THE CIRCUIT COURT FOR BALTIMORE CITY MARYLAND

IN
Civil Division

JENNIFER ROYLE
Plaintiff

Case

No

24C11001571

NASTY

1570

SPORTS LLC
Defendants

et

al

HEARING REQUESTED

DEFENDANT WNSTS MOTION TO COMPEL PLAINTIFF TO RESPOND TO WRITTEN DISCOVERY AND FOR AN AWARD OF COSTS AND INCORPORATED MEMORANDUM OF LAW
Defendant

WSNT

Sports

Media

LLC

WNST

or

Defendants

pursuant

Maryland

Rules

1-341

and 2-432

request

that

the

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
not

further

requests

that

Plaintiff

be prohibited

from entering

into

evidence

any documents

produced

and grant an

award

of costs

including

reasonable

attorneys

fees

as

sanctions

for

this

motion

WNST

requests

hearing

pursuant

to Rule

2-311f

In support

of this Motion

WNST

states

INTRODUCTION
For nearly three months Plaintiff
public personality
in

Baltimore sports

talk

radio has

failed

to

comply

with

written

discovery

served

May
the

2011

on

the

basic

issues

of

her

defamation

and

false

light

portrayal

claims

Despite

Courts

narrowing

of

this

case

in

granting

Defendants

partial

motion

to

dismiss

Plaintiffs

answers

to

basic

discovery

requests

are

evasive

and

incomplete

under

Rule

2-432

She

repeatedly

has

refused

to

provide

definitive

list

as

requested

of the

statements

she

claims

defamed

or

cast her

in

false

light

Indeed

her responses

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
athlete

21b
than

she

flatly

refuses

to

furnish

information

about

any

relationship

with

an

other

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
of private

Evelyn Omega Cannon

facts

dismissed
infliction light

Counts
of

II

and

IV

which
with

sounded

in

invasion

of

privacy claims
In

by publication
remaining
are for

and

intentional

emotional of privacy also

distress

prejudice

The

only

defamation
for false

Count
light

and not

false

invasion the

Count III
meets the standard
false for

Maryland Pox

claim

may

stand

unless

claim

defamation
claim can

Crowley
only

Broad

Co

851

Supp
asserts

700 704
provably

Md
false

1994

As

in

defamation

claim

light

be maintained
106

where

plaintiff

statement

of fact

Bagwell

Peninsula

Regional

Med

CIr

Md

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
have

members
information

of the

public

professional

athletes

and

fans

all

of

whom

she

claims

relevant to this lawsuit.3

As

Plaintiff

has

not

complied

with her obligations

under Maryland

law and

WNST
to

has

not

received

the

notice

to

which

it

is

entitled

this

Court should

limit

her

claims

the

18

statements

in

her

latest

discovery

response

require

that

she

furnish

all

additional

information

sought

in

this

motion

within

10

days

order

her

to

provide

access

to

her

entire

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

The

entire

Complaint

arose

of words

allegedly

written

or spoken

by the

Defendants

Complaint

generally

alluded

to

12

written

or

oral

statements

While

characterizing

them

however

the

Complaint

did

not

set

forth

the

words

dates

format

or

audience

for

any statement

On May
claims

2011

Defendants

moved

to

dismiss

the

private

facts

and emotional

distress

and answered

the

defamation

and

false

light

claims

At the

same

time

WNST

served

written

discovery

seeking

inter

alia

specific

list

of the statements

details

about

the timing

and

circumstances

under

which

each

allegedly

was made and an

explanation

of

why

each

was

Defendants
his

also

requested
letter

Plaintiffs

complete

Twitter
that

history
are will

and

all

of her medical obtained

records

Plaintiffs

counsel
to

in

July

18 2011
upon

Ex.l

represented basis the

they

being not
at

promptly
this

and compel

will

be

provided

the of the

Defendants those

receipt

On

that

the Defendants
to

time

move
the

to

Plaintiffs to

production provide

items

Defendants

reserve

right

supplement

this

Motion should

Plaintiff

fail

timely

documents

allegedly

false

This

discovery

obviously

is

necessary

to

furnish

the Defendants

with

notice

and

to

enable

them

to

prepare

their

defense

At

June

hearing

Judge

Cannon

granted

Defendants

motion

dismissing

the

private

facts

and emotional

distress

counts

with prejudice

and without

leave

to

amend

See June

22

2011

Order

attached

as Exhibit

During

that

hearing Judge

Cannon

explicitly

stated

that

Ms

Royle

had not

plead

facts

sufficient

to

state

claims

under

either

of those

torts

copy

of the

transcript

of the June

2011 hearing

is

attached

as Exhibit

The

ruling

left

Plaintiff

with just

two

causes

of action

defamation

and

false

light

portrayal

Although

Judge

Cannon

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
had no

Interrogatories

attached

as

Exhibit

number

of

these

statements

however

factual

content

at

all

and appear

related

to

the

emotional

distress

claim

that

the

Court dismissed

Moreover

number of

statements

were

not

even

attributed

to

the Defendants

at all

See ii

On
deficiencies

June

pursuant

to

Rule 2-432

Defendants

sent

Ms

Royle

letter

outlining

these

copy

of Defendants

June

letter

is

attached

as Exhibit

Counsel

for

the

parties

met by telephone

on June

15 and Defendants made by

counsel

reiterated

that

Plaintiff

needed

to

specify

which

statements

allegedly

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
to

Defendants

wrote two

letters

to

Plaintiffs

counsel

One

noted

her

continuing

failure

furnish

required

discovery

responses

copy

of this

letter

is

attached

as

Exhibit

The

other provided

notice

that

by continuing

to

mushroom

the

number of

allegedly

actionable

statements

Plaintiff

has

brought

herself within

the prohibitions

of Rule 1-341

as

she

is

forcing

Defendants

to

litigate

frivolous

claims

by

refusing

to

reasonably

conform

to

the

contours

of her defamation

and

false

light

counts

copy

of

this letter

is

attached

as

Exhibit

In response

Ms

Royle

again

supplemented

her

interrogatory

responses

The

text

of her

response

to

Interrogatory

No
33

listed

18

allegedly

false

statements

However

she

attached

another

Exhibit

listing

separate

statements

copy

of

Ms

Royles

Supplemental

Interrogatory

Responses

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
have asked

as to the

alleged

statements

around which

this

entire

lawsuit

is

framed

Defendants

on

at

least

five

separate

occasions

for

an appropriately

narrowed

list

and

Plaintiff

repeatedly

has

expanded

contracted

and

expanded

her

response

The

Courts

intervention

therefore

is

unfortunately

necessary

to

assist

the

parties

in

defining

the

contours

of Plaintiffs

claim

As

to

the

remaining discovery

issues

the

parties

are

at

impasse despite

Defendants

efforts

to

resolve

them

without inconvenience

to

the Court

ARGUMENT

Ms

Royle Has Failed to Meet Her Discovery

to

Obligations

under Rules 2-432 by

Responding
Under

WNSTs

Discovery

in an

Evasive

or Incomplete

Manner

Rule 2-43

court

may compel
are

production

of discovery

if

the information

sought

is

discoverable

and

the

partys

responses

evasive

or

incomplete

which

under

the

rule

constitutes

failure

to

provide

discovery

Md

Rule 2-432

Marylands

discovery

rules

are

broad

and

comprehensive

in

scope

Baltimore

Transit

Co

Mezzanotti

227

Md

13

1961

and promote

liberal

disclosures

in

the

interest

of advancing

the

sound

and expeditious

administration

of justice

Id

E.I

du Pont de

Nemours

Co

Forma-Pack

Inc
is

351

Md

396 405

1998 Among
possible

the fundamental

and principal objectives

of the rules

to

eliminate

as

far

as

the necessity

of any party

to

litigation

going

to

trial

in

confused or muddled

state

of

mind

concerning

the

facts

that

gave

rise

to

the

litigation

Mezzanotti

227

Md

at

13

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

Claims are Limited Supplemental
to the

Ms

Royles Defamation
Provided

and

False

Light

18 Statements

in the

Latest

Discovery

Response

and Should Award Costs

Following service

of the Complaint

vaguely

describing

12

allegedly

injurious

statements

WNST
statement

issued

the

following

simple

interrogatory

asking

Plaintiff

to

list

each

and

every

made by

WNST

she

alleges

was

false

and the reasons for her assertion of falsity

INTERROGATORY NO.4
Interrogatory
identify

For each
reason

statement

identified
it

your
false

answer

to

each

No.3 explain and every fact

to

the

that

on

which

you you base

of

claim

was

when made

persons
identified

known

you who
substance

have

knowledge persons of

such

all identify your contention and for each person facts

state the

of that

knowledge
Royles
in

Due
interrogatory incorporated

to

the see

extreme

length

Ms

many

responses

to

this

please

Ms

Royles

responses

Exhibits

and

which

are

by reference

hereto
for

Ms
half of her

Royle

answered

this

question

the

first

time

shortly after

Judge Cannon dismissed

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 her to

that

Ms

Royles

description

of an Orioles
she

analogizes

character
to

on the Jersey

Shore because

game was wrong He is disaster He states

at

later that

he doesnt want her

do her job better

Ex

Supp

Exhibit

000001
and are

Glenn Clark just ripped

Royle on
Exhibit

the air that

at

morning

now

calling

Ms

Royle Jen

Midol Ex
blogs that as

Supp
wont

000002
Royle
at

Drew
that

Forrester thinks

fans

get to

meet Jen
Exhibit

This

appears

to

be

joke

she

of herself

star

Ex
is

Supp
just

000006

Drew
at

Forrester tweets

that

Jen

Royle

tourist

in

Baltimore Ex

Supp

Exhibit

000009
initial

Despite

assurances

that

Plaintiff

had confined

herself

to

the

18

statements

in

her

the text

of her interrogatory

response

Plaintiffs

counsel

now

takes

the

position

that

the Plaintiff

will

not

disclose her

entire

factual

basis until

her

deposition

is

taken

there

are additional

actionable

statements

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
faith

conduct of any party

or without attorney costs

in

maintaining
justification

or defending the court

any

proceeding
the
to

was

in

bad
party

substantial advising the

may

require
to

offending the adverse

or the the

conduct or and the

both

of them

pay

party

of the

proceeding

reasonable

expenses
it

including

reasonable

attorneys

fees incurred by the adverse

party in opposing

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
144

200

592 A.2d

498

503

1991
is

see

also Seney

Seney 97

Md App

544

631

A.2d

139

1993
bad

the

Rules

purpose

to

deter unnecessary

and abusive

litigation.

