and Order
That
Plaintiffs
Complaint
is
limited
to
the
18
allegedly
false
statements
in
her
supplemental
response
to
Interrogatory
No
the
Plaintiff shall
That
within
10
days
answer
Interrogatory
Nos
21
and
22
regarding
her
involvement
in
personal
sexual
and/or
inappropriate
relationships
with
professional
athletes
That
within
10
days
the
Plaintiff
shall
produce
all
documents
responsive
to
Document
Request
Nos
10 11 12 13
and 14
or alternatively
if
she
asserts
the
reporters
privilege
that
she
produce
with
Discovery
Guideline
5c
and copying
her
That within
10
days
the
Plaintiff
shall
produce
for
inspection
personal
Facebook
account
or
alternatively
produce
her
complete
downloaded
personal
account
21
That within
10
days
the
Plaintiff
shall
identify
the
unnamed
individuals
within
her responses
to
Interrogatory
Nos
is
10
and 12
That
Plaintiff
prohibited
from introducing
into
evidence
any materials
she
has
not provided
to
the Defendants
within
the
10
days
provided
in
That the
Plaintiff
to
pay
the
Defendants
reasonable
attorneys
fees
and costs
in
responding
to
her
discovery
deficiencies
and
any
other
relief
the
Court
deems
just
and
necessary
2-43
for
faith
attempts
to
discuss
with
Ms
are
Royles
counsel
the
resolution
of the disputes
described
herein and
certify
that
the parties
unable
to
reach
agreement
on the
disputed
issues
The
parties
conducted
two
telephone
conferences
seeking
to
resolve
the issues
raised by Defendants
in this
Motion
on the afternoon
of
June
15 2011
for
approximately 30 minutes
and again
on the
afternoon
of July
15 2011
for
have
exchanged
the
correspondence
submitted
with
this
Motion
Defendants were
unable
to
resolve
their
disputes
Rule 2-311
Defendants
hereby request
that
this
Court hold
hearing
on
this
Motion
22
Dated
July
26
2011
Respectfully
Submitted
HOLLAND
Charles
KNIGHT LLP
Tobin
Drew
Shenkman
Ave N.W
20006
Suite 100
D.C
Fax
Phone
charles.tobin@hklaw.com
drew.shenkman@hklaw.com
Counsel for Defendants
hereby
certify
that
on
this
26th
copy
of the foregoing
was
sent
via
First
Class
postage
prepaid
to
HODES
Brian
PESSIN
KATZ
Esq Road
P.A
Goodman
Alexandra
901
Moylan Esq
Suite 400
Towson
21204-2600
4c1/4v92c
23
EXHIBIT
July
18 2011
Letter
H1PIK
HODES
90
OULANEY VALLEY
PESSIN
at
KATZ P.A
Low
ICAMBRIDGE
ROAD TOWSON
Attorneys
COLUMBIA
00 MD
2204
ISELAIR
WWW.HPKLCGAL.COM
Brian
WRITERS
Goodman
NUMBER 410 938-8705
E-MAIL
DIRECT DIAL
WRITERS
DIRECT
bgoodmanhpkIegaIcom
July
18
2011
VIA E-MAIL
charIes.tobinQihMaw.com
AND REGULAR
Charles Holland
U.S
Tobin
Esquire
Knight LLP
Avenue
20006
N.W
Ste
100
D.C
Re
Jennifer
Royle
NASTY
1570 Sports
LLC
et
al
Case
No
24-C-11001571
Dear
Mr
Tobin
send this
letter
pursuant
to
the issues
on July
5th
2011
As
possession
an
initial
have
provided your
all
responsive
documents
in
our
immediate
custody
answering
will the
discovery
to for
requests
The
Plaintiffs
discovery
responses
continue deadline
be
supplemented
in this
receipt
of
additional
responsive
documents
given
discovery
February
21
2012
Facebook.com
Plaintiff are
Moreover
every and/or individual
the
Plaintiffs
personal the
account
information
inclined
and
the
names of
sexual the
as
athlete
with
whom
has
ever been
to
to
in
personal
inappropriate
in
relationship
with
not
relevant relate
and
have
no bearing
upon
allegations
the
Complaint
Plaintiffs
allegations
her professional
reputation
To
production
the the
the
extent
that
the
information information
sought
in
Interrogatories collected
No
as
21
part
and of
22
the
is
related
to role
and/or
as
seeks
the
of
confidential
source
is
Plaintiffs
member
of of
media
such
information
confidential
under
court
9-112
of
the
Courts
the
and
Judicial
Proceedings of
confidential that
Annotated
Code
of by
information
is
collected to
cannot
compel
clear
admission convincing
her sources
without
and
evidence
it
relevant
significant
issue
HODES
Charles
PESSIN
KATZ P.A
Tobin
Esquire
July 18 2011
Page
journalist The
the
allegations
regarding
relationships
with
are
limited
solely
to
Defendants
and
defamatory
statements
concerning
Matusz
of
the
Baltimore See
Orioles
organization
Nick
Swisher
of the
New
York
Yankees
whether with
organization personal
Supplemental inappropriate
Answer
intimate
irrelevant
to
Interrogatory
or
No 21
Thus any
that
relationship
sexual
if
romantic
to
the Plaintiff
has/had
other athletes
any
is
wholly
whether
relationship
with
Mr Matusz
and
Mr
Swisher
With respect
control sent
to
medical
records
all
custody or
of the Plaintiff
We
for the
have followed
records
up with
Dr Liebman
health
and have
executed
authorizations
of the following
care providers
Dr
1205
Samuel Liebman
Associated
PA
21
Lutherville
Maryland 21093
William
Internal
Goldiner Medicine
lvii
120
Sister Pierre
Drive
207
Towson
Charles
Maryland 21204
Paulino
D.O
Group
West
Side Medical
PC
314 W.l4thStreet
New York
Diagnostic
NY
10014
Associates
230 West
New York
Chelsea
NY
10011-5325
Otolaryngology
William Portnoy
160
West
18tb
Street
New York
Upon
provide
receipt
NY
10011
of additional
Plaintiff
responsive
will
records
hereunto we
will
certainly
copies
However
not execute
of the Defendants
256936-1
HODES
Charles July
PESSIN
KATZ P.A
Tobin
2011
Esquire
18
Page
Further
to
produce despite
the
Defendants Facebook.com
request for such
account
information In
on the grounds
faith
the Plaintiffs
documents
that
good
attempt
to
obtain
responsive with
documents
we
request
the
Defendants
supplement including
their
discovery limited
responses
but
not
to the
It is
account information any professional Facebook.com and place page as well as WNST.net organization page inexplicable
that
you
refuse
to
produce
Defendant
Aparicio
personal
entitled related
Facebook.com
to to Plaintiffs
account personal
in
information
on the grounds
account and
of relevancy
and claim
contains
you
are
Facebook.com
the Complaint
information
is
which
for
no information
the
allegations
which
used
solely
non-professional
purposes
The
searching days
records
by Defendants
information
twitter are
are
incomplete simply
It
appears tweets
in
that
rather
than
for
you
produced
from
the
certain
surrounding
blog
and
there
posts
previously tweets
to that
identified
Plaintiffs to
discovery
responses
We
believe
additional
would be responsive
blogs
relating to
the
Plaintiffs discovery
requests
Furthermore
we
continue
discover
the Plaintiff
to
operated
failed
and maintained
to
by Defendant
indicates that
WNST
you
have responsive
and
readily to
accessible perform
you
produce
databases
This
for
failed
detailed
the requested
documents
and information
Given the
related to
foregoing
and
attached
hereto
Plaintiff
has
produced
to
the
all
information
her profesional
Facebook.com
account
fan page
as
look well
forward
as the
professional
Facebook.com
in
information
relevant
posts requested
the Plaintiffs
discovery
responses
Finally
have
received
your
that
letter
to
me
of July
15 2011
to
It
is
incorrect
What we
constitutes will to
discussed
Supplemental
are additional
Answer
Interrogatory statements
No
you
statements
are
actionable
If there
actionable
deposition
Plaintiffs
Answer
1-341
is
No
accordingly
Your
Maryland
Rule
inappropriate
and misplaced
Sincerely
Brian
Goodman
BSG/mjc cc
Ms
Jennifer
Royle
Alexandra
Moylan
Esquire
256936-1
EXHIBIT
June 2011 Order
JENNIFER
ROYE
INTETE CIRCUIT
Plaintiff
COURT
vs
NASTY 1570
LLC
et
al
Defendant
.s
Case
No
24.-C11001571
ORDER
Upon
docket no
consideration
of the Defendants
Motion
to Dismiss
Counts
II
and IV
17
stated
on the record
in
open court
it
is
this
day of
June 2011 by
the Circuit
City hereby
ORDERED
that the
Motion
is
GRANTED
and
it
is
further
ORDERED
amend
that Counts
II
and IV are
rPUE In
Cfl
DISMISSED
with prejudice
with no leave
to
EXHIBIT
June 2011 Hearing Transcript
IN FOR JENNIFER
THE
CIRCUIT
BALTIMORE
CITY
COURT MARYLAND
ROYLE
Plaintiff
CASE
NO
24C-ll--001571
NASTY
1570
SPORTS Defendant
LLC
_____________________________________________________/
OFFICIAL
TRANSCRIPT
OF
PROCEEDINGS
Motion
to
Dismiss
Baltimore
City Maryland
2011
CANNON
Judge
APPEARANCES
For
the
Plaintiff
ALEXANDRA
MS
For the
MOYLAN
ESQUIRE
Defendant
DREW
MR MR
SHENKHAN
ESQUIRE
and
CHARLES
TOBIN ESQUIRE
Audio
Transcribed
By
Erika
Newton
TABLE
OF
CONTENTS
COMPANY
Virginia
HUNT REPORTING
Court Reporting
Serving
3376
CALL OF THE
CASE
M3
PLAINTIFF
WITNESS None DIRECT CROSS REDIRECT RECROSS
offered
offered
EXHIBITS
EVIDENCE
offered
DEFENSE
EXHIBITS None
IN
EVIDENCE
offered
MOTION by by
ARGUMENTS
MR MS
TOBIN MOYLAN
M5
M12 M21
JUDGES RULING
PROCEEDINGS
HUNT REPORTING
Court Reporting
Serving
COMPANY
Virginia
3376
111652
THE Jennifer Royle
a.m
This
is the
COURT
Okay
1570
case
of
vs
Nasty
Sports
identify
LLC
Case
No
24-
C-ll-001571
Counsel
please Good
themselves
MS MOYLAN
Alexandra Moylan THE
this on
morning
of
Your
Honor
behalf Was
Ms
Royle
entered
in
COURT
your appearance
case
MS MOYLAN
19th
THE
It
was
It
was
entered
on
May
COURT
As
in
paid
--
how
much
is
the
fee
now MS
not quite MOYLiAN believe
it was $10 or
$15
Im
sure
THE
COURT
No
it was It
more
to
than
that how
if
you
is
entered
it
your
appearance
use
be
$15
much
now MR
SHENKMAN
Im
Its
not
the
sure
same
MS MOYLAN
Pessin THE personal
firm
Its Hodes
COURT
is
Its not
entered
the
firm
appearance
Whats Moylan
is
your
MS MOYLAN
THE Did you
Alexandra
COURT
Your appearance
not
entered
personally
appearance
3376
MS
THE
MOYLjAN
Yes When
It
Your
Honor
COURT
MS MOYLAN
THE
was did
done
on May
19th
COURT
MOYL2AN
Who
it
did
MS
THE
it
down here
to do
COURT
somebody
it MS MOYLAN
THE show
that it
believe
So
it was
mailed
any evidence
to
COURT
actually
you
dont have
got
here sorry
did not bring
MS MOYLAN
copy
of
Im
Okay
it
THE
COURT time
Im
sorry
Give
me your
name
one
last
MS MOYLAN
O-Y-L--A-N THE
Sure
Its
Alexandra
Moylan
COURT
SHENKMAN
of
Okay
Good
And
Counsel
Your
MR
Shenkman appearing
morning
Honor
me
Drew
on behalf
or
--
and
is
with
appearing
Is
vice
Chuck
Tobin
entered
THE
COURT
Mr Tobins
appearance
dont
see
it
SHENKMAN
MR
THE
Tobin
COURT
SHENEMAN
Huh
Tobin
We filed Motion
for
MR
3376
Pro
Hac
THE
COURT
SHENKMAN
Oh
Mr
Yes
Charles
Tobin
MR
THE going
to
COURT
Yes
okay yes
Okay
Whos
be
MR TOBIN
permission
THE Everybody read
COURT
Be
seated
have That
just be
seated You
minute
Okay each
everything
your
may have
ten minutes
includes
rebuttal
time
Thank
MR
Tobin here
on on
TOBIN
of the is
you
your
Honor
Charles
behalf
--
Defendants
Your reduced
Honor were
to
what
essentially
in the
Motion have
to
single
count
Complaint
We have
We
count
answered Discovery
to the
false
count
proceeding
in
on written
presently
to
entry
of
dismissal
of
an
invasion
So the as
privacy
by publication
for
private
facts
is
only
to
argument
today
our motion
of
Count
intentional
infliction
emotional
distress
Your
are the
owners
and
COMPANY
Virginia
Serving
3376
employees here
in
of
sports
radio
station
The
an
a.m station
Jennifer
the
the Baltimore
is
market
radio
Plaintiff
with
is
Royle
station against against
also by
sports
broadcaster
So this
f.m
owned rival
CBS WJZ
--
radio
lawsuit
sports
filed by
rival
sportscaster
rival The
sportscaster
for
grounds
as
our motion
today
is
are
that
emotional
distress
highly her
for
disfavored
by virtue light but elements pleading
of she
She has
pursue and
claim false
the
defamation
qualifications
of
meet
for
prima
on the
face
her complaint
of
claim for
intentional
infliction
emotional
distress
We they
go to
have
three grounds
for
our argument
of the
and
of
the
three separate
elements
she
cause
is all
action
Number
one
that
the
conduct alleges
alleges
oral
communications
she
defamatory
And under
the
second law
claim
the
case
if
Court
oral
in
statements
even
if
defamatory
even
allegedly
taste
than
in
even
actionable
absent And
that
like cases
personal
is set the
relationship
those
bar
Second
all
3376
the
severity
of
harm
required
has
to
the
tort in
for
Maryland
the
because
Maryland
such
threshold and
tort
disabling
in the facts
emotional
distress
She
that
complaint
sufficient
to
there were
of
no
support
the
allegation
intentionality
is
cause
severe that
As is to
emotional required
the
distress which
for the
third
element
tort
conduct we
first
one
the
alleged
fully
We
rely on answer
four
the
precedent
cases
that
believe
issue
decided
Batson by
the
phonetic
Court Penn
of
vs
Shiflett Ratner
phonetic phonetic
Cecil
Appeals
vs
Miller and by
Hollow
phonetic
Special
vs
County
decided
the
Court of relying
Appeals
And
finally
federal BET
the the the
case
on Maryland
law
Thompson
vs
In
Soundstage
first three cases Court was emotional
Batson
with
tort
Miller and
the of
Penn
Hollow
under
or
action
ability
defamatory
that
offensive
words
her
complaint Things
things
the the that
were
said about
of of
job
her
job
Things
were
her resume
to
demeaning
of
women
were how
said she
here
all
those
connections
HUNT REPORTING
Court Serving Reporting
COMPANY
Virginia
3376
performs
her
job
In
each
of
the
the
first
mentioned
Appeals and
Batson
the
Penn
Hollow
Court of mere
Appeals
if
mere words
to
alone
with
insults
to
woman
in
all
apologies
Court we
that
words
if
our reply
brief
Even
words
are
really
nasty
not
qualify
for
very
high
threshold
are that
in her in her
complaint
through
this
24
and
brief
that
makes
clear
entire
claim is
that
form light
is
defamation we
false
claims
basis alone
believe
dismissal
warranted
Moving distress
to the
severity
to
of
the
emotional
that
claim
She has
of
plead
and
prove caused
the severe
infliction interfered
the
stress
such
It
with
rendered
from conducting
the
life
Clearly
on the as to
complaint
still performs
on the
radio
the
is
Still conducts
herself
the
radio
that
But
complaint that
she
itself
seen
allegation health
has
mental
counselor
3376
medications
today
on the In
for
the
purposes
of
pleadings
Harris
in
case
vs
Jones
adopted
which the
is
where light
that
the
Court of
In the
Appeals case
of of
1977
false
tort
in
Polder Appeals
phonetic
revisited
in the
Bowen
the
1993
the
Court
in
tort
April of
2001
Special
Court
which out
Ladding arose
out to
phonetic
of this
vs
St Josephs
case
All
courthouse
on Motion said
Allison
someone
courts
that
went
to
mental enough
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health meet
for
counselor
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took
the
medication threshold
are not
test
severity
formulating
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emotional
distress
And
just to
give
you
an that
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in
Folder
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people
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people
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tort
cases words
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to
basis of
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or
psychiatrist
series
visits
to
psychiatrist
3376
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has
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time having
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relations
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distress
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qualify
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in public has
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were
dealing each
with
sportscasters
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things on
about
other
places profile
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on Twitter There
is
Facebook
that
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public
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to
relationship lower
the
cause high
this
bar below
level
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to the
has
set
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allege Ford intent with
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set
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intent
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is we
intended
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allege
And they say
be
3376
that
we
therefore
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inference
to
and
its axiomatic
emotional
that
must have
intended
cause
the in
severe law
distress
the
in Maryland it
says
says
In the
Minicki
case
the
particular
Plaintiff You
the
has ask
to
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particulars
inference
to
cant
acts
court
rely on
So
from very
and
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plead boiler
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what
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language
theyve done
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kind
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overlay about
any
case
involving like
airwaves
public
figure
Ms
Royle
sports
case
of of
First
the
amendment
vs
Hustler
magazine
depiction parody
rights
inaudible
Magazines
of
Reverend
an
advertisement
Court
advertisement
to
Supreme
establish
First
of
Amendment
actual
for
malice
free
The
highest under
standard First
culpability
in the
the
Amendment their
United
to
States
plead
the
would
facts
require
to
them in
that
and
show
we her as
knew
statements distress
were and
emotional
severe
her
debilitating
emotional
distress
the
that
would
disable
life under
standard
3376
So
Honor
today
for
three
for
independent
of
reasons
anything
the just the facts
Your else
were
not
dismissal conceded
other than We
weve
by
claimed
written
are moving on
the
forward
Weve
and
exchanged false
light
Discovery we
do the
defamation
for all
believe Court
three independent
the
that
should
infliction
claim as
does
the
bar that
Maryland
requires
you
Your
Honor
MS
Counsel
to
is
MOYLjAN that
for
Your we
the
correct
Motion
light publication
the
and here
as
facts
is
However
Your Honor
the
reason
were
determine whether
the
Defendants
which
is
conduct
the the
pled
truth
thereof
to
on
Motion
Dismiss yet
rises to
extreme
outrageousness
the
sufficient
motion
Court of
is
law
Appeals
the
of
Maryland would be
have
said the by
here
whether person
in
conduct
tolerated
todays
at one of
society
cooler while
being then
water
the
work that
Defendants neck
in
then
tweed
they would up
for
snapped when
your you
half
because
you
stood
yourself
3376
were
being
sniffed
at
the
water
cooler and
in
environment
you
as
Having and
reporter sniff
scratch that
at to the
sticker
in
--
the
complaint
Im
sorry
through type
in of the
forward and
is
-- Paragraph
25
This
type of
thats alleged
harassment
statute
that
criminal
the notion
tolerable
Defendants
grocery
conduct
or
had
if
been
conducted
at
cashier
at
store
even about
it was
firm saying
this
female
competitors
to
firm in
an effort
to
belittle them
to
person
not
lives
stifle
in
the
competition
cause
in
suffer
only
professional
life but
their personal
by spreading Who
this that
falsities about
has
that
persons private
with
life
when
person then
had
to
sexual
go
person
as
has
and
to
these
same
people with
in on
shes been
internet
alleged on
the
sexual
to
relations colleagues
the press
radio
other
the
boxes
in professional
work
settings
because
The there is no
intention that
issue by washing
doubt
its alleging
HUNT REPORTING
Court Reporting
Serving
COMPANY
Virginia
3376
complaint February
that
the Defendant
began more
to
do
this
on that the
24
2010
Royle
Its been
has been
than
year
Plaintiff
harassment
this
Ms
by
from constant
of quit
sole purpose
to
campaign
harass
her
to
to
her
on
job
to
competition
just that
havoc
her reputation
to
shes worked
hard
build
And the statements been have been
to
in
local
media
its
in
circulated
the
and
the
Defendants have
out
are
particular
of
position these
they do
various there
that for
outlets
placing
to
the public
believe
in
and
prove
the public
as
has
That
fact
taken
statements
true
she
slept with
professional
athletes
explain
at the
that
shes had
and that
to
herself very
at
work
was
for
least
it It to
reckless
disregard extreme
the
fact
that
Ms
and
of
Royle
emotional and
it
distress
was meant
malicious sports
drive
the
local
media
The physical caused
the
manifestations
of
the
Defendants
conduct distress
that
Plaintiff severe
pled
Shes
to
forced seek
to
treatment
continuing
medical
treatment
3376
Shes
changed
habits
to
to
take
prescription distress
of the
deal with
emotional intentional
of act
that
inflicted by
to
Defendants
endure
this
campaign that
abuse
are
And
not mere insults that
argue
Your
Honor
these
or as to the
tribulations
of
should
somebody
part
an everyday
life
Its
to
acceptable express as
engage
competitor
motion
Defendants However
what
the
says
shes professionally
the
inapt
Defendant
crossed
into
happened
here
Launching that
against
another
allegations taken
as
alleged
in her
relationships
to
her personal
relationships
cause
her
to
damage
endure
No professional
this as
woman everyday
part
of
life
And
argue
been
Your
to
statements
would
have
made
THE
Im
good
deciding
Im
the
deciding
statements
were
Thats not
inaudible
the
intentional would
or
infliction
been
to
Im
not
deciding
statements whether
have
male
Im
not
deciding
not
somebody
should
tolerate
them
Im
deciding
Thats
COMPANY
and Virginia
Serving
4868 3376
not
to
what be
the
law
is
So
thats not
--
and law
just
want
really clear
the
is
MS
THE good
MOYLZAN
COURT
not
Its
not
or
whether not
or
or
not
it was
idea
Its
whether
somebody
should
tolerate
it
not
they were
fair
not
they upset
her it
Its not
not
about you
people
believed
Its
job
not
not
know
it messed of
up her
Thats
intentional
of
infliction
emotional
distress
is
None
those
things
None
Your need
MS MOYLAN
THE any of
understand
So
Honor
to
COURT
then
dont
consider
that
MS MOYLAN
as
would
argue
that
the
statements
alleged
that
in
the
complaint acted
are extreme
and
outrageous
to
and
the
Defendant emotional
intentionally would
cause
Ms
Royle
severe
also submit
another
is
issue for by
the Court
that
todays society
of
altered
the
social
media by
have used
the
variety
outlets
the
that
--
Defendants
impute
with
of
purpose
to
make
statements
with
--
purpose
imputing
Ms
Royles professional
THE
In is
COURT
That
is not
emotional you
tell
distress
me
if
other
the
words
its
that
actually
is
when
that
intent
not
severe
emotional
distress
3376
Lets assume
what
the
-- in it
other had
it
words
other
affect
on
had
other
In the
people other
thinking
that
her
in
Im
the
worst
to
continue
tort
might
that
another
because
think
of
cant
intentional you
so
infliction
emotional
distress because
So if
think you
that
think
it
can
that
that
might be
another
of
emotional
Im
and
Im
evil
though recover
of
these but
me and
that
not
intentional
infliction
emotional
distress
MS MOYLAN
disfavored
--
And
understand
this
is
COURT
--
All
in
Im
other
saying
is
that
the
elements not
the
elements
And
for
MS MOYLAN
while conduct was they were
of
would
--
argue would
that argue
the
acts
the it
intended
that
the Defendant
to
had
purpose suffer
and
to
cause
Ms
suffer
emotional
distress
tell
COURT
And
me
cases
where
theyve
HUNT REPORTING
Court Reporting
Serving
COMPANY
Virginia
-800-950-DEPO
3376
given
facts
of
what
is
severe
emotional
distress
MS MOYLAN
THE severe where
Yes Whats
Your
Honor
character want
the of
COURT
factual
emotional
the
distress
and
dont
the
case That
therapist
slept with
counselor
doesnt work
MS
one
the of the
MOYLAN
In
Moniodis
--
Cook
64
Md
all
App
of
Plaintiffs
first and
of
foremost
distress The
intentional
to -- were
emotional
the
claims
went
to
jury
Court of
--
Appeals
said THE
that
these were
Plaintiffs
the
did meet
COURT
tr1hat
facts
were accused
--
MS MOYLAN
THE
The
COURT
No
the
severe
emotional
distress
MS MOYLAN
nervous condition that and
suffered found
--
existing
testimony
she was
at
home
inaudible
her
of
hands crying
her emotional
of
there was
significant
deterioration take
state
She was
for
required to
greater and
amount
prescriptions
her nervous
to
condition
relatives
had
THE
to
help
her
In
tend other
her household
she
chores
not
COURT
of
words
could
function
as
part
daily And
living
MS MOYLAN
THE
if Your Honor
is
inclined
get to
COURT
No
Its
not
me
dont
3376
make
it
up
not the
in
really charge
dont
of the
am not world
--
--
was not
going even
on to the
to in
say
Im
of of
but
Im
charge Court
it
Court of
Special
Im
get
not
even chance
this
Special
Appeals
deciding what
dont
whether
make
up
and
Im
what
not
or not
behavior
was
appropriate
to
but you
youve alleged
doesnt come
close
just
described
And
MS MOYLAN
to to
if Your Honor
is
inclined
for
grant
the Motion
to
Dismiss we would
ask
leave
amend
THE
COURT
you had
No
Why
would
to
you
have
to
amend
If
anything
say you
would
said
to
it
No
for
No
what
On what
basis would
there be
amend
MS MOYLAN
saying that
it fails to
To
provide
--
if of
is
state
cause
THE
COURT
going
to
What happen We
the
are you
going
amend
it
to
say
Whats
thats going
include and
change
it
MS MOYLAN
in the
would
the --
allegations
affidavit THE
of
statements
it
COURT
But
to
what
of
You
example
distress You
and have
youve described
to if she
nothing
show
the
that
comes was
And
again
Im
not
deciding that
behavior not
appropriate
Im
not
deciding
was
harmed
HUNT REPORTING
Court Reporting
Serving
COMPANY
Virginia
3376
is
before
me right
now
The
question
of
not
theres intentional
has
infliction
distress
been
adequately
to just
pled
it
dont
it
do
dont
the
get
chance
make
up it
Ive
got
what
law
says
Thank And assume and
dont
Your
to
see
MS MOYLAN
THE Court
in
you
want
Honor
very
COURT
be
clear
the
The
ruling can
that
everything that
everything
in
her
true
is
Including
to
fact
actually
the
argued
out at of
intent
and
that so
it was
intention
her
business
she
wouldnt be doing
that that
work
just
all
the
mean
facts
assuming support
and
Im
just
--
lets
matter grant and
assume
inference
cannot
No
what
still
to
theres no way
Dismiss
this
Court
the
mean
with
most obvious
of the
some
is it
other
elements severe
elements
theres not
really is
infliction
--
mean
different infliction
tort
of
It
not
damages
emotional
distress
damages
it means
is
thats
is
pled
saying Court
there
is
emotional
the is
deciding
more and
in
Thats
substantially
think
the example
given
by
Plaintiffs
Counsel
terms
3376
of
the
case
somebody that
was be
really disabled
--
from
fact that
functioning someone
of to is
would
mean
of
the
continue
to go
with
all
daily seek
and
seek
if
professional another
tort
and
that could
at
proved
another
the it
recover come
damages close
do to
under
all
intentional
all
infliction
will
just
doesnt
it
to
So
for
those
reasons
grant the
Motions
both
Counts
Okay
Thank
you
Thank
MR TOBIN
you
Your
Honor
Pause
MR
TOBIN
Your
Honor we submitted
an
order
THE order
COURT
Well Whether
do do
my own
--
see your
inaudible MR TOBIN
Okay thank
Thank Thank
you
Your And
MS MOYLAN
THE Counsel
you you
Honor
appreciate
COURT
argument
MS MOYLAN MR
TOBIN
Thank Thank
you
you
Your
Honor
very
much
concluded
at
Whereupon
the proceeding
114221
a.m
0-766-HUNT
-800-950-DEPO
4868 3376
EXHIBIT
Plaintiffs Initial Interrogatories
Responses to and
First
WNSTs
Exhibit
JENNIFER ROYLE
Plaintiff
IN
THE
COURT
FOR
NASTY
1570
SPORTS LLC
et
BALTIMORE
CASE
CITY
Defendants
NO 24-C-11001571
PLAINTIFF JENNIFER
WNST SPORTS MEDIA LLCS FIRST SET OF INTERROGATORIES AND REQUESTS FOR ADMISSION
Royle
Plaintiff
Brian
Goodman
and
Moylan
to her
of
Hodes
of
Pessin
P.A
one
answers
the
Interrogatories
propounded
follows
by
WNST
SPORTS
MEDIA LLC
of Defendants
and
states
as
INTRODUCTION
The information supplied knowledge
of the in these
Answers
the
is
not based
of the
solely
upon
the
executing
party
knowledge
partys
agents
representatives
and attorneys
unless
and sentence
does
structure
is
that
of the
attorneys exact
who
in fact
of
not purport
to be the
language
the
party
The
with
the
Interrogatories
have
been
plain
interpreted
and usage
answered and
to
in the
accordance
extent not the
Federal
Rules
of
Procedure
the
English
specifically
challenged
by objection
definitions
and
instructions
included
with
Interrogatories
GENERAL
Plaintiff
OBJECTIONS
to the extent the
objects
to
each
and
every
Interrogatory
Interrogatory of litigation
seeks
or materials
prepared
information or communications
or
protected
by the attorney-client
information opinions
communications impressions
protected conclusions
by
or
the
accountant-client of the
privilege Plaintiffs
mental
legal theories
attorneys
accountants
or other
representatives
Plaintiff
does
not waive
any
protections
or
privileges of any
these
Interrogatories
Inadvertent
of
production
privilege or
or exposure
such
not constitute
objection to the
waiver
such
of
admissibility
such
therein
Plaintiff
objects
to
each
is
and
every
Interrogatory to
this
to
the
extent
the
is
Interrogatory
seeks
information that
to lead
not relevant
case
not reasonably
calculated
to the
Plaintiff
objects
to
each unduly
extent the
and
every
Interrogatory
to
the
extent
the
Interrogatory
is
overly
broad
to the
burdensome
that the of
harassing
repetitious
vague
the
and/or
ambiguous
and
Interrogatories
purport
to require the
disclosure
of information
beyond
scope
admissible evidence
under
Federal
Plaintiff
objects
to
all
Interrogatories
and
duties
to
the
definitions or alter
and
the
instructions duties
extent
they impose
which exceed
imposed by
Maryland Rules
of Civil Procedure
Plaintiff to any and all interrogatories to the extent objects contain multiple unrelated subparts within numbered interrogatory single
that
they
in violation
of
Maryland
Rule
2421
and/or
all
interrogatories
to
the
extent
they
exceed
30
interrogatories
Plaintiffs
objections to
and
answers
to
the
lnterrogatories
are
based
on
information
right to
now
That
as
available
Plaintiff
and
are
made
without
prejudice additional
to Plaintiffs
assert
additional
Plaintiff
objections
should
Plaintiff
discover
is
grounds
for
objections be construed
has answered
any any
Interrogatory to
not intended
waiver
by
Plaintiff
of
objection
any Interrogatory
Plaintiff Plaintiff
has
and
therefore
additional
reserves
the
right to
supplemental
Answers
if
234620-1
By
objections to
its
providing admission
