Defendant Wnst's Motion to Compel Plaintiff to Respond

IN THE CIRCUIT COURT FORBALTIMORE CITY MARYLAND

Civil Division

JENNIFER ROYLE

Plaintiff

Case No 24C11001571

NASTY 1570 SPORTS LLC et al HEARING REQUESTED

Defendants

DEFENDANT WNSTS MOTION TO COMPEL PLAINTIFF TO RESPONDTO 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 Court enter an order 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 answers and documents

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

Facebook accounts and requiring Plaintiff to furnish privilege log for any documents she

claims protected under the Maryland journalists shield law WNST further requests that

Plaintiff be prohibited from entering into evidence any documents not 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 2011 on the basic issues of her

defamation and false light portrayal claims Despite the 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 have become murkier and more evasive with each communication between

counsel and their current positionif there are additional 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 around the allegation that Defendants intimated

that is involved in personal sexual and/or inappropriate relationships with professional

athletes Complaint 21b she flatly refuses to furnish information about any relationship

with an athlete other than one Baltimore Oriole 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 privilege log of any sort Moreover Plaintiff refuses to

produce what she arbitrarily has deemed her personal Facebook account with which she

On June 2001 the Honorable Evelyn Omega Cannon dismissed Counts II and IV which sounded in invasion of

privacy by publication of private facts and intentional infliction of emotional distress with prejudice The only

claims remaining are for defamation Count and false light invasion of privacy Count III

In Maryland claim for false light may not stand unless the claim also meets the standard for defamation

Crowley Pox Broad Co 851 Supp 700 704 Md 1994 As in defamation claim false light claim can

only be maintained where plaintiff asserts provably false statement of fact Bagwell Peninsula Regional Med

CIr 106 Md App 470 514 665 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

members of the public professional athletes and fans all of whom she claims have

information relevant to this lawsuit.3

As Plaintiff has not complied with her obligations under Maryland law and WNST has

not received the notice to which it is entitled this Court should limit her claims to 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 Facebook

accounts and order payment of costs and reasonable 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 entire Complaint arose of words allegedly written or spoken by the

Defendants The 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 2011 Defendants moved to dismiss the private facts and emotional distress

claims 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 was made and an explanation of why each was

Defendants also requested Plaintiffs complete Twitter history and all of her medical records Plaintiffs counsel in

his July 18 2011 letter Ex.l represented that they are being promptly obtained and will be provided to the

Defendants upon receipt On that basis the Defendants will not at this time move to compel Plaintiffs production of

those items Defendants reserve the right to supplement this Motion should the Plaintiff fail to timely provide the

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 cut Plaintiffs lawsuit 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 Interrogatories attached as Exhibit number of these

statements however had no 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 June pursuant to Rule 2-432 Defendants sent Ms Royle letter outlining these

deficiencies copy of Defendants June letter is attached as Exhibit Counsel for the parties

met by telephone on June 15 and Defendants counsel reiterated that Plaintiff needed to specify

which statements allegedly made by the Defendants that she claims are false and defamatory 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 Defendants wrote two letters to Plaintiffs counsel One noted her

continuing failure to 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 listed 18 allegedly false statements However she attached

another Exhibit listing 33 separate statements copy of Ms Royles Supplemental

Interrogatory Responses and her Supplemental 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 as to the alleged statements around which this entire lawsuit is framed Defendants

have asked 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 Royle Has Failed to Meet Her Discovery Obligations under Rules 2-432 by

Responding to WNSTs Discovery in an Evasive or Incomplete Manner

Under Rule 2-43 court may compel production of discovery if the information sought

is discoverable and the partys responses are 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 351 Md

396 405 1998 Among the fundamental and principal objectives of the rules is to eliminate

as far as possible 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

Defendants here have repeatedly 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

The Court Should Order That Ms Royles Defamation and False Light

Claims are Limited to the 18 Statements Provided in the Latest

Supplemental Discovery Response and Should Award Costs

Following service of the Complaint vaguely describing 12 allegedly injurious statements

WNST issued the following simple interrogatory asking Plaintiff to list each and every

statement made by WNST she alleges was false and the reasons for her assertion of falsity

INTERROGATORY NO.4 For each statement identified your answer to

Interrogatory No.3 explain the reason that you claim it was false when madeidentify each and every fact on which you base your contention identify all

persons known to you who have knowledge of such facts and for each person

identified state the substance of that persons knowledge

Due to the extreme length of Ms Royles many responses to this

interrogatory please see Ms Royles responses in Exhibits and which are

incorporated by reference hereto

Ms Royle answered this question for the first time shortly after Judge Cannon dismissed

half of her lawsuit As noted and throughout the successive responses outlined in this motion

Plaintiff appeared to have limited her remaining defamation and false light claims to universe

of approximately 18 statements recited in her Supplemental Response to Interrogatory No but

she also included document labeled Supplemental Exhibit See Ex That document

contains alleged statements that have no possible relevance to either remaining tort claim such

as

Glenn Clark blogs that Ms Royles description of an Orioles game was wrong He later

analogizes her to character on the Jersey Shore because she is disaster He states that

he doesnt want her to do her job better Ex Supp Exhibit at 000001

Glenn Clark just ripped Royle on the air that morning and are now calling

Ms Royle Jen Midol Ex Supp Exhibit at 000002

Drew Forrester blogs that fans wont get to meet Jen Royle This appears to be joke

that she thinks of herself as star Ex Supp Exhibit at 000006

Drew Forrester tweets that Jen Royle is just tourist in Baltimore Ex Supp Exhibit

at 000009

Despite initial 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 you will glean 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

under Rule 1-341 which states

In any civil action if the court finds that the conduct of any party in maintaining

or defending any proceeding was in bad faith or without substantial justification

the court may require the offending party or the attorney advising the conduct or

both of them to pay to the adverse party the costs of the proceeding and the

reasonable expenses including reasonable attorneys fees incurred by the adverse

party in opposing it

Rule 1-341 can be an effective tool for the deterrence of unnecessary or abusive

litigation and the Court may invoke it to award party costs including reasonable attorneys

fees if it finds the opposing party has been maintaining or defending any proceeding in bad

faith or without substantial justification Zdravkovich Bell Atlantic-Tricon Leasing 323 Md

200 592 A.2d 498 503 1991 see also Seney Seney 97 Md App 544 631 A.2d 139 144

1993 the Rules purpose is to deter unnecessary and abusive litigation. Under the Rule

bad faith exists when party litigates solely with the intent to cause harassment or

unreasonable delay Barnes Rosenthal Toyota Inc 126 Md App 97 727 A.2d 431 435

1999 And lack of substantial justification exists when litigants position is not fairly

debatable and not within the realm of legitimate advocacy Id Conduct lacks substantial

justification when there is no basis in law and/or in fact to support the plaintiffs claim against the

defendants who seek fees and costs Johnson Baker 84 Md App 521 581 A.2d 48 52

1990

Here Plaintiff and her counsel skirted all debateand the law of this caseby pressing

claims for numerous statements that clearly are neither defamatory nor cast her in 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

Defendants can glean her intent Just as breach of contract defendant is entitled to know

what contract he allegedly breached and an insurance company is entitled to know what

personal injury it is defending defamation defendant like WNST is entitled to know with

specificity the allegedly actionable words it will be called on to 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 further requests an

award of its costs including reasonable attorneys fee in connection with this request

Ms Royle Must Fully Answer Discovery Relevant to Her Allegation that

WNST Made Statements that is involved in personal sexual and/or

inappropriate relationships with professional athletes Complaint

21b

WNST is entitled to discovery related to the absolute defense of truth

Ms Royles Complaint includes the sweeping allegation that Defendants made statements

that Royle is involved in personal sexual and/or inappropriate relationships with

professional athletes Complaint 21b Accordingly WNST issued requests to Ms Royle

to better understand the nature of her claim and to discover facts relevant to its defense

INTERROGATORY NO 21 Identify all former or current professional

athletes with 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 of the coaching staff or

management in Major League Baseball the National Football League the

National Basketball Association the National Hockey League Major League

Soccer the Arena Football League the PGA Tour the ATP World Tour

NASCAR any minor league affiliate of such leagues or any other minor

professional league i.e AAA baseball and the American Hockey League For

each person identified state their full name address phone number and the dates

and nature of any such relationship

Response Plaintiff objects to this Interrogatory as it contains several

interrogatories 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 The interrogatory seeks information immaterial to the 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 Response Defendants have made false statements about

relationships with Nick Swisher and Brian Matusz Plaintiff limits her claims and

responses to these athletes Furthermore as the Interrogatory fails to define the phrase

inclined in4 and the Defendants have not supplemented the Interrogatory to define

the phrase Plaintiff continues to object on the grounds that this Interrogatory calls for

speculation and conjecture Without waiving these objections and subject thereto the

Plaintiff has not had any inappropriate and or sexual relationships with either Nick

Swisher or Brian Matusz as those words are defined in Plaintiffs Supplemental Answer

to Interrogatory No 20

INTERROGATORY NO 22 Identify all former or professional athletes

with whom you have ever had intimate romantic or sexual relations of any nature

including but not limited to any current or former player or member of the

coaching staff or management in Major League Baseball the National Football

League the National Basketball Association the National Hockey League Major

League Soccer the Arena Football League the PGA Tour the ATP World Tour


professional league i.e AAA baseball and the American Hockey League For

each person identified state their full name address phone number and the dates







evidence Further the Interrogatory is overly broad vague and ambiguous

Supplemental Response See Plaintiffs Supplemental Answer to Interrogatory

No 21

Ms Royles answers are evasive and incomplete as she arbitrarily limits her responses to

New York Yankee Nick Swisher and Baltimore Oriole Brian Matusz refusing to answer the

interrogatories with regard to any other professional athlete Ms Royle cannot escape the basic

allegation of her own Complaintthat she stands wrongly accused of having personal sexual

Ms Royle objects to the typographical error inclined in in Interrogatory No 20 ignoring the obvious intended

meaning apparent in Interrogatory No 21 which indicates inclined in was intended to be involved in MsRoyles objection does not relieve her of her discovery obligations

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and/or inappropriate relationships with professional athletes.5 Ms Royle cannot pick and

choose among the athletes about whom she will answer these questions

Indeed under Maryland law 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 on the mind of the reader from that

which the pleaded truth would have produced Batson Shfflett 325 Md 684 725 1992

citing Sack Libel Slander and Related Problems 138 1980 footnote omitted Thus any

relationship she has with any athlete is relevant to the truth or falsity of her allegations and to

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 answer the interrogatories as asked

Ms Royle cannot avoid her discovery obligations by broadly invoking

Marylands Reporters Shield Law and providing no privilege log

Consistent with WNSTs Interrogatory Nos 21 and 22 regarding the nature of Ms

Royles relationships with professional athletes WNST also served number of document

requests intending to discover the universe of athletes with whom Ms Royle had relationship

of any kind See Ms Royles First and Supplemental Responses to WNSTs Requests for

Production attached as Composite Exhibit 11 However Plaintiff broadly asserts the Maryland

Reporters Shield Law Md Code COURTS JUDICIAL PROC 9-112 flatly refusing to produce

single responsive document and failing to provide privilege log Notably while Plaintiff

attempts to limit her responses to Interrogatory Nos 21 and 22 to Mr Swisher and Mr Matusz

she provides no communications between her and either of these gentlemen For the sake of

At the appropriate juncture Defendants will establish that they made no such statement

Ill

brevity WNST includes the requests at issue followed by Ms Royles generic boilerplate

objection which she included in the exact same form responding to each request at issue

DOCUMENT REQUEST NO All documents and communications with

any current or former professional athlete 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 the PGA Tour the ATP World Tour


professional league i.e AAA baseball and the American Hockey LeagueDOCUMENT REQUEST NO 10 All documents and communications with

any current or former player member of the coaching staff or management in

Major League Baseball from 2000 to the present

DOCUMENT REQUEST NO 11 All documents and communications with

any current or former player member of the coaching staff or management in the

New York Yankees baseball organization from 2000 to the present



New York Mets baseball organization from 2000 to the present



Baltimore Orioles baseball organization from 2000 to the present



Baltimore Ravens football organization from 2010 to the present

Response Plaintiff objects to the foregoing Request as it is overly broad unduly

burdensome harassing vague and or ambiguous as it requires Plaintiff to 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 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 Judicial Proc 9-1 12

Tofani State 297 Md 165465 A.2d 413 1983 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

Supplemental Response To the extent non-privileged responsive documents

exist and are in the immediate possession custody or control of the Plaintiff they have

been produced herewith

First despite her supplemental response the Plaintiff has produced communications

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between her and professional athlete Second despite her assertion of reporte privilege

Plaintiff has refused to provide privilege log of any kind that states the basis for her assertion of

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-Paclç Inc 351 Md 396 415 1998 see also Maxima Corp 6933

Arlington Development Ltd Partnership 100 Md.App 441 456 1994 Ms Royles general

assertion of privilege without more fails to comply with the requirement of Rule 2-422 that

party fully state with specificity the grounds for refusal 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 100 Md App.at 457 Indeed one court applying Maryland law has held

that partys failure to provide privilege log may constitute forfeiture of any claims of

privilege Victor Stanley Inc Creative Pipe Inc 250 F.R.D 251 267 Md 2008

Maryland courts have not specifically addressed the reporters privilege in responding to

civil written discovery However in assessing the invocation of the reporters privilege in

depositions the Court of Special Appeals has held that such assertions must adhere to the Rules

of Procedure and Discovery Guidelines See Forensic Advisors Inc Matrixx initiatives Inc

170 Md App 520 536-37 2006 In particular Discovery Guideline 5c provides that where

claim of privilege is asserted the party invoking the privilege must identify 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 duces tecum including where appropriate the author addressee and

any other recipient of the document and where not apparent the relationship of the author

addressee and any other recipient to each other Discovery Guideline 5c

In this case Plaintiffs boilerplate assertion of reporters privilege fails to provide this

particularized justification for asserting privilege See Mezu Morgan State University 269

F.R.D 565 577 Md 2010 With no privilege log WNST has been denied the opportunity to

make meaningful challenge concerning information directly relevant to her claims and WNSTs

defenses For these reasons this Court should compel Plaintiff to produce the requested

documents or alternatively to produce privilege log containing the information called for in

Discovery Guideline 5c

Ms Royle Must Provide WNST With Her Complete Facebook Account

WNST requested that Ms Royle provide access to all of her Facebook accounts for

inspection and copying

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 See Ex Despite

the fact that her counsel has represented that Plaintiffs personal page has been download9d

DOCUMENT REQUEST NO 33 Produce for inspection and copying at

mutually agreeable place and time complete access to all Facebook.com accounts

within your control

Response Plaintiff objects to this Request as it is overly broad unduly

burdensome and is 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

Supplemental Response To the extent non-privileged responsive documents

are in the immediate possession custody or controL of the Plaintiff they have been

produced herewith

14

that information is being withheld without any cognizable objection Plaintiffs arbitrary

distinction between professional and personal Facebook 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

Facebook profile is attached as Exhibit 12 Thus to the extent that she has used Facebook to

communicate with these athletes and any others who might have privacy settings hiding them

from view as well as photos status updates or other information evidences such relationships

WNST is entitled to discover that information Moreover if Ms Royle has communicated with

any of her colleagues or friends on her personal Facebook page about her work as

journalist or other issues relevant to her lawsuit she has no greater right to protect such

communications because they were made through her personal Facebook page rather than

though any other medium of communication

Additionally Plaintiff alleges that Defendants have damaged her professional and

personal reputation among members of the public and among the professional athletes she

covers have been endangered See Plaintiffs Response to Interrogatory No 10 at Exs and

To this end the communications with and about Plaintiff on Facebook with nearly 1000 of her

friends are highly relevant to her reputation and credibility in the community even if she

deems the site personal Finally the communications Plaintiff makes are all highly relevant to

her frame of mind and thus to the emotional damages she claims Complaint 35 and 55

For all these reasons Ms Royles arbitrary distinction between her personal and

professional Facebook pages is inappropriate This Court should therefore compel Ms Royle

15

to comply with the discovery request and permit WNST an opportunity to inspect and copy what

she deems to be her personal Facebook page or alternatively order Ms Royle to produce in

electronic form all documents she has already obtained from Facebook

Ms Royle Must Identify 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 Plaintiff also refers to documents and communications with identified

individuals but has refused to produce those documents Plaintiffs responses therefore remain

evasive vague and incomplete

INTERROGATORY NO Identify all communications between you and any

other persons including but not limited to the Defendants relating to the

statements identified 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 communication was addressed all those who received the communication

whether the communication was made orally or in writing the substance of the

communication and any response to the communication




Rules of Civil Procedure The interrogatory as worded is overly broad vague and

ambiguous as well as unduly burdensome as the Interrogatory does not define the 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 and subject to said objections Plaintiff prepared

correspondence to the Baltimore Ravens organization on or about August 14 2010

Plaintiff exchanged emails with colleagues and management at MASN and CBS as

well as telephone conversations beginning on approximately January 13 2011

regarding the Defendants conduct As discovery is ongoing Plaintiff reserves the right

to supplement and or amend her response to this Interrogatory

Supplemental Response Without waiving and subject to Plaintiffs original

objections to the extent the correspondence is in the immediate custody possession or

control of the Plaintiff copies have been provided See PRDR 000070-000071

000076-000078 The recipients of the letter to the Raven Public RelationsMedia staff

included to Chad Steele Patrick Gleason and Kevin Byrne Plaintiff exchanged emails

16

with Jim Cuddihy of MASN on or about January 13 2011 regarding the Defendants

conduct Plaintiff emailed Greg Bader of the Baltimore Orioles Organization on or

about 6/11/2011 Greg Bader responded to the email with an email directly to Ms

Royle Plaintiff refers the Defendants to Plaintiffs Original and Supplemental

Responses to Requests for 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 and CBS as well as telephone

conversations. .regarding Defendants conduct Although Ms Royles counsel advised that the

only correspondence with MASN was one e-mail to Jim Cuddihy which has been provided Ms

Royle failed to provide py correspondence or information regarding conversations with her

colleagues at CBS including the names of the individuals with whom she spoke or the

dates and substance of those communications

INTERROGATORY NO 10 Describe in detail any damages you contend to

have suffered to your reputation as proximate result of the statements identified

in your answer to Interrogatory No the reasons for your belief that those

statements were the proximate cause of any such loss identify all persons who you

contend have knowledge of such loss and for each person identified state the

substance of that persons knowledge




Rules of Civil Procedure The Interrogatory as worded is overly broad vague and

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 Without waiving and subject to said objections the

Defendants 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 and has had 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

Similarly here despite multiple requests Ms Royle refuses to identify the individuals

who have called into question her professional and personal reputation the members of the

public who believe that WNSTs actions caused them to believe that Ms Royle is 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 nor the unidentified others who Ms Royle contends

that she has been forced to explain herself to

INTERROGATORY NO 12 Describe in detail any damages other than those

identified in response to the preceding interrogatories suffered by you as

proximate result of the statements identified in your answer to Interrogatory Nothe reasons for your belief that the such statements were the proximate cause of

any such loss identify all persons who you contend have knowledge of such loss

and for each person identified state the substance of that persons knowledge

Response Plaintiff refeis to and incorporates her Answers to Interrogatories

Nos 10 and 11

First Supplemental Response Plaintiff refers to and incorporates her Answers

to Interrogatories 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 supplement her Answer

Second Supplemental Response Plaintiff has suffered reputational damages as

supported by the negative comments tweets and general opinions held by fans who

have heard and believe the statements identified herein Additionally Plaintiff has been

called slut bitch and other insulting names by fans who have heard or read the

Defendants statements See Responses to Requests for Production of Documents and

Supplemental Exhibit

Finally here Ms Royle fails to identify the fans who have heard and believe the

statements identified herein and fans who have heard or read the Defendants statements

who allegedly called Ms Royle slut bitch or other insulting names Similar to the

deficiencies with her answers to Interrogatory Nos and 10 Ms Royles refusal to specifically

identify these individuals creates virtually limitless and impossible universe of witnesses from

which she might call upon to testify

18

II In Addition to Ordering Ms Royles Compliance With WNSTs Discovery Requests

Within 10 Days This Court Should Award Costs Including Reasonable Attorneys

Fees

Ms Royles continued reftisal to provide documents and information at the core of this

litigation has set back WNSTs evaluation of her claims and the preparation of its defense As

detailed above WNST made numerous efforts to amicably resolve these discovery disputes

inconveniencing the Court Since WNST has been forced to seek redress from this Court Ms

Royles continued failure to comply with her discovery obligations inhibits the trial courts

inherent authority to manage its affairs and achieve an orderly and expeditious disposition of

cases See Hossainkhail Gebrehiwot 143 Md App 716 728 2002

After granting motion to compel courts have broad discretion to determine appropriate

sanctions on the violating party River Ins Co Mayor City Council of Baltimore 343

Md 34 47 1996 Braxton Faber 91 Md App 391 396-97 1992 In imposing sanctions

trial courts have considered whether the disclosure violation was technical 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 produce her Facebook 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 continues to be prejudiced by them

Accordingly sanction of some kind is necessary to prevent Plaintiff from continuing to

frustrate WNSTs defense of her lawsuit

To begin 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

Storetrax.com Inc Gurland 168 Md App 50 89-90 895 2006 affd 397 Md 37 2007

the damage in withholding evidence despite the remedy available in motion to compel is

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 of its ability to reasonably

mount defense See Helman Mendelson 138 Md App 29 43-44 2001

Irrespective of the relief it orders the Court should award WNST costs and fees If the

Court finds failure of discovery it shall require the party to pay to 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 answer under Rule 2-432b The imposition of sanctions for failure to

20

comply with discovery including by awarding costs and attorneys fees under 2-433c is within

the sound discretion of the trial court See Mullaney Aude 126 Md.App 639 633 1999

Here Plaintiffs responses were plainly inappropriate Her deficient responses to

interrogatories even as supplemented as well as her evasive document production and improper

invocation of privilege clearly violate the rules of discovery 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 the heart of the Complaint As such WNST respectfully requests that this Court issue

an order to reimburse WNST for its attorneys fees and costs incurred in preparing this motion

CONCLUSION

For these reasons WNST requests the Court grant its Motion and Order

That Plaintiffs Complaint is limited to the 18 allegedly false statements in her

supplemental response to Interrogatory No

That within 10 days the Plaintiff shall 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 privilege log consistent with Discovery Guideline 5c

That within 10 days the Plaintiff shall produce for inspection and copying her

personal Facebook account or alternatively produce her complete downloaded personal

Facebook account

21

That within 10 days the Plaintiff shall identify the unnamed individuals within

her responses to Interrogatory Nos 10 and 12

That Plaintiff is prohibited from introducing into evidence any materials she has

not provided to the Defendants within the 10 days provided in the Courts Order

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

CERTIFICATION OF COMPLIANCE WITH RULE 2-43

Pursuant to Rule 2-431 counsel for Defendants made good faith attempts to discuss with

Ms Royles counsel the resolution of the disputes described herein and certify that the parties

are 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

approximately one hour and counsel have exchanged the correspondence submitted with this

Motion Defendants were unable to resolve their disputes

REQUEST FOR HEARING

Pursuant to Rule 2-311 Defendants hereby request that this Court hold hearing on

this Motion

22

Dated July 26 2011

Respectfully Submitted

HOLLAND KNIGHT LLP

Charles Tobin

Drew Shenkman

2099 Pennsylvania Ave N.W Suite 100

Washington D.C 20006

202-955-3000 Phone

202-955-5564 Fax

[email protected]

[email protected]

Counsel for Defendants

hereby certify that on this 26th day of July 2011 copy of the foregoing was sent via

First Class Mail postage prepaid to

HODES PESSIN KATZ P.A

Brian Goodman EsqAlexandra Moylan Esq

901 Dulaney Valley Road Suite 400

Towson Maryland 21204-2600

Counsel for Plaintiff

4c1/4v92c

23

EXHIBIT

July 18 2011 Letter

from Plaintiffs Counsel

H1PIKHODES PESSIN KATZ P.A

90 OULANEY VALLEY ROADAttorneys at Low

TELEPHONE 410-938-8800

00 FAX 410-832-5600

MD 2204 TOWSON COLUMBIA ISELAIR ICAMBRIDGE WWW.HPKLCGAL.COM

Brian GoodmanWRITERS DIRECT DIAL NUMBER

410 938-8705

WRITERS DIRECT E-MAIL

bgoodmanhpkIegaIcom

July 18 2011

VIA E-MAIL charIes.tobinQihMaw.com

AND REGULAR U.S MAIL

Charles Tobin Esquire

Holland Knight LLP

2099 Pennsylvania Avenue N.W Ste 100


Re Jennifer Royle NASTY 1570 Sports LLC et al

Case No 24-C-11001571

Dear Mr Tobin

send this letter pursuant to the issues discussed in our teleconference on July 5th 2011

As an initial matter we have provided all responsive documents in our immediate

possession custody and control answering your discovery requests on three separate occasions

The Plaintiffs discovery responses will continue to be supplemented upon the receipt of

additional responsive documents given the deadline for discovery in this matter is February 21

2012

Moreover the Plaintiffs personal Facebook.com account information and the names of

every individual athlete with whom the Plaintiff has ever been inclined in personal sexual

and/or inappropriate relationship with are not relevant to and have no bearing upon the

allegations in the Complaint Plaintiffs allegations relate to her professional reputation as

To the extent that the information sought in Interrogatories No 21 and 22 is related to and/or seeks the

production of confidential source information or information collected as part of the Plaintiffs role as member of

the media such information is confidential and protected under 9-112 of the Courts and Judicial Proceedings of

the Annotated Code of Maryland As you well know court cannot compel the admission of confidential

information collected by member of the press including her sources without clear and convincing evidence that it

is relevant to significant legal issue



July 18 2011

Page

journalist The allegations regarding relationships with professional athletes are limited solely to

the Defendants defamatory statements concerning Brian Matusz of the Baltimore Orioles

organization and Nick Swisher of the New York Yankees organization See Supplemental

Answer to Interrogatory No 21 Thus any relationship whether personal sexual inappropriate

intimate romantic or otherwise that the Plaintiff has/had with other athletes if any is wholly

irrelevant to whether the Plaintiff has had such relationship with Mr Matusz and Mr Swisher

With respect to the Plaintiffs medical records all records in the possession custody or

control of the Plaintiff have been produced We have followed up with Dr Liebman and have

sent executed authorizations and requests for the records of the following health care providers

Dr Samuel Liebman

Psychology Consultants Associated PA1205 York Road 21Lutherville Maryland 21093

William Goldiner lvii

Internal Medicine

120 Sister Pierre Drive 207

Towson Maryland 21204

Charles Paulino D.OWest Side Medical Group PC314 W.l4thStreet

New York NY 10014

Diagnostic Radiology Associates

230 West 17th Street

New York NY 10011-5325

Chelsea Otolaryngology

William Portnoy

160 West 18tb Street

New York NY 10011

Upon receipt of additional responsive records not produced hereunto we will certainly

provide copies However Plaintiff will not execute blanket authorization for the unfettered use

of the Defendants

256936-1



July 18 2011

Page

Further you have refused to produce the Defendants Facebook.com account information

on the grounds that it is not relevant despite the Plaintiffs request for such documents In good

faith attempt to obtain the relevant responsive documents we request that the Defendants

supplement their discovery responses with any professional Facebook.com account information

including but not limited to the WNST.net organization page and place page as well as

Defendant Aparicios fan page It is inexplicable that you refuse to produce Defendant Aparicio

Clark and Forresters personal Facebook.com account information on the grounds of relevancy

and claim that you are entitled to Plaintiffs personal Facebook.com account information which

contains no information related to the allegations in the Complaint and which is used solely for

non-professional purposes

The twitter records produced by Defendants are incomplete It appears that rather than

searching for the relevant responsive information you simply produced tweets from certain

days surrounding the blog posts and twitter posts previously identified in the Plaintiffs

discovery responses We believe there are additional tweets that would be responsive to the

Plaintiffs discovery requests Furthermore we continue to discover blogs relating to the Plaintiff

on the website operated and maintained by Defendant WNST and readily accessible to youwhich you have failed to produce This indicates that you have failed to perform detailed

search of the Defendants databases for the requested responsive documents and information

Given the foregoing and attached hereto Plaintiff has produced the all information

related to her profesional Facebook.com fan page look forward to receiving the Defendants

professional Facebook.com account information as well as the relevant blog posts and twitter

posts requested in the Plaintiffs discovery responses

Finally have received and reviewed your letter to me of July 15 2011 It is incorrect

What we discussed and what confirmed was that Supplemental Answer to Interrogatory Noconstitutes statements which are actionable If there are additional actionable statements youwill glean this in the Plaintiffs deposition and we will of course supplement Plaintiffs Answer

to Interrogatory No accordingly Your continued reference to Maryland Rule 1-341 is

inappropriate and misplaced

Sincerely

Brian Goodman

BSG/mjc

cc Ms Jennifer Royle

Alexandra Moylan Esquire

256936-1

EXHIBIT

June 2011 Order

JENNIFER ROYE INTETE

Plaintiff CIRCUIT COURT

vs FOR BALTIMORE CITY

NASTY 1570 SPORTS LLC et al

Defendant .s Case No 24.-C11001571

ORDER

Upon consideration of the Defendants Motion to Dismiss Counts II and IV

docket no 17 and for the reasons stated on the record in open court it is this day of

June 2011 by the Circuit Court for Baltimore City hereby ORDERED that the Motion is