Under

the

Rule

faith

exists

when

party

litigates

solely

with

the

intent

to

cause

harassment

or

unreasonable

delay

Barnes

Rosenthal

Toyota

Inc

126

Md App
litigants

97

727 A.2d

431

435

1999
debatable

And

lack

of substantial

justification

exists

when

position

is

not

fairly

and not

within

the

realm of legitimate

advocacy

Id

Conduct
the plaintiffs

lacks

substantial

justification

when

there

is

no basis

in

law and/or

in fact

to

support

claim

against

the

defendants

who

seek

fees

and

costs Johnson

Baker

84

Md App

521

581

A.2d

48

52

1990
Here
Plaintiff

and her counsel

skirted

all

debateand

the

law of

this

caseby
her
in

pressing

claims

for

numerous

statements

that

clearly are neither

defamatory

nor

cast

false

light

Then

just

when

it

appeared

the

Plaintiff

was

willing

to

scale

her

lawsuit

back

to

reasonable

proportions

counsel

advised

that

her

claims

will

remain

undefined

until

her

deposition

when know

Defendants

can

glean

her

intent

Just as

breach of contract

defendant

is

entitled

to

what

contract

he

allegedly

breached

and

an

insurance

company
like

is

entitled

to

know

what

personal

injury

it

is

defending

defamation

defendant

WNST
to

is

entitled

to

know

with

specificity

the

allegedly

actionable

words

it

will

be called on

defend

WNST

therefore

asked

the

Court

to

enter an order

under Rules

2-432 and

1-34

limiting Plaintiffs

claims

to

the

18

statements

listed

in

her supplemental

response

to

Interrogatory

No

WNST
with
this

further requests

an

award

of

its

costs

including

reasonable

attorneys

fee

in

connection

request

Ms

Royle

Must

Fully

Answer that

Discovery
is

Relevant

to

Her

Allegation sexual

that

WNST Made
inappropriate

Statements

involved in personal athletes

and/or

relationships

with

professional

Complaint

21b
WNST Ms
that Royles Complaint
is

entitled

to

discovery

related

to

the

absolute

defense of truth

includes

the

sweeping

allegation

that

Defendants made

statements

Royle

is

involved

in

personal

sexual

and/or

inappropriate

relationships

with

professional

athletes

Complaint

21b

Accordingly

WNST
facts

issued

requests

to

Ms

Royle

to

better understand

the nature

of her claim

and

to

discover

relevant to

its

defense

INTERROGATORY NO 21
athletes

Identify

all

former
in

or current

professional

with

whom

you

have

ever

been

inclined

personal

relationship but
staff not or the

sexual
limited

relationship
to

and/or

inappropriate player Baseball

the

relationship or

including
the

any

current
in

or former

member
Hockey

of

coaching

management
National

Major

League

the

National

Football

League

Basketball
the

Association Football league

National
the of

League
the

Soccer

Arena
any

League
affiliate

PGA Tour
such
the

ATP
or any

Major League World Tour

other

NASCAR
professional

minor

leagues

minor
For
dates

league i.e
identified of any

AAA

baseball

and

American

each

person

state their full

name

address

Hockey League phone number and the

and nature Response

such

relationship
contains of several single

Plaintiff

objects

to

this

Interrogatory issues

as

it

interrogatories interrogatory

each involving
in

separate

and
limits

distinct

under the guise

2-421

contravention

of the

imposed by Rule
seeks
to

of the Maryland
to

Rules of Civil Procedure

litigation

The

interrogatory calculated
is

information lead
to

immaterial discovery

the

instant

and

is

not

reasonably

the

of admissible

evidence

Further

the

Interrogatory

overly

broad

vague

and

ambiguous

The

interrogatory

calls

for

speculation

and

conjecture

as

it

does

not

define

the

phrase

inclined

in
Defendants and
Brian

Supplemental Response
relationships responses
to

have

made

false

statements her define claims

about

with these

Nick

Swisher

Matusz

Plaintiff

limits fails to

and

athletes

Furthermore have

as the not

Interrogatory

the phrase
to

inclined
the

in4

and the Defendants

continues
to

supplemented grounds
these or
that

the
this

Interrogatory Interrogatory

define
for

phrase

Plaintiff

object

on the

calls

speculation
Plaintiff

and conjecture
not

Without

waiving

objections

and subject
with

thereto
either

the

has

had

any

inappropriate
as

and

sexual
in

relationships
Plaintiffs

Nick

Swisher or Brian Matusz

to

those words

are defined

Supplemental

Answer

Interrogatory

No 20
Identify
all

INTERROGATORY NO 22
with

former or sexual

or professional
relations of any

athletes

whom

you have
but not

ever had intimate romantic

to

nature
of the

including coaching

limited

any
in

current

or former

player
the

or

member

staff or the

management
Basketball

Major League
the the

Baseball National

National

Football

League

National
the

Association

Hockey
the

League Soccer

Arena

Football

League
of

PGA Tour
leagues

ATP
any

League Major World Tour

other

NASCAR
professional

any

minor
i.e

league

affiliate

such
the

or

minor For
dates

league

AAA

baseball

and

American

each

person

identified of any

state

their full

name

address

Hockey League phone number and the

and nature Response

such relationship
several single

Plaintiff

objects

to

this

Interrogatory
distinct

as

it

contains

interrogatories interrogatory

each involving
in

separate of the

and

issues

under the guise

of

contravention

limits

imposed
seeks
to

by Rule 2-421

of the Maryland
to

Rules of Civil Procedure

litigation

The

interrogatory calculated
is

information lead
to

immaterial discovery

the instant

and

is

not

reasonably

the

of admissible

evidence

Further the Interrogatory

overly

broad vague and ambiguous Answer

to

Supplemental

Response

See

Plaintiffs Supplemental

Interrogatory

No 21 Ms
New
Royles answers are evasive and incomplete
as she
arbitrarily limits

her responses

to

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
in

to

the typographical

error inclined

in

in

Interrogatory

No

20

ignoring
to

the obvious

intended

meaning

apparent

Interrogatory not
relieve

No

21

which

indicates

inclined

in was

intended

be

involved

in

Ms

Royles objection

does

her of her discovery

obligations

10

and/or

inappropriate

relationships

with

professional

athletes.5

Ms

Royle

cannot

pick

and

choose

among

the athletes

about

whom
law

she

will

answer

these questions

Indeed

under

Maryland

her

relationships

with

athlete

is

relevant

and

discoverable

whatever

the

nature

and

whoever

they

are

In

Maryland

statement

is

not

considered

false

unless

it

would

have

different

effect

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

with any

and Related

Problems

138

1980

footnote

omitted

Thus any
and
to

relationship

she

has

athlete

is

relevant

to

the

truth

or falsity

of her allegations

her

reputation

in

the

professional

athletic

community

Because

these

broad allegations

are at

issue

Defendants

are

permitted

to

discover

information

relevant

to

the

allegations

of her

Complaint

and the

Plaintiff

should be compelled

to

answer the interrogatories

as

asked

Ms

Royle

cannot avoid Reporters

her discovery obligations

Shield

by broadly invoking no privilege log

Marylands

Law and
21

providing

Consistent

with

WNSTs

Interrogatory

Nos

and

22

regarding

the

nature

of

Ms

Royles

relationships

with

professional

athletes

WNST
with

also

served

number

of document

requests

intending

to

discover

the

universe

of

athletes

whom

Ms
to

Royle had

relationship

of any

kind

See

Ms

Royles

First

and

Supplemental

Responses

WNSTs
asserts

Requests

for

Production

attached

as Composite

Exhibit

11

However

Plaintiff

broadly

the

Maryland

Reporters

Shield

Law

Md

Code COURTS
and
to

JUDICIAL

PROC

9-112

flatly

refusing

to

produce

single

responsive

document

failing

provide

privilege

log

Notably

while

Plaintiff

attempts

to

limit

her responses

to

Interrogatory

Nos
and

21

and 22

to

Mr

Swisher and

Mr

Matusz

she

provides

no communications

between

her

either

of these

gentlemen

For the sake

of

At the appropriate

juncture

Defendants

will

establish

that

they

made

no such

statement

Ill

brevity

WNST
which

includes

the

requests

at

issue

followed

by

Ms
to

Royles

generic

boilerplate

objection

she included

in

the exact

same

form responding

each request

at

issue

DOCUMENT
any current purposes current
the of this

REQUEST NO
professional

All

documents

and
to

communications
the
is

with

or former question player

athlete

from 2000
includes
the

present

For

the

professional
in

athlete

but

not limited to any

Football

or former

Major League Baseball

the

National

League

National
the

Basketball

Association

National
the of the

Hockey

League
the

Major League World

other

Soccer

Arena
any

Football league

League
affiliate

PGA Tour
such leagues

ATP
or any

Tour
minor

NASCAR
professional

minor

AAA baseball DOCUMENT REQUEST NO 10

league i.e current or former player
to

and
All

American Hockey and

League
with
in

documents
of the

communications

any

member
the All

coaching

staff

or management

Major League Baseball from 2000

current or former

present

DOCUMENT REQUEST NO 11
any player

documents
coaching

and
staff

communications
or

with
in

member

of the

management

the

New York Yankees

current

baseball

organization
All

from 2000 documents

to the

present communications with

in

DOCUMENT REQUEST NO 12
any
or former baseball

and

player

member

of the

coaching
to

staff or management

the

New York Mets

organization

from 2000
All

the

present

DOCUMENT
any current Baltimore
Orioles

REQUEST NO 13
player
baseball

documents
coaching

and
staff

communications
or

with
in

or former

member

of the

management

the

organization
All

from 2000

to the

present communications or management with

in the

DOCUMENT
any current Baltimore

REQUEST NO 14
player
football

documents
coaching

and
staff

or former

member

of the

Ravens

organization

from 2010

to the

present

Response
voluminous Request evidence
information as

Plaintiff

objects

to

the foregoing or

Request
as
it

as

it

is

overly

broad
to

unduly produce The

burdensome harassing vague

documents
that

and

ambiguous
to

requires

Plaintiff

are

unrelated

the
to

allegations lead
to

of the

Complaint

worded
which

is

not

reasonably objects

calculated
to

the

discovery seeks
State

of admissible disclosure of

Further

the
is

Plaintiff

the

extent

this

Request

protected

by the See

First

Amendment

of the United

Constitution
9-1

and the Maryland

Tofani State seeks or

Shield

Law
or

Md

Code

297

Md

165465
be

A.2d 413

Ann 1983
the

Courts
Plaintiff in

Judicial

Proc
to

12
this

objects custody

the

extent of

Request

documents which

information obtained

already

the

or

control

the
less

Defendants

may
less

by

Defendants

more

conveniently

expensively and with

burden than by the Plaintiff

Supplemental
exist

Response
the

To

the

extent

non-privileged or control

responsive

documents

and are

in

immediate

possession

custody

of the Plaintiff they have

been produced

herewith

First despite

her

supplemental

response

the

Plaintiff

has

produced

communications

12

between

her and

professional

athlete

Second

despite

her

assertion of reporte

privilege

Plaintiff has

refused

to

provide

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-Pacl

Inc

351

Md
100

396

415

1998
441
the

see

also

Maxima

Corp

6933

Arlington

Development

Ltd

Partnership

Md.App
with

456

1994 Ms

Royles

general

assertion

of privilege

without

more

fails to

comply

requirement

of Rule 2-422

that

party

fully

state

with

specificity

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
failure to

100

Md

App.at

457

Indeed

one court applying

Maryland

law has held

that

partys

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
to

Maryland

courts

have

not

specifically

addressed

the

reporters

privilege in responding

civil

written

discovery

However

in

assessing

the

invocation

of the

reporters

privilege

in

depositions

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
the

In particular

Discovery

Guideline

5c
identify

provides

that

where

claim of privilege

is

asserted

party invoking

the privilege

must

with

specificity

the

nature

of the privilege

together

with

the type

of document

the

general

subject

matter

the

date

of the

document

and

such

other

information

as

is

sufficient

to

identify

the

13

document

for

subpoena

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
fails to

In this

case

Plaintiffs

boilerplate

assertion

of reporters

privilege

provide

this

particularized

justification

for asserting

privilege

See Mezu

Morgan

State

University

269

F.R.D 565 577 make

Md 2010
challenge

With

no privilege log

WNST
directly

has

been denied

the opportunity

to

meaningful

concerning

information

relevant to

her claims

and

WNSTs
requested

defenses

For these

reasons

this

Court

should

compel

Plaintiff

to

produce

the

documents

or

alternatively

to

produce

privilege

log

containing

the

information

called

for

in

Discovery

Guideline

5c
Royle Must Provide

Ms
WNST
inspection

WNST
provide

With Her Complete Facebook

of her

Account

requested

that

Ms

Royle

access

to

all

Facebook

accounts

for

and copying

DOCUMENT
mutually

REQUEST NO 33
place

Produce

for access

inspection
to all

agreeable

and time complete

copying at Facebook.com accounts

and

within your control

Response
burdensome evidence
in

Plaintiff

objects reasonably seeks

to

this

Request
to

as
to
is

it

is

overly discovery

broad

unduly

and

is

not

calculated information

lead

the not

of admissible
the allegations

Further the Request

which

relevant to

the

Complaint

Supplemental
are in

Response

To

the

extent or

non-privileged controL

responsive Plaintiff they

documents have been

the

immediate herewith

possession

custody

of the

produced

Instead

Plaintiff

reinterprets

this

straightforward

request

by

applying

an

arbitrary

distinction

She produced

complete copy

of her professional

fan

page

on Facebook

but flatly

refuses

to

provide

any information

regarding

her

personal Facebook

page
has

See

Ex

Despite

the

fact

that

her

counsel

has

represented

that

Plaintiffs

personal page

been download9d

14

that

information

is

being

withheld

without

any

cognizable

objection

Plaintiffs

arbitrary

distinction between

professional

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
is

as

well

as photos

status

updates

or other

information

evidences

such relationships

WNST
any

entitled

to

discover

that

information

Moreover

if

Ms

Royle has

communicated

with

of her

colleagues

or

friends

on

her

personal
she

Facebook

page

about

her

work

as

journalist

or

other

issues

relevant

to

her

lawsuit

has

no

greater

right

to

protect

such

communications

because

they

were

made

through

her

personal

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
See

the

public

and among the

professional

athletes

she

covers

have been endangered

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 deems

are highly

relevant

to

her

reputation

and credibility

in

the

community

even

if

she

the

site

personal

Finally

the communications

Plaintiff

makes

are

all

highly

relevant to

her frame of

mind and thus

to

the emotional

damages

she

claims

Complaint
between

35

and

55
and

For

all

these

reasons

Ms
is

Royles

arbitrary

distinction

her

personal

professional

Facebook

pages

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
has

Plaintiff

also refers

to

documents

and communications

with

identified

individuals

but

refused

to

produce those

documents

Plaintiffs

responses

therefore

remain

evasive

vague

and incomplete

INTERROGATORY NO
other

Identify

all

communications
to the

between

you and any

to the the
to

persons

including
in

but

not

limited
to

Defendants

relating

statements
date

identified

your answer
by

Interrogatory

No
was

For each
authored the the

identify

of the
the

communication communication

whom

the

communication
all

or

made

whom

was addressed was made

to

those or

who
in

received

communication of the

whether

the

communication

orally

writing

substance

communication

and any response

the

communication

Response
interrogatories interrogatory
in

Plaintiff

objects

to

this

Interrogatory
distinct

as

it

contains

several single

each

involving

separate

and
limits

issues

under the guise

of the

of

contravention

of the

imposed
as

by Rule 2-421
is

Maryland vague
the
it

Rules of Civil Procedure ambiguous

as well

The

interrogatory
as

worded

overly does
to

broad
define

and

as unduly

burdensome

the Interrogatory
to this

not the

term
seeks

communications
information doctrine

Further by

Plaintiff

objects

Interrogatory

extent

protected

the

attorney-client

privilege
to

and the

attorney

work-product
prepared

Without
to

waiving
the

and

subject

said

objections

Plaintiff

correspondence
Plaintiff

Baltimore Ravens
with colleagues

organization

on or about
at

August and

14 2010

exchanged
telephone the

emails

and management on
is

MASN

CBS
13

as

well

as

conversations

beginning

approximately

January reserves

2011

regarding
to

Defendants
or

conduct

As

discovery
to this

ongoing

Plaintiff

the right

supplement and

amend

her response

Interrogatory

Supplemental
objections control
to

Response
the

Without

waiving
is

and
the

subject

to

Plaintiffs

original

the extent Plaintiff

correspondence have of the been

letter

in

immediate

custody

possession

or

of the

copies

provided
to

See

PRDR

000070-000071
staff

000076-000078 The
included
to

recipients Patrick

the

Raven

Public

RelationsMedia exchanged

Chad

Steele

Gleason and Kevin

Byrne

Plaintiff

emails

16

with

Jim Cuddihy
Plaintiff

of

MASN
Bader
the
for

on or about

January

13 2011

regarding

the

Defendants on or
to

conduct
about

emailed Greg
refers

Greg

Bader of the Baltimore

to to

Orioles

Organization
directly

6/11/2011
Plaintiff to

responded Defendants

the

email

with

an email and

Ms

Royle

Plaintiffs

Original

Supplemental

Responses

Requests

Production

of Documents

and Exhibit

Here

her

supplemental

response

fails

to

provide

documents

and supporting

information

about the

e-mails with

colleagues

and management

at

MASN Ms

and

CBS

as

well

as telephone

conversations.

.regarding

Defendants

conduct

Although

Royles

counsel

advised

that

the

only

correspondence with

MASN py

was one

e-mail

to

Jim Cuddihy which

has

been provided

Ms
her

Royle

failed

to

provide

correspondence

or

information

regarding

conversations

with

colleagues

at

CBS

including

the

names

of the individuals

with

whom

she

spoke

or the

dates and substance

of those communications

INTERROGATORY NO 10
have
in

Describe
as

in

detail

any

damages you contend

statements
belief that

to

suffered

to

your reputation
to the

proximate

result

of the for

identified those

your answer statements were

contend have

Interrogatory proximate
of

No
loss

the

reasons
loss

your
all

cause of any such

identify

persons

who
state

you
the

knowledge

such

and

for

each

person

identified

substance

of that

persons knowledge
contains several single

Response
interrogatories interrogatory

Plaintiff

objects

to

this

Interrogatory
distinct

as

it

each involving
in

separate

and
limits

issues

under the guise

of the

of

contravention

of the

imposed
as
it

by Rule 2-421
is

Maryland vague
all

Rules

of Civil Procedure
as

The

Interrogatory as

worded
for

overly
to

broad
identify

and

ambiguous
with

well

as unduly

burdensome
facts

seeks
to

Plaintiff in

persons she has the

to

personal

knowledge of
their

of the existence

relevant

the issues

the case
to

even

if

no knowledge Defendants
called into
that

Without
Plaintiffs

waiving

and subject

said objections reputation

to

actions

have

caused

professional

and personal

be

question Defendants

conduct has had sexual

with the

caused

members of

the public

believe or

she

is

bitch
by these
result

liar

and has

relationships professional has

with Nick
she
to

Swisher and/
covers has

Brian

Matusz

Plaintiffs credibility
false

athletes

been
to

endangered
others as

assertions

and

she

been

forced

explain

herself

of the Defendants

false

statements

Similarly

here

despite

multiple

requests

Ms

Royle

refuses

to

identify

the

individuals

who have called

into

question

her

professional

and personal

reputation

the

members
is

of the

public

who

believe

that

WNSTs

actions

caused them

to

believe

that

Ms

Royle

bitch

or

liar

or

whom

believe

that

she

has

had

sexual

relationship

with

Nick

Swisher

and/or

Brian

Matusz

Ms

Royle has

also failed

to

identify the

professional

athletes

she

covers

with

whom

her

credibility

has

been endangered

nor the unidentified

others who

Ms

Royle

contends

that

she

has been forced

to

explain

herself

to
in detail

INTERROGATORY NO 12
identified in

Describe

any

damages other than

suffered

those as

response
of the

to

the

preceding

interrogatories in

by

you

proximate
the

result for

statements
belief that
all

identified the

reasons loss

your

your answer to Interrogatory No such statements were the proximate cause of

contend have

any

such

identify

persons

who you

knowledge
persons

of such

loss

and

for each

person

identified

state the

substance

of that

knowledge

Response

Plaintiff

refeis

to

and

incorporates

her

Answers

to

Interrogatories

Nos

10

and 11

First to

Supplemental

Response
10

Plaintiff

refers

to

and incorporates Defendants

to

her Answers the

Interrogatories
in

Nos
to

and

11

Plaintiff

refers for

the

documents
Plaintiff

attached reserves

response
to

Defendants
her

Request

Production

of Documents

the right

supplement

Answer

Second
supported

Supplemental by the

Response comments

Plaintiff

has

suffered

reputational held

damages by fans
has

as

negative

tweets

and

general

opinions

who
been

have heard
called

and believe

the statements

identified herein Additionally

Plaintiff

slut

bitch

and other insulting names by fans

who

have heard

or read the

Defendants

statements Exhibit

See Responses

to

Requests

for

Production

of Documents

and

Supplemental

Finally

here

Ms

Royle

fails

to

identify

the

fans

who

have

heard

and

believe

the

statements

identified

herein

and

fans

who

have

heard or read the Defendants

statements

who

allegedly

called

Ms

Royle

slut bitch
Interrogatory

or

other

insulting

names
refusal

Similar

to

the

deficiencies

with

her answers to

Nos

and 10

Ms

Royles

to

specifically

identify

these individuals

creates

virtually

limitless and impossible

universe

of witnesses

from

which

she

might

call

upon

to

testify

18

II

In Addition Within 10

to Ordering

Ms

Royles Compliance With

Should

WNSTs

Discovery

Requests Attorneys

Days

This

Court

Award Costs

Including

Reasonable

Fees

Ms
litigation

Royles

continued

reftisal

to

provide

documents

and information

at

the

core

of this

has

set

back

WNSTs
made

evaluation

of her claims

and the preparation

of

its

defense

As

detailed

above

WNST
the

numerous

efforts

to

amicably

resolve

these

discovery

disputes

inconveniencing

Court

Since

WNST
with

has

been forced

to

seek

redress

from

this

Court

Ms

Royles

continued

failure

to

comply

her

discovery

obligations

inhibits

the

trial

courts

inherent

authority

to

manage

its

affairs

and achieve

an orderly

and expeditious

disposition

of

cases See Hossainkhail

Gebrehiwot

143

Md App
courts

716 728

2002
to

After

granting

motion

to

compel

have broad discretion

determine

appropriate

sanctions

on the violating party

River

Ins

Co

Mayor 391
396-97

City

Council of Baltimore

343

Md
trial

34

47

1996

Braxton

Faber

91

Md App

1992

In imposing

sanctions

courts

have considered

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
to

continues

to

be prejudiced

by them

Accordingly

sanction

of some

kind

is

necessary

prevent

Plaintiff

from

continuing

to

frustrate

WNSTs
To
begin

defense

of her lawsuit

with

pursuant

to

Rule

2-43

the

Court

should

issue

an order

prohibiting

Plaintiff

from introducing

into

evidence

any materials

she

has

not provided

for

Defendants

Rule

2-433a2

See

also Attorney

Grievance

Commn

of Maryland

James

385

Md

637

659-

612005exclusion

of evidence

as

sanction

was warranted

where

partys

failure

to

provide

timely

discovery

failed

to

give

opposing

party

adequate

time

to

review

and

prepare
37

Storetrax.com

Inc

Gurland 168

Md

App

50
the

89-90

895

2006

affd

397

Md
to

2007
is

the

damage

in

withholding

evidence

despite

remedy

available

in

motion

compel

unfair

surprise

Ms

Royles

failure

to

provide

documents

and

information

material

to

her

claims

including

the

identity

of the

fans

and professional

athletes

whom

she

alleges have

information

substantiating

her

reputational

damage

deprives

WNST
43-44

of

its

ability

to

reasonably

mount

defense See Helman

Mendelson 138

Md App

29

2001
costs

Irrespective

of the

relief

it

orders the Court should award

WNST
to

and fees

If

the

Court finds

failure

of discovery

it

shall require the party

to pay

the

moving

party

the

reasonable

expenses

incurred

in

obtaining

the

order

including

attorneys

fees unless

the

court

finds

that

the

opposition

to

the

motion

was

substantially

justified

or

that

other

circumstances

make

an award

of expenses

unjust 2-433

evasive

or incomplete

answer

is

to

be

treated as

failure

to

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
633

is

within

the sound

discretion

of the

trial

court See Mullaney

Aude

126

Md.App 639
Her

1999
responses
to

Here

Plaintiffs

responses

were

plainly

inappropriate

deficient

interrogatories

even

as

supplemented

as well

as her evasive

document

production

and improper

invocation

of privilege

clearly violate

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
the
Plaintiff shall

That

within

10

days

answer

Interrogatory

Nos

21

and

22

regarding

her

involvement

in

personal

sexual

and/or

inappropriate

relationships

with

professional

athletes

That

within

10

days

the

Plaintiff

shall

produce

all

documents

responsive

to

Document

Request

Nos

10 11 12 13

and 14

or alternatively

if

she

asserts

the

reporters

privilege

that

she

produce

privilege log consistent

with

Discovery

Guideline

5c
and copying
her

That within

10

days

the

Plaintiff

shall

produce

for

inspection

personal
Facebook

Facebook

account

or

alternatively

produce

her

complete

downloaded

personal

account

21

That within

10

days

the

Plaintiff

shall

identify

the

unnamed

individuals

within

her responses

to

Interrogatory

Nos
is

10

and 12

That

Plaintiff

prohibited

from introducing

into

evidence

any materials

she

has

not provided

to

the Defendants

within

the

10

days

provided

in

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

Pursuant
to

2-43

Rule 2-431 counsel

for

Defendants made good

faith

attempts

to

discuss

with

Ms
are

Royles

counsel

the

resolution

of the disputes

described

herein and

certify

that

the parties

unable

to

reach

agreement

on the

disputed

issues

The

parties

conducted

two

telephone

conferences

seeking

to

resolve

the issues

raised by Defendants

in this

Motion

on the afternoon

of

June

15 2011

for

approximately 30 minutes

and again

on the

afternoon

of July

15 2011

for

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
Charles

KNIGHT LLP

Tobin

Drew

Shenkman

2099 Pennsylvania Washington 202-955-3000 202-955-5564

Ave N.W
20006

Suite 100

D.C
Fax

Phone

charles.tobin@hklaw.com

drew.shenkman@hklaw.com
Counsel for Defendants

hereby

certify

that

on

this

26th

day of July 2011

copy

of the foregoing

was

sent

via

First

Class

Mail

postage

prepaid

to

HODES
Brian

PESSIN

KATZ
Esq Road

P.A

Goodman

Alexandra
901

Moylan Esq
Suite 400

Dulaney Valley Maryland

Towson

21204-2600

Counsel for Plaintiff

4c1/4v92c

23

EXHIBIT
July

18 2011

Letter

from Plaintiffs Counsel

H1PIK
HODES
90
OULANEY VALLEY

PESSIN
at

KATZ P.A
Low
ICAMBRIDGE

ROAD TOWSON

Attorneys
COLUMBIA

00 MD

TELEPHONE 410-938-8800 FAX 410-832-5600

2204

ISELAIR

WWW.HPKLCGAL.COM

Brian
WRITERS

Goodman
NUMBER 410 938-8705
E-MAIL

DIRECT DIAL

WRITERS

DIRECT

bgoodmanhpkIegaIcom

July

18

2011

VIA E-MAIL

charIes.tobinQihMaw.com

AND REGULAR
Charles Holland

U.S

MAIL

Tobin

Esquire

Knight LLP

2099 Pennsylvania Washington

Avenue
20006

N.W

Ste

100

D.C

Re

Jennifer

Royle

NASTY

1570 Sports

LLC

et

al

Case

No

24-C-11001571

Dear

Mr

Tobin

send this

letter

pursuant

to

the issues

discussed in our teleconference

on July

5th

2011

As
possession

an

initial

matter we and control

have

provided your

all

responsive

documents

in

our

immediate

custody

answering
will the

discovery
to for

requests

on three separate occasions upon

matter
the
is

The

Plaintiffs

discovery

responses

continue deadline

be

supplemented
in this

receipt

of

additional

responsive

documents

given

discovery

February

21

2012
Facebook.com
Plaintiff are

Moreover
every and/or individual

the

Plaintiffs

personal the

account

information
inclined

and

the

names of
sexual the
as

athlete

with

whom

has

ever been
to
to

in

personal

inappropriate
in

relationship

with

not

relevant relate

and

have

no bearing

upon

allegations

the

Complaint

Plaintiffs

allegations

her professional

reputation

To
production
the the

the

extent

that

the

information information

sought

in

Interrogatories collected

No
as

21
part

and of

22
the

is

related

to role

and/or
as

seeks

the

of

confidential

source
is

or information and protected

Plaintiffs

member

of of

media

such

information

confidential

under
court

9-112

of

the

Courts
the

and

Judicial

Proceedings of
confidential that

Annotated

Code

of by

information
is

collected to

As you well know Maryland member of the press including

legal

cannot

compel
clear

admission convincing

her sources

without

and

evidence

it

relevant

significant

issue

HODES
Charles

PESSIN

KATZ P.A

Tobin

Esquire

July 18 2011

Page

journalist The
the

allegations

regarding

relationships

with

professional athletes Brian

are

limited

solely

to

Defendants
and

defamatory

statements

concerning

Matusz

of

the

Baltimore See

Orioles

organization

Nick

Swisher

of the

New

York

Yankees
whether with

organization personal

Supplemental inappropriate

Answer
intimate
irrelevant

to

Interrogatory
or

No 21

Thus any
that

relationship

sexual
if

romantic
to

otherwise the Plaintiff

the Plaintiff

has/had

other athletes

any

is

wholly

whether

has had such

relationship

with

Mr Matusz

and

Mr

Swisher

With respect
control sent

to

the Plaintiffs have

medical

records

all

records in the possession

custody or

of the Plaintiff

been produced and requests

We
for the

have followed
records

up with

Dr Liebman
health

and have

executed

authorizations

of the following

care providers

Dr
1205

Samuel Liebman
Associated

Psychology Consultants York Road

PA

21

Lutherville

Maryland 21093

William
Internal

Goldiner Medicine

lvii

120

Sister Pierre

Drive

207

Towson
Charles

Maryland 21204

Paulino

D.O
Group

West

Side Medical

PC

314 W.l4thStreet

New York
Diagnostic

NY

10014

Radiology 17th Street

Associates

230 West

New York
Chelsea

NY

10011-5325

Otolaryngology

William Portnoy
160

West

18tb

Street

New York
Upon
provide
receipt

NY

10011

of additional
Plaintiff

responsive
will

records

not produced blanket

hereunto we

will

certainly

copies

However

not execute

authorization for the unfettered use

of the Defendants

256936-1

HODES
Charles July

PESSIN

KATZ P.A

Tobin
2011

Esquire

18

Page

Further

you have refused

that
it is

to

produce despite

the

Defendants Facebook.com
request for such

account

information In

on the grounds
faith

not relevant the relevant

the Plaintiffs

documents
that

good

attempt

to

obtain

responsive with

documents

we

request

the

Defendants

supplement including

their

discovery limited

responses

but

not

to the
It is

account information any professional Facebook.com and place page as well as WNST.net organization page inexplicable
that

Defendant Aparicios fan page

Clark and Forresters
that

you

refuse

to

produce

Defendant

Aparicio

personal
entitled related

Facebook.com
to to Plaintiffs

account personal
in

information

on the grounds
account and

of relevancy

and claim
contains

you

are

Facebook.com
the Complaint

information
is

which
for

no information

the

allegations

which

used

solely

non-professional

purposes

The
searching days

twitter

records

produced responsive posts

by Defendants
information
twitter are

are

incomplete simply

It

appears tweets
in

that

rather

than

for

the relevant the

you

produced

from
the

certain

surrounding

blog

and
there

posts

previously tweets
to that

identified

Plaintiffs to

discovery

responses

We

believe

additional

would be responsive
blogs
relating to

the

Plaintiffs discovery

requests

Furthermore

we

continue

discover

the Plaintiff
to

on the website which you have

operated
failed

and maintained
to

by Defendant
indicates that

WNST
you
have responsive

and

readily to

accessible perform

you

produce
databases

This
for

failed

detailed

search of the Defendants

the requested

documents

and information

Given the
related to

foregoing

and

attached

hereto

Plaintiff

has

produced
to

the

all

information

her profesional

Facebook.com
account

fan page
as

look well

forward
as the

receiving the Defendants blog posts and

twitter

professional

Facebook.com
in

information

relevant

posts requested

the Plaintiffs

discovery

responses

Finally

have

received

and reviewed confirmed was

your
that

letter

to

me

of July

15 2011
to

It

is

incorrect

What we
constitutes will to

discussed

and what which

Supplemental
are additional

Answer

Interrogatory statements

No
you

statements

are

actionable

If there

actionable

glean this in the Plaintiffs Interrogatory

deposition

and we will of course supplement

continued reference
to

Plaintiffs

Answer
1-341
is

No

accordingly

Your

Maryland

Rule

inappropriate

and misplaced

Sincerely

Brian

Goodman

BSG/mjc cc

Ms

Jennifer

Royle

Alexandra

Moylan

Esquire

256936-1

EXHIBIT
June 2011 Order

JENNIFER

ROYE

INTETE CIRCUIT

Plaintiff

COURT

vs
NASTY 1570

FOR BALTIMORE CITY

SPORTS

LLC

et

al

Defendant

.s

Case

No

24.-C11001571

ORDER
Upon
docket no
consideration

of the Defendants

Motion

to Dismiss

Counts

II

and IV

17

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
amend

that Counts

II

and IV are

rPUE In

Cfl
DISMISSED

with prejudice

with no leave

to

EXHIBIT
June 2011 Hearing Transcript

IN FOR JENNIFER

THE

CIRCUIT

BALTIMORE

CITY

COURT MARYLAND

ROYLE
Plaintiff
CASE

NO

24C-ll--001571

NASTY

1570

SPORTS Defendant

LLC

_____________________________________________________/

OFFICIAL

TRANSCRIPT

OF

PROCEEDINGS

Motion

to

Dismiss

Baltimore

City Maryland
2011

Friday June BEFORE

THE HONORABLE EVELYN OMEGA

CANNON

Judge

APPEARANCES
For
the

Plaintiff
ALEXANDRA

MS
For the

MOYLAN

ESQUIRE

Defendant
DREW

MR MR

SHENKHAN

ESQUIRE

and

CHARLES

TOBIN ESQUIRE

Audio

Transcribed

By

Erika

Newton

TABLE

OF

CONTENTS
COMPANY
Virginia

HUNT REPORTING
Court Reporting
Serving

and Litigation Support

Maryland Washington and 41 0-766-HUNT 4868 -800-950-DEPO

3376

CALL OF THE

CASE

M3

PLAINTIFF
WITNESS None DIRECT CROSS REDIRECT RECROSS

offered

DEFENSE WITNESS None DIRECT CROSS REDIRECT RECROSS

offered
EXHIBITS

PLAINTIFF EXHIBITS None

IN

EVIDENCE

offered

DEFENSE
EXHIBITS None
IN

EVIDENCE

offered

MOTION by by

ARGUMENTS

MR MS

TOBIN MOYLAN

M5
M12 M21

JUDGES RULING

PROCEEDINGS
HUNT REPORTING
Court Reporting
Serving

COMPANY
Virginia

and Litigation Support

Maryland Washington and 410-766-HUNT 4868

1-800-950-DEPO

3376

111652
THE Jennifer Royle

a.m
This
is the

COURT

Okay
1570

case

of

vs

Nasty

Sports
identify

LLC

Case

No

24-

C-ll-001571

Counsel

please Good

themselves

MS MOYLAN
Alexandra Moylan THE
this on

morning
of

Your

Honor

behalf Was

Ms

Royle
entered
in

COURT

your appearance

case

MS MOYLAN
19th
THE

It

was

It

was

entered

on

May

COURT

As

in

paid

--

how

much

is

the

fee

now MS
not quite MOYLiAN believe
it was $10 or

$15

Im

sure
THE

COURT

No

it was It

more
to

than

that how

if

you
is

entered
it

your

appearance

use

be

$15

much

now MR
SHENKMAN

Im
Its

not
the

sure
same

MS MOYLAN
Pessin THE personal

firm

Its Hodes

COURT
is

Its not
entered

the

firm

Its your name

appearance

Whats Moylan
is

your

MS MOYLAN
THE Did you

Alexandra

COURT

Your appearance

not

entered

personally

enter your personal

appearance

HUNT REPORTING COMPANY

Court Reporting
Serving

and Litigation Support

Virginia

Maryland Washington and 41 0-766-HUNT 4868

1-800-950-DEPO

3376

MS
THE

MOYLjAN

Yes When
It

Your

Honor

COURT

MS MOYLAN
THE

was did

done

on May

19th

COURT
MOYL2AN

Who

it
did

MS
THE

My office You sent

it
down here
to do

COURT

somebody

it MS MOYLAN
THE show
that it

believe
So

it was

mailed
any evidence
to

COURT
actually

you

dont have

got

here sorry
did not bring

MS MOYLAN
copy
of

Im
Okay

it
THE

COURT time

Im

sorry

Give

me your

name

one

last

MS MOYLAN
O-Y-L--A-N THE

Sure

Its

Alexandra

Moylan

COURT
SHENKMAN
of

Okay
Good

And

Counsel
Your

MR
Shenkman appearing

morning

Honor
me

Drew

on behalf
or
--

the Defendants pro hac

and
is

with

appearing
Is

vice

Chuck

Tobin
entered

THE

COURT

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facts
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argument