the
information
requested grounds
Plaintiff
does
not
waive
or
on
the
of relevance
materiality
on
any
other
proper grounds
Plaintiff
objects
to
all
Interrogatories
to
the
extent
that
they
call
for
documents and/or
which concern
material
confidential
business
records
trade
secrets
business
plans
other
which would
allow the
Plaintiff
and/or
third persons
to obtain
competitive information
Plaintiff
objects
to
all
Interrogatories
to
the
extent that
that
they seek
all
all
communications communications
and
or
all
documents
on
the
ground
she
cannot
know
exist
No
Plaintiff
incidental
implied That
admissions
are
intended
by
an
answer
is
by
to
any Interrogatory
that
Plaintiff
Plaintiff
not an
admission
accepts or that
by such
evidence
Interrogatory
making
such
of
or
assumed
admissible
Neither production
Plaintiffs
agreement
or as
to
produce
or
nor
her
objections of
to
the
of
is
any
to
information be construed
documents an
any
or
category
information or
that
documents
admission
acknowledgement
any
or categories
Plaintiff
objects
to
any
Interrogatory protected
to
the
extent
that
it
requests
disclosure
of information
banned and/or
from
disclosure
by law
Plaintiff
makes
these
answers
subject
to
the
reservation action of
of her
right to or
object
to the
in this or
any other
any information
including
material limited
contained
produced hereunder
to relevancy
materiality
but not
Plaintiff
objects
to of
Interrogatories
in
party has
provided
the
their of
interpretation
of the
meaning
document
or purported
summarize
contents
document
allegations
in variance
of the of
actual
terms contained
characterizations
within such
to
document
further
in that
is
law and
which no
response
required beyond
to the actual
document
cited
Plaintiff
generally
objects
to
the
characterizations as
throughout
these
Interrogatories characterizations
Plaintiffs in these
answers
should
not be deemed
her agreement
with
the
Interrogatories
234620-1
Plaintiff
objects in the
to the
Interrogatories or control of
to the the
extent
or or
information already
custody
Plaintiff less
seek
more conveniently
Interrogatories
expensively
less
Plaintiff
objects
to to the
each public
Interrogatory
that
seeks
the
disclosure
of
documents
that
are available
objections to
specific
objection
and
is
particular general
and any
specific
objection
below
waiver
of the
objections
All
answers
stated
below
incorporate
the
above-stated
objections
and
are
provided
subject
to
and without
waiving
any
of the
objections
stated
above
The
fact that
Plaintiff
chooses
of the
foregoing
objections
for each
specific
Interrogatory
shall not
waive any
of the
above-stated
objections
ANSWERS INTERROGATORY
or
NO
to these
Identify
all
persons
who
assisted
in preparing
to
who
provided
answers
for
Interrogatories
and
your
responses
the
accompanying
requests
documents
ANSWER NO
Plaintiff
objects
to
this
Interrogatory
to
the
extent
that
it
by
the
attorney-client
privilege
and
the
attorney
work
product
doctrine
Without
waiving
said objection
or privilege
Plaintiffs attorneys
INTERROGATORY
number
of each
NO
believe
State
the
identity
address
and
telephone your
person
who you
the
has knowledge
or information relating to
knowledge
or information
ANSWER NO
interrogatories
Plaintiff
objects
to this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of the
Maryland
Rules
of
Civil
Procedure
Further
the
interrogatory
as
worded
is
overly
broad
234620-1
as well
as
unduly burdensome
as
it
seeks
for Plaintiff
to identify
all
facts
relevant
to the
issues
in the case
even
if
she
has
no knowledge
of
their
existence
For
that
reason
the
interrogatory
is
objectionable
as
it
calls
for speculation
and
conjecture
and
is
not reasonably
calculated
to lead
to admissible evidence
Without
waiving
and
subject
to said objections
Plaintiff
presumes knowledge
that
the
Defendants
Aparicio
Forrester
and
Clark
may
have
personal
Plaintiff
also
presumes
that
current
and
former
colleagues
of
the
Defendants
the
Plaintiff
and
other
members
of
the
local
personal
knowledge
including
to Jerry
Coleman
ongoing
Casey
Damon
Yaffe
John Gallo
is
Plaintiff
reserves
the
right to
supplement
to this Interrogatory
INTERROGATORY NO.3
by any
of the
all
Identify allege
is
each
of fact
made
Defendants subparts
the date
that
you
false
as
in Complaint
1J19-25
false
and
27
of
37 48-50
of such
quoting
the
each
of the
alleged
of fact
and time
statement
speaker
of the
the exact
medium web
to
communication
upon
if
which
statement found
was made
website
to or
this
etc
and
the the
statement statement
on
blog
the
exact
address
all
containing statements
Your
base
answer
the
interrogatory
should
identify
on
which
you
Complaint
including
that
you contend
or
state for
you
are
not
qualified of
competent
and
incapable
doing
job Complaint
you contend
athletes state
21
that
24
All statements that
implicate
otherwise insinuate
relationships
you
are
involved
in personal
sexual
and/or
that
inappropriate
with
multiple professional
and/or
with
you
ha
personal sexual
and/or inappropriate
relationship
professional
athlete
Complaint
20
21
that
21
21
21
that
All statements
you lied on
you contend state implicate or otherwise insinuate resume and did not have the credentials or experience
234620-1
that
with
regard to
profession
as
journalist
Complaint
21c
that
you contend
like
state
implicate
or otherwise insinuate
look
stripper
bitch
violence
and/or an idiot
Complaint
21
24c
that
All statements
Complaint
24d
that uncivilized that
against
e.g
All statements
you contend
demeaning and
way
Complaint
24b
your
professional
in
All statements
you contend
statements
about
you
Complaint
24e
objects to
this
ANSWER NO
interrogatories
Plaintiff
Interrogatory
as
it
contains
several
each involving
separate
guise
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of the
Maryland
Additionally
as discovery is
ongoing
Plaintiff
reserves
the
right
to supplement
and/or amend
her
Answer
Without
waiving
said
objection
see
chronology
attached
hereto
as Exhibit
NO
the
For each
statement
it
identified
false
your
answer
to
was
when made
all
identify to the
you who
have
on which you base your contention identify knowledge of such facts and for each person knowledge
persons
known
state
identified
ANSWER NO
interrogatories
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
of
single
interrogatory
in contravention
of
the
limits
imposed by Rule
2-421
of
the
Maryland
Rules
of
Civil
Procedure
The
interrogatory
as
worded
is
overly
broad
vague and
ambiguous
with
as well
as
unduly burdensome
as
it
seeks
for Plaintiff
to identify
all
persons
personal knowledge
of the
facts
relevant
to the
issues
in the
case
even
if
she
has
no knowledge
of their existence
Further
Plaintiff
objects
to
this Interrogatory
to the
234620-1
extent
it
seeks
information protected
from discovery by
the
attorney
work-product
doctrine
To answer
this
be required to provide
information regarding
counsels
litigation strategy
in this
case
Without waiving
said
objections
and
subject
thereto
Plaintiff
has
never
been
romantically involved
with
Nick Swisher
or Brian Matusz
Moreover
Plaintiff
Plaintiff
has never
purported
to
have
credentials
she does
not have
Plaintiff
incorporates
her
Answer
to
Interrogatory
As discovery
is
ongoing
Plaintiff
reserves
the
right to
supplement
INTERROGATORY
any
other
NO
but
Identify
all
communications
to
between
you and
to
persons
identified
including
in your
not
limited
the
relating identify
the date
statements
of the the the
answer
the
all
to Interrogatory
No
the to
communication
by
whom
communication those
was authored
the
made
whom
communication communication
to
who
received
communication
of the
whether
substance
communication
communication
ANSWER NO
interrogatories
Plaintiff
objects
to this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct issues
under
the
guise
of
single
interrogatory in contravention
of
the
limits
imposed by Rule
2-421
of
the
The interrogatory
as
worded
the
is
overly
broad
ambiguous
as
well
as
unduly burdensome
as
Interrogatory
does
not define
term
communications
Further
Plaintiff
objects
to this
Interrogatory
to
the
extent
it
seeks
information protected
by
the
attorney-client
privilege
and
the
attorney
work
product
doctrine
Without waiving
Baltimore
and
subject
to
said
objections
Plaintiff
prepared
correspondence
to the
Ravens
organization
on
or
about
August and
14 2010
Plaintiff
exchanged
emails with
colleagues
and management
at
MASN
CBS
as
234620-1
well
as
telephone
conversations
beginning
on
approximately
January
13
the
2011
regarding the
Defendants
conduct As discovery
is
ongoing
Plaintiff
reserves
right
to
to this Interrogatory
your
that the
With
if
respect
to that
each any
statement
of the
identified
in
you contend
entertained
Defendants
truth
knew
of
its
statement
or
was
false
subjectively the
doubts high
as to the
of falsity as to
statement
published
for
statement
state
with
the
degree
facts
of awareness
probable
falsity
each
Defendant
specific
and
all
persons
state
known
to
you whohave
on which you base your knowledge of such facts and for knowledge
identified
the substance
of that persons
ANSWER NO
interrogatories
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
issues under
the
guise
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of the
Maryland
Rules
of Civil
Procedure
as
worded
is
overly
broad
vague
all
and
ambiguous
with
as well
as unduly
as
it
seeks
for Plaintiff
to identify
persons
personal knowledge
of the
facts
relevant
to the
issues
in the
case
even
if
she has
no knowledge
of their existence
Further
Plaintiff
objects
to
this
Interrogatory
to the
extent
it
from discovery by
the
attorney
work-product
doctrine
To answer
this
be required to provide
information regarding
counsels
litigation
strategy
in this case
Without
waiving
said
objections
and
subject
thereto
Plaintiff
directs
Defendant
to
her
Answer
to
Interrogatory
No
case
and
incorporates
her Answer
thereto
Plaintiff
anticipates
that
discovery
in this
will provide
further
information in regards to
this
Interrogatory
and
as
such
reserves
the
right
to
supplement
and/or
amnd
her
Answer
to
this
Interrogatory
234620-1
INTERROGATORY NO.7
tend to show that the highly offensive
to
Describe
in
detail
all
facts
that
statements
reasonable
identified
in your identify
answer
all
to Interrogatory
person
for each
persons
who you
the
have
that
knowledge
persons
of
such
facts
and
person
identified
state
substance
knowledge
ANSWER NO
interrogatories
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
issues under
the
guise
of
single
interrogatory in contravention
of
the
limits
imposed by Rule
2-421
of the
Maryland and
Rules
of
Civil
Procedure
The interrogatory
as
worded
is
overly broad
vague
ambiguous
with
as well as
unduly burdensome
as
it
seeks for
Plaintiff
to identify
all
persons
personal knowledge
of the
facts
relevant
to
the
issues
in the
case
even
if
she
has
no knowledge
of their existence
Further
Plaintiff
objects
to
this
Interrogatory
to
the
extent
it
from discovery
by
the
attorney
work-product
doctrine
To answer
this
be required to provide
information regarding
counsels
litigation strategy
in this
case
Without
waiving
said
and
subject
to
said
objections
the
statements
outlined
in
Exhibit
speak
for
themselves
including
threats
that
Defendants
would
snap
Plaintiffs
neck
and
all
statements
referring
to Plaintiff
as
bitch trashy
she must cover
calling her
liar stating
that she
sleeps
with
professional
athletes
pursuant
to her professional
duties
etc
Plaintiff
reserves
the
right
to
supplement
and/or
amend
her
Answer
to
this
Interrogatory
is
INTERROGATORY NO
magazine
transcripts articles
letters
Describe
in
detail
all
newspaper
tapes
or
bulletins to the
flyers
computer
printouts
broadcast
videos from
or
January
2003
to
the
present
in
any form
regarding
you
that
were broadcast
published by anyone
other
than Defendants
234620-1
ANSWER NO
vague and ambiguous
It
Plaintiff
objects
to
this
Interrogatory
as
it
is
overly
broad
also
seeks
information which
is
immaterial
to
the
instant
matter and
is
not reasonably
calculated
to lead
to the
discovery of admissible
evidence
Without waiving
and
subject
to
said objections
see Exhibit
attached
hereto
INTERROGATORY NO.9
acted
If
you
contend
that
any
of
the
Defendants
in your
with
to
common
law malice
ill
of the statements
answer
Interrogatory identify
all
No
the
the
specific
facts
on which
of such
you base
facts
such
contention
have
knowledge
person identified
state
knowledge
ANSWER NO
interrogatories
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each
involving
separate
and
distinct
issues under
the
guise
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of
the
Maryland and
Rules
of
Civil
Procedure
The Interrogatory
as
worded
is
overly
broad
vague
ambiguous
with
as well as
unduly burdensome
as
it
seeks
for Plaintiff
to
identify
all
persons
personal knowledge
of the
facts
relevant
to the
issues
in the
case even
if
she has
no knowledge
of their existence
Further
Plaintiff
objects
to
this
Interrogatory
to
the
extent
it
seeks
information protected
from discovery by
the
attorney
work-product
doctrine
To answer
this
be required
to provide
information regarding
counsels
litigation
strategy
in this
case
Without
waiving
and
subject
to said objection
Plaintiff
directs
Defendant
to her
Answer
to Interrogatory
No
INTERROGATORY NO 10
have
suffered to your reputation as
Describe proximate
to in
No the reasons for your belief that those statements your answer to Interrogatory were the proximate cause of any such loss identify all persons who you contend have
10
234620-1
knowledge
persons
of
such
loss and
for each
person
identified
state
the
substance
of that
knowledge
ANSWER NO
interrogatories
10
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct issues
under
the
guise
of
single
interrogatory in contravention
of the
limits
imposed by Rule
2-421
of the
Maryland and
Rules
of
Civil
Procedure
The Interrogatory
as
worded
is
overly
broad
vague
ambiguous
with
as well as
unduly burdensome
as
it
seeks for
Plaintiff
to identify
all
persons
personal knowledge
of the
facts
relevant
to
the
issues
in the
case
even
if
she has
no knowledge
Defendants
waiving
and
subject
to
said
objections
the
actions
have
caused
Plaintiffs
professional
and personal
reputation
to
be
called
into question
Defendants
conduct
has caused
members
of the
public
to believe
that
she
is
bitch
liar
sexual
relationships
with
Nick
Swisher and/or
Brian Matusz
Plaintiffs
credibility with
the
professional
athletes
she covers
has been
endangered
by
these
false
assertions
and
she
has
been
forced
to
explain
herself
to
others
as
result
of the
Defendants
false
statements
INTERROGATORY
contend
to
NO
to as the
11
Describe
feelings of the
in
detail
any not
other
damages
to
you
have
suffered
your
including statements
but
limited
distress to or
all
result
identified of the or
in your alleged
answer
injury
No
special related of
state
nature
allege
extent are
and due
duration
damage
financial
any
damages you
thereto
injury the or
to such
injury that
damage
any
and
losses
such
statements
were
the
proximate
health care
cause
such
damage
you
the
addresses
the dates
of
of all
providers
who
treated
for such
and
such
treatment
ANSWER NO
interrogatories
11
Plaintiff
objects
to
this Interrogatory
as
it
contains
several
each involving
separate
and
distinct
guise
of
single
11
234620-1
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of the
Maryland
Rules
of
Civil
Procedure
The Interrogatory
as
worded
is
overly
broad
vague
and
ambiguous
as
it
does
not
define
the
phrase
damages.
Plaintiff
.suIfered
to
your
feelings
Without waiving
and
subject
to said objections
refers to
Dr
Goldiners
letter
produced
in
response
to
the
Defendants
Request
for
Production
of
Documents
Plaintiff
has suffered
from
severe
anxiety
depression
and
fear
that
any
slight action
may
about
cause
the
Defendants
to
publish spiteful
hateful atrocious
and
false
statements
has caused
Plaintiff
to
alter
her work
habits
and
her
the
way
she
dresses
Plaintiff
is
currently
being
treated
by Dr
1205 York
Road
21
Lutherville
Maryland
21093
and was
treated
by
Dr
William
Goldiner
MD
Internal
Medicine
Drive
207
to
Towson
medication
Maryland and
21204
Plaintiffs
damages Liebman
aie
ongoing
as
she continues
take
is
under
the
care
of
Dr
INTERROGATORY NO 12
those
identified in response to the
Describe preceding
in
detail
any
damages
suffered
other
than
as the
interrogatories
by you
proximate reasons
identified
in your
answer
the
to Interrogatory
No
of any
were
proximate
of such
cause
such
persons
who you
have
knowledge
identified
persons
knowledge
her
ANSWER NO
Interrogatories
12
Plaintiff
refers
to
and
incorporates
Answers
to
Nos
10 and 11
INTERROGATORY
state
NO 13
In
support
of
Count IV
that
of
your
Complaint
conduct
all
facts
any Defendants
in society
bounds
of decency
j60
12
234620-1
ANSWER NO
vague
13
Plaintiff
objects
to
this
Interrogatory
as
it
is
overly
broad
and ambiguous
Further
Plaintiff
objects
to this
Interrogatory
to
the
extent
it
from discovery by
the
attorney
work-product
doctrine
To
answer
this
regarding
counsels
litigation
strategy
in this case
said objections
and
subject
thereto
Plaintiff
directs
Defendant
to her
to Interrogatories
Nos
the
10
12 and Defendant
snap
is
her
neck
initial
along with
other statements
outlined
in Exhibit
As
this
litigation
in
its
stages
Plaintiff
reserves
the
right to supplement
this
Answer
as discovery proceeds
INTERROGATORY NO 14
state
all facts
In
support
of
Count IV
that
of
your
Plaintiff
IT
has suffered
Complaint and
will continue
62
her
ANSWER NO
Interrogatories
14
Plaintiff
refers
and
incorporates
Answers
to
10
11
and 12
INTERROGATORY
practitioner
NO
15
Identify
any
health
doctor counselor
physician
or
medical
health
psychologist
that
psychiatrist
mental
mental
practitioner you have ever visited concerning your mental health in your lifetime and for each state their person identified number and the date and purpose of any such visit phone
and/or
full
emotional address
name
ANSWER NO
seeks information that
15
Plaintiff
objects
to this
Interrogatory
as
it
is
overly
broad
and
is
not material
to the
instant
litigation
The
Interrogatory
is
not
reasonably
calculated
to lead
to
the
Without
waiving
and
subject
to
said
objection
Plaintiff
has
visited
Drs
Goldiner
and Liebman
See
Answer
to
Interrogatory
No
11
13
234620-1
INTERROGATORY NO 16
including
sent to
Identify
and
describe
all
communications
of the
to letters
and correspondence
in Baltimore
from members
public
you
relate to your
work
Maryland broad
ANSWER NO
vague and ambiguous
16
Plaintiff
objects
to this
Interrogatory
as
it
is
overly
as well
as unduly
burdensome
as
it
seeks
for Plaintiff
to provide
all
communications
her
which
term
is
left
undefined
Plaintiff
has
ever
received
regarding
work
in
Baltimore
Maryland
Moreover and
the
Interrogatory
seeks
litigation
is
not reasonably
calculated
to
lead
to the
INTERROGATORY NO 17
which you were named and
in for each the as
Identify either as
any
lawsuit
proceeding
or
in
party
defendant
state the
third-party case
respondent
or proceeding the
the
number
and court
which
case
pending
the
nature of the
status
in the
complaint
if
cross-claim
current
and
resolution
any
ANSWER NO
calculated to lead to
17
the
Plaintiff
objects
to
this
Interrogatory
as
it
is
not reasonably
discovery
of
admissible
evidence
Plaintiff
can
obtain
this
public
Maryland
Judiciary
Website
if
Plaintiff
finds
that
this
public
information
is
necessary
to
its
case
Plaintiff
may
access
this
informatibn from
public
sources
Without
waiving
and
subject
to said objection
none
INTERROGATORY NO 18
you attended and
all
Identify to the
every present
school
stating
college
the dates
or
university
beginning
from high
school
of attendance
degrees awarded
ANSWER NO
and graduated
with
in
18
Plaintiff
attended
Mansfeild
in 1988
1992
Plaintiff
attended
Salve Regina
1996 and
graduated
B.A
14
234620-1
INTERROGATORY NO 19
history With
for the respect to your
Describe to this
in
detail
your
entire contact
employment
information your
answer can
interrogatory provide
individual
who
verify
your
employment
at
describe of
work
the
identify
your
direct
supervisors
title
each
place
employment
employment
your job
including
of
any changes
during
employment
and
the
employment
ANSWER NO
interrogatories
19
Plaintiff
objects
to this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of the
Maryland
The
interrogatory
seeks
litigation
and
is
not
reasonably
calculated
to
lead
to
the
discovery
of
admissible
evidence
Further
the
interrogatory
is
unduly
burdensome
as
it
seeks
for Plaintiff
to
identify
employment
and employers
without
specification
to
relevant
well-defined
period
of
time Without
waiving
said
objections
Plaintiff
directs
Defendant
to
her
attached hereto
as Exhibit
INTERROGATORY
definition
NO 20
associated
Describe with
the
in
detail
your
understanding
as
of
the in
and/or
activities
following
terms
they
appear
paragraph sexual
21
subparts
and
personal
relationship
relationship
and
inappropriate
ANSWER NO
20
former
athletes
all
or
current
professional sexual to
in
personal
relationship
limited
relationship
current
relationship
of the
including
staff
but not
any
former
player
member
coaching
the
or
management
in Major the
League
Baseball the
National Football
League
National
Basketball
Association
National
Tour
other
Hockey League Major League Soccer the Arena Football League the PGA ATP World Tour NASCAR any minor league affiliate of such leagues or any minor professional and the American Hockey League league i.e AAA baseball
the identified state their full
name
address
phone
number
and
the
dates
and nature
of
15
234620-1
ANSWER NO 21
interrogatories
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of the
Maryland
The
interrogatory
seeks
litigation
and
is
not
reasonably
calculated
to
lead
to
the
discovery
of
admissible
evidence
Further
the
Interrogatory
is
overly
broad
vague
does
and
ambiguous
The
interrogatory
calls
for speculation
and
conjecture
as
it
not define
the
phrase
inclined
in
Identify
all
INTERROGATORY NO 22 whom
you have
limited ever to
former or professional
relations of any
athletes with
or sexual or
but not
any
former
player
member
of
the
or
management
Basketball Football
affiliate
in Major
League
the
Baseball the
National
Football
League
National
the
Association
National
League
of such
the
PGA
Tour
the
leagues
or any
other
Arena Hockey League Major League Soccer ATP World Tour NASCAR any minor league minor professional league i.e AAA baseball and each person
identified
state
the
American
League
and
For
their
full
name
the dates
and nature
of any
such relationship
ANSWER NO
interrogatories
22
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct issues
under
the
guise
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of
the
Maryland
The
interrogatory
seeks
litigation
and
is
not
reasonably
calculated
to
lead
to
the
discovery
of
admissible
evidence
Further
the
Interrogatory
is
overly
16
234620-1
Jun
02
2011
825PM
Martin
Bane
800-291-9303
page
SOLBMNLY AFFIRM
the
under
the penalties of
perjury
matters
stated
in
Answers
to Intrrogatories
my
information
arid
belief
17
234620-1
RESPONSES
REQUEST
RESPONSE
NO NO NO
You
are
sports
reporter
Admitted
REQUEST
On
March
the
23 2011 on
the
Masnsports.com
blog
located
at
royle_rundown/2011/
public figures
03/ goodbye-masn.htrnl
you
and
are
open
for criticism
RESPONSE
admitted
as the
NO
Admitted
subject
to
completeness
of
the
writing
being
whole
entry
from
said
MASN
sent
Blog stated
And
no
position
lastly
for those
of
you who
me
nasty
comments
on
this
blog
am
in
to preach
to
you
or
tell
you
that
however
If
you thought
that
personal attack
may
are
have been
hurtful they
were
While
sports
reporters
are
indeed
public
figures
open
of us
for criticism
which
completely
understand
please
keep
in
mind
that while
most
do have
thick
skin
we
feelings
as
you And
thats
all
have
to
REQUEST
RESPONSE
legal
NO NO
as
You
are
public
figure
Plaintiff
objects
to this
as
it
calls
for
conclusion
and
such
is
improper
18
234620-1
dh
Brian
Goodman
Moylan PESSIN KATZ P.A
Suite 400
Alexandra
HODES
901
Towson Maryland
21 204-2600
410 410
938-8800 825-2493
Fax
19
234620-1
JENNIFER ROYLE
Plaintiff
IN
THE
CIRCUIT
COURT
FOR NASTY
1570
SPORTS LLC
et
at
BALTIMORE
CASE
CITY
Defendants
NO
24-0.11001571
OF DISCOVERY
of
on
this
2nd day
June 2011
copy
of the
foregoing
and
Responses
to
Requests
for
Admission
directed
to
Jennifer
Royle
on
behalf
of
WNST
SPORTS MEDIA
to
LLC
one
of
Defendants
was
mailed via
first-class
Tobin Esquire
Shertlcman Knight Esquire
Drew
Holland
LLP Avenue
20006
2099 Pennsylvania
Suite
N.W
100
Washington D.C
202
955-3000
Ly
Brian
Goodman
k44
Road
Suite 400
Alexandra
HODES
Towson Maryland
410 410
938-8800 825-2493
Fax
EXHIBIT
uoffls
P3-SM1N
.4uoren
.4
KATZ
Lzw
Chronology
of Defamatory
Statements
Statements
Casting
Plaintiff
In
False Light
2/24/2010
On
his
lists
Top
Sports Media
Members We
Wouldnt Mind
Seeing
Few
Weeks
is
4/7/2010
that
Ms
Royle
on
notice
that
she
is
up
for the
Apologist
of the
Morning
4/23/2010
her statement
regarding
the
Orioles
Ms
Royles
commentary
the
He
congratulates
Apologist of
Morning
Royle
award
4/26/2010 she
is
On
his
blog Drew
Forrester
states that
that
is
Ms
hiring to
was
stereotypical
because
an
out-of-towner
that
He
later states
she
not qualified
ask
any questions
and
insinuates
she frequents
hang
outs
of Yankees outfielder
Nick Swisher
5/3/2010 the
to
that
Jen Royle
is
is
in the
running
to
win
The
the
Orioles Apologist
of
Month
her
He
also
notes that
ties
she
up
for
comparable
award with
Yankees
which seems
mock
New
York
511
2/2010
On his
ridicules
statement
made by
of the
Ms
Royle
in
her
commentary
5/18/2010
of the Orioles
He
notes that
she
won Apologist
Morning
earlier that
day
Glenn Clark
states
in his the
blog that
Ms
Royles
description of
game was
irrelevant
He
notes that
won
Apologist
of the
Morning
Orioles game
is
5/19/2010
later
that
Ms
the
Royles
was wrong
He
that
analogizes
character
on
Jersey Shore
disaster
He
states
he
6/2/2010
On his
loss
Ms
Royles
description of an
Orioles
game
as
heartbreaking of the
another
entry
he
states
that
the
Apologist
Morning
award
8/5/2010
CBS
employee
included
notifies that
Ms
Royle
that
Glenn Clark
about
the
just
ripped
her on the
air
that
morning
the term
Comments
she
knew
nothing
the
Ravens and
did not
know what
blitz meant
but that
she
knew who
right
fielder
of the Yankees
was
Swisher
9/7/2010
During
Ravens practice
Ms
Royle
is
informed
the
that
Glenn Clark
told
member
of
credentials/
experience
she claims to
it
have and
listening
does
to
be
covering
Ravens
have
Clark also
better
allegedly stated
to
that
is
brutal
anyone
cover
the
Ravens
HoDi3s
Page
Psssrn
KATZ P.A
9/12/2010
series clothes
included
that
he thought
working
for at the
and
in
that
the
wearing
strip club
Baltimore car
that
Drew
Forrester
were
Ms Royle
she was an
further idiot
alleges
they called
in front
her
bitch
said
she
after
and
while talking
of press
box
and
Later
confronting
states that
them Drew
reminds
Ms
shes
for
boots
He
also
After that
that
Drew
Nestor
about
her
9/20/2010 she
is
CJ
Spiller in
blogs on
WNSTs
website
that
Ms
to
He
states
that
disinterested like
Baltimore and
girl
does not
know how
He
further
alleges
that
she talks
high
school
After she
an altercation lucky
with
Drew
Forrester
at the in yet
Ravens
or
facility
Drew
Forrester
is
my
kicked
her head
off He
from
he was teams
by her actions
and
that to
He
later
tweets that
Rays
she was
seen running
away
WNST
when
lost in
power He
tweet
that
she does
not
is
know
the location
of Hopkins
Glenn Clark
insinuates
listening
Ms
Royle
awful
Drew
Ravens
the
Forrester Steelers at
condemns
fan jokingly
encouraging
to
Jen to follow
kill
herself
via
game
The
Drews
jab that
game Drew
home
fans
11/18/2010 joke
that
wont
get to
This appears
to
be
star
11/26/2010
further
Drew
Ms
in
Royle
is
not
teams
He
insinuates
that
interested
Yankees
outfielder
Nick Swisher
12/29/2010
Drew
town
like
Forrester blogs
bull in
that
Jen
for
coming
to
china
shop
things
stated
Baltimore
that
He
Baltimore
sucks
He
suggests
that
she has
dogged
saying that she
is is
Baltimore to everyone
1/2011
Drew
series
of tweets
shed
look
great
in
nothing on
but
brief the
Nick Swisher
shirt
and
that
stuck-up
snobby
tourist
here
tweets that
she
ignorant and
who
thought
1/11/2011 tweets
that
it
Drew
Jen
is
an
out-of-towner
then threatens during
and
tourist
Glen Clark
also
his
is
agreement
assertion
Drew
out-of-towners
Drew
tweets
suspicious
Jen received
WNST
text
press conference
which he
finds
humorous
HODES
Page
PESSIN
KATZ P.A
1/12/2011
insinuate
Drew
Forrester
blogs
that
Ms
with
Baltimore
He seems
to that
He
make
further
it
alleges
she
is
using
in
Baltimore
He
then seems to
threatening
tone towards
out-of-towners
which includes
Ms
Royle
1/20/2011 continue
Dave working
Hughes receives
for to
question
in his
asking dating
how
an
Ms
Royle
is
able to
MASN arid
the
cover
the Orioles
that
it
Orioles pitcher
for
Mr
Royle
Hughes responded
to
question
by noting
for
would be
conflict
of interest
Ms
date
member Drew
is
of
MA SN
the only qualification
to
1/26/2011
Forrester
states
on
This
his
is
blog that
in
be in Baltimore
in
Magazine
that
you work
is
here
reply to
why He
Ms
Royle
to
is
featured
the magazine
that
He
is
states
that
her scent
He
later
responds
another
that to
person
Ms
Royle
condescending
and
that
snarky he
likes
and
snobby
reiterates
she doesnt
scratch
know
sticker
Baltimore
way
she smells
making
reference
arid sniff
1/28/2011photo
Drew
Forrester
states
in his outfit
blog that
Baltimores
own
Jen
Royle showed up
to
shoot with
Nick Swisher
2/22/2010
Ms
Royle
is
is
informed
that
Nester
pretty
commented
face and
on
the
is
Ms
to
Royle
because
other
she has
breasts
is
she
Orioles or any
team because
Ms
that
Royle
woman
from the
5/25/2011
Glenn blogs
in
honor
of the fact
the reporter
FM sports
Things
station
in
town
list
yesterday
we
thought
wed
he
put together
bucket
for
Top
7..