GRANTED and it is further

ORDERED that Counts II and IV are DISMISSED with prejudice with no leave to

rPUE Cflamend In

EXHIBIT

June 2011 Hearing Transcript

IN THE CIRCUIT COURT

FOR BALTIMORE CITY MARYLAND

JENNIFER ROYLE

Plaintiff

CASE NO 24C-ll--001571

NASTY 1570 SPORTS LLC

Defendant_____________________________________________________/

OFFICIAL TRANSCRIPT OF PROCEEDINGS

Motion to Dismiss

Baltimore City Maryland

Friday June 2011

BEFORE

THE HONORABLE EVELYN OMEGA CANNON Judge

APPEARANCES

For the Plaintiff

MS ALEXANDRA MOYLAN ESQUIRE

For the Defendant

MR DREW SHENKHAN ESQUIRE and

MR CHARLES TOBIN ESQUIRE

Audio Transcribed By Erika Newton

TABLE OF CONTENTSHUNT REPORTING COMPANY

Court Reporting and Litigation Support

Serving Maryland Washington and Virginia

41 0-766-HUNT 4868-800-950-DEPO 3376

CALL OF THE CASE M3

PLAINTIFFWITNESS DIRECT CROSS REDIRECT RECROSS

None offered

DEFENSE

WITNESS DIRECT CROSS REDIRECT RECROSS

None offered

EXHIBITSPLAINTIFF

EXHIBITS IN EVIDENCE

None offered

DEFENSEEXHIBITS IN EVIDENCE

None offered

MOTION ARGUMENTS

by MR TOBIN M5by MS MOYLAN M12

JUDGES RULING M21

PROCEEDINGS

HUNT REPORTING COMPANYCourt Reporting and Litigation Support


410-766-HUNT 48681-800-950-DEPO 3376

111652 a.m

THE COURT Okay This is the case of

Jennifer Royle vs Nasty 1570 Sports LLC Case No 24-

C-ll-001571 Counsel please identify themselves

MS MOYLAN Good morning Your Honor

Alexandra Moylan on behalf of Ms Royle

THE COURT Was your appearance entered in

this case

MS MOYLAN It was It was entered on May

19th

THE COURT As in paid -- how much is the fee

now

MS MOYLiAN believe it was $10 or $15 Im

not quite sure

THE COURT No it was more than that if you

entered your appearance It use to be $15 how much is

it now

MR SHENKMAN Im not sure

MS MOYLAN Its the same firm Its Hodes

Pessin

THE COURT Its not the firm Its your

personal appearance is entered Whats your name

MS MOYLAN Alexandra Moylan

THE COURT Your appearance is not entered

Did you personally enter your personal appearance



41 0-766-HUNT 48681-800-950-DEPO 3376

MS MOYLjAN Yes Your Honor

THE COURT When

MS MOYLAN It was done on May 19th

THE COURT Who did it

MS MOYL2AN My office did it

THE COURT You sent somebody down here to do

it

MS MOYLAN believe it was mailed

THE COURT So you dont have any evidence to

show that it actually got here

MS MOYLAN Im sorry did not bring

copy of it

THE COURT Okay Im sorry Give me your

name one last time

MS MOYLAN Sure Its Alexandra Moylan

O-Y-L--A-N

THE COURT Okay And Counsel

MR SHENKMAN Good morning Your Honor Drew

Shenkman on behalf of the Defendants and with me

appearing or -- appearing pro hac vice is Chuck Tobin

THE COURT Is Mr Tobins appearance entered

dont see it

MR SHENKMAN Tobin

THE COURT Huh

MR SHENEMAN Tobin We filed Motion for



410-766-HUNT 4868-800-950-DEPO 3376

Pro Hac

THE COURT Oh Mr Charles Tobin

MR SHENKMAN Yes

THE COURT Yes okay yes Okay Whos

going to be arguing

MR TOBIN will with the Courts

permission

THE COURT Okay thats fine Be seated

Everybody just be seated for minute Okay have

read everything You may have ten minutes each That

includes your rebuttal time

MR TOBIN Thank you your Honor Charles

Tobin on behalf of the Defendants Your Honor were

here on -- what is essentially reduced to Motion to

Dismiss single count in the Complaint We have

answered defamation count We have answered false

light count and proceeding on written Discovery

presently And in their opposition papers to our Motion

to Dismiss they have conceded and cleared the way to

entry of dismissal of Count which sounds an invasion

of privacy by publication and private facts So the

only issue remaining for argument today is our motion as

to Count which is intentional infliction of emotional

distress

Your Honor my clients are the owners and



410-766-HUNT 48681-800-950-DEPO 3376

employees of sports radio station an a.m station

here in the Baltimore market The Plaintiff Jennifer

Royle is also sports radio broadcaster with the f.m

station owned by CBS WJZ radio So this is lawsuit

against rival sports -- filed by rival sportscaster

against rival sportscaster

The grounds for our motion today are that

emotional distress as tort in Maryland is highly

disfavored She has opportunities to pursue her claim

by virtue of our answering for defamation and for false

light but she does not meet the qualifications meet the

elements prima facie on the face of her complaint for

pleading claim for intentional infliction of emotional

distress

We have three grounds for our argument and

they go to the three separate elements of the cause of

action Number one the conduct she alleges is all oral

communications that she alleges are false and

defamatory the second basis for her defamation claim

And under the case law recited to the Court oral

statements even if defamatory even if allegedly in poor

taste even if injurious are not actionable absent more

than that like close personal relationship And even

in those cases the bar is set very very high

Second of all the Plaintiff has not alleged



41 0-766-HUNT 48681-800-950-DEPO 3376

the severity of harm required to satisfy the tort in

Maryland because Maryland has such high threshold for

the tort the harm must constitute severe and disabling

emotional distress She does not plead that in the

complaint Finally Your Honor there were no facts

sufficient to support the allegation of intentionality

to cause severe emotional distress which is third

element that is required for the tort

As to the first one the conduct alleged We

rely on four precedent cases that we believe fully

answer the issue Batson phonetic vs Shiflett

phonetic decided by the Court of Appeals Ratner

phonetic vs Miller and Penn Hollow phonetic vs

Cecil County decided by the Court of Special Appeals

And finally federal case relying on Maryland law

Thompson vs BET Soundstage

In the first three cases Batson Miller and

Penn Hollow the Court was confronted with the action

ability under the emotional distress tort of alleging

defamatory or offensive words Her complaint alleges

that things were said about her job Things were said

about the performance of her job Things were said

about the truthfulness of her resume Things were said

about that were demeaning to women Things were said

about here in all of those connections with how she



410-766-HUNT 48681-800-950-DEPO 3376

performs her job In each of the three of the first

three cases mentioned Batson Miller and Penn Hollow

The Court of Appeals and the Court of Special Appeals

held that mere words alone mere insults even if

offensive to woman with all apologies to the Court we

put those words in our reply brief Even words that are

really nasty if thats what we said which remains for

later proceedings just do not qualify for the tort

under that very high threshold

Our first grounds are that in her complaint

Paragraphs 19 through 24 and in her opposition brief

she makes clear this entire claim is about words that

she doesnt like and considers injurious and that form

the basis for her remaining defamation and false light

claims and on that basis alone we believe dismissal is

warranted

Moving to the severity of the emotional

distress claim She has to plead and prove that the

intentional infliction of the stress caused such severe

harm that it interfered with her ability It rendered

her disabled from conducting her daily life Clearly

she pleads in the complaint she still performs on the

radio Still conducts herself on the radio But as to

the complaint itself the allegation that she has made

is that she has seen mental health counselor and taken



41 0-766-HUNT 48681-800-950-DEPO 3376

medications Thats what we have for the purposes of

today on the face of the pleadings

In the case of Harris vs Jones which is

where the Court of Appeals in 1977 adopted the false

light tort In the case of Polder phonetic Bowen

that in 1993 the Court of Appeals revisited the tort

And most recently in April of 2001 in the Special

Appeals Court Ladding phonetic vs St Josephs

Society which arose out of this courthouse case

thrown out on Motion to Dismiss by Judge Allison All

of the courts said that allegations that someone went to

mental health counselor and took medication are not

enough to meet the severity of the threshold test

formulating for disabling and debilitating emotional

distress

And just to give you an example in Folder vs

Bolden the Plaintiff pleaded that he was unable to make

associations with people He was locked in room

unable to leave and as result of that lost trust in

people He became paranoid All of the allegations

that arguably are even more stringent than she has in

her complaint were held not to meet the needs of the

tort And the only cases that have succeeded on the

basis of offensive words or single visit to

psychiatrist or series of visits to psychiatrist



41 0-766-HUNT 4868-800-950-DEPO 3376

There has been special intimate relationship

They rely for example on the case of

Figuredo phonetic Torres In that case the Court

and the later court said that was really outlying

case really special case In that case marriage

counselor was counseling husband not to be intimate

with the wife and at the same time having sexual

relations with the wife And the Court of Appeals

understandably held that that was severe enough to

constitute intentional infliction of emotional distress

and the severity to harm was great enough to qualify for

the tort because of the specialness of the relationship

In this case were dealing with rival

sportscasters saying things about each other in public

places on Twitter on Facebook Everybody has public

profile There is not that special relationship that

should cause this ordering Court to lower the bar below

very high level that Maryland has set

Finally as to the element that they have to

allege intent with sufficient particularity In the

Ford case that we have cited Ford vs Juvenile

Administration the Court noted that pleading has to

set forth specific facts of the intent What their

complaint says is we intended it We obviously

knowingly made the statements that they allege

Whatever those statements turn out to be And they say



41 0-766-HUNT 48681-800-950-DEPO 3376

that therefore drawn inference and its axiomatic that

we must have intended to cause severe emotional

distress Thats not what the law in Maryland says In

the Minicki phonetic case in particular it says the

Plaintiff has to get to the evidentiary particulars

You cant ask court to rely on axiom or inference from

the acts to and from intent So they have to plead very

specifically what our intent was not just the boiler

plate of the language and theyve done nothing of the

kind

Moreover there is First Amendment overlay

to any case involving speech over public airwaves about

public figure like their client Ms Royle sports

radio personality And in the First amendment case of

Falwell vs Hustler magazine the rights inaudible of

Hustler Magazines depiction of Reverend Jerry Falwell

in an advertisement parody advertisement The

Supreme Court said they have to establish First

Amendment actual malice The highest standard of

culpability for free speakers under the First Amendment

in the United States That would require them in their

complaint to plead and prove facts to show that we

actually knew the statements were injurious to her as

matter of emotional distress and would cause severe

debilitating emotional distress that would disable her

from her daily life under the standard



41 0-766-HUNT 48681-800-950-DEPO 3376

So for those three independent reasons Your

Honor were not asking for dismissal of anything else

today other than what weve conceded by the facts

claimed We are moving forward Weve just exchanged

written Discovery on the defamation and the false light

claim but we do believe for all three independent

reasons that the Court should dismiss the prejudice the

intentional infliction claim as it does not meet the

very high bar that Maryland requires Thank you Your

Honor

MS MOYLjAN Your Honor first and foremost

Counsel is correct that we are not opposing the Motion

to Dismiss Count for the invasion of light publication

and public facts However Your Honor the reason were

here today is determine whether the Defendants conduct

as pled and assuming the truth thereof which is the

standard in Maryland on Motion to Dismiss rises to the

level of extreme and outrageousness yet sufficient

enough to withstand the instant motion

The case law and the Court of Appeals of

Maryland have said the task here is whether the conduct

would be tolerated by reasonable person in todays

society dont believe that being sniffed at water

cooler while youre at work and then having one of the

Defendants then tweed that they would have snapped your

neck in half because you stood up for yourself when you



41 0-766-HUNT 48681-800-950-DEPO 3376

were being sniffed at the water cooler in professional

environment Having reporter and colleague refer to

you as scratch and sniff sticker and various other

allegations that are contained in the complaint

specifically at 2lA through -- Im sorry through

going forward to Count -- Paragraph 25 This type of

behavior and the type of behavior thats alleged in the

complaint is harassment The General Assembly has

passed criminal statute and would argue that

supports the notion that this is not tolerable in

civilized society

Additionally we wouldnt be here today if the

Defendants conduct had been conducted at cashier in

grocery store or even if it was male attorney at one

firm saying this about female attorney at

competitors firm in an effort to belittle the person

to stifle the competition to cause them to suffer not

only in professional life but in their personal lives

by spreading falsities about that persons private life

Who that person has had sexual relationships with when

this person then has to go and then cover these same

people as shes been alleged to have sexual relations

with on the internet on the radio to other colleagues

in the press boxes in professional work settings

The intention issue find puzzling because

there is no doubt that by washing into -- its alleging



41 0-766-HUNT 48681-800-950-DEPO 3376

complaint that the Defendant began to do this on

February 24 2010 Its been more than year that the

Plaintiff Ms Royle has been suffering from constant

harassment by the Defendants And the sole purpose of

this campaign has been to harass her to get her to quit

her job to stifle her competition to just reek havoc

on her reputation that shes built and that shes worked

hard to build

And the statements have been circulated in

local media its been circulated to the public and the

Defendants are in particular position where they do

have various outlets of placing these false statements

out there for the public to believe and we intend to

prove that the public has in fact taken these

statements as true That she slept with various

professional athletes that shes lied on her resume

shes had to explain herself to her superiors at work

and that was at the very least done in reckless

disregard for the fact that it would cause Ms Royle

extreme emotional distress It was willful and

malicious and it was meant to drive her out of the local

sports media

The physical manifestations of the Defendants

conduct that caused the Plaintiff severe emotional

distress are well pled Shes forced to seek medical

treatment and is continuing to seek medical treatment



41 0-766-HUNT 48681-800-950-DEPO 3376

Shes changed her work habits She has to take

prescription medication to deal with the emotional

distress that has been inflicted by the intentional act

of the Defendants and to endure this campaign of abuse

And would argue Your Honor that these are

not mere insults and theyre not indignities or

tribulations that should be endured by somebody as part

of an everyday life Its perfectly acceptable to

engage competitor to comment and express as the

Defendants motion says that shes professionally inapt

However the Defendant has crossed the line is simply

what happened here Launching into year long tirade

against another reporter that includes allegations that

are completely false as alleged and has taken as true

causing her to suffer in her professional relationships

her personal relationships and intended to cause her

damage No professional woman should be expected to

endure this as part of everyday life And would

argue Your Honor that these statements would not have

been made to male

THE COURT But thats not really what Im

deciding Im not deciding if the statements were good

Thats not the inaudible for intentional infliction

Im not deciding the statements would have been to

male Im not deciding whether or not somebody should

tolerate them Thats not what Im deciding Thats



410-766-HUNT 48681-800-950-DEPO 3376

not what the law is So thats not -- and just want

to be really clear thats not what the law is

MS MOYLZAN Right

THE COURT Its not whether or not it was

good idea Its not whether or not somebody should

tolerate it Its not whether or not they were fair

Its not whether or not they upset her Its not

whether or not about people believed it Its not

whether or not you know it messed up her job Thats

not what intentional infliction of emotional distress

is None of those things None

MS MOYLAN understand Your Honor

THE COURT So then dont need to consider

any of that

MS MOYLAN would argue that the statements

as alleged in the complaint are extreme and outrageous

and that the Defendant acted intentionally to cause Ms

Royle severe emotional distress and would also submit

another issue for the Court today that todays society

is altered by social media by the variety of outlets

that the Defendants have used to impute with the purpose

-- to make statements with the purpose of imputing Ms

Royles professional --

THE COURT That is not emotional distress

In other words its actually when you tell me if that

is the intent that is not severe emotional distress



41 0-766-HUNT 48681-800-950-DEPO 3376

Lets assume -- in other words cause thats saying

what the affect it had on other people It had other

people thinking that it doesnt say disabled her In

other words you may think Im the worst person in the

whole wide world but if continue to function might

be able to sue under another tort because you think that

but cant sue under intentional infliction of

emotional distress because you think that

So if they did it so you can think that that

might be another tort but its not intentional

infliction of emotional distress because Im still

working and Im still functioning Even though you

think these evil things of me and can recover money

for that but not under intentional infliction of

emotional distress

MS MOYLAN And understand this is

disfavored --

THE COURT All Im saying is that the

different elements -- in other words what you are

arguing is not the elements

MS MOYLAN And would argue that the acts

while they were intended for -- would argue that the

conduct of the Defendant had two-fold purpose and it

was also intended to cause Ms Royle to suffer to

suffer severe emotional distress and --

THE COURT And tell me cases where theyve



41 0-766-HUNT 4868-800-950-DEPO 3376

given facts of what is severe emotional distress

MS MOYLAN Yes Your Honor

THE COURT Whats factual character of

severe emotional distress and dont want the case

where the therapist slept with the counselor That

doesnt work

MS MOYLAN In Moniodis Cook 64 Md App

one of the Plaintiffs -- first and foremost all of

the intentional infliction of emotional distress claims

went to -- were submitted to the jury The Court of

Appeals said that one of these Plaintiffs did meet --

THE COURT tr1hat were the facts

MS MOYLAN The Plaintiffs were accused --

THE COURT No What was the severe emotional

distress

MS MOYLAN She was suffered from an existing

nervous condition and she was found -- there was

testimony that she was found at home inaudible her

hands crying there was significant deterioration of

her emotional state She was required to take greater

amount of prescriptions for her nervous condition and

relatives had to help her tend to her household chores

THE COURT In other words she could not

function as part of daily living

MS MOYLAN And if Your Honor is inclined

THE COURT No Its not me dont get to



41 0-766-HUNT 48681-800-950-DEPO 3376

make it up really dont am not -- was going to

say Im not in charge of the world but Im not even in

charge of the Court of Special -- Im not even on the

Court of Special Appeals dont get chance to make

it up and Im not deciding whether or not this behavior

was appropriate but what youve alleged doesnt come

close to what you just described

MS MOYLAN And if Your Honor is inclined

to grant the Motion to Dismiss we would ask for leave

to amend

THE COURT No Why would you have anything

to amend If you had anything to say you would have

said it No No On what basis would there be leave

to amend for what

MS MOYLAN To provide -- if Your Honor is

saying that it fails to state cause of action --

THE COURT What are you going to amend it to

say Whats going to happen thats going to change it

MS MOYLAN We would include the allegations

in the affidavit of the statements and --

THE COURT But it doesnt come close to what

youve just described You just gave me an example of

severe emotional distress and what youve described

doesnt come close You have nothing to show that comes

close And again Im not deciding if the behavior was

appropriate Im not deciding that she was not harmed



410-766-HUNT 48681-800-950-DEPO 3376

Thats not what is before me right now The question

is whether or not theres intentional infliction of

emotional distress has been adequately pled dont

see it dont get chance to make it up Ive got

to do what the law says just dont see it

MS MOYLAN Thank you Your Honor

THE COURT And want to be very clear The

Court in ruling can assume that everything the Plaintiff

said in her complaint and everything that her lawyer

argued is true Including in fact actually what her

lawyer argued is to intent that it was the intention to

put her out of business and so she wouldnt be doing

this work at all mean assuming that and Im just --

lets just assume the facts support that inference No

matter what still theres no way this Court cannot

grant the Motion to Dismiss mean the most obvious

and think there are problems with some of the other

elements but the most obvious elements is theres not

severe infliction Severe -- mean it really is

different tort It is not damages Intentional

infliction of emotional distress does not mean emotional

damages Thats not what it means and thats

essentially what is pled is saying there is emotional

harm but thats not what the Court is deciding Thats

not the tort The tort is substantially more and

think the example given by Plaintiffs Counsel in terms



410-766-HUNT 4868-800-950-DEPO 3376

of the case where somebody was really disabled from

functioning that that would be -- mean the fact that

someone is able to continue with all of their activities

of daily living and to go and seek professional help and

to seek medication may mean that if another tort is

proved in fact the person could recover damages under

another tort but it does not at all come close to

intentional infliction It just doesnt do it So for

all those reasons will grant the Motions to both

Counts Okay Thank you

MR TOBIN Thank you Your Honor

Pause

MR TOBIN Your Honor we submitted an order

THE COURT Well do my own -- see your

order inaudible Whether do your order or my order

MR TOBIN Okay thank you


THE COURT Thank you And appreciate

Counsel argument


MR TOBIN Thank you very much

Whereupon the proceeding concluded at

114221 a.m



41 0-766-HUNT 4868-800-950-DEPO 3376

EXHIBIT

Plaintiffs Initial Responses to WNSTs

Interrogatories and First Exhibit

JENNIFER ROYLE IN THE

Plaintiff COURT

FOR

NASTY 1570 SPORTS LLC et BALTIMORE CITY

Defendants CASE NO 24-C-11001571

PLAINTIFF JENNIFER ROYLES ANSWERS AND RESPONSES TOWNST SPORTS MEDIA LLCS FIRST SET OF INTERROGATORIES

AND REQUESTS FOR ADMISSION

NOW COMES Jennifer Royle Plaintiff by her attorneys Brian Goodman and

Alexandra Moylan of Hodes of Pessin Katz P.A answers the Interrogatories

propounded to her by WNST SPORTS MEDIA LLC one of Defendants and states as

follows

INTRODUCTION

The information supplied in these Answers is not based solely upon the

knowledge of the executing party but includes the knowledge of the partys agents

representatives and attorneys unless privileged

The word usage and sentence structure is that of the attorneys who in fact

prepared these Answers and language does not purport to be the exact language of the

executing party

The Interrogatories have been interpreted and answered in accordance

with the Federal Rules of Procedure plain English usage and to the extent not

specifically challenged by objection the definitions and instructions included with the

Interrogatories

GENERAL OBJECTIONS

Plaintiff objects to each and every Interrogatory to the extent the

Interrogatory seeks work product information or materials prepared in contemplation

of litigation information or communications protected by the attorney-client privilege

information or communications protected by the accountant-client privilege or the

opinions mental impressions conclusions or legal theories of the Plaintiffs attorneys

accountants or other representatives

Plaintiff does not waive any protections or privileges by responding to

these Interrogatories Inadvertent production or exposure of any such document shall

not constitute waiver of such privilege or immunity or of any other ground of

objection to the admissibility of such documents or of any information contained

therein


Interrogatory seeks information that is not relevant to this case or information that is

not reasonably calculated to lead to the discovery of admissible evidence in this case


Interrogatory is overly broad unduly burdensome harassing repetitious vague

and/or ambiguous and to the extent that the Interrogatories purport to require the

disclosure of information beyond the scope of admissible evidence under the Federal

Rules of Civil Procedure

Plaintiff objects to all Interrogatories and to the definitions and

instructions set forth therein to the extent they impose duties which exceed or alter the

duties imposed by the Maryland Rules of Civil Procedure

Plaintiff objects to any and all interrogatories to the extent that they

contain multiple unrelated subparts within single numbered interrogatory in violation

of Maryland Rule 2421 and/or all interrogatories to the extent they exceed 30

interrogatories

Plaintiffs objections and answers to the lnterrogatories are based on

information now available to Plaintiff and are made without prejudice to Plaintiffs

right to assert additional objections should Plaintiff discover additional grounds for

objections That Plaintiff has answered any Interrogatory is not intended and shall not

be construed as waiver by Plaintiff of any objection to any Interrogatory

Plaintiff has not yet completed discovery in this lawsuit and therefore

Plaintiff reserves the right to file supplemental Answers if and when such additional

information comes into her possession

234620-1

By providing the information requested Plaintiff does not waive

objections to its admission into evidence on the grounds of relevance materiality or on

any other proper grounds for objections

Plaintiff objects to all Interrogatories to the extent that they call for

documents which concern confidential business records trade secrets business plans

and/or other material which would allow the Plaintiff and/or third persons to obtain

competitive information

Plaintiff objects to all Interrogatories to the extent that they seek all

communications and all documents on the ground that she cannot know all

communications or documents which may exist

No incidental or implied admissions are intended by an answer by

Plaintiff to any Interrogatory That Plaintiff has answered any Interrogatory is not an

admission that Plaintiff accepts or admits the existence of any facts set forth or assumed

by such Interrogatory or that the making of such an answer constitutes admissible

evidence

Neither Plaintiffs agreement to produce nor her objections to the

production of any information or documents or any category of information or

documents is to be construed as an admission or acknowledgement that any

information or documents exist within such category or categories

Plaintiff objects to any Interrogatory to the extent that it requests

disclosure of information banned and/or protected from disclosure by law

Plaintiff makes these answers subject to the reservation of her right to

object to the introduction into evidence in this or any other action of any information or

material contained herein or produced hereunder upon any ground including but not

limited to relevancy materiality competency and hearsay

Plaintiff objects to Interrogatories in which party has provided their

interpretation of the meaning of document or purported to summarize the contents of

document in variance of the actual terms contained within such document in that

allegations are conclusions of law and characterizations to which no further response is

required beyond reference to the actual document cited

Plaintiff generally objects to the characterizations throughout these

Interrogatories Plaintiffs answers should not be deemed as her agreement with the

characterizations in these Interrogatories

234620-1

Plaintiff objects to the Interrogatories to the extent they seek documents or

information already in the custody or control of the Plaintiff or seek documents or

information which may be obtained more conveniently less expensively and with less

burden than by Plaintiff or by these Interrogatories

Plaintiff objects to each Interrogatory that seeks the disclosure of

documents that are available to the public

These objections are hereby incorporated into each specific objection and

response Citation to particular general response and any specific objection below is

not waiver of any of the general objections not cited therein

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 not to repeat each of the foregoing objections for each specific Interrogatory

shall not waive any of the above-stated objections

ANSWERS

INTERROGATORY NO Identify all persons who assisted in preparing

or who provided answers to these Interrogatories and your responses to the

accompanying requests for documents

ANSWER NO Plaintiff objects to this Interrogatory to the extent that it

seeks information protected by the attorney-client privilege and the attorney work

product doctrine Without waiving said objection or privilege Plaintiffs attorneys

INTERROGATORY NO State the identity address and telephone

number of each person who you believe has knowledge or information relating to your

Complaint together with the substance of their testimony knowledge or information

ANSWER NO Plaintiff objects to this Interrogatory as it contains several



Rules of Civil Procedure Further the interrogatory as worded is overly broad

234620-1

vague and 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 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 that the Defendants Aparicio Forrester and Clark may have personal

knowledge Plaintiff also presumes that current and former colleagues of the

Defendants the Plaintiff and other members of the local media may have personal

knowledge including but not limited to Jerry Coleman Casey Willett Damon Yaffe

John Gallo and Ray Buchman As discovery is ongoing Plaintiff reserves the right to

supplement and/or amend her response to this Interrogatory

INTERROGATORY NO.3 Identify each and every statement of fact made

by any of the Defendants that you allege is false as alleged in Complaint 1J19-25

including all subparts and 27 37 48-50 quoting verbatim each 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

i.e in person radio Twitter website etc and if the statement is found on website or

blog state the exact web address containing the statement Your answer to this

interrogatory should identify all statements on which you base the Complaint

including but not limited to

All statements that you contend state implicate or otherwise insinuate

that you are not qualified or competent for position as journalist and

incapable of doing job Complaint 20 21a 21b 21c21 24


that you are involved in personal sexual and/or inappropriate relationships

with multiple professional athletes and/or that you ha personal sexual

and/or inappropriate relationship with professional athlete Complaint 2021 21 21 21


that you lied on resume and did not have the credentials or experience

234620-1

that purport Ito have with regard to profession as journalist

Complaint 21cAll statements that you contend state implicate or otherwise insinuate

that you were trashy look like stripper bitch and/or an idiot

Complaint 21 24cAll statements that you contend threatened violence against you see e.g

Complaint 24dAll statements that you contend your professional work in

demeaning and uncivilized way Complaint 24bAll statements that you contend are sexually inappropriate statements

about you Complaint 24e




Rules of Civil Procedure 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

INTERROGATORY NO For each statement identified your answer to

Interrogatory No explain the reason that you claim it was false when made identify

each and every fact on which you base your contention identify all persons known to

you who have knowledge of such facts and for each person identified state the








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 Interrogatory Plaintiffs counsel would 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 has not lied on her resume 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 and/or amend her Answer

INTERROGATORY NO Identify all communications between you and

any other persons including but not limited to the Defendants relating to the

statements identified in your answer to Interrogatory No For each identify the date

of the communication by whom the communication was authored or made to whomthe communication was addressed all those who received the communication whether

the communication was made orally or in writing the substance of the communication

and any response to the communication





ambiguous as well as unduly burdensome as the Interrogatory does not define the

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 and subject to said objections Plaintiff prepared


Plaintiff exchanged emails with colleagues and management at MASN and CBS as

234620-1

well as telephone conversations beginning on approximately January 13 2011

regarding the Defendants conduct As discovery is ongoing Plaintiff reserves the right

to supplement and/or amend her response to this Interrogatory

INTERROGATORY NO With respect to each statement identified in

your answer to Interrogatory No if you contend that any of the Defendants knew

that the statement was false subjectively entertained doubts as to the truth offalsity

of

the statement or published the statement with high degree of awareness as to its

probable falsity for each Defendant state thespecific

facts on which you base your

contention and all persons known to you whohave knowledge of such facts and for

each person identified state the substance of that persons knowledge










information regarding counselslitigation strategy in this case Without waiving said

objections and subject thereto Plaintiff directs Defendant to her Answer to

Interrogatory No and incorporates her Answer thereto Plaintiff anticipates that

discovery in this case 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 Describe in detail all facts that you contend

tend to show that the statements identified in your answer to Interrogatory No were

highly offensive to reasonable person identify all persons who you contend have

knowledge of such facts and for each person identified state the substance of that

persons knowledge











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 calling her liar stating that she

sleeps with professional athletes she must cover pursuant to her professional duties

etc Plaintiff reserves the right to supplement and/or amend her Answer to this

Interrogatory as discovery in this matter is ongoing

INTERROGATORY NO Describe in detail any and all newspaper or

magazine articles bulletins flyers computer printouts broadcast tapes videos

transcripts letters to the editor or similar broadcast or printed material published from

January 2003 to the present in any form regarding you that were broadcast or

published by anyone other than Defendants

234620-1

ANSWER NO Plaintiff objects to this Interrogatory as it is overly broad

vague and ambiguous It 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 If you contend that any of the Defendants

acted with common law malice ill will or spite in making any of the statements in your

answer to Interrogatory No state the specific facts on which you base such

contention identify all persons you contend have knowledge of such facts and for each

person identified state the substance of that persons knowledge










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 Describe in detail any damages you contend to

have suffered to your reputation as proximate result of the statements identified in

your answer to Interrogatory No the reasons for your belief that those statements

were the proximate cause of any such loss identify all persons who you contend have

10

234620-1

knowledge of such loss and for each person identified state the substance of that

persons knowledge

ANSWER NO 10 Plaintiff objects to this Interrogatory as it contains several






no knowledge of their existence Without waiving and subject to said objections the

Defendants 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 and has had 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 NO 11 Describe in detail any other damages youcontend to have suffered to your feelings including but not limited to distress

anguish and humiliation as result of the statements identified in your answer to

Interrogatory No state the nature extent and duration of the alleged injury or

damage any special damages you allege are due to such injury or damage any and all

financial losses related thereto the reasons you contend that such statements were the

proximate cause of such injury or damage the names and business addresses of all

health care providers who treated you for such alleged injuries and the dates of such

treatment



11

234620-1



ambiguous as it does not define the phrase damages. .suIfered to your feelings

Without waiving and subject to said objections Plaintiff 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 cause the Defendants to publish spiteful hateful atrocious and false statements

about her The aforementioned has caused Plaintiff to alter her work habits and her

appearance 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 120 Sister Pierre Drive 207

Towson Maryland 21204 Plaintiffs damages aie ongoing as she continues to take

medication and is under the care of Dr Liebman

INTERROGATORY NO 12 Describe in detail any damages other than

those identified in response to the preceding interrogatories suffered by you as

proximate result of the statements identified in your answer to Interrogatory No the

reasons for your belief that the such statements were the proximate cause of any such

loss identify all persons who you contend have knowledge of such loss and for each


ANSWER NO 12 Plaintiff refers to and incorporates her Answers to

Interrogatories Nos 10 and 11

INTERROGATORY NO 13 In support of Count IV of your Complaint

state all facts upon which you rely for your contention that any Defendants conduct

was extreme and outrageous and beyond the bounds of decency in society j60

12

234620-1

ANSWER NO 13 Plaintiff objects to this Interrogatory as it is overly broad

vague and ambiguous Further Plaintiff objects to this Interrogatory to the extent it

seeks information protected from discovery by the attorney work-product doctrine To

answer this Interrogatory Plaintiffs counsel would be required to provide information

regarding counsels litigation strategy in this case Without waiving said objections and

subject thereto Plaintiff directs Defendant to her Answers to Interrogatories Nos

