EFTA02520859.pdf

From: Lawrence Krauss Sent: Wednesday, February 28, 2018 2:26 AM To: jeffrey E. Subject: Re: Private and Confidential, in response to our meeting. Yup S=nt from my iPad On Feb 27, 2018, at 5:48 PM, jeffrey E. «= href="mailto:jeevacation@gmail.com">jeevacation@gmail.com> wrote:=br> used to view On Tue, Fe= 27, 2018 at 8:38 PM, Lawrence Krauss So far probably s=ightly positive. Plus they view the publicity benefit as very important.&nb=p; Lawrence M. Krauss Foundation Professor <1=> School of E=rth & Space Exploration and Physics Department apan style="background-color:rgba(255,255,255,0)">Arizona State University= P.O- Box 871404, Tempe, AZ 85287-14=4 earch Offic <tel . Assistant (Jessica): origins.asu.edu <tel target=> I twitter.comilkraussl <http://twitter.com/Ikraussl> I krauss.faculty.asu.ed= <1=> jeevacation@gmail.com> wrote: heres what this says. i lawrence kr=uss will tell you how i thinkyou should conduct your investigation , i= at all. and I would like to participate in it. rep=onse. go fuck yourself. we will not share the file ,=nbsp; all complaints are proteced from defamation and you must continue to c=operate. I wanted to add to his letter, to reiterate our concern about how your office was planning to follow up on the false and defamatory third-party allegations from Buzzfeed. Because this was initiated by an onl=ne entertainment news outlet with a clear agenda and established record of propagating false allegations about me, rather than by any of the individuals they refer to as sources, this should not b= considered a credible allegation worthy of EFTA_R1_01657837 EFTA02520859 investigation. I belie=e that our initial discussion was sufficient to settle this matter. Whether o= not you agree with this, there are two thin=s I think are important to establish. =/div> First=y, that the University should not propagate what can be false allegations from such a source by presenting them directly to current and/or former employees or to others. To do so would be to further their libelous =agenda, as Mr Waldman has emphasized. In this regard,=I would appreciate seeing copies of the correspondence you might send to curr=nt or former employees about this in the process of carrying out and concluding your investigation. https://www.asu.edu/aad/manuals/acd/acd401.html4=pan>) and its accompanying procedures (P20 — link to the procedures is =embedded in the policy document) directs the Office of Equity and Inclusion to conduct prompt and equitable investigations. Among the =points stated are that the Office accepts anonymous complai=ts as well as direct complaints. University employees are required to cooperate =with any investigation or allegations of violations of this policy. =Providing false or misleading information or failing to cooperate may result in disciplinary action. Individuals making a complaint or participating as a witness in an investigation cannot be retaliated against. Any employee who engages in retaliation will be disciplined.&=bsp; The Office of Equity and Inclusion does not make any findings until such time as it determines that it has completed its fact gathering. =/div> Our courts recognize that participants in an administrative investigation have a privilege ag=inst a defamation charge. In </=pan>Paros v. Hoemako Hospital, =/span>140 Ariz. 335, 681 P.2d 918 (Ct. App. Div. 2 1984), the court recognized that the employer's response to a notice of charge of discrimination=20 filed with the Equal Employment Opportunity Commission was absolutely privileged. In Miller v= Servicemaster by Rees, 174= Ariz. at 520, 851 P.2d 240, 243 (Ct. App. Div. 1 1993), the court recognized the existence of a conditional privilege for employees to report perceived acts of sexual harassment as public policy dictated that employees must be protected from workplace sexual harassment. Cited approvingly, Carey v. Marico=a County, 2009 WL 750225 (D= Ariz. 2009). Both Par=s and Miller </=pan>were cases concerning discrimination 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. The Office of Equity and Inclusion will proceed with its investigation as outlined in ACD 401 and P20. The Office will