The
Tuesday Top
Sports
was
entitled
It
The Top
that
is
You Need To
Do TO
Royle
Yourself
Baltimore
Expert
appears
insuating that
Ms
not
reporter
by using
Unknown
Dates
Drew
Forrester
allegedly
tells
Jerry
Coleman
from Fox
that
you know
right
follow
his
Drew
Forrester or
tweets that
fans can
live
stadium
sent
Ms
Royles
tweets
Appears
to
be
around
9/27/11
on
his
he
does
Jen Royle
be on
wear
that
short
skirts
why wont
TV
and
its pretty
cold
outside
EXHIBIT
Bmore Media
March
29
2011
11 .aspx
httpj//www.bmoremedia.com/features/jenroyleo329
Full
Count
Pitch
March
28
2011
11 /03/ftilleountpitch-ftill-count-j
http//mypinstripes.blogspot.comI2O
en-royle.html
Washington
http//dev
Examiner
February
19 2010
7.html
.www.washingtonexaminer.cornlsports/blogsfwatch-This/Jennifer-Royal-shoulcl-be
Seott-Garceaus-new-partner-847697
Washington
Examiner
March
29 2010
057fto-fan-baltimore-and-masn
http//washingtonexaminer.contfblogs/watchlroyle-welcome-
Washington
Examiner
March
24
2011
11/03/1 057ftn-fan-launch-orioles-pregame-and-
http//washingtonexaminer.comlblogs/watchl2o
postgame-shows
Baltimore Sports
Report
January
10 2011
en-royle-
http//baltimoresportsreport.com/interview-bsr-gets-to-know-masns-j
11316
.html
Baltimore Sports
blip
Report
February
10 2011
12690 html
//baltimoresportsreporteom/jen-royle-explains-orioles-flagship-switeh-her-role-
Baltimore Sports
Report
March
21
2011
http//baltimoresportsreport.comljen-royle-parting-ways-with-masn-staying-with-105-714137.html
Press
Box Magazine
May
2010
issue
http//www.pressboxonline.comlstory
efmid62
April
11
Free Daily
Baltimore
Sun
2011
Cover
http//www.readoz.comlpublicationlembedp1 8756
QA
http//www.baltimoresun.com/entertainment/bthesite/bal..en-royle-ga-you-have-to-say-enough is-enough-201
1040606805717story
Photos
http//www.baltimoresun.comlentertainment/bthesite/bs-bthesite-jennifer-royle 2011
0406 04543896.photogallery
Baltimore Magazine
--
Hottest
Singles
2011 issue
/02/to
http//www.ba1timoremagazine.net/features/2O11
p-singles-20 11 -wheres-the-1oy
JENNIFER ROYLE
Plaintiff
IN
THE
CIRCUIT
COURT
FOR NASTY
1570
SPORTS
LLC
et
cii
BALTIMORE
CASE
CITY
Defendants
NO 24-C-11001571
PLAINTIFF JENNIFER
ROYLES SUPPLEMENTAL ANSWERS AND RESPONSES TO WNST SPORTS MEDIA LLCS FIRST SET OF INTERROGATORIES
Royle
Plaintiff
Goodman
and
Moylan
of
Hodes
of Pessin
Katz
P.A
supplements
Interrogatories
propounded and
to
her
by
WNST
SPORTS
MEDIA
LLC
one
of
Defendants
states as follows
INTERROGATORY
those
identified in response
NO
to
12
Describe preceding
in
in
detail
any damages
suffered
other
than
as the
the
interrogatories
by you
proximate reasons
result of the
statements
the
identified
for your
all
belief that
such
No
of
any such
for each
persons
state
who
you contend
of that
knowledge
of such
loss and
identified
the
substance
persons
knowledge Answers
ANSWER NO
Interrogatories
12
Plaintiff
refers
to
and
incorporates
her
to
Nos
10 and
11
refers to
SUPPLEMENTAL ANSWER 12
Answers
to Interrogatories
Plaintiff
and
incorporates
her
Nos
10
and
11
Plaintiff
refers
the
Defendants
to
the
documents attached
in response
to
Defendants
Request
for Production
of
Documents
Plaintiff reserves
the
right to
INTERROGATORY
definition
NO 20
associated
in
detail
your understanding
terms
as
of
the in
and/or
activities
following
they
appear
paragraph
and
Complaint
relationship
personal
relationship
inappropriate
ANSWER NO 20
SUPPLEMENTAL ANSWER 20
Relationship Personal
the
Plaintiff
defines
the
following terms
way
in
which
things
are connected
Relationship
the lives
way
in
people
are
connected
in
their
Sexual Relationship
the
way
in
which people
activities
are connected
intimately
in any
way
referencing
Inappropriate
relate to particular
Relationship another
that
is
the
way
in
which people
are connected
and/or
in
one
unsuitable
unacceptable
and/or not
suitable
setting
location
or situation
Brian
Goodman
Moylan PESSIN KATZ P.A
Alexandra
HODES
Road
Suite 400
Towson Maryland
21204-2600
410 410
938-8800 825-2493
Fax
2474854
JENNIFER ROYLE
Plaintiff
IN
THE
CIRCUIT
COURT
FOR NASTY
1570
SPORTS
LLC
et
BALTIMORE
CASE
CITY
Defendants
NO 24-C-11001571
on
this
copy
of the
foregoing
Answers
to
Interrogatories
and Responses
to
Requests
for
Admission
directed
to
Jennifer
Royle
on
behalf
of
WNST SPORTS
MEDIA
LLC
one
of
electronic
mail to
Charles
Drew
Holland
LLP Avenue
20006
2099 Pennsylvania
Suite 100
N.W
Washington
D.C
202
955-3000
char1es.tobinhMaw.com
Attorney for Defendants
fta.Nuuiv1c
Brian
Goodman
PESSIN
Alexandra
Moylan
HODES
901
KATZ P.A
Suite 400
Towson Maryland
21204-2600
410 410
Fax
2474851
EXHIBIT
June 2011 Letter to Plaintiffs Counsel
Holland
2099
Pennsylvania Knight
Knight
NW
Suite
Avenue LLP
100
Washington
DC 20006
202.955.3000
202.955.5564
Holland
www.hklaw.com
CHARLES
TOBIN
202
419-2539
chaiies.tobin@hklaw.com
June
2011
Via
UPS
Overnight
and Email
Brian
Goodman
Pessin
Hodes
901
Towson
Maryland 21204-2600
bgoodmanhpklegal.com
Re
Jennjfer
Royle
Circuit
NASTY
Court
1570 Sports
Baltimore
LLC
et
aL
Maryland
for
City
Case
No
24C
11001
571
Dear
Mr Goodman
We
send
this letter
pursuant
to
Rule 2-431
in
effort
to
resolve
your
clients the
first
noncompliance
responses
set
with
her
discovery
obligations
under
and 2-422
Specifically
Plaintiff
furnished to
are
WNST
ten
to
Media LLCs
in detail
WNST
of interrogatories
that
and document
requests
deficient within
described
in this letter
letter
We
to
request avoid
Ms
to
Royle supplement
inconvenience
10
days
the
need
Motion
Compel
Plaintiffs
Responses
to
WNSTs
are
Interrogatories
clients
responses
to
the interrogatories
evasive
and incomplete
under
Rule
2-
the
following
deficiencies
Various responses
references
to
unnamed
individuals
Throughout
Ms
Royles
she alludes to
unnamed
individuals
who
may have
information
her Complaint
The
interrogatories
require her to
information
each
These references
include
Interrogatory
No
current
to
The
of Defendants
referenced
in
the
response
Interrogatory
No
local
The
other
members
of the
media
referenced
in
the
response
to
Interrogatory
No
referenced
in in relation to to
The
CBS
employee
statements
allegedly
made
on 8/5/20
10
as
described
Exhibit
Ms
Royles responses
Mr Brian
June
Goodman Esq
2011
Page
The
member
at
of
the
media
referenced
in
relation as
to
statements
in Exhibit
allegedly to
made
Ravens
practice
on 9/7/20
10
described
Ms
who informed you that Nestor made comments about you Ms Royles described in Exhibit to on 2/22/2010 as
responses
Interrogatory
No
individual within the Baltimore
The
Ravens on
organization
to
whom
Ms
as
Royle
prepared
in
correspondence
or about
August
14 2010
described
Ms
Royles answer
to
Interrogatory
at
The
colleagues
and management
as
MASN
and
No CBS
with
whom
you on
as
exchanged
approximately described
in
emails January
well
as
telephone regarding
conversations
beginning
13
2011
to
Defendants
conduct
Ms
Royles answer
Interrogatory
No
Interrogatory
No
10
The
individuals
who have
called
as
into
question
in
Ms
Royles professional
to
and personal
reputation
described
her answer
Interrogatory
No
have had
10
The
members
them
to
who
believe
that
Defendants bitch
liar
actions
caused sexual
in
Ms
Royle
is
and has
as
relationships
with Nick
to
Swisher
and/or
Brian
Matusz whom
described
Ms
Royles answer
Interrogatory
No
10
with
in
The
professional
athletes
Ms
Ms
Royle
covers
Ms
Royles
to
credibility Interrogatory
as described
Ms
Royles answer
No
with
10
The
others 10
whom
as
Royle contends
in
that
she
to
explain
herself
to
described
Ms
Royles
answer
Interrogatory
No
Interrogatory
No
but
Similarly
in
response
to
this
standard
to their
interrogatory
asking she
lists
Ms
five
Royle
to
identify
individuals
information the
relating
her Complaint
non-parties
by
name
the
to
state
substance
of
testimony
alludes
knowledge
to
or and
information as
former
interrogatory of Defendants
required
Further
Ms
Royles response
of the local
current not
colleagues
media
but does
identify
by
name
nor does
or
Interrogatory paraphrase
calls for
No
Ms
Royle responds
her that she
to
this
interrogatory
are
by attaching
Exhibit
of the
statements
about
alleges false
false
However
the interrogatory
verbatim
recitation
of each
in
alleged
statement
of fact
alleged
by
Ms
on
Royle
Exhibit
include
Ms
air
communications
where
Mr
Clark
ripped
Mr
June
Brian
Goodman Esq
92011
Page
and where
the
Drew
Nestor Exhibit
speaking
about
to
her 9/12/2010
the
fails
in
sufficient
notice Exhibit
Defendants or
to identifS the
of the
false
and defamatory
words
that
Further
web
address
of any
allegedly
actionable
statements
Ms
Royle
contends
are
on
WNSTs
website
Interrogatory interrogatory
No
in
Ms
entirely
Royles
response
incorporates
her response
to
the
preceding
which asks an
identified
different to
question
why
it
she believes
iistatement
Interrogatory
her answer
Interrogatory
states
No
that
was
she
false
when
was
made
as
No
requests
to
Ms
Royle generally
she
has
never
lied
on her resume
purported never
have
credentials
does
Moreover
Swisher
Ms
Royles response
she has
been romantically
alleges
involved
that
Nick
has
or Brian
Matusz
sexual
but
her
Complaint
generally
statements
had
personal
and/or
inappropriate
relationships to
with
professional
as to to
all
athletes
Complaint
athletes
as
27
asked
Therefore and
as
Ms
Royle
must respond
alleges
the interrogatory
limit
professional Swisher or
her Complaint
and not
her response
Ms
Mr
Matusz
Interrogatory telephone
No
with
Ms
Royle
generically
refers
to in
conversations addition
to
correspondence
failing or to
and
their
conversations
unnamed
fails
individuals
state the
and
provide
information
as
to
the substance
of
the interrogatory
requests
Interrogatory
No
none
Ms
Royles
response
incorporates sought
the in
her
response
to
Interrogatory regarding
No
Royles
which
provides
factual
of the
information
Interrogatory
No
Ms
complete
that or
Defendants knew
of statements
statements
entertained of awareness
the truth
falsity
or published
as to their
probable
falsity
No
which
Ms
factual
Royles
response of
the
directs
WNST
to
Ms
in
Royles
response
to
No
complete
provides
basis
none
for
information
allegation
sought
that
Interrogatory acted
No
with
Ms
Royles
Defendants
common
law malice
ill
will or spite
No
11
Ms
Royles
response
refers
to
Dr
Goldiners
letter
but has
not
document
Interrogatory
No
12
Ms
Royles
response
the
incorporates
her
response
in
to
Interrogatory
Nos
10
and
11
neither
of which
provides
information
sought
Interrogatory
No
on
12
this
regarding responses
whether
Ms
identified
Because
that
her
any
other
damages we
that
representation
she has
none and
proceed
the defense
on
basis
No
15
Ms
with
Royle responds
with ever
the names
visited
of two
doctors her
and
lists
no
professionals
whom
she
has
concerning
mental
and/or
Mr
June
Brian
Goodman Esq
92011
Page
emotional health
health
in
is
interrogatory
required
Ms
Royles
pre-existing
mental
condition
clearly
of her Complaint
No
16
Ms
of the
Royle
public
objects
to
this
interrogatory
in
which
without
requests
stating
members
about
that the
her
are
work
Baltimore
to
any documents
reputation requests
or communications
is
exist to
responsive
Obviously and
the
Ms
Royles
clearly
relevant
that
allegations
of
Complaint
interrogatory
information
on
issue
Interrogatory
to
No
19
Ms
Royle
failed
to
attach
the document
referenced
as
Exhibit
for
her responses
Moreover
as
her response
provides
no information
about
her reason
leaving
each
place of employment
the interrogatory
required
Interrogatory hearing
to that to
No 20 We
failed to as
advised
your
colleague
Alexandra Moylan
in
at
the June
2011 required
Ms
this
Royle
answer
with
this
interrogatory
any manner
Ms
Royle
is
respond
interrogatory
all
others
Interrogatory
Nos
21
and
22
Beyond
citing false
the boilerplate
objections to
these interrogatories
Ms
Royle provided
that
no information
grounds
that
Ms
had
Royles
Complaint
sexual
entitled
at
27
the
alleges
the
Defendants
made
with
she
personal
therefore are
and/or
to
relationships in
professional
Defendants
requested
Interrogatory
No
21
any
former andlor
for
or current professional
athlete as
which
as the
Ms
personal sexual
Interrogatory
inappropriate
about
relationship any
information sexual
No
has
22
information
intimate
or current
romantic
or
relations
any
nature
is
she
ever
had with
any
former
information
directly
of her Complaint
Plaintiffs
Responses
toWNSTs
Document
Requests
To
date
us with
any documents
to
responsive
to
WNSTs
that
requests
On
June
2011
Dismiss we asked
Ms
Moylan
she send or those
about
the requested
documents
right
she advised
your office
received
We
requested Please
us those
documents
to
away
To date we have
not
them
documents
us or send
them overnight
Ms
awaiting
Moylan
further
advised
during
our
June
discussion
are to
that
your
law firm
is
still
responsive
documents
from
that
Ms
Royle
Ms
for
Royle
parties
As you be prepared
aware
and
as
am
exchange
in
documents
to
by
the
deadline
in
responding
that
request
will
for
production
Accordingly
addition
all
your
possession
you
produce June
further
documents
Court with
by no
later
than
Thursday
avoid
our
having
to
inconvenience
discovery
motion practice
Mr
June
Brian 2011
Goodman
Esq
Page
to
Ms
Royles
written
responses
they
are
evasive
and incomplete
tinder
the following
deficiencies
Failure to concurrently
Provide
Privilege
privilege
Log
log and
Ms
the
Royle objects
with
are
on the basis of
instructions to
privilege
without
submitting
privilege are
consistent
the
law
Without documents
Specifically and/or
log
Defendants
Court or not
are
unable
determine
specific
being
withheld
asserts
and
that
whether
Ms
Royles
objections
appropriate
privilege
Ms
Royle
documents
to
protected
by the
attorney-client
work-product
Document
and
Request
Nos
Shield
16 17 Law
in
18 19 20 21 22 23 24 25 26 27 28 29 30 31
responses to Document
32
her
Request
Nos
9-14
Document
whether any
Request
No
The
exist
response
provides
an
objection
but
does
not
indicate
responsive
documents
Document
assertion possession
all
Request
No
For
Ms
between
Royles
objection Defendants
is
misplaced
are
Contrary
the large
to
her
communications
not
within
Defendants number
of
custody
and control
that
do not possess
they
to are
Ms Ms
Royles Tweets
@WNST
for to
and
on Twitter
suggest
that
Further
Ms
Royles
interrogatories
and requests
admission
the
Royle believes
are
is
she
asked
the Defendants
stop publishing
in that
statements
particularly
all
concerning
if
her yet
her in and
unaware
required
of any communications
under
this
regard
these
made by
documents
She
request
to
provide
and
other
communications between
Document communications
Request
between
No Ms
to
Ms
Royle
Royles objection
third parties
to
this
request
also
is
misplaced
not within
All
the
and
about
her
is
lawsuit not
are
Defendants possession
the contrary
it
custody
or control
Further
the request
overly burdensome
To
is
confined
Document
nonresponsive
characterization as
Request they of
the refer
Nos
21 22 23
to
and
26
Ms
Royles
responses
are
WNST
Exhibit
to
her interrogatory
responsesMs
than
Royles
the
is
alleged
statements
that
made
by
Defendantsrather
producing
documents
required to
supporting provide
are
these statements
in
were
in
fact
made
nature
The
with
plaintiff
the
litigation
of this
the
precise in in
words
Exhibit
that
allegedly than
and defamatory
the
Ms
Royles
of statements
rather
providing
statements
themselves
discovery
Request
to In
Nos
and 34
Ms
set
Royles objection
are
is
misplaced
here as well
All
relevant control
her the
activities
on Twitter
not
within
the
Defendants
possession
request
WNST
this
forth in
specific
electronic
non-burdensome
format
at
means by which
to
Ms
than
her entire
faith
history relevant
no
cost
her
Rather
to
good
with
and reasonable
request
Ms
Royle
refuses
Mr
June
Brian
Goodman Esq
92011
Page
produce
to
single
Tweet
Moreover
does
Ms
Royles
statement
that
she uses
daily pursuant
not relieve
Document Maryland
fails to
Request
Nos
fails to
through
assert
14
Ms
objects
on
the
basis
of the Royle
Shield
Law
court
but
whether such
the
do
Ms
submit
privilege
instructions
and Maryland
of any
law
Without
such
WNST Ms Royles
Baltimore
clearly
and
the
are unable to
the sufficiency
states solely to that
Moreover
to the
answer
Interrogatory
that
No
relates
she
prepared
raised
Ravens
organization
fall
an
incident
by her
lawsuit
which
would not
within
Law
is
Document
as are
Request
to
No 32
Ms
all
on relevance
misplaced of the
here
well
not
Contrary within
is
her assertion
communications custody
of
public
the
clearly
Defendants
relevant issue
to
possession
the
control
Obviously and
the
Ms
request
Royles
seeks
reputation
allegations
Complaint
documents
related
to that
Document
information
Request
No 33
Facebook
Contrary
profile
to
is
Ms
directly
Royles
relevant
boilerplate to
objection
raised in
the
contained Like
on her Facebook
the
issues
her
to
Complaint
access
all
provides
an
easy cost-free
including logged
to
and non-burdensome
status
method
information
on
Ms
tab
Royles
account
updates
messages
photos
should
listing select
of friends
the
etc
Specifically followed
when
by
the
onto
her Facebook
account
Ms
Royle
Account
Account
hit
Settings
tab followed
button
by
selecting entire
Download
account
will
your
Information
Ms
the
Download
and her
compiled by Facebook
and emailed
has on record
We
look
forward
to
and document
these objections
all
ten
10
days
of this letter
to
We
add
to
has
If
further
responded
her discovery
obligations
including
to
providing
responsive
documents
contact us
Very
truly
yours
HOLLAND
KNIGHT
LLP
Charles
Tobin
cc
Drew Shenkman
Esq
Holland
Knight
LLP
EXHIBIT
Plaintiffs
Revised Exhibit
EXHIBIT
PRDR00000I
HPK/ROYLEv.WNST
ROYLE
NASTY
Circuit
1570
SPORTS
LLC et
Court
for Baltimore
City
Case
2/24/2010
his
No
24-C-i 1-001571
Jen Royle
On
lists
as
number For
in
Media Members
We Wouldnt Mind
fiom
Seeing
Suspended
ESPN
of the top
sports
few weeks
Drews
List
Show Tuesday
For
Top
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Media Members
available
at
We Wouldnt Mind
Seeing
Suspended
Few Weeks
http //wnst.net/wordpress/glennclark/20
0/02/24/comcast-morning-
show-top-7-sport-media-members-we-want-to-see-suspendedl
4/7/20
10
that
Ms
Royle
is
on notice
that
she
is
up
for the
Apologist
Morning
award
regarding
the Orioles
Mike Gonzalez was TERRIBLE last night It wasnt all his fault but was TERRIBLE Hence Chris Stoner won our first Apologist of the
Morning
was the award from Drew Forrester and myself But She
said
he
Im putting
finish .500
Jenn
Royle on notice
last
compete
to
if
that
of Gonzalezs
Izturis
struggles
to get hits every
And
if
Cesar
manages
game
instead of
they
might be
better
than
that
Glenn Clark Glenn Clarks Blog Wednesday Mornings Crabs and Beer
available
at
http //wnst.net/wordpress/glennclark/20
10/04/07/wednesday-
mornings-crabs-and-beer-96/
4/23/2010
Ms
Royles commentary
record
He congratulates
The
Morning award
for
APs
David
Ginsburg says
Adam Jones
choose
to
wants
be role modeF
Adam Jones
actually
would
be .good
role
model
to other
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by
PRDR000002
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And
before
we
leave
to Jen
for being
Morning
something
Her
included 14 of
the last
To
me
lose
of 2-14..
to
just isn
adding
course
up
is
quote
is
myfavorite
Durham
the
good
friend
of mine used
the
it
say
This
very simple
game
You throw
ball
you
hit the
rains
Think
about
for
while
LaLoosh
better
Ebby
Calvin
Nuke
entire
city of
as well
movies
as the
huh
of
would
For example
things
were
as
simple
movies Id
be with
Mila Kunis.
available
at
10/04/23/friday-mornings-crabs-and-beer-
90/
4/26/2010
stereotypical
On
his
blog Drew
she
is
Ms
Royles
that
hiring
was
is
because
an out-of-towner
He
that
later states
she
not
and
insinuates
she frequents
hang outs of
Yankees
outfielder
Nick
is
Swisher
Jen
duties
Royle
the
new
0s
beat reporter
for the
teams
flagship to
105.7
In typical
Fan Fashion
the
of covering
team
In
fairness
.no
if
youre Shes
going
to hire
beat
offense
Casey
not equipped to even ask
What
ask
will Jen
Royle
ask
MacPhail
fan
in
Answer Maybe
anything shes
to the
Yankees
she can
MacPhail
heard
if
hes
ever
been of
Manhattan
think
Swishs
hang
outs
Blog
at
It
Drew
Forrester
Drew
Forresters available
takes
run
flag
http //wnst.net/wordpress/drewforrester/20
0/04/26/it-takes-20-minutes-orioles-
shouldnt-run-from-the-challenge-flag/
247747-I
PRDR000003
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5/3/20
10
that
Jen Royle
was
to
win
The
Orioles Apologist
Month
which
He
seems
also to
states
she
is
up
for
comparable
mock
her
New York
included
as
The
nominees
for
Apologist
of the
Months
Yankees
Apologist
-Jen Royle
of the
Morning
is
winners
and nominees
for
who
also
nominated
apologist
of the
month
.1
BUT..
None
of them were ready
to
claim
major championship
of the
Month
Is..
httpwnst
networdpress/glennclarkl2O
10/05/03/the-orioles-
apologist-of-the-month-is
5/12/2010
On
day
his
blog
Glenn Clark
ridicules that
statement she
made by
Ms
Royle
in
her commentary
earlier that
of the Orioles
He
notes
won
Apologist
of the
Morning
0s
on farm
the Orioles
And
Great
first
we move on from
to our
few things..
A-Congratulations Arbitrator on
Apologist
of the
Morning
Morning
as selected
by The
It
Reaction
isnt the
award
from her
You
really
think the
problems Compared
he
to the
Mariners
they
don
.Cliff
Hmm
The
not
Lee
last
night-was
problem
for the
Mariners Or for
the
Orioles
statement
is
obviously
ludicrous
The
as
many if
MORE
problems than
the Mariners
z..
Glenn Clarks Blog Wednesday Mornings Crabs and Beer available
http //wnst.net/wordpress/glennclarkl2O
at
10/05
2/wednesday-mornings-crabs-and-
beer- 10
5/18/2010
Glenn Clark
states
in his blog
that
Ms
Royles
description of
game
was
irrelevant
He
notes that
she once
again
won
the Apologist
of the
Morning
247747-1
PRDR000004
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Great Arbitrator
to
Sgt
Jen
AGAIN
105.7..
selected by
The
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of the
Morning Drew
new manager
for these
thoughts
Kansas
game and
listened
to their
Ned
Yost
compliment
Butler
who when
2-for-4 with
their
RBI
doesn
help
in
the
it
would
have been
relevant
Wow
available
at
10/05/18/tuesday-mornings-crabs-and-
beer-97/
5/19/20
10
that
Ms
Royles
description of an Orioles
game
she
was wrong
is
He
later analogizes
her to
disaster The
He
states that
APs
David
Ginsburg
up Royals
bullpen
after Creinke
win
over
at
No
the
beat
cough
is
Zack
said
105.7
cough
They
did however
win
game
started
by Zack
Greinke which
Edit from
similar to
GMC
Some
how many
as
of us are obsessed
that
Snooki
disaster
how
away
The
reality is
much
say
probably
REALLY dont
want her
to
at
10/05/19/wednesday-mornings-crabs-and-
beer-i
02/
10
as
6/2/20
On
The
his
blog
Glenn Clark
loss
mocks
Ms
Royles
description of an Orioles
game
heartbreaking
says
Tejada
made
fell
to
Yankees
New York
described
it
Our
girl
Jen Royle
as
losses
of
the season
The
rest of us barely to
even noticed
getting in
happened
close
was
my
car to go check
247747-I
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which
at
The Avenue
in
heartbreaking
was
Orioles Baseball
2010
at
10/06/02/wednesday-mornings-crabs-and-
beer-i
04/ link
to
http//sports
.wnst.net/mlb/recap.asp1
MLB
Ryan
Chell
gMLBg30060
111
0refrectrn
src
mocks
of the
Ms
Royle
as
Apologist
Morning
out the Apologist Jen of the
653-Giving
between
Morning
award
It
was
50-50 shot
the great
Royle
or
first-time
candidate
pulls the
listener
Allen
McCallum
upset
and wins
it. .congratulations
of the Morning
award
Ryan Chell
Chellin
Out Wednesday on
The
Morning
Reaction
available
at
http //wnst.net/wordpress/ryanchell87/20
10/06/02/wednesday-on-the-morning-
reactionl
6/5/20
10 Glenn Clark
tweets
GMC
Game
Tweet
local
journalist
in
town whose
is
apparently
playing
in
Celebrity Softball
With
Ravensplayer
by
name
they cant
spell
copied
Ms
6/9/1020
Ryan
Chell once
against
mocks
Ms
of the
Morning
Trying to give out the Apologist MASN/105.7 the Fan employees
wins
for the article
of the Morning
in
Two
of
the
nominees
are
Jen Royle
and
Rock Kubatko
Kubatko
he wrote
last
night for
MASN
Sports
Reaction
available
at
Ryan Chell
Chellin
Out Wednesday
to
on
The
Morning
http //wnst.net/wordpress/ryanchell87/20
10/06/09/wednesday-on-the-morning-
reaction-2/
link goes
http//w-ww.masnsports arent-enough.html
.com/school
of
rochl2o
0/06/when-7-runs-and-
15-hits-
8/5/2010
Casey Willet
just
co-worker and
her on the
air
CBS employee
morning and
she
that
notifies are
Ms
Royle
that
Glenn Clark
ripped
that
now
calling the
Ms
Ravens
Royle Jen
Midol Comments
included
knew
nothing
about
247747-1
PRDR00000G
HPK/ROYLEv.WN5T
know
that
she
knew who
the
right
fielder of the
Yankees
was Nick
Ravens
Swisher.1
9/7/2010
During
practice
Ms
Royle claims
that
that
Glenn Clark
told
co-worker
Damon
Yaffe
she
experience
my
credentials/
saw
have
be covering
to her
the
Ravens
is
brutal
listening
and inquired
why CBS
Patrick
better
to cover
the
Ravens
to
Letter to Ravens
sent
by Jen Royle
Baltimore
Chad
Steele
Ravens
Organization
in late
2010
Drew
about
her
called
Glenn
front
JenRoyleMASN
thought her
me
douchebag
meant
in
working
for the
Yankees
class..
Ms Royle
Clark
alleges to think
comment was
not in front of
anyone
Glenn
And
JenRoyleMASN
be considered
is
me
say that
trashy
do know
at
the Gold
Club
Drew
truth
Tweets
cut
dont know
is
if
Glenn
D-Bag
but
this..
those boots
JenRoyleMASN
and copied
wearing
are
from Twitter
into
letter
to Ravens.2
Copies
in letter
to
Ravens
Ms
Ms Royle
Mr
to
day him
his tweet
Mr
by the
Clark
and
told
was Crossing
the line
Ms
Mr
Clark
and yelled
Where
are
your
boots
Ms
first
Royle Asked
is
Mr
No This
then
Clark to step
outside
with
said
Drew
to talk
place
let
Drew
then
Go
home and
on
come
and
me
buy you
drink
of
media
member
looks
Jon
Gallo
CBS
Sportsline including
informed
Ms
Royle
stripper
Shes
complete
idiot
And Drew
Available
\ViIlit Letter to
Forrester
made
website
the
comment
with
Id
boots
Casey
on
the
Defendant
WN5Ts
in
Persons
personal
Ravens
from
sometime
Mid-september of 2010
247747-1
PRDR000007
HPK/ROYLEv.WN5T
Letter to
Ravens
Jon
Gallo
also
confronted
PR
staff
and said
like to
If you dont
have
tell
WNST
to
about
Royle
would
my seat changed
9/20/2010
CJ
Spiller blogs
on
WNST
Jen
Good
Royle
media
high school
Jen we
understand
in
New York
talk like
Jersey
reporter on
from CJ
Spiller blog
WNST.3
with
at
9/21/2010
After
brief encounter
Drew
water
Forrester cooler
at
the Ravens
facility
where
Ms
the
Drew
Ms
she
Royles
walked
space
how
she
was
away Drew
you want
to
Forrester then
Dont
Drew
know how
am Ms Royle
yelled
you going
Not
really
girl
is
lucky
snapped
her head
my off
real
in yet or
would
have
He
then tweets
It was
she
definitely to
water-cooler
spoke
me
But
shocked
at
the
way
Next he tweets
Miss He
He
also
America
that
has
left
the building
without
apologizing
to
me
tweeted
her
fUrther
two
favorite
teams
the Yankees
and
Rays
.1
tweets
lost
power
at
WNST
about
40 minutes
ago Rumor
hee
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someone
saw
away from
the building
hee
Jen
Copied
.LOL
10
by Jen Royle
Blog no longer
longer
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available
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247747-1
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On
or about
10/1/201
Drew
Forrester leaned
far
back
at the
Ravens
facility in
Owings was
Ms
her legs
Mr
Forrester conference
Ms
Royle witnessed
room when
Ms
Mr
to
Clark
Dont
say anything
Glenn
We
dont want
to get
again Upon
at
commencement
legs as she
Ms
Royles
Ms
of this occurrence
Drew
tweet
fan jokingly
Steelers
encouraging
Jen to
kill
game
game
at
appeared
Drews
jab
that
the
that
home
to kill
it
one
wasnt
of her joke
critics authored
It
herself
It
came
stress to
across
serious
is
that
way
in
her
or
response
implore
cant someone
how wrong
their
for
anyone
EVER Mud
encourage
end
life
available
at
Drew
Forresters
http //wnst.net/wordpress/drewforrester/20
10/10/08/coat-your-big-apple-with-
some-friday-mud
11/18/2010 appears
to
Drew
be
fans
wont
as
Royle
This
joke that
of herself
Fullerton
Come
Morning
one come
Reaction
Pub
with
tonight the
at
hosts
Rub
Elbows
Stars
And no
It
that
to
means
of
were
going
to
meet
YOU
YOU
the
real
stars
WNST
Drew
radio and
WNST.net
Blog Tonights
at
Drew
begins
Forrester
at
Forresters
the night
Our canned
food
drive
The
Fullerton
Pub
available
hap wnst.networdpress/drewforrester/20
food-drive-begins-at-the-fullerton-pub
10/1
1/1 8/tonights-the-night-our-canned-
11/26/2010
Drew
further
Ms
is
Royle
is
not
in
fan of Baltimore
outfielder
sports
she
interested
Yankees
Nick
247747-1
PRDR000009
HPK/ROYLEv.WN5T
Its
no
secret
that
one of our
local
isnt
fan of passed
Baltimore along
sports
teams
And
because
known here
questions take
questionaire
to her with If
some
One
of the
you out on date and try to earn your affection what would you want him to wear She sucker for wrote man in uniform so heres what Well Ive always been
questions was this
you could
ever have
handsome man
Id
Drew
like
him
to look
like
Forresters
Mud
available
at
http /wnst.net/wordpress/drewforrester/20
10/11 /26/stuff-yourself-with-fridayat
mud
link goes
to
picture of Nick
Swisher
http//www.zimbio.com/pictures/d3hjwdZ1
pYelBostonRedSoxvNewY
ork
YankeesyXBAZYPbiQY/Nick
FSwisher
12/27/2010
Drew
tweets
that
is
suspicious
that
Jen
received
WNST
text
during
press conference
which he
finds
humorous
text
RT @WNST
conference
Drew
WNST
looked
at
press
at
and
she
town
her
cell
looked
mine
media
LOL @WNST
folks in are
Drew At least we now know some of the other fans ahem of the WNST text service hehe
twitter.5
12/29/2010
Drew
for
2010
and says
No
longer
available
on
10
247747-I
PRDR0000I
HPK/ROYLEv.WN5T
coming
to
town
like
bull in
china
shop and
she got
Drew
Forrester
Royle And the vote wasnt close Next topic Drew Forresters Blog My Best of the Best in 2010
at http //wnst.net/wordpress/drewforrester/20
Dec 29
2010 available
the-best-
10/12/29/my-best-of-
in-20 10/
Several
comments on
the blog
Forresters
comments
affected
people
Steve
Oh
and while
have
to garner
the
Royle Whats her deal and hate Dont really know much about her..
us on Jen Jen
DF
Shes
Hatebad word No
an out of towner
one
HATES
Royle
the place
dont know
her deal
who
showed
up here
earlier in the
year and
immediately started
talking about
how much
sucks
at
102
pm
Baltimore .She has
to
Man
dogged
it
DF Brian
anyone
attention
Tom.
If
you What
up on
it
did she
actually
say
to
specifically
dogged youre
Baltimore
and everyone
you havent
picked
not paying
Stanton
Salter
at
1207
pm
radio talk-show
his
of
local
sports
host bashing
the
very
of one of
ripping the
employers
sponsors
WNSTS
Preakness
Forrester completely
Maryland
Jockey Clubs
in attendance
On
so the
slogan Preakness
slogan
had about
100000
once again
in
worked
negative
stooped
to this level
by posting
however Your
here about
Jen
is
Royle reminded
this.
me
you
of how unprofessional
to criticize
you
times
My
question
to learn
.Who
are
new
make
young
talent
town trying
arrival
Perhaps
she
did
least deserves
comfortable
for
in her
new
surroundings
it
You
other
hand have
been here
247747-I
PRDR0000I
HPK/ROYLEv.WNST
Baltimore
traditions
such
the
as the
0s
and Marylands
largest
sporting event
sticking
new
kid in
town
at
1259
pm
bunch of other Baltimore Did
reporters that
literally
stood
around
and
talked about
how much
really
happen
so
Ive
ever heard
It
is
interesting
to
much
of an affect
on you
that
you
were inclined
to include Interesting
review
is
to call her
indeed
DF Anyone
10/1
who
critical
of
an affect
Drew
Forrester
Drew
in
2010
available
at
http//wnst.net/wordpress/drewforrester/20
2/29/my-best-of-the-best-
in-20 10/
1/2011 nothing
Drew
but
Forrester sends
series
of tweets
she
is
saying that
shed
look great
tourist
in
Nick
Swisher
vacation
shirt
and
that
stuck-up snobby
that
on
here
Nestor tweets
she was
she
is
ignorant
and clueless
her bosses
who
thought
qualified
@WNST
at
Drew
So
Im
handling
@mattvensel
WNST.net
Hell
get
it .she
good nonetheless
@WNST
great in
@NoTjenrolemasn
Swisher
shirt
@ienrolemasn
else
Drew Well
bet
youd
look
Nick
and nothing
LOL
you know where
is.
to
@WNST
find
yoitschad
A-Rod
@JenRoyleMASN Drew Im
you were wearing yesterday
exhausted smelled
trying
to figure
You
fantastic
@WNST
youre
is
stuck-up snobby
on
brief professional
here
COMICAL too
12
247747-1
PRDR0000I
HPK/ROYLEvWNST
@WNST
of-town
Nester
When Ravens
season
are
ends
Ill
engage w/ignorant
out-
genius
journalists who
clueless
For
now Im purple
focused
@WNST
Renegade
qualified
KIND
to
Miss Yes
Jen
in corporate
bosses
who
though
Mr Yeah theyre
twitter.6
1/11/2011
Drew
Forrester tweets
that
Jen Royle
is
just
tourist in
Baltimore
@WNST
Thats
her
Drew LOL that Jen Royle thinks Im OPINION Heres my FACT Jen an
is
obsessed
with
he
tourist
out-of-towner
twitter.7
his
agreement with
that
assertion
Drew
@WNST
Baltimore
Sparky4ddub and
try to
tell
Drew Well
out-of-towners
sports is..
who come
to
ME
about
Baltimore
using your
word
.annoying
@WNST GMC
to
Im
glad
let
Drew
it
well Kudos
him
Drew
Forrester Out-of-towners
@WNST
to pick
beware.