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our motion
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Count

intentional

infliction

emotional

distress
Your

Honor my clients HUNT REPORTING

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COMPANY
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employees here
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of

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radio

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an

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Royle
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CBS WJZ
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filed by

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sportscaster
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grounds
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our motion

today
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are

that

emotional

distress

tort in Maryland opportunities

for the to

highly her
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our answering does not facie meet

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claim for

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We they
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our argument
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and
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three separate

elements
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cause
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action

Number

one
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the

conduct alleges

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oral

communications

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second law

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claim

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case
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personal
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relationship

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Plaintiff has not alleged

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the

severity

of

harm

required
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to

satisfy high severe

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Maryland

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threshold and

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distress

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does not plead

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Finally Your Honor

to

there were
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no

support

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allegation

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performs

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medications
today
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HUNT REPORTING COMPANY

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There

has

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HUNT REPORTING COMPANY

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that
we

therefore

drawn

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Ms

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radio personality Falwell Hustler

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severe
her

debilitating

emotional

distress
the

that

would

disable

from her daily

life under

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So
Honor
today

for

those asking what

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for

independent
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Your

Honor

MS
Counsel
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MOYLjAN that
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correct

Motion

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in

light publication
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facts
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reason

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Defendants
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were

being

sniffed

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complaint February

that

the Defendant

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treatment

HUNT REPORTING COMPANY

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Shes

changed

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HUNT REPORTING COMPANY

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Lets assume
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-800-950-DEPO

3376

given

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MS MOYLAN
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She was she was found

suffered found
--

from an there was

existing

testimony

she was

at

home

inaudible

her
of

hands crying
her emotional
of

there was

significant

deterioration take

state

She was
for

required to

greater and

amount

prescriptions

her nervous
to

condition

relatives

had
THE

to

help

her
In

tend other

her household
she

chores
not

COURT
of

words

could

function

as

part

daily And

living

MS MOYLAN
THE

if Your Honor

is

inclined
get to

COURT

No

Its

not

me

dont

HUNT REPORTING COMPANY

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make

it

up
not the
in

really charge

dont
of the

am not world
--

--

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on to the

to in

say

Im
of of

but

Im

charge Court
it

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get

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deciding what

dont
whether

make

up

and

Im
what

not

or not

behavior

was

appropriate
to

but you

youve alleged

doesnt come

close

just

described
And

MS MOYLAN
to to

if Your Honor

is

inclined
for

grant

the Motion

to

Dismiss we would

ask

leave

amend
THE

COURT
you had

No

Why

would
to

you

have

anything have leave

to

amend

If

anything

say you

would

said
to

it

No
for

No
what

On what

basis would

there be

amend

MS MOYLAN
saying that
it fails to

To

provide

--

if of

Your Honor action

to to
--

is

state

cause

THE

COURT
going
to

What happen We
the

are you

going

amend

it

to

say

Whats

thats going
include and

change

it

MS MOYLAN
in the

would

the --

allegations

affidavit THE

of

statements
it

COURT

But

doesnt come close

just gave what me an

to

what
of

youve just described

severe emotional

You

example

distress You

and have

youve described
to if she

doesnt come close

close

nothing

show
the

that

comes was

And

again

Im

not

deciding that

behavior not

appropriate

Im

not

deciding

was

harmed

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Thats not what is whether

emotional see
to or

is

before

me right

now

The

question
of

not

theres intentional
has

infliction

distress

been

adequately
to just

pled
it

dont

it
do

dont
the

get

chance

make

up it

Ive

got

what

law

says
Thank And assume and

dont
Your
to

see

MS MOYLAN
THE Court
in

you
want

Honor
very

COURT

be

clear
the

The

ruling can

that

everything that

Plaintiff lawyer what her

to

said in her complaint argued lawyer put

this is

everything
in

her

true
is

Including
to

fact

actually
the

argued
out at of

intent
and

that so

it was

intention

her

business

she

wouldnt be doing
that that

work
just

all
the

mean
facts

assuming support

and

Im

just

--

lets
matter grant and

assume

inference
cannot

No

what

still
to

theres no way
Dismiss

this

Court
the

the Motion think but

mean
with

most obvious
of the

there are problems the most obvious Severe

is

some
is it

other

elements severe

elements

theres not
really is

infliction

--

mean

different infliction

tort
of

It

not

damages

Intentional mean emotional

emotional

distress

does not and

damages

Thats not what

what
is

it means
is

thats
is

essentially harm but not

the

pled

saying Court

there
is

emotional

thats not what tort

The
tort

the is

deciding
more and
in

Thats

substantially

think

the example

given

by

Plaintiffs

Counsel

terms

HUNT REPORTING COMPANY

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3376

of

the

case

where that able

to

somebody that

was be

really disabled
--

from
fact that

functioning someone
of to is

would

mean
of

the

continue
to go

with

all

their activities help

is

daily seek

living and medication in fact tort but

and

seek
if

professional another
tort

and

may mean person does not

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that could
at

proved
another

the it

recover come

damages close
do to

under

all

intentional
all

infliction
will

just

doesnt

it
to

So

for

those

reasons

grant the

Motions

both

Counts

Okay

Thank

you
Thank

MR TOBIN

you

Your

Honor

Pause
MR
TOBIN
Your

Honor we submitted

an

order

THE order

COURT

Well Whether

do do

my own

--

see your

inaudible MR TOBIN

your order or my order

Okay thank
Thank Thank

you
Your And

MS MOYLAN
THE Counsel

you you

Honor
appreciate

COURT

argument

MS MOYLAN MR
TOBIN

Thank Thank

you
you

Your

Honor

very

much
concluded
at

Whereupon

the proceeding

114221

a.m

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4868 3376

EXHIBIT
Plaintiffs Initial Interrogatories

Responses to and
First

WNSTs

Exhibit

JENNIFER ROYLE
Plaintiff

IN

THE

COURT
FOR

NASTY

1570

SPORTS LLC

et

BALTIMORE
CASE

CITY

Defendants

NO 24-C-11001571

PLAINTIFF JENNIFER

ROYLES ANSWERS AND RESPONSES TO

WNST SPORTS MEDIA LLCS FIRST SET OF INTERROGATORIES AND REQUESTS FOR ADMISSION

NOW COMES Jennifer

Alexandra

Royle

Plaintiff

by her attorneys Katz

Brian

Goodman

and

Moylan
to her

of

Hodes

of

Pessin

P.A
one

answers

the

Interrogatories

propounded
follows

by

WNST

SPORTS

MEDIA LLC

of Defendants

and

states

as

INTRODUCTION
The information supplied knowledge
of the in these

Answers
the

is

not based
of the

solely

upon

the

executing

party

but includes privileged

knowledge

partys

agents

representatives

and attorneys

unless

The word usage

prepared executing
these

and sentence
does

structure

is

that

of the

attorneys exact

who

in fact
of

Answers and language

not purport

to be the

language

the

party

The
with
the

Interrogatories

have

been
plain

interpreted

and usage

answered and
to

in the

accordance
extent not the

Federal

Rules

of

Procedure
the

English

specifically

challenged

by objection

definitions

and

instructions

included

with

Interrogatories

GENERAL
Plaintiff

OBJECTIONS
to the extent the

objects

to

each

and

every

Interrogatory

Interrogatory of litigation

seeks

work product information

or materials

prepared

in contemplation privilege or the

information or communications
or

protected

by the attorney-client

information opinions

communications impressions

protected conclusions

by
or

the

accountant-client of the

privilege Plaintiffs

mental

legal theories

attorneys

accountants

or other

representatives

Plaintiff

does

not waive

any

protections

or

privileges of any

these

Interrogatories

Inadvertent
of

production
privilege or

or exposure

such

to by responding document shall

not constitute
objection to the

waiver

such
of

admissibility

such

immunity or of any other ground of documents or of any information contained

therein

Plaintiff

objects

to

each
is

and

every

Interrogatory to
this

to

the

extent

the
is

Interrogatory

seeks

information that
to lead

not relevant

case

or information that in this case

not reasonably

calculated

to the

discovery of admissible evidence

Plaintiff

objects

to

each unduly
extent the

and

every

Interrogatory

to

the

extent

the

Interrogatory

is

overly

broad
to the

burdensome
that the of

harassing

repetitious

vague
the

and/or

ambiguous

and

Interrogatories

purport

to require the

disclosure

of information

beyond

scope

admissible evidence

under

Federal

Rules of Civil Procedure

Plaintiff

objects

to

all

Interrogatories

and
duties

to

the

definitions or alter

and
the

instructions duties

set forth therein to the the

extent

they impose

which exceed

imposed by

Maryland Rules

of Civil Procedure

Plaintiff to any and all interrogatories to the extent objects contain multiple unrelated subparts within numbered interrogatory single

that

they

in violation

of

Maryland

Rule

2421

and/or

all

interrogatories

to

the

extent

they

exceed

30

interrogatories

Plaintiffs

objections to

and

answers

to

the

lnterrogatories

are

based

on

information
right to

now
That
as

available

Plaintiff

and

are

made

without

prejudice additional

to Plaintiffs

assert

additional
Plaintiff

objections

should

Plaintiff

discover
is

grounds

for

objections be construed

has answered

any any

Interrogatory to

not intended

and shall not

waiver

by

Plaintiff

of

objection

any Interrogatory

Plaintiff Plaintiff

has

not yet completed

file

discovery in this lawsuit

and

therefore
additional

reserves

the

right to

supplemental

Answers

if

and when such

information comes into her possession

234620-1

By
objections to
its

providing admission

the

information

requested grounds

Plaintiff

does

not

waive
or

into evidence for objections

on

the

of relevance

materiality

on

any

other

proper grounds

Plaintiff

objects

to

all

Interrogatories

to

the

extent

that

they

call

for

documents and/or

which concern
material

confidential

business

records

trade

secrets

business

plans

other

which would

allow the

Plaintiff

and/or

third persons

to obtain

competitive information

Plaintiff

objects

to

all

Interrogatories

to

the

extent that

that

they seek

all
all

communications communications

and
or

all

documents

on

the

ground

she

cannot

know

documents which may

or

exist

No
Plaintiff

incidental

implied That

admissions

are

intended

by

an

answer
is

by

to

any Interrogatory
that
Plaintiff

Plaintiff

has answered any Interrogatory

existence of

not an

admission

accepts or that

or admits the the

by such
evidence

Interrogatory

making

such

any facts set forth an answer constitutes

of

or

assumed

admissible

Neither production

Plaintiffs

agreement
or as

to

produce
or

nor

her

objections of

to

the

of
is

any
to

information be construed

documents an

any
or

category

information or
that

documents

admission

acknowledgement

any

information or documents exist within such category

or categories

Plaintiff

objects

to

any

Interrogatory protected

to

the

extent

that

it

requests

disclosure

of information

banned and/or

from

disclosure

by law

Plaintiff

makes

these

answers

subject

to

the

reservation action of

of her

right to or

object

to the

introduction into evidence herein

or

in this or

any other

any information
including

material limited

contained

produced hereunder

to relevancy

materiality

upon any ground and hearsay competency which

to

but not

Plaintiff

objects

to of

Interrogatories

in

party has

provided
the

their of

interpretation

of the

meaning

document

or purported

summarize

contents

document
allegations

in variance

of the of

actual

terms contained
characterizations

within such
to

document
further

in that
is

are conclusions reference

law and

which no

response

required beyond

to the actual

document

cited

Plaintiff

generally

objects

to

the

characterizations as

throughout

these

Interrogatories characterizations

Plaintiffs in these

answers

should

not be deemed

her agreement

with

the

Interrogatories

234620-1

Plaintiff

objects in the

to the

Interrogatories or control of

to the the

extent

they seek documents

or

or or

information already

custody

Plaintiff less

seek

documents and with

information which may be obtained burden than by Plaintiff or by these

more conveniently
Interrogatories

expensively

less

Plaintiff

objects

to to the

each public

Interrogatory

that

seeks

the

disclosure

of

documents

that

are available

These response not

Citation of any

objections to

are hereby general

incorporated into each response

specific

objection

and
is

particular general

and any

specific

objection

below

waiver

of the

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
or

NO
to these

Identify

all

persons

who

assisted

in preparing
to

who

provided

answers
for

Interrogatories

and

your

responses

the

accompanying

requests

documents

ANSWER NO

Plaintiff

objects

to

this

Interrogatory

to

the

extent

that

it

seeks information protected

by

the

attorney-client

privilege

and

the

attorney

work

product

doctrine

Without

waiving

said objection

or privilege

Plaintiffs attorneys

INTERROGATORY
number
of each

NO
believe

State

the

identity

address

and

telephone your

person

who you
the

has knowledge

or information relating to

Complaint together with

substance of their testimony

knowledge

or information

ANSWER NO
interrogatories

Plaintiff

objects

to this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under the guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of the

Maryland

Rules

of

Civil

Procedure

Further

the

interrogatory

as

worded

is

overly

broad

234620-1

vague and ambiguous

persons with

as well

as

unduly burdensome

as

it

seeks

for Plaintiff

to identify

all

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 knowledge

that

the

Defendants

Aparicio

Forrester

and

Clark

may

have

personal

Plaintiff

also

presumes

that

current

and

former

colleagues

of

the

Defendants

the

Plaintiff

and

other

members

of

the

local

media may have

Willett

personal

knowledge

including

but not limited

to Jerry

Coleman
ongoing

Casey

Damon

Yaffe

John Gallo

and Ray Buchman As discovery and/or amend her response

is

Plaintiff

reserves

the

right to

supplement

to this Interrogatory

INTERROGATORY NO.3
by any
of the
all

Identify allege
is

each

and every statement

alleged

of fact

made

Defendants subparts
the date

that

you

false

as

in Complaint

1J19-25
false

including statement statement i.e in

and

27
of

37 48-50
of such

quoting
the

verbatim identity the

is

each
of the

alleged

of fact

and time

statement

speaker

of the

the exact

medium web
to

communication

upon
if

which

statement found

was made
website
to or
this

person radio Twitter website

state

etc

and

the the

statement statement

on

blog

the

exact

address
all

containing statements

Your
base

answer
the

interrogatory

should

identify

on

which

you

Complaint

including

but not limited

All statements that

that

you contend
or

state for

implicate or otherwise insinuate

position as journalist

you

are

not

qualified of

competent

and

incapable

doing

job Complaint
you contend
athletes state

20 21a 21b 21c

or

21
that

24
All statements that

implicate

otherwise insinuate
relationships

you

are

involved

in personal

sexual

and/or
that

inappropriate

with

multiple professional

and/or
with

you

ha

personal sexual

and/or inappropriate

relationship

professional

athlete

Complaint

20

21
that

21

21

21
that

All statements

you lied on

you contend state implicate or otherwise insinuate resume and did not have the credentials or experience

234620-1

that

purport Ito have

with

regard to

profession

as

journalist

Complaint

21c
that

All statements that

you contend
like

state

implicate

or otherwise insinuate

you were trashy

look

stripper

bitch
violence

and/or an idiot

Complaint

21

24c
that

All statements

Complaint

24d
that uncivilized that

threatened you contend

against

you see work

e.g

All statements

you contend

demeaning and

way

Complaint

24b

your

professional

in

All statements

you contend

are sexually inappropriate

statements

about

you

Complaint

24e
objects to
this

ANSWER NO
interrogatories

Plaintiff

Interrogatory

as

it

contains

several

each involving

separate

and distinct issues under the

guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of the

Maryland

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 Interrogatory explain

each and every
fact

NO
the

For each

statement
it

identified
false

your

answer

to

reason that you claim

was

when made
all

identify to the

you who

have

on which you base your contention identify knowledge of such facts and for each person knowledge

persons

known
state

identified

substance of that persons

ANSWER NO
interrogatories

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under the guise

of

single

interrogatory

in contravention

of

the

limits

imposed by Rule

2-421

of

the

Maryland

Rules

of

Civil

Procedure

The

interrogatory

as

worded

is

overly

broad

vague and

ambiguous
with

as well

as

unduly burdensome

as

it

seeks

for Plaintiff

to identify

all

persons

personal knowledge

of the

facts

relevant

to the

issues

in the

case

even

if

she

has

no knowledge

of their existence

Further

Plaintiff

objects

to

this Interrogatory

to the

234620-1

extent

it

seeks

information protected

from discovery by

the

attorney

work-product

doctrine

To answer

this

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
any
other

NO
but

Identify

all

communications
to

between

you and
to

persons
identified

including
in your

not

limited

the

Defendants For each

or

relating identify

the date

statements
of the the the

answer
the
all

to Interrogatory

No

the to

communication

by

whom

communication those

was authored
the

made

whom

communication communication
to

was addressed was made

the

who

received

communication
of the

whether

orally or in writing the

substance

communication

and any response

communication

ANSWER NO
interrogatories

Plaintiff

objects

to this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct issues

under

the

guise

of

single

interrogatory in contravention

of

the

limits

imposed by Rule

2-421

of

the

Maryland vague and

the

Rules of Civil Procedure

The interrogatory

as

worded
the

is

overly

broad

ambiguous

as

well

as

unduly burdensome

as

Interrogatory

does

not define

term

communications

Further

Plaintiff

objects

to this

Interrogatory

to

the

extent

it

seeks

information protected

by

the

attorney-client

privilege

and

the

attorney

work

product

doctrine

Without waiving
Baltimore

and

subject

to

said

objections

Plaintiff

prepared

correspondence

to the

Ravens

organization

on

or

about

August and

14 2010

Plaintiff

exchanged

emails with

colleagues

and management

at

MASN

CBS

as

234620-1

well

as

telephone

conversations

beginning

on

approximately

January

13
the

2011

regarding the

Defendants

conduct As discovery

is

ongoing

Plaintiff

reserves

right

to

supplement and/or amend her response

to this Interrogatory

your
that the

INTERROGATORY NO answer to Interrogatory No

the

With
if

respect

to that

each any

statement
of the

identified

in

you contend
entertained

Defendants
truth

knew
of
its

statement
or

was

false

subjectively the

doubts high

as to the

of falsity as to

statement

published
for

statement
state

with
the

degree
facts

of awareness

probable

falsity

each

Defendant

specific

contention each person

and

all

persons
state

known

to

you whohave

on which you base your knowledge of such facts and for knowledge

identified

the substance

of that persons

ANSWER NO
interrogatories

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under

the

guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of the

Maryland

Rules

of Civil

Procedure

The Interrogatory burdensome

as

worded

is

overly

broad

vague
all

and

ambiguous
with

as well

as unduly

as

it

seeks

for Plaintiff

to identify

persons

personal knowledge

of the

facts

relevant

to the

issues

in the

case

even

if

she has

no knowledge

of their existence

Further

Plaintiff

objects

to

this

Interrogatory

to the

extent

it

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

Answer

to

Interrogatory

No
case

and

incorporates

her Answer

thereto

Plaintiff

anticipates

that

discovery

in this

will provide

further

information in regards to

this

Interrogatory

and

as

such

reserves

the

right

to

supplement

and/or

amnd

her

Answer

to

this

Interrogatory

234620-1

INTERROGATORY NO.7
tend to show that the highly offensive
to

Describe

in

detail

all

facts

that

statements
reasonable

identified

in your identify

answer
all

to Interrogatory

you contend No were

contend
of

person
for each

persons

who you
the

have
that

knowledge
persons

of

such

facts

and

person

identified

state

substance

knowledge

ANSWER NO
interrogatories

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under

the

guise

of

single

interrogatory in contravention

of

the

limits

imposed by Rule

2-421

of the

Maryland and

Rules

of

Civil

Procedure

The interrogatory

as

worded

is

overly broad

vague

ambiguous
with

as well as

unduly burdensome

as

it

seeks for

Plaintiff

to identify

all

persons

personal knowledge

of the

facts

relevant

to

the

issues

in the

case

even

if

she

has

no knowledge

of their existence

Further

Plaintiff

objects

to

this

Interrogatory

to

the

extent

it

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

and

subject

to

said

objections

the

statements

outlined

in

Exhibit

speak

for

themselves

including

threats

that

Defendants

would

snap

Plaintiffs

neck

and

all

statements

referring

to Plaintiff

as

bitch trashy
she must cover

calling her

liar stating

that she

sleeps

with

professional

athletes

pursuant

to her professional

duties

etc

Plaintiff

reserves

the

right

to

supplement

and/or

amend

her

Answer

to

this

Interrogatory

as discovery in this matter

is

ongoing any and

INTERROGATORY NO
magazine
transcripts articles
letters

Describe

in

detail

all

newspaper
tapes

or

bulletins to the

flyers

computer

printouts

broadcast

videos from
or

editor or similar broadcast

or printed material published

January

2003

to

the

present

in

any form

regarding

you

that

were broadcast

published by anyone

other

than Defendants

234620-1

ANSWER NO
vague and ambiguous
It

Plaintiff

objects

to

this

Interrogatory

as

it

is

overly

broad

also

seeks

information which

is

immaterial

to

the

instant

matter and

is

not reasonably

calculated

to lead

to the

discovery of admissible

evidence

Without waiving

and

subject

to

said objections

see Exhibit

attached

hereto

INTERROGATORY NO.9
acted

If

you

contend

that

any

of

the

Defendants
in your

with
to

common

law malice

ill

will or spite in making any

state

of the statements

answer

Interrogatory identify
all

No
the

the

specific

facts

on which
of such

you base
facts

such

contention

persons you contend

have

knowledge

and for each

person identified

state

substance of that persons

knowledge

ANSWER NO
interrogatories

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each

involving

separate

and

distinct

issues under

the

guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of

the

Maryland and

Rules

of

Civil

Procedure

The Interrogatory

as

worded

is

overly

broad

vague

ambiguous
with

as well as

unduly burdensome

as

it

seeks

for Plaintiff

to

identify

all

persons

personal knowledge

of the

facts

relevant

to the

issues

in the

case even

if

she has

no knowledge

of their existence

Further

Plaintiff

objects

to

this

Interrogatory

to

the

extent

it

seeks

information protected

from discovery by

the

attorney

work-product

doctrine

To answer

this

Interrogatory Plaintiffs counsel would

be required

to provide

information regarding

counsels

litigation

strategy

in this

case

Without

waiving

and

subject

to said objection

Plaintiff

directs

Defendant

to her

Answer

to Interrogatory

No

INTERROGATORY NO 10
have
suffered to your reputation as

Describe proximate

in detail any result of the

damages you contend

statements
identified

to in

No the reasons for your belief that those statements your answer to Interrogatory were the proximate cause of any such loss identify all persons who you contend have

