EFTA02520779.pdf

From: jeffrey E. <jeevacation@gmail.com> Sent: Tuesday, February 27, 2018 10:41 PM To: Lawrence Krauss Subject: Re: Private and Confidential, in response to our meeting. you dont understand. AT ALL . !!! =C240 they dont need your permission to copy you. they now nee= your lawyers approval . to copy you her letter is makes clea= that your tellign them how to do their job is bullshitk and they can inve=tigate claims brought by anyone at anytime. .. 4>=A0 and complaints made to them are protected from defamation c=aims.. They must do a new thorough investigation. =. and dig deeper. . and take every allegatio= from buzz fed an run it down. . and anyone else now who decid=s to join the bandwagon. . sad!!! as most of this =ut clearly not all was self inflicted. ==< On Tue, Feb 27, 2018 at 3:55 PM, Lawrence K=aus mailto Dear Cynthia et al: wrote: Adam forwarded me your note whil= on a plane. I wanted to let you know that you can feel free to cc mr, on all communication or email me and cc Adam, as you wish.. Adam i= advising me on matters related to Buzzfeed, and so it is appropriate to c=mmunicate to both of us in this regard. I expect he will be writing =o you. In any case, I wanted to assure you that I will continue to c=operate with all your offices, as I have done thus far. I value the colleg=al relationship I have with all of my colleagues at ASU. I do hope =aimah's group has taken all of our concerns about Buzzfeed under a=visement, but I also understand the requirements on the University as well= Thanks for your attention to this.<=div> Best Lawrence Krauss Lawrence M. Krauss Director, =he Origins Project at ASU Co-Director, Cosmology Initiativeapan style="font-size:10.5pt"> Foundation Professor Sc=ool of Earth & Space Exploration and Physics Department Arizona Sta=e ni r i P. . ox 871404 Tem AZ 85287.1404 Research =ffic tel: j Assistant (Jessica): <tel, i trig=ns Office (Cynthia) tel: <mailto origins.asu.edu I twitter.comilkrausslgspan> <https://urldefense.proofpoint.com/v2/url?wht=p- 3A_twitter.comikraussl&d=DQMFAg&c=AGbYxf.lbXK67KfXyGgyv2Eji=41FqQuZFk4A- EFTA_R1_01657718 EFTA02520779 llxfAU&r=DB9LvLOIQiaqWcFOihHC0LZCntZCR8Xtq5BHKNVIISTo&=m=ciP97mEbO4349G8_Nf9ISUp33Th7MWHYf6uw7y UBPZc&s=mspp0SBZaPjp5BOPRb=2xXlzHCi4LgiTZ8KNgjNBBKg&e=> I krauss.faculty.asu.edu -<=span>Ori=ins Project 10 Year Celebration- Be a part of something 10 years in=the making! April 5-9th 2018 4)=93 Visit for more info <https://www.originsl0year.com/> =br> Begin forwarded message: From: Adam Waldman <=>Subject: FW: Private and Confidential, in response=to our meeting. <=>Date: February 27, 2018 at 12:28:21 PM PST =/div> To: Lawre=ce Krauss mailto Fyi Just got back on wifi and reading now From:=span class="m -8865247676199483936Apple-converted-space"> </=pan>Cynthia Jewett <mailto =r>Date: Tuesday, February 27, 2018 at=3:21 PM To: Adam Waldman Cc: Naimah Saadic Erin Ellison «, href="mailto: style="color:purple;text-decorat=on:underline" target="_blank" Subject: FW: Private and Confidential, in resp=nse to our meeting. Mr. Waldman, <=iv style="margin:0in 0in 0.0001pt;font-size:12pt;font-family:"Times=New Roman",serif">Your client, Lawrence Krauss, copied me on =is February 23rd email communication to the Office of Equity and l=clusion. I am writing to convey the University's position on=its responsibility to conduct administrative investigations into allegatio=s of conduct that would violate institutional policy, if true. Becau=e Dr. Krauss has retained legal counsel, I am writing directly to you.4k=A0 You may forward my communication on to your client. Without havin= first secured your permission, I did not think it was proper for me to co=ying him on this reply. =ur policy on the Prohibition Against Discrimination, Harassment, and Retal=ation (ACD 401=C24>https://ww=.asu.edu/aad/manuals/acd/acd401.html <https://www.asu.edu/aad/manuals/acd/acd401.html> ) and its accompanying proced=res (P20 — link to the procedures is embedded in the policy docume=t) directs the Office of Equity and Inclusion to conduct prompt and equita=le investigations. Among the points stated are that the Office accep=s anonymous complaints as well as direct complaints. University empl=yees are required to cooperate with any investigation or allegations of vi=lations of this policy. Providing false or misleading information or=failing to cooperate may result in disciplinary action. Individuals =aking a complaint or participating as a witness in an investigation cannot=be retaliated against. Any employee who engages in retaliation will =e disciplined. The Office of Equity and Inclusion does not make any =indings until such time as it determines that it has completed its fact ga=hering. 