.this
isnt
good week
on Baltimore http//bit.ly.fK3hnI-l
@WNST
Drew Hey
worries..
@DamStone JenRoyleMASN @1
its just like pro wrestling
O57TheFan
role to
@matt\ensel play
We
all
have
No
twitter.8
Glenn coming
also
posts
blog
in
which
he
states that
Ms
flames since
to Baltimore
and
that
he thinks
she has
good
Jen
Royle has been fanning the flames since the day she graced
last
us with
that
her
presence
spring
And
in
FULL
disclosure
at
have
the
to admit
she
SMELLED
6No No No
longer longer longer
available available available
like
million dollars
yesterday
Ravens
press conference
on on on
247747-I
PRDR0000I
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she
literally
did grace
us with
whatever
she was
was glorious
When
Quick
you
arrive
in Baltimore
to
work
where
wasnt
said
that
It
No
it
Matusz
Love
Ravens
with
know
won
the Super
that
Bowl and
who was
so impressed
our
he bought
into
station
beware.
.this
Drew week
Forrester
to pick
at
Blog
Out-of-towners
isnt
good
on Baltimore
http //wnst.net/wordpress/drewforrester/20
available
11/01
11 /out-of-towners
bewarethis-isnt-a-good-week-to-pick-on-baltimore/
Drew
then
comments
that
Ms
Royle
prefers
is
just in Baltimore
on
scholarship
As
for that
girl
at
how much
sunset
Sabatinos and
is
of the
matter
that
from
now
her apartment
or
be occupied
and
shell be in Chicago
ritzy place
where her
pretty
some
EDIT from DF
ferocious anything baseball Baltimore but
at
535pm
Since
posted
this
into
Twitter attack
claiming
among
talk
other things
Ill never
cries
be
his
show
host
who
over
in
team
to be
lot
about claiming
is
something
since she
on
the
ahem
left
YES Network
to be
in
2009
in
but chose
Baltimore
because
it gives
me
the
chance
big fish
SMALL pond
Drew
Forresters
Drew week
Forrester
to pick
Blog
at
Out-of-towners
beware
.this
isnt
good
on Baltimore
available
http //wnst.net/wordpress/drewforrester/20
11/01
11 /out-of-towners-bewarethis
isnt-a-good-week-to-pick-on-baltimore/2/
In
tweet
is
Drew
that
to
Ms
Royle when he
she
upset
the Patriots
14
247747-1
PRDR0000I4
HPK/ROYLEv.WNST
@WNST
the
Drew Somewhere
feel
tonight
certain
local
journalist
is
down
in
dumps
bad
for
her Really
do
do Really
Copied
1/20/2011
conflict
Dave Hughes
of
interest for
answers
question
on
DCRTV.com
on
the
that
it
would be
for
Ms
Royle
to date
player
MASN
available
The
question
he responded
that
to stated
people
MASN
Likely on
an Orioles pitcher
http//www.dcrtv.com/davetvl
to confirm
1/21/2011
Drew
link
is
link
2010
The
sign saying
sign Welcome to
to
that
ruined
Ms
Royles
Baltimore
The
Drew
Jen Royles
entire
2010
is is
RIGI IT
better
Hon hERE
day
at
Forrester
Drew
at
Forresters
Blog
Friday
Mud
than
the
beach available
http //wnst.net/wordpress/drewforrester/20
11/01/21/friday-
mud-is-better-than-a-day-at-the-beach
http
link
to 10/1
//www.baltimorebrew
2/honto
welcome-to-baltimore-katrina-krauss
sign saying
Welcome
Baltimore
Hon
Drew
Forrester states in response
that also to
1/26/2011
comments on
his blog
is
that
the
only qualification
Ms
Royle has
to be in Baltimore
Magazine
that
she she
works here
He
way
why
Al
How
Says
26th 2011
at
January
848 am
Baltimore
Magazine
be for promoting
eligible
certain
sports
singles Shouldnt
or an
should
actually
be from Baltimore
member
of the Baltimore
Second
friends horrible
question
When
said
all
her
to include
how
up the
picture
Magazine
offer
community
Perhaps
of their mistake
waited
until the
add
her
travel issue to highlight
all
they shouldve
spring
of
town
9No
longer
to
available
on on
be
verified
sound Video
clip no 15
printout
247747-1
PRDR0000I
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DF
our
This
is
question
better
suited
is
Magazine
and
their
selection
committee
My
guess
you
WORK
in
Baltimore
youre
eligible
havent
sexy
singles so
sticker.
you know
what
mean
by far
Kristen January
Says
26th 2011
at
1149 am
actually
Drew Have
you ever
or
do you
to
female
and
according
always smells
sports
really nice
which
of saying
she doesnt
you know
but because
job
like
doesnt give
why
DF
Youre funny
occasions
Each
think she
said
knows
is
sports
that
she doesnt
NEVER once said she didnt know know BALTIMORE And because
at all
What Ive
she has
no
historical
My
remarks about
how
great
.those
COMPLIMENTS
Youd
admit
have
of athletes Thats
why she insists on smelling that for me to decide But she always
Blog Back
in the saddle
around
like
bunch winner
smells
that
Drew
Forresters going
to
Drew
Forrester
again 21 Questions
at
1-
Returns
Update Were
OVERRRRR-TIME
available
http//wnst.networdpress/drewforrester/20 questions-returns
11/01 /26/back-in-the-saddle-again-2
1/28/2011-
Drew
to
that
Baltimores own
outfit
Jen
Royle
showed
up
photo
Nick
Swisher
By now Im sure
Baltimore
as
nearly
of you have
features
picked
up the
latest
copy of
Magazine
which
Baltimores own
Jen
Royle of
MASN
her an
Sexy Singles
at
Evidently
well
outfit that
When
she arrived
the location
the magazine
handed
and asked
her to get
But
something
allow
SHOOT
16
247747-1
PRDR0000I
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Drew
Forrester
at
Drew
Forresters
Blog
Mud
is
available
http //wnst.net/wordpress/drewforrester/20
11/01/28/just-in-the-nick-
of-time-its-friday-mud available
at
link provided
shows Nick
Swish
outfit
below
and
http//product.images.fansedge.com32-3
0/32-303
54-F.jpg
In the
comments
to the
blog
someone
responds
that
on January
could
29t1
it
to insults
about
Jen
Forrester responds
she
handle
29th 2011
at
1130 am
royle stuff
is
funny along
with
everything
tail
else
but
also
definitely totally
on
her
on her
for
pull
brett
my
advice but do
it
from
DF
you
Whatever.
for
.shes
to
from Boston.
crush
.she
can
handle
little
chiding
Theres
no reason
actually
on anyone Im married And trust me once meet her the crush-thing ends Shes boorish snobby and
me
have
caustic
Other
that
that shes
real
peach
of time its Friday
Drew
Forrester
at
Drew
Forresters
Blog
Mud
available
http//wnst.net/wordpress/drewforrester/20
11/01/28/just-in-the-nick-
of-time-its-friday-mud/
2/04/2011
that
Ms
for
Royle needs
picture
nickname
of the
suggesting
Jenny-Poo
settling
on
link to
New Yorker
baseball year in
all
Our
prepping
season
of outstanding
coverage
MASN
like
and
now
that
shes embarking
on her second
considered
Baltimore
natural
nickname
or
of the
ones
Jenny-poo Jen-Jen
17
Roysie
However
none of
247747-1
PRDR0000I
HPK/ROYLEv.WNST
those
fits
were
as
appropriate
as
THIS
NICKNAME
The
Great
for
her
Hey.
.if
the shoe
Drew
Forrester
right Drew
Forresters
at
Blog
Friday
Mud
is
the
preferred
nomenclature available
http//wnst.net/wordpress/drewforrester/20
11/02/04/the-
great-friday-mud-is-the-preferred-nomenclature
http
link
to
0/09/new-yorker-ipad
.jpg
picture
New
Yorker displayed
on it
2/22/2011
is
comments
pretty
that
the
only reason
that
is
Ms
is
because
face
and breasts
she
Ms
Royle
woman.1
3/30/2011
Nestor can
You
truth
search
shred of evidence
weve We
ever
you like and you will not find done anything more than tell the
behavior
in social
skills
media
and
Owings
Mills
literally
pronouncements would
media
that
quite
frankly
ex employee
And yes
do
the
WNST
of people
in Baltimore
feelings
quite
fighter based
that
we
work
Her
blog reiterates
on
daily basis
jerks Baltimorons
public
just like this
and blog
the
like
You
can
check
it
Its quite
Apparently
Perhaps
like its
to sue
us here
at
WNST.net
its because she feels
extract
were
in the
direct local
competitor perhaps
name us
some money
dealing
loser
out of
this
Win
or lose
attorney
fees
and
my time
case
Not
spent
with
nonsense
will certainly
be draining of this
my
piggy bank so
Im
beginning
today
frivolous
But
to spread
vicious
me
Not
this staff
EVER
at
my reaction
is
to
anyone
in
my professional
me
advice
guilt
settle
lawsuit that
where there
none
Text
message
from stranger
18
247747-I
PRDR0000I
HPK/ROYLEv.WNST
Ive been
on
the
doing
this for
27 years
spread
as
professional
internet
We
dont
able to
rumors
to
were
But
unabashedly
own up
at
WNST.net
is
were
also
not strangers
marketplace
every
day and
you
why
and proving
If
every
tell
and accountability
expect
we dont
to talent
how
good
we
are
we
certainly
dont
do
it into
And when
marketplace Especially
our competitors
bring inferior
it
the
were
going
to point
out
brazen
to the
Yankees
serving I.
.1
when any media member would be so and Red Sox and so openly disrespectftil
the community
that
is literally
about
loving
the
community
theyre
feeding
them
No We
do
one
at
WNST.net
close
has
suggest
Not even
said
Jennifer Royle
doesnt know
as
much
about Baltimore
sports
as
we
We
said shes
lacking
which
if youve
followed
youd
see
to that
conclusion
to
Shes
She has
fan page on
She chooses
go on
culture
And
she
Baltimoreans
and
local
day of her
life
on the internet
The
truth
is
this is
frivolous
case filed by
woman who
is
trying
to
come
to Baltimore
and make
name
for
company
arrived hurt and
in Baltimore
weve
known
since the
Shes
is
not
Baltimore
to injure
now
trying
WNST
employees
and fans
by trying
Nestor
to take
money from
Royle
my company
An
indictment of local
at
Aparicio Nestor
our side
Aparicios Blog
journalism
Heres
of baseless
WNST
lawsuit available
http //wnst.net/wordpress/nestoraparicio/20
11/03/30/an-indictment-of-local-
journalism-here%E2%80%99s-our-side-of-baseless-royle-v-wnst-lawsuit/
4/18/2011
Drew
Forrester tweets
that
when
Ms
Mayor
he was
of Baltimore
who
19
that
the
cx
know who
because
247747-1
PRDR0000I
HPK/ROYLEv.WNST
@WNST
Drew Somewhere
Schaefer
tonight
local
sports
reporter
was
William Donald
passed
away and
the response
was
who
told
5/4/2011
Personal
tweet
From @GlennClarkwNST
@CL_
Copied from
@BaltimoreLuke
Im 100%
certain
Ill
Ill
regret
fun
get sued
again
by Jen
Royle
6/4/2011 Baltimore
Glenn blogs
Sports Expert
fact that
in
honor
what he considers
In
honor of the
the
FM
sports
station
in
town had
Towson
University yesterday
we
thought
wed
put together
this
for our
Tuesday
Top
which came on
Wednesday
week
Todays Tuesday
Consider Yourself
Top
topic was
The Top
Things
You Need To Do To
hope its
self
Baltimore
Sports
Expert As always
Reaction
Top
Things
at
You
Need To Do To Consider
Yourself
Baltimore
Sports
Expert
available
http //wnst.net/wordpress/glennclark/20
11 /05/25/morning-reaction-tuesday-top-7-
things-you-need-to-do-to-consider-yourself-a-baltimore-sports-expert/
6/10/2011
is
Drew
Forrester blogs
insulting
that
Jen Royle
unintelligent
Speaking
allowed Stanley
the
of
Boston
Im
quite
pained
by the having
fact
that
the Canucks
have
Bruins
back
in the series
it
won Game
and
of the
Cup
Finals to even
up
at
2-games apiece
know
.trust
me
even
know
The
Anytime someone
its
experiences
morsel of success
disheartening
They dont
out of that
deserve
anything
only acceptable
things to
come
hell-hole are
Curtis
Damon The
his
where
Everyone
that
Strange
two
U.S Opens
Well
else. .sucks
OK
need
to take
back
record
PART
of Bostons
heritage didnt
suck
For the
12No longer
available available
on on
twitter
twitter
In
correspondence
folder
No
longer
20
247747-1
PRDR00002O
HPKIROYLEvWNST
Im sure
and
will
youve
heard
by
now
that
Mark Viviano
his duties
is
leaving
sports citizen
his post at
105.7
now
side
concentrate
solely
on
as the solid
anchor
at
Channel
13
On
.and
note
Ill
mention
his
is
that
Mark
is
and
good
guy.
hope he enjoys
new
life sports
Anyway Vivianos
talk
departure means
The Fan
looking
new
host
As
is
Im hearing
As
has
to
rumors
their
and theyre
just that
rumors
about
for
replacement
become come
it
custom
105.7
someone
out-of-state
in
and
wow
everyone with
their search
knowledge
Carolina
flying
Rumor
and
that
is
has
theyve
centered
on
THIS GIRL
RIGHT HERE
to take
passed
her interview
talk .but
colors
and
over
Vivs
show
gig
of
Drew
Friday
Forrester
Drew
Forresters
Blog Hit
at
this edition
Mud
http //wnst.net/wordpress/drewforrester/20
11/06/1
0/hit-records-are-shortbut-this-
edition-of-friday-mud-sure-isnt/
first link to
video
of the
the
1986 World
http to
Series
available
at
//www.youtube
video
.comlwatchvghQ VU12T
giving
8Efeaturerelated
link
of
girl
bad answer
in
Miss Teen
USA
available
http//www.youtube.comlwatchv1j3
iNxZ8Dww
blog states that Jen Royle references
are
Comment on Drew
Forresters
common
Mike
June
10th 2011
921 am
The
Finding
the Royle
references
in
Mud
is
like finding
the toy
in the
cereal
box Love it
think with
DF
Huh
To borrow
think
line
from Bull
Meat
just pitch
youre
thinking too
it
Drew Foresters Blog Hit
at
Drew
Friday
Forrester
records are
short
of
Mud
http//wnst
net/wordpress/drewforrester/20
11/06/1
0/hit-records-are-shortbut-this-
edition-of-friday-mud-sure-isnt/
About
6/11/2011
Ms
Royle contacts
he had
reliable
Greg Bader
source
to
complain
that
Glenn
Forrester told
that
reporters
who
told
him
Ms Royle had relationship with player Hi Greg Sorry to BOTHER you with this.. But Drew
was sleeping
in the
Forester
it
told
some
reporters
with
Matusz and
guarantee
is
now
is
saying going
came from
throw
that
reliable
source
the
warehouse
Drew
21
to
source
under
247747-
PRDR000021
HPK/ROYLEv.WNST
bus
in court to
is
make
Any
idea
who
this
warehouse
source
part
in putting this
ridiculous
rest
Again Tm
but
its
very very
and
if
you know
very disheartening
directly
and disturbing
these kind
come
especially
when
MA SN
Thank
you
Jen
Email from Jen Royle
Mr
Bader
replies that
there
was
real
source
doubt
would
love to
know who
this
supposed source
is
he has one
No
it
one
spread
it
such
rumor
wouldnt
Monica
about
and
she doesnt
know where
in spring
to her after
Brian
and
spoke and
training
tolerate
mongering
doubt
is
specifically
mentioned
this
doing
whatever
she can
of false
am
this
season
Email from Greg Bader
Exact
Dates
Unknown On
or about July
tells
Jerry
Mt
with
Washington
Tavern
Jen
that
this in an email.14
Jerry
Coleman
can
that
he had
Warehouse
that
confirm
Warehouse
offices
Drew
season
Forrester tweets
at
the beginning
of the 2010
for
Ravens
in
RT
source
@wnst
Drew Good
news
you guys
14
Comment
not
available
in
recorded
online
22
247747-1
PRDR000022
HPK/ROYLEv.WNST
BALT You
Jen
sent
can
follow
live
our tweets
live
or
Royles
tweets
from her
couch Appears
twitter
be
15
around 9/27/11
Copied from
by Jen Royle
On
or about
September
on
blog that
short
he does
not understand
to
why Jen
Royle
wear
be on
skirts that
and boots
and
its pretty
she
wont
TV
On
in
or around August
training
camp
the
Westminster
heard
MD
Ravens
field
when
they had
called
--
Jen Midol on
morning
show Drew
to
and Glenn
came up
shake
me
and introduced
declined
my hand
to shake
hand
station
it
has
nothing
good
to say about
me
appreciate
because
me
He
said
have never
said
word
about
you
cant control
say
you
said well
Im telling
now
youre responsible
And
he walked
away
air
and
told
everyone
was
he has ever
met
Email from
Ms
No
longer
available
on
The Defendants
Ms
Royle
have
knowledge
about
this
occurrence
23
247747-1
PRDR000023
HPK/ROYLEv.WNST
EXHIBIT
June
27
2011 Letter
to Plaintiffs
Counsel re 2-432
Holland
2099
Pennsylvania Knight
Knight
NW
Suite
Avenue LLP
100
Washington
DC 20006
202.955.3000
202.955.5564
Holland
www.hklaw.com
CHARLES
TOWN
202
419-2539
charles.tobin@hklaw.com
June
272011
Via
UPS
Overnight
and Email
Brian
Goodman
Pessin
Hodes
901
Re
Jennjfer
Royle
Circuit
NASTY
Court
1570 Sports
LLC
et
aL
Maryland
for
Baltimore City
Case
No
24C1l00157l
Dear
Mr
Goodman
Rule with 2-431
further effort to
We
client
send
this
letter
pursuant
to
as
good-faith
resolve 2-421
your
2-
Jennifer Royles
non-compliance
her discovery
obligations
under
Rules
and
Ms
Royle
to
initially
responded with
on June
detailed
2011 explanation
briefly
to
our
clients
written
requests
We
wrote
of our concerns
with
response
Following
our letter
that
15 you and
spoke
by telephone
and
you
suggested
and
agreed
assured
we
June
further
discussion
until
after
we
had
exchanged
address
certain
documents most
of our
You
us
that
Ms
Royles
supplementation furnished
would
to
concerns
responses
On
17
you
Ms
supplement
interrogatory
us with
documents
We
in as
have
carefully
reviewed
the
information
you
have
provided
Unfortunately
Ms
noted
Royles supplementation
our June they indicate
largely letter In
and production
fact
of the deficiencies
raise
we
us on June
that
still
17
new
she
set
number expand
the
appear
claims accounts
has
completely relevancy
refused to
to
provide
of her Twitter
their
obvious
her Complaint
This
letter
supersedes
our
to
June
letter
and
specifies
the
numerous
to
deficiencies
in
the
date
the
Ms
Royles
continued
failure
meaningfully
meet her
impeding
We
Ms
need
Royle provide
to
of the
information with
by July
2011
to
avoid
the
inconvenience
the Court
Motion
Compel
Mr
Page
Brian 2011
Goodman Esq
June27
Plaintiffs
Responses
to
WNSTs
Interrogatories
The
to
supplemental nearly
all
answers
issues
to
interrogatories
submitted
with
the June
17 production responses
detailed
failed to the
address
of the
we have
previously
raised under
Your
clients as
interrogatories
and incomplete
Rule 2-432
below
Various
references
to
unnamed
therefore
individuals
are
Various
individuals
to
alluded
to
in
Ms
of
Royles
responses
and
who
material
to
witnesses
the
her
Complaint
for
remain any
unidentified
Furthermore
as
Ms
Royle has
failed
provide
contact
information
these individuals
These references
include
Interrogatory
No
unidentified
in
The
current
to
and
former
colleagues
of
Defendants
referenced
the response
Interrogatory of the
No
local
The
unidentified
to
other
members
media
referenced
in
the
response
Interrogatory
No
Interrogatory
No
unidentified individuals within the Baltimore
The
Ravens
organization
to
whom
Ms
as
Royle prepared
in
correspondence
to
on or about
Interrogatory
at
August
14
2010
The
described
Ms
Royles answer
No
and
as
unidentified
colleagues
and management
emails
MASN
as
CBS
with
whom
Ms
Royle
exchanged
well
telephone regarding
conversations
beginning
as
on approximately
described
in
January
to
13 2011
Defendants conduct
her answer
Interrogatory
No
Interrogatory
No
10 individuals
The
unidentified
who have
reputation
called as
into
question
in
Ms
Royles
to
professional Interrogatory
and personal
described
her
answer
No
10 members
them
to
The
unidentified
of
the
public
that
who
believe
that
Defendants
liar
actions has
have caused
believe with
Ms No
Royle is
and/or
bitch
Brian
and
as
had sexual
in
relationships
Nick
Swisher
Matusz
with
described
10 Royle
covers
as
The
unidentified
whom
in
Ms
The
Royles
to
credibility
been
ndangered
Royle
contends
in
described
her
answer
Interrogatory
No
10 who
unidentified
to
others
herself
Ms
that to
she
has
been
forced
explain
to
as
described
her
answer
Interrogatory
No
10
Mr
June
Brian
Goodman Esq
27
2011
Page
Exhibit
Mr
Jon
Royle
Gallo
fails
to
identify
the
Ravens PR
Defendants
staff
with
whom
she
alleges
spoke
with
about
comments
PRDR000007that
000008
The
unidentified
individual
who
about
informed
her
Ms
air
Royle
Nestor
Aparicio
made comments
identification 11
on the
as
on
2/22/2010
is
Ms
Royles
footnote
of
this
individual
stranger
inadequate
PRDR0000I
The
unidentified
to
some
reporters
Ms
Royle
with
in
alleges
that
Drew
Forrester
spoke
also
about
to
Ms
fully
Royles
identify
relationship
Brian
Matusz
e-mail
Ms
Royle
failed
Monica
informed
the
same
exchange
PRDROO
The
as
002 1-000022
person
unidentified
who
Ms
referred
to
PRDR000023
our request
to
Interrogatory response
to this
No
to
Similarly
interrogatory
Ms
lists
Royle
her
ignored
to
supplement
her have
the
standard
asking
identify
individuals
who
may
to
information
relating
her Complaint
She
or
five
non-parties by
as the
name
but refuses
state
substance
information
interrogatory
required and
Further
Ms
Royles
of
alludes
to
and
former
colleagues
of
other
she 17
members
media
but
identify
those
individuals
nor does
in the
of their testimony
knowledge
or information with
June
Ms
000022
any information
him
as
required by Interrogatory
No
to
It
is
entirely
unclear supersedes
whether
the
Exhibit
the
referred
to
in
this
us
on June
17
previous
Exhibit
Further
sufficient
These documents
each
contain remain of
in
some
entirely
different
document
or the
paraphrased allegedly
to state
notice
Defendants
Court
the or
and defamatory
with personal
words
The
statements include
paraphrased
fail
witness
knowledge
Ms
fails
Royle
to
alleges
that
but
specify
the
words
which
were
allegedly
said
about
her
PRDR000006
Statements
practice
Ms
Royle
alleges
Mr
rest
Clark
made
to
Damon
of the
Yaffee
during
Ravens
regarding
her
credentials the
quotes
some
allegedly
defamatory
letter to the letter
statements persons
but paraphrases
the
Ms
Royle
but
identifies failed
her source as
to
within
Ravens
organization
produce
PRDR000007
Ms
Royle
fails
to
identify
witness
with
personal
knowledge on
to
exchanges
In
alleged
between
Ms
Royle
Mr
Clark
and
Mr
Forrester
9/12/2010
Mr
Page
Brian 2011
Goodman Esq
June27
addition Jon
Mr
Royle
with
fails
to
identify
the
Ravens PR
staff with
whom
on
she alleges
Gallo spoke
about
Ms
Royle
quotes but
statements
to
made
and
by
CJ
Spiller
his
blog
on
9/20/2010
available
fails
produce
instead
states
Blog no
longer
on website
PRDR000008
answered
arise if
Dave
Hughes
allegedly
question
in
his
mailbag
regarding
whether
conflict for
of interest
would
Ms
Royle dated
MASN
to
on 1/20/2011
defend but
PRDR0000I
that
Ms
want our
clients
they
did not
make and
told
appeared
precisely
on someone what
that
elses
forum was
not
even
specifically
us
statement
The
substance
of what
is
Ms
Royle
alleges
Mr
on
Forrester told
some
reporters
on
or about
6/11/2011
PRDR00002I-000022
his
Comments
allegedly
made by
Mr
Clark
fails
blog
on or about
September
2010 which
Ms
to
provide
source
PRDR000023
Defendants
On
fails
or
around
broadcast
to
segment
she heard 2010 Ms Royle alleges Reaction Jen Midol on The Morning
Ms
Royle
Royle
identify
who
told
her about
the
the segment
nor does
she provide
also
any
fails
supporting
to state
regarding personal
Jen Midol
as to
segment
Ms
with
knowledge
the
her alleged
exchange Moreover
with
Mr
Aparicio
fails to
day regarding
substantiation
Jen Midol
the
segment
Ms
Mr met
Royle
provide
air
any
that
for
allegedly he
made by
ever
Aparicio
on the
Ms
Royle
was
bitch
has
PRDR000023
Interrogatory
the deficiencies to
No
this
Ms
response
Royle ignored
letter that to
with
Thus
believes
Ms
Royles
an the
response
continues
incorporate
response response
the preceding
to
interrogatory
which asks
entirely
different in
question
Ms
no
14
Royles
matter
fails
explain
false
why when
she
it
iiof
as
still
statements
was
to
made
Interrogatory
No
addition
Ms
lied
update
Interrogatory
No
after
adding
more than
that
additional
statements
Ms
Royle have
she has
never
never
purported
to
credentials
have
with
Moreover
Ms
still
states
that
been romantically
statements athletes
that
Nick Swisher or
Matusz
inappropriate
Complaint
athletes and
as
27
Therefore and
as
Ms
her
interrogatory
limit
professional
we asked
her response
to
Mr
Swisher
Mr .Matusz
our June
letter that refers to
Interrogatory
the deficiencies
No
this
Ms
Royle ignored
the request
still
in
she resolve
with
response
Ms
Royle
with
generically
conversations
in
correspondence
failing to
and telephone
their the
conversations
unnamed
individuals
fails
and
the
addition date of
to the
provide
or
names
and
of
contact the
information
as
to
state
communications
substance
communications
the
interrogatory
requests
Ms
Mr
Page
Brian
Qoodman Esq
June27
2011
Royle continues
with
several
to
refuse to
in
provide
this
information
even
after
directly
quoting
correspondence
individuals
her revised
Exhibit
including
and Chad
Steele
PRDR
000007
in
Interrogatory the
deficiencies
No
Ms
Royle ignored
the
request
our June
letter that
she resolve
with this Ms Royles response incorporates to response response No which provides none of the information sought in Interrogatory No Ms Royles complete factual basis for her assertion that the Defendants knew her
entertained
doubts
as to
as their
to
the
truth
or falsity
of statements
or
of awareness
probable
falsity
Interrogatory
the deficiencies
No
this
Ms
Royle ignored
the request
in
our June
directs
letter that
with
response provides
basis
Ms
for
Royles
response
us
in
to
her
No
complete
which
none of the
information
allegation
sought
that
Interrogatory acted
No
with
factual
Ms
Royles
Defendants
common
law malice
ill
will or spite
Interrogatory
No
11
While
Ms
Nos
medical
records she
from
Dr
Goldiner
as
and
Dr
provided
no records
Dr
Liebman
whom
identified
receiving
continuing
provider in Interrogatory
and 15
No
12
Ms
answer
to
Interrogatory
to
No
12
continues
to in
and inappropriately
the
in
referring
Defendants
unidentified
documents
lieu
interrogatory other
regarding
whether
Ms
Royle has
those
the
referenced because
interrogatory
it
responses
the
Specifically
Ms
Royles
response
Rule
2-421c
fails to
specify
records
may be
derived
or ascertained
No
this
15
Ms
Royle ignored
the
request with
in
our June
letter
that
she resolve
response with
Ms
Royle responds
she has ever
the
and
lists
no other medical
emotional health health
professionals
in
is
whom
visited
her mental
pre-existing
and/or mental
required
Ms
Royles
condition
clearly
of her Complaint
Interrogatory the
deficiencies
No
16
Ms
Royle ignored
the
request
to
in
our June
letter that
she resolve
with with
this
response
of
Ms
the
Royle
objects her
are
this
interrogatory
in
which requests
without
stating
correspondence whether
members
public
about
that the
work
Baltimore
to
any documents
reputation requests
or communications
is
exist to
responsive
Obviously and
the
Ms
Royles
clearly
relevant
that
allegations
of
Complaint
interrogatory
information
on
issue
No
19
Ms
Royle ignored
response
in
our June
fails to
letter
that
she any
deficiencies
with
this
Ms
Royles
response
provide
Mr
June
Brian
Goodman
Esq
27
2011
Page
infonnation required
about
her
reason
for
leaving
each
place
of
employment
as
the
interrogatory
Nos
21
and
22
Ms
in
our June
letter
that
she
deficiencies
with
citing
this
response
boilerplate
objections
at
Ms
Royle
that
no
information
relevancy
grounds
that
Ms
Royles
Complaint
sexual
27
the
alleges
Defendants
made
with
false
she
had
personal
therefore are
and/or
to
relationships
professional
Defendants
entitled
requested
in
Interrogatory
No
any former
and/or
for
or current professional
athlete
which
Ms
personal
Interrogatory
sexual
inappropriate
about
or
relationship any
well as the
or
No
22
information any
intimate romantic
relations
of any nature
is
she has
former
current professional
athlete
information
directly
of her Complaint
Plaintiffs
Responses
to
WNSTs
to
Document
Requests
Ms
be
evasive
under
Rule
2-432
wholly
inadequate
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deficiencies
to
Provide call
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Log
to privilege
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we
have
noted
and
as
you on
the
and
basis
15
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providing
certain
documents
under
without
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submitting
log
are
as
required
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are
law
log
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and
the
Court or not
unable
determine
specific
being our
withheld
June 15
and whether
telephone
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you
Royles
agreed
to
objections furnish
appropriate
log for
during
conference
privilege
these documents
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17 production
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production
to the
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In
Ms
Royles revised
either
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the or
June
17
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directly
quotes
statements
allegedly
single
made by
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referring
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document
evidencing
these statements
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number
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revised provide
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document though
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themselves
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deficiencies
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any
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Defendants
are
and
within
we
already
contrary
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objection
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to
communications
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sent
Defendants
they
are
possession
custody
and control
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any
communications she
via Twitter
no longer
accessible easily at
Ms
Royle
however
account
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directed
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to
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clients account
@WNST
to
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retrieve
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her
Complaint
to
Ms
Royle
is
obligated
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us
in that
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resolve
Request
No
this
Ms
response
Royle ignored
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to
the request
our June
letter
she
the deficiencies
third
with
her objection
communications
possession
it
between custody
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Ms
Royle and
parties the
about
is
the Defendants
Further
request