10
234620-1

knowledge
persons

of

such

loss and

for each

person

identified

state

the

substance

of that

knowledge

ANSWER NO
interrogatories

10

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct issues

under

the

guise

of

single

interrogatory in contravention

of the

limits

imposed by Rule

2-421

of the

Maryland and

Rules

of

Civil

Procedure

The Interrogatory

as

worded

is

overly

broad

vague

ambiguous
with

as well as

unduly burdensome

as

it

seeks for

Plaintiff

to identify

all

persons

personal knowledge

of the

facts

relevant

to

the

issues

in the

case

even

if

she has

no knowledge
Defendants

of their existence Without

waiving

and

subject

to

said

objections

the

actions

have

caused

Plaintiffs

professional

and personal

reputation

to

be

called

into question

Defendants

conduct

has caused

members

of the

public

to believe

that

she

is

bitch

liar

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
contend
to

NO
to as the

11

Describe
feelings of the

in

detail

any not

other

damages
to

you

have

suffered

your

including statements

but

limited

distress to or
all

anguish and humiliation

Interrogatory

result

identified of the or

in your alleged

answer
injury

No
special related of

state

nature
allege

extent are

and due

duration

damage
financial

any

damages you
thereto
injury the or

to such

injury that

damage

any

and

losses

reasons you contend

such

statements

were

the

proximate
health care

cause

such

damage
you

the

names and business

alleged injuries

addresses
the dates
of

of all

providers

who

treated

for such

and

such

treatment

ANSWER NO
interrogatories

11

Plaintiff

objects

to

this Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under the

guise

of

single

11
234620-1

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of the

Maryland

Rules

of

Civil

Procedure

The Interrogatory

as

worded

is

overly

broad

vague

and

ambiguous

as

it

does

not

define

the

phrase

damages.
Plaintiff

.suIfered

to

your

feelings

Without waiving

and

subject

to said objections

refers to

Dr

Goldiners

letter

produced

in

response

to

the

Defendants

Request

for

Production

of

Documents

Plaintiff

has suffered

from

severe

anxiety

depression

and

fear

that

any

slight action

may
about

cause

the

Defendants

to

publish spiteful

hateful atrocious

and

false

statements

her The aforementioned

has caused

Plaintiff

to

alter

her work

habits

and

her

appearance including Samuel Liebman

the

way

she

dresses

Plaintiff

is

currently

being

treated

by Dr

1205 York

Road

21

Lutherville

Maryland

21093

and was

treated

by

Dr

William

Goldiner

MD

Internal

Medicine

120 Sister Pierre

Drive

207
to

Towson
medication

Maryland and

21204

Plaintiffs

damages Liebman

aie

ongoing

as

she continues

take

is

under

the

care

of

Dr

INTERROGATORY NO 12
those
identified in response to the

Describe preceding

in

detail

any

damages
suffered

other

than
as the

interrogatories

by you

proximate reasons

result of the statements the

identified

in your

answer
the

to Interrogatory

No
of any

for your belief that

all

such statements contend

of that

were

proximate
of such

cause

such

loss identify person

persons

who you

have

knowledge

loss and for each

identified

state the substance

persons

knowledge
her

ANSWER NO
Interrogatories

12

Plaintiff

refers

to

and

incorporates

Answers

to

Nos

10 and 11

INTERROGATORY
state

NO 13

In

support

of

Count IV
that

of

your

Complaint
conduct

upon was extreme and outrageous

all

facts

which you rely for your contention and beyond

the

any Defendants
in society

bounds

of decency

j60

12
234620-1

ANSWER NO
vague

13

Plaintiff

objects

to

this

Interrogatory

as

it

is

overly

broad

and ambiguous

Further

Plaintiff

objects

to this

Interrogatory

to

the

extent

it

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 Answers

said objections

and

subject

thereto

Plaintiff

directs

Defendant

to her

to Interrogatories

Nos
the

10

12 and Defendant

Forresters threat that he would

snap
is

her

neck
initial

along with

other statements

outlined

in Exhibit

As

this

litigation

in

its

stages

Plaintiff

reserves

the

right to supplement

this

Answer

as discovery proceeds

INTERROGATORY NO 14
state
all facts

In

support

of

Count IV
that

of

your

upon which you

to suffer severe

rely for your contention

Plaintiff
IT

has suffered

Complaint and

will continue

and extreme emotional distress

62
her

ANSWER NO
Interrogatories

14

Plaintiff

refers

and

incorporates

Answers

to

10

11

and 12

INTERROGATORY
practitioner

NO

15

Identify

any
health

doctor counselor

physician
or

medical
health

psychologist
that

psychiatrist

mental

mental

practitioner you have ever visited concerning your mental health in your lifetime and for each state their person identified number and the date and purpose of any such visit phone

and/or
full

emotional address

name

ANSWER NO
seeks information that

15

Plaintiff

objects

to this

Interrogatory

as

it

is

overly

broad

and

is

not material

to the

instant

litigation

The

Interrogatory

is

not

reasonably

calculated

to lead

to

the

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
including
sent to

Identify

and

describe

all

communications
of the

but not limited

that

to letters

and correspondence
in Baltimore

from members

public

you

relate to your

work

Maryland broad

ANSWER NO
vague and ambiguous

16

Plaintiff

objects

to this

Interrogatory

as

it

is

overly

as well

as unduly

burdensome

as

it

seeks

for Plaintiff

to provide

all

communications
her

which

term

is

left

undefined

Plaintiff

has

ever

received

regarding

work

in

Baltimore

Maryland

Moreover and

the

Interrogatory

seeks

information immaterial to the instant

litigation

is

not reasonably

calculated

to

lead

to the

discovery of admissible evidence

INTERROGATORY NO 17
which you were named and
in for each the as

Identify either as

any

lawsuit

or criminal plaintiff parties claims the

proceeding
or

in

party

defendant
state the

third-party case

respondent

such lawsuit is/was

or proceeding the

the

number

and court

which

case

pending
the

nature of the
status

in the

complaint
if

and/or counterclaim and/or

cross-claim

current

and

resolution

any

ANSWER NO
calculated to lead to

17
the

Plaintiff

objects

to

this

Interrogatory

as

it

is

not reasonably

discovery

of

admissible

evidence

Plaintiff

can

obtain

this

public

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
you attended and
all

Identify to the

every present

school
stating

college
the dates

or

university

beginning

from high

school

of attendance

degrees awarded

ANSWER NO
and graduated
with
in

18

Plaintiff

attended

Mansfeild

High School beginning from 1992 through

in 1988

1992

Plaintiff

attended

Salve Regina

1996 and

graduated

B.A

14
234620-1

INTERROGATORY NO 19
history With
for the respect to your

Describe to this

in

detail

your

entire contact

employment
information your

answer can

interrogatory provide

individual

who

verify

your

employment
at

describe of

work
the

responsibilities dates of each

identify

your

direct

supervisors
title

each

place

employment

employment

your job

including
of

any changes

during

employment

and

the

reason for your leaving each place

employment

ANSWER NO
interrogatories

19

Plaintiff

objects

to this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under the guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of the

Maryland

Rules of Civil Procedure

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

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
definition

NO 20
associated

Describe with
the

in

detail

your

understanding
as

of

the in

and/or

activities

following

terms

they

appear

paragraph sexual

21

subparts

and

your Complaint relationship

personal

relationship

relationship

and

inappropriate

ANSWER NO

20
former

athletes

INTERROGATORY NO 21 Identify with whom you have ever been inclined

and/or
inappropriate
or or

all

or

current

professional sexual to

in

personal

relationship
limited

relationship
current

relationship
of the

including
staff

but not

any

former

player

member

coaching
the

or

management

in Major the

League

Baseball the

National Football

League

National

Basketball

Association

National

Tour
other

Hockey League Major League Soccer the Arena Football League the PGA ATP World Tour NASCAR any minor league affiliate of such leagues or any minor professional and the American Hockey League league i.e AAA baseball
the identified state their full

For each person

name

address

phone

number

and

the

dates

and nature

of

any such relationship

15
234620-1

ANSWER NO 21
interrogatories

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under the guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of the

Maryland

Rules of Civil Procedure

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
does

and

ambiguous

The

interrogatory

calls

for speculation

and

conjecture

as

it

not define

the

phrase

inclined

in
Identify
all

INTERROGATORY NO 22 whom
you have
limited ever to

former or professional
relations of any

athletes with

had intimate romantic

current or

or sexual or

nature including coaching

the
staff

but not

any

former

player

member

of

the

or

management
Basketball Football
affiliate

in Major

League
the

Baseball the

National

Football

League

National
the

Association

National

League
of such

the

PGA

Tour

the

leagues

or any

other

Arena Hockey League Major League Soccer ATP World Tour NASCAR any minor league minor professional league i.e AAA baseball and each person
identified
state

the

Hockey address phone number

American

League
and

For

their

full

name

the dates

and nature

of any

such relationship

ANSWER NO
interrogatories

22

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct issues

under

the

guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of

the

Maryland

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

16
234620-1

Jun

02

2011

825PM

Martin

Bane

800-291-9303

page

SOLBMNLY AFFIRM
the

under

the penalties of

perjury

that the factual

matters

stated

in

Answers

to Intrrogatories

are true to the best of

my

information

arid

belief

17
234620-1

RESPONSES

REQUEST
RESPONSE

NO NO NO

You

are

sports

reporter

Admitted

REQUEST

On

March
the

23 2011 on

the

Masnsports.com

blog

located

at

http/ www.masnsports.com/ wrote sports reporters are indeed

royle_rundown/2011/
public figures

03/ goodbye-masn.htrnl

you

and

are

open

for criticism

RESPONSE
admitted
as the

NO

Admitted

subject

to

completeness

of

the

writing

being

whole

entry

from

said

MASN
sent

Blog stated

And
no
position

lastly

for those

of

you who

me

nasty

comments

on

this

blog

am

in

to preach

to

you

or

tell

you

that

youre bad people

dont even know you

the non-baseball related

will say this

however

If

you thought

for one split second

that

personal attack

you wrote and

may
are

have been

hurtful they

were

While

sports

reporters

are

indeed

public

figures

open
of us

for criticism

which

completely

understand

please

keep

in

mind

that while

most

do have

thick

skin

we

are also people

with the same

feelings

as

you And

thats

all

have

to

say about that

REQUEST
RESPONSE
legal

NO NO
as

You

are

public

figure

Plaintiff

objects

to this

request for admission

as

it

calls

for

conclusion

and

such

is

improper

18
234620-1

dh
Brian

Goodman
Moylan PESSIN KATZ P.A
Suite 400

Alexandra

HODES
901

Dulaney Valley Road

Towson Maryland

21 204-2600

410 410

938-8800 825-2493

Fax

Attorneys for Plaintiff

19
234620-1

JENNIFER ROYLE
Plaintiff

IN

THE

CIRCUIT

COURT

FOR NASTY
1570

SPORTS LLC

et

at

BALTIMORE
CASE

CITY

Defendants

NO

24-0.11001571

NOTICE OF SERVICE HEREBY CERTIFY

Answers
to Interrogatories that

OF DISCOVERY
of

on

this

2nd day

June 2011

copy

of the

foregoing

and

Responses

to

Requests

for

Admission

directed

to

Jennifer

Royle

on

behalf

of

WNST

SPORTS MEDIA
to

LLC

one

of

Defendants

was

mailed via

first-class

mail postage prepaid

Charles

Tobin Esquire
Shertlcman Knight Esquire

Drew
Holland

LLP Avenue
20006

2099 Pennsylvania
Suite

N.W

100

Washington D.C

202

955-3000

Attorney for Defendants

Ly
Brian

Goodman

k44
Road
Suite 400

Alexandra

HODES

Moylan PESSIN KATZ P.A

21204-2600

901 Dulaney Valley

Towson Maryland

410 410

938-8800 825-2493

Fax

Attorneys for Plaintiff

EXHIBIT

uoffls

P3-SM1N
.4uoren
.4

KATZ
Lzw

Chronology

of Defamatory

Statements

Statements

Casting

Plaintiff

In

False Light

2/24/2010

On

his

blog Glenn Clark Suspended For

lists

Jen Royle in his

Top

Sports Media

Members We

Wouldnt Mind

Seeing

Few

Weeks
is

4/7/2010

Glenn Clark blogs award

for

that

Ms

Royle

on

notice

that

she

is

up

for the

Apologist

of the

Morning
4/23/2010

her statement

regarding

the

Orioles

Glenn Cambell mocks

her on winning
the

Ms

Royles

commentary
the

of the Orioles 2-14 record

He

congratulates

Apologist of

Morning
Royle

award

4/26/2010 she
is

On

his

blog Drew

Forrester

states that

that
is

Ms

hiring to

was

stereotypical

because

an

out-of-towner
that

He

later states

she

not qualified

ask

any questions

and

insinuates

she frequents

hang

outs

of Yankees outfielder

Nick Swisher

5/3/2010 the
to

Glenn Clark blogs

that

Jen Royle
is

is

in the

running

to

win

The
the

Orioles Apologist

of

Month
her

He

also

notes that
ties

she

up

for

comparable

award with

Yankees

which seems

mock

New

York

511

2/2010

On his

blog Glenn Clark

ridicules

statement

made by
of the

Ms

Royle

in

her

commentary
5/18/2010

of the Orioles

He

notes that

she

won Apologist

Morning

earlier that

day

Glenn Clark

states

in his the

blog that

Ms

Royles

description of

game was

irrelevant

He

notes that

she once again

won

Apologist

of the

Morning
Orioles game
is

5/19/2010
later

Glenn Clark blogs

her to
to

that

Ms
the

Royles

description of an because she

was wrong

He
that

analogizes

character

on

Jersey Shore

disaster

He

states

he

doesnt want her

do her job better

6/2/2010

On his
loss

blog Glenn Clark mocks

In

Ms

Royles

description of an

Orioles

game

as

heartbreaking of the

another

entry

he

states

that

she barely lost out on winning

the

Apologist

Morning

award

8/5/2010

CBS

employee
included

notifies that

Ms

Royle

that

Glenn Clark
about
the

just

ripped

her on the

air

that

morning
the term

Comments

she

knew

nothing
the

Ravens and

did not

know what

blitz meant

but that

she

knew who

right

fielder

of the Yankees

was

Swisher
9/7/2010

During

Ravens practice

Ms

Royle

is

informed
the

that

Glenn Clark

told

member

of

the media that

she lied on her resume not deserve

to

and does not have

the

credentials/

experience

she claims to
it

have and
listening

does
to

be

covering

Ravens
have

Clark also
better

allegedly stated
to

that

is

brutal

her and inquired

why CBS didnt

anyone

cover

the

Ravens

HoDi3s
Page

Psssrn

KATZ P.A

9/12/2010

Glenn Clark sends

class

series clothes

of tweets that she was

included

that

he thought

working

for at the

Yankees meant Gold Club

and
in

that

the

wearing

would be considered trashy

strip club

Baltimore car
that

Drew

Forrester

tweets that the boots she was wearing

that

were

worth more than Glenns

looked
like stripper

Ms Royle
she was an

further idiot

alleges

they called
in front

her

bitch

said

she
after

and

while talking

of press

box
and

Later

confronting
states that

them Drew

reminds

Ms
shes

Royle of his affinity Yankee fan

for

her appearance she alleges

boots

He

also

they hate her because speaking

After that

that

Drew

Nestor

and Glenn continued

about

her

9/20/2010 she
is

CJ

Spiller in

blogs on

WNSTs

website

that

Ms
to

Royle should shut up do her job

He

states

that

disinterested like

Baltimore and
girl

does not

know how

He

further

alleges

that

she talks

high

school

9/21/2010 tweets that

After she

an altercation lucky

with

Drew

Forrester

at the in yet

Ravens
or

facility

Drew

Forrester

is

my

roid rage hasnt shocked

kicked

would have snapped

her head

off He
from

then tweets that her

favorite
it

he was teams

by her actions
and
that to

but really enjoys her boots

arid that

He

later

tweets that

are the Yankees also states

Rays

she was

seen running

away

WNST

when

lost in

power He
tweet
that

she does

not
is

know

the location

of Hopkins

Glenn Clark

insinuates

listening

Ms

Royle

awful

10/8/2010 during watching

the

Drew
Ravens
the

Forrester Steelers at

condemns

fan jokingly

encouraging
to

Jen to follow

kill

herself

via

tweet Jen was

game

The

fans tweet appeared

Drews

jab that

game Drew

home
fans

11/18/2010 joke
that

Forrester blogs that

as

wont

get to

meet Jen Royle

This appears

to

be

she thinks of herself

star

11/26/2010
further

Drew

Forrester blogs that she

is

Ms
in

Royle

is

not

fan of Baltimore sports

teams

He

insinuates

that

interested

Yankees

outfielder

Nick Swisher

12/29/2010

Drew
town
like

Forrester blogs
bull in

that

Jen

Royle wins the award

and
alienating later states

for

best example of someone

all

coming

to

china

shop

herself by pissing on she

is

things
stated

Baltimore
that

from the minute she got here

He

an out of towner who has

Baltimore

sucks

He

suggests

that

she has

dogged
saying that she
is is

Baltimore to everyone

1/2011

Drew

Forrester sends she

series

of tweets

shed

look

great

in

nothing on

but
brief the

Nick Swisher

shirt

smells fantastic Nestor

and

that

stuck-up

snobby

tourist

professional vacation bosses

here

tweets that

she

ignorant and

clueless while insulting

who

thought

she was qualified

1/11/2011 tweets
that
it

Drew

Forrester tweets that with

that said

Jen

is

an

out-of-towner
then threatens during

and

tourist

Glen Clark
also

his
is

agreement

assertion

Drew

out-of-towners

Drew

tweets

suspicious

Jen received

WNST

text

press conference

which he

finds

humorous

HODES
Page

PESSIN

KATZ P.A

1/12/2011
insinuate

Drew

Forrester

blogs

that

Ms
with

Royle doesnt understand

Orioles pitcher

Baltimore

He seems

to that

an inappropriate relationship Baltimore as use temporary

Brian Matusz she will never

He
make

further
it

alleges

she

is

using

career stop and that

in

Baltimore

He

then seems to

threatening

tone towards

out-of-towners

which includes

Ms

Royle

1/20/2011 continue

Dave working

Hughes receives
for to

question

in his

mail bag when

she
is

asking dating

how
an

Ms

Royle

is

able to

MASN arid
the

cover

the Orioles
that
it

Orioles pitcher
for

Mr
Royle

Hughes responded
to

question

by noting
for

would be

conflict

of interest

Ms

date

member Drew
is

of

team she covers

MA SN
the only qualification
to

1/26/2011

Forrester

states

on
This

his
is

blog that
in

be in Baltimore
in

Magazine

that

you work
is

here

reply to

why He

Ms

Royle
to

is

featured

the magazine
that

He
is

states

that

her scent

her best attribute unfriendly

the

He

later

responds

another
that to

person

Ms

Royle

condescending
and
that

snarky he
likes

and

snobby

reiterates

she doesnt
scratch

know
sticker

Baltimore

way

she smells

making

reference

arid sniff

1/28/2011photo

Drew

Forrester

states

in his outfit

blog that

Baltimores

own

Jen

Royle showed up

to

shoot with

Nick Swisher

2/22/2010

Ms

Royle
is

is

informed

that

Nester
pretty

commented
face and

on

air that that

the
is

only reason not qualified

Ms
to

Royle

has been employed discuss the

because
other

she has

breasts
is

she

Orioles or any

team because

Ms
that

Royle

woman
from the

5/25/2011

Glenn blogs

in

honor

of the fact

the reporter

FM sports
Things

station

in

town
list

had trouble finding Towson University

our Tuesday Consider
is

yesterday

we

thought

wed
he

put together

bucket

for

Top

7..

The

Tuesday Top
Sports

was

entitled
It

The Top
that
is

You Need To

Do TO
Royle

Yourself

Baltimore

Expert

appears

insuating that

Ms

not

reporter

by using

Unknown

Dates

Drew

Forrester

allegedly

tells

Jerry

Coleman

from Fox

that

you know

shes hooking up with Matusz

right
follow
his

Drew

Forrester or

tweets that

fans can
live

tweets from the

stadium
sent

Ms

Royles

tweets

from her couch

Appears

to

be

around

9/27/11

Glenn Clark comments

on

his

blog that and

he

does

not understand she

Jen Royle
be on

wear
that

short

skirts

boots to games knowing

why wont

TV

and

its pretty

cold

outside

EXHIBIT

Bmore Media

March

29

2011
11 .aspx

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

Full

Count

Pitch

March

28

2011
11 /03/ftilleountpitch-ftill-count-j

http//mypinstripes.blogspot.comI2O

en-royle.html

Washington
http//dev

Examiner

February

19 2010
7.html

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

Seott-Garceaus-new-partner-847697

Washington

Examiner

March

29 2010
057fto-fan-baltimore-and-masn

http//washingtonexaminer.contfblogs/watchlroyle-welcome-

Washington

Examiner

March

24

2011
11/03/1 057ftn-fan-launch-orioles-pregame-and-

http//washingtonexaminer.comlblogs/watchl2o

postgame-shows

Baltimore Sports

Report

January

10 2011
en-royle-

http//baltimoresportsreport.com/interview-bsr-gets-to-know-masns-j

11316

.html

Baltimore Sports
blip

Report

February

10 2011
12690 html

//baltimoresportsreporteom/jen-royle-explains-orioles-flagship-switeh-her-role-

Baltimore Sports

Report

March

21

2011

http//baltimoresportsreport.comljen-royle-parting-ways-with-masn-staying-with-105-714137.html

Press

Box Magazine

May

2010

issue

http//www.pressboxonline.comlstory

efmid62
April

11

Free Daily

Baltimore

Sun

2011

Cover
http//www.readoz.comlpublicationlembedp1 8756

Feature http//www.baltimoresun 201104060.41

10137.story eomlentertainment/bthesite/bal-ean-jen-royle-win-over-birdland

QA
http//www.baltimoresun.com/entertainment/bthesite/bal..en-royle-ga-you-have-to-say-enough is-enough-201

1040606805717story

Photos
http//www.baltimoresun.comlentertainment/bthesite/bs-bthesite-jennifer-royle 2011