2 EFTA_R1_01657719 EFTA02520780 =C2* Our courts recog=ize that participants in an administrative investigation have a privilege =gainst a defamation charge. In Paros v. Hoemako Hospital, 140 Ariz. 335= 681 P.2d 918 (Ct. App. Div. 2 1984), the court recognized that the employ=r's response to a notice of charge of discrimination filed with th= Equal Employment Opportunity Commission was absolutely privileged. =n =i>Miller v. Servicemaster by Rees, 174 Ariz. at 520, 851 P.2d 240, 243 (C=. App. Div. 1 1993), the court recognized the existence of a conditional p=ivilege for employees to report perceived acts of sexual harassment as pub=ic policy dictated that employees must be protected from workplace sexual =arassment. Cited approvingly, Carey v. Maricopa County, 2009 WL 750225 (D= Ariz. 2009). Both Paros and Miller were cases concerning discrimi=ation and harassment under Title VII. In addition to its obligations=under Title VII, the University must also operate its educational programs=and activities to be free from gender discrimination under Title IX. <=span> The Office of Equity and Inclu=ion will proceed with its investigation as outlined in ACD 401 and P20. Th= Office will not provide your client with its investigative file. We=look forward to Dr. Krauss's continuing cooperation. Regards= <=> Cynthia L. Jewett Senior Associate General Counsel<=u> Arizona State Univer=ity From:.=A0Lawrence Krauss [mailto mailto Sent: Friday, February 23, 2018 4:19 PM To:<=pan class="m_-8865247676199483936Apple-converted-space"> Nai=ah Saadiq mailto C nthia Jewett <mailto • Cc. <mailto <mailto: Subject: Private and Confid=ntial, in response to our meeting. <=iv style="margin:0in 0in 0.0001pt;font-size:12pt;font-family:"Times=New Roman",serif"> Dear Naimah et al: <a Attached=you will find a letter from my attorney, along with a letter he sent to Bu=zfeed earlier in this week regarding the defamatory and false story they w=re planning on printing. The story was then published yesterday morn=ng. </=pan> I wanted to add to his letter, to reiterate our =oncern about how your office was planning to follow up on the false and de=amatory third-party allegations from Buzzfeed. Because this wa= initiated by an online entertainment news outlet with a clear agenda and =stablished record of propagating false allegations about me, rather than b= any of the individuals they refer to as sources, this should not be =onsidered a credible allegation worthy of investigation. I believe that ou= initial discussion was sufficient to settle this matter. Whethrr or not you agree with this, there are two things=l think are important to establish. <a Firstly,=b> that the University should not propagate what can be false all=gations from such a source by presenting them directly to current and/or f=rmer employees or to others. To do so would be to further their libe=ous agenda, as Mr Waldman has emphasized. In this regard, I would ap=reciate seeing copies of the correspondence you might send to current or f=rmer employees about this in the process of carrying out and concluding yo=r investigation. Secondly, I reiterate once again that t=e Origins Project environment is supportive, candid, frank, honest, and pr=ductive, with all employees being treated with respect, as well as being s=pported and mentored. I am proud of our team, and I believe they feel the =ame way. Thanks f=r your attention to these letters. Lawrence Krauss =C2. Lawrence Krauss 3 EFTA_R1_01657720 EFTA02520781 Dear Ms. Saadiq: My name is Adam Waldman, and I am Prof=ssor Lawrence Krauss' litigation counsel. Earlier this week,=I sent the attached letter to Buzzfeed via one of their reporters named Pe=er Aldhous. I am also in =eceipt of Mr. Aldhous' letter to ASU, which is a variation on defa=ation — both libel and slander — that Mr. Aldhous and his =olleagues have been manufacturing for at least 6 months (notably without a=y reporting) in a campaign with a purpose known only to them. Buzzfe=d's first method is to call or write third parties, posit a list o= fake, anonymous, recklessly false and malicious "allegations,Q=8040 and ask if the third party has anything to add. Buzzfeed.