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the contrary
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confined
text
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Royle makes
in
at least
two references
to
messages
which she
failed
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produce
an
unidentified
in
three-page revised
document
Exhibit but
on June
written
fails
17 PRDR000099-000101
communications
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21 22 23
these requests
as
26
fact
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has
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document
all
production
adequately
Ms
of
Royle
in
produce
Plaintiff
documents
required to
that are
supporting provide
her allegations
these statements
were
made
with her
The
is
the Defendants
false
and
the
Court
in litigation
this to
nature
the precise
in
words
allegedly
and defamatory
Ms
Royle
fails
meet
obligations
discovery
by
We
card
have
to
even
retrieve
furnished
you
in
our
Document
history by
Request
No
obtain
with
this
the
simple
directions
Ms
Royle
written
needs
to to
follow Twitter
account signed
You may
to the
information of
valid
by sending
request
by fax
to
you
together with
copy
government-issued
for
identification
Twitter
to
will
send
the
you
confirmation
email address
they have
you on
file to
which
will to
authorize
Twitter
clients
release
you
requested
information
Our
clients
followed
these
instructions
respond
your
document request
Mr Brian
June
Goodman
Esq
27
2011
Page
continuing
to
rely
on
characterizations for
of
statements
in
Exhibit
rather
than
providing
the
statements themselves
statements
including
Statements
allegedly
made on
8/5/2010
by
Mr
Clark which
Ms
to
Royle claims
find the
are
on
Defendants website
she references Statements
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therefore
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locate
are
unable
statements
We
request that
Spiller
you
us with
copy
are
allegedly
made by CJ
on 9/20/2010
Ms
find
Royle claims
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on
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references
website
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alerted that
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34
this
Ms
Royle ignored
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our
June
letter
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resolve
deficiencies
response
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last
Royles
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June
flatly
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they
are restricted to
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the
are these
but your
few weeks of
therefore
2011
and
clients to
Complaint
activities
Ms
Royle
has
reftised in
any
to
documents
Request
relevant
that
her she
on Twitter
Ms
Royles
to
statement
her
No
uses
in
Twitter discovery
daily pursuant
to
her
professional history
duties
not relieve
provide
her account
Document
that
Request
Nos
but
through
14
Ms
Royle ignored
the
request
in
our June
letter
she resolve
the deficiencies
Ms
Royle
still
broadly
objects
if
on
the
basis
Law
to
assert
whether
such
documents
exist and
they
do
Ms
Royle such
falls
to
submit
privilege
Without
Defendants and
the court
unable
to
evaluate
the states
sufficiency
that
Moreover
the
Ms
Royles
answer
to
Interrogatory
that relates
No
solely
she prepared
Baltimore
Ravens organization
fall
to
an
by her lawsuit
which
clearly
would not
within
the
Law
in
Document
resolve
the
Request
No
with
32
this
Ms
Royle ignored
Contrary not within
is
the to
request her
our June
all
letter
that
she
deficiencies
response
are
assertion
communications custody
of
possession
the
and
her
Obviously
and
Ms
Royles
reputation
clearly to that
allegations
Complaint
documents
related
Document
resolve
the
Request
No 33
this
Ms
the
request
to
in
our June
the
letter
that
she
deficiencies
with
response your
failed
produce
requested telephone
page
despite
assurance
during
our June
15 2011
information
accounts
Like
Mr
June
Brian
Goodman Esq
27
2011
Page
provides
an
easy cost-free
to status
and non-burdensome
method
to
access
all
information
on
Ms
Royles
account including
photos
listing
of friends
etc.2
We
all
must have
Ms
Royles
complete
supplemental
responses
to
and avoid
documents
to
we have requested
by no
later
than
2011
to
our having
am
times for
happy
call
to
discuss
this to
with adhere
you
to
by telephone
the July
and
will in
you
some
suggested
this
But we need
timeframe
order to
move
matter
forward
Very
truly
yours
HOLLAND
KNIGHT
LLP
Charles
Tobin
cc
CDThje
Holland
Knight
LLP
When
Settings and her
logged
onto
her
Facebook
selecting
account
Ms
Royle your
should
select
the
Account
tab
followed
hit the
by
the
Account
button
tab followed
entire
by
will
Download
Information
emailed
to the
Ms Royle
may
then
Download
record
account
compiled
by Facebook
and
email address
has on
EXHIBIT
June
27
2011 Letter
to Plaintiffs
Counselre 1-341
Holland
2099
Pennsylvania Knight
Knight
NW
Suite
Avenue LIP
100
Washington
DC 20006
202.955.3000
202.955.5564
Holland
www.hklaw.oom
CHARLES
TOBIN
202
419-2539
charles.tobin@hklaw.com
June
27 UPS
2011
Via
Overnight
and Email
Brian
Goodman Esq
Pessin
Hodes
901
Katz
P.A
Ste 400
Re
NASTY
Court
1570 Sports
LLC
et
for
Baltimore City
Case
No
24C 11001571
Dear
Mr Goodman
We
send
in this letter
pursuant
to
Rule
1-341 which
justification
prohibits
litigants for
from maintaining
the Court adverse
to
proceeding
bad
faith
or without including
substantial
and provides
fees incurred
in
award party
narrow about
the reasonable
This your
letter
expenses
reasonable
attorneys
by the
asked
follows
our telephone
to
fit
conversation
the
of June of
15 2011
this
which
you
to
clients
claims
prevent within
proliferation
litigation
through
allegations
statements that
do not
remain
in the
Complaint
As you
action for Plaintiff for also
are
aware
the Court
at
the
June
2011
hearing
dismissed
your
clients
cause
that
of
the
intentional
infliction
of emotional
the
distress in
Count
IV
as
With your
the Court
concession dismissed
inappropriately of privacy
included
count
her Complaint
her claim
invasion
by publication
causes
of private
facts
Count II
in this
well
The
dismissal of these
claims
specific
of action
remaining
lawsuit
defamation
and
false
light
invasion
Counts
and III
As you
Plaintiff that are
thrther
rare
aware
the
defamation
and
false
false
light
torts
each
requires
that
the
plead not
and prove
fact
among
are
statement
true
of fact
are
Alleged
are
statements actionable
and
that
of being
proved
false
not
under
these torts
raised
this
issue
with
you
in
our June
15
telephone
conversation
where
as
we
discussed can
tell
your
clients
initial
deficient
discovery
responses Since
Your
the
clients
Complaint
all
best
we
includes
12
allegedly actionable
statements
Court
dismissed should
claims
and
the
false
of allegedly
in
actionable
the
initial
statements discovery
June
Nevertheless of allegedly
responses
served of
increased
number
actionable
statements
and
listed
29 statements
Mr Brian
June
Goodman
Esq
27
2011
Page
conversation
on June
to
15
those
asked
you
to that
reconsider arguably
the
statements
fit
and
Ms
Royles
Complaint
only
statements
would
within
defamation
of action
You
advised that
the Plaintiff
would
do this
Following
that
discussion
to
on June
Included
in
17 you
as
served
supplemental
is
interrogatory
documents
us
those documents
an
entirely it
new
list the
and PRDR000099-lOl
statements
least that
which
we
understand
supersedes
this
actionable includes
at
you provided
on June
actionable
to
At
juncture
Ms
Royles
just
now
50 separate allegedly
such
as
statements her as
To name
of the
two
examples
Ms
Royle
lists
phrases others
those referring
to
apologist
morning
because an of
and
analogizher
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as
character statements
or or
disaster
of
fact or
PRDR000005
is
of
these
true
contains dozens
assertion
capable
of
proved
false
false
These
among
statements
that
defamation
light invasion
of privacy
Ms
squander believe
appear
determined
in
to
make made
her allegations
to
as
broad under
as
possible to
derogation
the Rules
for
We
of
extraneous
have
an
effort
been
to
solely
purposes unnecessary of
or unreasonable
delay
insist in
in
drive up costs
We
therefore
that
by July and
are
2011
that
you
allegedly
statements of those
so that
provided statements
you
instead as
with or
discrete
false light
narrow
list
you
actionable discovery
defamation an
portrayal
we may
efficiently
with
under
appropriately
defined
claim
We
Rule
1-341
obligations
this
letter
dispute
in
prior
to
the
filing
of
motion under
discovery
This
no way waives
your
clients
and remedies
Very
truly
yours
HOLLAND
KNIGHT
LLP
Charles
Tobin
cc
CDThje
Drew Shenkman
Esq
Holland
Knight
LLP
EXHIBIT
Plaintiffs
Supplemental Responses to
Interrogatories
WNSTs
and
Supplemental Exhibit
JENNIFER ROYLE
Plaintiff
IN
THE
CIRCUIT
COURT
FOR NASTY
1570
SPORTS LLC
et
cii
BALTIMORE
CASE
CITY
Defendants
NO
24-c-uooi57l
PLAINTIFF TENNIFER
RESPONSES TO
ROYLES SECOND SUPPLEMENTAL ANSWERS AND WNST SPORTS MEDIA LLCS FIRST SET OF
INTERROGATORIES
INTERROGATORY NO.2
number
of each
State
the
identity
address
and
telephone
person
who you
believe
has knowledge
or information relating
to your
Complaint
together
knowledge
or information
ANSWER
interrogatories
NO
Plaintiff
objects
to this Interrogatory
as
it
contains
several
each involving
separate
and
distinct issues
under
the
guise
of
single
interrogatory in contravention
of the
limits
imposed by Rule
2-421
of the
Maryland
Further
the
interrogatory as
worded
is
overly broad
vague
and ambiguous
as well as
unduly burdensome
as
it
seeks for
Plaintiff
to identify
all
persons
of the
facts
relevant
to the
issues
in the
case
even
if
reason
the
interrogatory
is
objectionable
as
it
calls
for speculation
and
conjecture
and
is
not reasonably
calculated
Without waiving
and
subject
to said objections
Plaintiff
presumes knowledge
that the
Defendants
Aparicio
Forrester
Plaintiff
also
presumes and
that
current
and former
colleagues
Defendants
the Plaintiff
other
members
of the local
personal
knowledge including
to Jerry
Coleman
ongoing
Casey
Willett
Damon
the
Yaffe
John
Gallo
is
Plaintiff
reserves
right to
to this
Interrogatory
Without
waiving
and
subject
to
the
the
contact
person
is
in
the
Plaintiffs
immediate
custody and
possession
or
control
it
has
been
provided
see
Exhibit
Plaintiffs
Original
Supplemental
Responses
to
Request
for Production
of
Documents
See
also
persons
identified
in
Supplemental
Exhibit
Supplemental
Answers
to Interrogatories
Nos
34
and
INTERROGATORY NO.3
by any
of the
Identify
statement
of fact
made
Defendants
that
you
allege
is
false
as
alleged
in
Complaint fl19-25
each
including
all
subparts
and
fl27
37
48-50
quoting
verbatim
alleged
false
statement
of fact
the
date
and time
of such
statement
the
identity
of the
speaker
of the
statement
the
exact
medium
of
communication
upon
which
the
statement
was made
website
etc
and
if
the
statement
is
found on Your
website
or
blog
state
the
exact
web
address
containing
the
statement
answer
to
this
interrogatory
should
identify
all
statements
on
which
you
base
the
Complaint
including
to
that
you contend
or competent
state for
you
are
not
qualified of
and
incapable
doing
job Complaint
you contend
state
21
that
24
All statements that
implicate or otherwise
you
are
involved
in personal athletes
sexual
and/or inappropriate
that
relationships sexual
with
multiple professional
and/or
with
you halve
athlete
personal
and/or inappropriate
relationship
professional
Complaint
20
21
that that
21
21
21
that
All statements
you lied on
you contend state implicate or otherwise insinuate resume and did not have the credentials or experience
have with regard
to profession as journalist
purport
to
Complaint
21c
21
that
you contend
like
state
implicate
or otherwise insinuate
look
stripper
bitch
and/or an
idiot
you see work
e.g
Complaint
24c
that
Complaint
24d
that uncivilized that
threatened
violence
against
All statements
your
professional
in
demeaning and
way
Complaint
24b
statements
All statements
you contend
about
you
Complaint
24e
objects to
this
ANSWER
interrogatories
NO
Plaintiff
Interrogatory
as
it
contains
several
each
involving
separate
and
distinct
issues under
the
guise
of
single
interrogatory
in contravention
of
the
limits
imposed by Rule
2-421
of the
Maryland
Additionally
as
discovery
is
ongoing
Plaintiff
reserves
the
right
to
supplement
waiving
said
objection
see
chronology
attached
hereto as Exhibit
Plaintiff
incorporates
her
original
refers the
Defendants
to Supplemental
Exhibit
attached
hereto
Plaintiffs
Original
and
Supplemental
Responses
to
Requests
for
Production
of
Documents
as well as Supplemental
Answers
to Interrogatory
Nos
and
On
training
8/5/
2010 Casey
Willett
CBS employee
Defendant
informed
Ms
camp
in
Westminster
MV that
insulted
her on the
morning
that
Defendant
Clark
specifically
used
new nickname
for
her Jen
Midol
that
Defendant
Clark said
Ms
know what
blitz was
insinuating
she was
incompetent
and
that
Defendant
knew who
Nick
Swisher
of the Yankees
was
insinuating
an inappropriate/sexual
relationship
between
Plaintiff
of the
Ravens
Public
Relations/Media
Staff
Chad
Steele
and
Patrick
the
Baltimore
of the
incident Casey
Willet
statements
on
WNST
1570
AM
Ms
On
Royle
that
9/7/2010
Damon
told
Yaffee
Glenn Clark
him
that
Plaintiff
my resume
and
the
credentials/
experience
that
appears
on
my
resume
do not deserve
to
be
covering
the
Ravens
Damon
listening
Yaffee
further
informed
Ms
Royle that
Defendant
Clark
had
said
it
was
brutal
to her
better
to cover
the
Ravens
Damon
Yaffee
and Defendant
information regarding
the
statements
On
Plaintiff
9/12/2010
WNSTs
website
published
blog wherein
CJ Spiller stated
that
was
demoted
blog from
See
Supplemental
Exhibit
WNST
has
since
removed
the
its
website
or
else
it
is
not discoverable
through
general
search
patterns
Plaintiff
has
made
on
the
substantial
efforts
to produce
copy
of the
said
blog but
it
is
no longer
available
Defendants website
On
know
she
or
about
7/1/2010
Defendant
Forrester
told
Jerry
Coleman
Dude
you
is
hooking
up with Matusz
is
right
Plaintiffs
at
the
Mt
Washington Tavern
control
copy
of
the
oral
statement
not
in
the
possession
custody
or
Jerry
Forrester
of the
statement
On
even heard Gold
9/12/2010
Defendant
tweeted
And
to think
@JenRoyleMASN trashy
if
hasnt
me
tonight
would be considered
at
the
Club and
Defendant
Forrester
followed
dont know
Glenn
is
D-Bag but
than
do know this.
those boots
@JenRoyleMASN day
Jen
is
wearing
are
worth more
Glenn Clarks
car
truth
series
Later
that
Royle
Drew
Forrester and
Glen
to
of statements
made
in
conversation between
them
tweet
The statements
began when
Ms
Royle
approached
Mr
Clark
and
stated
that
made
earlier
that
day
by
Mr
with
Clark
was
crossing
the
line
and
extremely
unprofessional
Concurrently
these
statements
Mr
if
Forrester
walked by and
yelled
where
are your
boots Ms
This
is
Royle asked
Mr
Clark
he could
step
outside to talk
Mr
Clark said
no
place
and
let
Mr
Forrester
then said
go home
and put
your boots on
first
then come
inside
me buy you
on
drink
was
In
blog
that
is
no longer
available
WNSTs
website
that
originally
posted
on
or about
9/1/2010
short
skirts
and boots
to
games knowing
she
wont
be on
TV
and
that
its pretty
cold outside
copy
of the
original
blog
is
believed to in the
files at
WNST
identified
INTERROGATORY NO.4
Interrogatory
For each
statement
your answer
to
No
explain
the
reason
that
you claim
it
was
false
when made
identify
each
and every
fact
identify
all
persons
known
to
you
who
have
knowledge
such
facts
and
for
each
person
identified
state
the
knowledge
ANSWER
interrogatories
NO
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
guise
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of
the
Maryland and
Rules
of
Civil
Procedure
The interrogatory
as
worded
is
overly
broad
vague
ambiguous
with
as well as
unduly burdensome
as
it
seeks
for Plaintiff
to identify
all
persons
personal knowledge
of the
facts relevant
to the
issues
in the
case
even
if
she has
no knowledge
of
their existence
Further
Plaintiff
objects
to
this
Interrogatory
to
the
extent
it
seeks
information protected
from discovery
by
the
attorney
work-product
doctrine
To answer
this
be required to provide
information regarding
counsels
litigation
strategy
in this
case
Without waiving
with
said
objections
and
subject
thereto
Plaintiff
Nick
Swisher
or
Brian Matusz
Moreover
Plaintiff
Plaintiff
has
never
purported
to
have
credentials
she
does
not
have
Plaintiff
incorporates
her
Answer
to
Interrogatory
As discovery
is
ongoing
Plaintiff
reserves
the
right to
SUPPLEMENTAL
objections
Plaintiff
ANSWER NO.4
her Answer
Without
waiving
Plaintiffs
original
supplements
as
follows
The statements
made by
to
the
Defendants
place
Ms
Royle
in
false position
by
attributing
false conduct
Ms
Royle
namely
that
relationship
with Nick
Swisher
Further
the
statements
place
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to
unprofessionalism
and incompetence
Specifically
False Statment
8/5/2010
Glenn Clark
said
Ms
Royle
did not
know
of
what
blitz
sports
reporter
who knew
the
definition
blitz
The statement
places
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to The
unprofessionalism
and incompetence
in regards
to
her occupation
parties
herein
have
knowledge
of
the
falsity
of
the
statement
see
also
Exhibit
False Statnient
9/7/2010
Glenn Clark
told
Damon
Yaiffe
that
Ms
the
Royle
lied
the
experience
to
cover
Ravens
Ms
as
reported
covering
the
years
of experience
gained
in
New
covering
professional
athletic
teams The
statements
place
Ms
Royle in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
to unprofessionalism The
and
incompetence
in regards
to her
occupation
parties
herein
and
Mr
Yaffe
have
knowledge
of these
statements
see
also Exhibit
False Statinent
9/21
2010
Drew
At
Forrester
tweeted
where Hopkins
is.
LOL
10
Johns
the
time
this
statement
made
places
Jen
Royle
did
know
where
Hopkins
was
The statement
Ms
Royle
in
fale
position
by
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to
unprofessionalism
and
incompetence
in
regards to
her
occupation
The
parties
herein
have
knowledge
of
the
falsity
of the
statement
see
also Exhibit
False
Statment
11/26/2010
Drew
Forrester
blogged
that
he had sent
Ms
man
Royle
questionnaire asking
ever have
handsome
take
you out on
date
and
try to earn
your
affection
what would
to
wear He
man
in
blogged
that
She
wrote what Id
for
uniform
so
heres
like
like The
link
is
to
picture
of Nick
Swisher
in
uniform
Ms
Royle never
sent
such
response
or
link
to
Mr
in the
blog
place
Ms
Royle
in
false
position
by
attributing
false
conduct
to
Ms
Royle namely
that
she
has
some
sort of
personal/inappropriate/sexual
relationship
with
Nick
Swisher Further
the
statements
place
Ms
Royle in
false
position by attributing
to
Ms
Royle
false
characteristics
including
to unprofessionalism
and incompetence
in regards to her
occupation
The
parties
herein
as well
as
of the
falsity
of the
statements
False
Statinent
12/29/2010
Drew
Forrester
responded
to
comment
in
blog
stating
that
Royle
is an out of towner
who showed up
about
here
earlier
in the
started
talking
how much
position
the
place
sucks
The statement
places
Ms
Royle
in
false
by
attributing
to
Ms
Royle
false
characteristics
including
to The
unprofessionalism
and
incompetence
in regards
to
her occupation
parties
herein
have
knowledge
of
the
falsity
of
the
statement
see
also
Exhibit
False
Statment
12/29/2010
Drew
Forrester
responded
to
comment
on
blog
stating
that
Royle has
specifically
dogged
Baltimore to
anyone
and everyone
Ms
Royle
did
not specifically
dog Ms
the
city
of
Baltimore
to
anyone
places
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
to unprofessionalism
and incompetence
of
in regards to her
profession
The
parties
herein
have
knowledge
the
falsity
of
the
statement
see
also Exhibit
False Statment
Drew
Porrester
tweeted
@WNST
@JenlRoyleMASN
tourist
Drew And
professional
think the
fact
that
youre
stuck-up
snobby
on
brief
vacation
here
is
COMICAL too Ms
in
at
the
time
of
the
comment
Baltimore
she
was
not
engaged
in
vacation
as
tourist Moreover
the
use
of the
term professional
as
it
as
whole
places
Ms
Royle in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
to unprofessionalism
herein have
and incompetence
in regards to her
occupation
The
parties
knowledge
of
the
falsity
of
the
statement
False
Statment
1/2011
Nestor
Aparicio
tweeted
@VJNST
Renegade
Nestor
But
Drew
has
been
KIND
to
Miss
Yes
Jen
Mr
..
real
disgrace
is
in corporate bosses
theyre
qualified was
Ms
The
Royle
was
qualified
for
her
the
time
she
hired
statement
places
Ms
Royle in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
to unprofessionalism
and
incompetence
in
regards
to
her
occupation
The
parties
herein
have
knowledge
of the
falsity
of the statement
see
also Exhibit
False
Statment
1/11/2011
Drew
Forrester
tweeted
@WNST
Drew
LOL
that
Jen Royle
thinks
Im obsessed
ai-t
with
her
Thats her
OPINION
Royle
Heres
my FACT
Jen
is
out-of-towner
tourist
Jen
was
employed
in Baltimore
at the
time of the
statement
The statement
places
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to
unprofessionalism
and
incompetence
in
regards
to
her
occupation
The
parties
herein
have
knowledge
of the
falsity
of the
statement
see
also Exhibit
False
Statment 10
1/11/2011
Drew
Forrester
blogged
Quick Love
false
Jen who
said
that
No
it
wasnt
Brian Matusz
think he said
those
jeans.. The
statements
in
the
blog
place
Ms
Royle
in
position
by
attributing
false
conduct
to
Ms
Royle
namely
that
she has
some
sort
of
personal/inappropriate/sexual
relationship
with
Brian
Matusz
Further
the
statements
place
Ms
Royle
in
false
position
by
10
attributing
to
Ms
Royle
false
characteristics
including
to
uriprofessionalism
and incompetence
in regards
to
her
occupation
The
parties
herein
as
knowledge
of the
falsity
of
the
statements
False
Statment
11
1/11/2011
In
response
to
comment
on
his
blog
Drew
Forrester
wrote
Im
obsessed
about
one
thing
an
out-of
towner
coming
in here
and
trying
to talk to people
when
in
it The
statement
places
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to
unprofessionalism
and
incompetence
in
regards
to
her
occupation
The
parties
herein
have
knowledge
of the
falsity
of the statement
see
also Exhibit
False Statment
12
1/11/2011
Drew
Forrester
claimed
on
blog
that
Ms
Royle was
here on
scholarship
The statement
places
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to
unprofessionalism
and
incompetence
in
regards to
her
occupation
The
parties
herein
have
knowledge
of
the
falsity
of the statement
False Statinent
13
1/28/2011
Drew
Forrester
claimed
that
when
didnt
Jen Royle
showed
up
to
Baltimore
Magazine photo
shoot
she
want
to
wear
the
clothes
given
to
her and
instead
brought
her
own Nick
Swisher
jersey
that
she wanted
to
else
The statement
11
places
Ms
Royle
in
false
position
by
attributing
false
conduct
to
Ms
Royle namely
that
she has
some
sort of personal/inappropriate/sexual
relationship
with
Nick
Swisher
Further
the
statement
places
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to unprofessionalism The
and
incompetence
in
regards to
her
occupation
parties
herein
and
Nick
Swisher
have
knowledge
of the
falsity
of the
statements
False Statment
14
1/28/2011
Drew
Forrester
responded
to
comment
on
blog
She
came
to Baltimore
professed
this
place
to be
how much
she missed
New
place
me Ms
it
Royle
that
Baltimore
was beneath
her or brag
that
had nothing
for
her The
statement
places
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
to unprofessionalism The
herein
and
incompetence
in
regards
to
her
occupation
parties
have
knowledge
of the
falsity
of the
statement
see
also Exhibit
False Statment
15
2/22/2011
Nestor
Aparicio
said
that
the
only
reason
Ms
Royle
was
hired was
her
because
of
her
breasts
and
her
attractive
face
and
that
she
was not
qualified
to
report
on any
sports
team At
the
time of Defendant
Aparicios
statements
Ms
of experience
covering
various
athletic
place
Ms
Royle in
false
position
by
attributing
12
to
Ms
Royle
false
characteristics
including
but
not
limited
to
unprofessionalism
and
incompetence
in
The
parties
herein have
knowledge
of the
falsity
of these
statements
See also
Exhibit
False Statment
16
6/4/2011
in
blog
that
Jen Royle
had
trouble
finding
Towson
University the
previous
day
Ms
Deb
Royle
trouble
finding
Towson
University on 6/3/2011
Poquette
can
confirm
Ms
Royles
arrival
before
practice
began
her
contact
information is email
deb@campinslffestyle.com
telephone-410-
340-3569
The statement
places
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to
unprofessionalism
and
incompetence
in regards
to
her occupation
The
parties
herein as well as
Ms
Poquette
have
knowledge
of the
falsity
of the
statement
False
Statinent
17
6/10/2011
Drew
Forrester
blogged
that
Ms
hiring
sports
reporter
and
when
the
station
interviewed
girl
who
performed
unintelligently
in
beauty
pageant she
passed
the
interview
with
by
flying
places
Ms
Royle
in
false
position
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to unprofessionalism The
herein
and
incompetence
in
regards
to
her
occupation
parties
have
knowledge
of
the
falsity
of this
statement
13
False Statinent
18
Drew
Forrester
told
Jerry
Coleman
that
Ms
did
Royle
was engaged
in sexual
activity
with
Brian Matusz
Ms
Royle
not engage
in sexual activity
The statement
places
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to unprofessionalism
statement
and
incompetence
in
regards to
her profession
Further
the
places
Ms
Royle
in
false
position
by
attributing
false
conduct
to
Ms
Royle namely
that
she
has
some
sort of
personal/inappropriate/sexual
relationship
with
Brian
Matusz
The
parties
herein
have
knowledge
of
the
falsity
of the
statements
Plaintiff
also
refers
and
incorporates
Answer
and
Supplemental
Answers
to
Interrogatories
Nos
Responses
and
Supplemental
Exhibit
and
Plaintiffs
Original
and
Supplemental
to Request
for Production
of
Documents
Further
the
persons
identified
herein have
knowledge
of the
false
statements
INTERROGATORY NO.5
any
other
Identify
all
communications
between
you and
persons
identified
including
but
not
limited
to
the
Defendants
relating
to
the
statements
in
your answer
to Interrogatory
No
For each
identify
the
date
of
the
communication
by
whom
the
communication
was authored
or
made
to
whom
the
all
those
who
received
the
communication
whether
the
substance
of the
communication
to the
communication
14
ANSWER
interrogatories
NO
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each
involving
separate
and
distinct
guise
of
single
interrogatory in contravention
of
the
limits
imposed by Rule
2-421
of the
Maryland and
Rules
of
Civil
Procedure
The interrogatory
as
worded
is
overly
broad
vague
ambiguous
as well as
unduly burdensome
as the
Interrogatory
the
term
communications
Further
Plaintiff
objects
to this
Interrogatory
to the
extent
it
seeks
privilege
and
the
attorney
work-product
doctrine
Without
waiving
and
subject
to
said
objections
Plaintiff
prepared
correspondence
to
the
Baltimore
Ravens
organization
on
or
about
Plaintiff
exchanged
emails with
colleagues
and management
at
MASN
13
CBS
as well
as telephone
conversations beginning
on approximately January
Defendants
conduct
As discovery
is
ongoing
Plaintiff
reserves
to this
Interrogatory
SUPPLEMENTAL
original objections to
ANSWER
extent
NO
Without
waiving
and
subject
to Plaintiffs
the
the
correspondence
is
in
the
immediate
custody
000070-
possession
or
control
of
the
Plaintiff
copies
have
been
provided Raven
See
PRDR
000071 000076-000078
The
recipients
of the
letter
to the
Public
Relations/Media
staff
included
to
Chad
Steele Patrick
Gleason
and
Kevin Byrne 13
Plaintiff
exchanged
emails with
Jim Cuddihy
of
MASN
on
or
about
January
2011
regarding
the
Defendants
conduct
Plaintiff
emailed
Greg
Bader
of
the
Baltimore
Orioles
Organization
on
or
about 6/11/2011
to the
email with
an email
15
directly
to
Ms
Royle
Plaintiff
refers
the
Defendants
to
Plaintiffs
Original
and
Supplemental
Responses
to Requests
for Production
of
Documents
and
Exhibit
INTERROGATORY NO.6
your answer
that the to Interrogatory
With
respect
to
each
statement
identified
in
No
if
you contend
that
any
of the
Defendants
knew
statement
was
false
subjectively
entertained
doubts
as
to
the
truth
of
falsity
of the
statement
or published
the
statement
with
high degree
of awareness
as
to its probable
Defendant
state
the specific
facts
contention
and
all
persons
known
to
knowledge
facts
and
for
each person
identified
state the
knowledge
ANSWER
interrogatories
NO
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each
involving
separate
and
distinct
guise
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of the
Maryland and
Rules
of
Civil
Procedure
The Interrogatory
as
worded
is
overly
broad
vague
ambiguous
with
as well as
unduly burdensome
as
it
seeks
for Plaintiff
to identify
all
persons
personal knowledge
of the
facts
relevant
to the
issues
in the
case
even
if
she has
no knowledge
of
their existence
Further
Plaintiff
objects
to
this
Interrogatory
to
the
extent
it
seeks
information protected
from discovery by
the
attorney
work-product
doctrine
To answer
this
would
be required to provide
information regarding
counsels
litigation
strategy
in this
case
Without waiving
her
said
objections
and
subject
thereto
Plaintiff
directs
Defendant
to
Answer
to
Interrogatory
No
this
and
incorporates
her
Answer
thereto