not provide yo=r client with its investigative file. We look forward to Dr. KraussQ=99s continuing cooperation. Regards, =span style="font-size:11ptfont-family:Calibri,sans-serif;color:rgb(31,73=125)"> Dear=Naimah et al: Attached you will find a letter from my attorney, along with a letter he sent to Buzzfeed earlier in this week regarding the defamatory and false story they were planning on printing. The story was then published yesterday=20 morning. <=b> I wanted to add to his letter, to reiterate our concern about how your office was planning to follow up on the false and defamatory third-party allegations from Buzzfeed. Because this was initiated by an onl=ne entertainment news outlet with a clear agenda and established record of propagating false allegations about me, rather than by any of the individuals they refer to as sources, this should not be considered a =credible allegation worthy of investigation. I believe that our initial discussion was sufficient to settle this matter. Whether or not y=u agree with this, there are two things I think a=e important to establish. Firstly,&nbs=;that the University should not propagate what can be false allegations from such a source by presenting them directly to current and/or former employees or to others. To do so would be to further their libelous =agenda, as Mr Waldman has emphasized. In this regard, I would appreciate seeing copies of the correspondence you might send to current or former employees about this in the process of carrying out and concluding your investigation. Secondly, I reiterate once again that the Origins Project environment is supportive, candid, frank, honest, and productive, with all employees being treated with respect, as well as being supported and mentored. I am proud of our team, and I believe they feel the same way. <=u> Thanks for your attention=to these letters. 2 EFTA_R1_01657838 EFTA02520860 On Tue, Feb 27, 2018 at 6:30 PM, Lawrence Krauss <mailt c wrote: aiv style="word-wrap:break-word;line-break:after-white-space">Hi all: =br> I just wanted to clarify this further, in case it wasn'= completely clear. I am not being represented by Adam vis a vis the U=iversity investigation. He is advising me regarding buzzfeed issues i= case there is litigation required regarding Buzzfeed. So I haven40=99t retained legal counsel for the University Investigation. Just so=you know. You should continue to contact me if there any further questions,=developments, etc. Thanks again. Lawrenceadiv> On Feb 27, 2018, at 1:=8 PM, Cynthia Jewett <mailto <mailt • wrote: CIE Thank you. From:mailt Sent: Tuesday, Februar 27 2018 1:55 PM To= C nthia Jewett Adam Waldman mailt >; Erin El=ison - Ill • I - - • Cc: Lawrence Krauss Subject: Fwd: Private and Confidential, in respons= to our meeting. Dear Cynthia et al:=/u> Adam forwarded me your note while on a plane.=nbsp; I wanted to let you know that you can feel free to cc me on all commu=ication or email me and cc Adam, as you wish.. Adam is advising me o= matters related to Buzzfeed, and so it is appropriate to communicate to bo=h of us in this regard. I expect he will be writing to you. In a=y case, I wanted to assure you that I will continue to cooperate with all y=ur offices, as I have done thus far. I value the collegial relationship I h=ve with all of my colleagues at ASU. I do hope Naimah's grou= has taken all of our concerns about Buzzfeed under advisement, but I also u=derstand the requirements on the University as well. =/u> Thanks for your attention to this.</=> aiv> Best I Assistant (Jessica)= tel Origins Office (Cynthia): to =div st le="mar in:0in Om 0.0001pt; ont-size:l2pt;font-family:"Times=New Roman",serif' cmailtc krauss.faculty.asu=edu Be a part of something 10 years in the making! 