=99s second method is to seek tortious interference with Professor Krauss=E24* professional contracts, by writing third parties with whom Profes=or Krauss is in privity, present a similarly inflammatory series of anonym=us, recklessly false and malicious accusations, and then question: how can=the email's recipient allow such a person to serve on their board,=or speak at their conference? The letter from Buzzfeed to the Univer=ity falls into both categories. There will be appropriate legal consequenc=s for Buzzfeed's actions. It is my understanding that your office believes it is compelled by t=e above to investigate false, defamatory, anonymous accusations posited by=the online tabloid Buzzfeed by contacting third parties and potentially re=roadcasting the tabloid Buzzfeed's accusations. To be clear,=these accusations were not made to the University by actual human beings w=o are alleging they were victims. There is no evidence they were pre=ented to Buzzfeed by actual human beings. Moreover, no present or former e=ployees of ASU have made any such allegations to your office, or to any of=ice at ASU, to our knowledge. They are simply alleged by a tabloid, and on= that had yet published a "story" on the topic when they forw=rded these to you. You may propose to rebroadcast this tabloid's=libel to other third parties who have also made no accusation against Prof=ssor Krauss. I suggest that you consult with the University'= counsel before taking so rash a step as re-broadcasting hearsay defamatio= that came to you via an online tabloid under these circumstances.<=> Professor Krauss and I both recognize the =bsolute need to investigate real allegations. Some of the women who =ave bravely come forward with personal harassment allegations against Harv=y Weinstein are my clients and friends. Some of these victims have b=en advised by me. Those actual allegations are entirely distinct fro= a tabloid attempting to manufacture allegations to create harm. Sincerely, Adam Waldman =C24, <=pan style="font-size:10pt;font-family:Calibri,sans-serir>DISCLAIMER Confidentiality Notice: This e=ail, including any attachments, is being sent by or on behalf of the Endea=or Group or Endeavor Law Firm; it is confidential and may contain informat=on protected by the attorney-client and/or the attorney work-product privi=eges. If you are not the intended recipient, you are hereby notified that =ny review, disclosure, copying, or distribution of this information is una=thorized and prohibited. If you have received this communication in error =please advise the sender immediately by reply email and delete this messag= and any attachments without retaining a copy. <=iv style="margin:Oin Oin 0.0001pt;font-size:12pt;font-family:"Times=New Roman",serif"> IRS Circular 230=Disclosure: Any statements regarding Federal tax law contained in this =-mail are not intended or written to be used, and cannot be used, for the =urposes of avoiding penalties that may be imposed under federal tax law or=to market any entity, investment plan or arrangement.=/div> B=gin forwarded message: <=> =/div> From: Adam Waldma <mailto: 4 EFTA_R1_01657721 EFTA02520782 Date: Tuesday, Febr=ary 20, 2018 at 5:42 PM To: Peter Aldous <peter.aldhous@buzzfeed.com> Subject:=C2*Cease and Desist/Professor Lawrence Krauss</=iv> Dear Mr. Aldous:<=div> <=iv style="margin:0in 0in 0.0001pt;font-size:12ptfont-family:"Times=New Roman",serir>l am writing as litigation counsel to Professor Lawrence Kraus=. It has come to my attention that you and Buzzfeed have engaged in =n outrageous and protracted defamation campaign against Professor Krauss, =ncluding both libel and slander. Buzzfeed's campaign has bee= malicious, undertaken with absolute reckless disregard for the truth, and=despite repeated disprovals of the