Plaintiff
anticipates
that
discovery in
case
will provide
further
information in regards to
this
Interrogatory
16
and
as
such
reserves
the
right
to
supplement
and/or
amend
her
Answer
to
this
Interrogatory
SUPPLEMENTAL
objections
ANSWER
Plaintiff
NO
directs
Without
waiving
Plaintiffs
original
and
subject
thereto
Defendants
to her Supplemental
Answer
to
Interrogatory
No
Exhibit
and
and
incorporates
her
Answers thereto
as
well
as
Supplemental
and
Exhibit
Plaintiff
anticipates
that
discovery in
this
case
will
provide
further
information
concerning
the
information
sought
by
this
reserves
the
right to continue
to supplement
and/or amend
her Answer
to this Interrogatory
sports
reporter
through
his
employment
in as
sports
reporter
upon
this
knowledge
but
not
limited
thereto
Defendant
Clark
knew
that
Ms
and
Royle
had
sufficient
expertise
in
sports
to
cover
professional
sports
teams
that
she
was
qualified
for
position
in
reporting
Defendant
Ms
and
in publishing
the
statements
without
verifying
the
accuracy
thereof
Mr
Clark recklesly
made
the
false
statements
or
knew
that
the
statements
were
false
and purposefully
made them
by
nonetheless
The
Defendants
statements
place
Ms
Royle
in
false
position
attributing
to
Ms
Royle
false
characteristics
including
but
not
limited
to
unprofessionaiism
and incompetence
Drew
Forrester
knew
other
of
Ms
Royles employment
in
Baltimore
and
previous
employment covering
this
athletic
teams
as he
is
upon
knowledge
thereto
Defendant
Porrester
knew
that
Ms
Royle
17
had
sufficient
expertise
in sports
to cover
professional
sports
teams and
that
she was
qualified
for
position
in reporting
Defendant
Forrester
had no
that
Ms
know where
Further
Johns Hopkins
was and
had no
he recklessly
made
false
statement
to that
effect
Defendant
Forrester
Ms
Royle
was
sleeping
with
or
had
personal/inappropriate/sexual
relationship
as
defined in Plaintiffs
Supplemental
Answer
to
Interrogatory
No 20
Royle
in
with
Mr
Swisher
and/or
Mr
Matusz
The Defendants
statements
place
Ms
that
false
position
by
attributing
false
conduct
to
Ms
Royle
namely
with
she
has
some
sort
of
personal/inapprOpriate/sexual
relationship
Nick
Swisher
and
Brian
Matusz
Further
the
statements
place
Ms
Royle
in
false
position
by
attributing
to
Ms
Royle
false characteristics
including
to unprofessionalism
and incompetence
Nestor
Aparicio
knew
of
Ms
Royles experience
in sports
journalism as
result
of
his extensive
work covering
Baltimore sporting
statements
that
Plaintiff
either subjectively
false
made
in reckless
falsity
thereof
The Defendants
statements
place
Ms
Royle in
false
position
by
attributing
to
Ms
Royle
false
characteristics
including
to
unprofessionalism
and incompetence
INTERROGATORY NO.9
acted
If
you
contend
that
any
of
the
Defendants
with
common law
malice
ill
statements
in your
answer
to
Interrogatory
No
state
the
specific
facts
on which
you base
such
18
contention
identify
all
persons
you contend
have
knowledge
of such
facts
and
for each
person identified
state the
knowledge
several
ANSWER
interrogatories
NO
each
Plaintiff
objects
to
this
Interrogatory
as
it
contains
involving
separate
and
distinct
guise
of
single
interrogatory
in contravention
of
the
limits
imposed by Rule
2-421
of the
Maryland and
Rules
of
Civil
Procedure
The Interrogatory
as
worded
is
overly
broad
vague
ambiguous
as well as
unduly burdensome
as
it
seeks
for Plaintiff
to identify
all
persons
with
personal knowledge
of the
facts
relevant
to the
issues
in the
case
even
if
she has
no knowledge
of
their existence
Further
Plaintiff
objects
to
this
Interrogatory
to the
extent
it
from discovery
by
the
attorney
work-product
doctrine
To answer
this
be required to provide
information regarding
counsels
litigation
strategy
in this
case
Without
waiving
and
subject
to said objection
Plaintiff
directs
Defendant
to her
Answer
to Interrogatory
No
SUPPLEMENTAL
objection
Plaintiff
ANSWER
her
NO
Answer
Without
waiving
and
subject
to
said
supplements
as
follows
Plaintiff
anticipates
that
discovery
in
this
case
will
provide
further
information
concerning
the
information
sought
by
this
Interrogatory
and
as such
reserves
the
right to continue
to supplement
to this Interrogatory
statements
were made
intentionally
and
recklessly
without
verification
of the
accuracy
of such
statements
and without
regard of the
falsity
thereof
The statements
place
Royle
in
false
position
by
attributing
false
conduct
to
Ms
19
Royle
with
namely
that
she
has
some
sort
of personal/inappropriate/sexual
relationship
Nick
Swisher
Further
the statements
place
Ms
Royle in
false
position
by attributing
to
Ms
Royle
false
characteristics
including
to
unprofessionalism
and
incompetence
in
regards to
her
occupation
Plaintiff
directs
Defendant
to
her
Supplemental
Answers
to
Interrogatory
Nos
and
and
Supplemental
Exhibit
and
Exhibit
INTERROGATORY
contend
to
NO
to
11
Describe
in
detail
any
other
damages
you
have
suffered
your
feelings
including
but
not
limited
to
distress
as
result
of
the
statements
identified
in
your answer
to
Interrogatory
No
special
state
the
nature
extent
and
duration
of
the
alleged
injury
or
damage
financial
any
damages you
allege
are
due
to such
injury or
damage
any and
all
losses
related
thereto
the
that
such
statements
were
the
proximate
cause
of
such
injury
or
damage
you
the
addresses
of
all
health
care
providers
who
treated
for such
alleged
injuries
the
dates
of such
treatment
ANSWER
interrogatories
NO 11
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
guise
of
single
interrogatory
in contravention
of
the
limits
imposed by Rule
2-421
of
the
Maryland and
Rules
of
Civil
Procedure
The Interrogatory
as
worded
is
overly
broad
vague
ambiguous
as
it
does
not
define
the
phrase
damages
Plaintiff
.suffered
to
your
feelings
Without waiving
and
subject
to said
objections
refers to
Dr
Goldiners
letter
produced
in response
to the
Defendants
Request
for Production
of
Documents
Plaintiff
20
has suffered
depression
and
fear that
any
slight action
may
cause
the
Defendants
to publish
spiteful
hateful
atrocious
and
false
statements
about
her
The aforementioned
has caused
Plaintiff
to alter
her work
habits
including
the
way
she
dresses
Plaintiff
is
currently
being
treated
by
Dr
Samuel
Liebman
1205
York Road
21
Lutherville
Maryland
21093
and was
treated
by Dr
William
Goldiner
MD
Internal
Medicine
Drive
207 Towson
medication
Maryland and
21204
Plaintiffs
damages Liebman
are
ongoing
as she
continues
to take
is
under
the
care
of
Dr
SUPPLEMENTAL
objections to the extent
ANSWER
NO
11 Without
waiving
and
subject
to
said
any responsive
information/documents
are
in the
immediate
custody possession
or
control
of the
Plaintiff
they have
been
produced
Plaintiff
will
supplement
this
Answer
with
any
further
information as soon
as
it
comes
into
her
custody
possession
or
control
Plaintiff
has
provided
all
of
Dr
Liebmans
contact
information
and
notes
that
the
Defendant
does
have
the
authority
to
subpoena
the
records
INTERROGATORY
those identified
NO 12
to the
Describe
in
detail
any
damages
other
than
in response
preceding
interrogatories
suffered
by you
as
proximate
result
of the
statements
identified
in your
answer
to Interrogatory
No
of
the
reasons
for
your
all
belief that
the
such
statements
were
the
proximate cause
any such
loss identify
persons
who you
contend
have knowledge
of such
person identified
state
the
substance
of that
persons
knowledge
21
ANSWER
Interrogatories
NO 12
Plaintiff
refers
to
and
incorporates
her
Answers
to
Nos
10 and 11
SUPPLEMENTAL ANSWER
damages
as supported
NO 12
Plaintiff
has
suffered
reputational
by
the
negative
comments
the
tweets
and
general
opinions held by
fans
who
have
heard
and
believe
statements
identified
herein
Additionally
Plaintiff
slut bitch
statements
and
other
insulting
names by
fans
who
have
heard
or read
the
Defendants
See Responses
to Requests
for Production
of
Documents
and Supplemental
Exhibit
INTERROGATORY
practitioner
NO 15
psychiatrist
Identify
any
health
doctor
physician
medical
psychologist
mental
counselor
or
mental
health
practitioner
that
visited concerning
your mental
and/or emotional
health
in your
lifetime
person
identified
state
their full
name
address
phone
number
and
the
of any
such visit
ANSWER NO
seeks information that
15
Plaintiff
objects
to this
Interrogatory
as
it
is
overly
broad
and
is
not material
to the
instant
litigation
The
Interrogatory
is
not
reasonably
calculated
to lead
to the
and
subject
to
said
objection
Plaintiff
has
visited
Drs
Goldiner
Answer
to Interrogatory
No
11
SUPPLEMENTAL
and Liebman
in regard to
ANSWER
her
mental
NO
15
Plaintiff
has
visited
only
Drs Goldiner
and/emotional
health
22
INTERROGATORY
including but not limited
NO 16
letters
Identify
and
describe
all
communications
to
and correspondence
from members
of the
public
sent to
you
that
relate to
your work
Plaintiff
in Baltimore
Maryland broad
ANSWER
NO 16
objects
to
this
Interrogatory
as
it
is
overly
as well as
unduly burdensome
term
as
it
seeks
for Plaintiff
to provide
all
communications
her
which
is
left
undefined
Plaintiff
has
ever
received
regarding
work
in
Baltimore
Maryland
Moreover
the
Interrogatory
seeks
instant
litigation
and
is
not reasonably
calculated
to lead
to the
SUPPLEMENTAL
information
exists
ANSWER
is
NO
16 To
extent
responsive
documents and/or
and
in
the
immediate
custody
possession
or
control
of
the
Plaintiff
it
has
been produced
To
extent
information responsive
to this
Interrogatory
comes
into the
Plaintiffs
possession
it
will be
produced
to the
Defendants
Plaintiff
has
complied
with
the
and
Requests
of
the
Defendants
which
are
responsive
to this
Interrogatory See
Plaintiffs
Supplemental
Responses
to Production
of
Documents
INTERROGATORY
history With respect
NO 19
answer
Describe
in
detail
your
entire
employment
information
to your
to this
interrogatory provide
contact
for
the
individual
who
can
verify
your
employment
each
describe
your
work
responsibilities
identify
your
direct
supervisors
at
place
of
employment
the
dates
of each
employment
your job
title
including
any changes
during
employment
and
the reason
each place
of
eniployment
23
ANSWER
interrogatories
NO 19
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
guise
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of
the
Maryland
The
interrogatory
seeks
litigation
and
is
not
reasonably
calculated
to
lead
to
the
discovery
of
admissible
evidence
Further
the
interrogatory
is
unduly burdensome
as
it
seeks for
Plaintiff
to
identify
employment
and employers
without
specification
to
relevant
well-defined
period
of
said
objections
Plaintiff
directs
Defendant
to
her
SUPPLEMENTAL ANSWER
supplemental information
NO 19
was
Plaintiff
provides
the
following
Ms
Royle
transferred
to
MLB
Advanced
Media when
MLB
Advanced
Media purchased
eliminated
the
YES Network
Advanced
website
her
previous
employer Her
position
was
at
MLB
Media
the
She
received
job offer at
Sirius/XM Radio
to
continue
covering
the Yankees
and
Mets
Ms
Royle
worked
for Sirius/XM
Radio
after
YES/MLB
Advanced
Media
Ms
Royle received
better
opportunity
at
MASN
and CBS
Radio
in Baltimore
and
relocated
after
the
conclusion
of the
2009 World
Series
When
for
CBS
lost
their flagship
rights
to the
Orioles
Ms
to
work
MASN Ms
because
her position
there
was eliminated
Ms
CBS
Royle received
an
offer for
and accepted
the
co-hosting
job
on Baltimore
Baseball
Tonight
Orioles unofficial
pregame
show
24
INTERROGATORY 21
with
Identify
all
former
or
current
professional
athletes
whom
you
have
ever
been
inclined
in
personal
relationship
sexual
relationship
and/or
inappropriate
relationship
including
but
not limited
to
any
current
or
former
player
or
member
Football
of the
coaching
staff
or
management
in Major
League Baseball
National
the
National
League
the
National Basketball
Association
the
Hockey
League
Major
League Soccer
the
Arena
Football
League
the
PGA
or
Tour
the
AW World
Tour
NASCAR
i.e
affiliate
of such
leagues
any
league
AAA
baseball
and
the
League
the dates
For each
person
identified
name
address
phone
and nature
of
any such
relationship
ANSWER TO INTERROGATORY
Interrogatory as
it
NO 21
Plaintiff
objects
to
this
contains
several
interrogatories
each involving
separate
and
distinct
of
single
interrogatory in contravention
of the
limits
imposed
by Rule
2-421
of
the
Maryland
Rules
of
Civil
Procedure
The
interrogatory
seeks
instant
litigation
and
is
not reasonably
calculated
to lead
to
the discovery
of
admissible
evidence
Further
the
Interrogatory
is
overly
broad
vague
and ambiguous
The
interrogatory
calls
for speculation
and conjecture
as
it
does
not define
the phrase
inclined
in
SUPPLEMENTAL ANSWER
about relationships with
NO 21
Defendants
have made
false
statements
Nick Swisher
Plaintiff
and
responses to these
athletes
Furthermore
as the
Interrogatory
fails
to define
the
phrase
inclined
in
and
the
Defendants
have
not supplemented
the
Interrogatory
to define
25
the
phrase
Plaintiff
continues
to object
on
the
grounds
that
this
Interrogatory
calls
for
speculation
and conjecture
has not had
Without waiving
these
objections
and
subject
thereto
the
Plaintiff
any inappropriate
as those
and/or
sexual
relationships
with
either
Nick
Swisher
or Brian
Matusz
words
Answer
to Interrogatory
No
20
NO 22
Identify
all
former or professional
athletes with
relations of any
nature
including
to
any
current
or
former
player
or
member
of
the
coaching
staff
or
management
Basketball
in Major
League
the
Baseball the
National
Football
League
the
National
Association
National
Hockey
League
Major
League
Soccer
the
Arena
Football
League
of such
the
PGA Tour
or
the
ATP World
minor
Tour
NASCAR
league i.e
affiliate
leagues
any
other
professional
AAA
baseball
and
the
Ameridan
Hockey
League
and
the
For
each
person
identified
state
their
full
name
address
phone number
dates
and nature
of
any such
relationship
ANSWER
interrogatories
NO 22
Plaintiff
objects
to
this
Interrogatory
as
it
contains
several
each involving
separate
and
distinct
guise
of
single
interrogatory
in contravention
of the
limits
imposed by Rule
2-421
of
the
Maryland
instant
The
interrogatory
seeks
litigation
and
is
not
reasonably
calculated
to
lead
to
the
discovery
of
admissible
evidence
Further
the
Interrogatory
is
overly broad
vague
arid
ambiguous Answer
SUPPLEMENTAL ANSWER
Interrogatory
NO 22
See
Plaintiffs
Supplemental
to
No
21
26
SOLEMNLY AFFIRM
the
under
the penalties
of perjury
that
the factual
matters
stated
Ia
Answers
to Interrogatories
my
Brian
Goodman
Moylan PESSIN KATZ P.A
Alexandra
HODES
Road
Suite 400
Towson Maryland
21 204-2600
410 410
938-8800 825-2493
Fax
28
234620-1
2/24/20
his
10
On
lists
in
Top Sports Media Members We Wouldnt Mind Seeing Few Weeks In honor of Tons Kornheisers suspension from ESPN
have compiled
for
lists
of the
top
sports
media members
suspended
few weeks
Drews
List
Jen Royle Glenn Clark Glenn Clarks Blog Comcast Morning Media Members
available
at
We Wouldnt Mind
Seeing
http//wnst.net/wordpress/glennclark/20
show-top-7-sport-media-mernbers-we-want-to-see-suspended/
Original
See
Plaintiffs
and Supplemental
Responses
to Request
for Production
of Documents
4/26/2010
stereotypical qualified
On
his
blog
she
is
v5ite
Swisher
states that
Ms
Royles
states
hiring
was
is
because
an out-of-towner
He
that
later
that
she
not of
Yankees
Nick
is
Jen Royle
105.7
duties
the
new
In typical of covering
the
teams
flagship
radio
station the
an out-of-towner
if
to handle to hire
team In
all
fairness
.no
youre going
beat
offense
What
been
of
will Jen
MacPhail Answer
fan
to even
if
ask anything
to the
Yankees
Maybe
hes
ever
Drew
from
Forrester
the
Blog
at
It
takes
20 minutes
Orioles
shouldnt run
challenge
flag
0/04/26/ittakesL20minutesorioles
See
of
Plaintiffs
Original
and
Supplemental
Documents
of an Orioles
5/19/2010
blogs that
Ms
Royles
description
game
she
character was wrong He later analogizes her to on the Jersey Shore because is disaster He states that he doesnt want her to do her job better
The
after
Ginsburg says Orioles touched up Royals bullpen Greinke departed for 10 inning win
APs
David
Supp Exhibit
000001
Supplemental Page
Exhibit
No
the
Orioles
did not
beat
cough
is
Zack Greinke
said
despite
at
105.7
cough
Jen Royle
They
did
however
game
started
by Zack
Greinke which
ALMOST
just as
good
with her
Edit from
similar to
GMC Some
disaster as
might say
Im obsessed
with
Theyre
The
right
Its
how many
of us are obsessed
that
Snooki
how
away
reality
is
much
say
better
probably
REALLY
to
Mornings
Crabs and Beer available
at
http //wnst.net/wordpress/glennclark/20
10/05/19/wednesday-mornings-crabs-and-
beer-102/ See
Production
Plaintiffs
Original
and Supplemental
Responses
to Request
for
of Documents.
6/5/2010
GMC
Softball
journalist
in
town
is
apparently playing
in
Celebrity
Game
by
With aRavensplayer whose name they cant spell Royle from Twitter.com
Tweet
copied
Ms
8/5/2010
Casey Willett
training that
co-worker
in
and
CBS
employee
that
notifies
Ms
just
Royle
camp
Westminster
MD
Ms PR
ripped
was
now
calling
Royle
Jen Midol
called
when
and
segment Chad
Jen Midol on
morning
show Drew
incident
Glenn
the
Ravens
Steele
and Patrick
Gleason
following
from
Baltimore
Sun spoke
with
Ms
Royle
Comments
what
the
knew
know
Yankees
term blitz
meant
knew who
the
Plaintiffs
Second
Supplemental
Answer
to
No
later
Some time
shake
Nestor
came up
to
me
his
my hand
your
radio
declined to shake
hand
said because
station
me
and
dont
appreciate
it
me
He
said
have
never said
cant
control
what
other
people
say
supp Exhibit
000002
Supplemental
Exhibit
Page
Isaid well
Im telling
away
you
now
and youre
the
owner
so
youre responsible
And
That ever
he walked
air
and
told everyone
was
the
biggest bitch
he has
met Ms
Royle
Emailfrom
9/7/20
10
During
Ravens practice
Ms
Royle claims
that
that
told
Damon
Yaffe
on
my resume anddo
it is
not have
the
credentials/
experience
saw
have
stated
to be covering
the
Ravens
why CBS
anyone
Letter to
better
Ravens
Gleason and Kevin
Ravens
sent
Bryne employees
Response
of the Baltimore of
in late
2010 See
to Production
Documents
PRDR
000076-000078
9/12/2010
Drw
ao
JenRoyleMASNcalled me
thought
douchebag
meant
in
here tonight
for the
Yankees
class
Ms Royle
in front of
anyone
to think
JenRoyleMASN hasnt
even
heard
me
say that
what shes wearing tonight would be considered trashy at the Gold Club Drew dont know if Glenn is D-Bag but do know this.. those boots
JenRoyleMASN is wearing
truth
Tweets
cut
are worth
and copied
from Twitter
into letter
to
Ravens
Ms
Royle
asks
them
to
Ms Royle
confronting
stop
later
in the
day
was Crossing
the
confronted
Mr Mr
unprofessional While
Forrester
Ms
Royle was
and yelled
Mr
Clark
walked by
the
altercation
Where
are your
boots
Ms
said
Royle Asked
Mr
No This
with
Drew
to talk
and Clark
and put
is
place
inside
Drew
let
then said
Go
home
your boots on
first
come
and
me
buy you
drink
Supp
Exhibit
000003
Supplemental Page
Exhibit
media member_Jon
and
Gallo of
CBS
Ms
Royle
made comments
looks like
the
stripper
Shes
complete
idiot
And Drew
Letter to
Forrester
made
comment
Id
boots
Ravens
Jon
the
Ravens
PR
Gleason
If you
dont
tell
WNST
to stop
negatively
like to have
my seat changed
9/20/20
10
CJ
Spiller blogs on
WNST
First of all roles
Good
freakin
Jen we understand
spot here
in
New
York media
to your current
girl
You
talk like
high school
trying
Jersey
reporter
blog on
WNST.1 Drew
Ravens
9/21/20
10
After
brief encounter
with
Forrester
at
the
facility
where
Ms
Royles
at the water Royle was approached space and asked her how she was
cooler
Drew
Forrester
invaded
Ms
Ms
Forrester
then yelled
to
Ms
Dont
Drew
you want
to
know how
tweets
am Ms
Royle
Forrester
later
girl
is
lucky
my
yet or
would have
snapped
her head
off
real
He
then tweets
It was
definitely to
water-cooler
moment
was shocked
at
the
way
she spoke
me
But
dig the
boots
Next
he tweets
Miss He He
America has
that
favorite
left
the
building without
apologizing
to
me.
.1
also tweeted
her
further
two
teams
the
Yankees
and
Rays
ago Rumor
is
tweets
lost
power
at
WNST
about 40 minutes
the
someone saw
away from
building
hee
hee
Blog
no
longer
available
on website
Supp
Exhibit
000004
Supplemental Page
Exhibit
Finally he tweets
is.
.LOL
10
On
or about
in
10/1/2010
Drew
Forrester
in
his chair
at
at
the
Ravens
facility
Owings
Ms
staring
her legs
Mr
Forrester
Ms
Royle witnessed
past
conference
room when
Ms
Mr
Clark
Clark
Dont
We
dont want
to get
in trouble stared
again Upon
at
commencement
legs as she
conference
Ms
Royles
walked
and laughed
Ms
Royle and
the
Defendants
have
personal knowledge
of
this
occurrence
10/8/2010
herself
Drew
tweet
1orjester
condemns Ravens
fan
jokingly encouraging
len to
kill
via
during the
game
game
at
appeared
to follow
Drews
home
len to
kill
of her
authored
tweet
encouraged
herself
It
wasnt
joke It came across as very serious and len took it that way cant stress how wrong it is for anyone to EVER encourage response implore someone to end their life
in her or
Drew
Mud
available
at
http//wnst.net/wofdpress/drewforrester/20
some-friday-mud/
Request
See
Plaintiffs
Original
for Production
of
Documents comment on
11/10/2010
bMw
st
Says
all
responds
to
his
blog
Anonymous
November
10th 2010
at
849
pm
the
silly
How
continue
Fan 105.7
DF Hey
that
len thanks
really
for stopping
by
know
kiddo
there
ISNT
you in seven weeks. .ever since that day at the and asked how YOU were doing and you didnt respond and bad poison
spoke
to
you
last
had
time
DONT CARE
Thats
you
media people
then youve carried on like town and nationally telling them how much
bunch of
weve
All
tweets
referenced
herein
are
no
longer
on
5upp
Exhibit
000005
mistreated
you
.when you
in fact
havent blog
bothered
in about
and the truth is we you know the truth months Thanks for checking out my
picture
.next
week
Ill include
of Nick
Swisher
or Brian
Matusz
for
you
Drew
Forrester
Drew
Forresters
at
Blog Wednesday
11/01/1 Original
QA
In honor
of Brooks
Ill
take 21 questions
available
hlp//wnst.net/wordpress/drewforrester/20 rush-through-friday-mud/
to Request for Production
See
of
Plaintiffs
Documents
11/18/2010
Didw
wont
as
get to star
This
Pub
tonight the
at
Rub
Elbows with
Stars
And no
It
that
to
to
meet
YOU
with
YOU
the
real
stars
WNST
Drew
Fullerton
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WNST.net
Blog Tonights
at
Drew
begins
Forrester
at
Forresters
the
night
Our canned
food
drive
The
Pub available
http //wnst.net/wordpress/drewforrester/20
10/11
8/tonights-the-night-our-cannedOriginal
food-drive-begins-at-the-fullerton-pub/ Responses
to Request for Production
of
and Supplemental
11/26/2010
b.eW
Fonester
blogs that
that
Ms
is
Royle
is
sports
insinuates
she
interested
Yankees
outfielder
Nick
Swisher
Its no
secret
that
radio
reporters
in
town isnt
fan of passed
Baltimore along
questions date
sports
teams
And
because
questionaire
to her with If
some
personal questions
One
of the
was this
ever have
handsome
and
wear
She
wrote
Well Ive
him
always
man
in
Id Drew
like
to look
like
Mud
available
at
hap //wnst.net/wordpress/drewforrester/20
10/11 /26/stuff-yourself-with-fridayat
mud/
link goes
to
picture
of Nick
Swisher
http//www.zimbio .compictures/d3hjwdZlpYeLBostonRedSoxvNewYork
Supp
Exhibit
000006
Supplemental Page
Exhibit
Yankees/yXBAZYPbiOY/NickSwisher
Supplemental Responses
to Request
See
Plaintiffs
Original
and
for Production
of
Documents
Drew
Forrester
for
2010
to
town
like
bull in
china
shop
and
she got
he rself by pissing on
all
things
Baltimore
Jen Royle
And
the vote
wasnt
close
Next topic
in
Drew
Forrester
Drew
at
Forresters
Blog
My
2010 Dec 29
2/29/my-best-ofto
2010 available
the-best-in-2010/ Request
hup //wnst.networdpress/drewforrester/20
10/1
See
Plaintiffs
Original
and Supplemental
Responses
for Production
of
Several
comments
on
the
blog show
affected
people
Steve Says
December 29th 2010
have
to
at
413
pm
us on Jen Royle
really
Oh
and while
you
.enlighten
all
Whats
her deal
and
gamer
the
hate Dont
know much
about her..
DF Hatebad
Shes
immediately
word No
one
HATES
Jen Royle
an out of towner
started
sucks
102
pm
Supp
Exhibit
000007
Supplemental Page
Exhibit
Man
she specifically
dogged Baltimore
it
to
you What
up on
it
say
to
DF
Brian err
or
is
Tom.
If
dogged
Baltimore
you havent
Stanton
Salter
Says
at
December
30th 2010
1207
pm
talk-show host bashing the very
Best example of
successflil
local
sports radio
marketing
efforts
WNSTS
once again in
Drew
Forrester
completely
ripping
Maryland Jockey
Clubs Preakness
Preak 2010
On
so the
slogan slogan
Preakness
in attendance
worked
have
stooped
to this level
this however
Your negative
by posting reminded
me
you
of
how
times town
My
question
to learn
is
this.
.Who
are
to criticize
talent
in
trying
Perhaps
she did
going
is
comfortable
for
in her
new
as the
surroundings
it
You
hand
have
been here
Baltimore
traditions
0s
Ive
and Marylands
largest
sporting
event
sticking
The Preakness up
for the
record
never
Only
new
town
1259
pm
bunch
of other Baltimore
reporters
So she
openly
If
literally
stood about
around
and
talked
how much
happen
so
is
It
interesting inclined
much
of an affect
on you
that
you
her
were
section
in your
2010 review
to call
indeed
DF Anyone
10/1
who
is
critical
of
has an affect
Drew
Forrester
Drew
in
2010 available
at
http//wnst.net/wordpress/drewforrester/20
2/29/my-best-of-the-best-in-20
10/
Supp
Exhibit
000008
Supplemental Page
Exhibit
Original
arid
Supplemental
Responses
to Request
for Production
of
1/20 11
Drew
Forrester
sends
shirt
series
of tweets
is
shed
snobby
look great in
tourist
nothing but
Nick Swisher
vacation
on
brief professional
here
tweets
she
is
ignorant
and clueless
while insulting
her bosses
who
thought
@WNST
at
Drew
So
Im handling
it..she
WNST.net
Hell
get
@mattvensel and jnroylemasn today might cry.. but its all good nonetheless
@WNST
great in
NOTjenrolemasn
shirt
bet
youd
look
Nick Swisher
and nothing
LOL
you know where
is. to
@WNST
find
yoitschad
the
her Shell be
how
cute
A-Rod
JenRoyleMASN Drew Im
you were wearing
yesterday
exhausted
trying
to figure
You
smelled fantastic
@WNST
stuck-up
JenRoyleMASNDrew And
tourist on brief
think the
fact that
youre
is
snobby
professional
vacation
here
COMICAL too
@WNST
of-town
Nester
When Ravens
who
season
are
ends
Ill engage
w/ignorant
out-
genius
journalists
clueless For
now Im purple
focused
@WNST
Renegade
KIND
to
Miss Yes
Jen
in corporate bosses
who
though
Mr Yeah theyre
qualified
Copied by Jen Royle from
twitter
1/11/2011
Drew
Forrester
tweets
that
that Jen
Royle
is
just
tourist in Baltimore
@WNST
Thats
her
Drew LOL
Im obsessed
is
with
her
tourist
an out-of-towner
5upp
Exhibit
000009
Supplemental Page 10
Exhibit
___________
tweets
his agreement
out-of
towners
@WNST
Baltimore
Sparky4ddub and
try to tell
Drew Well
to
ME
about Baltimore
using your
word. .annoying
let
Drew
write
today he handled
it
well Kudos
him
Drew
Forrester Out-of-towners
@WNST
to pick
beware
.this
isnt
good week
on Baltimore http//bit.Iv.fK3hnH
@WNST
Drew Hey
worries..
@DamStone
@mattvensel play
No
Drew
also posts
Ms
since
coming
to Baltimore
she has
good scent
Jen
the
flames since
the
presence
spring
And
she
in
FULL
disclosure
she
SMELLED
wearing
.it
like
million
Ravens
conference
Yesterday honestly
she was
was glorious
When
you
arrive
in Baltimore
to
work
where
is
in like
banshee
and kick
the
door
down
said
and say
son-of-a-bitch
Note
of the
that
It
No
it
wasnt Bowl
Brian
Matusz
Love
Ravens
with
those jeans
know
the
when
they
won
the
who was
so impressed
he bought
station beware
.this
Drew week
Forrester
to pick
at
Drew
Forresters
Blog
Out-of-towners
isnt
good
on Baltimore
http//wnst.net/wordpress/drewforrester/20 11/01/il /out-of-towners Original and
available
See
of
Plaintiffs
Documents
Supp Exhibit
000010
Supplemental Page
11
Exhibit
brew
continues
insulting
comments
in response to
comments
on
his
blog
Chris Says
January That
at
213
pm
he is eff the steelers and anybody from
sports
Drew
great blogger
pittsburgh
and stupid
and
em
all...
over4ODon
January
Says
2011
11th
at246pm
really have gall
These Daahnn
Laroche
Tahners
eat
crow about
the
non-offer/signing
to believe
And
only
sburg
A-HOLE
good
would expect
the
anyone Ravens
aint
wouldnt
mostly
incense
masses
of
Town
of
Flacco
but Bush-league
massses
in
BIRDLAND
subject
stirred up
Fridasys
MUID
1015 how
pm
rag
have
column
reading
about
he hated homeless
man your
perfume.
wouldnt were
attacks
onjen
royle
are so pathetic
dude
the
if
or read
man
obsessed
creepy old
man
stuff
she were
you
be spending
nearly this
much
time on her
DF
dude shed
Im obsessed
talk to people
coming
to
when
investment
in it
much
Blog
although
you
clearly
wrote
Drew week
Forrester
to pick
at
Drew
Forresters
Out-of-towners
beware
.this
isnt
good
on Baltimore
http//wnst.net/wordpress/drewforrester/20 11/01/11 /out-of-towners
Original
available
See of Documents
Plaintiffs
and
Supp
Exhibit
000011
Supplemental
Exhibit
Page
12
rwthen
on
comments
that
Ms
Royle
prefers
other
cities
and
is
just in Baltimore
scholarship
As for
crabs
that
girl
at
about
how much
the
and Sabatinos
is
Points
view of
sunset
of the matter
that
She knows
that Three
from
now
her apartment
or
Baltimore
will be occupied or
by someone
other
shell be in Chicago
Los Angeles
Miami
or
some
ritzy place
where her
other
perfume
habit
will be part of
some
stations
budget
..
Since posted
this Jen
EDITfrom
ferocious
DF
at
535pm
has launched
into
attack
claiming
among
talk
lot
other things
be
over his
in
team
to be
know
about claiming
is
something
since she
on
had
in
opportunities
when
because
she
ahem
gives
left
the
YES Network
to
chose
Baltimore
it
me
the chance
be
big fish
SMALL pond
Drew
Forresters
Drew week
Forrester
Blog
at
Out-of-towners
beware.