3 EFTA_R1_01657839 EFTA02520861 =pril 5-9th 2018 —Adam Waldman < chttps://urldef=nse.proofpoint.com/v2/url?u=https-3A_www.originsl0year.com_&d=DwMFa=&c=l45AxH- kUV29SRQusp9vYR0nlGycN4_2jInuKy6zbqQ&r=lXvAt9Yyr2FDWi=ZF1A3ilL1Vn7OaKfvAPIXMR3ircA&m=znMdUakitHbuy yp0pJYIFvVS5vuv1LTTTDP94O=4bm0&s=FMeL447.3RFSNukOF7jyDzfs036dHKE4NQdWMsfiMxk&e=> Subject: FW: P=ivate and Confidential, in response to our meeting. <mailto:awaldman@theendeavorgroup.com> Date: February 27, 2018 at 12:28:21=PM PST To:&=bsp;Lawr=nce Krauss </=iv> Fyi Just got back on wifi and reading now <=iV> From mailto Date: < =pan> ues ay, ebrua 27, 2018 at 3:21 PM Waldman <mailto: Cc: Naimah Saadi <mailt > Erin Ellison <=span sty e= co or:purp e <mailt Sub=ect: FW: Private and Confidentia=, in response to our meeting. Mr. Waldman, Your client, Lawrence Krauss, copied me on his February 23=sup>rd email communication to t=e Office of Equity and Inclusion. I am writing to convey the Universi=y's position on its responsibility to conduct administrative invest=gations into allegations of conduct that would violate institutional policy= if true. Because Dr. Krauss has retained legal counsel, I am writing=directly to you. You may forward my communication on to your client.&=bsp; Without having first secured your permission, I did not think it was p=oper for me to copying him on this reply. <=iv> Our policy on the Prohibition Against Disc=imination, Harassment, and Retaliation (ACD 401&=bsp;https://w=w.asu.edu/aad/manuals/acd/acd401.html <https://urldefense.proofpoint.com/v2/url?u=https- 3A=_www.asu.edu_aad_manuals_acd_acd401.html&d=DwMFaQ&c=l45AxH- kUV2=SRQusp9vYR0nlGycN4_2jInuKy6zbqQ&r=lXvAt9Yyr2FDWivZF1A3ilLTVn7OaKfvAPi=MR3ircA&m=znMdUaPvtHbuy ypOpJYIFvVS5vuv1LTTTDP94Oi4bm0&s=fGloe_z=tNcRUFiYCSoJmaBJXtQKJ_SFbRg2AhDIdKs&e=> ) and its accompanying=procedures (P20— link to the procedures is embedded in the policy d=cument) directs the Office of Equity and Inclusion to conduct prompt and eq=itable investigations. Among the points stated are that the Office ac=epts anonymous complaints as well as direct complaints. University em=loyees are required to cooperate with any investigation or allegations of v=olations of this policy. Providing false or misleading information or=failing to cooperate may result in disciplinary action. Individuals m=king a complaint or participating as a witness in an investigation cannot b= retaliated against. Any employee who engages in retaliation will be d=sciplined. The Office of Equity and Inclusion does not make any findi=gs until such time as it determines that it has completed its fact gatherin=. <=span> Our cour=s recognize that participants in an administrative investigation have a pri=ilege against a defamation charge. In Paros v. Hoemako Hospital, 1=0 Ariz. 335, 681 P.2d 918 (Ct. App. Div. 2 1984), the court recognized that=the employer's response to a notice of charge of discrimination fil=d with the Equal Employment Opportunity Commission was absolutely privilege=. In Miller v. Servicemaste= by Rees, 174 Ariz. at 520, 851 P=2d 240, 243 (Ct. App. Div. 1 1993), the court recognized the existence of a=conditional privilege for employees to report perceived acts of sexual hara=sment as public policy dictated that employees must be protected from workp=ace 4 EFTA_R1_01657840 EFTA02520862 sexual harassment. Cited approvingly, <=span>Carey v. Maricopa County, 2009 WL 750225 (D. Ariz. 2009). Both =Paros and Miller were cases concerning discrimination and harassment under Title VII. = In addition to its obligations under Title VII, the University must also o=erate its educational programs and activities to be free from gender discri=ination under Title IX. The Office of Equity and Inclusion will proceed with its inv=stigation as outlined in ACD 401 and P20. The Office will not provide your c=ient with its investigative file. We look forward to Dr. Krauss4,=99s continuing cooperation. Regards, =div> <=iV> target="_blank">48=.965.4550 Cynthia L. Jewett Senior Associate General Counsel Arizona State U=iversity =a href="te alue="+14809654550" span> <mailto: From: Lawr=nce Krauss [mail= <rnailt° J Sent: Friday, February 23, 2=18 4:19 PM To: Naimah Saad=q <mailto ; Cynthia Jewett «=pan style="color:purple" <mailt <mailt <mailt Cc: Adam Waldma span> ; Lawrence Krauss Subject: Private and Confidential, in respon=e to our meeting. Dear Naimah et al: <a =nbsp;I wanted to add to his letter, to reiterate our concern about how your=office was planning to follow up on the false and defamatory third•party al=egations from Buzzfeed. Because this was initiated by an