0406 04543896.photogallery

Baltimore Magazine

--

Hottest

Singles

2011 issue
/02/to

http//www.ba1timoremagazine.net/features/2O11

p-singles-20 11 -wheres-the-1oy

JENNIFER ROYLE
Plaintiff

IN

THE

CIRCUIT

COURT

FOR NASTY
1570

SPORTS

LLC

et

cii

BALTIMORE
CASE

CITY

Defendants

NO 24-C-11001571

PLAINTIFF JENNIFER

ROYLES SUPPLEMENTAL ANSWERS AND RESPONSES TO WNST SPORTS MEDIA LLCS FIRST SET OF INTERROGATORIES

AND REQUESTS FOR ADMISSION

NOW COMES Jennifer

Alexandra

Royle

Plaintiff

by her attorneys Brian

Goodman

and

Moylan

of

Hodes

of Pessin

Katz

P.A

supplements

her answers to the

Interrogatories

propounded and

to

her

by

WNST

SPORTS

MEDIA

LLC

one

of

Defendants

states as follows

INTERROGATORY
those
identified in response

NO
to

12

Describe preceding
in

in

detail

any damages
suffered

other

than
as the

the

interrogatories

by you

proximate reasons

result of the

statements
the

identified

for your
all

belief that

such

your answer to Interrogatory statements were the proximate cause

have

No
of

any such
for each

loss identify person

persons
state

who

you contend
of that

knowledge

of such

loss and

identified

the

substance

persons

knowledge Answers

ANSWER NO
Interrogatories

12

Plaintiff

refers

to

and

incorporates

her

to

Nos

10 and

11
refers to

SUPPLEMENTAL ANSWER 12
Answers
to Interrogatories

Plaintiff

and

incorporates

her

Nos

10

and

11

Plaintiff

refers

the

Defendants

to

the

documents attached

in response

to

Defendants

Request

for Production

of

Documents

Plaintiff reserves

the

right to

supplement her Answer

INTERROGATORY
definition

NO 20
associated

Describe with your

the

in

detail

your understanding
terms
as

of

the in

and/or

activities

following

they

appear

paragraph

21 subparts sexual relationship and

and

Complaint
relationship

personal

relationship

inappropriate

ANSWER NO 20
SUPPLEMENTAL ANSWER 20
Relationship Personal
the
Plaintiff

defines

the

following terms

way

in

which

things

and/or people which

are connected

Relationship

the lives

way

in

people

are

connected

in

their

personal and/or private

Sexual Relationship

the

way

in

which people
activities

are connected

intimately

in any

way

referencing

sex and/or sexual

Inappropriate
relate to particular

Relationship another
that
is

the

way

in

which people

are connected

and/or
in

one

unsuitable

unacceptable

and/or not

suitable

setting

location

or situation

Brian

Goodman
Moylan PESSIN KATZ P.A

Alexandra

HODES

901 Dulaney Valley

Road

Suite 400

Towson Maryland

21204-2600

410 410

938-8800 825-2493

Fax

Attorneys for Plaintiff

2474854

JENNIFER ROYLE
Plaintiff

IN

THE

CIRCUIT

COURT

FOR NASTY
1570

SPORTS

LLC

et

BALTIMORE
CASE

CITY

Defendants

NO 24-C-11001571

NOTICE OF SERVICE OF DISCOVERY HEREBY CERTIFY

Supplemental
that

on

this

17th 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 transmitted by

electronic

mail to

Charles

Tobin Esquire Shenlcman

Knight Esquire

Drew
Holland

LLP Avenue
20006

2099 Pennsylvania
Suite 100

N.W

Washington

D.C

202

955-3000

char1es.tobinhMaw.com
Attorney for Defendants

fta.Nuuiv1c
Brian

Goodman
PESSIN

Alexandra

Moylan

HODES
901

KATZ P.A
Suite 400

Dulaney Valley Road

938-8800 825-2493

Towson Maryland

21204-2600

410 410

Fax

Attorneys for Plaintiff

2474851

EXHIBIT
June 2011 Letter to Plaintiffs Counsel

Holland
2099
Pennsylvania Knight

Knight
NW
Suite

Avenue LLP

100

Washington

DC 20006

202.955.3000

202.955.5564

Holland

www.hklaw.com

CHARLES

TOBIN

202

419-2539

chaiies.tobin@hklaw.com

June

2011

Via

UPS

Overnight

and Email

Brian

Goodman
Pessin

Hodes
901

Esq Katz P.A

Ste 400

Dulaney Valley Road

Towson

Maryland 21204-2600

bgoodmanhpklegal.com

Re

Jennjfer

Royle
Circuit

NASTY
Court

1570 Sports
Baltimore

LLC

et

aL

Maryland

for

City

Case

No

24C

11001

571

Dear

Mr Goodman
We
send
this letter

pursuant

to

Rule 2-431

in

good-faith Rules 2-421 Sports

as

effort

to

resolve

your

clients the
first

noncompliance
responses
set

with

her

discovery

obligations

under

and 2-422

Specifically

Plaintiff

Jennifer Royle has

furnished to
are

WNST
ten
to

Media LLCs
in detail

WNST

of interrogatories
that

and document

requests

deficient within

described

in this letter
letter

We
to

request avoid

Ms
to

Royle supplement
inconvenience

her responses the Court with

10

days

of the date of this

the

need

Motion

Compel

Plaintiffs

Responses

to

WNSTs
are

Interrogatories

Your 432 due

to

clients

responses

to

the interrogatories

evasive

and incomplete

under

Rule

2-

the

following

deficiencies

Various responses

references

to

unnamed

individuals

Throughout

Ms

Royles

interrogatory related to for

she alludes to

unnamed

individuals

who

she contends provide

may have

information

her Complaint

The

interrogatories

require her to

the names and contact

information

each

These references

include

Interrogatory

No
current
to

and Exhibit and

former colleagues

The

of Defendants

referenced

in

the

response

Interrogatory

No
local

The

other

members

of the

media

referenced

in

the

response

to

Interrogatory

No
referenced
in in relation to to

The

CBS

employee

statements

allegedly

made

on 8/5/20

10

as

described

Exhibit

Ms

Royles responses

Mr Brian
June

Goodman Esq

2011

Page

The

member
at

of

the

media

referenced

in

relation as

to

statements
in Exhibit

allegedly to

made

Ravens

practice

on 9/7/20

10

described

Ms

Royles responses The individual on the

air

who informed you that Nestor made comments about you Ms Royles described in Exhibit to on 2/22/2010 as

responses

Interrogatory

No
individual within the Baltimore

The

Ravens on

organization

to

whom

Ms
as

Royle

prepared
in

correspondence

or about

August

14 2010

described

Ms

Royles answer

to

Interrogatory
at

The

colleagues

and management
as

MASN

and

No CBS

with

whom

you on
as

exchanged
approximately described
in

emails January

well

as

telephone regarding

conversations

beginning

13

2011
to

Defendants

conduct

Ms

Royles answer

Interrogatory

No

Interrogatory

No

10

The

individuals

who have

called
as

into

question
in

Ms

Royles professional
to

and personal

reputation

described

her answer

Interrogatory

No
have had

10
The

members
them
to

of the public believe

that

who

believe

that

Defendants bitch
liar

actions

caused sexual
in

Ms

Royle

is

and has
as

relationships

with Nick
to

Swisher

and/or

Brian

Matusz whom

described

Ms

Royles answer

Interrogatory

No

10
with
in

The

professional

athletes

Ms
Ms

Royle

covers

Ms

Royles
to

credibility Interrogatory

has been endangered

as described

Ms

Royles answer

No
with

10

The

others 10

whom
as

Royle contends
in

that

she

has been forced

to

to

explain

herself

to

described

Ms

Royles

answer

Interrogatory

No
Interrogatory

No
but

Similarly

in

response

to

this

standard
to their

interrogatory

asking she
lists

Ms
five

Royle

to

identify

individuals

who may have

fails

information the

relating

her Complaint

non-parties

by

name
the

to

state

substance

of

testimony
alludes

knowledge
to

or and

information as
former

interrogatory of Defendants

required

Further

Ms

Royles response
of the local

current not

colleagues

and other members

media

but does

identify

those individuals information

by

name

nor does

she disclose the substance

of their testimony knowledge

or

Interrogatory paraphrase
calls for

No

Ms

Royle responds
her that she

to

this

interrogatory
are

by attaching

Exhibit

of the

statements

about

alleges false

false

However

the interrogatory

verbatim

recitation

of each
in

alleged

statement

of fact

alleged

by

Ms
on

Royle

Very few of the alleged statements Royle

alleges oral

Exhibit

include

the exact words used allegedly just

For example her

the

Ms
air

communications

where

Mr

Clark

ripped

Mr
June

Brian

Goodman Esq

92011

Page

8/512010 These and

the Court

and where
the

Drew

Nestor Exhibit

and Glenn continued do not provide

speaking

about
to

her 9/12/2010
the
fails

other instances allegedly

in

sufficient

notice Exhibit

Defendants or
to identifS the

of the

false

and defamatory

words
that

Further

web

address

of any

allegedly

actionable

statements

Ms

Royle

contends

are

on

WNSTs

website

Interrogatory interrogatory

No
in

Ms
entirely

Royles

response

incorporates

her response

to

the

preceding

which asks an
identified

different to

question

Rather than explaining

why
it

she believes

iistatement
Interrogatory

her answer

Interrogatory
states

No
that

was
she

false

when

was

made

as

No

requests
to

Ms

Royle generally
she

has

never

lied

on her resume

and has never

states that

purported never

have

credentials

does

not have with she

Moreover
Swisher

Ms

Royles response

she has

been romantically
alleges

involved
that

Nick
has

or Brian

Matusz
sexual

but

her

Complaint

generally

statements

had

personal

and/or

inappropriate

relationships to

with

professional
as to to
all

athletes

Complaint
athletes
as

27
asked

Therefore and
as

Ms

Royle

must respond
alleges

the interrogatory
limit

professional Swisher or

her Complaint

and not

her response

Ms

Mr

Matusz

Interrogatory telephone

No
with

Ms

Royle

generically

refers

to in

conversations addition
to

correspondence
failing or to

and
their

conversations

unnamed
fails

individuals
state the

and

provide

names and contact

the communications

information
as

to

date of the communications

the substance

of

the interrogatory

requests

Interrogatory

No
none

Ms

Royles

response

incorporates sought
the in

her

response

to

Interrogatory regarding

No
Royles

which

provides
factual

of the

information

Interrogatory

No

Ms

complete

basis for her assertion doubts

as to

that or

Defendants knew
of statements

statements

were false them with

subjectively high degree

entertained of awareness

the truth

falsity

or published

as to their

probable

falsity

Interrogatory Interrogatory regarding the

No
which

Ms
factual

Royles

response of
the

directs

WNST

to

Ms
in

Royles

response

to

No
complete

provides
basis

none
for

information
allegation

sought
that

Interrogatory acted

No
with

Ms

Royles

Defendants

common

law malice

ill

will or spite

Interrogatory furnished any such

No

11

Ms

Royles

response

refers

to

Dr

Goldiners

letter

but has

not

document

Interrogatory

No

12

Ms

Royles

response
the

incorporates

her

response
in

to

Interrogatory

Nos

10

and

11

neither

of which

provides

information

sought

Interrogatory

No
on

12
this

regarding responses

whether

Ms

Royle has any damages other than those

response does not include with

identified

the other interrogatory

will rely

Because
that

her

any

other

damages we
that

representation

she has

none and

proceed

the defense

on

basis

Interrogatory other medical

No

15

Ms
with

Royle responds

with ever

the names
visited

of two

doctors her

and

lists

no

professionals

whom

she

has

concerning

mental

and/or

Mr
June

Brian

Goodman Esq

92011

Page

emotional health

health

in
is

her lifetime as the

interrogatory

required

Ms

Royles

pre-existing

mental

condition

clearly

relevant to the allegations

of her Complaint

Interrogatory correspondence whether with

No

16

Ms
of the

Royle
public

objects

to

this

interrogatory
in

which
without

requests
stating

members

about
that the

her
are

work

Baltimore
to

any documents
reputation requests

or communications
is

exist to

responsive

the question her

Obviously and
the

Ms

Royles

clearly

relevant
that

allegations

of

Complaint

interrogatory

information

on

issue

Interrogatory
to

No

19

Ms

Royle

failed

to

attach

the document

referenced

as

Exhibit
for

her responses

Moreover
as

her response

provides

no information

about

her reason

leaving

each

place of employment

the interrogatory

required

Interrogatory hearing
to that to

No 20 We
failed to as

advised

your

colleague

Alexandra Moylan
in

at

the June

2011 required

Ms
this

Royle

answer
with

this

interrogatory

any manner

Ms

Royle

is

respond

interrogatory

all

others

Interrogatory

Nos

21

and

22

Beyond
citing false

the boilerplate

objections to

these interrogatories

Ms

Royle provided
that

no information

relevancy statements athletes about

grounds
that

Ms
had

Royles

Complaint
sexual
entitled

at

27
the

alleges

the

Defendants

made
with

she

personal
therefore are

and/or
to

inappropriate information with well

relationships in

professional

Defendants

requested

Interrogatory

No

21

any

former andlor
for

or current professional

athlete as

which
as the

Ms

Royle has ever had

requested of
in

personal sexual
Interrogatory

inappropriate
about

relationship any

information sexual

No
has

22

information

intimate
or current

romantic

or

relations

any

nature
is

she

ever

had with

any

former

professional athlete This

information

directly

relevant to the allegations

of her Complaint

Plaintiffs

Responses

toWNSTs

Document

Requests

To

date

you have not provided

following the hearing
that

us with

any documents
to

responsive

to

WNSTs
that

requests

On

June

2011

on Defendants Motion were

in

Dismiss we asked

Ms

Moylan
she send or those

about

the requested

documents
right

she advised

your office
received

We

requested Please

us those

documents
to

away

To date we have

not

them

email

documents

us or send

them overnight

Ms
awaiting

Moylan

further

advised

during

our

June

discussion
are to

that

your

law firm

is

still

responsive

documents

from
that

Ms

Royle

Ms
for

Royle

Rule 2-422 requires

to

parties

As you be prepared

aware

and

as

am

sure you advised

exchange
in

documents
to

by

the

deadline
in

responding
that

request
will

for

production

Accordingly

addition
all

the documents responsive the

your

possession

you

produce June

immediately please provide

16th
to

further

documents
Court with

by no

later

than

Thursday

avoid

our

having

to

inconvenience

discovery

motion practice

Mr
June

Brian 2011

Goodman

Esq

Page

With respect Rule 2-432 due

to

to

Ms

Royles

written

responses

they

are

evasive

and incomplete

tinder

the following

deficiencies

Failure to concurrently

Provide

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privilege

Log
log and

Ms
the

Royle objects
with
are

on the basis of
instructions to

privilege

without

submitting
privilege are

consistent

the

and Maryland what

are

law

Without documents
Specifically and/or

log

Defendants

Court or not
are

unable

determine

specific

being

withheld
asserts

and
that

whether

Ms

Royles

objections

appropriate
privilege

Ms

Royle

documents
to

protected

by the

attorney-client

work-product

doctrine in her responses

Document
and

Request

Nos
Shield

16 17 Law
in

18 19 20 21 22 23 24 25 26 27 28 29 30 31
responses to Document

32

and the Maryland

her

Request

Nos

9-14

Document
whether any

Request

No

The
exist

response

provides

an

objection

but

does

not

indicate

responsive

documents

Document
assertion possession
all

Request

No
For

Ms
between

Royles

objection Defendants

is

misplaced
are

Contrary
the large

to

her

communications

her and the

not

within

Defendants number
of

custody

and control
that

example the Defendants

do not possess
they
to are

Ms Ms

Royles Tweets

were directed towards

@WNST
for to

and

not available Defendants

on Twitter
suggest
that

Further

Ms

Royles

interrogatories

and requests

admission

the

Royle believes
are
is

she

asked

the Defendants

stop publishing
in that

statements
particularly
all

concerning
if

her yet
her in and

the Defendants writing

unaware
required

of any communications
under
this

regard
these

made by
documents

She

request

to

provide

and

other

communications between

her and any Defendant

Document communications

Request

between

No Ms
to

Ms
Royle

Royles objection
third parties

to

this

request

also

is

misplaced
not within

All
the

and

about

her
is

lawsuit not

are

Defendants possession
the contrary
it

custody

or control

Further

the request

overly burdensome

To

is

confined

the time period

relevant to this litigation

Document
nonresponsive
characterization as

Request they of
the refer

Nos

21 22 23
to

and

26

Ms

Royles

responses

are

WNST

Exhibit

to

her interrogatory

responsesMs
than

Royles
the
is

alleged

statements
that

made

by

Defendantsrather

producing

documents
required to

supporting provide
are

her allegations Defendants

false

these statements
in

were

in

fact

made
nature

The
with

plaintiff

the

and the Court

litigation

of this

the

precise in in

words
Exhibit

that

allegedly than

and defamatory
the

Ms

Royles

characterizations does not

of statements

rather

providing

statements

themselves

meet her obligations

discovery

Document documents custody

or

Request
to In

Nos

and 34

Ms
set

Royles objection
are

is

misplaced

here as well

All

relevant control

her the

activities

on Twitter

not

within

the

Defendants

possession

request

WNST
this

forth in

specific
electronic

non-burdensome
format
at

means by which
to

Ms
than

Royle may obtain complying

in

her entire
faith

Twitter

history relevant

no

cost

her

Rather
to

good

with

and reasonable

request

Ms

Royle

refuses

Mr
June

Brian

Goodman Esq

92011

Page

produce
to

single

Tweet

Moreover
does

Ms

Royles

statement

that

she uses

Twitter

daily pursuant

her professional duties

not relieve

her of her obligations in discovery

Document Maryland
fails to

Request

Nos
fails to

through
assert

14

Ms

Royle broadly documents

objects

on

the

basis

of the Royle

Shield

Law
court

but

whether such
the

exist and if they

do

Ms

submit

privilege

log consistent with

to evaluate

instructions

and Maryland
of any

law

Without

such

WNST Ms Royles
Baltimore
clearly

and

the

are unable to

the sufficiency
states solely to that

asserted privilege correspondence

Moreover
to the

answer

Interrogatory
that

No
relates

she

prepared
raised

Ravens

organization
fall

an

incident

by her

lawsuit

which

would not

within

the protections of the Maryland Shield

Law
is

Document
as are

Request
to

No 32

Ms
all

Royles objection based between and

her

on relevance

misplaced of the

here

well
not

Contrary within
is

her assertion

communications custody
of

her and members

public

the
clearly

Defendants
relevant issue
to

possession
the

control

Obviously and
the

Ms
request

Royles
seeks

reputation

allegations

Complaint

documents

related

to that

Document
information

Request

No 33
Facebook

Contrary
profile

to
is

Ms
directly

Royles
relevant

boilerplate to

objection
raised in

the

contained Like

on her Facebook

the

issues

her
to

Complaint
access
all

Twitter

provides

an

easy cost-free
including logged
to

and non-burdensome
status

method

information

on

Ms
tab

Royles

account

updates

email

messages

photos
should

listing select

of friends
the

etc

Specifically followed

when
by
the

onto

her Facebook

account

Ms

Royle

Account

Account
hit

Settings

tab followed
button

by

selecting entire

Download
account
will

your

Information

Ms

Royle may then

to the

the

Download

and her

compiled by Facebook

and emailed

email address Facebook

has on record

We

look

forward

to

your supplemented responses

reserve the right
to

and document
these objections
all

disclosures within once your

client

ten

10

days

of this letter
to

We

add

to

has
If

further

responded

her discovery

obligations

including
to

providing

responsive

documents

you have any questions

please do not hesitate

contact us

Very

truly

yours

HOLLAND

KNIGHT

LLP

Charles

Tobin

cc

Drew Shenkman

Esq

Holland

Knight

LLP

EXHIBIT
Plaintiffs

Revised Exhibit

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4/7/20

10

Glenn Clark blogs

of the

that

Ms

Royle

is

on notice

that

she

is

up

for the

Apologist

Morning

award

for her statement

regarding

the Orioles

Mike Gonzalez was TERRIBLE last night It wasnt all his fault but was TERRIBLE Hence Chris Stoner won our first Apologist of the
Morning
was the award from Drew Forrester and myself But She
said

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Jenn

Royle on notice
last

the Orioles would

compete

to

if

that

of Gonzalezs
Izturis

struggles
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And

if

Cesar

manages

game

instead of

they

might be

better

than

that

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

http //wnst.net/wordpress/glennclark/20

10/04/07/wednesday-

mornings-crabs-and-beer-96/

4/23/2010

Glenn Clark mocks

Ms

Royles commentary

of the Orioles 2-14 of the

to

record

He congratulates
The

her on winning the Apologist

Morning award
for

APs

David

Ginsburg says

Adam Jones
choose
to

wants

be role modeF

young African-Americans would

prefer that

Adam Jones
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would

be .good

role

model

to other

baseball players

by

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before

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hearty congratulations of the

to Jen

Royle from 105.7

thoughts

for being

named todays Apologist

record

Morning
something

Her

included 14 of
the last

To
me

lose

16 games and have

of 2-14..

to

just isn

adding
course

up
is

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to

wins She adds..

movie
Bull

quote
is

myfavorite

Durham
the

good

friend

of mine used
the
it

say

This

very simple

game

You throw

ball you catch

ball

you

hit the

ball Sometimes you

that

win sometimes you lose sometimes

rains

Think

about

for

while
LaLoosh
better

Ebby

Calvin

Nuke

Luke Scott said he

Baltimore Certainly course
is

praying things get

think the as the

entire

city of

as well

If things were only as simple

if

movies
as the

huh
of

would

For example

things

were

as

simple

movies Id

be with

Mila Kunis.

Glenn Clark Glenn Clarks Blog Friday

http //wnst.net/wordpress/glennclarkl2O

Mornings Crabs and Beer

available

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10/04/23/friday-mornings-crabs-and-beer-

90/

4/26/2010
stereotypical

On

his

blog Drew
she
is

Forrester states that

Ms

Royles
that

hiring

was
is

because

an out-of-towner

He
that

later states

she

not

qualified to ask any questions

and

insinuates

she frequents

hang outs of

Yankees

outfielder

Nick
is

Swisher

Jen
duties

Royle

the

new

0s

beat reporter

for the

teams

flagship to

radio station handle the

105.7

In typical

Fan Fashion
the

they hired an out-of-towner

all

of covering

team

In

fairness
.no

if

youre Shes

going

to hire

beat

reporter she might as well be pretty

offense

Casey
not equipped to even ask

What
ask

will Jen

Royle

ask

MacPhail
fan
in

Answer Maybe

anything shes
to the

Yankees

she can

MacPhail
heard

if

hes

ever

been of

Cobb Chop House

favorite

Manhattan

think

her say its one

Swishs

hang

outs
Blog
at
It

Drew

Forrester

Drew

Forresters available

takes

20 minutes Orioles shouldnt

run

from the challenge

flag

http //wnst.net/wordpress/drewforrester/20

0/04/26/it-takes-20-minutes-orioles-

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

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10

Glenn Clark blogs

of the

that

Jen Royle

was

in the running that

to

win

The

Orioles Apologist

Month
which

He
seems

also to

states

she

is

up

for

comparable

award with the Yankees

mock

her

New York
included
as

ties such former

The

nominees

for

Apologist

of the

Months
Yankees

Apologist
-Jen Royle

of the

Morning
is

winners

and nominees
for

who

also

nominated

apologist

of the

month

.1

BUT..
None
of them were ready
to

claim

major championship
of the

Glenn Clark Glenn Clarks Blog The Orioles Apologist

available
at

Month

Is..

httpwnst

networdpress/glennclarkl2O

10/05/03/the-orioles-

apologist-of-the-month-is

5/12/2010

On
day

his

blog

Glenn Clark

ridicules that

statement she

made by

Ms

Royle

in

her commentary
earlier that

of the Orioles

He

notes

won

Apologist

of the

Morning

The Suns Dean Jones Jr

solid

says Joey Gathright

Brandon Waring had

night for before

0s

on farm
the Orioles

And
Great
first

we move on from
to our

few things..

A-Congratulations Arbitrator on

Apologist

of the

Morning
Morning

as selected

by The
It

AM1570 WNSTs The

claimed the

Reaction

isnt the

time Jen Royle has

this

award

but its one of the funnier efforts

from her

season Via MASNSports.com..