.this
isnt
good
to pick on Baltimore
available
http //wnst.netlwordpress/drewforrester/20
11/01/11
/out-of-towners-bewarethis
Original
See
Plaintiffs
and
for Production
of
Documents own
1/15/20
11
is
Drew
posts
picture
asking
viewers
to write
their
caption that
implies he
saying
Ms
Royle
is
failure
is
Someone
You Drew
Friday
fan of Friday
Mud
it
sent
me THIS PICTURE
read
Lay-Up
Ill
say
one
Im leaving
it
alone
to rush through
Forrester
Mud
available
http //wnst.net/wordpress/drewforrester/20
11/01
14/take-
.com/wp
taped
to Request
woman
with
FAILURE
Responses
mouth See
of
Plaintiffs
for Production
Documents
Supp Exhibit
000012
Supplemental
Exhibit
Page
13
1/20/2011
conflict
___________
of interest for
answers
question on
DCRTV.com
the
that
it
would be
for
Ms
Royle
to date
player on people
MASN
to stated
on
team and
MASN
sleeping with of
this
employqs were
demonstrating Brian
pitcher
is
the
of the Defendants
Ms
Royle
incident previously
available
http//www.dcrtv.com/davetvl.html
1/21/2011
Drew
link
is
Forrester picture
blogs with of
sign
link to
sign that
is
ruined
Ms
Royles
saying
Welcome
2010
to Baltimore
Hon
day
at
The
sign that
entire
RIGHT
better
HERE
the 11/01/21/friday-
Forrester
Drew
at
Blog
Friday
Mud
is
than
beach available
http //wnst.net/wordpress/drewforrester/20
mud-is-better-than-a-day-at-the-beach
link to
10/1 sign saying
http//www.baltimorebrew.compublish/wp-content/uploads/20 welcome-to-baltimore-katrina-krauss.jpg
picture
2/honto
of
Welcome
Baltimore
Hon See
of
Plaintiffs
Original
and Supplemental
Responses
to Request
for Production
Documents
BALIIMORE
1/26/2011
PtewFc
that
to
comments
on
the
only qualification
Ms
Royle has
to be in Baltimore
Magazine
that
she
5upp
Exhibit
000013
Supplemental
Exhibit
Page 14
also says
he
likes the
way
she.smells
and questions
why
she
athletes
Al Says
January
26th 2011
at
848 am
Baltimore
How
the
embarrassed
should
Magazine be
for promoting
certain
be that Baltimore
singles
should
actually
be from Baltimore
or an
active
member
of the Baltimore
Second question
friends horrible
When
said
how
agreed
all
her
to include
how
up
the
magazine
retraction
picture
Magazine
offer
community
her
travel issue to highlight
all
of
in
DE
This
question better
Magazine and
their
selection
committee
My
guess
you
WORK
so
in Baltimore
youre
sticker
eligible
havent
sexy
singles
our girl
and sniff
.if
mean
Thats
far
.1
26th 2011
at
1149 am
actually
air
Drew
always
sports
Have
you ever
talked
disrespect
her on the
because
female
and
according
to
smells
really nice
which
your
way
you know
she has
ajob
like
you
the
DF Youre
sports
funny Each
more Ive
talked
to Jen
Royle on
several
occasions
think she
said
sports
Ive
that
she doesnt
NEVER once said she didnt know know BALTIMORE And because
at all
What Ive
historical
perspective
on
the
Orioles
and
Ravens
My
remarks
about
how
great
are
COMPLIMENTS
on smelling
decide
She always
that great
smells great
Youd
admit
have
her
why
she
insists
around
bunch winner
of athletes
Thats
not for
me to
smells like
that
Supp Exhibit
000014
Supplemental Page 15
Exhibit
Drew
Forrester
Drew
Forresters going
to
Blog Back
in the
Returns
Update Were
See
OVERRRRR-T.LME
11/01 Original
/26/back-in-the-saddle-again-2
and Supplemental
Responses
to
for Production
of
Documents
Baltimores
outfit
1/28/2011-
Diew
to
Forrester
own
Jen
Royle
showed up
photo
Nick
Swisher
By
now
Im sure
of you have
features
Baltimore
as one
Magazine which
MASN
Evidently
shoot didnt go so
well
When
she arrived
at
the
location the
staffer
handed her an
something
asked
think depicts
the editor wouldnt my style THE CLOTHES SHE BROUGHT TO THE PHOTO
brought
SHOOT
Drew
Forrester
at
Drew
Forresters
Blog
Just in the
Mud
is
available
http/wnst.networdpressdrewforrester20
11/01/28/just-in-the-nickoutfit
of-time-its-friday-mud
available Plaintiffs
at
link provided
below and
hap product.images .fansedge coml3 2-30/32-303 54-F.jpg See to Request for Production of Original and Supplemental Responses
Documents
In the
comments
to the
on January
Jen Royle
and Drwotresthf
she could
handle it
malt Says
January
29th 2011
at
1130 am
Supp Exhibit
000015
Supplemental
Exhibit
Page
16
do think
stuff
is
funny
along with
everything
tail
else but
also
agree you definitely kindergarten pig pull thing going on towards her totally crushing on her for good reason looks not personality
the
have
pull
brett favre
on her
thats
my advice
but do
it
from
DF Whatever.
no reason you
for actually
little
chiding
Theres
me to have crush on anyone Im married And trust me once meet her the crush-thing ends Shes boorish snobby and
real
caustic
peach
nick of time its Friday 11/01/2
Drew
Forrester
at
Drew
Forresters
Blog
Just in the
Mud
to
available
http//wnst.net/wordpress/drewforrester/20
8/lust-in-the-nick-
of-time-its-friday-mud
Request few
for Production
See of Documents
on
Plaintiffs
Original
and Supplemental
Responses
other
comments Says
the
Tom
January
28th 2011
at
1142 am
too
it
Methinks
he doth protest
are tired
much
Usually
Royle jokes
Keep
to yourself if
youre
that
obsessed
so
pretty nice
though
dont blame
you
Good
Vicodins
are your
friend with
DF Methinks
how
silly tell
it is
you need
sense of
to
humor
in like
Im
for
an out-of-towner
come
bull in
shop
and try to
.11
me and
you
if
about Baltimore
sports
Steve Says
January28th 2011
at
141
pm
so disappointed
lot
Royle jab
huh Tm
for
Man
once
know
is
speak
of other
WNST
the
followers
girl
me
hope
just too
alone
She does
inferiority
best
of
fulfills
to
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anything to
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Mud
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available
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11/01/28/just-in-the-nick-
of-time-its-friday-mud Request
for Production
of
Original
and Supplemental
Responses
2/22/2011
is
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woman
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000017
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that
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guy See
of
Original
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Responses
to Request
for Production
Documents
3/29/2011
Drew
responds
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comments
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Ms
Royle
in
blog sarcastically
Mike
103
pm
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1/04/29/noPlaintiffs Original
stunner-herefriday-mud-is-back-and-hot-as-a-firecracker/
See
of
and Supplemental
Responses
to Request
for Production
Documents
3/30/2011
fiblogs
can search anywhere on the
that internet
You
truth
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like
and you
shred of evidence
weve
the
skills literally
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of public
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Supp
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000018
Supplemental Page 19
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Miss Royles
and she
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feelings
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its because
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Win
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staff
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on the internet We dont spread rumors We dont gossip We dont lie And were unabashedly able to own up to ANYTHING we officially report via
any of our media properties
at
WNST.net
our product
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ou why
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conclusion
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000019
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Page 20
Shes
the
public
figure
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to
go on
radio
And
she every
chooses
single
Baltimoreans
seemingly
day
of her
life
on
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internet
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truth
is
this
is
frivolous
case filed by
for herself
woman who
suing the
is
trying sports
to
come
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name
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best
media
day she
compan
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my company
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indictment of local journalism
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Nestor
Heres
Royle
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available
http //wnst.net/wordpress/nestoraparicio/20
11/03/30/an-indictment-of-local-
journalism-here%E2%80%99s-our-side-of-baseless-royle-v-wnst-lawsuit/
Plaintiffs Original
See
of
and Supplemental
Responses
to Request
for Production
Documents Comments on
blog Says
at
BmoreBobRob
March 30th 2011
1139 am
big steamer
all
love
how you
did
guys took
what you
someone better
being
qualified
wrong Was she qualifed to do the Yes can see where you have
but
think
knock
you guys went too far You really crossed the line Its like you want to act like Howard Stern and dump all
fun of people but then you want the same people to
journalist
make
you
are
it
Ted Koppell
both
respected
and opinion
maker
You cant
.1
have
ways
Tom
Says
at
1059 am
someone who worked
surprised
it
to see
so hard to create
all
that
they
point
cant imagine
lawsuit
out of the
is
clear epic
You
some
So Royle
calls in
you
still
out
for repeatedly
trashing
her reputation
and
ability to
do her job
difficult
economy
to
Supp
Exhibit
000020
Supplemental Page 21
Exhibit
find
employment
in and
you have
the
nerve to be
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worried
essentially
shes going
trying to
to take the
everything
to her
you have
do
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by
attempting to
make
everyone
believe
she was
Karma
is
bitch
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make you
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win
any
woman who
See
Plaintiffs
Original
and Supplemental
Responses
to Request
for Production
of
Documents
6/4/2011 Baltimore
blogs
Sports Expert of the
in
honor
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considers
In honor
had
trouble together this
reporter from
the
FM
we
sports
station
in
town
thought
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put
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Top
which came on
Wednesday
week
was
topic
The Top
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hope
its self
Baltimore
Sports
Expert As always
explanatory Glenn Clark Glenn Clarks Blog Morning Reaction Tuesday Top Things You Need To Do To Consider Yourself Baltimore Sports Expert available at
http //wnst.net/wordpress/glennclark/20 11 /05/25/morning-reaction-tuesday-top-7-
things-you-need-to-do-to-consider-yourself-a-baltimore-sports-expert/
Plaintiffs Original
See
of
and Supplemental
Responses
to Request
for Production
Documents Drew
Boston and compares Jen Royle
is
6/10/2011 another
Forrester
blogs
insulting
to
media person
insinuating
Ms
Royle
pained
Speaking
allowed Stanley
the
of Boston
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it
by
Canucks and
have
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of the
Cup
up
at
2-games apiece
know
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me
know
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or something
even
morsel of success
come
Club
of Brookline
where
Curtis
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won
one of
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Exhibit
000021
Supplemental Page 22
Exhibit
Well
heritage
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need
to take
that the
back
record
apologize voted
is
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PART
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sure
and will
heard by
now
that
For Mark
981
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note
Ill mention
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good Vivianos
new
stressful life
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talk host
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is
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sports
As
is
always
the
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As
to
rumors
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about
for
his replacement
has become
custom
someone
out-of-state
come
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Rumor
and
that
is
has
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their search
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native
of South with
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passed
her interview
talk
flying colors
and
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edition
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Friday
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short.
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at
hap //wnst.netlwordpress/drewforrester/20
edition-of-friday-mud-sure-isnti
11/06/1
0/hit-records-are-shortbut-this-
first link to
at
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Plaintiffs
Response
to
Comment on rwTthiesters
blog
states
that Jen
Royle
references
are
common
Mike
June
10th
921 am
The
in
Mud
is
like
fmding
the
toy
in
the
cereal
box Love it
think
DF Huh
pitch..
To borrow
line
from Bull
Meat
just
with
it
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Forresters
at
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Friday
Forrester
Blog Hit
records
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short
of
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sure
isnt available
hflp //wnst.net/wordpress/drewforrester/20
11/06/1
0/hit-records-are-shortbut-thisOriginal
edition-of-friday-mud-sure-isntl
See
Plaintiffs
and Supplemental
Responses
to Request
for Production
of
Documents
Supp Exhibit
000022
Supplemental
Exhibit
Page
23
6/11/2011
reporters
Ms
who
Royle
contacts
__________
to complain that
that
Glenn
Forrester
told
knew
told
about Jerry
Coleman
he had
reliable
Warehouse
him
that
Ms
Royle had
relationship
with
Hi Greg
Sorry to
reporters reliable
bitter
you with this.. But Drew Forrester told some was sleeping with Matusz and is now saying it came from
guarantee
Drew
is
going
to throw
that
to
make
Any
idea
who
warehouse source
this
putting
ridiculous
rumor
Again Tm
but
its
for the
drama
and
if
you know
verydisheartening
directly
and
disturbing
these
come
from
the
organization
especially
when
was an employee of
MASN
Thank
you
Jen
Email from Jen Royle
there
was
real source
would love
to
know who
have
this supposed
source is
doubt
he has
one
about
No
it
one
know would
spread such
it
rumor
spoke
with
clear
Monica
know where
in spring
was
to her after
Brian and
training
wouldnt
mongering and
doubt
is
specifically
mentioned
this
no
doing
whatever
she can to
curtail
the
am
or any
media members
this
season
Email from Greg Bader See
Request
for Production Plaintiffs Original
and
Supplemental
Responses
to
of
Documents
6/16/2011 undercutting
his
tweets
to
Gold Club
strip
club
argument
Ms
Royles Ravens
22812
PM
Supp
Exhibit
000023
Supplemental
Exhibit
Page 24
to
NOW
1/2
price
to save
www.wnst.net/youpon
from
places
Baltimore
Copied
by Jen Royle
Unknown
Dates
Drew
season
Forrester
t-weets
at
the
beginning
of the 2010
for
Ravens
RT
You
BALT
sent
or
from her
couch
twitter
9/27/10
On
or about September
on
blog that
short
why Jen
Royle
wear
be on
the
skirts
she
wont
TV
and
that
outside
that
This demonstrates
is
Defendants
because she
Ms
Royle
employed only
otherwise
an attractive
female but
is
job
Coleman from Fox on
with
or about
Drew
July
Forrester
tells
Jerry
2010
he had
You
Matusz
Coleman
that
right Drew
that
Forrester
Jerry
can and
confirm Warehouse
Defendant
incident
Forrester
Coleman
of
this
have
personal knowledge
Supp Exhibit
000024
PLAINTIFFS EXHIBIT
Dianne Royle
Mother
knowledge
of Plaintiffs
career
and
personally
droyleconicast.net
Beth
Royle
Sister-in-law
knowledge
of Plaintiffs
career
and
personally
Labrozzi
of Plaintiffs
professional
career
dave.labrozzi@cbsradio.com
Bob
Philips
Boss
of Plaintiffs
professional
career
bob.philips@cbsradio.com
Jim Cuddihy
Former boss
MASN
knowledge
of Plaintiffs
professional
career
jcuddihymasnsports.com
John Angelos
contact
knowledge
immediate
of Plaintiffs
professional
career
information
possession
custody or control
Jim Duquette
Friend/Co-worker
knowledge
of Plaintiffs
professional
career
jrduqettecomcast.net
Ken Weinman
Friend/Co-worker
knowledge
of Plaintiffs
professional
career
ken.weinman@cbsradio.com Conn
of Plaintiffs
Jeremy
Friend/Co-worker
knowledge
professional
career
jcole5545@aol.com
Scott
Garceau
Friend/Co-worker o.com
knowledge
of Plaintiffs
professional
career
scott.garceaucbsradi
Bob Haynie
Friend/Co-worker
knowledge
of Plaintiffs
professional
career
bob.hayniecbsradio.com
Damon
Yaffe
Friend/Co-worker
knowledge
of Plaintiffs
professional
career
damon.bulldog.yaffegmail.com Ed Norris
of Plaintiffs
Friend/Co-worker
knowledge
professional
career
ed@l057thefan.com
Bruce
Cunningham
is
Friend/Co-worker
knowledge
of Plaintiffs
professional
career
contact
information
immediate
possession
custody or control
employee
is
at
WBAL
knowledge
immediate
of Plaintiffs
professional or
career
contact
possession custody
control
Exhibit
000001
Jerry
Coleman
Formerly
of
FOX
1370
AM
knowledge
of Plaintiffs
professional
career
301-
12-5800
Jon Gallo
Formerly
of
CBS
Sportsline knowledge
of Plaintiffs
professional
career
443-695-
2226
Casey career
Willett
WBAL
and
formerly of
of Plaintiffs
professional
dwill77@aol.com
Exhibli
000002
JENNIFER ROYLE
Plaintiff
IN
THE
CIRCUIT
COURT
FOR NASTY
1570
SPORTS LLC
et
al
BALTIMORE
CASE
CITY
Defendants
NO 24-C-11001571
on
this
8th
day
of July
2011
copy
of the
foregoing
Answers
to Interrogatories
directed
to Jennifer
Royle on behalf
of
WNST
SPORTS MEDIA
prepaid to
LLC
one
of
Defendants
was mailed
via
first-class
mail postage
Charles
Tobin Esquire
Drew
Holland
2099 Pennsylvania
Suite
N.W
100
Washington
D.C
202
Attorney
1Qt50
Brian
Goodman
Moylan PESSIN KATZ P.A
Alexandra
HODES
Road
Suite 400
Towson Maryland
21204-2600
410 410
938-8800 825-2493
Fax
EXHIBIT
July
10
15 2011
Letter
to Plaintiffs
Counsel
Holland
2099
Pennsylvania Knight
Krnght
NW
Suite
Avenue LLP
100
Washington
DC 20000
202.955.3000
202.955.5564
Holland
www.hklaw.com
CHARLES
TQSIN
202
419-2539
charIes.tobinhkjaw.eom
July
15 2011
Brian
Goodman Esq
Pessin
Member Hodes
901
Katz P.A
Suite
400
Towson
MD
21204
Dear
Mr
Goodman
This
is
to
confirm
our telephone
conference
today
During
our discussion
in the
asked
for
you
to
confirm
that
the
numbered
1-18 enumerated
constitute
Ms
Royles Supplemental
that
Answer
Interrogatory actionable
Number
served on July
only statements
she contends
in this litigation
You
confirmed
that
our understanding
is
correct
that
representation
we do
not intend
at this
time to pursue
motion under
1-341
Sincerely
HOLLAND
KNIGHT
LLP
Charles
Tobin
CDThje
lO477977vl
EXHIBIT
to
11
WNSTs
Document Requests
JENNIFER ROYLE
Plaintiff
IN
THE
CIRCUIT
COURT
FOR NASTY
1570
SPORTS
LLC et
at
BALTIMORE
CASE
CITY
Defendants
NO 24-C-11001571
PLAINTIFF JENNIFER
ROYLES RESPONSES TO
WNST SPORTS MEDIA LLCS FIRST REQUEST FOR DISCOVERY OF DOCUMENTS ELECTRONICALLY STORED INFORMATION AND PROPERTY
Jennifer
Royle
Plaintiff
by
her
attorneys
Brian
Goodman
and
Alexandra
Moylan
of
Modes
Pessin
to
First
Request
For
Discovery
of
Documents
Electronically
Stored
Information
to her
by
WNST
Sports
Media LLC
states
INTRODUCTION
The
based following responses
represent the Plaintiffs to
present date
knowledge
Discovery
the right
on
discovery
trial
investigation
and
trial
preparation
Plaintiff
investigation and
to rely
preparation
are continuing
expressly
reserves
upon
further
information adduced
upon completion
or
of discovery
investigation
and
trial
preparation
and
to supplement
amend
Plaintiff
objects
is
to to
the
portions
of the
requests
purporting
the extent
to
dictate
the
maimer
in
which
are
Plaintiff
produce
documents
or
at
To
that will
responsive
documents documents
in
her
possession
available
for inspection
control
the or
offices
Plaintiff
make
such
of
Modes
copies
Pessin
Katz
as
P.A
at
such
time as counsel
available
may
mutually
agree
will provide
to counsel
they become
objects
to each or
to the
in
extent
the
Request
of
seeks
work
product
information
materials
contemplation
litigation
information or communications
or communications
protected
by the
privilege or the
information mental
or
opinions
impressions
other
conclusions
attorneys
accountants
representatives
Plaintiff
objects
to each or
to the in the
extent
the
Request
of
seeks
work
product
information
materials
course
settlement
discussions
Plaintiff
does
not waive
any
or
protections
or of
privileges
these
Requests
Inadvertent
of such
production
or
exposure
any such
other
constitute the
waiver
privilege
immunity
or of any
ground
admissibility
of such
documents
or of any
information contained
therein
Plaintiff
objects
to each
to the
extent
is
the
Request
seeks
to
information that
the
is
not relevant
to this
or information that
not
likely
to lead
case
Plaintiff
objects
to
each
and
every
Request
repetitious
to the
extent
the
Request
is
overly
broad
the
unduly burdensome
that the
harassing purport
to
vague
the
and/or ambiguous
of
and
to
extent
Requests
require
disclosure
information
beyond
the scope
of admissible evidence
Plaintiff
objects of the
to these
Requests Rules
on
of
the Civil
grounds
that
they exceed
and/or
are
in
contravention
Federal
Procedure
and
the
Discovery
Guidelines
Plaintiff
objects or
to
these
Requests
to
the
extent
they
seek
information
technical
regarding
financial
trade
secrets
other
confidential
commercial
proprietary
or business
information
Statements
as
that that
responsive
documents
an acknowledgment
possession
they will be
produced
if
in the
custody
of Plaintiff the
offices
Documents
of
are immediately
available
for your
inspection Suite
and copying
Hodes
attorneys
Pessin
for
Katz
901
Dulaney
costs
Valley
Road
21204
Plaintiff
Copying
will be borne
by
the Plaintiff
Plaintiff
objects to the
to each
of these
Requests
privilege
to the
extent
that
Plaintiff
seeks
information
doctrine
subject
attorney-client privileges
and/or
attorney
work
of of
or other shall of
applicable
Inadvertent production
of such of privilege
or exposure
document ground
not constitute
to the
waiver
objection
admissibility
such
234664-1
contained
therein
Unless
to
expressly
noted
to the
contrary
the
following responses
that
do
any document
subject
to such
privileges
were generated
of other separate
received
by
Plaintiff
to counsel
schedule
in
documents withheld
writing
on
grounds
any
will be provided
Plaintiff Plaintiff
has
discovery in Responses
this
if
lawsuit
and
therefore
additional
reserves
the
right to
Supplemental
By
objections to
its
providing admission
the
information
requested grounds
Plaintiff
does
not
waive
or
on
the
of relevance
materiality
on
any
other
proper grounds
Neither production of
is
Plaintiffs
agreement
or as
to
produce
or
nor
her
objections
of
to
the or
any
to
information be construed
documents
an
any
or
category
information
that
documents
admission category
acknowledgement
any
or categories
Plaintiff
objects
to any
Request
to
the
extent
that
it
requests
disclosure
of
information banned
objects the to the extent
and/or
any
protected seeks
from
disclosure
by law and
Specifically
Plaintiff
Request
disclosure
of information the
which
is
protected by
Shield
First
Amendment
Code
of the
United
State
Constitution
Maryland
State 297
Law
See
Md
413
Ann
Courts
Judicial
Proc
9-112
Tofani
Md
165 465
A2d
1983
These
objections to are hereby general
incorporated response
into each
specific
objection
and
is
response not
Citation of any
particular general
and any
specific
objection
below
waiver
of the
objections
Plaintiff
reserves
the
right to
her
responses
is
and
objections of that
to
Defendants Requests
and
response to any
Requests
not
waiver
right
RESPONSES REQUEST
relate to the
NO NO
All
which
refer
reflect
or
Defendants
RESPONSE
broad
Plaintiff
objects
to the
foregoing Request
as
it
is
overly
unduly burdensome
harassing
as
it
requires
Plaintiff
234664-1
to
produce
voluminous
documents
that
are
unrelated
to
the
allegations
of
the
Complaint
Moreover
Plaintiff
objects
to
this Request
as
it
does
not specify
time
period
for
are
sought
The Request
as
worded
is
not reasonably
calculated
to
lead
to
the
that
is
not relevant
to the
Complaint Further
the
Request
seeks
disclosure
of
information which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in
anticipation
of litigation
Plaintiff
objects
to the extent
this
Request
seeks
documents
custody
or
control
of
the
Defendants
or
which
may
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
less
burden than by
the Plaintiff
REQUEST
Defendant
NO NO
All
between
RESPONSE
Plaintiff
objects
to
this
Request
as
overly
broad
unduly burdensome
vague
and/or ambiguous
as
it
fails
to
define
time period
for
are
sought Further
Plaintiff
objects
to this
Request
to
the
extent
it
seeks documents
or
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
burden than
the
Plaintiff
Without
waiving
these
objections
to
the
extent
non-privileged
documents
exist
REQUEST
anyone
concerning
NO
the
All subject
documents
matter of
this
and
communications
between
you
and
lawsuit
234664-1
RESPONSE
NO
Plaintiff
objects
to the
foregoing Request
as
it
is
overly
as
it
requires
Plaintiff
to
produce
documents
that
are
unrelated
to
the
allegations
of
the
Complaint Moreover
period for which such
Plaintiff
objects
to
this
Request
as
it
does
not specify
time
documents
and communications
are
sought
The Request
as
worded
Further
is
not reasonably
calculated
to lead
to the
the Request
seeks
disclosure
of information
which
is
protected
by
the
attorney-
client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigation
Plaintiff
objects
to
the
extent
this
Request
seeks
documents
or
information
already in the
custody
or control
of
the
Defendants
or
by
the
Defendants
more conveniently
less
expensively
and
less
burden
than
by
the
Plaintiff
REQUEST
relate to
NO
All that
which
in
refer
reflect
or
your
contention
defamed
as
alleged
Count
of
your
Complaint
RESPONSE NO
it
Plaintiff
objects
to the
foregoing
Request
to the
extent
seeks
disclosure
of information
which
is
protected
by the attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in
anticipation
of
litigation
Plaintiff
objects
to the
extent
this
Request
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by
the
Plaintiff
or
by
this
Request
Without waiving
these
objections
to
the
extent
other
non-privileged
non
234664-i
protected
responsive
documents
exist
the
will be
produced
Plaintiff
refers Defendant
to Exhibit
attached
to Plaintiffs
Answers
to Interrogatories
REQUEST
relate to
NO
All that
which
false
refer
reflect
or in
your
of
contention
light as
alleged
Count
III
your Complaint
RESPONSE NO
REQUEST
relate to your
See Response
to Request
No.4
which
NO NO
All
refer
reflect
or
Answer
to Interrogatory
No.4
RESPONSE
REQUEST
See Response
No
which
refer
reflect
NO
All
or
you have
emotional distress
RESPONSE NO
it
Plaintiff
objects
to
the
foregoing Request
to the
extent
seeks disclosure
of information
which
is
privilege
the
attorney
work-product
doctrine
and or
extent
created
in anticipation
of
litigation
Without
waiving
these
objections
to
the
non-privileged
and non-protected
responsive
documents
exist
REQUEST
relate to
NO
All
which
refer to the
reflect
or
any Twiuer.com
but not limited
account
to
from 2008
For
all
present
including
shall
Jen
obtain
and @JenRoyleMASN
history including information by sending
this
request
sent
you
complete
account
this
tweets
written
by you
to
from each
Twitter
You may
request
of
by
415-222-9958
identification
signed
by
you
together
with
copy
valid
government-issued
card
RESPONSE
broad
NO
Plaintiff
objects
to the
foregoing Request
as
it
is
overly
as
it
requires
Plaintiff
to
produce
are
unrelated
to
the
allegations
of
the
Complaint
as
Plaintiff
uses
this
medium
daily
pursuant
to
her professional
duties
234664-1
Moreover
the
Request
fails
to define
in
as
worded
is
not
reasonably
calculated
to lead
Plaintiff
objects
to
the
extent
this
Request
seeks documents
or
information already
in the
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by
the
Plaintiff
Twitter will
then send
you
confirmation
to the
for
you on
file
which
will
to
you
the
requested
information
REQUEST
former professional professional Major
NO
athlete
All
documents and
communications
with
any
current
or
from 2000
but
is
to the present
of this question
not limited
Football
or former
player
Basketball
in
League
the
National
National
the
Association
Hockey
minor
League
Major
Arena
Football of the
League
such
the
PGA
or
Tour
any
the other
NASCAR
league
minor league
affiliate
leagues
professional
AAA
baseball
and
American Hockey
League
Plaintiff
RESPONSE NO
broad
objects
to the
foregoing Request
as
it
is
overly
as
it
requires
Plaintiff
to
produce
documents
that
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Plaintiff
objects
to the extent
this
Request
seeks
disclosure
of
information which
is
protected
by
the
First
Amendment
Code
of
the
United
State
Constitution
and
the
Maryland
Shield
Law
See
Md
Ann
Courts
Judicial
Proc
extent
9-112 Tofani
State 297
Md
1983
Plaintiff
objects
to
the
this
Request
seeks
documents
or
information already
in the
custody
or
234664-1
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
the Plaintiff
REQUEST
former player
NO 10
present
All
documents
coaching
communications
with
any
current
or
member
of the
staff or
management
in Major
League Baseball
from 2000
to the
RESPONSE NO 10
Plaintiff
objects
to the
foregoing Request
as
it is
overly
as
it
requires
Plaintiff
produce
voluminous
documents
that
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the Plaintiff
objects
to the
extent
this
Request
seeks
disclosure
of
information which
is
protected
by
the
First
Amendment
Code
of
the
United
State
Constitution
and
the
Maryland
Shield
Law
See
Md
Ann
Courts
Judicial
Proc
9412
Tofani
State 297
Md
1983
Plaintiff
objects
to
the
extent
this Request
seeks
documents
or
information already
in the
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
the Plaintiff
REQUEST
former player
baseball
NO 11
Ail
documents
coaching
communications
with
any
current
or
member
of the
staff or
management
in the
New
York Yankees
organization
from 2000
to the present
RESPONSE NO 11
Plaintiff
objects
to the foregoing
Request
as
it
is
overly
as
it
requires
Plaintiff
produce
voluminous
documents
that
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Plaintiff
objects
to the extent
this
Request
234664-1
seeks disclosure
of
information which
is
protected
by
the
First
Amendment
of
the
United
State
Constitution
and
the
Maryland
Shield
Law
Md
Code
Ann
Courts
Judicial
Proc
extent
9-112 Tofani
State 297
Md
1983
Plaintiff
objects
to
the
this
Request
seeks
documents
or
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
the
Defendants
more
conveniently
less
expensively
and with
Plaintiff
REQUEST
former
baseball
NO 12
All
documents
coaching
to the
communications
or
with
in the
any
current
or
player
member
of the
staff
management
New
York Mets
organization
from 2000
present
RESPONSE NO 12
Plaintiff
objects
to the foregoing
Request
as
it
is
overly
as
it
requires
Plaintiff
produce
voluminous
documents
that
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Plaintiff
objects
to the
extent
this
Request
seeks disclosure
of
information which
is
protected
by
the
First
Amendment
of
the
United
State
Constitution
and
the
Maryland
297
Shield
Law
See
Md
Code
Ann
Courts
Judicial
Proc
extent
9-112 Tofani
State_
Md
1983
Plaintiff
objects
to
the
this
Request
seeks
documents
or
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
the
Plaintiff
REQUEST
former
baseball
NO 13
All
documents
coaching
to the
communications
with
in the
any
current
or
player
member
of the
staff
management
Baltimore Orioles
organization
from 2000
present
234664-1
RESPONSE
NO
13
Plaintiff
objects
to
this
Request
as
it
is
overly
broad
unduly burdensome
voluminous
harassing
vague
and/or ambiguous
as
it
requires
Plaintiff
to
produce
documents
that
are unrelated
to the
allegations
of the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
discovery
of
admissible
evidence
Further
the
Plaintiff
objects
to
the
extent
this
Request
seeks
disclosure
of
information which
is
protected
by the
First
Amendment
of
the
United
State
Constitution
and
the
Maryland
Shield
Law
See
Md
Code
ArirL
Courts
Judicial
Proc
extent
9-112
Tofani
State 297
Md
1983
Plaintiff
objects
to
the
this
Request
seeks
documents
or information already
in the custody
or control
of
the
Defendants
or
by
the
Defendants
more conveniently
less
expensively
and with
the
Plaintiff
REQUEST
former
football
NO 14
All
and
or
communications
with
in the
any
current
or
player
member
of the
staff
management
Baltimore
Ravens
organization
from 2010
present
RESPONSE
broad
NO
14
Plaintiff
objects
to the foregoing
Request
as
it
is
overly
as
it
requires
Plaintiff
to
produce
that
are
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Plaintiff
objects
to the
extent
this
Request
seeks disclosure
of
information which
is
protected
by
the
First
Amendment
Code
of
the
United
State
Constitution
and
the
Maryland
297
Shield
Law
See
Md
Ann
Courts
Judicial
Proc
9-112 Tofani
Statefl
Md
1983
Plaintiff
objects
to
the extent
this
Request
seeks
documents
or
custody
or
10
234664-1
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by
the
Plaintiff
REQUEST
relate to
NO 15
All
which
refer
reflect
or
demo
reel
or the
like
from 2000
to the present
RESPONSE NO 15
unduly burdensome
harassing
Plaintiff
objects
to
this
Request
as
it
is
overly
broad
Further
Plaintiff
objects
to
the
extent
the
Request
seeks
is
relevant
to
the
pending
litigation
nor
likely
to lead
to
the
discovery of admissible
evidence
Without waiving
these
objections
and
to the
extent
responsive
documents
exist
REQUEST
relate to your
NO 16
All
which
refer
reflect
or
105.7
The Fan
RESPONSE NO 16
Plaintiff
objects
to the foregoing
Request
as
it
is
overly
as
it
requires
Plaintiff
to
produce
to the
allegations
Plaintiff
objects
to
this
Request
as
it
does
not specify
time
period
for
documents
and
communications
are
sought
of
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
discovery
admissible
evidence
Further
the
Request
seeks
disclosure
of
information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in
anticipation
of
litigation
Plaintiff
objects
to
the
extent
this
Request
seeks
documents
or
information
already in the
custody
or control
of the
Defendants
or
by the
Defendants
more conveniently
less
expensively
and
burden
than
by
the
Plaintiff
Without waiving
these
objections
to
the
extent
that
non-privileged
and
non
11
234664-1
protected
documents
exist
and
are
in the
possession
of
the
Plaintiff
they will
be
produced
REQUEST
relate to your the
NO 17
All
which
refer
reflect
or
employment with
from January
2010 to
present
RESPONSE
broad
NO 17
Plaintiff
objects
to the
foregoing Request
as
it
is
overly
as
it
requires
Plaintiff
to
produce
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not reasonably
calculated
to
of admissible
evidence
Further
the
Request
seeks
disclosure
of information
which
is
protected by the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in
anticipation
of litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or
information
already
in the
custody
or
control
of
the
Defendants
or
which
may
be
obtained
by
the
Defendants
more conveniently
less
expensively
and with
less
burden
waiving
these
objections
to the
extent
that non-privileged
exist
and
are in the
they will
REQUEST
relate to your
NO 18 NO
All
which
refer
reflect
or
employment with
MLB
Advanced
to the present
RESPONSE
18
Plaintiff
objects
to the
foregoing Request
as
it
is
overly
as
it
requires
Plaintiff
produce
documents
that
are
unrelated
to
the
allegations
of
the
Complaint The
of admissible
Request
as
worded
is
not reasonably
calculated
to lead
to the
discovery
12
234664
evidence
Further
the Request
seeks
disclosure
of information
which
is
protected by the
attorney-client
privilege
the
attorney
work-product
doctrine
and/
or
created
in
anticipation
of litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or
information
already
in
the
custody
or
control
of
the
Defendants
or
which
may
be
obtained
by
the
Defendants
more conveniently
less
expensively
and with
less
burden
these
objections
to the
extent
that
non-privileged
exist
and
are in the
possession
of the
Plaintiff
they will
REQUEST
relate to your
NO 19
All
which
refer
reflect
or
employment with
XM Satellite
Plaintiff
Radio Holdings
from 2008
to the present
RESPONSE
NO
19
objects
to
the foregoing
Request
as
it
is
overly
as
it
requires
Plaintiff
to
produce
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
evidence
as
worded
is
not reasonably
calculated
to lead
to the
discovery of admissible
Further
the Request
seeks
disclosure
of information
which
is
protected by the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in
anticipation
of litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or
information
already
in
the
custody
or
control
of
the
Defendants
or
which
may
be
obtained
by
the
Defendants
more conveniently
less
expensively
and with
less
burden
these
objections
to
the
extent
that
non-privileged
and non-protected
be produced
documents
exist
and
are in the
possession
of the
Plaintiff
they will
13
234664-1
REQUEST
relate to your
NO 20
All
which
Sports
refer
reflect
or
New
with
Yankees
Entertainment
and
Network
or the
organization
from 2003
to the present
RESPONSE NO 20
broad
Plaintiff
objects
to the
foregoing Request
as
it
is
overly
as
it
requires
Plaintiff
to
produce
are
unrelated
to
the
allegations
of
the
Complaint The
admissible
Request
as
worded
is
not reasonably
calculated
to lead
to
the
discovery
of
evidence
Further
the
Request
seeks
disclosure
of information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in
anticipation
of litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or
information
already
in
the
custody
or
control
of
the
Defendants
or
which
may
be
obtained
by
the
Defendants
more conveniently
less
expensively
and with
less
burden
than
by
the
Plaintiff Without
waiving
these
objections
to the
extent
that
non-privileged
and non-protected
be produced
documents
exist
and
are in the
possession
of the
Plaintiff
they will
REQUEST
relate to insinuate that
NO 21
are
All
which
refer
reflect
or
your contention
that
WNST made
qualified or
you
not
journalist
Complaint
X20
Plaintiff
RESPONSE NO 21
disclosure of
objects
to
the
foregoing
Request
as
it
seeks
information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of litigation
Plaintiff
objects
to the
extent
this
Request
in the
custody
or
control
of
the
Defendants
or
which
may
be
obtained
by
the
Defendants
more
14
234664-1
conveniently
less
expensively
and with
less
burden than by
the
Plaintiff
considering
most
of the
communications
relating to
this
Request
were published by
the
Defendants
on
the
WNST
website
and/or made on
their
own
radio
shows
Without
waiving
these
objections
to the extent
that
non-privileged
exist
and
are
in the
possession of the
Plaintiff
Plaintiff
to Exhibit
attached
to Plaintiffs
Answers
to Interrogatories
REQUEST
reflect
NO 22
to
AU
contention
documents
that
and
communications statements
sexual
which
refer or
or
relate
your
that
WNST made
in personal
implications
inappropriate
otherwise insinuated
relationships
you
are
involved
and/or
athletes Complaint
20
Request
as
it
RESPONSE
disclosure of
NO 22
Plaintiff
objects
to the
foregoing
seeks
information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigation
Plaintiff
objects
to the extent
this
Request
seeks
documents
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by
the
Plaintiff
considering
most
of the
communications
relating
to
this
Request
were published by
the
Defendants
on
the
WNST
website
and/or made on
their
own
radio
shows
Without
waiving
these
objections
to the
extent
that
non-privileged
exist
and
are
in the
possession
of the
Plaintiff
Plaintiff
to Exhibit
attached
to Plaintiffs
Answers
to
lnterrogatories
REQUEST
relate to
NO 23
All
which
against
refer
reflect
or e.g
your
contention
that
WNST
threatened
violence
you
see
Complaint
T24d
15
234664-1
RESPONSE NO 23
disclosure of
Plaintiff
objects
to
the
foregoing
Request
as
it
seeks
information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigation
Plaintiff
objects
to
the
extent
this
Request
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden
than
by
the
Plaintiff
considering
most
of the
communications
relating
to this Request
were published by
the
Defendants
on
the
WNST
website
and/or made on
their
own
radio
shows
Without
waiving
these
objections
to the
extent
that
non-privileged
exist
and
are
in the
possession
of the
Plaintiff
Plaintiff
to Exhibit
attached
to Plaintiffs
Answers
to Interrogatories
REQUEST
relate to
NO 24
answer
All
which
any
of
refer the
reflect
or
your
in
contention your
any
to
Defendants
knew
that
that the
statements
No
of falsity as to
its
statement statement
falsity
was
false
entertained
doubts
of the
or published
statement
with
high degree
of awareness
probable
RESPONSE NO 24
disclosure of
Plaintiff
objects
to
the
foregoing
Request
as
it
seeks
information which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigation
Plaintiff
objects
to the
extent
this
Request
in
the custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and
with
burden
than
by
the
Plaintiff
Further
Plaintiff
objects
to
this
Request
to
the
extent
it
calls
for evidence
and documents
that
will be used
of
impeachment
16
Without
waiving
these
objections
to
234664-1
the
extent
that
non-privileged
and
non-protected
documents
exist
and
are
in
the
possession
of the
Plaintiff
REQUEST
relate to
NO 25
or
All
which
refer
reflect
or
newspaper
tapes videos
magazine
bulletins editor or
flyers
computer form
printouts
or printed
broadcast material
that
transcripts
to the to the
published
from January
or published
2003 by anyone
present
regarding
you
were broadcast
other
than Defendants
RESPONSE NO 25
Plaintiff
objects
to the foregoing
Request
as
it
is
overly
ambiguous
as
it
requires
Plaintiff
produce
voluminous
documents
that
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
discovery
of admissible evidence
Further
the
Request
seeks
disclosure
of
information
which
is
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of litigation
Plaintiff
objects
to
the
extent
this
Request
or control
of the
Defendants
or
which
may
be obtained
by
the
Defendants
less
expensively
and
with
less
burden than by
the
Plaintiff
Without waiving
subject
to these
objections
see
Exhibit
attached
to Plaintiffs
Answers
to Interrogatories
REQUEST
NO 26
All
which
refer
reflect
or
ill
Defendants
in
acted
with
common law
malice
your answer
to Interrogatory
No
as
it is
RESPONSE NO 26
broad
Plaintiff
objects
to the foregoing
Request
overly
as
it
requires
Plaintiff
to
produce
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
17
234664-Ti
Further
the
Request
seeks
disclosure
of information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of litigation
Plaintiff
objects
to
the
extent
this
Request
seeks
documents
custody
or control
of the
Defendants
or
by
the
Defendants
more conveniently
less
expensively
and
burden than by
statements
the
Plaintiff
Without waiving
these
objections
and
subject
thereto
the
and
written
materials
summarized
in
Exhibit
speak
for
themselves
and
to
the
extent
other
non-privileged
non-protected
documents
exists
REQUEST
relate to
NO 27
All
which
to
refer
reflect
or as
your
contention
that
identified
damage answer to
your
reputation
Interrogatory
No
as
it is
RESPONSE
broad
unduly
NO 27
Plaintiff
objects
to
the
foregoing Request
overly
burdensome
vague
is
and/or
ambiguous
Further
the
Request
seeks
disclosure
of
information
which
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or information already
in the custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and
with
burden than
by
the
Plaintiff
Without
waiving
these
objections
and
subject
thereto
to
the
extent
non-privilege
and
non
REQUEST
NO 28
All
which
refer
reflect
or
that
you have
damage
to your feelings
including
but
18 2346644
not limited
to distress
as
result of the
statements
identif led
in your answer
to Interrogatory
No.3
See Response
RESPONSE NO 28 REQUEST
reflect
to Request
No
which
refer
NO 29
the
All
documents
that
and
communications conduct
or
relate
to your
contention
any
Defendants
in society
was
extreme and
outrageous
and beyond
bounds
of decency
60
as
it is
RESPONSE NO 29
Plaintiff
objects
to the
foregoing Request
overly
The Request
as
worded
is
not
reasonably
calculated
to
to
the
discovery
of
admissible
evidence
Further
the
Request
seeks
disclosure
of
information which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in
anticipation
of
litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or
information
already in the
custody
or
control
of the
Defendants
or
by
the
Defendants
more conveniently
less
expensively
and with
burden
than
by
the
Plaintiff
Without waiving
these
objections
and
subject
thereto
the
statements
and
written materials
summarized
in Exhibit
speak
for themselves
and
to the
extent
other
non-privileged
REQUEST
NO 30
All
which
refer
reflect
or
that
has
suffered
and
will continue
to suffer
severe
RESPONSE
REQUEST
relate to health
NO 30
All
See Responses
to Requests
No
and 29
NO 31
or
which
refer
reflect
or
any doctor
physician mental
psychologist
psychiatrist
mental
counselor
health
practitioner in
you have
ever visited
concerning
your mental
and/or
emotional health
your
lifetime
19
234664-1
RESPONSE NO 31
Plaintiff
objects
as
it
is
overly
ambiguous
as
it
requires
Plaintiff
to
produce
that
are
to
the
allegations
of
the
Complaint.