10 12 and Defendant Forresters threat that he would snap her neck along with the

other statements outlined in Exhibit As this litigation is in its initial stages Plaintiff

reserves the right to supplement this Answer as discovery proceeds

INTERROGATORY NO 14 In support of Count IV of your Complaint

state all facts upon which you rely for your contention that Plaintiff has suffered and

will continue to suffer severe and extreme emotional distress IT 62

ANSWER NO 14 Plaintiff refers and incorporates her Answers to

Interrogatories 10 11 and 12

INTERROGATORY NO 15 Identify any doctor physician medical

practitioner psychologist psychiatrist mental health counselor or mental health

practitioner that you have ever visited concerning your mental and/or emotional

health in your lifetime and for each person identified state their full name address

phone number and the date and purpose of any such visit

ANSWER NO 15 Plaintiff objects to this Interrogatory as it is overly broad and

seeks information that is not material to the instant litigation The Interrogatory is not

reasonably calculated to lead to the discovery of admissible evidence 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 Identify and describe all communications

including but not limited to letters and correspondence from members of the public

sent to you that relate to your work in Baltimore Maryland


vague and ambiguous as well as unduly burdensome as it seeks for Plaintiff to provide

all communications which term is left undefined Plaintiff has ever received

regarding her work in Baltimore Maryland Moreover the Interrogatory seeks

information immaterial to the instant litigation and is not reasonably calculated to lead

to the discovery of admissible evidence

INTERROGATORY NO 17 Identify any lawsuit or criminal proceeding in

which you were named as party either as defendant plaintiff or third-party

respondent and for each such lawsuit or proceeding state the parties the case number

and court in which the case is/was pending the nature of the claims in the complaint

and/or counterclaim and/or cross-claim the current status and the resolution if any

ANSWER NO 17 Plaintiff objects to this Interrogatory as it is not reasonably

calculated to lead to the discovery of admissible evidence Plaintiff can obtain this

public information from the 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 Identify every school college or university

you attended beginning from high school to the present stating the dates of attendance

and all degrees awarded

ANSWER NO 18 Plaintiff attended Mansfeild High School beginning in 1988

and graduated in 1992 Plaintiff attended Salve Regina from 1992 through 1996 and

graduated with B.A

14

234620-1

INTERROGATORY NO 19 Describe in detail your entire employment

history With respect to your answer to this interrogatory provide contact information

for the individual who can verify your employment describe your work

responsibilities identify your direct supervisors at each place of employment the

dates of each employment your job title including any changes during employmentand the reason for your leaving each place of employment





litigationand 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

resume and biography attached hereto as Exhibit

INTERROGATORY NO 20 Describe in detail your understanding of the

definition and/or activities associated with the following terms as they appear in

paragraph 21 subparts and your Complaint personal relationship

sexual relationship and inappropriate relationship

ANSWER NO 20

INTERROGATORY NO 21 Identify all former or current professional

athletes with 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 of the coaching staff or management in Major

League Baseball the National Football League the National Basketball Association the

National Hockey League Major League Soccer the Arena Football League the PGATour the ATP World Tour NASCAR any minor league affiliate of such leagues or any

other minor professional league i.e AAA baseball and the American Hockey LeagueFor each person identified state their full name address phone number and the dates


15

234620-1






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

INTERROGATORY NO 22 Identify all former or professional athletes with

whom you have ever had intimate romantic or sexual relations of any nature including

but not limited to any current or former player or member of the coaching staff or

management in Major League Baseball the National Football League the National

Basketball Association the National Hockey League Major League Soccer the Arena

Football League the PGA Tour the ATP World Tour NASCAR any minor league

affiliate of such leagues or any other minor professional league i.e AAA baseball and

the American Hockey League For each person identified state their full name

address phone number and the dates and nature of any such relationship






evidence Further the Interrogatory is overly broad vague and ambiguous

16

234620-1

Jun 02 2011 825PM Martin Bane 800-291-9303 page

SOLBMNLY AFFIRM under the penalties of perjury that the factual matters stated in

the Answers to IntŁrrogatories are true to the best of my information arid belief

234620-1

17

RESPONSES

REQUEST NO You are sports reporter

RESPONSE NO Admitted

REQUEST NO On March 23 2011 on the Masnsports.com blog located at

http/ www.masnsports.com/ the royle_rundown/2011/ 03/ goodbye-masn.htrnl youwrote sports reporters are indeed public figures and are open for criticism

RESPONSE NO Admitted subject to completeness of the writing being

admitted as the whole entry from said MASN Blog stated

And lastly for those of you who sent me nasty comments on this blog am in

no position to preach to you or tell you that youre bad people dont even know you

will say this however If you thought for one split second that the non-baseball related

personal attack you wrote may have been hurtful they were While sports reporters are

indeed public figures and are open for criticism which completely understand please

keep in mind that while most of us do have thick skin we are also people with the same

feelings as you And thats all have to say about that

REQUEST NO You are public figure

RESPONSE NO Plaintiff objects to this request for admission as it calls for

legal conclusion and as such is improper

18

234620-1

dhBrian Goodman

Alexandra Moylan



Towson Maryland 21 204-2600

410 938-8800

410 825-2493 FaxAttorneys for Plaintiff

19234620-1



FOR

NASTY 1570 SPORTS LLC et at BALTIMORE CITY

Defendants CASE NO 24-0.11001571

NOTICE OF SERVICE OF DISCOVERY

HEREBY CERTIFY that on this 2nd day of June 2011 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 Defendants was

mailed via first-class mail postage prepaid to


Drew Shertlcman Esquire

Holland Knight LLP

2099 Pennsylvania Avenue N.WSuite 100


202 955-3000

Attorney for Defendants

Ly k44Brian Goodman

Alexandra Moylan




410 938-8800


EXHIBIT

uoffls P3-SM1N KATZ

.4uoren .4 Lzw

Chronology of Defamatory Statements Statements Casting Plaintiff In False Light

2/24/2010 On his blog Glenn Clark lists Jen Royle in his Top Sports Media Members WeWouldnt Mind Seeing Suspended For Few Weeks

4/7/2010 Glenn Clark blogs that Ms Royle is on notice that she is up for the Apologist of the

Morning award for her statement regarding the Orioles

4/23/2010 Glenn Cambell mocks Ms Royles commentary of the Orioles 2-14 record He

congratulates her on winning the Apologist of the Morning award

4/26/2010 On his blog Drew Forrester states that Ms Royle hiring was stereotypical because

she is an out-of-towner He later states that she is not qualified to ask any questions and

insinuates that she frequents hang outs of Yankees outfielder Nick Swisher

5/3/2010 Glenn Clark blogs that Jen Royle is in the running to win The Orioles Apologist of

the Month He also notes that she is up for comparable award with the Yankees which seems

to mock her New York ties

511 2/2010 On his blog Glenn Clark ridicules statement made by Ms Royle in her

commentary of the Orioles He notes that she won Apologist of the Morning earlier that day

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

5/19/2010 Glenn Clark blogs that Ms Royles description of an Orioles game was wrong He

later analogizes her to character on the Jersey Shore because she is disaster He states that

he doesnt want her to do her job better

6/2/2010 On his blog Glenn Clark mocks Ms Royles description of an Orioles game as

heartbreaking loss In another entry he states that she barely lost out on winning the Apologist

of the Morning award

8/5/2010 CBS employee notifies Ms Royle that Glenn Clark just ripped her on the air that

morning Comments included that she knew nothing about the Ravens and did not know what

the term blitz meant but that she knew who the right fielder of the Yankees was

Swisher

9/7/2010 During Ravens practice Ms Royle is informed that Glenn Clark told member of

the media that she lied on her resume and does not have the credentials/ experience she claims to

have and does not deserve to be covering the Ravens Clark also allegedly stated that it is brutal

listening to her and inquired why CBS didnt have anyone better to cover the Ravens

HoDi3s Psssrn KATZ P.A

Page

9/12/2010 Glenn Clark sends series of tweets that included that he thought working for

Yankees meant class and that the clothes she was wearing would be considered trashy at the

Gold Club strip club in Baltimore Drew Forrester tweets that the boots she was wearing were

worth more than Glenns car Ms Royle further alleges that they called her bitch said she

looked likestripper and that she was an idiot while talking in front of press box Later after

confronting them Drew reminds Ms Royle of his affinity for her appearance and boots He also

states that they hate her because shes Yankee fan After that she alleges that Drew Nestor

and Glenn continued speaking about her

9/20/2010 CJ Spiller blogs on WNSTs website that Ms Royle should shut up He states that

she is disinterested in Baltimore and does not know how to do her job He further alleges that

she talks like high school girl

9/21/2010 After an altercation with Drew Forrester at the Ravens facility Drew Forrester

tweets that she is lucky my roid rage hasnt kicked in yet or would have snapped her head

off He then tweets that he was shocked by her actions but really enjoys her boots He later

tweets that her favorite teams are the Yankees and Rays arid that she was seen running away

from WNST when it lost power He also states that she does not know the location of Hopkins

Glenn Clark insinuates in tweet that listening to Ms Royle is awful

10/8/2010 Drew Forrester condemns fan jokingly encouraging Jen to kill herself via tweet

during the Ravens Steelers game The fans tweet appeared to follow Drews jab that Jen was

watching the game at home

11/18/2010 Drew Forrester blogs that fans wont get to meet Jen Royle This appears to be

joke that she thinks of herself as star

11/26/2010 Drew Forrester blogs that Ms Royle is not fan of Baltimore sports teams He

further insinuates that she is interested in Yankees outfielder Nick Swisher

12/29/2010 Drew Forrester blogs that Jen Royle wins the award for best example of someone

coming to town like bull in china shop and alienating herself by pissing on all things

Baltimore from the minute she got here He later states she is an out of towner who has stated

that Baltimore sucks He suggests that she has dogged Baltimore to everyone

1/2011 Drew Forrester sends series of tweets saying that shed look great in nothing but

Nick Swisher shirt she smells fantastic and that she is stuck-up snobby tourist on brief

professional vacation here Nestor tweets that she is ignorant and clueless while insulting the

bosses who thought she was qualified

1/11/2011 Drew Forrester tweets that Jen is an out-of-towner and tourist Glen Clark

tweets his agreement with said assertion Drew then threatens out-of-towners Drew also tweets

that it is suspicious that Jen received WNST text during press conference which he finds

humorous


Page

1/12/2011 Drew Forrester blogs that Ms Royle doesnt understand Baltimore He seems to

insinuate an inappropriate relationship with Orioles pitcher Brian Matusz He further alleges that

she is using Baltimore as temporary career stop and that she will never make it in Baltimore

He then seems to use threatening tone towards out-of-towners which includes Ms Royle

1/20/2011 Dave Hughes receives question in his mail bag asking how Ms Royle is able to

continue working for MASN arid cover the Orioles when she is dating an Orioles pitcher Mr

Hughes responded to the question by noting that it would be conflict of interest for Ms Royle

to date member of team she covers for MASN

1/26/2011 Drew Forrester states on his blog that the only qualification to be in Baltimore

Magazine is that you work here This is in reply to why Ms Royle is featured in the magazine

He states that her scent is her best attribute He later responds to another person that Ms Royle

is condescending snarky unfriendly and snobby He reiterates that she doesnt know

Baltimore and that he likes the way she smells making reference to scratch arid sniff sticker

1/28/2011- Drew Forrester states in his blog that Baltimores own Jen Royle showed up to

photo shoot with Nick Swisher outfit

2/22/2010 Ms Royle is informed that Nester commented on air that the only reason Ms Royle

has been employed is because she has pretty face and breasts that she is not qualified to

discuss the Orioles or any other team because Ms Royle is woman

5/25/2011 Glenn blogs in honor of the fact that the reporter from the FM sports station in

town had trouble finding Towson University yesterday we thought wed put together bucket

list for our Tuesday Top 7.. The Tuesday Top was entitled The Top Things You Need To

Do TO Consider Yourself Baltimore Sports Expert It appears that he is insuating that MsRoyle is not reporter by using

Unknown Dates

Drew Forrester allegedly tells Jerry Coleman from Fox that you know

shes hooking up with Matusz right

Drew Forrester tweets that fans can follow his tweets from the

stadium or Ms Royles tweets live from her couch Appears to be

sent around 9/27/11

Glenn Clark comments on his blog that he does not understand whyJen Royle wear short skirts and boots to games knowing she wont

be on TV and that its pretty cold outside

EXHIBIT

Bmore Media March 29 2011

httpj//www.bmoremedia.com/features/jenroyleo329 11 .aspx

Full Count Pitch March 28 2011

http//mypinstripes.blogspot.comI2O 11 /03/ftilleountpitch-ftill-count-j en-royle.html

Washington Examiner February 19 2010

http//dev .www.washingtonexaminer.cornlsports/blogsfwatch-This/Jennifer-Royal-shoulcl-be

Seott-Garceaus-new-partner-847697 7.html

Washington Examiner March 29 2010

http//washingtonexaminer.contfblogs/watchlroyle-welcome- 057fto-fan-baltimore-and-masn

Washington Examiner March 24 2011

http//washingtonexaminer.comlblogs/watchl2o 11/03/1 057ftn-fan-launch-orioles-pregame-and-

postgame-shows

Baltimore Sports Report January 10 2011

http//baltimoresportsreport.com/interview-bsr-gets-to-know-masns-j en-royle- 11316 .html

Baltimore Sports Report February 10 2011

blip //baltimoresportsreporteom/jen-royle-explains-orioles-flagship-switeh-her-role- 12690 html

Baltimore Sports Report March 21 2011

http//baltimoresportsreport.comljen-royle-parting-ways-with-masn-staying-with-105-7-

14137.html

Press Box Magazine May 2010 issue

http//www.pressboxonline.comlstory efmid62 11

Free Daily Baltimore Sun April 2011

Cover

http//www.readoz.comlpublicationlembedp1 8756

Feature

http//www.baltimoresun eomlentertainment/bthesite/bal-ean-jen-royle-win-over-birdland

201104060.41 10137.story

QAhttp//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

http//www.ba1timoremagazine.net/features/2O11 /02/to p-singles-20 11 -wheres-the-1oy



FOR

NASTY 1570 SPORTS LLC et cii BALTIMORE CITY


PLAINTIFF JENNIFER ROYLES SUPPLEMENTAL ANSWERS AND RESPONSES

TOWNST SPORTS MEDIA LLCS FIRST SET OF INTERROGATORIES

AND REQUESTS FOR ADMISSION

NOW COMES Jennifer Royle Plaintiff by her attorneys Brian Goodman and

Alexandra Moylan of Hodes of Pessin Katz P.A supplements her answers to the

Interrogatories propounded to her by WNST SPORTS MEDIA LLC one of

Defendants and states as follows









SUPPLEMENTAL ANSWER 12 Plaintiff refers to and incorporates her

Answers to Interrogatories 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 supplement her Answer

INTERROGATORY NO 20 Describe in detail your understanding of the

definition and/or activities associated with the following terms as they appear in

paragraph 21 subparts and your Complaint personal relationship

sexual relationship and inappropriate relationship

ANSWER NO 20

SUPPLEMENTAL ANSWER 20 Plaintiff defines the following terms

Relationship the way in which things and/or people are connected

Personal Relationship the way in which people are connected in their

personal and/or private lives

Sexual Relationship the way in which people are connected intimately in any

way referencing sex and/or sexual activities

Inappropriate Relationship the way in which people are connected and/or

relate to one another that is unsuitable unacceptable and/or not suitable in

particular setting location or situation

Brian Goodman

Alexandra Moylan




410 938-8800


2474854



FOR




HEREBY CERTIFY that on this 17th day of June 2011 copy of the foregoing

Supplemental Answers to Interrogatories and Responses to Requests for Admission

directed to Jennifer Royle on behalf of WNST SPORTS MEDIA LLC one of

Defendants was transmitted by electronic mail to


Drew Shenlcman Esquire

Holland Knight LLP



202 955-3000

char1es.tobinhMaw.com


fta.Nuuiv1cBrian Goodman

Alexandra Moylan




410 938-8800


2474851

EXHIBIT

June 2011 Letter to Plaintiffs Counsel

Holland Knight

2099 Pennsylvania Avenue NW Suite 100 Washington DC 20006 202.955.3000 202.955.5564

Holland Knight LLP www.hklaw.com

CHARLES TOBIN

202 419-2539

[email protected]

June 2011

Via UPS Overnight and Email

Brian Goodman Esq

Hodes Pessin Katz P.A

901 Dulaney Valley Road Ste 400


bgoodmanhpklegal.com

Re Jennjfer Royle NASTY 1570 Sports LLC et aL

Maryland Circuit Court for Baltimore City Case No 24C 11001 571

Dear Mr Goodman

We send this letter pursuant to Rule 2-431 in good-faith effort to resolve your clients

noncompliance with her discovery obligations under Rules 2-421 and 2-422 Specifically the

responses Plaintiff Jennifer Royle has furnished to WNST Sports Media LLCs WNST first

set of interrogatories and document requests are deficient as described in detail in this letter We

request that Ms Royle supplement her responses within ten 10 days of the date of this letter to

avoid the need to inconvenience the Court with Motion to Compel

Plaintiffs Responses to WNSTs Interrogatories

Your clients responses to the interrogatories are evasive and incomplete under Rule 2-

432 due to the following deficiencies

Various references to unnamed individuals Throughout Ms Royles interrogatory

responses she alludes to unnamed individuals who she contends may have information related to

her Complaint The interrogatories require her to provide the names and contact information for

each These references include

Interrogatory No and Exhibit

The current and former colleagues of Defendants referenced in the

response to Interrogatory NoThe other members of the local media referenced in the response to

Interrogatory NoThe CBS employee referenced in relation to statements allegedly made

on 8/5/20 10 as described in Exhibit to Ms Royles responses

Mr Brian Goodman Esq

June 2011

Page

The member of the media referenced in relation to statements allegedly

made at Ravens practice on 9/7/20 10 as described in Exhibit to Ms

Royles responses

The individual who informed you that Nestor made comments about you

on the air on 2/22/2010 as described in Exhibit to Ms Royles

responses

Interrogatory NoThe individual within the Baltimore Ravens organization to whom Ms

Royle prepared correspondence on or about August 14 2010 as

described in Ms Royles answer to Interrogatory NoThe colleagues and management at MASN and CBS with whom you

exchanged emails as well as telephone conversations beginning on

approximately January 13 2011 regarding Defendants conduct as

described in Ms Royles answer to Interrogatory No

Interrogatory No 10

The individuals who have called into question Ms Royles professional

and personal reputation as described in her answer to Interrogatory No10

The members of the public who believe that Defendants actions have

caused them to believe that Ms Royle is bitch liar and has had

sexual relationships with Nick Swisher and/or Brian Matusz as described

in Ms Royles answer to Interrogatory No 10

The professional athletes Ms Royle covers with whom Ms Royles

credibility has been endangered as described in Ms Royles answer to

Interrogatory No 10

The others with whom Ms Royle contends that she has been forced to

explain herself to as described in Ms Royles answer to Interrogatory

No 10

Interrogatory No Similarly in response to this standard interrogatory asking Ms

Royle to identify individuals who may have information relating to her Complaint she lists five

non-parties by name but fails to state the substance of their testimony knowledge or

information as the interrogatory required Further Ms Royles response alludes to current and

former colleagues of Defendants and other members of the local media but does not identify

those individuals by name nor does she disclose the substance of their testimony knowledge or

information

Interrogatory No Ms Royle responds to this interrogatory by attaching Exhibit

paraphrase of the statements about her that she alleges are false However the interrogatory

calls for verbatim recitation of each alleged false statement of fact alleged by Ms Royle

Very few of the alleged statements in Exhibit include the exact words used For example MsRoyle alleges oral communications where Mr Clark allegedly just ripped her on the air


June 92011

Page

8/512010 and where Drew Nestor and Glenn continued speaking about her 9/12/2010

These and the other instances in Exhibit do not provide sufficient notice to the Defendants or

the Court of the allegedly false and defamatory words Further Exhibit fails to identifS the

web address of any allegedly actionable statements that Ms Royle contends are on WNSTswebsite

Interrogatory No Ms Royles response incorporates her response to the preceding

interrogatory which asks an entirely different question Rather than explaining why she believes

iistatement identified in her answer to Interrogatory No was false when it was made as

Interrogatory No requests Ms Royle generally states that she has never lied on her resume

and has never purported to have credentials she does not have Moreover Ms Royles response

states that she has never been romantically involved with Nick Swisher or Brian Matusz but

her Complaint generally alleges statements that she has had personal sexual and/or

inappropriate relationships with professional athletes Complaint 27 Therefore Ms Royle

must respond to the interrogatory as to all professional athletes as asked and as her Complaint

alleges and not limit her response to Ms Swisher or Mr Matusz

Interrogatory No Ms Royle generically refers to conversations correspondence and

telephone conversations with unnamed individuals and in addition to failing to provide their

names and contact information fails to state the date of the communications or the substance of

the communications as the interrogatory requests

Interrogatory No Ms Royles response incorporates her response to Interrogatory

No which provides none of the information sought in Interrogatory No regarding MsRoyles complete factual basis for her assertion that the Defendants knew statements were false

subjectively entertained doubts as to the truth or falsity of statements or published them with

high degree of awareness as to their probable falsity

Interrogatory No Ms Royles response directs WNST to Ms Royles response to

Interrogatory No which provides none of the information sought in Interrogatory Noregarding the complete factual basis for Ms Royles allegation that Defendants acted with

common law malice ill will or spite

Interrogatory No 11 Ms Royles response refers to Dr Goldiners letter but has not

furnished any such document

Interrogatory No 12 Ms Royles response incorporates her response to Interrogatory

Nos 10 and 11 neither of which provides the information sought in Interrogatory No 12

regarding whether Ms Royle has any damages other than those identified the other interrogatory

responses Because her response does not include any other damages we will rely on this

representation that she has none and proceed with the defense on that basis

Interrogatory No 15 Ms Royle responds with the names of two doctors and lists no

other medical professionals with whom she has ever visited concerning her mental and/or


June 92011

Page

emotional health in her lifetime as the interrogatory required Ms Royles pre-existing mental

health condition is clearly relevant to the allegations of her Complaint

Interrogatory No 16 Ms Royle objects to this interrogatory which requests

correspondence with members of the public about her work in Baltimore without stating

whether any documents or communications exist that are responsive to the question Obviously

Ms Royles reputation is clearly relevant to the allegations of her Complaint and the

interrogatory requests information on that issue

Interrogatory No 19 Ms Royle failed to attach the document referenced as Exhibit

to her responses Moreover her response provides no information about her reason for leaving

each place of employment as the interrogatory required

Interrogatory No 20 We advised your colleague Alexandra Moylan at the June 2011

hearing that Ms Royle failed to answer this interrogatory in any manner Ms Royle is required

to respond to this interrogatory as with all others

Interrogatory Nos 21 and 22 Beyond the boilerplate objections to these interrogatories

Ms Royle provided no information citing relevancy grounds Ms Royles Complaint at 27alleges that the Defendants made false statements that she had personal sexual and/or

inappropriate relationships with professional athletes Defendants therefore are entitled to the

information requested in Interrogatory No 21 about any former or current professional athlete

with which Ms Royle has ever had personal sexual andlor inappropriate relationship as

well as the information requested in Interrogatory No 22 for information about any intimate

romantic or sexual relations of any nature she has ever had with any former or current

professional athlete This information is directly relevant to the allegations of her Complaint

Plaintiffs Responses toWNSTs Document Requests

To date you have not provided us with any documents responsive to WNSTs requests

On June 2011 following the hearing on Defendants Motion to Dismiss we asked Ms Moylan

about the requested documents that she advised were in your office We requested that she send

us those documents right away To date we have not received them Please email or those

documents to us or send them overnight

Ms Moylan further advised during our June discussion that your law firm is still

awaiting responsive documents from Ms Royle As you are aware and as am sure you advised

Ms Royle Rule 2-422 requires that parties be prepared to exchange documents by the deadline

for responding to request for production Accordingly in addition to the documents in your

possession that you will produce immediately please provide all further responsive documents

by no later than Thursday June 16th to avoid our having to inconvenience the Court with

discovery motion practice


June 2011

Page

With respect to Ms Royles written responses they are evasive and incomplete tinder

Rule 2-432 due to the following deficiencies

Failure to Provide Privilege Log Ms Royle objects on the basis of privilege without

concurrently submitting privilege log consistent with the instructions and Maryland law

Without privilege log Defendants and the Court are unable to determine what specific

documents are being withheld and whether or not Ms Royles objections are appropriate

Specifically Ms Royle asserts that documents are protected by the attorney-client privilege

and/or work-product doctrine in her responses to Document Request Nos 16 17

18 19 20 21 22 23 24 25 26 27 28 29 30 31 and 32 and the Maryland Shield Law in her

responses to Document Request Nos 9-14

Document Request No The response provides an objection but does not indicate

whether any responsive documents exist

Document Request No Ms Royles objection is misplaced Contrary to her

assertion all communications between her and the Defendants are not within the Defendants

possession custody and control For example the Defendants do not possess large number of

Ms Royles Tweets that were directed towards @WNST and they are not available on Twitter

Further Ms Royles interrogatories and requests for admission to the Defendants suggest that

Ms Royle believes she asked the Defendants to stop publishing statements concerning her yet

the Defendants are unaware of any communications in that regard particularly if made by her in

writing She is required under this request to provide these and all other documents and

communications between her and any Defendant

Document Request No Ms Royles objection to this request also is misplaced All

communications between Ms Royle and third parties about her lawsuit are not within the

Defendants possession custody or control Further the request is not overly burdensome To

the contrary it is confined to the time period relevant to this litigation

Document Request Nos 21 22 23 and 26 Ms Royles responses are

nonresponsive as they refer WNST to Exhibit to her interrogatory responsesMs Royles

characterization of the alleged statements made by Defendantsrather than producing the

documents supporting her allegations that these statements were in fact made The plaintiff is

required to provide the Defendants and the Court in litigation of this nature with the precise

words that are allegedly false and defamatory Ms Royles characterizations of statements in

Exhibit rather than providing the statements themselves does not meet her obligations in

discovery

Document Request Nos and 34 Ms Royles objection is misplaced here as well All

documents relevant to her activities on Twitter are not within the Defendants possession

custody or control In the request WNST set forth specific non-burdensome means by which

Ms Royle may obtain her entire Twitter history in electronic format at no cost to her Rather

than complying in good faith with this relevant and reasonable request Ms Royle refuses to


June 92011

Page

produce single Tweet Moreover Ms Royles statement that she uses Twitter daily pursuant

to her professional duties does not relieve her of her obligations in discovery

Document Request Nos through 14 Ms Royle broadly objects on the basis of the

Maryland Shield Law but fails to assert whether such documents exist and if they do Ms Royle

fails to submit privilege log consistent with the instructions and Maryland law Without such

WNST and the court are unable to evaluate the sufficiency of any asserted privilege Moreover

Ms Royles answer to Interrogatory No states that she prepared correspondence to the

Baltimore Ravens organization that relates solely to an incident raised by her lawsuit which

clearly would not fall within the protections of the Maryland Shield Law

Document Request No 32 Ms Royles objection based on relevance is misplaced here

as well Contrary to her assertion all communications between her and members of the public

are not within the Defendants possession custody and control Obviously Ms Royles

reputation is clearly relevant to the allegations of her Complaint and the request seeks

documents related to that issue

Document Request No 33 Contrary to Ms Royles boilerplate objection the

information contained on her Facebook profile is directly relevant to the issues raised in her

Complaint Like Twitter Facebook provides an easy cost-free and non-burdensome method to

access all information on Ms Royles account including to status updates email messages

photos listing of friends etc Specifically when logged onto her Facebook account Ms Royle

should select the Account tab followed by the Account Settings tab followed by selecting

Download your Information Ms Royle may then hit the Download button and her entire

account will compiled by Facebook and emailed to the email address Facebook has on record

We look forward to your supplemented responses and document disclosures within ten

10 days of this letter We reserve the right to add to these objections once your client has

further responded to her discovery obligations including providing all responsive documents If

you have any questions please do not hesitate to 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 1570 SPORTS LLC et

Circuit Court for Baltimore City

Case No 24-C-i 1-001571

2/24/2010 On Glenn Clarks blog Drew Forrester lists Jen Royle as number in

his Top Sports Media Members We Wouldnt Mind Seeing Suspended For

Few WeeksIn honor of Tony Kornheisers suspension fiom ESPN Glenn and Drew

have compiled lists of the top sports media members they want to see

suspended for few weeks

Drews List

Jen Royle

Glenn Clark Glenn Clarks Blog Comcast Morning Show Tuesday Top 7-Sports

Media Members We Wouldnt Mind Seeing Suspended For Few Weeks

available at 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 Glenn Clark blogs that Ms Royle is on notice that she is up for the

Apologist of the Morning award for her statement regarding the Orioles

Mike Gonzalez was TERRIBLE last night It wasnt all his fault but he

was TERRIBLE Hence Chris Stoner won our first Apologist of the

Morning award from Drew Forrester and myself But Im putting Jenn

Royle on notice She said the Orioles would compete to finish .500 if that

was the last of Gonzalezs struggles

And if Cesar Izturis manages to get hits every 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 Glenn Clark mocks Ms Royles commentary of the Orioles 2-14

record He congratulates her on winning the Apologist of the Morning award

The APs David Ginsburg says Adam Jones wants to be role modeF for

young African-Americans

would prefer that Adam Jones would choose to be role model to other

baseball players by actually being. .you know. .good

PRDR000002

HPK/ROYLEv.WNST

And before we leave the Orioles completely hearty congratulations to Jen

Royle from 105.7 for being named todays Apologist of the Morning Her

thoughts included

To lose 14 of the last 16 games and have record of 2-14.. something to

me just isn adding upThe answer of course is wins She adds..

Let me quote myfavorite movie Bull Durham good friend of mine used

to say This is very simple game You throw the ball you catch the ball

you hit the ball Sometimes you win sometimes you lose sometimes it rains

Think about that for while

Ebby Calvin Nuke LaLoosh

Luke Scott said he praying things get better think the entire city of

Baltimore is as well If things were only as simple as the movies huhCertainly would For example if things were as simple as the movies Id of

course be with Mila Kunis.

Glenn Clark Glenn Clarks Blog Friday Mornings Crabs and Beer available at

http //wnst.net/wordpress/glennclarkl2O 10/04/23/friday-mornings-crabs-and-beer-

90/

4/26/2010 On his blog Drew Forrester states that Ms Royles hiring was

stereotypical because she is an out-of-towner He later states that she is not

qualified to ask any questions and insinuates that she frequents hang outs of

Yankees outfielder Nick Swisher

Jen Royle is the new 0s beat reporter for the teams flagship radio station

105.7 In typical Fan Fashion they hired an out-of-towner to handle the

duties of covering the team In all fairness if youre going to hire beat

reporter she might as well be pretty .no offense Casey

What will Jen Royle ask MacPhail Answer Shes not equipped to even

ask anything shes Yankees fan Maybe she can ask MacPhail if hes ever

been to the Cobb Chop House in Manhattan think heard her say its one

of Swishs favorite hang outs

Drew Forrester Drew Forresters Blog It takes 20 minutes Orioles shouldnt run

from the challenge flag available at

http //wnst.net/wordpress/drewforrester/20 0/04/26/it-takes-20-minutes-orioles-

shouldnt-run-from-the-challenge-flag/

247747-I

PRDR000003

HPKIROYLEv.WNST

5/3/20 10 Glenn Clark blogs that Jen Royle was in the running to win The

Orioles Apologist of the Month He also states that she is up for comparable

award with the Yankees which seems to mock her New York ties

The nominees for Apologist of the Months included such former

Apologist of the Morning winners and nominees as

-Jen Royle who is also nominated for Yankees apologist of the month .1

BUT..