Orioles have

You
really

think the

problems Compared
he

to the

Mariners

they

don
.Cliff

Hmm
The
not

Lee

last

night-was

problem

for the

Mariners Or for

the

Orioles
statement
is

obviously

ludicrous

The

Orioles not only have

as

many if

MORE

problems than

the Mariners

they have more problems than Jay

z..
Glenn Clarks Blog Wednesday Mornings Crabs and Beer available
http //wnst.net/wordpress/glennclarkl2O
at

10/05

2/wednesday-mornings-crabs-and-

beer- 10

5/18/2010

Glenn Clark

states

in his blog

that

Ms

Royles

description of

game

was

irrelevant

He

notes that

she once

again

won

the Apologist

of the

Morning

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Great Arbitrator

to

Sgt

Jen

Royle who was

she over

AGAIN
105.7..

selected by

The

Drew

Forrester as our Apologist

left at

of the

Morning Drew
new manager

honored Jen went

to the

for these

thoughts

Kansas

City side post

the

game and

listened

to their

Ned

Yost

compliment

pesky Patterson two

Butler

who when

2-for-4 with
their

RBI

up top and then heard Billy The 0s got praise Bergesen

that

compliments from win column

could exactly

opponents but unfortunately

doesn

help

in

the

have dissected the Orioles pre-game meal and

as

it

would

have been

relevant

Wow

Glenn Clark Glenn Clarks Blog Tuesday

http //wnst.net/wordpress/glennclark/20

Mornings Crabs and Beer

available

at

10/05/18/tuesday-mornings-crabs-and-

beer-97/

5/19/20

10

Glenn Clark blogs

that

Ms

Royles

description of an Orioles

game
she

was wrong
is

He

later analogizes

her to

character on the Jersey Shore because

disaster The

He

states that

he doesnt want her to do her job better says Orioles touched

APs

David

Ginsburg

up Royals

bullpen

after Creinke

departed for 10 inning

win
over
at

No

the

Orioles did not Jen Royle

beat
cough
is

Zack
said

Greinke despite what someone

105.7

cough

They

did however

win

game

started

by Zack

Greinke which

Edit from
similar to

GMC

Some

ALMOST just as good vith might say Im obsessed

with

her Theyre right Its from Jersey Shore

how many
as

of us are obsessed
that

Snooki

Its just such

that as

disaster

how

can you possibly turn

to

away

The

reality is

much

say

want Jen Royle

do her job better

probably

REALLY dont

want her

to
at

Glenn Clarks Blog Wednesday Mornings Crabs and Beer available

http //wnst.net/wordpress/glennclark/20

10/05/19/wednesday-mornings-crabs-and-

beer-i

02/
10
as

6/2/20

On
The

his

blog

Glenn Clark
loss

mocks

Ms

Royles

description of an Orioles

game

heartbreaking

APs Howie Rumberg

in

says

Tejada

made

costly error as Orioles

fell

to

Yankees

New York
described
it

Our

girl

Jen Royle

as

one of the most heartbreaking

it

losses

of

the season

The

rest of us barely to

even noticed
getting in

happened

In fact as the out Shrek

game was coming

close

was

my

car to go check

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heartbreaking

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2010
at

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http //wnst.net/wordpress/glennclarkl2o

10/06/02/wednesday-mornings-crabs-and-

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04/ link

to

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MLB
Ryan
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gMLBg30060

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mocks
of the

Ms

Royle

as

barely having missed winning the award for

Apologist

Morning
out the Apologist Jen of the

653-Giving
between

Morning

award

It

was

50-50 shot

the great

Royle

or

first-time

candidate
pulls the

listener

Allen

McCallum

The rookie Allen McCallum

upset

and wins

it. .congratulations

Allen for winning the Apologist

of the Morning

award
Ryan Chell
Chellin

Out Wednesday on

The

Morning

Reaction

available

at

http //wnst.net/wordpress/ryanchell87/20

10/06/02/wednesday-on-the-morning-

reactionl

6/5/20

10 Glenn Clark

tweets

GMC
Game
Tweet

local

journalist

in

town whose

is

apparently

playing

in

Celebrity Softball

With

Ravensplayer
by

name

they cant

spell

copied

Ms

Royle from Twitter.com

6/9/1020

Ryan

Chell once

against

mocks

Ms

Royle about Apologist

of the

Morning
Trying to give out the Apologist MASN/105.7 the Fan employees
wins
for the article

of the Morning
in

Two

of

the

nominees

are

Jen Royle

and

Rock Kubatko

Kubatko

he wrote

last

night for

MASN

Sports
Reaction
available
at

Ryan Chell

Chellin

Out Wednesday
to

on

The

Morning

http //wnst.net/wordpress/ryanchell87/20

10/06/09/wednesday-on-the-morning-

reaction-2/

link goes

http//w-ww.masnsports arent-enough.html

.com/school

of

rochl2o

0/06/when-7-runs-and-

15-hits-

8/5/2010

Casey Willet
just

co-worker and
her on the
air

CBS employee
morning and
she
that

notifies are

Ms

Royle

that

Glenn Clark

ripped

that

now

calling the

Ms
Ravens

Royle Jen

Midol Comments

included

knew

nothing

about

247747-1

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and did not

know

what the term blitz meant but

that

she

knew who

the

right

fielder of the

Yankees

was Nick
Ravens

Swisher.1

9/7/2010

During

practice

Ms

Royle claims
that

that

Glenn Clark

told

media member/CBS lied on

co-worker

Damon

Yaffe

she
experience

my

resume and do not have the

to

credentials/

saw

have

and do not deserve

that
it

be covering
to her

the

Ravens

Clark also allegedly stated

is

brutal

listening

and inquired

why CBS
Patrick

didnt have anyone Gleason and Kevin

better

to cover

the

Ravens
to

Letter to Ravens

sent

by Jen Royle
Baltimore

Chad

Steele

Bryne employees of the

9/12/2010

Ravens

Organization

in late

2010

Drew

Nestor and Glenn tweet

about

her
called

Glenn
front

Clark Cant believe

JenRoyleMASN
thought her

me

douchebag
meant

in

of everyone here tonight

working

for the

Yankees

class..

Ms Royle
Clark

alleges to think

comment was

not in front of

anyone

Glenn

And

JenRoyleMASN
be considered
is

hasnt even heard

me

say that

what shes wearing tonight would

trashy
do know

at

the Gold

Club

Drew
truth
Tweets
cut

dont know
is

if

Glenn

D-Bag

but

this..

those boots

JenRoyleMASN
and copied

wearing

are

worth more than Glenn Clarks car

from Twitter

into

letter

to Ravens.2

Copies

in letter

to

Ravens

Ms

Ms Royle
Mr

Royle asks them

confronted

to

stop later in the

day him
his tweet

Mr
by the

Clark

and

told

was Crossing

the line

and was Extremely unprofessional While

Forrester walked
altercation

Ms

Royle was confronting

Mr

Clark

and yelled

Where

are

your

boots

Ms
first

Royle Asked
is

Mr

No This
then

Clark to step

outside

with
said

Drew

to talk

and Clark said

put your boots

not the right

inside

place
let

Drew

then

Go

home and

on

come

and

me

buy you

drink
of

After that another

media

member
looks

Jon

Gallo

CBS

Sportsline including

informed

Ms

Royle

Drew Nestor and Fuck that bitch She

that

Glenn made comments

like

stripper

Shes

complete

idiot

And Drew
Available
\ViIlit Letter to

Forrester

made
website

the

comment
with

Id

like to smell her

boots
Casey

on

the

Defendant

WN5Ts
in

Persons

personal

knowledge include Jon Gallo and

Ravens

from

sometime

Mid-september of 2010

247747-1

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Letter to

Ravens

Jon

Gallo

also

confronted

the Ravens Jen

PR

staff

and said
like to

If you dont
have

tell

WNST

to

stop talking negatively

about

Royle

would

my seat changed

9/20/2010

CJ

Spiller blogs

on

WNST
Jen

Good

freakin lord Shaddup

Royle
media
high school

First of all roles to

girl

Jen we

understand
in

you were demoted from Podunkamore .. You

Shore Copied
not
sports

New York
talk like

your current spot here

trying out for the

Jersey

reporter on

from CJ

Spiller blog

WNST.3
with
at

9/21/2010

After

brief encounter

Drew
water

Forrester cooler

at

the Ravens

facility

where

Ms

Royle was approached and asked

her

the

Drew

Forrester invaded Instead

Ms
she

Royles
walked

space

how

she

was

away Drew
you want
to

Forrester then

Dont
Drew

know how

am Ms Royle

yelled

Ms Royle did not respond to Ms Royle Wait where

responded

you going

Not

really

Forrester later tweets

girl

is

lucky

snapped

her head

my off
real

roid rage hasnt kicked

in yet or

would

have

He

then tweets

It was
she

definitely to

water-cooler

spoke

me

But

dig the hell out

moment was of her boots

shocked

at

the

way

Next he tweets

Miss He
He
also

America
that

has

left

the building

without

apologizing

to

me

tweeted

her
fUrther

two

favorite

teams

the Yankees

and

Rays

.1

tweets
lost

power

at

WNST

about

40 minutes

ago Rumor
hee

is

someone

saw

Jen Royle running Finally

away from

the building

hee

he tweets doesnt know where Hopkins from Twitter

is.

Jen
Copied

.LOL

10

by Jen Royle

Blog no longer
longer

available

on website

available

on Twitter

247747-1

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On

or about

10/1/201

Drew

Forrester leaned

far

back

in his chair staring

at

at the

Ravens

facility in

Owings was

Mills and eyed

Ms

Royle up and down

her legs

Mr

Forrester conference

well aware that

Ms

Royle witnessed

this Later in the press

room when

Ms

Royle walked past

Mr

Clark Forrester yelled

in trouble

to

Clark

Dont

say anything

Glenn

We

dont want

to get

again Upon
at

commencement
legs as she

of the press conference

Clark and Forrester stared

Ms

Royles

walked past and laughed

Ms

Royle and the Defendants

have personal knowledge

of this occurrence

10/8/2010 herself via

to follow

Drew
tweet

Forrester condemns during the Ravens

fan jokingly
Steelers

encouraging

Jen to

kill

game
game
at

The fans tweet

appeared

Drews

jab

that

Jen was watching tweet

as very
it

the
that

home
to kill
it

one
wasnt

of her joke

critics authored
It

encouraged Jen and Jen took

to

herself

It

came
stress to

across

serious
is

that

way

in

her
or

response
implore

cant someone

how wrong
their

for

anyone

EVER Mud

encourage

end

life
available
at

Drew

Forresters

Blog Coat your big apple with some Friday

http //wnst.net/wordpress/drewforrester/20

10/10/08/coat-your-big-apple-with-

some-friday-mud

11/18/2010 appears
to

Drew
be

Forrester blogs that she thinks

all to the

fans

wont
as

get to meet Jen star

Royle

This

joke that

of herself
Fullerton

Come
Morning

one come
Reaction

Pub
with

tonight the

at

7pm when The

hosts

Rub

Elbows

Stars

And no
It

that

doesnt mean youre going

to

meet Jen Royle

means
of

were

going

to

meet

YOU

and rub elbows with

YOU

the

real

stars

WNST
Drew

radio and

WNST.net
Blog Tonights
at

Drew
begins

Forrester
at

Forresters

the night

Our canned

food

drive

The

Fullerton

Pub

available

hap wnst.networdpress/drewforrester/20
food-drive-begins-at-the-fullerton-pub

10/1

1/1 8/tonights-the-night-our-canned-

11/26/2010

Drew
further

Forrester blogs that insinuates

that

Ms
is

Royle

is

not
in

fan of Baltimore
outfielder

sports

teams and he Swisher

she

interested

Yankees

Nick

247747-1

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Its

no

secret

that

one of our

local

radio reporters in town she isnt well

fairly personal

isnt

fan of passed

Baltimore along

sports

teams

And

because

known here
questions take

questionaire

to her with If

some

One

of the

you out on date and try to earn your affection what would you want him to wear She sucker for wrote man in uniform so heres what Well Ive always been
questions was this

you could

ever have

handsome man

Id
Drew

like

him

to look

like

Forresters

Blog Stuff yourself with Friday

Mud

available

at

http /wnst.net/wordpress/drewforrester/20

10/11 /26/stuff-yourself-with-fridayat

mud

link goes

to

picture of Nick

Swisher

http//www.zimbio.com/pictures/d3hjwdZ1

pYelBostonRedSoxvNewY

ork

YankeesyXBAZYPbiQY/Nick

FSwisher

12/27/2010

Drew

tweets

that

is

suspicious

that

Jen

received

WNST

text

during

press conference

which he

finds

humorous
text

RT @WNST
conference

Drew

WNST
looked
at

went out during the Harbaugh phone

at

press
at

and

she
town

her

cell

the same time

looked

mine
media

LOL @WNST
folks in are

Drew At least we now know some of the other fans ahem of the WNST text service hehe

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

10

247747-I

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HPK/ROYLEv.WN5T

Best example of someone

here
Jen

coming

to

town

like

bull in

china

shop and
she got

alienating herself by pissing on all things Baltimore

from the minute

Drew

Forrester

Royle And the vote wasnt close Next topic Drew Forresters Blog My Best of the Best in 2010
at http //wnst.net/wordpress/drewforrester/20

Dec 29

2010 available
the-best-

10/12/29/my-best-of-

in-20 10/

Several

comments on

the blog

show how Drew

Forresters

comments

affected

people

Steve

Says December 29th 2010

Oh

and while

have

413 pm you .enlighten

at all

what did she do

to garner

the

Royle Whats her deal and hate Dont really know much about her..
us on Jen Jen

DF
Shes

Hatebad word No
an out of towner

one

HATES

Royle
the place

dont know

her deal

who

showed

up here

earlier in the

year and

immediately started

talking about

how much

sucks

Says December 29th 2010

bhop

at

102

pm
Baltimore .She has
to

Man

she specifically err or

is

dogged
it

DF Brian
anyone
attention

Tom.
If

you What
up on
it

did she

actually

say
to

specifically

dogged youre

Baltimore

and everyone

you havent

picked

not paying

Stanton

Says December 30th 2010

Best example

Salter

at

1207

pm
radio talk-show
his

of

local

sports

host bashing

the

very

successful marketing efforts

of one of
ripping the

employers

sponsors

WNSTS
Preakness

Drew Preak 2010

this

Forrester completely

Maryland

Jockey Clubs
in attendance

On
so the

slogan Preakness
slogan

had about

100000

once again

in

worked
negative

wouldnt have comments on

are at in

stooped

to this level

by posting

however Your

here about

Jen
is

Royle reminded
this.

me
you

of how unprofessional
to criticize

you

times

My

question
to learn

.Who

are

new
make

young

talent

town trying
arrival

Perhaps

she

did

few blunders upon

at

ropes dont know just going

the
is

by what youre saying but she

getting

least deserves

few breaks while she on

the

comfortable
for

in her

new

surroundings
it

You

other

hand have

been here

long time and

seems you have no problem bashing

11

247747-I

PRDR0000I

HPK/ROYLEv.WNST

Baltimore

traditions

such
the

as the

0s

and Marylands

largest

sporting event
sticking

The Preakness For

up
for the

record Ive never even met Jen Royle Only

new

kid in

town

Says December 30th 2010

bhop So she
openly
If

at

1259

pm
bunch of other Baltimore Did
reporters that

literally

stood

around

and

talked about

how much

she hated Baltimore thing

really

happen

so

thats got to be the weirdest

Ive

ever heard

It

is

interesting

to

note that she had that

specific

much

of an affect

on you

that

you

were inclined

to include Interesting

section in your 2010

review
is

to call her

out unprovoked Baltimore has

indeed

DF Anyone
10/1

who

critical

of

an affect

Drew

Forrester

Drew

me Im from Baltimore Forresters Blog My Best of the Best

on

in

2010

available

at

http//wnst.net/wordpress/drewforrester/20

2/29/my-best-of-the-best-

in-20 10/

1/2011 nothing

Drew
but

Forrester sends

series

of tweets
she
is

saying that

shed

look great
tourist

in

Nick

Swisher
vacation

shirt

and

that

stuck-up snobby
that

on

brief professional while

insulting

here

Nestor tweets
she was

she

is

ignorant

and clueless

her bosses

who

thought

qualified

@WNST
at

Drew

So

Im

handling

@mattvensel

and jenroylemasn today

all

WNST.net

Hell

get

it .she

might cry.. but its

good nonetheless

@WNST
great in

@NoTjenrolemasn
Swisher
shirt

@ienrolemasn
else

Drew Well

bet

youd

look

Nick

and nothing

LOL
you know where
is.
to

@WNST
find

yoitschad

JenRoyleMASN Drew Well

how
cute

her Shell be the one talking about

A-Rod

@JenRoyleMASN Drew Im
you were wearing yesterday

exhausted smelled

trying

to figure

out what perfume

You

fantastic

@WNST

JenRoyleMASN Drew And

tourist

think the fact that vacation

youre
is

stuck-up snobby

on

brief professional

here

COMICAL too
12

247747-1

PRDR0000I

HPK/ROYLEvWNST

@WNST
of-town

Nester

When Ravens

season
are

ends

Ill

engage w/ignorant

out-

genius

journalists who

clueless

For

now Im purple

focused

@WNST
Renegade
qualified

Nestor But Drew has been

.. real disgrace
is

KIND

to

Miss Yes

Jen

in corporate

bosses

who

though

Mr Yeah theyre

Copied by Jen Royle from

twitter.6

1/11/2011

Drew

Forrester tweets

that

Jen Royle

is

just

tourist in

Baltimore

@WNST
Thats
her

Drew LOL that Jen Royle thinks Im OPINION Heres my FACT Jen an
is

obsessed

with

he
tourist

out-of-towner

Copied by Jen Royle from

twitter.7

Glen Clark tweets towners

his

agreement with

that

assertion

Drew

then threatens out-of

@WNST
Baltimore

Sparky4ddub and
try to
tell

Drew Well

out-of-towners
sports is..

who come

to

ME

about

Baltimore

using your

word

.annoying

@WNST GMC
to

Im

glad

let

Drew

write today he handled

it

well Kudos

him
Drew
Forrester Out-of-towners

@WNST
to pick

beware.

.this

isnt

good week

on Baltimore http//bit.ly.fK3hnI-l

@WNST
Drew Hey
worries..

@DamStone JenRoyleMASN @1
its just like pro wrestling

O57TheFan
role to

@matt\ensel play

We

all

have

No

Copied by Jen Royle from

twitter.8

Glenn coming

also

posts

blog

in

which

he

states that

Ms

Royle has fanned

scent

flames since

to Baltimore

and

that

he thinks

she has

good

Jen

Royle has been fanning the flames since the day she graced
last

us with
that

her

presence

spring

And

in

FULL

disclosure
at

have
the

to admit

she

SMELLED
6No No No
longer longer longer
available available available

like

million dollars

yesterday

Ravens

press conference

on on on

Twitter Twitter Twitter 13

247747-I

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Yesterday honestly wearing

.it

she

literally

did grace

us with

whatever

she was

was glorious

When
Quick

you

arrive

in Baltimore

to

work
where
wasnt

and kick the door down and say

banshee you cant come in like is the son-of-a-bitch Note

Brian

Jen who when

said

that
It

No

it

Matusz

think he said the coach of the

Love
Ravens
with

those jeans. they

was Brian Billick you

know

won

the Super
that

Bowl and

the guy the

who was

so impressed

our

small audience Drew

Forresters

he bought

into

station
beware.
.this

Drew week

Forrester
to pick
at

Blog

Out-of-towners

isnt

good

on Baltimore
http //wnst.net/wordpress/drewforrester/20

available

11/01

11 /out-of-towners

bewarethis-isnt-a-good-week-to-pick-on-baltimore/

Drew

then

comments

that

Ms

Royle

prefers

other cities and

is

just in Baltimore

on

scholarship

As

for that

girl

at

105.7 she can

Fells

try to write about

how much
sunset

she loves but the truth

crabs and of the

Sabatinos and
is

Points great view

of the

matter

that

shes here on scholarship

in Baltimore will

She knows that Three years by someone

else

from

now

her apartment
or

be occupied

and

shell be in Chicago

Los Angeles or Miami or some other perfume

ritzy place

where her

pretty

smile and expensive

habit will be part of

some

other stations budget

EDIT from DF
ferocious anything baseball Baltimore but

at

535pm

Since

posted

this

len has launched

that

into

Twitter attack

claiming

among
talk

other things

Ill never
cries

be
his

miserable small-time She should know small-time

show

host

who

over
in

team
to be

lot

about claiming
is

something

since she

on

the

record saying she had

the

numerous job opportunities when she

ahem

left

YES Network
to be

in

2009
in

but chose

Baltimore

because

it gives

me

the

chance

big fish

SMALL pond
Drew
Forresters

Drew week

Forrester
to pick

Blog
at

Out-of-towners

beware

.this

isnt

good

on Baltimore

available

http //wnst.net/wordpress/drewforrester/20

11/01

11 /out-of-towners-bewarethis

isnt-a-good-week-to-pick-on-baltimore/2/

1/16/2011 implies that

In

tweet
is

Drew
that

Forrester seems to be referring lost

to

Ms

Royle when he

she

upset

the Patriots

14

247747-1

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HPK/ROYLEv.WNST

@WNST
the

Drew Somewhere
feel

tonight

certain

local

journalist

is

down

in

dumps

bad

for

her Really

do

do Really

Copied

by Jen Royle from twitter.9

1/20/2011
conflict

Dave Hughes
of
interest for

answers

question

on

DCRTV.com
on
the

that

it

would be
for

Ms

Royle

to date

player

on the team she covers team and

MASN
available

The

question

he responded
that

to stated

people

MASN
Likely on

employees were well aware

at
10

she has been dating

an Orioles pitcher

http//www.dcrtv.com/davetvl

.html but no sound

to confirm

1/21/2011

Drew
link
is

Forrester blogs with picture of

link

2010

The

sign saying

sign Welcome to
to

that

ruined

Ms

Royles

Baltimore

The
Drew

sign that ruined

Jen Royles

entire

2010

is is

RIGI IT
better

Hon hERE
day
at

Forrester

Drew
at

Forresters

Blog

Friday

Mud

than

the

beach available

http //wnst.net/wordpress/drewforrester/20

11/01/21/friday-

mud-is-better-than-a-day-at-the-beach
http

link

to 10/1

//www.baltimorebrew

comlpublishwp-content/uploads/20 .jpg picture of

2/honto

welcome-to-baltimore-katrina-krauss

sign saying

Welcome

Baltimore

Hon
Drew
Forrester states in response
that also to

1/26/2011

comments on

his blog
is

that

the

only qualification

Ms

Royle has

to be in Baltimore

Magazine

that

she she

works here

He

says he likes the

way

she smells and questions

why

makes herself smell good around athletes

Al
How

Says
26th 2011
at

January

848 am
Baltimore

embarrassed should personality

as

Magazine

be for promoting
eligible

certain

sports

one of Baltimores most

singles

singles Shouldnt
or an

the criteria be that Baltimore

active

should

actually

be from Baltimore

member

of the Baltimore

Second
friends horrible

question

When

said

community Baltimore single commented how

all from out of state
Baltimore agreed is shouldnt
to

all

her

and back tracked

her magazine
retraction

to include

how
up the

picture

Magazine

offer

community
Perhaps

of their mistake
waited
until the

add

her
travel issue to highlight
all

they shouldve

spring

of

the tourist sites in and around

town

9No

longer
to

available

on on

Twitter computer with

be

verified

sound Video

clip no 15

printout

247747-1

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DF
our

This

is

question

better

suited
is

for Baltimore as long as

Magazine

and

their

selection

committee

My

guess

you

WORK

in

Baltimore

youre

eligible

havent

seen the other

the

sexy

singles so

dont know how

girl got in but too bad

.if

magazine didnt have Thats

scratch and sniff

sticker.

you know

what

mean

her best attribute

by far

Kristen January

Says
26th 2011
at

1149 am
actually

Drew Have

you ever

met and talked with Jen Royal shes

is

or

do you
to

disrespect her on the air because

female

and

according

always smells
sports

really nice

which

your way you dont

of saying

she doesnt

you know

but because

she smells nice she has

job
like

She probably her

doesnt give

you the time of day and thats

but Ill

why

DF

Youre funny
occasions

humor you more Ive Ive

talked to Jen Royle on several

Each

time shes been condescending

snarky unfriendly and snobby

sports of that

think she
said

knows
is

sports

that

she doesnt

NEVER once said she didnt know know BALTIMORE And because
at all

What Ive
she has

no

historical

perspective she smells

to

on the Orioles and Ravens

are

My

remarks about

how

great

.those

COMPLIMENTS

She always smells great

great

Youd
admit

have

ask her not

of athletes Thats

why she insists on smelling that for me to decide But she always
Blog Back
in the saddle

around
like

bunch winner

smells

that
Drew
Forresters going
to

Drew

Forrester

again 21 Questions
at
1-

Returns

Update Were

OVERRRRR-TIME

available

http//wnst.networdpress/drewforrester/20 questions-returns

11/01 /26/back-in-the-saddle-again-2

1/28/2011-

Drew
to

Forrester states in his blog shoot with

all

that

Baltimores own
outfit

Jen

Royle

showed

up

photo

Nick

Swisher

By now Im sure
Baltimore
as

nearly

of you have
features

picked

up the

latest

copy of

Magazine

which

Baltimores own

Jen

Royle of

MASN
her an

one of our citys

Sexy Singles
at

Evidently

Jens photo shoot didnt go so

staffer

well
outfit that

When

she arrived

the location

the magazine

handed

and asked

her to get

dressed Royle replied

little

But

brought the editor

something

think depicts Jen to wear

allow

wouldnt Fortunately my style THE CLOTHES SHE BROUGHT TO THE PHOTO

better

SHOOT
16

247747-1

PRDR0000I

HPK/ROYLEv.WN5T

Drew

Forrester
at

Drew

Forresters

Blog

Just in the nick

of time its Friday

Mud
is

available

http //wnst.net/wordpress/drewforrester/20

11/01/28/just-in-the-nick-

of-time-its-friday-mud available
at

link provided

shows Nick

Swish

outfit

below

and

http//product.images.fansedge.com32-3

0/32-303

54-F.jpg

In the

comments

to the

blog

someone

responds
that

on January
could

29t1
it

to insults

about

Jen

Royle and Drew malt Says

January

Forrester responds

she

handle

29th 2011

at

1130 am

do think thejen agree you

towards

royle stuff

is

funny along

with

everything
tail

else

but

also

definitely totally

have the kindergarten pig

crushing

pull thing going

on

her

on her

for

good reason looks not personality

pull

brett

favre on her thats

my

advice but do

it

from

pre paid phone

DF
you

Whatever.
for

.shes
to

from Boston.
crush

.she

can

handle

little

chiding

Theres

no reason

actually

on anyone Im married And trust me once meet her the crush-thing ends Shes boorish snobby and

me

have

caustic

Other

that

that shes

real

peach
of time its Friday

Drew

Forrester
at

Drew

Forresters

Blog

Just in the nick

Mud

available

http//wnst.net/wordpress/drewforrester/20

11/01/28/just-in-the-nick-

of-time-its-friday-mud/

2/04/2011

Glenn Forrester blogs and eventually

pal Jen Royle
at
is

that

Ms
for

Royle needs
picture

nickname
of the

suggesting

Jenny-Poo

settling

on

link to

New Yorker
baseball year in
all

Our

prepping

season

of outstanding

coverage

MASN
like

and

now

that

shes embarking

on her second
considered

Baltimore
natural

figured its time to give her

nickname
or

of the

ones

Jenny-poo Jen-Jen
17

Roysie

However

none of

247747-1

PRDR0000I

HPK/ROYLEv.WNST

those
fits

were

as

appropriate

as

THIS

NICKNAME
The
Great

for

her

Hey.