The
Request
as
worded
the
is
not reasonably
calculated
to lead
to the
discovery of admissible
evidence
Further
Request
seeks
disclosure
of information
which
is
protected by the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in
anticipation
of litigation
Without
waiving
these
objections
and subject
thereto
Plaintiff
refers Defendant
to Responses
to Requests
No
and 29
REQUEST
relate to
NO 32
public
All
which
refer
reflect
or
communications
of the
including
sent to
and correspondence
in
from
members Maryland
you
your
employment
Baltimore
since
2009
RESPONSE
broad
NO 32
Plaintiff
objects
to the
foregoing Request
as
it
is
overly
harassing vague
and/or
ambiguous
as
it
requires
Plaintiff
to
produce
documents
that
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Request
seeks
disclosure
of information
which
is
protected
by the attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of litigation
Plaintiff
objects
to
the
extent
this
Request
or control
of the
Defendants
or
which
may
be obtained
by
the
Defendants
more conveniently
less
expensively
and
with
less
burden than by
the Plaintiff
20
234664-1
REQUEST
place
NO 33
Produce
to
for inspection
all
and copying
at
mutually
agreeable
access
Facebook.com
RESPONSE NO 33
unduly burdensome and
is
Plaintiff
objects
to this
Request
as
it
is
overly
broad
not
reasonably
calculated
to
lead
to
the
discovery
of
admissible evidence
Further
the Request
seeks
information which
is
not relevant
to the
allegations
in the
Complaint
REQUEST
place
NO 34
Produce
and copying
to
all
at
mutually
agreeable within
and uninhibited
Twitter.com
accounts
your control
RESPONSE NO 34
See Response
to Request
No
Brian
Goodman
Moylan PESSIN KATZ P.A
Alexandra
HODES
Towson
Road
Suite 400
Maryland 21204-2600
410 410
938-8800 825-2493
Fax
21
234664-I
JENNIFER ROYLE
Plaintiff
IN
THE
CIRCUIT
COURT
FOR NASTY
1570
SPORTS
LLC et
BALTIMORE
CASE
CITY
Defendants
NO 24-C-11001571
CERTIFY
that
on
this
2nd day
of
June 2011
copy
of the
foregoing
First
Request
For
Discovery
of
Documents on
Electronically
Stored
In.formation
and
Property
directed
to
Jennifer
Royle
behalf
of
WNST SPORTS
to
MEDIA
one of Defendants
was mailed
via
first-class
Charles
Tobin Esquire
Drew
Holland
Shenkman
Knight
Esquire
LLP Avenue
20006
2099 Pennsylvania
Suite
N.W
100
Washington
D.C
202
Attorney
Brian
Goodman
KATZ P.A
Suite 400
Towson Maryland
21204-2600
410 410
938-8800 825-2493
Fax
JENNIFER ROYLE
IN
THE
Plaintiff
CIRCUIT
COURT
FOR NASTY
1570
SPORTS LLC
et
BALTIMORE
CASE
CITY
Defendants
NO 24-C-11001571
ROYLES SUPPLEMENTAL RESPONSES TO WNST SPORTS MEDIA LLCS FIRST REQUEST FOR DISCOVERY OF DOCUMENTS ELECTRONICALLY STORED INFORMATION AND PROPERTY
PLAINTIFF JENNIFER
Jennifer
Royle
Plaintiff
by
her
attorneys
Brian
Goodman
to
and
Alexandra
Moylan
of
Hodes
Pessin
First
Request
For
Discovery
of
Documents
Electronically
to her
by
WNST
Sports
Media
LLC
Supplemental Responses
REQUEST
reflect
NO.1
Defendants
All
documents
and
communications
which
refer
or relate to the
RESPONSE NO.1
broad unduly burdensome voluminous
Plaintiff
objects
to the foregoing
Request
as
it
is
overly
harassing
as
it
requires
Plaintiff
to
produce
documents
are
unrelated
to
the
allegations
of
the
Complaint Moreover
period for which such
Plaintiff
objects
to
this
Request
as
it
does
not
specify
time
are
as
worded
is
not reasonably
discovery
of
evidence
that
is
not relevant
to the
Complaint Further
the
Request
seeks
disclosure
of
information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or information already
in the
custody
or
control
of
the
Defendants
or
which
may
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
less
burden than by
the
Plaintiff
See
Supplemental
Documents
attached
REQUEST NO.2
Defendant
All
between
you and
any
RESPONSE
NO
Plaintiff
objects
to
this
Request
as
overly
broad
unduly
as
it
fails
to define
are
sought Further
Plaintiff
objects
to this
Request
to
the
extent
it
seeks
documents
or
custody
or
control
of the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more conveniently
less
burden than
the
Plaintiff
these
objections
to the
extent
non-privileged
exist
they will be
produced
To
the
extent
the
information sought
in
Request
is
in the
Plaintiffs
immediate
possession
custody
or
control
it
has been
produced
in
the
Supplement
with
Documents
attached
Plaintiff
reserves
the
right
to
supplement
this
Response
additional
responsive
documents
254497.1
REQUEST NO.3
anyone concerning
the
All
documents
and
communications
between
you
and
subject
matter of
this
lawsuit
RESPONSE
NO
Plaintiff
objects
to
the
foregoing
Request
as
it
is
overly
harassing
as
it
requires
Plaintiff
to
produce
documents
are
unrelated
to
the
allegations
of
the
Plaintiff
objects
to
this
Request
as
it
does
not specify
time
period
for
are
as
worded
Further
is
not reasonably
to
the Request
seeks
disclosure
of information
which
is
client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigation
Plaintiff
objects
to
the
extent
this
Request
seeks documents
or
information
already in the
custody
or
control
of the
Defendants
or
by
the
Defendants
more conveniently
less
expensively
and
burden
than
by
the
Plaintiff
To
the
extent
non-privileges responsive
Request
are
in the
immediate
possession
custody
or control
of
the
Plaintiff
they
have
been
produced
herewith
Plaintiff
reserves
the
right
to
supplement
this
Response
with
additional
responsive
documents
REQUEST
relate to
NO.4
All
which
refer
reflect
or
your
contention
that
you have
been
defamed
as
alleged
in
Count
of your
Complaint
254497.1
RESPONSE NO.4
seeks disclosure
Plaintiff
objects
to
the
foregoing
Request
to
the
extent
it
of information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigati
on
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or information already
in the
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than
by
the
Plaintiff
or
by
this
Request
Without
waiving
these
objections
to
the
extent
other
non-privileged
non-
protected responsive
documents
exist
the
will be
produced
Plaintiff
refers Defendant
to Exhibit
attached
to Plaintiffs
Answers
to Interrogatories
To
the
extent
non-privileged
responsive
immediate
possession
custody
or
control
of
the
Plaintiff
they
have
Plaintiff
reserves
the
right to supplement
this
Response
matter
is
ongoing which
reflect
REQUEST
relate to
NO
All
refer
or
your
contention
that
you have
been
portrayed
in
false
light as
alleged
in
Count
III
of your
Complaint
See Response
RESPONSE NO.5
to Request
No.4
the
To
extent
non-privileged
responsive
immediate
possession
custody
or
control
of
the
Plaintiff
they
Plaintiff
reserves
the
right to supplement
this
Response
as discovery in the
instant
matter
is
ongoing
254497.1
REQUEST NO.6
relate to your
All
which
refer
reflect
or
Answer
to Interrogatory
No.4 No.4
To
RESPONSE NO.6
See Response
the
extent
non-privileged
responsive
immediate
possession
custody
or
control
of
the
Plaintiff
they
have
Plaintiff
reserves
the
right to supplement
this
Response
as discovery in the
instant
matter
is
ongoing which
reflect
REQUEST NO.8
relate to
All
refer
or
any
Twitter.com
account
within
your
control
from
2008
to
the
present
including
to
@Jen
Royle
and @JenRoyleMASN
Por
this
request
you
shall obtain
from Twitter
complete
all
tweets
sent
by you
from each
account
You may
obtain
this
information by sending
written
request tQ
by
fax
to
415-222-9958
signed
by
you
together
with
copy
of
valid
government-issued
identification
card
RESPONSE
NO
Plaintiff
objects
to
the
foregoing
Request
as
it
is
overly
harassing
as
it
requires
Plaintiff
to
produce
documents
that
are
to
the
allegations
of
the
Complaint Moreover
as
Plaintiff
uses
this
medium
daily
pursuant
to
her professional
duties
the
Request
fails
to define
in
worded
is
not
reasonably
calculated
to lead to the
Plaintiff
objects
to
the
extent
this
Request
seeks
documents
or
information
already
in
the
custody
or
control
of
the
Defendants
or
which
may
be
obtained
by
the
Defendants
more
254497.1
conveniently
less
expensively
and with
less
burden than by
the
Plaintiff
Twitter will
then send
you
confirmation
to the
for
you on
file
which
will
authorize Twitter
to release
to
you
the
requested
information
Plaintiff
has
complied
with
the
Request
and
will
supplement
this
Response
as
the
documents
become
available
REQUEST NO.9
former
professional athlete
All
documents
and
communications
with
any
current
or
from 2000
to the
present
For the
purposes
of this
question
professional
athlete includes
but
is
not limited
to any
current
or
former
player
in
Major
League
Baseball
the
National
Football
League
the
National
Basketball
Association
the
National
Hockey
League
Major
League
Soccer
the
Arena
Football
League
such
the
PGA Tour
or
the
ATP World
minor
Tour
NASCAR
league
any
minor league
affiliate
of
leagues
any
other
professional
i.e
AAA
baseball
and
the
American Hockey
League
RESPONSE
NO
Plaintiff
objects
to
the
foregoing
Request
as
it
is
overly
harassing vague
and/or ambiguous
unrelated
as
it
requires
Plaintiff
to
produce
documents
that
are
tO
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Plaintiff
objects
to the
extent
this
Request
seeks disclosure
of
information which
is
protected
by
the
First
Amendment
Code
of
the
United
State
Shield
Law
See
Md
Ann
Courts
Judicial
Proc
9-112
Tofani
State 297
Md
1983
Plaintiff
objects
2544971
to
the
extent
this
Request
seeks
documents
or
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by To
the Plaintiff
the
extent
non-privileged
responsive
and
are in the
immediate
possession
custody
or control
of the
Plaintiff
REQUEST
former player
NO 10
All
documents
and
communications
with
any
current
or
member
of the
coaching
staff
or
management
in Major
League
Baseball
from 2000
to the
present
RESPONSE
NO 10
Plaintiff
objects
to the foregoing
Request
as
it
is
overly
harassing vague
and/or ambiguous
unrelated
as
it
requires
Plaintiff
to
produce
documents
that
are
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Plaintiff
objects
to the
extent
this
Request
seeks disclosure
of
information which
is
protected
by
the
First
Amendment
Code
of
the
United
State
Shield
Law
Md
Ann
Courts
Judicial
Proc
extent
9-112 Tofani
State 297
Md
1983
Plaintiff
objects
to
the
this
Request
seeks
documents
or
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
the
Defendants
more
conveniently
less
expensively
and with
burden than by
Plaintiff
254497.1
SUPPLEMENTAL RESPONSE
documents
exist
NO 10
To
the
extent
non-privileged
responsive
and
are
fri
the
immediate
possession
custody
or control
of the Plaintiff
REQUEST NO.11
former player
All
documents
and
communications
with
any
current
or
member
of the
coaching
staff or
management
in the
New
York Yankees
baseball
organization
from 2000
to the
present
RESPONSE
broad
NO 11
Plaintiff
objects
to the
foregoing Request
as
it
is
overly
harassing
as
it
requires
Plaintiff
to
produce
documents
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Plaintiff
objects
to the
extent
this
Request
seeks disclosure
of
irtformation
which
is
protected
by
the
First
Amendment
of
the
United
State
Shield
Law
See
Md
Code
Ann
Courts
Judicial
Proc
extent
9-112
Tofani
Staj
297
Md
1983
Plaintiff
objects
to the
this
Request
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by To
the
Plaintiff
SUPPLEMENTAL RESPONSE
responsive
NO 11
immediate
the
extent
non-privileged
documents
exist
and
are in the
possession
custody
or control
of
the
Plaintiff
254497.1
REQUEST
former player
NO 12
All
documents
and
communications
with
any
current
or
member
of the
coaching
staff
or
management
in the
New
York Mets
baseball
organization
from 2000
to the
present
RESPONSE
NO 12
Plaintiff
objects
to the
foregoing Request
as
it is
overly
harassing
as
it
requires
Plaintiff
to
produce
voluminous documents
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Plaintiff
objects
to the
extent
this
Request
seeks
disclosure
of
information which
is
protected
by
the
First
Amendment
of
the
United
State
Constitution
and
the
Maryland
Shield
Law
Md
Code
Ann
Courts
Judicial
Proc
extent
9-112 Tofani
State 297
Md
1983
Plaintiff
objects
to
the
this
Request
seeks documents
or
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by To
the Plaintiff
SUPPLEMENTAL RESPONSE
responsive
NO 12
immediate
the
extent
non-privileged
documents
exist
and
are in the
possession
custody
or control
of
the
Plaintiff
REQUEST
former player
NO 13
All
documents
and
communications
with
any
current
or
member
of the
coaching
staff
or
management
in the
Baltimore Orioles
baseball
organization
from 2000
to the
present
RESPONSE
NO 13
harassing
Plaintiff
objects
to this
Request
as
it
is
overly
broad
unduly burdensome
vague
and/or ambiguous
as
it
requires
Plaintiff
to
254497.1
that
are unrelated
to the
allegations
of the
Complaint
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
discovery
of
admissible
evidence
Further
the
Plaintiff
objects
to
the
extent
this
Request
seeks
disclosure
of information
which
is
protected
by
the
First
Amendment
of the
United
State
Constitution
and
the
Maryland
Shield
Law See Md
Code
Ann Courts
Plaintiff
Judicial
Proc
extent
9-112
Tofani
StateS 297
Md
1983
objects
to the
this
Request
seeks
documents
custody
or control
of
the Defendants
or
by
the
Defendants
more conveniently
less
expensively
and with
less
the
Plaintiff
SUPPLEMENTAL RESPONSE
responsive
NO 13
immediate
To
the
extent
non-privileged
documents
exist
and
are in the
possession
custody
or control
of
the
Plaintiff
REQUEST
former player
NO 14
All
documents
and
communications
with
any
current
or
member
of the
coaching
staff
or
management
in the
Baltimore Ravens
football
organization
from 2010
to the present
RESPONSE
broad
NO 14
Plaintiff
objects
to the
foregoing Request
as
it
is
overly
harassing
as
it
requires
Plaintiff
to
produce
documents
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Plaintiff
objects
to the
extent
this
Request
seeks
disclosure
of
information which
is
protected
by
the
First
Amendment
Code
of
the
United
State
Maryland
Shield
Law
See
Md
Ann
Courts
10
254497.1
Judicial
Proc
extent
9-112
Tofani
State1
297
Md
1983
Plaintiff
objects
to
the
this
Request
seeks
documents
or
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
arid with
burden than by To
the
Plaintiff
SUPPLEMENTAL RESPONSE
documents
are in the
NO 14
the
extent
non-privileged
responsive
immediate
possession
custody
or
control
of the
Plaintiff
they
have produced
here in The
letter
Plaintiffs
Original
Responses
to
Request
for Production
of
Documents
REQUEST
NO 21
All
which
refer
reflect
or
Wl\IST
made
statements
that
state
implicate or otherwise
insinuate
that
you
are
not
qualified
or
competent
for
your
position
as
journalist
Complaint
X20
Plaintiff
RESPONSE
disclosure of
NO 21
objects
to
the
foregoing
Request
as
it
seeks
information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by
the
Plaintiff
considering
most
of the
communications
relating
to this Request
were published by
the
Defendants
on
the
WNST
website
and/or made on
their
own
radio
shows
Without
waiving
these
objections
to the
extent
that
non-privileged
exist
and
are
11
254497.1
in the
possession
of the
Plaintiff
Plaintiff
to Exhibit
attached
to Plaintiffs
Answers
to
Interrogatories
SUPPEMENTAL RESPONSE
documents
are in the
NO 21
To
the
extent
non-privileged
responsive
immediate
possession
custody
or
control
of
the
Plaintiff
they
Plaintiff
reserves
the
right to supplement
this
Response
as discovery in the
instant
matter
is
ongoing which
reflect
REQUEST
relate to
NO 22
All
refer
or
your
contention
that
WNST
made
statements
implications
or
otherwise
insinuated
that
you
are
involved
in
personal
sexual
and/or
inappropriate
relationships
athletes Complaint
20
Request
as
it
RESPONSE
disclosure of
NO 22
Plaintiff
objects
to
the
foregoing
seeks
information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of
litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by
the
Plaintiff
considering
most
of the
communications
relating
to this
Request
were published by
the
Defendants
on
the
WNST
website
and/or made on
their
own
radio
shows
Without waiving
these
objections
to the
extent
that
non-privileged
exist
and
are
in the
possession
of the
Plaintiff
Plaintiff
to Exhibit
attached
to Plaintiffs
Answers
to Interrogatories
12
254497.1
SUPPLEMENTAL RESPONSE
documents
are in the
NO 22
To
the
extent
non-privileged
responsive
immediate possession
custody
or
control
of
the
Plaintiff
they
have
Plaintiff
reserves
the
right to
supplement
this
Response
as discovery in the
instant
matter
is
ongoing which
REQUEST
relate to
NO 23
All
refer
reflect
or
your
contention
that
WNST
threatened
violence
against
you
see
e.g
Complaint
T24d
RESPONSE
disclosure of
NO 23
which
Plaintiff
objects
to
the
foregoing
Request
as
it
seeks
information
is
protected
by
the
attorner-client
privilege
the
attorney
work-product
doctrine
and/or
created
in
anticipation
of litigation
Plaintiff
objects
to the
extent
this
Request
seeks
documents
custody
or
control
of
the
Defendants
or
which
may
less
be
obtained
by
the
Defendants
more
conveniently
less
expensively
and with
burden than by
the
Plaintiff
considering
most
of the
communications
relating
to this
Request
were published by
the
Defendants
on
the
WNST
website
and/or made on
their
own
radio
shows
Without waiving
these
objections
to the
extent
that
non-privileged
and non-protected
documents
exist
and
are
in the
possession
of the
Plaintiff
Plaintiff
to Exhibit
attached
to Plaintiffs
Answers
to Interrogatories
SUPPLEMENTAL RESPONSE
documents
are in the
NO 23
To
the
extent
non-privileged
responsive
immediate
possession
custody
or
control
of
the
Plaintiff
they
have
See
Supplemental
Documents
attached
hereto
PRDR
13
254497.1
000225-000618
Plaintiff
reserves
the
right to supplement
this
Response
as discovery
in
the
instant
matter
is
ongoing documents
arid communications
REQUEST
relate to
NO 26
All
which
refer
reflect
or
acted with
common
law malice
ill
in your
answer
to Interrogatory
No.3
RESPONSE
NO 26
Plaintiff
objects
to
the
foregoing Request
as
it
is
overly
harassing
as
it
requires
Plaintiff
to
produce
documents
are
unrelated
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Request
seeks
disclosure
of information
which
is
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of litigation
Plaintiff
objects
to the
extent
this
Request
or control
of the
Defendants
or
by
the
Defendants
more conveniently
less
expensively
and
burden than
by
the
Plaintiff
Without
waiving
these
objections
and
subject
thereto
the
statements
and
written
materials
summarized
in
Exhibit
speak
for
themselves
and
to
the
extent
other
non-privileged
non-protected
documents
exists
SUPPLEMENTAL RESPONSE
responsive
NO 26
To
the
extent
non-privileged
documents
are
in
the
immediate
possession
custody
or
control
of
the
Plaintiff
herewith
Plaintiff
reserves
the
right to supplement
this
Response
as discovery
in the
instant
matter
is
ongoing
14
254497.1
REQUEST
relate to
NO 32
All
which
refer
reflect
or
communications
including
to letters
and correspondence
from
members
of
the
public
sent
to
you
that
relate
to
your
employment
in
Baltimore
Maryland
since
2009
RESPONSE
NO 32
Plaintiff
objects
to the foregoing
Request
as
it
is
overly
harassing
as
it
requbes
Plaintiff
to
produce
documents
that
are
to
the
allegations
of
the
Complaint
The
Request
as
worded
is
not
reasonably
calculated
to
lead
to
the
Further
the
Request
seeks disclosure
of information
which
is
protected
by
the
attorney-client
privilege
the
attorney
work-product
doctrine
and/or
created
in anticipation
of litigation
Plaintiff
objects
to the
extent
this
Request
or control
of the
Defendants
or
which
may
be obtained
by
the
Defendants
more conveniently
less
expensively
and
with
less
burden than by
the
Plaintiff
SUPPLEMENTAL RESPONSE
documents
axe in the
NO 32
To
the
extent
non-privileged
responsive
immediate
possession
custody
or
control
of
the
Plaintiff
they
Plaintiff
reserves
the
right to
supplement
this
Response
as discovery in the
instant
matter
is
REQUEST
place
NO 33
Produce
for inspection
at
mutually
agreeable
access
to all
Facebook.com
RESPONSE
NO 33
and
is
Plaintiff
objects
to
this
Request
as
it
is
overly
broad
unduly burdensome
not
reasonably
calculated
to
lead
to
the
discovery
of
15
254497.1
admissible evidence
Further
the
Request
is
not relevant
to the
allegations
in the
Complaint
Plaintiff
reserves
the
right to
supplement
as responsive
documents become
available
SUPPLEMENTAL RESPONSE
documents
are in the
NO 33
To
the
extent
non-privileged
responsive
immediate
possession
custody
or
control
of the
Plaintiff
they
REQUEST
place
NO 34
Produce
for inspection
and copying
at
mutually
agreeable
and uninhibited
access
to
all
Twitter.com
accounts
within
your control
RESPONSE
NO 34
See Response
to Request
No.8
extent
SUPPLEMENTAL RESPONSE
documents
are in the
NO 34
To
the
non-privileged
responsive
immediate
possession
custody
or
control
of the
Plaintiff
they
have
been produced
herewith
Plaintiff
has
complied
with
Defendants
Request
and
will
supplement
this
Response
as the
responsive
documents become
available
ftQLYJPPL
Brian
Goodman
Moylan PESSIN KATZ P.A
Alexandra
HODES
Road
Suite 400
Towson Maryland
21204-2600
410 410
938-8800 825-2493
Fax
16
254497.1
JENNIFER ROYLE
IN
THE
Plaintiff
CIRCUIT
COURT
FOR NASTY
1570
SPORTS LLC
et
BALTIMORE
CASE
CITY
Defendants
NO 24-C-11001571
on
this
day
of July
2011
copy
of the
foregoing
First
Request
For Discovery
of
Documents
Electronically
Stored
Information
and
Property
directed
to
Jennifer
Royle
on
behalf
of
WNST
SPORTS MEDIA
to
one of Defendants
was mailed
via
first-class
Charles
Drew
Holland
LLP Avenue
20006
2099 Pennsylvania
Suite
NW
100
Washington
D.C
202
955-3000
Crcein-cin/
Brian
Goodman
PESSIN
Kirnya Belibahani
HODES
KATZ
Road
PA
Suite
400
Towson Maryland
21204-2600
410 410
938-8800 825-2493
Fax
EXHIBIT
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104434
AM
JENNIFER ROYLE
Plaintiff
Case
No
24C11001571
NASTY
1570
SPORTS LLC
Defendants
et
al
PROPOSED ORDER
Upon
WNST
and
for
Sports
Media
LLCs
Motion
to
Compel
Plaintiff
to
Respond
to
Written
Discovery
an
Award
of Costs
and
Incorporated
Memorandum 2011
of
Law
and
any
opposition
thereto
it
____ day
is
of
ORDERED
her supplemental
that
Plaintiffs Complaint
limited
to
the
18
allegedly
false
statements
in
response
to
Interrogatory
No
and
it
is
ORDERED
regarding her
that
within
10
days
the Plaintiff
shall
answer
Interrogatory
Nos
21
and 22
involvement
in
personal
sexual
and/or
inappropriate
relationships
with
professional
athletes and
it is
ORDERED
Document
Request
that within
10
days
the
Plaintiff
shall
produce
all
documents
responsive
to
Nos
10
11 12
13 and 14
or
alternatively
if
she
asserts
the
reporters
privilege
that
she produce
privilege
Guideline
5c
and
it
is
ORDERED
her
that
within
10
days
the
Plaintiff
shall
produce
for
inspection
and copying
personal Facebook
and
account
or alternatively
downloaded
personal
account
it
is
ORDERED
within her responses
that
within
10 days
the
Plaintiff
shall
identify
the
unnamed
individuals
to
Interrogatory
Nos
10
and 12 and
it
is
ORDERED
has not provided
to
that
Plaintiff
is
prohibited
from introducing
into
evidence
the Defendants
within
the
10
days provided
in
the Courts
Order and
it
is
ORDERED
costs in responding
that
the
Plaintiff
shall
pay
the
Defendants
reasonable
attorneys
fees
and
to
her discovery
deficiencies
Copies to
Charles
Tobin
Drew
HOLLAND
2099 Pennsylvania
Ave N.W
Suite 100
Brian
Goodman
PESS1N
Esq
Alexandra
Moylan
Esq
HODES
901
KATZ P.A
Road
Suite 400
Towson
21204-2600