None of them were ready to claim major championshipGlenn Clark Glenn Clarks Blog The Orioles Apologist of the Month Is..

available at httpwnst networdpress/glennclarkl2O 10/05/03/the-orioles-

apologist-of-the-month-is

5/12/2010 On his blog Glenn Clark ridicules statement made by Ms Royle in

her commentary of the Orioles He notes that she won Apologist of the Morning

earlier that day

The Suns Dean Jones Jr says Joey Gathright Brandon Waring had

solid night for 0s on farm

And before we move on from the Orioles few things..

A-Congratulations to our Apologist of the Morning as selected by The

Great Arbitrator on AM1570 WNSTs The Morning Reaction It isnt the

first time Jen Royle has claimed the award but its one of the funnier efforts

from her this season Via MASNSports.com..You think the Orioles have problems Compared to the Mariners they

really don

Hmm .Cliff Lee last night-was he problem for the Mariners Or for the

Orioles

The statement is obviously ludicrous The Orioles not only have as many if

not MORE problems than the Mariners they have more problems than Jayz..

Glenn Clarks Blog Wednesday Mornings Crabs and Beer available at

http //wnst.net/wordpress/glennclarkl2O 10/05 2/wednesday-mornings-crabs-and-

beer- 10

5/18/2010 Glenn Clark states in his blog that Ms Royles description of gamewas irrelevant He notes that she once again won the Apologist of the Morning

247747-1

PRDR000004

HPKIROYLEv.WNST

Congratulations to Sgt Jen Royle who was AGAIN selected by The

Great Arbitrator Drew Forrester as our Apologist of the MorningDrew

honored Jen for these thoughts she left over at 105.7..

went to the Kansas City side post game and listened to their new managerNed Yost compliment the pesky Patterson up top and then heard Billy

Butler who when 2-for-4 with two RBI praise Bergesen The 0s got

complimentsfrom their opponents but unfortunately that doesn help in the

win column

could have dissected the Orioles pre-game meal and it would have been

exactly as relevant WowGlenn Clark Glenn Clarks Blog Tuesday Mornings Crabs and Beer available at

http //wnst.net/wordpress/glennclark/20 10/05/18/tuesday-mornings-crabs-and-

beer-97/

5/19/20 10 Glenn Clark blogs that Ms Royles description of an Orioles gamewas wrong He later analogizes her to character on the Jersey Shore because she

is disaster He states that he doesnt want her to do her job better

The APs David Ginsburg says Orioles touched up Royals bullpen

after Creinke departed for 10 inning win

No the Orioles did not beat Zack Greinke despite what someone over at

105.7 cough Jen Royle cough said They did however win game started

by Zack Greinke which is ALMOST just as good

Edit from GMC Some might say Im obsessed vith her Theyre right Its

similar to how many of us are obsessed with Snooki from Jersey Shore

Its just such disaster that how can you possibly turn away The reality is

that as much as say want Jen Royle to do her job better probably

REALLY dont want her toGlenn Clarks Blog Wednesday Mornings Crabs and Beer available at

http //wnst.net/wordpress/glennclark/20 10/05/19/wednesday-mornings-crabs-and-

beer-i 02/

6/2/20 10 On his blog Glenn Clark mocks Ms Royles description of an Orioles

game as heartbreaking loss

The APs Howie Rumberg says Tejada made costly error as Orioles

fell to Yankees in New York

Our girl Jen Royle described it as one of the most heartbreaking losses of

the season The rest of us barely even noticed it happened In fact as the

game was coming to close was getting in my car to go check out Shrek

247747-I

PRDR000005

HPKIROYLEv.WN5T

which was okay over at The Avenue in White Marsh This wasnt

heartbreaking this was Orioles Baseball 2010Glenn Clarks Blog Wednesday Mornings Crabs and Beer available at

http //wnst.net/wordpress/glennclarkl2o 10/06/02/wednesday-mornings-crabs-and-

beer-i 04/ link to

http//sports .wnst.net/mlb/recap.asp1 gMLBg30060 111 0refrectrn src

MLB

Ryan Chell mocks Ms Royle as barely having missed winning the award for

Apologist of the Morning653-Giving out the Apologist of the Morning award It was 50-50 shot

between the great Jen Royle or first-time candidate listener Allen

McCallum The rookie Allen McCallum pulls the upset and wins

it. .congratulations Allen for winning the Apologist of the Morningaward

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 local journalist in town is apparently playing in Celebrity Softball

Game With Ravensplayer whose name they cant spell

Tweet copied by Ms Royle from Twitter.com

6/9/1020 Ryan Chell once against mocks Ms Royle about Apologist of the

MorningTrying to give out the Apologist of the Morning Two of the nominees are

MASN/105.7 the Fan employees in Jen Royle and Rock Kubatko Kubatko

wins for the article he wrote last night for MASN Sports

Ryan Chell Chellin Out Wednesday on The Morning Reaction available at

http //wnst.net/wordpress/ryanchell87/20 10/06/09/wednesday-on-the-morning-

reaction-2/ link goes to

http//w-ww.masnsports .com/school of rochl2o 0/06/when-7-runs-and- 15-hits-

arent-enough.html

8/5/2010 Casey Willet co-worker and CBS employee notifies Ms Royle that

Glenn Clark just ripped her on the air that morning and are now calling MsRoyle Jen Midol Comments included that she knew nothing about the Ravens

247747-1

PRDR00000G

HPK/ROYLEv.WN5T

and did not know what the term blitz meant but that she knew who the right

fielder of the Yankees was Nick Swisher.1

9/7/2010 During Ravens practice Ms Royle claims that Glenn Clark told

media member/CBS co-worker Damon Yaffe that she

lied on my resume and do not have the credentials/ experience saw have

and do not deserve to be covering the Ravens Clark also allegedly stated

that it is brutal listening to her and inquired why CBS didnt have anyone

better to cover the Ravens

Letter to Ravens sent by Jen Royle to Chad Steele Patrick Gleason and Kevin

Bryne employees of the Baltimore Ravens Organization in late 2010

9/12/2010 Drew Nestor and Glenn tweet about her

Glenn Clark Cant believe JenRoyleMASN called me douchebag in

front of everyone here tonight thought working for the Yankees meant

class.. Ms Royle alleges her comment was not in front of anyone

Glenn Clark And 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 are worth more than Glenn Clarks car

truth

Tweets cut and copied from Twitter into letter to Ravens.2 Copies in letter to

Ravens

Ms Royle asks them to stop later in the dayMs Royle confronted Mr Clark and told him his tweet was Crossing the line

and was Extremely unprofessional While Ms Royle was confronting Mr Clark

Mr Forrester walked by the altercation and yelled Where are your boots

Ms Royle Asked Mr Clark to step outside with Drew to talk and Clark said

No This is not the right place Drew then said Go home and put your boots on

first then come inside and let me buy you drink

After that another media member Jon Gallo of CBS Sportsline informed MsRoyle that Drew Nestor and Glenn made comments including

Fuck that bitch She looks like stripper Shes complete idiot

And Drew Forrester made the comment Id like to smell her boots

Available on the Defendant WN5Ts website Persons with personal knowledge include Jon Gallo and Casey

\ViIlit

Letter to Ravens from sometime in Mid-september of 2010

247747-1

PRDR000007

HPK/ROYLEv.WN5T

Letter to Ravens

Jon Gallo also confronted the Ravens PR staff and said If you dont tell WNST to

stop talking negatively about Jen Royle would like to have my seat changed

9/20/2010 CJ Spiller blogs on WNSTGood freakin lord Shaddup Jen Royle First of all Jen we understand

you were demoted from New York media roles to your current spot here in

Podunkamore .. You talk like high school girl trying out for the Jersey

Shore not sports reporter

Copied from CJ Spiller blog on WNST.3

9/21/2010 After brief encounter with Drew Forrester at the Ravens facility

where Ms Royle was approached at the water cooler Drew Forrester invaded MsRoyles space and asked her how she was Ms Royle did not respond Instead she

walked away Drew Forrester then yelled to Ms Royle Wait where you going

Dont you want to know how am Ms Royle responded Not really

Drew Forrester later tweets

girl is lucky my roid rage hasnt kicked in yet or would have

snapped her head offHe then tweets

It was definitely real water-cooler moment was shocked at the wayshe spoke to me But dig the hell out of her boots

Next he tweets

Miss America has left the building without apologizing to meHe also tweeted that

her two favorite teams the Yankees and Rays .1

He fUrther tweets

lost power at WNST about 40 minutes ago Rumor is someone saw

Jen Royle running away from the building hee hee

Finally he tweets

Jen doesnt know where Hopkins is. .LOL 10Copied by Jen Royle from Twitter

Blog no longer available on website

longer available on Twitter

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On or about 10/1/201 Drew Forrester leaned far back in his chair at the Ravens

facility in Owings Mills and eyed Ms Royle up and down staring at her legs MrForrester was well aware that Ms Royle witnessed this Later in the press

conference room when Ms Royle walked past Mr Clark Forrester yelled to

Clark Dont say anything Glenn We dont want to get in trouble again Upon

commencement of the press conference Clark and Forrester stared at Ms Royles

legs as she walked past and laughed

Ms Royle and the Defendants have personal knowledge of this occurrence

10/8/2010 Drew Forrester condemns fan jokingly encouraging Jen to kill

herself via tweet during the Ravens Steelers game The fans tweet appeared

to follow Drews jab that Jen was watching the game at home

one of her critics authored tweet that encouraged Jen to kill herself It

wasnt joke It came across as very serious and Jen took it that way in her

response cant stress how wrong it is for anyone to EVER encourage or

implore someone to end their life

Drew Forresters Blog Coat your big apple with some Friday Mud available at

http //wnst.net/wordpress/drewforrester/20 10/10/08/coat-your-big-apple-with-

some-friday-mud

11/18/2010 Drew Forrester blogs that fans wont get to meet Jen Royle This

appears to be joke that she thinks of herself as star

Come one come all to the Fullerton Pub tonight at 7pm when The

Morning Reaction hosts Rub Elbows with the Stars

And no that doesnt mean youre going to meet Jen Royle

It means were going to meet YOU and rub elbows with YOU the real

stars of WNST radio and WNST.net

Drew Forrester Drew Forresters Blog Tonights the night Our canned food drive

begins at The Fullerton Pub available at

hap wnst.networdpress/drewforrester/20 10/1 1/1 8/tonights-the-night-our-canned-

food-drive-begins-at-the-fullerton-pub

11/26/2010 Drew Forrester blogs that Ms Royle is not fan of Baltimore sports

teams and he further insinuates that she is interested in Yankees outfielder Nick

Swisher

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Its no secret that one of our local radio reporters in town isnt fan of

Baltimore sports teams And because she isnt well known here passed

along questionaire to her with some fairly personal questions One of the

questions was this If you could ever have handsome man take you out on

date and try to earn your affection what would you want him to wear She

wrote Well Ive always been sucker for man in uniform so heres what

Id like him to look like

Drew Forresters Blog Stuff yourself with Friday Mud available at

http /wnst.net/wordpress/drewforrester/20 10/11 /26/stuff-yourself-with-friday-

mud link goes to picture of Nick Swisher at

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

RT @WNST Drew WNST text went out during the Harbaugh press

conference and she looked at her cell phone at the same time looked at

mine LOL @WNST Drew At least we now know some of the other

media folks in town are fans ahem of the WNST text service hehe

Copied by Jen Royle from twitter.5

12/29/2010 Drew Forrester blogs about his best of the best of Baltimore for 2010

and says

No longer available on Twitter

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Best example of someone coming to town like bull in china shop and

alienating herself by pissing on all things Baltimore from the minute she got

here Jen Royle And the vote wasnt close Next topicDrew Forrester Drew Forresters Blog My Best of the Best in 2010 Dec 292010 available at http //wnst.net/wordpress/drewforrester/20 10/12/29/my-best-of-

the-best- in-20 10/

Several comments on the blog show how Drew Forresters comments affected

people

Steve SaysDecember 29th 2010 at 413 pmOh and while have you .enlighten us on Jen Royle Whats her deal and

what did she do to garner all the hate Dont really know much about her..

DF Hatebad word No one HATES Jen Royle dont know her deal

Shes an out of towner who showed up here earlier in the year and

immediately started talking about how much the place sucks

bhop SaysDecember 29th 2010 at 102 pm

Man she specifically dogged Baltimore to you What did she actually say

DF Brian err or is it Tom. .She has specifically dogged Baltimore to

anyone and everyone If you havent picked up on it youre not paying

attention

Stanton Salter SaysDecember 30th 2010 at 1207 pm

Best example of local sports radio talk-show host bashing the very

successful marketing efforts of one of his employers sponsors WNSTSDrew Forrester completely ripping the Maryland Jockey Clubs Preakness

Preak On slogan Preakness had about 100000 in attendance once again in

2010 so the slogan worked wouldnt have stooped to this level by posting

this however Your negative comments on here about Jen Royle reminded

me of how unprofessional you are at times My question is this. .Who are

you to criticize new young talent in town trying to learn the ropes

Perhaps she did make few blunders upon arrival dont know just going

by what youre saying but she at least deserves few breaks while she is

getting comfortable in her new surroundings You on the other hand have

been here for long time and it seems you have no problem bashing

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Baltimore traditions such as the 0s and Marylands largest sporting event

The Preakness For the record Ive never even met Jen Royle Only sticking

up for the new kid in town

bhop SaysDecember 30th 2010 at 1259 pm

So sheliterally stood around bunch of other Baltimore reporters and

openly talked about how much she hated Baltimore Did that really happenIf so thats got to be the weirdest thing Ive ever heard

It is interesting to note that she had that much of an affect on you that you

were inclined to include specific section in your 2010 review to call her

out unprovoked Interesting indeed DF Anyone who is critical of

Baltimore has an affect on me Im from BaltimoreDrew Forrester Drew Forresters Blog My Best of the Best in 2010 available at

http//wnst.net/wordpress/drewforrester/20 10/1 2/29/my-best-of-the-best- in-20 10/

1/2011 Drew Forrester sends series of tweets saying that shed look great in

nothing but Nick Swisher shirt and that she is stuck-up snobby tourist on

brief professional vacation here Nestor tweets that she is ignorant and clueless

while insulting her bosses who thought she was qualified

@WNST Drew So Im handling @mattvensel and jenroylemasn today

at WNST.net Hell get it .she might cry.. but its all good nonetheless

@WNST @NoTjenrolemasn @ienrolemasn Drew Well bet youd look

great in Nick Swisher shirt and nothing else LOL

@WNST yoitschad JenRoyleMASN Drew Well you know where to

find her Shell be the one talking about how cute A-Rod is.

@JenRoyleMASN Drew Im exhausted trying to figure out what perfume

you were wearing yesterday You smelled fantastic

@WNST JenRoyleMASN Drew And think the fact that youre

stuck-up snobby tourist on briefprofessional vacation here is

COMICAL too

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@WNST Nester When Ravens season ends Ill engage w/ignorant out-

of-town genius journalists who are clueless For now Im purple

focused

@WNST Nestor But Drew has been KIND to Miss Yes Jen Mr

Renegade .. real disgrace is in corporate bosses who though Yeah theyre

qualified


1/11/2011 Drew Forrester tweets that Jen Royle is just tourist in Baltimore

@WNST Drew LOL that Jen Royle thinks Im obsessed with heThats her OPINION Heres my FACT Jen is an out-of-towner tourist


Glen Clark tweets his agreement with that assertion Drew then threatens out-of

towners

@WNST Sparky4ddub Drew Well out-of-towners who come to

Baltimore and try to tell ME about Baltimore sports is.. using your

word .annoying

@WNST GMC Im glad let Drew write today he handled it well Kudos

to him

@WNST Drew Forrester Out-of-towners beware. .this isnt good week

to pick on Baltimore http//bit.ly.fK3hnI-l

@WNST @DamStone JenRoyleMASN @1 O57TheFan @matt\ensel

Drew Hey its just like pro wrestling We all have role to play Noworries..


Glenn also posts blog in which he states that Ms Royle has fanned flames since

coming to Baltimore and that he thinks she has good scent

Jen Royle has been fanning the flames since the day she graced us with her

presence last spring And in FULL disclosure have to admit that she

SMELLED like million dollars yesterday at the Ravens press conference

6No longer available on Twitter



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Yesterday honestly she literally did grace us with whatever she was

wearing .it was glorious

When you arrive in Baltimore to work you cant come in like banshee

and kick the door down and say where is the son-of-a-bitch NoteQuick Jen who said that No it wasnt Brian Matusz think he said

Love those jeans. It was Brian Billick you know the coach of the

Ravens when they won the Super Bowl and the guy who was so impressed

with our small audience that he bought into the stationDrew Forrester Drew Forresters Blog Out-of-towners beware. .this isnt good

week to pick on Baltimore

available at http //wnst.net/wordpress/drewforrester/20 11/01 11 /out-of-towners

bewarethis-isnt-a-good-week-to-pick-on-baltimore/

Drew then comments that Ms Royle prefers other cities and is just in Baltimore

on scholarship

As for that girl at 105.7 she can try to write about how much she loves

crabs and Sabatinos and Fells Points great view of the sunset but the truth

of the matter is that shes here on scholarship She knows that Three years

from now her apartment in Baltimore will be occupied by someone else and

shell be in Chicago or Los Angeles or Miami or some other ritzy place

where her pretty smile and expensive perfume habit will be part of some

other stations budget

EDIT from DF at 535pm Since posted this len has launched into

ferocious Twitter attack claiming among other things that Ill never be

anything but miserable small-time talk show host who cries over his

baseball team She should know lot about claiming something in

Baltimore to be small-time since she is on the record saying she had

numerous job opportunities when she ahem left the YES Network in

2009 but chose Baltimore because it gives me the chance to be big fish

in SMALL pondDrew Forrester Drew Forresters Blog Out-of-towners beware .this isnt good

week to pick on Baltimore available at

http //wnst.net/wordpress/drewforrester/20 11/01 11 /out-of-towners-bewarethis

isnt-a-good-week-to-pick-on-baltimore/2/

1/16/2011 In tweet Drew Forrester seems to be referring to Ms Royle when he

implies that she is upset that the Patriots lost

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@WNST Drew Somewhere tonight certain local journalist is down in

the dumps feel bad for her Really do do Really


1/20/2011 Dave Hughes answers question on DCRTV.com that it would be

conflict of interest for Ms Royle to date player on the team she covers for

MASN The question he responded to stated people on the team and MASN

employees were well aware that she has been dating an Orioles pitcher Likely

available at http//www.dcrtv.com/davetvl .html but no sound to confirm on10

1/21/2011 Drew Forrester blogs with link to sign that ruined Ms Royles2010 The link is picture of sign saying Welcome to Baltimore Hon

The sign that ruined Jen Royles entire 2010 is RIGI IT hEREDrew Forrester Drew Forresters Blog Friday Mud is better than day at the

beach available at http //wnst.net/wordpress/drewforrester/20 11/01/21/friday-

mud-is-better-than-a-day-at-the-beach link to

http //www.baltimorebrew comlpublishwp-content/uploads/20 10/1 2/hon-

welcome-to-baltimore-katrina-krauss .jpg picture of sign saying Welcome to

Baltimore Hon

1/26/2011 Drew Forrester states in response to comments on his blog that the

only qualification that Ms Royle has to be in Baltimore Magazine is that she

works here He also says he likes the way she smells and questions why she

makes herself smell good around athletes

Al Says

January 26th 2011 at 848 amHow embarrassed should Baltimore Magazine be for promoting certain

sports personality as one of Baltimores most eligible singles Shouldnt

the criteria be that Baltimore singles should actually be from Baltimore or an

active member of the Baltimore communitySecond question When said Baltimore single commented how all her

friends and back tracked to include all from out of state agreed how

horrible her magazine picture is shouldnt Baltimore Magazine offer up the

community retraction of their mistake to add her

Perhaps they shouldve waited until the spring travel issue to highlight all of

the tourist sites in and around town

9No longer available on Twitter

to be verified on computer with sound Video clip no printout

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DF This is question better suited for Baltimore Magazine and their

selection committee My guess is as long as you WORK in Baltimore

youre eligible havent seen the other sexy singles so dont know how

our girl got in but too bad the magazine didnt have scratch and sniff

sticker. .if you know what mean Thats her best attribute by far

Kristen Says

January 26th 2011 at 1149 am

Drew Have you ever actually met and talked with Jen Royal or do you

disrespect her on the air because shes female and according to you

always smells really nice which is your way of saying she doesnt know

sports but because she smells nice she has job She probably doesnt give

you the time of day and thats why you dont like her DF Youre funny

but Ill humor you more Ive talked to Jen Royle on several occasions Each

time shes been condescending snarky unfriendly and snobby think she

knows sports Ive NEVER once said she didnt know sports What Ive said

is that she doesnt know BALTIMORE And because of that she has no

historical perspective at all on the Orioles and Ravens My remarks about

how great she smells .those are COMPLIMENTS She always smells great

Youd have to ask her why she insists on smelling that great around bunch

of athletes Thats not for me to decide But she always smells like winner

admit thatDrew Forrester Drew Forresters Blog Back in the saddle again 21 Questions

Returns Update Were going to OVERRRRR-TIME available at

http//wnst.networdpress/drewforrester/20 11/01 /26/back-in-the-saddle-again-2 1-

questions-returns

1/28/2011- Drew Forrester states in his blog that Baltimores own Jen Royleshowed up to photo shoot with Nick Swisher outfit

By now Im sure nearly all of you have picked up the latest copy of

Baltimore Magazine which features Baltimoresown Jen Royle of MASNas one of our citys Sexy Singles Evidently Jens photo shoot didnt go so

well When she arrived at the location the magazine staffer handed her an

outfit and asked her to get dressed Royle replied But brought something

that think depicts my style little better Fortunately the editor wouldnt

allow Jen to wear THE CLOTHES SHE BROUGHT TO THE PHOTO

SHOOT

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Drew Forrester Drew Forresters Blog Just in the nick of time its Friday Mud

available at http //wnst.net/wordpress/drewforrester/20 11/01/28/just-in-the-nick-

of-time-its-friday-mud link provided shows Nick Swish outfit below and is

available at http//product.images.fansedge.com32-3 0/32-303 54-F.jpg

In the comments to the blog someone responds on January 29t1 to insults about

Jen Royle and Drew Forrester responds that she could handle it

malt Says


do think thejen royle stuff is funny along with everything else but also

agree you definitely have the kindergarten pig tail pull thing going on

towards her totally crushing on her for good reason looks not personality

pull brett favre on her thats my advice but do it from pre paid phone

DF Whatever. .shes from Boston. .she can handle little chiding Theres

no reason for me to have crush on anyone Im married And trust me once

you actually meet her the crush-thing ends Shes boorish snobby and

caustic Other that that shes real peachDrew Forrester Drew Forresters Blog Just in the nick of time its Friday Mud

available at http//wnst.net/wordpress/drewforrester/20 11/01/28/just-in-the-nick-

of-time-its-friday-mud/

2/04/2011 Glenn Forrester blogs that Ms Royle needs nickname suggesting

Jenny-Poo and eventually settling on link to picture of the New Yorker

Our pal Jen Royle is prepping for season of outstanding baseball

coverage at MASN and now that shes embarking on her second year in

Baltimore figured its time to give her nickname considered all of the

natural ones like Jenny-poo Jen-Jen or Roysie However none of

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those were as appropriate as THIS NICKNAME for her Hey. .if the shoe

fits right

Drew Forrester Drew Forresters Blog The Great Friday Mud is the preferred

nomenclature available at http//wnst.net/wordpress/drewforrester/20 11/02/04/the-

great-friday-mud-is-the-preferred-nomenclature link to

http //www.macgasm.net/wp-content/uploads/20 0/09/new-yorker-ipad .jpg

picture of an iPad with the New Yorker displayed on it

2/22/2011 Nestor comments that the only reason Ms Royle has been employed

is because she has pretty face and breasts that she is not qualified to discuss the

Orioles or any other team because Ms Royle is woman.1

3/30/2011 Nestor blogs

You can search anywhere on the internet you like and you will not find

shred of evidence that weve ever said or done anything more than tell the

truth about her journalism skills and her outlandish behavior in social media

and in Owings Mills We literally have hundreds and hundreds of public

pronouncements made by Miss Royle via social media that quite frankly

would make any WNST.net employee an ex employee And yes do the

hiring and firing here at WNSTMiss Royles feelings have been hurt by thousands of people in Baltimore

and she is quite fighter based on what we read from her public work Her

blog reiterates that on daily basis as she calls fans jerks Baltimorons

and the like You can check it out for yourself Its quite public just like this

blog

Apparently shes only decided to sue us here at WNST.net

Perhaps its because were direct competitor perhaps its because she feels

like shell get her name in the local newspaper and shell eventually extract

some money out of us Win or lose the attorney fees and my time spent

dealing with this nonsense will certainly be draining my piggy bank so Imloser beginning today no matter the outcome of this frivolous case

But to spread vicious rumors about her Not me Not this staff Not EVER at

WNST.net

You wouldnt have wanted to hear my reaction to anyone in my professional

world who gave me advice to settle lawsuit that didnt have any merit

and somehow admit guilt where there is none

Text message from stranger

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Ive been doing this for 27 years as professional locally nationally and

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

But were also not strangers to pointing out that our product is the best in the

marketplace every day and telling you why and proving it every day with

our passion industriousness and accountability If we dont tell you how

good we are we certainly dont expect our competition to do it

And when our competitors bring inferior out-of-town talent into the

marketplace were going to point it out

Especially when any media member would be so brazen about loving the

Yankees and Red Sox and so openly disrespectftil to the community theyre

serving the community that is literally feeding them

I. .1

No one at WNST.net has ever written or said what these allegations suggest

Not even close

We said Jennifer Royle doesnt know as much about Baltimore sports as we

do

We said shes lacking information and professionalism which ifyouve

followed her on Twitter youd see why weve come to that conclusion

Shes public figure She has fan page on Facebook She chooses to go on

the radio and serve up her opinions about our sports culture And she

chooses to fight with Baltimoreans and local sports fans seemingly every

single 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 herself by suing the best sports media

company in Baltimore for pointing out what weve known since the day she

arrived Shes not Baltimore sports expert and now she has her feelings

hurt and is trying to injure WNST its partners employees agents and fans

by trying to take money from my companyNestor Aparicio Nestor Aparicios Blog An indictment of local journalism

Heres our side of baseless Royle WNST lawsuit available at

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 Royle was informed that the cx

Mayor of Baltimore died she responded who insinuating she didnt know who

he was because shes not from Baltimore

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@WNST Drew Somewhere tonight local sports reporter was told

William Donald Schaefer passed away and the response was whoCopied from Twitter by Jen Royle.2

5/4/2011 Personal tweet from Drew Forrester to Jen Royle

From @GlennClarkwNST

@CL_ @BaltimoreLuke Im 100% certain Ill regret this But in the

meantime maybe well have enough fun Ill get sued again

Copied from twitter by Jen Royle

6/4/2011 Glenn blogs in honor of Jen Royle not being what he considers

Baltimore Sports Expert

In honor of the fact that the reporter from the FM sports station in town had

trouble finding Towson University yesterday we thought wed put together

bucket list for our Tuesday Top which came on Wednesday this week

Todays Tuesday Top topic was The Top Things You Need To Do To

Consider Yourself Baltimore Sports Expert As always hope its self

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/

6/10/2011 Drew Forrester blogs insulting Boston and insinuating that Jen Royle

is unintelligent

Speaking of Boston Im quite pained by the fact that the Canucks have

allowed the Bruins back in the series having won Game and of the

Stanley Cup Finals to even it up at 2-games apiece know .trust meknow Anytime someone or something from Boston experiences even

morsel of success its disheartening They dont deserve anything goodThe only acceptable things to come out of that hell-hole are The Cars Matt

Damon The Country Club of Brookline where Curtis Strange won one of

his two U.S Opens and Steve Carell Everyone and everything

else. .sucks Well OK need to take that back apologize THIS PARTof Bostons heritage didnt suck For the record voted 981 times

12No longer available on twitter In correspondence folder

No longer available on twitter

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Im sure youve heard by now that Mark Viviano is leaving his post at 105.7

and will now concentrate solely on his duties as the sports anchor at Channel

13 On side note Ill mention that Mark is solid citizen and good

guy. .and hope he enjoys his new less stressftil life Anyway Vivianos

departure means The Fan is looking for new sports talk host As is

always the case Im hearing rumors and theyre just that rumors about

his replacement As has become their custom 105.7 execs are looking for

someone out-of-state to come in and wow everyone with their sports

knowledge Rumor has it theyve centered their search on native of South

Carolina and that THIS GIRL RIGHT HERE passed her interview with

flying colors and is the lead candidate to take over Vivs talk show gigDrew Forrester Drew Forresters Blog Hit records are short. .but this edition of

Friday Mud sure isnt available at

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 Red Sox blowing the

1986 World Series available at

http //www.youtube .comlwatchvghQ VU12T 8Efeaturerelated second link

to video of girl giving bad answer in Miss Teen USA available at

http//www.youtube.comlwatchv1j3 iNxZ8Dww

Comment on Drew Forresters blog states that Jen Royle references are commonMike from Carney SaysJune 10th 2011 at 921 am

Finding the Royle references in The Mud is like finding the toy in the cereal

box Love it DF Huh To borrow line from Bull Durham. .dont

think Meat just pitch think youre thinking too much But have fun

with itDrew Forrester Drew Foresters Blog Hit records are short .but this edition of


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 Greg Bader to complain that Glenn

Forrester told reporters he had reliable source from the Warehouse who told him

that Ms Royle had relationship with player

Hi Greg

Sorry to BOTHER you with this.. But Drew Forester told some reporters

was sleeping with Matusz and is now saying it came from reliable source

in the warehouse guarantee Drew is going to throw that source under the

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bus in court to make himself look innocent Any idea who this warehouse

source is and can you please confirm you did your part in putting this

ridiculous rumor to rest

Again Tm very very sorry for the drama and you know love you to pieces

but its very disheartening and disturbing if these kind of false accusations

come directly from the organization especially when was an employee of

MA SN

Thank you

Jen

Email from Jen Royle

Mr Bader replies that he does not believe there was real source

would love to know who this supposed source is doubt he has one

No one know would have spread such rumor spoke with Monica about

it and she doesnt know where it came from And was clear to her after

Brian and spoke in spring training that wouldnt tolerate any rumor

mongering and specifically mentioned this item She agreed and have no

doubt is doing whatever she can to curtail the spread of false rumors As am

have heard no such rumors about you or any other media members this

season

Email from Greg Bader

Exact Dates Unknown

On or about July 2010 Drew Forrester allegedly tells

Jerry Coleman from Fox at the Mt Washington Tavern that

know shes hooking up with Matusz right Jen

Royle mentioned this in an email.14 Drew Forrester also

allegedly told Jerry Coleman that he had reliable source

in the Warehouse that can confirm Warehouse Orioles

offices

Drew Forrester tweets at the beginning of the 2010 Ravens

season RT @wnst Drew Good news for you guys in

14 Comment not available in recorded source online

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BALT You can follow our tweets live from the stadium or