online=entertainment news outlet with a clear agenda and established record of pro=agating false allegations about me, rather than by any of the individuals t=ey refer to as sources, this should not be considered a credible alleg=tion worthy of investigation. I believe that our initial discussion was suf=icient to settle this matter. Whether or not you agree with&n=sp;this, there are two things I think are =mportant to establish. Firstly, that the U=iversity should not propagate what can be false allegations from such a sou=ce by presenting them directly to current and/or former employees or to oth=rs. To do so would be to further their libelous agenda, as Mr Waldman=has emphasized. In this regard, I would appreciate seeing copies of t=e correspondence you might send to current or former employees about this i= the process of carrying out and concluding your investigation.</=> Secondly, I reiterate once again that the Origins Project en=ironment is supportive, candid, frank, honest, and productive, with all emp=oyees being treated with respect, as well as being supported and mentored. I=am proud of our team, and I believe they feel the same way. =/u> Thanks for your attentio= to these letters. Lawrence Krauss <=u> =div> Dear Ms. Saadiq: 5 EFTA_R1_01657841 EFTA02520863 My name is Ada= Waldman, and I am Professor Lawrence Krauss' litigation counsel.&n=sp; Earlier this week, I sent the attached letter to Buzzfeed via one of th=ir reporters named Peter Aldhous. </=iv> I am also in receipt of Mr. Aldhous' letter to A=U, which is a variation on defamation — both libel and slander Q=93 that Mr. Aldhous and his colleagues have been manufacturing for at least=6 months (notably without any reporting) in a campaign with a purpose known=only to them. Buzzfeed's first method is to call or write thi=d parties, posit a list of fake, anonymous, recklessly false and malicious 40=804>allegations," and ask if the third party has anything to add.&=bsp; Buzzfeed's second method is to seek tortious interference with=Professor Krauss' professional contracts, by writing third parties w=th whom Professor Krauss is in privity, present a similarly inflammatory se=ies of anonymous, recklessly false and malicious accusations, and then ques=ion: how can the email's recipient allow such a person to serve on t=eir board, or speak at their conference? The letter from Buzzfeed to t=e University falls into both categories. There will be appropriate legal co=sequences for Buzzfeed's actions. <=div> It is my understanding that your office believes it is=compelled by the above to investigate false, defamatory, anonymous accusati=ns posited by the online tabloid Buzzfeed by contacting third parties and p=tentially rebroadcasting the tabloid Buzzfeed's accusations. T= be clear, these accusations were not made to the University by actual huma= beings who are alleging they were victims. There is no evidence they=were presented to Buzzfeed by actual human beings. Moreover, no present or f=rmer employees of ASU have made any such allegations to your office, or to a=y office at ASU, to our knowledge. They are simply alleged by a tabloid, an= one that had yet published a "story" on the topic when they forwar=ed these to you. You may propose to rebroadcast this tabloid's libel t= other third parties who have also made no accusation against Professor Kra=ss. I suggest that you consult with the University's counsel b=fore taking so rash a step as re-broadcasting hearsay defamation that came t= you via an online tabloid under these circumstances.<=div> Professor Krauss and I both recognize the absolu=e need to investigate real allegations. Some of the women who have br=vely come forward with personal harassment allegations against Harvey Weinstein are my clients and friends. Some of these victims have been advis=d by me. Those actual allegations are entirely distinct from a tabloi= attempting to manufacture allegations to create harm. =u> <=iv> Sincerely, DISCLAIMER Confi=entiality Notice: This email, including any attachments, is being sent by=or on behalf of the Endeavor Group or Endeavor Law Firm; it is confidential=and may contain information protected by the