falsehoods you continue to harmfully di=seminate. Your defamatory efforts have also been undertaken, for rea=ons known only to you and your colleagues, with the intention of tortiousl= interfering with the contracts of Professor Krauss, and Buzzfeed has unfo=tunately succeeded in this malignant purpose. We have both testimony=and documents from a litany of well respected third parties that provide o=erwhelming evidence of your and Buzzfeed's malfeasant attacks on P=ofessor Krauss. We are still tallying the damage. </=iv> You and Buzzfeed will immediately cease and de=ist from further defamatory statements regarding Professor Krauss, and you=and Buzzfeed will immediately cease and desist from any further efforts to=tortiously interfere with Professor Krauss' contracts. If yo= and Buzzfeed are unwise enough to ignore this notice to cease and desist =rom the actions described above, the appropriate legal response will be sw=ft. Notwithstanding the foregoing, all legal rights are reserved. =C2* =span style="font-size:10.5pt;font-family:Calibri,sans-serif">*=A0 If you have more harassing =mails or any prospective communication you wish to transmit to Professor K=auss, you are instructed to send them to me as he is now represented by co=nsel. If your or Buzzfeed's counsel, whomever they may be, wish =o send me a letter in response to the above, be aware that I may, dependin= on its contents and because I would be obligated to forward it to my clie=t, consider such letter to also constitute a trigger of the above and reac= accordingly. Professor Krauss has suffered enough abuse at your han=s without commensurate consequences. Sincerely, Adam Waldman </=iv> DISCLAIMER Conf=dentiality Notice: This email, including any attachments, is being sent=by or on behalf of the Endeavor Group or Endeavor Law Firm; it is confiden=ial and may contain information protected by the attorney- client and/or th= attorney work-product privileges. If you are not the intended recipient, =ou are hereby notified that any review, disclosure, copying, or distributi=n of this information is unauthorized and prohibited. If you have received=this communication in error, please advise the sender immediately by reply=email and delete this message and any attachments without retaining a copy= </=iv> IRS Circular 230 Disclosure: Any statements reg=rding Federal tax law contained in this e-mail are not intended or written=to be used, and cannot be used, for the purposes of avoiding penalties tha= may be imposed under federal tax law or to market any entity, investment =Ian or arrangement. </=> Lawrence M. Krauss Director, The Origins Project at ASU =o-Director, Cosmology Initiative Foundation Professor =span style="font-size:9ptfont-family:Calibri,sans-serir>School of Eart= & Space Exploration and Physics Department Arizona State Universit=, P.O. Box 871404, Tempe, AZ 85287-1404 5 EFTA_R1_01657722 EFTA02520783 target="_blank" Research Offic Origins Office =a href tel style="color:purple;text-decoration:und=rline" •u <https://urldefense.proofpoint.com/v2/urI?u=http- 3A_origi=s.asu.edu_&d=DQMFAg&c=AGbYxfJbXK67KfXyGqyv2Ejiz41FqQuZFk4A- 1Ix=AU&r=DB9LvLOIQiaqWcFOihHC0LZCntZCR8Xtq5BHKNVR5To&m=ciP97mEbO43=9G8_Nf9I5Up33Th7MWHYf6uw7yU BPZc&s=Gc-m4FUPqBmB-H8qg0HdYhSQN_hZ8rHMdp=1HH3C6B0&e=> I twitter.comfikraussl <https://urldefense.proofpoin=.com/v2/url?u=http- 3A twitter.com_lkraussl&d=DQMFAg&c=AGbYx=JbXK67KfXyGqyv2Ejiz41FqQuZFk4A- 1IxfAU&r=DB9LvLOIQiaqWcFOihHC0LZCntZC=8Xtq5BHKNVR5To&m=ciP97mEbO4349G8_Nf9l5Up33Th7MWHYf6uw7yU BPZc&s=3Dmspp0SBZaPjp5BOPRbD2xXlzHCi4LgzTZ8KNgjNBBKg&e=> I krauss.facu=ty.asu.edu <https://urldefense.proofpoint.com/v2/url?u=http- 3A_=rauss.faculty.asu.edu_&d=DQMFAg&c=AGbYxfJbXK67KfXyGqyv2Ejiz41F=QuZFk4A- 1IxfAU&r=DB9LvLOIQiaqWcFOihHC0LZCntZCR8Xtq5BHKNVR5To&m=3DciP97mEbO4349G8_Nf9l5Up33Th7MWHYf6uw7 yUBPZc&s=f7W9C_XvplQaElpZ3o8v=h0dM_e0hTXbMIVPaUviEt8&e=> Visit for more inf=</=> =/div> <=iv class="gmail_signature" data-smartmail="gmail_signature"> please note The=information contained in this communication is confidential, may be att=rney-client privileged, may constitute inside information, and is inten=ed only for the use of the addressee. 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