Jen Royles tweets live from her couch Appears to be

sent around 9/27/11 Copied from twitter by Jen Royle15

On or about September 2010 Glenn Clark comments on

blog that he does not understand why Jen Royle wearshort skirts and boots to games knowing she wont be on TV

and that its pretty cold outside

On or around August 2010 during Ravens training campin Westminster MD was crying on the Ravens field

when heard they had segment called Jen Midol on the

morning show Drew and Glenn -- That afternoon Nestor

came up to me and introduced himself and reached out to

shake my hand declined to shake his hand

said your radio station has nothing good to say about me

and dont appreciate it because you dont even know me

He said have never said word about you cant control

what other people say

said well Im telling you now and youre the owner so

youre responsible

And he walked away

That afternoon he went on the air and told everyone was

the biggest bitch he has ever met Email from MsRoyle.16

No longer available on twitter

The Defendants Ms Royle have knowledge about this occurrence

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EXHIBIT

June 27 2011 Letter to Plaintiffs

Counsel re 2-432

Holland Knight



CHARLES TOWN202 419-2539

[email protected]

June 272011


Brian Goodman Esq




bgoodmanhpklegal.com

Re Jennjfer Royle NASTY 1570 Sports LLC et aL

Maryland Circuit Court for Baltimore City Case No 24C1l00157l

Dear Mr Goodman

We send this letter pursuant to Rule 2-431 as further good-faith effort to resolve your

client Jennifer Royles non-compliance with her discovery obligations under Rules 2-421 and 2-

422

As you know Ms Royle initially responded on June 2011 to our clients written

discovery requests We wrote to you on June with detailed explanation of our concerns with

that response Following our letter on June 15 you and spoke briefly by telephone and you

suggested and agreed that we table further discussion until after we had exchanged

documents You assured us that Ms Royles supplementation and documents would address

most of our concerns On June 17 you furnished Ms Royles supplement to certain

interrogatory responses and you provided us with documents

We have carefully reviewed the information you have provided Unfortunately MsRoyles supplementation and production did not address the majority of the deficiencies we noted

in our June letter In fact the materials provided to us on June 17 raise new set of concerns

as they indicate she possesses number of documents that still have not been provided and they

appear largely designed to expand the scope of her claims Moreover she has completely

refused to provide copies of her Twitter and Facebook accounts despite their obvious relevancy

to her Complaint

This letter supersedes our June letter and specifies the numerous deficiencies in the

responses you have provided to date Ms Royles continued failure to meaningfully meet her

discovery obligations is impeding the timely course of this litigation We therefore request that

Ms Royle provide all of the information requested in this letter by July 2011 to avoid the

need to inconvenience the Court with Motion to Compel


June27 2011

Page

Plaintiffs Responses to WNSTs Interrogatories

The supplemental answers to interrogatories submitted with the June 17 production failed

to address nearly all of the issues we have previously raised Your clients responses to the

interrogatories therefore remain evasive and incomplete under Rule 2-432 as detailed below

Various references to unnamed individuals Various individuals alluded to in MsRoyles responses and who therefore are material witnesses to her Complaint remain

unidentified Furthermore Ms Royle has failed to provide the contact information for any of

these individuals as required by the interrogatories These references include

Interrogatory NoThe unidentified current and former colleagues of Defendants

referenced in the response to Interrogatory NoThe unidentified other members of the local media referenced in the

response to Interrogatory No

Interrogatory NoThe unidentified individuals within the Baltimore Ravens organization to

whom Ms Royle prepared correspondence on or about August 14

2010 as described in Ms Royles answer to Interrogatory NoThe unidentified colleagues and management at MASN and CBS with

whom Ms Royle exchanged emails as well as telephone

conversations beginning on approximately January 13 2011 regarding

Defendants conduct as described in her answer to Interrogatory No

Interrogatory No 10

The unidentified individuals who have called into question Ms Royles

professional and personal reputation as described in her answer to

Interrogatory No 10

The unidentified members of the public who believe that Defendants

actions have caused them to believe that Ms Royle is bitch liar and

has had sexual relationships with Nick Swisher and/or Brian Matusz as

described in her answer to Interrogatory No 10

The unidentified professional athletes Royle covers with whomMs Royles credibility has been ndangered as described in her

answer to Interrogatory No 10

The unidentified others who Ms Royle contends that she has been

forced to explain herself to as described in her answer to Interrogatory

No 10


June 27 2011

Page

Exhibit

Mr Royle fails to identify the Ravens PR staff with whom she alleges

Jon Gallo spoke with about Defendants comments PRDR000007-

000008

The unidentified individual who informed Ms Royle that Nestor

Aparicio made comments about her on the air on 2/22/2010 MsRoyles identification of this individual as stranger is inadequate

footnote 11 PRDR0000I

The unidentified some reporters Ms Royle alleges that Drew Forrester

spoke to about Ms Royles relationship with Brian Matusz Ms Royle

also failed to fully identify Monica in the same e-mail exchange

PRDROO 002 1-000022

The unidentified person who informed Ms Royle she had been referred to

as Jen Midol on The Morning Reaction PRDR000023

Interrogatory No Similarly Ms Royle ignored our request to supplement her

response to this standard interrogatory asking her to identify individuals who may have

information relating to her Complaint She lists five non-parties by name but refuses to state the

substance of their testimony knowledge or information as the interrogatory required Further

Ms Royles response alludes to current and former colleagues of Defendants and other

members of the local media but does not identify those individuals by name nor does she

disclose the substance of their testimony knowledge or information Moreover in the June 17

production Ms Royle quotes portions of her e-mail exchange with Greg Bader PRDR000021-

000022 but fails to provide any information about him as required by Interrogatory

Interrogatory No It is entirely unclear whether the Exhibit referred to in this

response and provided to us on June 17 supersedes or supplements the previous Exhibit

provided on June These documents contain some overlap but are entirely different Further

several statements in each document remain in paraphrased form and do not provide sufficient

notice to the Defendants or the Court of the allegedly false and defamatory words The

statements which remain vague paraphrased or fail to state witness with personal knowledge

include but are not limited to

Ms Royle alleges that Glenn Clark just ripped her on the air on 8/5/2010 but

fails to specify the exact words which were allegedly said about her

PRDR000006Statements Ms Royle alleges Mr Clark made to Damon Yaffee during Ravens

practice regarding her credentials quotes some of the allegedly defamatory

statements but paraphrases the rest Ms Royle identifies her source as letter to

persons within the Ravens organization but failed to produce the letter

PRDR000007Ms Royle fails to identify witness with personal knowledge to exchanges

alleged between Ms Royle Mr Clark and Mr Forrester on 9/12/2010 In


June27 2011

Page

addition Mr Royle fails to identify the Ravens PR staff with whom she alleges

Jon Gallo spoke with about Defendants conduct PRDR000007-000008

Ms Royle quotes statements allegedly made by CJ Spiller on his blog on

9/20/2010 but fails to produce the blog and instead states Blog no longer

available on website PRDR000008Dave Hughes allegedly answered question in his mailbag regarding whether

conflict of interest would arise if Ms Royle dated player on the team she covers

for MASN on 1/20/2011 PRDR0000I Ms Royle not only appears to want our

clients to defend statement that they did not make and appeared on someone

elses forum but she has not even specifically told us precisely what that

statement was

The substance of what Ms Royle alleges Mr Forrester told some reporters on

or about 6/11/2011 is not even paraphrased PRDR00002I-000022

Comments allegedly made by Mr Clark on his blog on or about September

2010 which Ms Royle quotes but fails to provide source PRDR000023On or around August 2010 Ms Royle alleges she heard Defendants

broadcast segment called Jen Midol on The Morning Reaction Ms Royle

fails to identify the source who told her about the segment nor does she provide

any supporting documentation regarding the Jen Midol segment Ms Royle also

fails to state witness with personal knowledge as to her alleged exchange with

Mr Aparicio later that day regarding the Jen Midol segment Moreover MsRoyle fails to provide any substantiation for the statements allegedly made by Mr

Aparicio on the air that Ms Royle was the biggest bitch he has ever met

PRDR000023

Interrogatory No Ms Royle ignored the request in our June letter that she resolve

the deficiencies with this response Thus Ms Royles response continues to incorporate her

response to the preceding interrogatory which asks an entirely different question Ms Royles

response fails to explain why she believes iiof the statements in her Exhibit no matter

which version were false when it was made as Interrogatory No requests In addition MsRoyle failed to update her response to Interrogatory No after adding more than 14 additional

statements in her revised Exhibit Ms Royle still only generally states that she has never lied

on her resume and has never purported to have credentials she does not have Moreover MsRoyles response still states that she has never been romantically involved with Nick Swisher or

Brian Matusz but her Complaint generally alleges statements that she has had personal sexual

and/or inappropriate relationships with professional athletes Complaint 27 Therefore MsRoyle must respond to the interrogatory as to all professional athletes as we asked and as her

Complaint alleges and not limit her response to Mr Swisher and Mr .Matusz


the deficiencies with this response Ms Royle still generically refers to conversations

correspondence and telephone conversations with unnamed individuals and in addition to

failing to provide their names and contact information fails to state the date of the

communications or the substance of the communications as the interrogatory requests Ms

Mr Brian Qoodman Esq

June27 2011

Page

Royle continues to refuse to provide this information even after directly quoting correspondence

with several individuals in her revised Exhibit including John Bader PRDR000021-000022

and Chad Steele Patrick Gleason and Kevin Bryne PRDR 000007


the deficiencies with this response Ms Royles response incorporates her response to

Interrogatory No which provides none of the information sought in Interrogatory No

regarding Ms Royles complete factual basis for her assertion that the Defendants knew

statements were false subjectively entertained doubts as to the truth or falsity of statements or

published them with high degree of awareness as to their probable falsity


the deficiencies with this response Ms Royles response directs us to her response to

Interrogatory No which provides none of the information sought in Interrogatory No

regarding the complete factual basis for Ms Royles allegation that Defendants acted with

common law malice ill will or spite

Interrogatory No 11 While Ms Royle provides medical records from Dr Goldiner and

Dr Paolino she has provided no records from Dr Liebman whom she identified as receiving

continuing provider in Interrogatory Nos 11 and 15

Interrogatory No 12 Ms Royles amended answer to Interrogatory No 12 continues to

be non-responsive and inappropriately vague referring Defendants to unidentified documents in

lieu of answering the interrogatory regarding whether Ms Royle has any damages other than

those identified in the other referenced interrogatory responses Specifically Ms Royles

response violates Rule 2-421c because it fails to specify the records from which the answer

may be derived or ascertained

Interrogatory No 15 Ms Royle ignored the request in our June letter that she resolve

the deficiencies with this response Ms Royle responds with the names of two doctors and lists

no other medical professionals with whom she has ever visited concerning her mental and/or

emotional health in her lifetime as the interrogatory required Ms Royles pre-existing mental

health condition is clearly relevant to the allegations of her Complaint

Interrogatory No 16 Ms Royle ignored the request in our June letter that she resolve

the deficiencies with this response Ms Royle objects to this interrogatory which requests

correspondence with members of the public about her work in Baltimore without stating

whether any documents or communications exist that are responsive to the question Obviously

Ms Royles reputation is clearly relevant to the allegations of her Complaint and the

interrogatory requests information on that issue

Interrogatory No 19 Ms Royle ignored most of the request in our June letter that she

resolve the deficiencies with this response Ms Royles response fails to provide any

Mr Brian Goodman EsqJune 27 2011

Page

infonnation about her reason for leaving each place of employment as the interrogatory

required

Interrogatory Nos 21 and 22 Ms Royle ignored the request in our June letter that she

resolve the deficiencies with this response Beyond her boilerplate objections Ms Royle

provided no information citing relevancy grounds Ms Royles Complaint at 27 alleges that

the Defendants made false statements that she had personal sexual and/or inappropriate

relationships with professional athletes Defendants therefore are entitled to the information

requested in Interrogatory No 21 about any former or current professional athlete with which

Ms Royle has ever had personal sexual and/or inappropriate relationship as well as the

information requested in Interrogatory No 22 for information about any intimate romantic or

sexual relations of any nature she has ever had with any former or current professional athlete

This information is directly relevant to the allegations of her Complaint

Plaintiffs Responses to WNSTs Document Requests

Ms Royles written responses continue to be evasive and incomplete under Rule 2-432

and her production of documents remains wholly inadequate due to the following deficiencies

Continued Failure to Provide Privilege Log As we have noted and as you and

discussed during our June 15 call Ms Royle objects to providing certain documents on the basis

of privilege without concurrently submitting privilege log as required under Maryland law

Without privilege log Defendants and the Court are unable to determine what specific

documents are being withheld and whether or not Ms Royles objections are appropriate

Moreover during our June 15 telephone conference you agreed to furnish privilege log for

these documents You did not do so in the June 17 production

Document Reqpest No In Ms Royles revised Exhibit furnished with the June 17

production she directly quotes statements either allegedly made by the Defendants or referring

to the Defendants Ms Royle has not produced single document evidencing these statements

Further for number of the entries listed in the revised Exhibit Ms Royle refers to

document from which she has quoted but does not provide the documents themselves even

though clearly they are in her possession For example statements quoted for which no

supporting documentation has been provided include but are not limited to

All references to Tweets throughout PRDR000001-000023

Blog postings no longer available online footnote PRDR000008Tweets no longer available on Twitter footnote PRDR000008 footnote

PRDR0000 10 footnote 6-8 PRDR0000 13 footnote PRDR0000I footnote 12-13

PRDR00002O and footnote 15 PRDR000023Letters PRDR000007E-mails PRDR000021-000023Text messages footnote 11 PRDR00001


June27 2011

Page7

personal tweet from Mr Forrester that Ms Royle quotes but fails to substantiate

with documentation stating only that it is No longer available on twitter footnote 13

PRDR000020

three-page document seems to list series of Tweets between Ms Royle and the

Defendants but Ms Royle has failed to produce of her Tweets PRDR000099-

000101 Ms Royle also refers to emails and other communications in this document

but fails to provide them as well

Document Request No Ms Royle ignored the request in our June letter that she

resolve the deficiencies with this response She has provided no documents between her and

any of the Defendants and as we already noted contrary to her objection all such

communications are not within the Defendants possession custody and control As to any

communications she sent via Twitter they are no longer accessible by the public on the Internet

Ms Royle however controls her Twitter account and can easily obtain complete file of her

Twitter communications including those that she directed at our clients account @WNSTGiven the relevancy of these communications to her Complaint Ms Royle is obligated to

retrieve the Twitter communications and provide copy to us

Document Request No Ms Royle ignored the request in our June letter that she

resolve the deficiencies with this response Contrary to her objection communications between

Ms Royle and third parties about her lawsuit are not within the Defendants possession custody

or control Further the request is not overly burdensome To the contrary it is confined to the

time period relevant to this litigation Ms Royle makes at least two references to text messages

and c-mails which she failed to produce in an unidentified three-page document she produced

on June 17 PRDR000099-000101 Moreover in Ms Royles revised Exhibit she quotes

written communications between her and third parties regarding Defendants but nevertheless

fails to produce them including but not limited to

Letters PRDR000007B-mails PRDR00002I-000023 PRDR000099Text messages footnote 11 PRDR0000 18 PRDR000099

Document Request Nos 21 22 23 and 26 Ms Royles document production

fails to adequately respond to these requests as Ms Royle has yet to produce all documents

supporting her allegations that these statements were in fact made The Plaintiff is required to

provide the Defendants and the Court in litigation of this nature with the precise words that are

allegedly false and defamatory Ms Royle fails to meet her obligations in discovery by

We have even furnished you in our Document Request No with the simple directions Ms Royle needs to

follow to retrieve her Twitter account history You may obtain this information by sending written request to

Twitter by fax to 415-222-9958 signed by you together with copy of valid government-issued identification

card Twitter will then send you confirmation to the email address they have for you on file which will authorize

Twitter to release to you the requested information Our clients followed these instructions to respond to your

clients document request


Page

continuing to rely on characterizations of statements in Exhibit rather than providing the

statements themselves for statements including but not limited to

Statements allegedly made on 8/5/2010 by Mr Clark which Ms Royle claims are on

Defendants website PRDR000006-000007 We are unable to find the statements

she references We therefore request that you locate and provide us with copy

Statements allegedly made by CJ Spiller on 9/20/2010 which Ms Royle claims are on

Defendants website PRDR000008 We are unable to find the statements she

references We therefore request that you locate and provide us with copy

The text message that alerted Ms Royle to statements Mr Aparicio made about her

on 2/22/2011 PRDR0000I8

personal tweet from Mr Forrester to Ms Royle on 5/4/2011 PRDR00002O Weare unable to find the statement she references We therefore request that you locate

and provide us with copy

Document Request Nos and 34 Ms Royle ignored the request in our June letter

that she resolve the deficiencies with this response Rather than producing Ms Royles own

Tweets she instead provides Tweets sent by others PRDR0001O2-000224 Not only are these

Tweets entirely non-responsive to the requests but they are restricted to the last few weeks of

June 2011 and not the timeframe referenced in your clients Complaint Ms Royle therefore has

flatly reftised to produce any documents relevant to her activities on Twitter Ms Royles

statement in her response to Request No that she uses Twitter daily pursuant to her

professional duties does not relieve her of her obligations in discovery to provide her account

history

Document Request Nos through 14 Ms Royle ignored the request in our June letter

that she resolve the deficiencies with this response Ms Royle still broadly objects on the basis

of the Maryland Shield Law but falls to assert whether such documents exist and if they do MsRoyle falls to submit privilege log consistent with the instructions and Maryland law Without

such Defendants and the court are unable to evaluate the sufficiency of any asserted privilege

Moreover Ms Royles answer to Interrogatory No states that she prepared correspondence to

the Baltimore Ravens organization that relates solely to an incident raised by her lawsuit which

clearly would not fall within the protections of the Maryland Shield Law

Document Request No 32 Ms Royle ignored the request in our June letter that she

resolve the deficiencies with this response Contrary to her assertion all communications

between her and members of the public are not within the Defendants possession custody and

control Obviously Ms Royles reputation is clearly relevant to the allegations of her

Complaint and the request seeks documents related to that issue

Document Request No 33 Ms Royle ignored the request in our June letter that she

resolve the deficiencies with this response She has failed to produce the requested information

from her Facebook page despite your assurance during our June 15 2011 telephone conference

that you would produce information from her professional Facebook accounts Like Twitter


Page

Facebook provides an easy cost-free and non-burdensome method to access all information on

Ms Royles account including to status updates email messages photos listing of friends etc.2

We must have Ms Royles complete supplemental responses to the interrogatories and

all documents and other information we have requested by no later than July 2011 to avoid

our having to inconvenience the judge with motion practice

am happy to discuss this with you by telephone and will email you some suggested

times for call But we need to adhere to the July timeframe in order to move this matter

forward

Very truly yours

HOLLAND KNIGHT LLP

Charles Tobin


CDThje

When logged onto her Facebook account Ms Royle should select the Account tab followed by the Account

Settings tab followed by selecting Download your Information Ms Royle may then hit the Download buttonand her entire account will compiled by Facebook and emailed to the email address Facebook has on record

EXHIBIT

June 27 2011 Letter to Plaintiffs

Counselre 1-341

Holland Knight


Holland Knight LIP www.hklaw.oom

CHARLES TOBIN

202 419-2539

[email protected]

June 27 2011


Brian Goodman Esq




bgoodmanhpk1ega1.com

Re Jennter Royle NASTY 1570 Sports LLC et

Maryland Circuit Court for Baltimore City Case No 24C 11001571

Dear Mr Goodman

We send this letter pursuant to Rule 1-341 which prohibits litigants from maintaining

proceeding in bad faith or without substantial justification and provides for the Court to award

the reasonable expenses including reasonable attorneys fees incurred by the adverse party

This letter follows our telephone conversation of June 15 2011 in which asked you to narrow

your clients claims to prevent the proliferation of this litigation through allegations about

statements that do not fit within the torts that remain in the Complaint

As you are aware the Court at the June 2011 hearing dismissed your clients cause of

action for intentional infliction of emotional distress Count IV With your concession that the

Plaintiff also inappropriately included the count in her Complaint the Court dismissed her claim

for invasion of privacy by publication of private facts Count II as well The dismissal of these

claims leaves two specific causes of action remaining in this lawsuit defamation and false light

invasion of privacy Counts and III

As you thrther rare aware the defamation and false light torts each requires that the

Plaintiff plead and prove among other elements false statement of fact Alleged statements

that are not fact and that are not capable of being proved true are false are not actionable

under these torts

raised this issue with you in our June 15 telephone conversation where we discussed

your clients initial deficient discovery responses Your clients Complaint as best we can tell

includes 12 allegedly actionable statements Since the Court dismissed all claims but defamation

and false light the number of allegedly actionable statements should have decreased following

the June hearing Nevertheless in the initial discovery responses you served your client

increased the number of allegedly actionable statements and listed total of 29 statements


June 27 2011

Page

During our telephone conversation on June 15 asked you to reconsider the statements and

narrow Ms Royles Complaint to only those statements that arguably would fit within

defamation or false light causes of action You advised that the Plaintiff would do this

Following that discussion on June 17 you served supplemental interrogatory responses

and produced documents to us Included in those documents is an entirely new list contained in

PRDR000001-23 and PRDR000099-lOl which as we understand it supersedes the previous list

of allegedly actionable statements that you provided on June At this juncture Ms Royles

claim now includes at least 50 separate allegedly actionable statements To name just two

examples Ms Royle lists phrases such as those referring to her as apologist of the morning

see e.g PRDR000002 and others analogizher to character on the Jersey Shore because

she is disaster PRDR000005 Neither of these statements even arguably contains an

assertion of fact or is capable of being proved true or false These are among dozens of

statements that simply are not actionable as defamation or false light invasion of privacy

Ms Royle and you appear determined to make her allegations as broad as possible to

squander our resources and the Courts in derogation to the obligations under the Rules Webelieve these extraneous allegations have been made vexatiously solely

for purposes of

harassment or unreasonable delay in an effort to drive up costs and cause otherwise unnecessary

proceedings We therefore insist that by July 2011 you withdraw the list of allegedly

actionable statements provided in discovery and that you instead provide us with discrete

narrow list of those statements you contend are actionable as defamation or false light

portrayal so that we may efficiently proceed with discovery under an appropriately defined

claim

We send this letter in an effort to resolve this dispute prior to the filing of motion under

Rule 1-341 and other applicable rules This letter in no way waives your clients discovery

obligations or our clients rights and remedies

Very truly yours

HOLLAND KNIGHT LLP

Charles Tobin


CDThje

EXHIBIT

Plaintiffs Supplemental Responses to

WNSTs Interrogatories and




FOR

NASTY 1570 SPORTS LLC et cii BALTIMORE CITY

Defendants CASE NO 24-c-uooi57l

PLAINTIFF TENNIFER ROYLES SECOND SUPPLEMENTAL ANSWERS ANDRESPONSES TO WNST SPORTS MEDIA LLCS FIRST SET OF

INTERROGATORIES

INTERROGATORY NO.2 State the identity address and telephone

number of each person who you believe has knowledge or information relating to your

Complaint together with the substance of their testimony knowledge or information




Rules of Civil Procedure 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 with personal knowledge of the 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 that the Defendants Aparicio Forrester and Clark may have personal

knowledge Plaintiff also presumes that current and former colleagues of the

Defendants the Plaintiff and other members of the local media may have personal

knowledge including but not limited to Jerry Coleman Casey Willett Damon Yaffe

John Gallo and Ray Buchman As discovery is ongoing Plaintiff reserves the right to

supplement and/or amend her response to this Interrogatory

SUPPLEMENTAL ANSWER NO.2 Without waiving and subject to the

Plaintiffs original objections to the extent the information sought including the contact

information for each person is in the Plaintiffs immediate custody possession or

control it has been provided see Exhibit Plaintiffs Original and 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 Identify each and every statement of fact made

by any of the Defendants that you allege is false as alleged in Complaint fl19-25

including all subparts and fl27 37 48-50 quoting verbatim each 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

i.e in person radio Twitter website etc and if the statement is found on website or

blog state the exact web address containing the statement Your answer to this

interrogatory should identify all statements on which you base the Complaint

including but not limited to


that you are not qualified or competent for position as journalist and

incapable of doing job Complaint 20 21a 21b 21c21 24


that you are involved in personal sexual and/or inappropriate relationships

with multiple professional athletes and/or that you halve personal sexual

and/or inappropriate relationship with professional athlete Complaint 2021 21 21 21


that you lied on resume and did not have the credentials or experience

that purport to have with regard to profession as journalist

Complaint 21cAll statements that you contend state implicate or otherwise insinuate

that you were trashy look like stripper bitch and/or an idiot

Complaint 21 24cAll statements that you contend threatened violence against you see e.g

Complaint 24dAll statements that you contend your professional work in

demeaning and uncivilized way Complaint 24bAll statements that you contend are sexually inappropriate statements

about you Complaint 24e




Rules of Civil Procedure 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

SUPPLEMENTAL ANSWER NO.3 Plaintiff incorporates her original

objections Plaintiff 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 8/5/ 2010 Casey Willett CBS employee informed Ms Royle during Ravens

training camp in Westminster MV that Defendant Glenn Clark had insulted her on the

radio earlier that morning that Defendant Clark specifically used new nickname for

her Jen Midol that Defendant Clark said Ms Royle did not know what blitz was

insinuating she was incompetent and that Defendant Clark said she knew who Nick

Swisher of the Yankees was insinuating an inappropriate/sexual relationship between

Plaintiff and Swisher Members of the Ravens Public Relations/Media Staff Chad Steele

and Patrick Gleason and Mike Preston from the Baltimore Sun have knowledge of the

incident Casey Willet heard the Defendants statements on WNST 1570 AM

On 9/7/2010 Damon Yaffee media member and CBS employee informed Ms

Royle that Glenn Clark told him that Plaintiff had lied on my resume and do not have

the credentials/ experience that appears on my resume and do not deserve to be

covering the Ravens Damon Yaffee further informed Ms Royle that Defendant Clark

had said it was brutal listening to her and inquired why CBS didnt have anyone better

to cover the Ravens Damon Yaffee and Defendant Clark have information regarding

the statements

On 9/12/2010 WNSTs website published blog wherein CJ Spiller stated that

Plaintiff was demoted from her job See Supplemental Exhibit WNST has since

removed the blog from its website or else it is not discoverable through general search

patterns Plaintiff has made substantial efforts to produce copy of the said blog but it

is no longer available on the Defendants website

On or about 7/1/2010 Defendant Forrester told Jerry Coleman Dude you

know she is hooking up with Matusz right at the Mt Washington Tavern copy

of the oral statement is not in the Plaintiffs possession custody or control Jerry

Coleman and Defendant Forrester have personal knowledge of the statement

On 9/12/2010 Defendant Clark tweeted And to think @JenRoyleMASN hasnt

even heard me say that what shes wearing tonight would be considered trashy at the

Gold Club and Defendant Forrester followed with the tweet dont know if Glenn is

D-Bag but do know this. those boots @JenRoyleMASN is wearing are worth more

than Glenn Clarks car truth Later that day Jen Royle Drew Forrester and Glen

Clark were witnesses to series of statements made in conversation between them

The statements began when Ms Royle approached Mr Clark and stated that tweet

made earlier that day by Mr Clark was crossing the line and extremely

unprofessional Concurrently with these statements Mr Forrester walked by and yelled

where are your boots Ms Royle asked Mr Clark if he could step outside to talk Mr

Clark said no This is not the right place Mr Forrester then said go home and put

your boots on first then come inside and let me buy you drink

In blog that is no longer available on WNSTs website that was originally

posted on or about 9/1/2010 Glenn Clark asked why does Jen Role wear 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

INTERROGATORY NO.4 For each statement identified your answer to

Interrogatory No explain the reason that you claim it was false when made identify

each and every fact on which you base your contention identify all persons known to

you who have knowledge of such facts and for each person identified state the












objections and subject thereto Plaintiff has never been romantically involved with Nick

Swisher or Brian Matusz Moreover Plaintiff has not lied on her resume 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 and/or amend her Answer

SUPPLEMENTAL ANSWER NO.4 Without waiving Plaintiffs original

objections Plaintiff supplements her Answer as follows The statements made by the

Defendants 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 and Brian Matusz Further the statements place 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 Specifically

False Statment 8/5/2010 Glenn Clark said Ms Royle did not know

what blitz was She was sports reporter who knew the definition of

blitz 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 thefalsity

of the statement see also

Exhibit

False Statnient 9/7/2010 Glenn Clark told Damon Yaiffe that Ms

Royle lied on her resume and did not have the experience to cover the

Ravens Ms Royle has never lied on her resume and her employment as

reported covering the Ravens was based upon years of experience gained

in New York and Boston covering other professional athletic teams The

statements place 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 and Mr

Yaffe have knowledge of these statements see also Exhibit

False Statinent 9/21 2010 Drew Forrester tweeted Jen doesnt know

where Hopkins is. LOL 10 At the time this statement was made Jen

Royle did know where Johns Hopkins was The statement places 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 Royle questionnaire asking her If you could ever have handsome

man take you out on date and try to earn your affection what would

you want him to wear He blogged that She wrote Well Ive always

been sucker for man in uniform so heres what Id like him to look

like The link is to picture of Nick Swisher in uniform Ms Royle never

sent such response or link to Mr Forrester The statements 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

but not limited to unprofessionalism and incompetence in regards to her

occupation The parties herein as well as Nick Swisher have knowledge

of the falsity of the statements See also Exhibit

False Statinent 12/29/2010 Drew Forrester responded to comment

in blog stating that Royle is an out of towner who showed up

here earlier in the year and immediately started talking about how much

the place sucks The statement places Ms Royle in false position by

attributing to Ms Royle false characteristics including but not limited to


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 thecity

of

Baltimore to anyone and everyone The statement places Ms Royle in



profession The parties herein have knowledge of the falsityof the

statement see also Exhibit

False Statment Drew Porrester tweeted @WNST @JenlRoyleMASN

Drew And think the fact that youre stuck-up snobby tourist on brief

professional vacation here is COMICALtoo Ms Royle was employed

at the time of the comment in Baltimore she was not engaged in

vacation as tourist Moreover the use of the term professional as

it appears in the tweet and the statement as whole places Ms Royle in



occupation The parties herein have knowledge of the falsity of the

statement

False Statment 1/2011 Nestor Aparicio tweeted @VJNST Nestor

But Drew has been KIND to Miss Yes Jen Mr Renegade .. real

disgrace is in corporate bosses who though Yeah theyre qualified Ms

Royle was qualified for her position at the time she was hired The

statement places Ms Royle in false position by attributing to Ms Royle


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 with her Thats her OPINION

Heres my FACT Jen is ai-t out-of-towner tourist Jen Royle 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



False Statment 10 1/11/2011 Drew Forrester blogged Quick

Jen who said that No it wasnt Brian Matusz think he said Love

those jeans.. The statements 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 Brian