.if

the shoe

Drew

Forrester

right Drew

Forresters
at

Blog

Friday

Mud

is

the

preferred

nomenclature available

http//wnst.net/wordpress/drewforrester/20

11/02/04/the-

great-friday-mud-is-the-preferred-nomenclature
http

link

to

//www.macgasm.net/wp-content/uploads/20 of an iPad with

the

0/09/new-yorker-ipad

.jpg

picture

New

Yorker displayed

on it

2/22/2011
is

Nestor she has

comments
pretty

that

the

only reason
that
is

Ms
is

Royle has been employed

not qualified
to discuss the

because

face

and breasts

she

Orioles or any other team because

Ms

Royle

woman.1

3/30/2011

Nestor can

blogs anywhere on the

that internet said or

You
truth

search

shred of evidence

weve We

ever

you like and you will not find done anything more than tell the
behavior
in social

about her journalism

in

skills

and her outlandish

media

and

Owings

Mills

literally

have hundreds and hundreds of public

via social an

pronouncements would

made by Miss Royle

employee

media

that

quite

frankly

make any WNST.net

at

ex employee

And yes

do

the

hiring and firing here

WNST
of people
in Baltimore

Miss Royles and she

is

feelings

have been hurt by thousands on what

as

quite

fighter based
that

we

read from her public

work

Her

blog reiterates

on

daily basis

she calls fans

jerks Baltimorons
public
just like this

and blog

the

like

You

can

check

it

out for yourself

Its quite

Apparently
Perhaps
like its

shes only decided

because

to sue

us here

at

WNST.net
its because she feels
extract

were
in the

direct local

competitor perhaps

shell get her

name us

newspaper and shell eventually

the

some money
dealing
loser

out of
this

Win

or lose

attorney

fees

and

my time
case
Not

spent

with

nonsense

will certainly

be draining of this

my

piggy bank so

Im

beginning

today

no matter the outcome

frivolous

But

to spread

vicious

rumors about her Not

me

Not

this staff

EVER

at

WNST.net You wouldnt

world who have wanted
to hear to

my reaction
is

to

anyone

in

my professional

gave and somehow admit

me

advice
guilt

settle

lawsuit that

didnt have any merit

where there

none

Text

message

from stranger

18

247747-I

PRDR0000I

HPK/ROYLEv.WNST

Ive been
on
the

doing

this for

27 years
spread

as

professional

locally nationally and

internet

We

dont
able to

rumors
to

were
But

unabashedly

own up
at

We dont gossip We dont lie And ANYTHING we officially report via

our product
it

any of our media properties

WNST.net
is

were

also

not strangers

to pointing out that telling

the best in the

marketplace

every

day and

you

why

and proving
If

every
tell

day with you

our passion industriousness

and accountability
expect

we dont
to talent

how

good

we

are

we

certainly

dont

our competition out-of-town

do

it into

And when
marketplace Especially

our competitors

bring inferior
it

the

were

going

to point

out
brazen
to the

Yankees
serving I.
.1

when any media member would be so and Red Sox and so openly disrespectftil
the community
that
is literally

about

loving

the

community

theyre

feeding

them

No We
do

one

at

WNST.net
close

has

ever written or said what these allegations

suggest

Not even
said

Jennifer Royle

doesnt know

as

much

about Baltimore

sports

as

we

We

said shes

lacking

information and professionalism

which

if youve

followed

her on Twitter public figure

youd

see

why weve come

about our sports
sports

to that

conclusion
to

Shes

She has

fan page on

Facebook

She chooses

go on

the radio and serve up her opinions chooses

single to fight with

culture

And

she

Baltimoreans

and

local

fans seemingly every

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

for herself by suing the best sports

media day she

company
arrived hurt and

in Baltimore

pointing out what

sports
its

weve

known

since the

Shes
is

not

Baltimore
to injure

expert and partners

now

she has her feelings agents

trying

WNST

employees

and fans

by trying
Nestor

to take

money from
Royle

my company
An
indictment of local
at

Aparicio Nestor
our side

Aparicios Blog

journalism

Heres

of baseless

WNST

lawsuit available

http //wnst.net/wordpress/nestoraparicio/20

11/03/30/an-indictment-of-local-

journalism-here%E2%80%99s-our-side-of-baseless-royle-v-wnst-lawsuit/

4/18/2011

Drew

Forrester tweets

that

when

Ms

Mayor
he was

of Baltimore

died she responded

who
19

Royle was informed

insinuating she didnt

that

the

cx

know who

because

shes not from Baltimore

247747-1

PRDR0000I

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@WNST

Drew Somewhere
Schaefer

tonight

local

sports

reporter

was

William Donald

passed

away and

the response

was

who

told

Copied from Twitter by Jen Royle.2

5/4/2011

Personal

tweet

from Drew Forrester to Jen Royle

From @GlennClarkwNST

@CL_
Copied from

@BaltimoreLuke

Im 100%

certain
Ill

Ill

regret

this But in the

meantime maybe well have enough

twitter

fun

get sued

again

by Jen

Royle

6/4/2011 Baltimore

Glenn blogs
Sports Expert
fact that

in

honor

of Jen Royle not being

what he considers

In

honor of the

the

reporter from the

FM

sports

station

in

town had

trouble finding bucket

list

Towson

University yesterday

we

thought

wed

put together
this

for our

Tuesday

Top

which came on

Wednesday

week

Todays Tuesday
Consider Yourself

Top

topic was

The Top

Things

You Need To Do To
hope its
self

Baltimore

Sports

Expert As always
Reaction

explanatory Glenn Clark Glenn Clarks Blog Morning Tuesday

Top

Things
at

You

Need To Do To Consider

Yourself

Baltimore

Sports

Expert

available

http //wnst.net/wordpress/glennclark/20

11 /05/25/morning-reaction-tuesday-top-7-

things-you-need-to-do-to-consider-yourself-a-baltimore-sports-expert/

6/10/2011
is

Drew

Forrester blogs

insulting

Boston and insinuating

that

Jen Royle

unintelligent

Speaking
allowed Stanley
the

of

Boston

Im

quite

pained

by the having

fact

that

the Canucks

have

Bruins

back

in the series
it

won Game

and

of the

Cup

Finals to even

up

at

2-games apiece

know

.trust

me
even

know
The

Anytime someone
its

or something from Boston

experiences

morsel of success

disheartening

They dont
out of that

deserve

anything

only acceptable

things to

come

hell-hole are
Curtis

good The Cars Matt won one THIS times

of

Damon The
his

Country Club of Brookline and Steve Carell

where
Everyone
that

Strange

two

U.S Opens
Well

and everything apologize

voted 981

else. .sucks

OK

need

to take

back
record

PART

of Bostons

heritage didnt

suck

For the

12No longer

available available

on on

twitter
twitter

In

correspondence

folder

No

longer

20

247747-1

PRDR00002O

HPKIROYLEvWNST

Im sure
and
will

youve

heard

by

now

that

Mark Viviano
his duties

is

leaving
sports citizen

his post at

105.7

now
side

concentrate

solely

on

as the solid

anchor

at

Channel

13

On
.and

note

Ill

mention
his
is

that

Mark

is

and

good

guy.

hope he enjoys

new

less stressftil for

life sports

Anyway Vivianos
talk

departure means

The Fan

looking

new

host

As

is

always the case

his

Im hearing
As
has
to

rumors
their

and theyre

just that

rumors

about
for

replacement

become come
it

custom

105.7

execs are looking

their sports

someone

out-of-state

in

and

wow

everyone with
their search

knowledge
Carolina
flying

Rumor
and
that
is

has

theyve

centered

on

native of South with

THIS GIRL

RIGHT HERE
to take

passed

her interview
talk .but

colors

and

the lead candidate

over

Vivs

show

gig
of

Drew
Friday

Forrester

Drew

Forresters

Blog Hit
at

records are short.

this edition

Mud

sure isnt available

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 second

at

the

1986 World
http to

Series

available

at

//www.youtube
video

.comlwatchvghQ VU12T
giving

8Efeaturerelated

link

of

girl

bad answer

in

Miss Teen

USA

available

http//www.youtube.comlwatchv1j3

iNxZ8Dww
blog states that Jen Royle references
are

Comment on Drew

Forresters

common

Mike
June

from Carney Says

at

10th 2011

921 am
The

Finding

the Royle

references

in

Mud

is

like finding

the toy

in the

cereal

box Love it
think with

DF

Huh

To borrow
think

line

from Bull

Meat

just pitch

youre

thinking too

Durham. .dont much But have fun

.but this edition

it
Drew Foresters Blog Hit
at

Drew
Friday

Forrester

records are

short

of

Mud

sure isnt available

http//wnst

net/wordpress/drewforrester/20

11/06/1

0/hit-records-are-shortbut-this-

edition-of-friday-mud-sure-isnt/

About

6/11/2011

Ms

Royle contacts
he had
reliable

Greg Bader
source

to

complain

that

Glenn

Forrester told
that

reporters

from the Warehouse

who

told

him

Ms Royle had relationship with player Hi Greg Sorry to BOTHER you with this.. But Drew
was sleeping
in the