attorney-client and/or the att=rney work-product privileges. If you are not the intended recipient, you ar= hereby notified that any review, disclosure, copying, or distribution of t=is information is unauthorized and prohibited. If you have received this co=munication in error, please advise the sender immediately by reply email an= delete this message and any attachments without retaining a copy. IRS Circular 230 Disclosure: Any statements regarding Fe=eral tax law contained in this e-mail are not intended or written to be use=, and cannot be used, for the purposes of avoiding penalties that may be im=osed under federal tax law or to market any entity, investment plan or arra=gement. =u> <=u> Begin forwarded message:<=u> =/div> From:=nbsp;Adam Waldman 6 EFTA_R1_01657842 EFTA02520864 Date:&nb=p;Tuesda Februa 20 2018 at 5:42 PM To: Peter Aldous= <mailto: Subject: Cease and Desis=/Professor Lawrence Krauss =div style="margin:Oin 0in 0.0001pt;font-size:12pt;font-family:"Times=New Roman",serif"> Dear Mr. Aldous: I am writing as litigation counsel to Professor Lawrence=Krauss. It has come to my attention that you and Buzzfeed have engage= in an outrageous and protracted defamation campaign against Professor Krau=s, including both libel and slander. Buzzfeed's campaign has b=en malicious, undertaken with absolute reckless disregard for the truth, an= despite repeated disprovals of the falsehoods you continue to harmfully di=seminate. Your defamatory efforts have also been undertaken, for reas=ns known only to you and your colleagues, with the intention of tortiously i=terfering with the contracts of Professor Krauss, and Buzzfeed has unfortun=tely succeeded in this malignant purpose. We have both testimony and d=cuments from a litany of well respected third parties that provide overwhel=ing evidence of your and Buzzfeed's malfeasant attacks on Professor=Krauss. We are still tallying the damage. <=> You and Buzzfeed will immediately cease=and desist from further defamatory statements regarding Professor Krauss, a=d you and Buzzfeed will immediately cease and desist from any further effor=s to tortiously interfere with Professor Krauss' contracts. 1= you and Buzzfeed are unwise enough to ignore this notice to cease and desi=t from the actions described above, the appropriate legal response will be s=ift. Notwithstanding the foregoing, all legal rights are reserved. &n=sp; If you have mo=e harassing emails or any prospective communication you wish to transmit to=Professor Krauss, you are instructed to send them to me as he is now repres=nted by counsel. If your or Buzzfeed's counsel, whomever they may be,=wish to send me a letter in response to the above, be aware that I may, dep=nding on its contents and because I would be obligated to forward it to my c=ient, consider such letter to also constitute a trigger of the above and re=ct accordingly. Professor Krauss has suffered enough abuse at your ha=ds without commensurate consequences. au> =/div> Sincerely, Adam Waldman </=iv> DISCLAIMERau> Confidentiality Notice:q=pan> =This email, including any attachments, is being sent by or on behalf of the=Endeavor Group or Endeavor Law Firm; it is confidential and may contain inf=rmation protected by the attorney-client and/or the attorney work-product p=ivileges. If you are not the intended recipient, you are hereby notified th=t any review, disclosure, copying, or distribution of this information is u=authorized 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> IRS Circular 230 Disclosure: Any statements regarding Federal ta= law contained in this e-mail are not intended or written to be used, and c=nnot be used, for the purposes of avoiding penalties that may be imposed un=er federal tax law or to market any entity, investment plan or arrangement.=/span> =div> Lawrence M. Krauss 7 EFTA_R1_01657843 EFTA02520865 Director, The Origins Project at ASU Co-Dir=ctor, Cosmology Initiative Foundation Professor School of Earth & Spa=e Exploration and Physics Department Arizona State University, P.O.