Matusz Further the statements place Ms Royle in false position by

10


uriprofessionalism and incompetence in regards to her occupation The

parties herein as well as Brian Matusz have knowledge of the falsity of

the statements See also Exhibit

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 about Baltimore sports

when she doesnt have any kind of investment in it The statement places

Ms Royle in false position by attributing to Ms Royle false

characteristics including but not limited to unprofessionalism and


knowledge of thefalsity

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



falsity of the statement See also Exhibit

False Statinent 13 1/28/2011 Drew Forrester claimed that when

Jen Royle showed up to Baltimore Magazine photo shoot she didnt

want to wear the clothes given to her and instead brought her own Nick

Swisher jersey that she wanted to wear with nothing 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



regards to her occupation The parties herein and Nick Swisher have

knowledge of thefalsity

of the statements See also Exhibit

False Statment 14 1/28/2011 Drew Forrester responded to

comment on blog She came to Baltimore professed this place to be

beneath her then quietiy went about bragging how much she missed New

York and how this place has nothing for me Ms Royle did not claim

that Baltimore was beneath her or brag that it had nothing for her The

statement places Ms Royle in false position by attributing to Ms Royle




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 Royle had years

of experience covering various athletic teams that qualified her for sports

reporting The statements place Ms Royle in false position by attributing

12

to Ms Royle false characteristics including but not limited to

unprofessionalism and incompetence in regards to her profession The

parties herein have knowledge of the falsity of these statements See also

Exhibit

False Statment 16 6/4/2011 Glenn Clark claimed in blog that

Jen Royle had trouble finding Towson University the previous day Ms

Royle did not have trouble finding Towson University on 6/3/2011 Deb

Poquette can confirm Ms Royles arrival before practice began her

contact information is email [email protected] telephone-410-

340-3569 The statement places Ms Royle in false position by attributing

to Ms Royle false characteristics including but not limited to


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

Royles employer was hiring sports reporter and when the station

interviewed girl who performed unintelligently in beauty pageant she

passed the interview with flying colors The statement places Ms Royle




falsity of this statement See also Exhibit

13

False Statinent 18 Drew Forrester told Jerry Coleman that Ms

Royle was engaged in sexual activity with Brian Matusz Ms Royle did

not engage in sexual activity with Brian Matusz The statement places Ms

Royle in false position by attributing to Ms Royle false characteristics


regards to her profession Further the statement 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 and Brian Matusz have knowledge of the

falsity of the statements See also Exhibit

Plaintiff also refers and incorporates Answer and Supplemental Answers to

Interrogatories Nos and Supplemental Exhibit and Plaintiffs Original and

Supplemental Responses to Request for Production of Documents Further the persons

identified herein have knowledge of the false statements

INTERROGATORY NO.5 Identify all communications between you and

any other persons including but not limited to the Defendants relating to the

statements identified 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 communication was addressed all those who received the communication whether

the communication was made orally or in writing the substance of the communication

and any response to the communication

14





ambiguous as well as unduly burdensome as the Interrogatory does not define the 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 and subject to said objections Plaintiff prepared


Plaintiff exchanged emails with colleagues and management at MASN and CBS as well

as telephone conversations beginning on approximately January 13 2011 regarding the

Defendants conduct As discovery is ongoing Plaintiff reserves the right to supplement

and/or amend her response to this Interrogatory

SUPPLEMENTAL ANSWER NO Without waiving and subject to Plaintiffs

original objections to the extent the correspondence is in the immediate custody

possession or control of the Plaintiff copies have been provided See PRDR 000070-

000071 000076-000078 The recipients of the letter to the Raven Public Relations/Media

staff included to Chad Steele Patrick Gleason and Kevin Byrne Plaintiff exchanged

emails with Jim Cuddihy of MASN on or about January 13 2011 regarding the

Defendants conduct Plaintiff emailed Greg Bader of the Baltimore Orioles

Organization on or about 6/11/2011 Greg Bader responded 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 With respect to each statement identified in

your answer to Interrogatory No if you contend that any of the Defendants knew

that the 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 falsity for each Defendant state the specific facts on which you base your

contention and all persons known to you who have knowledge of such facts and for

each person identified state the substance of tht persons knowledge











objections and subject thereto Plaintiff directs Defendant to her Answer to

Interrogatory No and incorporates her Answer thereto Plaintiff anticipates that

discovery in this 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 ANSWER NO Without waiving Plaintiffs original

objections and subject thereto Plaintiff directs Defendants to her Supplemental Answer

to Interrogatory No and and incorporates her Answers thereto as well as

Supplemental Exhibit and Exhibit 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 and/or amend

her Answer to this Interrogatory

Glenn Clark knew Jen Royle was sports reporter through his employment in as

sports reporter himself Based upon this knowledge but not limited thereto

Defendant Clark knew that Ms Royle had sufficient expertise in sports to cover

professional sports teams and that she was qualified for position in reporting

Defendant Clark had no basis to claim Ms Royle lied on her resume and in publishing

the statements without verifying the accuracy thereof Mr Clark reckleºsly made the

false statements or knew that the statements were false and purposefully made them

nonetheless The Defendants statements place Ms Royle in false position by


unprofessionaiism and incompetence regarding her occupation

Drew Forrester knew of Ms Royles employment in Baltimore and previous

employment covering other athletic teams as he is competitor in the same field Based

upon this knowledge but not limited 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 reliable basis to assert

that Ms Royle did not know where Johns Hopkins was and he recklessly made false

statement to that effect Further Defendant Forrester had no reliable basis to assert that

Ms Royle was sleeping with or had personal/inappropriate/sexual relationship as

defined in Plaintiffs Supplemental Answer to Interrogatory No 20 with Mr Swisher

and/or Mr Matusz The Defendants statements 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 and Brian Matusz

Further the statements place Ms Royle in false position by attributing to Ms Royle

false characteristics including but not limited to unprofessionalism and incompetence

regarding her occupation

Nestor Aparicio knew of Ms Royles experience in sports journalism as result of

his extensive work covering Baltimore sporting news The Defendants statements that

Plaintiff was unqualified were either subjectively false statements or made in reckless

disregard for the falsity thereof The Defendants statements place Ms Royle in false

position by attributing to Ms Royle false characteristics including but not limited to

unprofessionalism and incompetence regarding her occupation

INTERROGATORY NO.9 If you contend that any of the Defendants

acted with common law malice ill will or spite in making any of the 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











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 ANSWER NO Without waiving and subject to said

objection Plaintiff supplements her Answer 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

and/or amend her Answer to this Interrogatory

The Defendants statements were made intentionally and recklessly without

verification of the accuracy of such statements and without regard of the falsitythereof

The statements place Royle in false position by attributing false conduct to Ms

19

Royle namely that she has some sort of personal/inappropriate/sexual relationship

with Nick Swisher and Brian Matusz Further the statements place 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 Plaintiff directs

Defendant to her Supplemental Answers to Interrogatory Nos and and

Supplemental Exhibit and Exhibit

INTERROGATORY NO 11 Describe in detail any other damages you

contend to have suffered to your feelings including but not limited to distress

anguish and humiliation as result of the statements identified in your answer to

Interrogatory No state the nature extent and duration of the alleged injury or

damage any special damages you allege are due to such injury or damage any and all

financial losses related thereto the reasons you contend that such statements were the

proximate cause of such injury or damage the names and business addresses of all

health care providers who treated you for such alleged injuries and the dates of such

treatment





ambiguous as it does not define the phrase damages .suffered to your feelings

Without waiving and subject to said objections Plaintiff refers to Dr Goldiners letter

produced in response to the Defendants Request for Production of Documents Plaintiff

20

has suffered from severe anxiety 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 and her appearance

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 120 Sister Pierre Drive 207 Towson

Maryland 21204 Plaintiffs damages are ongoing as she continues to take medication

and is under the care of Dr Liebman

SUPPLEMENTAL ANSWER NO 11 Without waiving and subject to said

objections to the extent 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







21



SUPPLEMENTAL ANSWER NO 12 Plaintiff has suffered reputational

damages as supported by the negative comments tweets and general opinions held by

fans who have heard and believe the statements identified herein Additionally

Plaintiff has been called slut bitch and other insulting names by fans who have

heard or read the Defendants statements See Responses to Requests for Production of

Documents and Supplemental Exhibit

INTERROGATORY NO 15 Identify any doctor physician medical

practitioner psychologist psychiatrist mental health counselor or mental health

practitioner that you have ever visited concerning your mental and/or emotional health

in your lifetime and for each person identified state their full name address phone

number and the date and purpose of any such visit

ANSWER NO 15 Plaintiff objects to this Interrogatory as it is overly broad and

seeks information that is not material to the instant litigation The Interrogatory is not

reasonably calculated to lead to the discovery of admissible evidence Without waiving

and subject to said objection Plaintiff has visited Drs Goldiner and Liebman See

Answer to Interrogatory No 11

SUPPLEMENTAL ANSWER NO 15 Plaintiff has visited only Drs Goldiner

and Liebman in regard to her mental and/emotional health

22

INTERROGATORY NO 16 Identify and describe all communications

including but not limited to letters and correspondence from members of the public

sent to you that relate to your work in Baltimore Maryland


vague and ambiguous as well as unduly burdensome as it seeks for Plaintiff to provide

all communications which term is left undefined Plaintiff has ever received

regarding her work in Baltimore Maryland Moreover the Interrogatory seeks


to the discovery of admissible evidence

SUPPLEMENTAL ANSWER NO 16 To extent responsive documents and/or

information exists and is 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 Facebook and Twitter Requests of the Defendants which are

responsive to this Interrogatory See Plaintiffs Supplemental Responses to Production

of Documents

INTERROGATORY NO 19 Describe in detail your entire employment

history With respect to your answer to this interrogatory provide contact information

for the individual who can verify your employment describe your work

responsibilities identify your direct supervisors at each place of employment the

dates of each employment your job title including any changes during employment

and the reason for your leaving each place of eniployment

23






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

resume and biography attached hereto as Exhibit

SUPPLEMENTAL ANSWER NO 19 Plaintiff provides the following

supplemental information Ms Royle was transferred from YES Network to MLB

Advanced Media when MLB Advanced Media purchased the YES Network website

her previous employer Her position was eliminated at MLB Advanced Media She

received job offer at Sirius/XM Radio to continue covering the Yankees and the Mets

Ms Royle worked for Sirius/XM Radio after YES/MLB Advanced Media Ms

Royle received an offer for what she considered better opportunity at MASN and CBS

Radio in Baltimore and relocated after the conclusion of the 2009 World Series When

CBS lost their flagship rights to the Orioles Ms Royle was no longer able to work for

MASN because her position there was eliminated Ms Royle did not want to leave CBS

Ms Royle received an offer for and accepted the co-hosting job on Baltimore Baseball

Tonight Orioles unofficial pregame show

24

INTERROGATORY 21 Identify all former or current professional athletes

with 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 of the coaching staff or management in Major

League Baseball the National Football League the National Basketball Association the

National Hockey League Major League Soccer the Arena Football League the PGA

Tour the AW World Tour NASCAR any minor league affiliate of such leagues or any

other minor professional league i.e AAA baseball and the American Hockey League

For each person identified state theft full name address phone number and the dates


ANSWER TO INTERROGATORY NO 21 Plaintiff objects to this

Interrogatory as it contains several interrogatories 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 The interrogatory seeks


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 NO 21 Defendants have made false statements

about relationships with Nick Swisher and Brian Matusz Plaintiff limits her claims 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 Without waiving these objections and subject thereto the

Plaintiff has not had any inappropriate and/or sexual relationships with either Nick

Swisher or Brian Matusz as those words are defined in Plaintiffs Supplemental Answer

to Interrogatory No 20

INTERROGATORY NO 22 Identify all former or professional athletes with

whom you have ever had intimate romantic or sexual relations of any nature including

but not limited to any current or former player or member of the coaching staff or

management in Major League Baseball the National Football League the National

Basketball Association the National Hockey League Major League Soccer the Arena

Football League the PGA Tour the ATP World Tour NASCAR any minor league

affiliate of such leagues or any other minor professional league i.e AAA baseball and

the Ameridan Hockey League For each person identified state their full name

address phone number and the dates and nature of any such relationship






evidence Further the Interrogatory is overly broad vague arid ambiguous

SUPPLEMENTAL ANSWER NO 22 See Plaintiffs Supplemental Answer to

Interrogatory No 21

26

SOLEMNLY AFFIRM under the penalties of perjury that the factual matters stated Ia

the Answers to Interrogatories are true to the best of my information and belief

Brian Goodman

Alexandra Moylan



Towson Maryland 21 204-2600

410 938-8800


28

234620-1

Plaintiffs Supplemental Exhibit

2/24/20 10 On Glenn Clarks blog Dte vFrróst4r lists Jen Royle as number in

his Top Sports Media Members We Wouldnt Mind Seeing Suspended For

Few WeeksIn honor of Tons Kornheisers suspension from ESPN Glenn and Drew

have compiled lists of the top sports media members they want to see

suspended for few weeks

Drews List

Jen Royle

Glenn Clark Glenn Clarks Blog Comcast Morning Show Tuesday Top 7-Sports

Media Members We Wouldnt Mind Seeing Suspended For Few Weeks

available at http//wnst.net/wordpress/glennclark/20 0/02/24/comcast-morning-

show-top-7-sport-media-mernbers-we-want-to-see-suspended/ See Plaintiffs

Original and Supplemental Responses to Request for Production of Documents

4/26/2010 On his blog v5ite states that Ms Royles hiring was

stereotypical because she is an out-of-towner He later states that she is not

qualified to ask any questions and insinuates that she frequents hang outs of

Yankees outfielder Nick Swisher

Jen Royle is the new 0s beat reporter for the teams flagship radio station

105.7 In typical Fan Fashion they hired an out-of-towner to handle the

duties of covering the team In all fairness if youre going to hire beat

reporter she might as well be pretty .no offense CaseyWhat will Jen Royle ask MacPhail Answer Shes not equipped to even

ask anything shes Yankees fan Maybe she can ask MacPhail if hes ever

been to the Cobb Chop House in Manhattan think heard her say its one

of Swishs favorite hang outs

Drew Forrester Drew Forresters Blog It takes 20 minutes Orioles shouldnt run

from the challenge flag available at

http//wnst.netlwordpress/drewforrester/20 0/04/26/ittakesL20minutesorioles

shouldnt-run-from-the-challenge-flag/ See Plaintiffs Original and Supplemental

Responses to Request for Production of Documents

5/19/2010 blogs that Ms Royles description of an Orioles game

was wrong He later analogizes her to character on the Jersey Shore because she

is disaster He states that he doesnt want her to do her job better

The APs David Ginsburg says Orioles touched up Royals bullpen

after Greinke departed for 10 inning win

Supp Exhibit 000001


Page

No the Orioles did not beat Zack Greinke despite what someone over at

105.7 cough Jen Royle cough said They did however win game started

by Zack Greinke which is ALMOST just as good

Edit from GMC Some might say Im obsessed with her Theyre right Its

similar to how many of us are obsessed with Snooki from Jersey Shore

Its just such disaster that how can you possibly turn away The reality is

that as much as say want Jen Royle to do her job better probably

REALLY dont want her toGlenn Clarks Blog Wednesday Mornings Crabs and Beer available at

http //wnst.net/wordpress/glennclark/20 10/05/19/wednesday-mornings-crabs-and-

beer-102/ See Plaintiffs Original and Supplemental Responses to Request for

Production of Documents.

6/5/2010 Glenn Clark tweets

GMC local journalist in town is apparently playing in Celebrity

Softball Game With aRavensplayer whose name they cant spell

Tweet copied by Ms Royle from Twitter.com

8/5/2010 Casey Willett co-worker and CBS employee notifies Ms Royle

during Ravens training camp in Westminster MD that just rippedher on the air that morning and are now calling Ms Royle Jen Midol was

crying on the Ravens field when heard they had segment called Jen Midol on

the morning show Drew and Glenn Ravens PR Chad Steele and Patrick

Gleason and Mike Preston from the Baltimore Sun spoke with Ms Royle

following the incident

Comments included that she knew nothing about the Ravens and did not know

what the term blitz meant but that she knew who the right fielder of the Yankees

was Nick Swisher See Plaintiffs Second Supplemental Answer to

Interrogatory No

Some time later Nestor came up to me and introduced himself and reached out to

shake my hand declined to shake his hand

said your radio station has nothing good to say about me and dont appreciate it

because you dont even know me

He said have never said word about you cant control what other people

say

supp Exhibit 000002


Page

Isaid well Imtelling you now and youre the owner so youre responsible

And he walked away

That afternoon he went on the air and told everyone was the biggest bitch he has

ever metEmailfrom Ms Royle

9/7/20 10 During Ravens practice Ms Royle claims that told

media member/CBS co-worker Damon Yaffe that

lied on my resume anddo not have the credentials/ experience saw

have and do not deserve to be covering the Ravens Clark also allegedly

stated that it is brutal listening to her and inquired why CBS didnt have

anyone better to cover the Ravens

Letter to Ravens sent by Jen Royle to Chad Steele Patrick Gleason and Kevin

Bryne employees of the Baltimore Ravens Organization in late 2010 See

Response to Production of Documents PRDR 000076-000078

9/12/2010 Drçw ao and _____ tweet about her

Glenn Clark Cant believe JenRoyleMASNcalled me douchebag in

front of everyone here tonight thought working for the Yankees meant

class Ms Royle alleges her comment was not in front of anyoneGlenn Clark And to think JenRoyleMASNhasnt 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

JenRoyleMASNis wearing are worth more than Glenn Clarks car

truth

Tweets cut and copied from Twitter into letter to Ravens

Ms Royle asks them to stop later in the dayMs Royle confronted Mr Clark and told him his tweet was Crossing the

line and was Extremely unprofessional While Ms Royle was

confronting Mr Clark Mr Forrester walked by the altercation and yelled

Where are your boots

Ms Royle Asked Mr Clark to step outside with Drew to talk and Clark

said No This is not the right place Drew then said Go home and put

your boots on first then come inside and let me buy you drink

Supp Exhibit 000003


Page

After that another media member_Jon Gallo of CBS Sportsline informed MsRoyle that Drew and made comments including

Fuck that bitch She looks like stripper Shes complete idiot

And Drew Forrester made the comment Id like to smell her boots

Letter to Ravens

Jon Gallo also confronted the Ravens PR staff Patrick Gleason and Chad Steele

and said If you dont tell WNST to stop talking negatively about Jen Royle

would like to have my seat changed

9/20/20 10 CJ Spiller blogs on WNSTGood freakin lord Shaddup Jen Roylel First of all Jen we understand

you were demoted from New York media roles to your current spot here in

Podunkamore You talk like high school girl trying out for the Jersey

Shore not ports reporter

CojAed from blog on WNST.1

9/21/20 10 After brief encounter with Drew Forrester at the Ravens facility

where Ms Royle was approached at the water cooler Drew Forrester invaded MsRoyles space and asked her how she was Ms Royle did not respond Instead she

walked away Drew Forrester then yelled to Ms Royle Wait where you goingDont you want to know how am Ms Royle responded Not really

Drew Forrester later tweets

girl is lucky my roid rage hasnt kicked yet or would have

snapped her head offHe then tweets

It was definitely real water-cooler moment was shocked at the wayshe spoke to me But dig the hell out of her boots

Next he tweets

Miss America has left the building without apologizing to me. .1

He also tweeted that

her two favorite teams the Yankees and RaysHe further tweets

lost power at WNST about 40 minutes ago Rumor is someone saw

Jen Royle running away from the building hee hee

Blog no longer available on website

Supp Exhibit 000004


Page

Finally he tweets

len doesnt know where Hopkins is. .LOL 10Copied by len Royle from Twitter.2

On or about 10/1/2010 Drew Forrester leaned far back in his chair at the Ravens

facility in Owings Mills and eyed Ms Royle up and down staring at her legs MrForrester was well aware that Ms Royle witnessed this Later in the press

conference room when Ms Royle walked past Mr Clark Forrester yelled to

Clark Dont say anything Glenn We dont want to get in trouble again Uponcommencement of the press conference Clark and Forrester stared at Ms Royles

legs as she walked past and laughed

Ms Royle and the Defendants have personal knowledge of this occurrence

10/8/2010 Drew 1orjester condemns fan jokingly encouraging len to kill

herself via tweet during the Ravens Steelers game The fans tweet appeared

to follow Drews jab that len was watching the game at home

of her critics authored tweet that encouraged len to kill herself It

wasnt joke It came across as very serious and len took it that way in her

response cant stress how wrong it is for anyone to EVER encourage or

implore someone to end their life

Drew Forresters Blog Coat your big apple with some Friday Mud available at

http//wnst.net/wofdpress/drewforrester/20 10/10/08/coat-your-big-apple-with-

some-friday-mud/ See Plaintiffs Original and Supplemental Responses to

Request for Production of Documents

11/10/2010 bMw stresponds to comment on his blog

Anonymous Says

November 10th 2010 at 849 pmHow long will you all continue the silly cold war with Jen Royle from The

Fan 105.7 DF Hey len thanks for stopping by Nice boots.. You should

know kiddo that there really ISNT cold war with you havent talked to

you in seven weeks. .ever since that day at the facility when greeted YOUand asked how YOU were doing and you didnt respond and told you had

bad poison ivy and you said quote DONT CARE Thats the last time

spoke to you Sinóe then youve carried on like 6-year old with bunch of

media people in town and nationally telling them how much weve

All tweets referenced herein are no longer on twitter

5upp Exhibit 000005


Page

mistreated you .when in fact you know the truth and the truth is we

havent bothered you in about months Thanks for checking out myblog .next week Ill include picture of Nick Swisher or Brian Matusz for

youDrew Forrester Drew Forresters Blog Wednesday QA In honor of Brooks Ill

take 21 questions available at

hlp//wnst.net/wordpress/drewforrester/20 11/01/1 4/take-your-timeno-need-to-

rush-through-friday-mud/ See Plaintiffs Original and Supplemental Responses

to Request for Production of Documents

11/18/2010 Didw Irrester blogs that fans wont get to meet Jen Royle This

appears to be ajoke that she thinks of herself as star

Come one come all to the Fullerton Pub tonight at 7pm when The

Morning Reaction hosts Rub Elbows with the Stars

And no that doesnt mean youre going to meet Jen Royle

It means were going to meet YOU and rub elbows with YOU the real

stars of WNST radio and WNST.netDrew Forrester Drew Forresters Blog Tonights the night Our canned food drive

begins at The Fullerton Pub available at

http //wnst.net/wordpress/drewforrester/20 10/11 8/tonights-the-night-our-canned-

food-drive-begins-at-the-fullerton-pub/ See Plaintiffs Original and Supplemental


11/26/2010 b.eW Fonester blogs that Ms Royle is not afan of Baltimore sports

teams and he further insinuates that she is interested in Yankees outfielder Nick

Swisher

Its no secret that one of our local radio reporters in town isnt fan of

Baltimore sports teams And because she isnt well known here passed

along questionaire to her with some fairly personal questions One of the

questions was this If you could ever have handsome man take you out on

date and try to earn your affection what would you want him to wear She

wrote Well Ive always been sucker for man in uniform so heres what

Id like him to look like

Drew Forresters Blog Stuff yourself with Friday Mud available at

hap //wnst.net/wordpress/drewforrester/20 10/11 /26/stuff-yourself-with-friday-

mud/ link goes to picture of Nick Swisher at

http//www.zimbio .compictures/d3hjwdZlpYeLBostonRedSoxvNewYork

Supp Exhibit 000006


Page

Yankees/yXBAZYPbiOY/NickSwisher See Plaintiffs Original and

Supplemental Responses to Request for Production of Documents

12/29/2010 Drew Forrester blogs about his best of the best of Baltimore for 2010

and says

Best example ofsomeone coming to town like bull in china shop and

alienating he rself by pissing on all things Baltimore from the minute she got

Jen Royle And the vote wasnt close Next topicDrew Forrester Drew Forresters Blog My Best of the Best in 2010 Dec 292010 available at hup //wnst.networdpress/drewforrester/20 10/1 2/29/my-best-of-

the-best-in-2010/ See Plaintiffs Original and Supplemental Responses to


Several comments on the blog show how Drew Forresters comments affected

people

Steve Says

December 29th 2010 at 413 pmOh and while have you .enlighten us on Jen Royle Whats her deal and

what did she do to gamer all the hate Dont really know much about her..

DF Hatebad word No one HATES Jen Royle dont know her deal

Shes an out of towner who showed up here earlier in the year and

immediately started talking about how much the place sucks II..

bhop Says

December 29th 2010 at 102 pm

Supp Exhibit 000007


Page

Man she specifically dogged Baltimore to you What did she actually say

DF Brian err or is it Tom. .She has specifically dogged Baltimore to

anyone and everyone If you havent picked up on it youre not paying

attention

Stanton Salter Says


Best example of local sports radio talk-show host bashing the very

successflil marketing efforts of one of his employers sponsors WNSTSDrew Forrester completely ripping the Maryland Jockey Clubs Preakness

Preak On slogan Preakness had about 100000 in attendance once again in

2010 so the slogan worked wouldnt have stooped to this level by posting

this however Your negative comments on here about Jen Royle reminded

me of how unprofessional you are at times My question is this. .Who are

you to criticize new young talent in town trying to learn the ropes

Perhaps she did make few blunders upon anival dont know just going

by what youre saying but she at least deserves few breaks while she is

getting comfortable in her new surroundings You on the other hand have

been here for long time and it seems you have no problem bashing

Baltimore traditions such as the 0s and Marylands largest sporting event

The Preakness For the record Ive never even met Jen Royle Only sticking

up for the new kid in town

bhop Says


So she literally stood around bunch of other Baltimore reporters and

openly talked about how much she hated Baltimore Did that really happenIf so thats got to be the weirdest thing Ive ever heard

It is interesting to note that she had that much of an affect on you that you

were inclined to include specific section in your 2010 review to call her

out unprovoked Interesting indeed DF Anyone who is critical of

Baltimore has an affect on me Im from Baltimore

Drew Forrester Drew Forresters Blog My Best of the Best in 2010 available at

http//wnst.net/wordpress/drewforrester/20 10/1 2/29/my-best-of-the-best-in-20 10/

Supp Exhibit 000008


Page

See Plaintiffs Original arid Supplemental Responses to Request for Production of

Documents

1/20 11 Drew Forrester sends series of tweets saying that shed look great in

nothing but Nick Swisher shirt and that she is stuck-up snobby tourist on

brief professional vacation here tweets that she is ignorant and clueless

while insulting her bosses who thought she was qualified

@WNST Drew So Im handling @mattvensel and jØnroylemasn today

at WNST.net Hell get it..she might cry.. but its all good nonetheless

@WNST NOTjenrolemasn jenrolemasnDrew Well bet youd look

great in Nick Swisher shirt and nothing else LOL

@WNST yoitschad JenRoylcMASNDrew Well you know where to

find her Shell be the one talking about how cute A-Rod is.

JenRoyleMASN Drew Im exhausted trying to figure out what perfume

you were wearing yesterday You smelled fantastic

@WNST JenRoyleMASNDrew And think the fact that youre

stuck-up snobby tourist on brief professional vacation here is

COMICAL too

@WNST Nester When Ravens season ends Ill engage w/ignorant out-

of-town genius journalists who are clueless For now Im purple

focused

@WNST Nestor But Drew has been KIND to Miss Yes Jen MrRenegade .. real disgrace is in corporate bosses who though Yeah theyre

qualified

Copied by Jen Royle from twitter

1/11/2011 Drew Forrester tweets that Jen Royle is just tourist in Baltimore

@WNST Drew LOL that Jen Royle thinks Im obsessed with herThats her OPINION Heres myFACT Jen is an out-of-towner tourist


5upp Exhibit 000009


Page 10

___________ tweets his agreement with that assertion ThiS. then threatens out-of

towners

@WNST Sparky4ddub Drew Well out-of-towners who come to

Baltimore and try to tell ME about Baltimore sports is.. using your

word. .annoying

@WNST GMC Im glad let Drew write today he handled it well Kudos

to him

@WNST Drew Forrester Out-of-towners beware .this isnt good week

to pick on Baltimore http//bit.Iv.fK3hnH

@WNST @DamStone JenRoyleMASN@lO57TheFan @mattvensel

Drew Hey its just like pro wrestling We all have role to play No

worries..


Drew also posts blog in which he states that Ms Royle has fanned flames since

coming to Baltimore and that he thinks she has good scent

Jen Royle has been fanning the flames since the day she graced us with her

presence last spring And in FULL disclosure have to admit that she

SMELLED like million dollars yesterday at the Ravens press conference

Yesterday honestly sheliterally

did grace us with whatever she was

wearing .it was glorious

When you arrive in Baltimore to work you cant come in like banshee

and kick the door down and say where is the son-of-a-bitch NoteQuick Jen who said that No it wasnt Brian Matusz think he said

Love those jeans It was Brian Billick you know the coach of the

Ravens when they won the Super Bowl and the guy who was so impressed

with our small audience that he bought into the station

Drew Forrester Drew Forresters Blog Out-of-towners beware .this isnt good


available at http//wnst.net/wordpress/drewforrester/20 11/01/il /out-of-towners

bewarethis-isnt-a-good-week-to-pick-on-baltimore/ See Plaintiffs Original and


Supp Exhibit 000010


Page 11

brew continues insulting comments in response to comments on his blog

Chris Says

January 11th 2011 at 213 pmThat Drew what great blogger he is eff the steelers and anybody from

pittsburgh and stupid bimbos from boston who no nothing about sports and

only got their job because of their looks eff em all...

over4ODon Says

January 11th 2011 at246pmThese Daahnn Tahners really have gall Did Royle ever eat crow about the

Laroche non-offer/signing And only Pitt sburg A-HOLE would expect

anyone to believe the use of bush-league wouldnt incense the masses of

Ravens Town Flacco might be alot things mostly good but Bush-league

aint of them The same way some high class journalistic BIMBO had to

know provincial would stir the massses in BIRDLAND How about some

pictures to keep this subject stirred up in Fridasys MUID

bhop Says

Januaryllth 2011 at 1015 pmill have to agree about that rag remember some bozo posting

column in there about how he hated homeless people thats when stopped

reading

man your attacks onjen royle are so pathetic dude dont know her or read

her stuff but you really seem like man obsessed the comments about her

perfume. .thats borderline creepy old man stuff if she were dude you

wouldnt be spending nearly this much time on her DF First off if she

were dude shed never smell that good or look that good in those boots

Im obsessed about one thing an out-of-towner coming in here and trying to

talk to people about Baltimore sports when she doesnt have any kind of

investment in it wrote as much although you clearly didnt read what

wroteDrew Forrester Drew Forresters Blog Out-of-towners beware .this isnt good


available at http//wnst.net/wordpress/drewforrester/20 11/01/11 /out-of-towners

bewarethis-isnt-a-good-week-to-pick-on-baltimore/ See Plaintiffs Original and


Supp Exhibit 000011


Page 12

rØwthen comments that Ms Royle prefers other cities and is just in Baltimore

on scholarship

As for that girl at 105.7 she can try to write about how much she loves

crabs and Sabatinos and Fells Points great view of the sunset but the truth

of the matter is that shes here on scholarship She knows that Three years

from now her apartment in Baltimore will be occupied by someone else and

shell be in Chicago or Los Angeles or Miami or some other ritzy place

where her pretty smile and expensive perfume habit will be part of some

other stations budget ..

