You are on page 1of 6
Michael Kump May 25, 2016 VIA E-MAIL AND FEDEX Steve Stanulis Re: Cease and Desist in Your Breach of Your Confidentiality Agreement Dear Mr. Stanulis: We are litigation counsel for Kim Kardashian West and Kanye West Fora brief period of time, you were employed by the security agency that provides security services to Kim, Kanye, and their children. The position you held was a very important one because you were entrusted with protecting these family members, and the position was also a very sensitive one because you were entrusted with protecting the privacy of these family members. ‘You understood these important duties and obligations, and you promised in writing NEVER to speak in public or in private about the family or its members. In fact, on February 7, 2016, you signed a Confidentiality Agreement in which you agreed to not disclose, publicly or privately, ANY information about the Kardashian West families or their members. A copy of the Confidentiality Agreement signed by you is enclosed with this letter. As your text messages to the security agency show, you elected to leave the security agency ~ you were not terminated by anyone. At the time you voluntarily left, you never ‘complained to anyone about any of your interactions with, or treatment by, Kanye or Kim. In light of this, everyone was shocked when they read your interviews with The Daily Mail (May 5), The Sun (May 20) and The New York Daily News (today). Your interviews are filled with false and defamatory statements by you. You obviously gave these interviews solely to gain publicity for yourself Steve Stanulis May 25, 2016 Page 2 Your interviews also violate your express, written promises in the Confidentiality ‘Agreement signed by you. As a result of your blatant and wrongful actions, you are liable for substantial damages, including: # liquidated damages in the amount of $10 million for each inter * punitive damages; © the disgorgement of any money or benefits you received in giving the interviews; and © attorneys” fees incurred in enforcing the Confidentiality Agreement By this letter, we hereby demand that you keep the contractual promises you made in writing to Kim and Kanye, and that you: cease and desist from disclosing, either publically or formation about the family or its members; > immediatel privately, any + immediately cease and desist from making any negative statements about Kim and/or Kanye; and % issue a written public apology to Kim, Kanye and their family for having put them through this ordeal, despite your contractual obligation never to do so. All rights and remedies are reserved. Govern yourself accordingly. MIK:ch CONFIDENTIALITY AGREEMENT into this sag i . to enter into Shue Slanc| ‘gfObligor), hereby agree Pe iowing terms ment (this Raroamtet) and to strictly comply with the : ee i ‘acknowledges that he or she will ot may leam, obtain, be exposed t0 wee information, andlor in the past has or may have acquired informaror Conceming Kristen Jenner, Kourtney Kardashian, Kimberly Kardashian ae lian, Robert Kardashian, Kendall Jenner, Kylie Jenner, Scott Disick, He Mason Disick, Penelope Disick, Reign Disick, North West, Saint West a r. Obligor shall not at any time disclose, publicly or privately, any information any Way, fashion or manner related to. associated with or connected to the ‘Family/Jenner family/Disick femily/ West family and/or their personal relationships, iN@SS activities, plans, operations, finances or employees, or those of their affiliates, (OF aniy of theit respective families, associates, friends, affiliates, agents, assigns or socially and ‘collectively, the "Protected Persons”), and/or any of their. les, plans or finances. jor acknowledges and agrees that the above-described information (collectively, d Information") is deemed to| be strictly confidential, private, secret and shall be kept confidential and secret by them and they agree that they shall not, indirectly, verbally or otherwise, publish, reveal, disseminate, disclose, or permit or lished, revealed, disseminated or disclosed to any person or entity. © This lent Of confidentiality shall apply to disclosures to Obligor's family, associates and ‘communicated or not), and occurring by any verbal or non-verbal means, in any non-visual or otherwise, between or among the Protected Persons and/or any (whether or not employed by the Protected Persons) and includes all information ind the like), and: alt Phone, memory stick, em, whether owned by. » Blackberry-type devices, hard ‘making of copying of any audio 1 ldpe, film, record or otherwise duplicate: (A) any likenesses or son; (B) any private or public\ appearance by any Protected ith of between Protected Persons. nh ive oF authorize aay interview(s), lecture(s) or speech(s), oF Gell or otherwise : ON, oF prepare or assist anyone in the preparation of any book(s), on or motion picture ict(8) or other creation(s) of any kind or nature g or incorporating Protected Information, including, without limitation; @ any person whelher fictional or real, who any member of the public ‘associate with any Protectod Person, regardiess of whether there imer purporting to disassociate such fictitious person from a Protected Affix, discuss, reveal, disclose in any manner whatsoever, or provide any ve Gonceming any Protected Person to anyone at any time in any manner F example only, during and in connection with any promotional interviews, n of any ‘Kind, Whether in verbal, written, typed, electronic or non-verbal form, ‘of any communication, with or to reporters, writers, tabloids, magazines, , broadcasters, talk shows {whether T.V., radio or internet), internet chat rooms, jotographers and the like, bligor agrees that if he or she breaches or threatens to breach any covenant int, in addition to all other rights and remedies available to the Protected otacted Persons shall be entitled to injunctive relief preventing the disclosure, osure, of any Protected Information. Further, if Obligor breaches or ‘any covenant in this Agreement, without limiting any other rights or d Parsons, Obligor shall be required to pay to the Protected Persons urted by the Protected Persons to enforce this Agreement, punitive 9 be determined by a court of competent jurisdiction and liquidated fot less than ten milion dollars and no/100 ($10,000,000,00) per lad Parsons shall be entitled to seek recovery of any and all monies racelved by Obligor or on his or her behalf from any and all Fany use or dissemination by Obligor of any material descnbed in reed by Obligor that all such monies and other benefits received by if shall be held in trust by Obligor or on his or her behalf for : the Protected Persons. For the purposes hereof, any use by rmation in violation of this Agreement shall conslitute theft. : (ies. thal the Prcneded Verses fapds in thee nates iS exrncndinary Character Ging INU Sith DOOR nF the isu ok wich ech connol ba Loromsesties 104.0 ani cee aia FOF Giant of» breach by Cdigen oh may corer i We any oh the provaions of this Aoreomert, # by ie stata cours locaied i LOS ANGELES, to erflorce anvy oh the province of tia hagreerreert cea, s ‘coniany 10 the intent of he partes, the partes herdkay Sipnice Tiigation of any provision ofthis Agreerrert, the cour fhe chal be oualed ond He feeue 2 protecive order prohitiing tha, tivsomre of ony Of the Prckected fimniting the diaclosure of any other intention ohne eo discerns eas id neh gt curl as Fae (i) his oF hor failure shall in no way impair the legally |

You might also like