=Box 871404, Tem e, AZ 85287-1404 Research Office~tel: =bsp;Assistant (Jessica): tel .1~ origins.asu.edu <https://urldefense.pr=ofpoint.com/v2/url?u=http- 3A_origins.asu.edu_&d=DQMFAg&c=AGb=xfJbXK67KfXyGqyv2Ejiz41FqQuZFk4A- 1IxfAU&r=DB9LvLOIQiaqWcFOihHCOLZCntZ=R8Xtq5BHKNVR5To&m=ciP97mEbO4349G8_Nf9l5Up33Th7MWHYf6uw7yU BPZc&s==c-m4FUPqBmB-H8qg0HdYhSCLN_hZ8rH MdpPJHH3C6B0&e=> (twitter.com/Ikraussl=/span> <https://urldefense.proof poi nt.com/v2/url ?u=http- 3A_twit=er.com_Ikrauss l&d= DQMFAg&c=AGbYxf1 bXK67KfXyGgyv2 Ejiz41 kauZFk4A=1IxfAU&r=DB9LvLOIQiaqWcF0ih HCOLZCnaCR8Xtq5BHKNVR5To&m=ciP97mEb=434968_Nf9I5Up33Th7MWHYfaJw7yUBPZc&s=msppOSBZaPjp5B0PRbD 2xXlzHCi4LgzT=8KNgjNBBKg&e=> I krauss.faculty.asu.edu</=> mailta Origins Office (Cynthia) -Origins Project 1= Year Celebration- <=iv style="margin:0in Oin 0.0001pefont-size:12pefont-family:"Times N=w Roman",serif">Be a part of something 10 years in the making!<=div> April 5.9th 2018 <>=93 Visit=for more info <https://urIdefense.proofpoint.com/v2/urI?u=https-3A=_www.origins1Oyear.com_&d=DwMFaQ&c=I45AxH- kUV29SRQusp9vYROn1Gyc=4_2jInuKy6zbqQ&r=IXvAt9Yyr2FDWivZF1A3iILTVn7OaKfvAPiXMR3ircA&m==GzYZGvEU4QWv jalf6Pv02a_uDaqD2eV3yYmuVVVY41U&s=vVnehfuYQ9NbPIDQYMOYM4f0=NjOkFuBeDhri6hmZOk&e=> <image001.png> =nbsp; <image001.png> =/div> <=div> I Assistant (les • • • Orig=ns Office (Cynthia): <tel: <mailto: =/u> =span style="color:rgb(68,114,196)">origins.asu.edu <https://urIdefense.proofpoint.com/v2/urI?u=http- =A_origins.asu.edu_&d=DQMFAg&c=AGbYxfJbXK67KfXyGqyv2Ejiz41FqQuZ=k4A- 1IxfAU&r=DB9LvLOIQiaqWcFOihHCOl2CntZCR8Xtq5BHKNVR5To&m=ciP9=mEbO4349G8_Nf9I5Up33Th7MWHYf6uw7yU BInc&s=Gc-m4FUPqBmB-H8qg0HdYhSC1N_hZ=itiMdpPJHH3C6B0&e=> I twitter.com/Ikraussl <https://urIdefense.proofpoint.=om/v2/urI?u=http- 3A_twitter.com_lkrauss1&d=DQMFAg&c=AGbYxfJb=K67KfXyGqyv2Ejiz41FqQuZFk4A- 1IxfAU&r=DB9LvLOlQiaqWcFOihHCOLZCntZCR8Xt=5BHKNVR5To&m=ciP97mEbO4349G8_Nf9I5Up33Th7MWHYf6uw7yU BPZc&s=mspp=SBZaPjp5B0PRbD2xXlzHCi4LgzTZ8KNgjNBBKg&e=> I krauss.faculty.asu.edu<=span> -Origins Project 10 Year Celebration-</=iv> Be a part of something=10 years in the making! 8 EFTA_R1_01657844 EFTA02520866 April 5.9th 2018 — <= href="https://www.originsl0year.com/" style="color:rgb(149,79,114)" ta=get="_blank">Visit for more info <image002.png> <=0-- &nbs=; please note The information contained in t=is communication is confidential, may be attorney-client privileged, may=br>constitute inside information, and is intended only for the use of th= addressee. It is the property of JEE Unauthorized use, disclosure or=copying of this communication or any part thereof is strictly prohibited=br>and may be unlawful. If you have received this communication in error= please notify us immediately by return e-mail or by e-mail to Lawrence M. Krauss Director, The Origins Project at ASU Co=Director, Cosmology Initiative<=r>Foundation Professor School of Earth & Space Explorati=n and Physics Department Arizona State University, P.O. Box 871404,=nbsp;Tempe, AZ 85287-1404 Research Office Assista=t (Jessica): <tel: IMi llgins Office (Cynthia) tel: <mailt -Origins Project 10 Y=ar Celebration= Be a part of something 10 years in the making! April 5.9th 2018 — Visit for more info <https://w=w.originsl0year.com/> =u> cimage002.png=gt; -- Cr> p=ease note The information contained in this communication is con=idential, may be attorney-client privileged, may constitute inside infor=ation, and is intended only for the use of the addressee. It is the prop=rty of JEE Unauthorized use, disclosure or copying of this 9 EFTA_R1_01657845 EFTA02520867 communisation or any part thereof is strictly prohibited and may be unlawful. If=you have received this communication in error, please notify us immediat=ly by return e-mail or by e-mail to jeevacation@gmail.com <mailtoleevacation@gmail.=om> , and destroy this commun=cation and all copies thereof, including all attachments. copyright -all=rights reserved please note The inf=rmation contained in this communication is confidential, may be attorney=client privileged, may constitute inside information, and is intended on=y for the use of the addressee. It is the property of JEE Unauthor=zed use, disclosure or copying of this communication or any part thereof=is strictly prohibited and may be unlawful. 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