EDITfrom DF at 535pm Since posted this Jen has launched into

ferocious Twitter attack claiming among other things that Ill never be

anything but miserablesmall-time talk show host who cries over his

baseball team She should know lot about claiming something in

Baltimore to be small-time since she is on the record saying she had

numerous job opportunities when she ahem left the YES Network in

2009 but chose Baltimore because it gives me the chance to be big fish

in SMALL pondDrew Forrester Drew Forresters Blog Out-of-towners beware. .this isnt good

week to pick on Baltimore available at

http //wnst.netlwordpress/drewforrester/20 11/01/11 /out-of-towners-bewarethis

isnt-a-good-week-to-pick-on-baltimore/2/ See Plaintiffs Original and


1/15/20 11 Drew posts picture asking viewers to write their own caption that

implies he is saying Ms Royle is failure

Someone from 105.7 who is fan of Friday Mud sent me THIS PICTURE

yesterday and in the subject line of the e-mail it read Lay-Up Ill say

You can caption this one Im leaving it alone

Drew Forrester Drew Foresters Blog Take your time. .no need to rush through

Friday Mud available at http //wnst.net/wordpress/drewforrester/20 11/01 14/take-

your-timeno-need-to-rush-through-friday-mud/ link to http //confidentl .com/wp

content/uploads/2010/03/failure.jpg picture of woman with FAILURE taped

over her mouth See Plaintiffs Original and Supplemental Responses to Request

for Production of Documents

Supp Exhibit 000012


Page 13

1/20/2011___________ answers question on DCRTV.com that it would be

conflict of interest for Ms Royle to date player on the team she covers for

MASN The question he responded to stated people on the team and MASNemployqs were well aware that she has been dating an Orioles pitcher

demonstrating the effect of the Defendants claims that Ms Royle is sleeping with

Brian Matusz Dave Hughes and the Plaintiff have personal knowledge of this

incident previously available at http//www.dcrtv.com/davetvl.html

1/21/2011 Drew Forrester blogs with link to sign that ruined Ms Royles

2010 The link is picture of sign saying Welcome to Baltimore HonThe sign that ruined Sen Royles entire 2010 is RIGHT HERE

Drew Forrester Drew Forresters Blog Friday Mud is better than day at the

beach available at http //wnst.net/wordpress/drewforrester/20 11/01/21/friday-

mud-is-better-than-a-day-at-the-beach link to

http//www.baltimorebrew.compublish/wp-content/uploads/20 10/1 2/hon-

welcome-to-baltimore-katrina-krauss.jpg picture of sign saying Welcome to

Baltimore Hon See Plaintiffs Original and Supplemental Responses to Request

for Production of Documents

BALIIMORE

1/26/2011 PtewFc tester states in response to comments on his blog that the

only qualification that Ms Royle has to be in Baltimore Magazine is that she

5upp Exhibit 000013


Page 14

works here He also says he likes the way she.smells and questions why she

makes herself smell good around athletes

Al Says

January 26th 2011 at 848 amHow embarrassed should Baltimore Magazine be for promoting certain

sports personality as one of Baltimores most eligible singles Shouldnt

the criteria be that Baltimore singles should actually be from Baltimore or an

active member of the Baltimore communitySecond question When said Baltimore single commented how all her

friends and back tracked to include all from out of state agreed how

horrible her magazine picture is shouldnt Baltimore Magazine offer up the

community retraction of their mistake to add her

Perhaps they shouldve waited until the spring travel issue to highlight all of

the tourist sites in and around town

DE This is question better suited for Baltimore Magazine and their

selection committee My guess is as long as you WORK in Baltimore

youre eligible havent seen the other sexy singles so dont know how

our girl got in but too bad the magazine didnt have scratch and sniff

sticker .ifyou know what mean Thats her best attribute by far

.1

Kristen Says


Drew Have you ever actually met and talked with Jen Royal or do you

disrespect her on the air because shes female and according to you

always smells really nice which is your way of saying she doesnt know

sports but because she smells nice she has ajob She probably doesnt give

you the time of day and thats why you dont like her DF Youre funny

but Ill humor you more Ive talked to Jen Royle on several occasions Each

time shes been condescending snarky unfriendly and snobby think she

knows sports Ive NEVER once said she didnt know sports What Ive said

is that she doesnt know BALTIMORE And because of that she has no

historical perspective at all on the Orioles and Ravens My remarks about

how great she smells. .those are COMPLIMENTS She always smells great

Youd have to ask her why she insists on smelling that great around bunch

of athletes Thats not for me to decide But she always smells like winner

admit that

Supp Exhibit 000014


Page 15

Drew Forrester Drew Forresters Blog Back in the saddle again 21 Questions

Returns Update Were going to OVERRRRR-T.LME available at

http//wnst.netlwordpress/drewforrester/20 11/01 /26/back-in-the-saddle-again-2 1-

questions-returns See Plaintiffs Original and Supplemental Responses to


1/28/2011- Diew Forrester states in his blog that Baltimores own Jen Royleshowed up to photo shoot with Nick Swisher outfit

By now Im sure nearly all of you have picked up the latest copy of

Baltimore Magazine which features Baltimores own Jen Royle of MASNas one of our citys Sexy Singles Evidently Jens photo shoot didnt go so

well When she arrived at the location the magazine staffer handed her an

outfit and asked her to get dressed Royle replied But brought something

that think depicts my style little better Fortunately the editor wouldnt

allow Jen to wear THE CLOTHES SHE BROUGHT TO THE PHOTOSHOOT

Drew Forrester Drew Forresters Blog Just in the nick of time its Friday Mud

available at http/wnst.networdpressdrewforrester20 11/01/28/just-in-the-nick-

of-time-its-friday-mud link provided shows Nick Swish outfit below and is

available at hap product.images .fansedge coml3 2-30/32-303 54-F.jpg SeePlaintiffs Original and Supplemental Responses to Request for Production of

Documents

In the comments to the blog someone responds on January 29th to insults about

Jen Royle and Drwotresthf responds that she could handle it

malt Says


Supp Exhibit 000015


Page 16

do think the jen royle stuff is funny along with everything else but also

agree you definitely have the kindergarten pig tail pull thing going on

towards her totally crushing on her for good reason looks not personality

pull brett favre on her thats my advice but do it from pre paid phone

DF Whatever. .shes from Boston. .she can handle little chiding Theres

no reason for me to have crush on anyone Im married And trust me once

you actually meet her the crush-thing ends Shes boorish snobby and

caustic Other that that shes real peachDrew Forrester Drew Forresters Blog Just in the nick of time its Friday Mud

available at http//wnst.net/wordpress/drewforrester/20 11/01/2 8/lust-in-the-nick-

of-time-its-friday-mud See Plaintiffs Original and Supplemental Responses to


few other comments on the blog are insulting

Tom Says


Methinks he doth protest too much Usually enjoy your blog but the Jen

Royle jokes are tired Keep it to yourself if youre that obsessed with her

Ive met her once myselfand shes pretty nice though so dont blame you

Good luck with the pain though Vicodins are your friend DF Methinks

you need better sense of humor Im only obsessed with how silly it is for

an out-of-towner to come in like bull in china shop and try to tell me and

you if you know anything.. about Baltimore sports .11

Steve Says

January28th 2011 at 141 pm

Another Royle jab huh Tm so disappointed Man once again you look so

pathetic know speak for lot of other WNST followers but you lost meThis crap is just too immature and stupid Leave the girl alone She does

good job Your inferiority complex has gotten the best of you buddy hope

someday Jen fulfills your wildest dreams and says hello to you guarantee

shes never given you second glance and thats why youre bitter Youve

yet to make sports related attack on her Its all personal which is

irrelevant and its borderline creepy Good luck DF Well if it means

Supp Exhibit 000016


Page 17

anything to you Im GREATLY disappointed in you Sports related attack

Is that what you said Are you on dope Its ALL sports related chief She

came to Baltimore professed this place to be beneath her then quietly went

about bragging how much she missed New York and how this place has

nothing for meAnd then shes tried to tell lYlE and you but you dont

have the balls to speak up. .1 do how the community should feel about the

Orioles and how all we want to do is cry about our baseball team Grow

pair and get back to me when youre not smitten And one other thing. .not

sure if youve figured it out or not but the blog is all about poking fun at

people Its meant to be light-hearted took jab at Glenn in the

blog .you dont see him whining like little girl Say hey to Jenny for me

when you see her at the water fountain at 105.7 today

StevenB Says

January28th 2011 at2S4pm

Nothing for her to see here as tourist and nothing here for her

professionally are two different things bro will root for another And

wish was Jen so could smell as nice as you say she does Guess Ill never

know

John Says

January 28th 2011 at 1054 pmKeep up the good work with Mud and keep up the Jen jokes because cant

stand herDrew Forrester Drew Forresters Blog Just in the nick of time its Friday Mud

available at http //wnst.net/wordpress/drewforrester/20 11/01/28/just-in-the-nick-

of-time-its-friday-mud See Plaintiffs Original and Supplemental Responses to


2/22/2011 J$jcomments that the only reason Ms Royle has been employed

is because she has pretty face and breasts that she is not qualified to discuss the

Orioles or any other team because Ms Royle is womanRoyleJ What did Nestor say about me on the air Its len texting from

CBS

Herneker He went on 30 minute tirade saying yer not from

baltimore and dont care about the team yer not qualified to talk about the orioles

or any other team for that matter because youre woman and the only reason

youve gotten the jobs that have is because have pretty face and breasts And

5upp Exhibit 000017


Page 18

that people that support that programming are contributing to the economic decline

in baltimore because theyre indirectly hurting his station which is the only station

that tells the truth about the orioles in this city and they get blacklisted Same old

crap He was targeting anyone that wasnt from baltimore over there but ii were the

only one that him and that jackass drew called out by name.Im stem fan so love

controversy but this was time that made me cringe cuz hate that guy See

Plaintiffs Original and Supplemental Responses to Request for Production of

Documents

3/29/2011 Drew responds to comments about Ms Royle in blog sarcastically

Mike from Carney Says

April 29th 2011 at 103 pmalways believed that the voice is from the vote You dont vote you dont

have voice And thats just fact

When did all the Jen bashing stop Except for the hidden message about out

of town reporters telling bow great it is out there we get it DF If dont

vote for anyone because they all stink in my opinion absolutely still

have the right to critique theft in-office performance and criticize it if

necessary That my friend is the REAL fact .1

Purple Kelly Says

April 29th 2011 at 539 pmLove Jen shes welcome addition to this city hope she stays around

long time DF Huh Jen whoDrew Forrester Drew Forresters Blog No stunner here. .Friday Mud is back and

hot as firecracker http//wnst.netlwordpress/drewforrester/201 1/04/29/no-

stunner-herefriday-mud-is-back-and-hot-as-a-firecracker/ See Plaintiffs Original

and Supplemental Responses to Request for Production of Documents

3/30/2011 fiblogsYou can search anywhere on the internet you like and you will not find

shred of evidence that weve ever said or done anything more than tell the

truth about her journalism skills and her outlandish behavior in social media

and in Owings Mills We literally have hundreds and hundreds of public

pronouncements made by Miss Royle via social media that quite frankly

would make any WNST.net employee an ex employee And yes do the

hiring and firing here at WNST

Supp Exhibit 000018


Page 19

Miss Royles feelings have been hurt by thousands of people in Baltimore

and she is quite fighter based on what we read from her public work Her

blog reiterates that on daily basis as she calls fans jerks Baltimorons

and the like You can check it out for yourself Its quite public just like this

blog

Apparently shes only decided to sue us here at WNST.net

Perhaps its because were direct competitor perhaps its because she feels

like shell get her name in the local newspaper and shell eventually extract

some money out of us Win or lose the attorney fees and my time spent

dealing with this nonsense will certainly be draining my piggy bank so Imloser beginning today no matter the outcome of this frivolous case

But to spread vicious rumors about her Not me Not this staff Not EVER at

WNST.nºt

You wouldnt have wanted to hear my reaction to anyone in my professional

world who gave me advice to settle lawsuit that didnt have any merit

and somehow admit guilt where there is none

Ive been doing this for 27 years as professional locally nationally and

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

But were also not strangers to pointing out that our product is the best in the

marketplace every day and telling ou why and proving it every day with

our passion industriousness and accountability If we dont tell you how

good we are we certainly dont expect our competition to do it

And when our competitors bring inferior out-of-town talent into the

marketplace were going to point it out

Especially when any media member would be so brazen about loving the

Yankees and Red Sox and so openly disrespectffil to the community theyre

serving the community that is literally feeding them

No one at WNST.net has ever written or said what these allegations suggest

Not even close

We said Jennifer Royle doesnt know as much about Baltimore sports as we

do

We said shes lacking information and professionalism which if youvefollowed her on Twitter youd see why weve come to that conclusion

5upp Exhibit 000019


Page 20

Shes public figure She has fan page on Facebook She chooses to go on

the radio and serve up her opinions about our sports culture And she

chooses to fight with Baltimoreans and local sports fans seemingly every

single 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 herself by suing the best sports media

compan in Baltimore for pointing out what weve known since the day she

arrived Shes not Baltimore sports expert and now she has her feelings

hurt and is trying to injure WNST its partners employees agents and fans

by trying to take money from my companyNestor Aparicio Nestor Aparicios Blog An indictment of local journalism

Heres our side of baseless Royle WNST lawsuit available at

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/ SeePlaintiffs Original and Supplemental Responses to Request for Production of

Documents

Comments on blog

BmoreBobRob Says

March 30th 2011 at 1139 am

love how you guys took big steamer all over her and now you wonder

what you did wrong Was she qualifed to do the job No Was there

someone better Yes can see where you have right to knock her for not

being qualified but think you guys went too far You really crossed the line

of professionalism Its like you want to act like Howard Stern and dump all

over people and make fun of people but then you want the same people to

treat like you are Ted Koppell respected journalist and opinion maker

You cant have it both ways

.1

Tom Says

March3lst 2011 at 1059 am

As much as hate to see someone who worked so hard to create all that they

have you cant actually be surprised by this Dollars to donuts you were

warned to stop long before it ever got to this point cant imagine lawsuit

came blasting out of the clear blue sky

You act like this is some epic crisis So Royle calls you out for repeatedly

trashing her reputation and ability to do her job in still difficult economy to

Supp Exhibit 000020


Page 21

find employment in and you have the nerve to be angry Youre worried

shes going to take everything you have from you but you were essentially

trying to do the same to her by attempting to make everyone believe she was

an unemployable tramp

Joe of Bel Air makes great point Karma is bitch Maybe youll win

maybe youll lose but bet this will make you think twice before you go on

another vicious smear campaign and THAT is win for any woman who

ever has to work in Baltimore

See Plaintiffs Original and Supplemental Responses to Request for Production of

Documents

6/4/2011 blogs in honor of Jen Royle not being what he considers

Baltimore Sports Expert

In honor of the fact that the reporter from the FM sports station in town

had trouble fmding Towson University yesterday we thought wed put

together bucket list for our Tuesday Top which came on Wednesday

this week

Todays Tuesday Top topic was The Top Things You Need To Do To

Consider Yourself Baltimore Sports Expert As always hope its self

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/ See

Plaintiffs Original and Supplemental Responses to Request for Production of

Documents

6/10/2011 Drew Forrester blogs insulting Boston and compares Jen Royle to

another media person insinuating Ms Royle is unintelligent

Speaking of Boston Im quite pained by the fact that the Canucks have

allowed the Bruins back in the series having won Game and of the

Stanley Cup Finals to even it up at 2-games apiece know .trust meknow Anytime someone or something from Boston experiences even

morsel of success its disheartening They dont deserve anything goodThe only acceptable things to come out of that hell-hole are The Cars Malt

Damon The Country Club of Brookline where Curtis Strange won one of

his two U.S Opens and Steve Carell Everyone and everything

Supp Exhibit 000021


Page 22

else. .sucks Well OK need to take that back apologize THIS PARTof Bostons heritage didnt suck For the record voted 981 times

Im sure youve heard by now that Mark Viviano is leaving his post at 105.7

and will now concentrate solely on his duties as the sports anchor at Channel

13 On side note Ill mention that Mark is solid citizen and good

guy .and hope he enjoys his new less stressful life Anyway Vivianos

departure means The Fan is looking for new sports talk host As is

always the case Im hearing rumors and theyre just that rumors about

his replacement As has become their custom 105.7 execs are looking for

someone out-of-state to come in and wow everyone with their sports

knowledge Rumor has it theyve centered their search on native of South

Carolina and that THIS GIRL RIGHT HERE passed her interview with

flying colors and is the lead candidate to take over Vivs talk show gigDrew Forrester Drew Forresters Blog Hit records are short. .but this edition of


hap //wnst.netlwordpress/drewforrester/20 11/06/1 0/hit-records-are-shortbut-this-

edition-of-friday-mud-sure-isnti first link to video of the Red Sox blowing the

1986 World Series available at

http //www.youtube.comlwatchvghQ VU12T1 8Efeaturerelated second link

to video of girl giving bad answer in Miss Teen USA available at

http//www.youtube.comlwatchvlj3iNxz8Dww See Plaintiffs Response to


Comment on rwTthiesters blog states that Jen Royle references are common

Mike from Carney Says

June 10th 2011 at 921 am

Finding the Royle references in The Mud is like fmding the toy in the cereal

box Love it DF Huh To borrow line from Bull Durham. .dont

think Meat just pitch.. think youre thinking too much But have fun

with itDrew Forrester Drew Forresters Blog Hit records are short .but this edition of


hflp //wnst.net/wordpress/drewforrester/20 11/06/1 0/hit-records-are-shortbut-this-

edition-of-friday-mud-sure-isntl See Plaintiffs Original and Supplemental


Supp Exhibit 000022


Page 23

6/11/2011 Ms Royle contacts __________ to complain that Glenn Forrester told

reporters knew about Jerry Coleman that he had reliable source from the

Warehouse who told him that Ms Royle had relationship with player

Hi Greg

Sorry to bitter you with this.. But Drew Forrester told some

reporters was sleeping with Matusz and is now saying it came from

reliable source in the warehouse guarantee Drew is going to throw that

source under the bus in court to make himself look innocent Any idea who

this warehouse source is and can you please confirm you did your part in

putting this ridiculous rumor to rest

Again Tm very very sorry for the drama and you know love you to pieces

but its verydisheartening and disturbing if these kind of false accusations

come directly from the organization especially when was an employee of

MASN

Thank you

Jen

Email from Jen Royle

__________ replies that he does not believe there was real source

would love to know who this supposed source is doubt he has one

No one know would have spread such rumor spoke with Monica about

it and she doesnt know where it came from And was clear to her after

Brian and spoke in spring training that wouldnt tolerate any rumor

mongering and specifically mentioned this item She agreed and have no

doubt is doing whatever she can to curtail the spread of false rumors As am

have heard no such rumors about you or any other media members this

season

Email from Greg Bader See Plaintiffs Original and Supplemental Responses to


6/16/2011 tweets about sale of discount tickets to Gold Club strip club

undercutting his argument that Ms Royles Ravens outfits are trashy

22812 PM

Supp Exhibit 000023


Page 24

Nestor Ever been to GoldClubon Route4o Wanna go 1/2 price

Available NOW www.wnst.net/youpon Plenty of cool places to save

Baltimore Copied from twitter by Jen Royle

Unknown Dates

Drew Forrester t-weets at the beginning of the 2010 Ravens

season RT @wnst Drew Good news for you guys in

BALT You can follow our tweets live from the stadium or

Jen Royles tweets live from her couch Appears to be

sent around 9/27/10 Copied from twitter by Jan Royle

On or about September 2010 comments on

blog that he does not understand why Jen Royle wearshort skirts and boots to games knowing she wont be on TVand that its pretty cold outside This demonstrates the

Defendants assertions that Ms Royle is employed only

because she is an attractive female but is otherwise

unqualified for her job

Drew Forrester tells Jerry Coleman from Fox on or about

July 2010 You know shes hooking up with Matusz

right Drew Forrester also allegedly told Jerry Coleman

that he had reliable source in the Warehouse that can

confirm Warehouse Orioles offices Jerry Coleman and

Defendant Forrester have personal knowledge of this

incident

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

bethroyle.79gmail.com

Dave Labrozzi Boss CBS Radio knowledge of Plaintiffs professional career

[email protected]

Bob Philips Boss CBS Radio knowledge of Plaintiffs professional career

[email protected]

Jim Cuddihy Former boss MASN knowledge of Plaintiffs professional career

jcuddihymasnsports.com

John Angelos Former boss MASN/Orioles knowledge of Plaintiffs professional career

contact information is not in the Plaintiffs immediate 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

[email protected]

Jeremy Conn Friend/Co-worker knowledge of Plaintiffs professional career

[email protected]

Scott Garceau Friend/Co-worker knowledge of Plaintiffs professional career

scott.garceaucbsradi o.com

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 Friend/Co-worker knowledge of Plaintiffs professional career [email protected]

Bruce Cunningham Friend/Co-worker knowledge of Plaintiffs professional career contact

information is not in the Plaintiffs immediate possession custody or control

Keith Mills employee at WBAL knowledge of Plaintiffs professional career contact

information is not in the Plaintiffs immediate possession custody or 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 Willett WBAL and formerly of CBS Radio knowledge of Plaintiffs professional

career [email protected]

Exhibli 000002



FOR

NASTY 1570 SPORTS LLC et al BALTIMORE CITY



HEREBY CERTIFY that on this 8th day of July 2011 copy of the foregoing

Supplemental Answers to Interrogatories directed to Jennifer Royle on behalf of WNST

SPORTS MEDIA LLC one of Defendants was mailed via first-class mail postage

prepaid to


Drew Sheækman Esquire

Holland Knight LLP



202 955-3000


1Qt50Brian Goodman

Alexandra Moylan




410 938-8800


EXHIBIT 10

July 15 2011 Letter

to Plaintiffs Counsel

Holland Krnght



CHARLES TQSIN

202 419-2539

charIes.tobinhkjaw.eom

July 15 2011

Brian Goodman EsqMember



Towson MD 21204

Dear Mr Goodman

This is to confirm our telephone conference today

During our discussion asked for you to confirm that the allegedly false statements

numbered 1-18 enumerated in Ms Royles Supplemental Answer to Interrogatory Number

served on July constitute the only statements that she contends are actionable in this litigation

You confirmed that our understanding is correct

Based on that representation we do not intend at this time to pursue motion under

Maryland Rule 1-341

Sincerely

HOLLAND KNIGHT LLP

Charles Tobin

CDThje lO477977vl

EXHIBIT 11

CompositeExhibit of Plaintiffs

Responses and Supplemental Responses

to WNSTs Document Requests



FOR

NASTY 1570 SPORTS LLC et at BALTIMORE CITY


PLAINTIFF JENNIFER ROYLES RESPONSES TOWNST 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 Katz P.A responds to First Request For

Discovery of Documents Electronically Stored Information and Property propounded

to her by WNST Sports Media LLC one of the Defendants and states as follows

INTRODUCTION

The following responses represent the Plaintiffs present knowledge

based on discovery investigation and trial preparation to date Discovery

investigation and trial preparation are continuing Plaintiff expressly reserves the right

to rely upon further information adduced upon completion of discovery investigation

and trial preparation and to supplement or amend her responses in light thereof

Plaintiff objects to the portions of the requests purporting to dictate the

maimer in which Plaintiff is to produce documents To the extent that responsive

documents are in her possession custody or control Plaintiff will make such

documents available for inspection and copying at the offices of Modes Pessin Katz

P.A at such time as counsel may mutually agree or will provide copies to counsel as

they become available

GENERAL RESPONSES AND OBTECTIONS

Plaintiff objects to each and every Request to the extent the Request seeks

work product information or materials prepared in contemplation of litigation

information or communications protected by the attorney-client privilege information

or communications protected by the accountant-client privilege or the opinions mental

impressions conclusions or legal theories of the Plaintiffs attorneys accountants or

other representatives


work product information or materials prepared in the course of settlement

discussions

Plaintiff does not waive any protections or privileges by responding to

these Requests Inadvertent production or exposure of any such document shall not

constitute waiver of such privilege or immunity or of any other ground of objection to

the admissibility of such documents or of any information contained therein


information that is not relevant to this case or information that is not likely to lead to

the discovery of admissible evidence in this case

Plaintiff objects to each and every Request to the extent the Request is

overly broad unduly burdensome harassing repetitious vague and/or ambiguous

and to the extent that the Requests purport to require the disclosure of information

beyond the scope of admissible evidence under the Federal Rules of Civil Procedure

Plaintiff objects to these Requests on the grounds that they exceed and/or

are in contravention of the Federal Rules of Civil Procedure and the Discovery

Guidelines

Plaintiff objects to these Requests to the extent they seek information

regarding trade secrets or other confidential commercial proprietary technical

financial or business information

Statements that responsive documents will be produced shall not be read

as an acknowledgment that such documents exist but only that they will be produced if

in the possession custody or control of Plaintiff Documents are immediately available

for your inspection and copying at the offices of Hodes Pessin Katz 901 Dulaney

Valley Road Suite 400 Towson Maryland 21204 attorneys for Plaintiff Copying costs

will be borne by the Plaintiff

Plaintiff objects to each of these Requests to the extent that Plaintiff seeks

information subject to the attorney-client privilege and/or attorney work product

doctrine or other applicable privileges Inadvertent production or exposure of any such

document shall not constitute waiver of such privilege or immunity or of any other

ground of objection to the admissibility of such documents or of any information

234664-1

contained therein Unless expressly noted to the contrary the following responses do

not include references to any document subject to such privileges that were generated

or received by Plaintiff after this matter was referred to counsel schedule of other

documents withheld on the grounds of privilege if any will be provided in separate

writing

Plaintiff has not yet completed discovery in this lawsuit and therefore

Plaintiff reserves the right to file Supplemental Responses if and when such additional

information comes into her possession

By providing the information requested Plaintiff does not waive

objections to its admission into evidence on the grounds of relevance materiality or on

any other proper grounds for objections

Neither Plaintiffs agreement to produce nor her objections to the

production of any information or documents or any category of information or

documents is to be construed as an admission or acknowledgement that any

information or documents exist within such category or categories

Plaintiff objects to any Request to the extent that it requests disclosure of

information banned and/or protected from disclosure by law Specifically Plaintiff

objects to the extent any Request seeks disclosure of information which is protected bythe First Amendment of the United State Constitution and the Maryland Shield LawSee Md Code Ann Courts Judicial Proc 9-112 Tofani State 297 Md 165 465

A2d 413 1983

These objections are hereby incorporated into each specific objection and

response Citation to particular general response and any specific objection below is

not waiver of any of the general objections not cited therein

Plaintiff reserves the right to modify and supplement her responses and

objections to Defendants Requests and response to any of the Requests is not waiver

of that right

RESPONSES

REQUEST NO All documents and conununications which refer reflect or

relate to the Defendants

RESPONSE NO Plaintiff objects to the foregoing Request as it is overly

broad unduly burdensome harassing vague and/or ambiguous 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 which such documents and communications are sought The Request as

worded is not reasonably calculated to lead to the discovery of admissible evidence

and seek information 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

REQUEST NO All documents and communications between you and any

Defendant

RESPONSE NO Plaintiff objects to this Request as overly broad

unduly burdensome vague and/or ambiguous as it fails to define time period for

which all documents and communications are sought Further Plaintiff objects to this

Request to the extent it 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 the Plaintiff Without waiving

these objections to the extent non-privileged and non-protected responsive documents

exist they will be produced

REQUEST NO All documents and communications between you and

anyone concerning the subject matter of this lawsuit

234664-1







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

REQUEST NO All documents and communications which refer reflect or

relate to your contention that you have been defamed as alleged in Count of your

Complaint

RESPONSE NO Plaintiff objects to the foregoing Request to the extent

it seeks disclosure of information which is protected by the attorney-client privilege the




conveniently less expensively and with less 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


relate to your contention that you have been portrayed in false light as alleged in

Count III of your Complaint

RESPONSE NO See Response to Request No.4


relate to your Answer to Interrogatory No.4

RESPONSE NO See Response No


relate to your contention that you have suffered emotional distress

RESPONSE NO Plaintiff objects to the foregoing Request to the extent

it 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 to the extent non-privileged and non-protected responsive

documents exist they will be produced


relate to any Twiuer.com account within your control from 2008 to the present

including but not limited to Jen Royle and @JenRoyleMASN For this request youshall obtain from Twitter complete account history including all tweets sent by youfrom each account You may obtain this information by sending written request to

Twitter by fax to 415-222-9958 signed by you together with copy of valid

government-issued identification card




Complaint as Plaintiff uses this medium daily pursuant to her professional duties

234664-1

Moreover the Request fails to define in your control The Request as worded is not

reasonably calculated to lead to the discovery of admissible evidence Plaintiff objects to

the extent this Request seeks documents or information already in the custody or


conveniently less expensively and with less burden than by the Plaintiff Twitter will

then send you confirmation to the email address they have for you on file which will

authorize Twitter to release to you the requested information

REQUEST NO All documents and communications with any current or

former professional athlete 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 the PGA Tour the ATP World Tour NASCAR any minor league affiliate of

such leagues or any other minor professional league i.e AAA baseball and the

American Hockey League




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 Ann Courts

Judicial Proc 9-112 Tofani State 297 Md 165 465 A.2d 413 1983 Plaintiff objects

to the extent this Request seeks documents or information already in the custody or

234664-1



REQUEST NO 10 All documents and communications with any current or

former player 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







Judicial Proc 9412 Tofani State 297 Md 165 465 A.2d 413 1983 Plaintiff objects




REQUEST NO 11 Ail documents and communications with any current or

former player member of the coaching staff or management in the New York Yankees

baseball organization from 2000 to the present






234664-1


United State Constitution and the Maryland Shield Law Md Code Ann Courts






former player member of the coaching staff or management in the New York Mets









Judicial Proc 9-112 Tofani State_ 297 Md 165 465 A.2d 413 1983 Plaintiff objects





former player member of the coaching staff or management in the Baltimore Orioles


234664-1

RESPONSE NO 13 Plaintiff objects to this Request as it is overly broad

unduly burdensome harassing vague and/or ambiguous as it requires Plaintiff to

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 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 9-112 Tofani State 297 Md 165 465 A.2d 413 1983 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



former player member of the coaching staff or management in the Baltimore Ravens

football organization from 2010 to the present








Judicial Proc 9-112 Tofani Statefl 297 Md 165 465 A.2d 413 1983 Plaintiff objects


10

234664-1



REQUEST NO 15 All documents and communications which refer reflect or

relate to your resume audition tape demo reel or the like from 2000 to the present


unduly burdensome harassing vague and/or ambiguous Further Plaintiff objects to

the extent the Request seeks information that is neither 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 they will be produced


relate to your employment with CBS Radio Baltimore and/or 105.7 The Fan



to produce documents that are unrelated to the allegations of the Complaint Moreover

Plaintiff objects to this Request as it does not specify time period for which such

documents and communications are sought 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 protected by the attorney-client

privilege the attorney work-product doctrine and/or created in anticipation of




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


relate to your employment with the Mid-Atlantic Sports Network from January 2010 to

the present



to produce documents that are unrelated to the allegations of the Complaint The


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 documents exist and are in the possession of the Plaintiff they will

be produced


relate to your employment with MLB Advanced Media from 2006 to the present





12

234664


attorney-client privilege the attorney work-product doctrine and/ or created in






be produced


relate to your employment with XM Satellite Radio Holdings from 2008 to the present












be produced

13

234664-1


relate to your employment with the Yankees Entertainment and Sports Network or the

New York Yankees Baseball organization from 2003 to the present












be produced


relate to your contention that WNST made statements that state implicate or otherwise

insinuate that you are not qualified or competent for your position as

journalist Complaint X20

RESPONSE NO 21 Plaintiff objects to the foregoing Request as it seeks





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 and non-protected documents exist and are

in the possession of the Plaintiff they will be produced Plaintiff also refers Defendant


REQUEST NO 22 AU documents and communications which refer

reflect or relate to your contention that WNST made statements implications or

otherwise insinuated that you are involved in personal sexual and/or inappropriate

relationships with multiple professional athletes Complaint 20











to Exhibit attached to Plaintiffs Answers to lnterrogatories


relate to your contention that WNST threatened violence against you see e.g

Complaint T24d

15

234664-1













relate to your contention any of the Defendants knew that any of the statements

identified in your answer to Interrogatory No that the 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 falsity






conveniently less expensively and with less burden than by the Plaintiff Further

Plaintiff objects to this Request to the extent it calls for evidence and documents that

will be used solely for purposes of impeachment Without waiving these objections to

16

234664-1

the extent that non-privileged and non-protected documents exist and are in the

possession of the Plaintiff they will be produced


relate to newspaper or magazine articles bulletins flyers computer printouts

broadcast tapes videos transcripts letters to the editor or similar broadcast or printed

material published from January 2003 to the present in any form regarding youthat were broadcast or published by anyone other than Defendants





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

which may be obtained by the Defendants more conveniently less expensively and

with less burden than by the Plaintiff Without waiving and subject to these objections

see Exhibit attached to Plaintiffs Answers to Interrogatories


relate to your contention that any of the Defendants acted with common law malice ill

will or spite in making any of the statements in your answer to Interrogatory No





17

234664-Ti






with less 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

they will be produced


relate to your contention that you have suffered damage to your reputation as

proximate result of the statements identified in your answer to Interrogatory No


broad unduly burdensome vague and/or ambiguous Further the Request seeks





conveniently less expensively and with less burden than by the Plaintiff Without

waiving these objections and subject thereto to the extent non-privilege and non

protected documents exist they will be produced


relate to your contention that you have suffered damage to your feelings including but

18

2346644

not limited to distress anguish and humiliation as result of the statements identif led

in your answer to Interrogatory No.3

RESPONSE NO 28 See Response to Request No

REQUEST NO 29 All documents and communications which refer

reflect or relate to your contention that any Defendants conduct was extreme and

outrageous and beyond the bounds of decency in society 60RESPONSE NO 29 Plaintiff objects to the foregoing Request as it is overly

broad unduly burdensome vague and/or ambiguous 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 protected by the attorney-client

privilege the attorney work-product doctrine and/or created in anticipation of




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 they will be produced


relate to your contention that Plaintiff has suffered and will continue to suffer severe

and extreme emotional distress 1J62

RESPONSE NO 30 See Responses to Requests No and 29


relate to any doctor physician medical practitioner psychologist psychiatrist mental

health counselor or mental health practitioner that you have ever visited concerning

your mental and/or emotional health in your lifetime

19

234664-1



to produce documents that are unrelated to the allegations of the Complaint. The




anticipation of litigation Without waiving these objections and subject thereto Plaintiff

refers Defendant to Responses to Requests No and 29


relate to communications including but not limited to letters and correspondence from

members of the public sent to you that relate to your employment in Baltimore

Maryland since 2009










with less burden than by the Plaintiff

20

234664-1

REQUEST NO 33 Produce for inspection and copying at mutually agreeable

place and time complete access to all Facebook.com accounts within your control


unduly burdensome and is 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


place and lime complete and uninhibited access to all Twitter.com accounts within

your control

RESPONSE NO 34 See Response to Request No

Brian Goodman

Alexandra Moylan




410 938-8800


21

234664-I



FOR




HEREBY CERTIFY that on this 2nd day of June 2011 copy of the foregoing

Reponses to First Request For Discovery of Documents Electronically Stored

In.formation and Property directed to Jennifer Royle on behalf of WNST SPORTS

MEDIA one of Defendants was mailed via first-class mail postage prepaid to


Drew Shenkman Esquire

Holland Knight LLP



202 955-3000


Brian Goodman

Kimya Behbahani




410 938-8800




FOR



PLAINTIFF JENNIFER ROYLES SUPPLEMENTAL RESPONSES TOWNST 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 Hodes Pessin Katz P.A responds to First Request For

Discovery of Documents Electronically Stored Information and Property propounded

to her by WNST Sports Media LLC one of the Defendants and states as follows

Supplemental Responses

REQUEST NO.1 All documents and communications which refer

reflect or relate to the Defendants

RESPONSE NO.1 Plaintiff objects to the foregoing Request as it is overly






and seek information that is not relevant to the Complaint Further the Request seeks






SUPPLEMENTAL RESPONSE NO.1 See Supplemental Documents attached

hereto

REQUEST NO.2 All documents and communications between you and any

Defendant

RESPONSE NO Plaintiff objects to this Request as overly broad unduly

burdensome vague and/or ambiguous as it fails to define time period for which all

documents and communications are sought Further Plaintiff objects to this Request to

the extent it 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 the Plaintiff Without waiving these objections

to the extent non-privileged and non-protected responsive documents exist they will be

produced

SUPPLEMENTAL RESPONSE NO.2 To the extent the information sought in

this Request is in the Plaintiffs immediate possession custody or control it has been

produced in the Supplement Documents attached Plaintiff reserves the right to

supplement this Response with additional responsive documents

254497.1

REQUEST NO.3 All documents and communications between you and

anyone concerning the subject matter of this lawsuit







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




Plaintiff

SUPPLEMENTAL RESPONSE NO.3 To the extent non-privileges responsive

documents sought in this 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 NO.4 All documents and communications which refer reflect or

relate to your contention that you have been defamed as alleged in Count of your

Complaint

254497.1

RESPONSE NO.4 Plaintiff objects to the foregoing Request to the extent it

seeks disclosure of information which is protected by the attorney-client privilege the

attorney work-product doctrine and/or created in anticipation of litigati on Plaintiff



conveniently less expensively and with less 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


SUPPLEMENTAL RESPONSE NO.4 To the extent non-privileged responsive

documents are in the immediate possession custody or control of the Plaintiff they

have been produced herewith Plaintiff reserves the right to supplement this Response

as discovery in the instant matter is ongoing


relate to your contention that you have been portrayed in false light as alleged in

Count III of your Complaint

RESPONSE NO.5 See Response to Request No.4





254497.1

REQUEST NO.6 All documents and communicatiQns which refer reflect or

relate to your Answer to Interrogatory No.4

RESPONSE NO.6 See Response No.4


documents axe in the immediate possession custody or control of the Plaintiff they



REQUEST NO.8 All documents and communications which refer reflect or

relate to any Twitter.com account within your control from 2008 to the present

including but not limited to @Jen Royle and @JenRoyleMASN Por this request you

shall obtain from Twitter complete account history including all tweets sent by you

from each account You may obtain this information by sending written request tQ

Twitter by fax to 415-222-9958 signed by you together with copy of valid

government-issued identification card




Complaint as Plaintiff uses this medium daily pursuant to her professional duties

Moreover the Request fails to define in your control The Request as worded is not

reasonably calculated to lead to the discovery of admissible evidence Plaintiff objects to

the extent this Request seeks documents or information already in the custody or


254497.1

conveniently less expensively and with less burden than by the Plaintiff Twitter will

then send you confirmation to the email address they have for you on file which will

authorize Twitter to release to you the requested information

SUPPLEMENTAL RESPONSE NO.8 Plaintiff has complied with the

instructions in the Request and will supplement this Response as the documents

become available

REQUEST NO.9 All documents and communications with any current or

former professional athlete 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 the PGA Tour the ATP World Tour NASCAR any minor league affiliate of

such leagues or any other minor professional league i.e AAA baseball and the

American Hockey League



to produce voluminous documents that are unrelated tO the allegations of the






2544971





documents exist and are in the immediate possession custody or control of the Plaintiff

they have been produced herewith


former player member of the coaching staff or management in Major League Baseball

from 2000 to the present












254497.1

SUPPLEMENTAL RESPONSE NO 10 To the extent non-privileged responsive

documents exist and are fri the immediate possession custody or control of the Plaintiff

they have been produced herewith

REQUEST NO.11 All documents and communications with any current or

former player member of the coaching staff or management in the New York Yankees







seeks disclosure of irtformation which is protected by the First Amendment of the


Judicial Proc 9-112 Tofani Staj 297 Md 165 465 A.2d 413 1983 Plaintiff objects




SUPPLEMENTAL RESPONSE NO 11 To the extent non-privileged

responsive documents exist and are in the immediate possession custody or control of

the Plaintiff they have been produced herewith

254497.1


former player member of the coaching staff or management in the New York Mets

















former player member of the coaching staff or management in the Baltimore Orioles



unduly burdensome harassing vague and/or ambiguous as it requires Plaintiff to

254497.1

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 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 Judicial

Proc 9-112 Tofani StateS 297 Md 165 465 A.2d 413 1983 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






former player member of the coaching staff or management in the Baltimore Ravens

football organization from 2010 to the present








10

254497.1

Judicial Proc 9-112 Tofani State1 297 Md 165 465 A.2d 413 1983 Plaintiff objects



conveniently less expensively arid with less burden than by the Plaintiff



have produced here in The letter was produced with Plaintiffs Original Responses to



relate to your contention that Wl\IST made statements that state implicate or otherwise

insinuate that you are not qualified or competent for your position as

journalist Complaint X20










11

254497.1



SUPPEMENTALRESPONSE NO 21 To the extent non-privileged responsive





relate to your contention that WNST made statements implications or otherwise

insinuated that you are involved in personal sexual and/or inappropriate

relationships with multiple professional athletes Complaint 20












12

254497.1






relate to your contention that WNST threatened violence against you see e.g

Complaint T24d


disclosure of information which is protected by the attorner-client privilege the












have been produced herewith 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

REQUEST NO 26 All documents arid communications which refer reflect or

relate to your contention that any of the Defendants acted with common law malice ill

will or spite in making any of the statements in your answer to Interrogatory No.3










with less 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

they will be produced


responsive documents are in the immediate possession custody or control of the

Plaintiff they have been produced herewith Plaintiff reserves the right to supplement

this Response as discovery in the instant matter is ongoing

14

254497.1


relate to communications including but not limited to letters and correspondence from

members of the public sent to you that relate to your employment in Baltimore

Maryland since 2009


broad unduly burdensome harassing vague and/or ambiguous as it requbes Plaintiff








with less burden than by the Plaintiff


documents axe in the immediate possession custody or control of the Plaintiff they




place and time complete access to all Facebook.com accounts within your control


unduly burdensome and is not reasonably calculated to lead to the discovery of

15

254497.1

admissible evidence Further the Request seeks information which is not relevant to the

allegations in the Complaint Plaintiff reserves the right to supplement as responsive

documents become available



have been produced herewith


place and time complete and uninhibited access to all Twitter.com accounts within

your control

RESPONSE NO 34 See Response to Request No.8



have been produced herewith Plaintiff has complied with Defendants Request and

will supplement this Response as the responsive documents become available

ftQLYJPPLBrian Goodman

Alexandra Moylan




410 938-8800


16

254497.1



FOR




HEREBY CERTIFY that on this day of July 2011 copy of the foregoing

Supplemental Reponses to First Request For Discovery of Documents Electronically

Stored Information and Property directed to Jennifer Royle on behalf of WNST

SPORTS MEDIA one of Defendants was mailed via first-class mail postage prepaid

to


Drew Shenlcman Esquire

Holland Knight LLP

2099 Pennsylvania Avenue NWSuite 100


202 955-3000


Crcein-cin/Brian Goodman

Kirnya Belibahani

HODES PESSIN KATZ PA901 Dulaney Valley Road Suite 400


410 938-8800


EXHIBIT 12

Listing of Jennifer Royles Friends

available from her Personal

Facebook Page

Jennifer Royle

FjJ Info

ft Friends

Friends 901

Craig Minervini

Kimberly Synnott

Ken Weinmen

Jeremy Conn

Catherine Toner

Mary Milenesi

Koenig

Scott Garceeu

Chris Tiliman

Melissa HopeChusid

Skidmore

Anita Marks

Report/Block This Person

Jennifer Royle Friends Add Friend Fraraeosuoesee LJ

lee In 30 Presate

https//www.fscebook.com//jennlferroyleskfriendsvfrlends 1104434 AM

Create an Ad

Linkany

American

Jennifer Royle

Aaron Wilson

Adam Dillon

Adam Gerstenhaber

WFAN

Adam Harlor

Adam Jacobs

Adam Orlando

Adam Rubin

Agnes Roache

Aishlinn Eileen

Loyle sidy High Schoul unrwcan Cd

Alan Zirmor

LIAlanna

Albert Antonucci

Albino Riganello

kN Alex Lanzetta

Major League Seseba

Alex Ripley

Alfred McKeever

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Adam Scotch

Aditi Kinkhabwala

https//www.fecebook.com/ /jenniferroyleskfriendsvfriends 104434 AM

Jennifer Royle

Alfred Aceves

Alice Drayfahloyola Mayand

Alicia Mullin

Major eajue Basebat Brown

Alison Powers

Alison Schuermann

hftps//www.facebook.com//jennifer.rOyIeskfriendsVfriefldS7/26/2011 104434 AM

Allen Lamb

Allison Bacon Marsh

AHoy Marketnq Promotions

Allison Weitzman

Amalie BenjaminNorthwestern

Amanda Best

Amanda Zinobile Easter

Amy Carpenter

Amy Figueredo Garland

Amy Nathan

Amy Zalneraitis

Andrew Crusco

St Johns UMass Amherst

Andrew Fegyveresi.Spnrtsher New York

Andrew Goldberg

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Jennifer Royle

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Andrew IbrahimCase Western Jules lopkins

Andrew Marchand

Andrew MclaughlinBC

Andrew Oshman

Andrew Scheer

NYU

Andrew Shelton

Andrew StetkaCBS Radio Harford CC

Andy Snakovsky

Angel Valentina Burce

Angela Porcello

Anita Marks

Ann Marie Donaldson

Anthony Castrovince

Ohio

Anthony DiComo1311

Anthony Causi

Anthony Taffuri

Arian Gerstel Burtman

Ashley Brilliant

Majni Lnour Baseba

https//www.facebook.com/I/jennifer.roylesk$riendsVfriendS 104434 AM

Jennifer Royle

Ashley Scharge

Audrey DeWys McLaughlin

Barbara Cady

Barry Bloom

Basche Warner

SportsNet New york

Becky BaItzelI Giesing

Becky Weiss Graham

Ben Baisden

Ben GoesslingIlnivur ty r.rv

Ben Grubbs

Ben Masur

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Benjamin Uam Gilmore

Bernadette Ela Maragnano

Beth Morissette Osha

Beth Royle

Bethany Anderson Rosinha

Betsy Brown Bernbaum

Betsy Mel Fanchiang

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Jennifer Royle

______ Bill Cook

Bill Stetka

Baltimore Orioles

Billy OBrien

______ Bob Flaynie

Bob l-lerzog

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Betsy Wall

Bill Gluvna

Bowling Green

Bill Ladson

Bill Meth

Bill Rosenzweig

Blakely Cain

Blayke ScheerIndiana Yes Network

Bob Eyre

Bobby Aguilera

flBobby Goldwater

Bobby Santucci

Brad NeedlemanGB Richard Ellis

Brad Stearns

Aleska Anch Concordio N5ii

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Jennifer Royle

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Brady Gardiner

XM Sateiita Rado Holdings Maryland

Brandon Fairbanks

Brandon Tierney

Brenda Sansone

Brendan Cawley

LiBrendon Ayanbadejo

Brent Harris

Brent 14 Heroux

Brent Gambill

XM Sicoite Rado Holdirga cwis XM Sntellte Padk

Bret Devich

Brett Hollander

Dirkinsor

Brian Bray

Brian Gerald

Brian Goodman

Brian Heyman

Brian Lavery

Brian Lewis

Li

Bridget Fialo

https//www.facebook.com//ieflnlfer.rOYleSkfriendsV4riefldS104434 AM

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Jennifer Royie

Bridget Wentworth Quinnthe Star Ledger

Britney Caruso

Brittany UmarTheStreet.com

Broc Jackson

Bruce Cunningham

rnn

Bryan lioch

Bryan LevyCBS Rado Dear nar.rrel Con rrurricatiom

Bryan McCarthy

C. Nitkowski

Cameron White

______ Carlos Medeiros

Carly Lindsay

SportLNet New York

Carol Perry Harner

Carolyn Nangle CaIdwell

Carolyn Pyne Bohnenberger

Carolynne Kish

Carrie Bonanno

Carrie Sheldon-Hicks

rn

Jennifer Royte

Caryn Pace

LiCasey Stern

Major League Basebat

Casey Willett

Catherine Toner

Cathy Danner-Connole

Catie Webster

Celes Lee Ybarra

Chad Steele

Chad Terry

Chantre Randolph

Charles Dowd

Charley Steiner

Chelsea Rice Reale

StChris McKinley

Chris Montpetit

Chris Phillips

Chris Pollucci

Chris Red

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Jennifer Royte

Chris Rossomando

Chris Russo

Chris Shearn

Yes Notwoik

Chris Tillman

Chris Tyler Merluzzo

Chris Wilder

UPeno

Chris Wragge

Christa Robinson

Christian Roberts

Christina AbadThe Corcoran Group

______ Christina Crespo

Christine Palomba

Christine Strand Cook

Christopher BegleyMajor Leaquo Basebah

Christopher Cady

Christopher LJrciuoli

Chuck Dickemann

Chuck Wilson

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Jennifer Royle

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Cindy Anzel

Major League Baseo

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Cindy Jackson

Cj Papa

Clara Malafarina

Claudia Porcello Campbell

Colleen Ferrick Minon

Colleen Folan MosleyIron Mountan

Connie SchwabRutgers

Corey Sansone

.4Craig Cimini

Craig Germain

Craig Heist

Craig Minervini

Crystal Moroney

ta Curt FergStevensus University

Damien Spellman

Majo League Baseba

Damon Santostefano

Damon Yaffe

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Jennifer Royle

Dan Gentile

Major League Basebat

Dan Gerstein

Harvard

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______ Dan Duquette

Dan Kolko

DeNware

Dan Martin

L.a__I

Dan Pratt

Dan Rams

R-wbok interraticrrs

Dan Sarro

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Dana Iloiles

Dana Kaplan

Dana Schoenfeld

Dana Zweig Becker

Dani Modelevsky Toole

Daniel GuernseyYes Network

Daniel Kruchkow

Daniel Lombardo

Danielle Roberts Walsh

Iiprornise

Danielle Visco

CorneD

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Jennifer Royle

Danny Turco

Dante Carnevale

Dara DeCando

Dara Glick Rosenberg

Dara Zilin Evans

Daren Gray

Dave Burgess

Dave Racaniello

Dave Sims

David Aifreds

David Blecman

David Ginsburg

David Goff

David Goyea

David Henri

David Horn

David Katz

David Cohen

Major Laaoue Baseba CoIurnbt

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Jennifer Royle

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David Lennon

David Picker

FSPN

David Schultz

David Schuster

North Texas

David Smullin

David Szen

______ David Volpe

Debbie St John

Deborah Knight Snyder

Deborah Stratton

Deidra DeAngelis Ruvido

Della Dufresne

Denise Porcello

Derek Beatty

Derek Hallal

Derek Litsey

Derek Prendergast

Derrick Hall

https//www.facebook.com/ /jenniferroyleskfriendsvfriends 104434 AM

Jennifer Royle

Diana Parente

NYIJ

Diane Alvarez

Dianne Borriello Royle

Dominic Amore

Don Jamieson

Donna Porcello

Dora Melissa Vargas

Doreen Prendergast

Doug Reaves

Drew Katz

Stntord

LnDrew Sarver

Duke Castiglione

Ed Cohen

fl ltIdd

Ed McDonald

Ed Price

Stanfxci

Eddie Lau

Edward Lee

Edward Michael

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Jennifer Royle

Edward Norris

Edye Fine Katz

Eileen Grant Marsh

E3 Argenio

Major League Baeeba recuee

Eli Jy

Elizabeth Phillips Keough

Elizabeth Smither Donhauser

iThffiui Elliot Hill

IUhltt%t1

Emil Bodenstein

Emily Greenstein

Emily Mackay Lotterhand

Emma-Louise Calus

Eric Bell

Eric Llney

Eric Talent

Erica Rincon

Major League Basehal

Erik BolandNYU

Erin Gaetz

UVi

https//www.facebook.com//jennifer.royieskfriendsvfriends 1104434 AM

lAdd

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Jennifer Royle

Erin White

Fermin Fernandez

Flavia Miralles

Foleys Ny

Francine Lubera

Frank Archer Jr

Fred Ilarner

Gaia AiagUnivei cily ru irgi

Gary Myers

Gary Palmieri

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Gary Stein

Ft Geoffrey Chatham Lindsay

Geoffrey Mackler

George Vasilakos

George Willis

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VIGina Colombo

https//www.facebaok.com/I/jennifer.royIeskfriendSVfrieflds 104434 AM

Gina Dei Simonelli

Rhode Icland

Gina Rizzo

Jennifer Royle

Gingi Pica

Glenn

Glenn Geffner

Glenn GiangrandeYes Network

Graham Bingham

Haley MahoneyMess Amhcrst

Harold WoodsDePeuI

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Greg Casterioto

Greg Clark

Greg Consalvo

Greg Bader

Greg Kiernan

Greg DiMaggio

Greg WacksSkidmore MTV Netvork

Gregg Bernstein

Gregg Caserta

ordhaw

Gregory Salois

Hal Martin

https//www.facebook.com//jennifer.rOyIeSkfriendSVfriendS7/26/2011 104434 AM

Jennifer Royie

Heather Hamilton Pelletier

Heather King

Heather Roderick

Herbie Zucker

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Hiatt BakerNYU

Hilary Ivey Mueller

Holden Kushner

Holly Johnson

Howard Bryant

Howie Karpin

Ian Browne

Ian Oconnor

Ishan GirdharThunderbird Siool ol Global Management

Jack Curry

Jack Lundin

cy acre tftqh Sd cr1

Jack SzigetyBergen County Academies

Jackie Person

Jacob Stevens- Kittner

https//www.facebook.com//jennifer.royieskriendSVfriendS 104434 AM

Jamison 1-lensley

Saitiiriore Sari

Jane Hirt

Jane Pollack

Janice Molinari

Jason Gallagher

Jason Kidd

CBS Radio

Jason La Canfora

Jennifer Royle

Jacqueline Brown

Jaime Brown

JakeToole

Penn State Sharon High Sri .ooi

James Leyritz

_____ James Kóuledianos

James Walker Espn

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Jami Brown

11Janet Lerch

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Jared Kanter

Maryland New York Magazine

Jason Armstrong

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Jennifer Royle

Jason Savoy

Jay Coffey

Jay Cohen

Jay Feldman

Jay Goldberg

Jay Levy

Jay Moskowitz

Maryland

Jean Sampson

ft1UP1

Jeanette Bombiela

Jeannie Kamen Fine

Jeff Grimshaw

rr Jeff Lantz

Baltntu Ornks

Jeff Washo

fljJeff

Jeffery Butler

Jeffrey PennConmIna

Jen Sarro MacDonald

Jen Schmidt

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Jennifer Royle

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Jenn Barbero SwaineCoidwet Banker Real BawL Corporation

Jenn Duffy Burns

Jenna Wolfe

NBC liniveraal

Jennifer Acuti

Jennifer Baglnski

Jennifer Brown Johnson

Jennifer Fountain

Jennifer Gallagher

Jennifer Lynn Venezia

Jennifer Meola Mack

Jennifer Zucker Mealy

Jenny VrentasPenn State Columbia

Jeremy Brisiel

Major eaque Basebai

Jeremy Conn

Jerome Preisler

Jerry Coleman

Jerry Crasnick

Jessica Alfreds

https//www.facebook.com//Jennifer.royleskfriefldsVfriends7/26/2011 104434 AM

Jennifer Royle

Jessica Fraser

GIaxoSrnitkKIne

Jessica GenningerLoumbia Tufts

Jill St Germain Davis

Jill Young McCarthy

Jim Bowden

Jim Duquette

4iJim

Jim Parente

Jim Petrozzello

Jim Roberts

NBC tinwersa

Jim

Jim Williams

Jimmy Hunter

Joanna Newman

Joanne Rys

Joanne Woods McCormack

Jodi Bernstein Combs

Jodi Kopecky

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https//www.facebook.com/ /jennifer.royleskfriendsvfriends 2011 104434 AM

Jody Mcdonald

Joe AuriemmaYes Network

Joe Capozzi

Joe Castellano

Joe ConnVictciulic

Joe Cook

Joe KanakarajMotor League Baseua

Joe McDonald

Jennifer Royle

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Joe Mclaughlin

Joe Pandiscio

Joe Royle

Coyle Lassidy High School

Joe Sansone

Joel Mueller

WI

______New Leo hoc instftut of Art

John Armstrong

John Todaro

John CampbellWentworth Tewkshury frlernoral High

John Moxon

hUps//www.facebookcom/ /jennlfer.royleskfriendsvfriends 104434 AM

Jennifer Royle

John Grimpel

John Guilfoy

John Lazarou

John Maroon

John Martinez

John McKennaYes Network

John Porto

John Rallo

John Rosenfelderabe

John Tomasehe Boston Herald

Johnny 1-lolliday

_____Jon De Meglio

Sr______ Jon Gallo

Jon Knowles

Jon Lane

Major league Bauco

Jon Luick

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John Regan

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Jennifer Royle

Jon Rose

Jon Walker

Jonah Ken

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Jonathan Beck

8U

Jordan GreenbergXM SateUitn Radio Holdings American

Josh Fox

Joshua Knowles

RET

Joshua Sternlicht

Judy Anzivino Porcello

Julia Chan

Julie Abelson

Julie Alexandria

Julie Anne Donaldson

Julie Austin DiGirolamo

Julie Gardner Koster

Julie Robinson

Therrio sher ccnIf

Justin Hackley

Justin Perez

https//www.facebook.com//jenniferroyleskfriendsv4riends7/2G/201 104434 AM

Jennifer Royle

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Kaleigh Powell

Coyle Caceidy High School

Kara Souza Colby

LiKaren Argenzio Cinelli

Karen CahnGoogle

Karen Fernancles

Karen MacKay Chiaradonna

Karl Boettger

Karlie Keller Perkins

Karyn Riale

Kasey Klaas

Kat OBrienlJPenr

Kate Frasso Graf

Kate Landers Olinger

Katie Begley Fisher

Katie Des Londe

Katie McDermott Laufer

Katie StrangCoumbia Mirboan c.tato Linivers ty

Katy Lathan

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Jennifer Royle

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Ken Austin

Ken Cardosa

Ken Davidoff

Ken Weinman

Kay-Lin Richardson

Keith Mills

Keith Nolfi

Keith Wade

Kelliann ODonnell

Kelly Armstrong

Kelly Auriemma

Kelly Dillon Fitzpatrick

Kelly Hines Walsh

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Kenny Choi

Kenny Wild

Kenneth Colby


Kern 3oyce Lynch

Kerry Austin Klaas

Jennifer Royle

Kerry Ceurvels Martin

Kerry McKinley Palmieri

Kerry Vallett McIntyre

EiiKevin Battle

Kevin BaxterLos Arujeles Irnes

Kevin Begley

Kevin Burkhardt

Kevin CowherdSiR

Kevin Doyle

Kevin Hooshangi

Kevin Rhodes

12Kevin Van Valkenburg

______ Kiki Castiglione

Kim Malvey

Kim OBrien

Kim Porcello York

Kim Wayman

Kimberly Livek

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Kimberly Risicato KreuzbergerConde Nsa

Kimberly Synnott

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Kimi Wada

Krissy Arek

Major League Baseball 3M

Krista Basis

Kristen Barbato Weber

Kristen Berset

University of Florida

Kristen Ellsworth Bennett

Kristen Hudak

Krister 3ohnson

Ewertlirnore

Kristi LeFaivre Anderson Oliver

Kristian Castro

Kristie Ackert

Kristin Coffey

Kristin Conti MurphywpT

Kristin Donovan CadyMeditech

Kristin Ferro Costa

Kristin Lazure

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Jennifer Royle

Kristine Fallon Maw

Kristoffer Drew

Larry Brooks

Larry DiSarro

Larry Fleisher

Larry Knobel

Hofetra

Laura Ahern-Chartier

Laura Fahy

Laura Lee

Lauren Ashley Barnhart

______ Lauren Malone

riLauren Spencer Deford

SportsNet New York Johns Hopkkw

Leah Mc6unnigle

Lee Caouette

Lia Gangi

Lindsay Rykiel

So thur

Lindsey Strese

Lisa Ponte

https//www.facebook.com//jennifer.rOYIesk4riendsVfriendS 1104434 AM

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Jennifer Royte

Lisa CaIdwell Cochrane

Lisa DeChellis Zhawred

Lisa Grasso Archer

Lisa Heaton

Lisa KennellyHarvard

Lisa Klobucher Salgadinho

Lisa Marzella

Lisa Tulis Osgood

Liz Drabick

Lloyd Carroll

Lolita Lopez

LoLo Malone

Major League Baseha

Lora FeinmanBroadbed Enterprises

Lou Holder

Louise Cornetta

Luke Jones

Lya Vallat

Lyle McCollum

https//www.facebook.com//iennifer.roYieskfriendsVfriendS 104434 AM

Jennifer Royle

Marc WeinerPSPN

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IN THE CIRCUIT COURT FORBALTIMORE CITY MARYLAND

Civil Division

Case No 24C11001571

PROPOSED ORDER

Upon WNST Sports Media LLCs Motion to Compel Plaintiff to Respond to Written

Discovery and for an Award of Costs and Incorporated Memorandum of Law and any

opposition thereto it is by this Court this ____ day of 2011

ORDERED that Plaintiffs Complaint is limited to the 18 allegedly false statements in

her supplemental response to Interrogatory No and it is

ORDERED that within 10 days the Plaintiff shall answer Interrogatory Nos 21 and 22

regarding her involvement in personal sexual and/or inappropriate relationships with

professional athletes and it is

ORDERED 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 privilege log consistent with Discovery Guideline 5c and it is

ORDERED that within 10 days the Plaintiff shall produce for inspection and copying

her personal Facebook account or alternatively produce her complete downloaded personal

Facebook account and it is

JENNIFER ROYLE

Plaintiff

NASTY 1570 SPORTS LLC et al

Defendants

ORDERED that within 10 days the Plaintiff shall identify the unnamed individuals

within her responses to Interrogatory Nos 10 and 12 and it is

ORDERED that Plaintiff is prohibited from introducing into evidence any materials she

has not provided to the Defendants within the 10 days provided in the Courts Order and it is

ORDERED that the Plaintiff shall pay the Defendants reasonable attorneys fees and

costs in responding to her discovery deficiencies

Circuit Court Judge

Copies to

Charles Tobin

Drew Shenkman

HOLLAND KNIGHT LLP

2099 Pennsylvania Ave N.W Suite 100


Brian Goodman Esq

Alexandra Moylan EsqHODES PESS1N KATZ P.A901 Dulaney Valley Road Suite 400


Defendant Wnst's Motion to Compel Plaintiff to Respond

Documents

Transcript of Defendant Wnst's Motion to Compel Plaintiff to Respond