Forester
it

told

some

reporters

with

Matusz and
guarantee

is

now
is

saying going

came from
throw
that

reliable

source
the

warehouse

Drew
21

to

source

under

247747-

PRDR000021

HPK/ROYLEv.WNST

bus

in court to
is

make

himself look innocent

Any

idea

who

this

warehouse

source

and can you please confirm rumor

to

you did your

part

in putting this

ridiculous

rest

Again Tm
but
its

very very

sorry for the drama

and
if

you know

love you to pieces

very disheartening
directly

and disturbing

these kind

of false accusations was an employee of

come

from the organization

especially

when

MA SN
Thank

you

Jen
Email from Jen Royle

Mr

Bader

replies that

he does not believe

there

was

real

source
doubt

would

love to

know who

this

supposed source

is

he has one

No
it

one

know would have

spread
it

such

rumor
wouldnt

spoke with was

clear

Monica

about

and

she doesnt

know where
in spring

came from And

that

to her after

Brian

and

spoke and

training

tolerate

mongering
doubt
is

specifically

mentioned

this

item She agreed

any rumor and have no rumors As

doing

whatever

she can

to curtail the spread or

of false

am

have heard no such

rumors about you

any other media members

this

season
Email from Greg Bader

Exact

Dates

Unknown On
or about July

2010 Drew Forrester allegedly

at the

tells

Jerry

Coleman from Fox

Mt
with

Washington

Tavern
Jen

that

know shes hooking up

Royle mentioned
allegedly told
in the

Matusz right Drew

reliable

this in an email.14

Forrester also source Orioles

Jerry

Coleman
can

that

he had

Warehouse

that

confirm

Warehouse

offices

Drew
season

Forrester tweets

at

the beginning

of the 2010
for

Ravens
in

RT
source

@wnst

Drew Good

news

you guys

14

Comment

not

available

in

recorded

online

22

247747-1

PRDR000022

HPK/ROYLEv.WNST

BALT You
Jen
sent

can

follow
live

our tweets

live

from the stadium

to

or

Royles

tweets

from her

couch Appears
twitter

be
15

around 9/27/11

Copied from

by Jen Royle

On

or about

September

2010 Glenn Clark comments

on

blog that
short

he does

not understand
to

why Jen

Royle

wear
be on

skirts that

and boots

and

its pretty

games knowing cold outside

she

wont

TV

On
in

or around August

2010 during Ravens was crying segment on

the

training

camp
the

Westminster
heard

MD

Ravens

field

when

they had

called
--

Jen Midol on

morning

show Drew
to

and Glenn

That afternoon Nestor

out to

came up
shake

me

and introduced
declined

himself and reached

his

my hand

to shake

hand

said your radio and

dont

station
it

has

nothing

good

to say about

me

appreciate

because

you dont even know

me

He

said

have never

said

word

about

you

cant control

what other people

say
you

said well

Im telling

now

and youre the owner so

youre responsible

And

he walked

away
air

That afternoon he went on the

the biggest bitch Royle.16

and

told

everyone

was

he has ever

met

Email from

Ms

No

longer

available

on

twitter

The Defendants

Ms

Royle

have

knowledge

about

this

occurrence

23

247747-1

PRDR000023

HPK/ROYLEv.WNST

EXHIBIT
June

27

2011 Letter

to Plaintiffs

Counsel re 2-432

Holland
2099
Pennsylvania Knight

Knight
NW
Suite

Avenue LLP

100

Washington

DC 20006

202.955.3000

202.955.5564

Holland

www.hklaw.com

CHARLES

TOWN

202

419-2539

charles.tobin@hklaw.com

June

272011

Via

UPS

Overnight

and Email

Brian

Goodman
Pessin

Hodes
901

Esq Katz P.A

Ste 400

Dulaney Valley Road

Towson Maryland 21204-2600 bgoodmanhpklegal.com

Re

Jennjfer

Royle
Circuit

NASTY
Court

1570 Sports

LLC

et

aL

Maryland

for

Baltimore City

Case

No

24C1l00157l

Dear

Mr

Goodman
Rule with 2-431
further effort to

We
client

send

this

letter

pursuant

to

as

good-faith

resolve 2-421

your
2-

Jennifer Royles

non-compliance

her discovery

obligations

under

Rules

and

422 As you know

discovery
that

Ms

Royle
to

initially

responded with

on June
detailed

2011 explanation
briefly

to

our

clients

written

requests

We

wrote

you on June on June

table

of our concerns

with

response

Following

our letter
that

15 you and

spoke

by telephone

and

you

suggested

and

agreed
assured

we
June

further

discussion

until

after

we

had

exchanged
address
certain

documents most
of our

You

us

that

Ms

Royles

supplementation furnished

and documents Royles

would
to

concerns
responses

On

17

you

Ms

supplement

interrogatory

and you provided

us with

documents

We
in as

have

carefully

reviewed

the

information

you

have

provided

Unfortunately

Ms
noted

Royles supplementation
our June they indicate
largely letter In

and production
fact

did not address the majority

to

of the deficiencies
raise

we

the materials provided

us on June
that
still

17

new
she

set

of concerns and they

she possesses designed copies

to

number expand
the

of documents scope and of her

have not been provided Moreover

despite

appear

claims accounts

has

completely relevancy

refused to
to

provide

of her Twitter

Facebook

their

obvious

her Complaint

This

letter

supersedes

our
to

June

letter

and

specifies

the

numerous
to

deficiencies

in

the

responses you have provided discovery obligations

all is

date
the

Ms

Royles

continued

failure

meaningfully

meet her

impeding

timely course of this litigation requested

to in this letter

We

therefore request that

Ms
need

Royle provide
to

of the

information with

by July

2011

to

avoid

the

inconvenience

the Court

Motion

Compel

Mr
Page

Brian 2011

Goodman Esq

June27

Plaintiffs

Responses

to

WNSTs

Interrogatories

The
to

supplemental nearly
all

answers
issues

to

interrogatories

submitted

with

the June

17 production responses
detailed

failed to the

address

of the

we have

previously

raised under

Your

clients as

interrogatories

therefore remain evasive

and incomplete

Rule 2-432

below

Various

references

to

unnamed
therefore

individuals
are

Various

individuals
to

alluded

to

in

Ms
of

Royles

responses

and

who

material
to

witnesses
the

her

Complaint
for

remain any

unidentified

Furthermore
as

Ms

Royle has

failed

provide

contact

information

these individuals

required by the interrogatories

These references

include

Interrogatory

No
unidentified
in

The

current
to

and

former

colleagues

of

Defendants

referenced

the response

Interrogatory of the

No
local

The

unidentified
to

other

members

media

referenced

in

the

response

Interrogatory

No

Interrogatory

No
unidentified individuals within the Baltimore

The

Ravens

organization

to

whom

Ms
as

Royle prepared
in

correspondence
to

on or about
Interrogatory
at

August

14

2010
The

described

Ms

Royles answer

No
and
as

unidentified

colleagues

and management
emails

MASN
as

CBS

with

whom

Ms

Royle

exchanged

well

telephone regarding

conversations

beginning
as

on approximately
described
in

January
to

13 2011

Defendants conduct

her answer

Interrogatory

No

Interrogatory

No

10 individuals

The

unidentified

who have
reputation

called as

into

question
in

Ms

Royles
to

professional Interrogatory

and personal

described

her

answer

No

10 members
them
to

The

unidentified

of

the

public
that

who

believe

that

Defendants
liar

actions has

have caused

believe with

Ms No

Royle is
and/or

bitch
Brian

and
as

had sexual
in

relationships

Nick

Swisher

Matusz
with

described

her answer to Interrogatory professional has

athletes

10 Royle
covers
as

The

unidentified

whom
in

Ms
The

Royles
to

credibility

been

ndangered
Royle
contends
in

described

her

answer

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Account
button

tab followed
entire

by
will

Download

Information
emailed
to the

Ms Royle

may

then

Download
record

account

compiled

by Facebook

and

email address

Facebook

has on

EXHIBIT
June

27

2011 Letter

to Plaintiffs

Counselre 1-341

Holland
2099
Pennsylvania Knight

Knight
NW
Suite

Avenue LIP

100

Washington

DC 20006

202.955.3000

202.955.5564

Holland

www.hklaw.oom

CHARLES

TOBIN

202

419-2539

charles.tobin@hklaw.com

June

27 UPS

2011

Via

Overnight

and Email

Brian

Goodman Esq
Pessin

Hodes
901

Katz

P.A
Ste 400

Dulaney Valley Road

Towson Maryland 21204-2600 bgoodmanhpk1ega1.com

Re

Jennter Royle Maryland

Circuit

NASTY
Court

1570 Sports

LLC

et

for

Baltimore City

Case

No

24C 11001571

Dear

Mr Goodman
We
send
in this letter

pursuant

to

Rule

1-341 which
justification

prohibits

litigants for

from maintaining
the Court adverse
to

proceeding

bad

faith

or without including

substantial

and provides
fees incurred
in

award party
narrow about

the reasonable
This your
letter

expenses

reasonable

attorneys

by the
asked

follows

our telephone
to
fit

conversation
the

of June of

15 2011
this

which

you

to

clients

claims

prevent within

proliferation

litigation

through

allegations

statements that

do not

the torts that

remain

in the

Complaint

As you
action for Plaintiff for also

are

aware

the Court

at

the

June

2011

hearing

dismissed

your

clients

cause
that

of
the

intentional

infliction

of emotional
the

distress in

Count

IV
as

With your
the Court

concession dismissed

inappropriately of privacy

included

count

her Complaint

her claim

invasion

by publication
causes

of private

facts

Count II
in this

well

The

dismissal of these

claims

leaves two of privacy

specific

of action

remaining

lawsuit

defamation

and

false

light

invasion

Counts

and III

As you
Plaintiff that are

thrther

rare

aware

the

defamation

and
false

false

light

torts

each

requires

that

the

plead not

and prove
fact

among
are

other elements not capable

statement
true

of fact
are

Alleged
are

statements actionable

and

that

of being

proved

false

not

under

these torts

raised

this

issue

with

you

in

our June

15

telephone

conversation

where
as

we

discussed can
tell

your

clients

initial

deficient

discovery

responses Since

Your
the

clients

Complaint
all

best

we

includes

12

allegedly actionable

statements

Court

dismissed should

claims

but defamation following your

client

and
the

false

light the number hearing

the

of allegedly
in

actionable
the
initial

statements discovery

have decreased you

total

June

Nevertheless of allegedly

responses

served of

increased

number

actionable

statements

and

listed

29 statements

Mr Brian
June

Goodman

Esq

27

2011

Page

During our telephone narrow

conversation

on June
to

15
those

asked

you

to that

reconsider arguably

the

statements
fit

and

Ms

Royles

Complaint

only

statements

would

within

defamation

or false light causes

of action

You

advised that

the Plaintiff

would

do this

Following

that

discussion
to

on June
Included
in

17 you
as

served

supplemental
is

interrogatory

responses contained previous

in
list

and produced PRDR000001-23

of allegedly claim

documents

us

those documents

an

entirely it

new

list the

and PRDR000099-lOl
statements
least that

which

we

understand

supersedes
this

actionable includes
at

you provided

on June
actionable
to

At

juncture

Ms

Royles
just

now

50 separate allegedly
such
as

statements her as

To name
of the

two

examples

Ms

Royle

lists

phrases others

those referring
to

apologist

morning
because an of

see e.g PRDR000002

she
is

and

analogizher
Neither being
as

character statements
or or

on the Jersey Shore

even arguably
are

disaster
of
fact or

PRDR000005
is

of

these
true

contains dozens

assertion

capable

of

proved

false
false

These

among

statements

that

simply are not actionable

defamation

light invasion

of privacy

Ms
squander believe

Royle and you

appear

determined
in

to

make made

her allegations
to

as

broad under

as

possible to

our resources these

and the Courts

allegations

derogation

the obligations vexatiously

the Rules
for

We
of

extraneous

have
an
effort

been
to

solely

purposes unnecessary of

harassment proceedings actionable

or unreasonable

delay
insist in

in

drive up costs

and cause otherwise withdraw

provide the us
list

We

therefore

that

by July and
are

2011
that

you

allegedly

statements of those
so that

provided statements

discovery contend proceed

you

instead as

with or

discrete
false light

narrow

list

you

actionable discovery

defamation an

portrayal

we may

efficiently

with

under

appropriately

defined

claim

We
Rule
1-341
obligations

send this letter in an effort to resolve

this
letter

dispute
in

prior

to

the

filing

of

motion under
discovery

and other applicable rules

or our clients
rights

This

no way waives

your

clients

and remedies

Very

truly

yours

HOLLAND

KNIGHT

LLP

Charles

Tobin

cc
CDThje

Drew Shenkman

Esq

Holland

Knight

LLP

EXHIBIT
Plaintiffs

Supplemental Responses to
Interrogatories

WNSTs

and

Supplemental Exhibit

JENNIFER ROYLE
Plaintiff

IN

THE

CIRCUIT

COURT

FOR NASTY
1570

SPORTS LLC

et

cii

BALTIMORE
CASE

CITY

Defendants

NO

24-c-uooi57l

PLAINTIFF TENNIFER

RESPONSES TO

ROYLES SECOND SUPPLEMENTAL ANSWERS AND WNST SPORTS MEDIA LLCS FIRST SET OF
INTERROGATORIES

INTERROGATORY NO.2
number
of each

State

the

identity

address

and

telephone

person

who you

believe

has knowledge

or information relating

to your

Complaint

together

with the substance of their testimony

knowledge

or information

ANSWER
interrogatories

NO

Plaintiff

objects

to this Interrogatory

as

it

contains

several

each involving

separate

and

distinct issues

under

the

guise

of

single

interrogatory in contravention

of the

limits

imposed by Rule

2-421

of the

Maryland

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 knowledge

that the

Defendants

Aparicio

Forrester

and Clark may have personal

of the

Plaintiff

also

presumes and

that

current

and former

colleagues

Defendants

the Plaintiff

other

members

of the local

media may have

personal

knowledge including

but not limited

to Jerry

Coleman
ongoing

Casey

Willett

Damon
the

Yaffe

John

Gallo

and Ray Buchman As discovery

is

Plaintiff

reserves

right to

supplement and/or amend her response

to this

Interrogatory

SUPPLEMENTAL ANSWER NO.2

Plaintiffs original objections to the extent the

Without

waiving

and

subject

to

the

information sought including

the

contact

information for each

person

is

in

the

Plaintiffs

immediate

custody and

possession

or

control

it

has

been

provided

see

Exhibit

Plaintiffs

Original

Supplemental

Responses

to

Request

for Production

of

Documents

See

also

persons

identified

in

Supplemental

Exhibit

Supplemental

Answers

to Interrogatories

Nos

34

and

INTERROGATORY NO.3
by any
of the

Identify

each and every

statement

of fact

made

Defendants

that

you

allege

is

false

as

alleged

in

Complaint fl19-25
each

including

all

subparts

and

fl27

37

48-50

quoting

verbatim

alleged

false

statement

of fact

the

date

and time

of such

statement

the

identity

of the

speaker

of the

statement

the

exact

medium

of

communication

upon

which

the

statement

was made

i.e in person radio Twitter

website

etc

and

if

the

statement

is

found on Your

website

or

blog

state

the

exact

web

address

containing

the

statement

answer

to

this

interrogatory

should

identify

all

statements

on

which

you

base

the

Complaint

including

but not limited

to

All statements that

that

you contend
or competent

state for

implicate or otherwise insinuate

position as journalist

you

are

not

qualified of

and

incapable

doing

job Complaint
you contend
state

20 21a 21b 21c

insinuate

21
that

24
All statements that

implicate or otherwise

you

are

involved

in personal athletes

sexual

and/or inappropriate
that

relationships sexual

with

multiple professional

and/or
with

you halve
athlete

personal

and/or inappropriate

relationship

professional

Complaint

20

21
that that

21

21

21
that

All statements

you lied on

you contend state implicate or otherwise insinuate resume and did not have the credentials or experience
have with regard
to profession as journalist

purport

to

Complaint

21c
21

All statements that

that

you contend
like

state

implicate

or otherwise insinuate

you were trashy

All statements

look

stripper

bitch

and/or an

idiot
you see work
e.g

Complaint

24c
that

Complaint

24d
that uncivilized that

you contend you contend

threatened

violence

against

All statements

your

professional

in

demeaning and

way

Complaint

24b
statements

All statements

you contend

are sexually inappropriate

about

you

Complaint

24e
objects to
this

ANSWER
interrogatories

NO

Plaintiff

Interrogatory

as

it

contains

several

each

involving

separate

and

distinct

issues under

the

guise

of

single

interrogatory

in contravention

of

the

limits

imposed by Rule

2-421

of the

Maryland

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

objections
Plaintiff

Plaintiff

incorporates

her

original

refers the

Defendants

to Supplemental

Exhibit

attached

hereto

Plaintiffs

Original

and

Supplemental

Responses

to

Requests

for

Production

of

Documents

as well as Supplemental

Answers

to Interrogatory

Nos

and

On
training

8/5/

2010 Casey

Willett

CBS employee
Defendant

informed

Ms

Royle during Ravens

camp

in

Westminster

MV that

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
Ms

On
Royle
that

9/7/2010

Damon
told

Yaffee

media member and CBS employee informed had lied on

Glenn Clark

him

that

Plaintiff

my resume
and

and do not have

the

credentials/

experience

that

appears

on

my

resume

do not deserve

to

be

covering

the

Ravens

Damon
listening

Yaffee

further

informed

Ms

Royle that

Defendant

Clark

had

said

it

was

brutal

to her

and inquired why CBS didnt have anyone

Clark have

better

to cover

the

Ravens

Damon

Yaffee

and Defendant

information regarding

the

statements

On
Plaintiff

9/12/2010

WNSTs

website

published

blog wherein

CJ Spiller stated

that

was

demoted
blog from

from her job

See

Supplemental

Exhibit

WNST

has

since

removed

the

its

website

or

else

it

is

not discoverable

through

general

search

patterns

Plaintiff

has

made
on
the

substantial

efforts

to produce

copy

of the

said

blog but

it

is

no longer

available

Defendants website

On
know
she

or

about

7/1/2010

Defendant

Forrester

told

Jerry

Coleman

Dude

you

is

hooking

up with Matusz
is

right
Plaintiffs

at

the

Mt

Washington Tavern
control

copy

of

the

oral

statement

not

in

the

possession

custody

or

Jerry

Coleman and Defendant

Forrester

have personal knowledge

Clark

of the

statement

On
even heard Gold

9/12/2010

Defendant

tweeted

And

to think

@JenRoyleMASN trashy
if

hasnt

me

say that what shes wearing

tonight

would be considered

at

the

Club and

Defendant

Forrester

followed

with the tweet

dont know

Glenn

is

D-Bag but
than

do know this.

those boots

@JenRoyleMASN day
Jen

is

wearing

are

worth more

Glenn Clarks

car

truth
series

Later

that

Royle

Drew

Forrester and

Glen

Clark were witnesses

to

of statements

made

in

conversation between

them
tweet

The statements

began when

Ms

Royle

approached

Mr

Clark

and

stated

that

made

earlier

that

day

by

Mr
with

Clark

was

crossing

the

line

and

extremely

unprofessional

Concurrently

these

statements

Mr
if

Forrester

walked by and

yelled

where

are your

boots Ms
This
is

Royle asked

Mr

Clark

he could

step

outside to talk

Mr

Clark said

no

not the right

place
and
let

Mr

Forrester

then said

go home

and put

your boots on

first

then come

inside

me buy you
on

drink
was

In

blog

that

is

no longer

available

WNSTs

website

that

originally

posted

on

or about

9/1/2010

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
identified

INTERROGATORY NO.4
Interrogatory

For each

statement

your answer

to

No

explain

the

reason

that

you claim

it

was

false

when made

identify

each

and every

fact

on which you base your contention

of

identify

all

persons

known

to

you

who

have

knowledge

such

facts

and

for

each

person

identified

state

the

substance of that persons

knowledge

ANSWER
interrogatories

NO

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under the

guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of

the

Maryland and

Rules

of

Civil

Procedure

The interrogatory

as

worded

is

overly

broad

vague

ambiguous
with

as well as

unduly burdensome

as

it

seeks

for Plaintiff

to identify

all

persons

personal knowledge

of the

facts relevant

to the

issues

in the

case

even

if

she has

no knowledge

of

their existence

Further

Plaintiff

objects

to

this

Interrogatory

to

the

extent

it

seeks

information protected

from discovery

by

the

attorney

work-product

doctrine

To answer

this

Interrogatory Plaintiffs counsel would

be required to provide

information regarding

counsels

litigation

strategy

in this

case

Without waiving
with

said

objections

and

subject

thereto

Plaintiff

has never been romantically involved

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
objections
Plaintiff

ANSWER NO.4
her Answer

Without

waiving

Plaintiffs

original

supplements

as

follows

The statements

made by
to

the

Defendants

place

Ms

Royle

in

false position

by

attributing

false conduct

Ms

Royle

namely

that

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
of

what

blitz

was She was

sports

reporter

who knew

the

definition

blitz

The statement

places

Ms

Royle

in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but

not

limited

to The

unprofessionalism

and incompetence

in regards

to

her occupation

parties

herein

have

knowledge

of

the

falsity

of

the

statement

see

also

Exhibit

False Statnient

9/7/2010

Glenn Clark

told

Damon

Yaiffe

that

Ms
the

Royle

lied

on her resume and did not have

the

experience

to

cover

Ravens

Ms

Royle has never lied on her resume and her employment

as

reported

covering

the

Ravens was based upon

other

years

of experience

gained

in

New

York and Boston

covering

professional

athletic

teams The

statements

place

Ms

Royle in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but not limited

to unprofessionalism The

and

incompetence

in regards

to her

occupation

parties

herein

and

Mr

Yaffe

have

knowledge

of these

statements

see

also Exhibit

False Statinent

9/21

2010

Drew
At

Forrester

tweeted

Jen doesnt know

was

where Hopkins

is.

LOL

10
Johns

the

time

this

statement

made
places

Jen

Royle

did

know

where

Hopkins

was

The statement

Ms

Royle

in

fale

position

by

attributing

to

Ms

Royle

false

characteristics

including

but

not

limited

to

unprofessionalism

and

incompetence

in

regards to

her

occupation

The

parties

herein

have

knowledge

of

the

falsity

of the

statement

see

also Exhibit

False

Statment

11/26/2010

Drew

Forrester

blogged

that

he had sent

Ms
man

Royle

questionnaire asking

her If you could

ever have

handsome

take

you out on

date

and

try to earn

your

affection

what would

you want him been

sucker

to

wear He
man
in

blogged

that

She

wrote what Id

Well Ive always him

to look

for

uniform

so

heres

like

like The

link

is

to

picture

of Nick

Swisher

in

uniform

Ms

Royle never

sent

such

response

or

link

to

Mr

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
about

here

earlier

in the

year and immediately

started

talking

how much
position

the

place

sucks

The statement

places

Ms

Royle

in

false

by

attributing

to

Ms

Royle

false

characteristics

including

but not limited

to The

unprofessionalism

and

incompetence

in regards

to

her occupation

parties

herein

have

knowledge

of

the

falsity

of

the

statement

see

also

Exhibit

False

Statment

12/29/2010

Drew

Forrester

responded

to

comment

on

blog

stating

that

Royle has

specifically

dogged

Baltimore to

anyone

and everyone

Ms

Royle

did

not specifically

dog Ms

the

city

of

Baltimore

to

anyone

and everyone The statement

places

Royle

in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but not limited

to unprofessionalism

and incompetence
of

in regards to her

profession

The

parties

herein

have

knowledge

the

falsity

of

the

statement

see

also Exhibit

False Statment

Drew

Porrester

tweeted

@WNST

@JenlRoyleMASN
tourist

Drew And
professional

think the

fact

that

youre

stuck-up

snobby

on

brief

vacation

here

is

COMICAL too Ms
in

Royle was employed

at

the

time

of

the

comment

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

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but not limited

to unprofessionalism
herein have

and incompetence

in regards to her

occupation

The

parties

knowledge

of

the

falsity

of

the

statement

False

Statment

1/2011

Nestor

Aparicio

tweeted

@VJNST
Renegade

Nestor

But

Drew

has

been

KIND

to

Miss

Yes

Jen

Mr

..

real

disgrace

is

in corporate bosses

who though Yeah

position
at

theyre

qualified was

Ms
The

Royle

was

qualified

for

her

the

time

she

hired

statement

places

Ms

Royle in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

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

1/11/2011

Drew

Forrester

tweeted

@WNST

Drew

LOL

that

Jen Royle

thinks

Im obsessed
ai-t

with

her

Thats her

OPINION
Royle

Heres

my FACT

Jen

is

out-of-towner

tourist

Jen

was

employed

in Baltimore

at the

time of the

statement

The statement

places

Ms

Royle

in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but

not

limited

to

unprofessionalism

and

incompetence

in

regards

to

her

occupation

The

parties

herein

have

knowledge

of the

falsity

of the

statement

see

also Exhibit

False

Statment 10

1/11/2011

Drew

Forrester

blogged

Quick Love
false

Jen who

said

that

No

it

wasnt

Brian Matusz

think he said

those

jeans.. The

statements

in

the

blog

place

Ms

Royle

in

position

by

attributing

false

conduct

to

Ms

Royle

namely

that

she has

some

sort

of

personal/inappropriate/sexual

relationship

with

Brian

Matusz

Further

the

statements

place

Ms

Royle

in

false

position

by

10

attributing

to

Ms

Royle

false

characteristics

including

but not limited

to

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

incompetence

in

regards

to

her

occupation

The

parties

herein

have

knowledge

of the

falsity

of the statement

see

also Exhibit

False Statment

12

1/11/2011

Drew

Forrester

claimed

on

blog

that

Ms

Royle was

here on

scholarship

The statement

places

Ms

Royle

in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but

not

limited

to

unprofessionalism

and

incompetence

in

regards to

her

occupation

The

parties

herein

have

knowledge

of

the

falsity

of the statement

See also Exhibit

False Statinent

13

1/28/2011

Drew

Forrester

claimed

that

when
didnt

Jen Royle

showed

up

to

Baltimore

Magazine photo

shoot

she

want

to

wear

the

clothes

given

to

her and

instead

brought

her

own Nick

Swisher

jersey

that

she wanted

to

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

in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but

not

limited

to unprofessionalism The

and

incompetence

in

regards to

her

occupation

parties

herein

and

Nick

Swisher

have

knowledge

of the

falsity

of the

statements

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
it

Royle

did not claim

that

Baltimore

was beneath

her or brag

that

had nothing

for

her The

statement

places

Ms

Royle

in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but not limited

to unprofessionalism The
herein

and

incompetence

in

regards

to

her

occupation

parties

have

knowledge

of the

falsity

of the

statement

see

also Exhibit

False Statment

15

2/22/2011

Nestor

Aparicio

said

that

the

only

reason

Ms

Royle

was

hired was

her

because

of

her

breasts

and

her

attractive

face

and

that

she

was not

qualified

to

report

on any

sports

team At

the

time of Defendant

Aparicios

statements

Ms

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
Deb

Royle

did not have

trouble

finding

Towson

University on 6/3/2011

Poquette

can

confirm

Ms

Royles

arrival

before

practice

began

her

contact

information is email

deb@campinslffestyle.com

telephone-410-

340-3569

The statement

places

Ms

Royle

in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but

not

limited

to

unprofessionalism

and

incompetence

in regards

to

her occupation

The

parties

herein as well as

Ms

Poquette

have

knowledge

of the

falsity

of the

statement

False

Statinent

17

6/10/2011

Drew

Forrester

blogged

that

Ms

Royles employer was

hiring

sports

reporter

and

when

the

station

interviewed

girl

who

performed

unintelligently

in

beauty

pageant she

passed

the

interview

with
by

flying

colors The statement

places

Ms

Royle

in

false

position

attributing

to

Ms

Royle

false

characteristics

including

but

not

limited

to unprofessionalism The
herein

and

incompetence

in

regards

to

her

occupation

parties

have

knowledge

of

the

falsity

of this

statement

See also Exhibit

13

False Statinent

18

Drew

Forrester

told

Jerry

Coleman

that

Ms
did

Royle

was engaged

in sexual

activity

with

Brian Matusz

Ms

Royle

not engage

in sexual activity

with Brian Matusz

The statement

places

Ms

Royle

in

false

position

by

attributing

to

Ms

Royle

false

characteristics

including

but

not

limited

to unprofessionalism
statement

and

incompetence

in

regards to

her profession

Further

the

places

Ms

Royle

in

false

position

by

attributing

false

conduct

to

Ms

Royle namely

that

she

has

some

sort of

personal/inappropriate/sexual

relationship

with

Brian

Matusz

The

parties

herein

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
Responses

and

Supplemental

Exhibit

and

Plaintiffs

Original

and

Supplemental

to Request

for Production

of

Documents

Further

the

persons

identified

herein have

knowledge

of the

false

statements

INTERROGATORY NO.5
any
other

Identify

all

communications

between

you and

persons
identified

including

but

not

limited

to

the

Defendants

relating

to

the

statements

in

your answer

to Interrogatory

No

For each

identify

the

date

of

the

communication

by

whom

the

communication

was authored

or

made

to

whom

the

communication was addressed communication was made

all

those

who

received

the

communication

whether

the

orally or in writing the

substance

of the

communication

and any response

to the

communication

14

ANSWER
interrogatories

NO

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each

involving

separate

and

distinct

issues under the

guise

of

single

interrogatory in contravention

of

the

limits

imposed by Rule

2-421

of the

Maryland and

Rules

of

Civil

Procedure

The interrogatory

as

worded

is

overly

broad

vague

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 and

Plaintiff

exchanged

emails with

colleagues

and management

at

MASN
13

CBS

as well

as telephone

conversations beginning

on approximately January

2011 regarding the

Defendants

conduct

As discovery

is

ongoing

Plaintiff

reserves

the right to supplement

and/or amend her response

to this

Interrogatory

SUPPLEMENTAL
original objections to

ANSWER
extent

NO

Without

waiving

and

subject

to Plaintiffs

the

the

correspondence

is

in

the

immediate

custody
000070-

possession

or

control

of

the

Plaintiff

copies

have

been

provided Raven

See

PRDR

000071 000076-000078

The

recipients

of the

letter

to the

Public

Relations/Media

staff

included

to

Chad

Steele Patrick

Gleason

and

Kevin Byrne 13

Plaintiff

exchanged

emails with

Jim Cuddihy

of

MASN

on

or

about

January

2011

regarding

the

Defendants

conduct

Plaintiff

emailed

Greg

Bader

of

the

Baltimore

Orioles

Organization

on

or

about 6/11/2011

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
your answer
that the to Interrogatory

With

respect

to

each

statement

identified

in

No

if

you contend

that

any

of the

Defendants

knew

statement

was

false

subjectively

entertained

doubts

as

to

the

truth

of

falsity

of the

statement

or published

the

statement

with

high degree

of awareness

as

to its probable

falsity for each

Defendant

state

the specific

facts

on which you base your

of such

contention

and

all

persons

known

to

you who have

knowledge

facts

and

for

each person

identified

state the

substance of tht persons

knowledge

ANSWER
interrogatories

NO

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each

involving

separate

and

distinct

issues under the

guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of the

Maryland and

Rules

of

Civil

Procedure

The Interrogatory

as

worded

is

overly

broad

vague

ambiguous
with

as well as

unduly burdensome

as

it

seeks

for Plaintiff

to identify

all

persons

personal knowledge

of the

facts

relevant

to the

issues

in the

case

even

if

she has

no knowledge

of

their existence

Further

Plaintiff

objects

to

this

Interrogatory

to

the

extent

it

seeks

information protected

from discovery by

the

attorney

work-product

doctrine

To answer

this

Interrogatory Plaintiffs counsel

would

be required to provide

information regarding

counsels

litigation

strategy

in this

case

Without waiving
her

said

objections

and

subject

thereto

Plaintiff

directs

Defendant

to

Answer

to

Interrogatory

No
this

and

incorporates

her

Answer

thereto

Plaintiff

anticipates

that

discovery in

case

will provide

further

information in regards to

this

Interrogatory

16

and

as

such

reserves

the

right

to

supplement

and/or

amend

her

Answer

to

this

Interrogatory

SUPPLEMENTAL
objections

ANSWER
Plaintiff

NO
directs

Without

waiving

Plaintiffs

original

and

subject

thereto

Defendants

to her Supplemental

Answer

to

Interrogatory

No
Exhibit

and

and

incorporates

her

Answers thereto

as

well

as

Supplemental

and

Exhibit

Plaintiff

anticipates

that

discovery in

this

case

will

provide

further

information

concerning

the

information

sought

by

this

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

himself Based

sports

reporter

through

his

employment

in as

sports

reporter

upon

this

knowledge

but

not

limited

thereto

Defendant

Clark

knew

that

Ms
and

Royle

had

sufficient

expertise

in

sports

to

cover

professional

sports

teams

that

she

was

qualified

for

position

in

reporting

Defendant

Clark had no basis to claim

Ms

Royle lied on her resume

and

in publishing

the

statements

without

verifying

the

accuracy

thereof

Mr

Clark recklesly

made

the

false

statements

or

knew

that

the

statements

were

false

and purposefully

made them
by

nonetheless

The

Defendants

statements

place

Ms

Royle

in

false

position

attributing

to

Ms

Royle

false

characteristics

including

but

not

limited

to

unprofessionaiism

and incompetence

regarding her occupation

Drew

Forrester

knew
other

of

Ms

Royles employment

in

Baltimore

and

previous

employment covering
this

athletic

teams

as he

is

competitor in the same field Based

upon

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
Further

Johns Hopkins

was and
had no

he recklessly

made

false

statement

to that

effect

Defendant

Forrester

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
Royle
in

with

Mr

Swisher

and/or

Mr

Matusz

The Defendants

statements

place

Ms
that

false

position

by

attributing

false

conduct

to

Ms

Royle

namely
with

she

has

some

sort

of

personal/inapprOpriate/sexual

relationship

Nick

Swisher

and

Brian

Matusz

Further

the

statements

place

Ms

Royle

in

false

position

by

attributing

to

Ms

Royle

false characteristics

including

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
or

statements

that

Plaintiff

was unqualified were

either subjectively

false

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
acted

If

you

contend

that

any

of

the

Defendants

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

person identified

state the

substance of that persons

knowledge
several

ANSWER
interrogatories

NO
each

Plaintiff

objects

to

this

Interrogatory

as

it

contains

involving

separate

and

distinct

issues under the

guise

of

single

interrogatory

in contravention

of

the

limits

imposed by Rule

2-421

of the

Maryland and

Rules

of

Civil

Procedure

The Interrogatory

as

worded

is

overly

broad

vague

ambiguous

as well as

unduly burdensome

as

it

seeks

for Plaintiff

to identify

all

persons

with

personal knowledge

of the

facts

relevant

to the

issues

in the

case

even

if

she has

no knowledge

of

their existence

Further

Plaintiff

objects

to

this

Interrogatory

to the

extent

it

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

and

subject

to said objection

Plaintiff

directs

Defendant

to her

Answer

to Interrogatory

No

SUPPLEMENTAL
objection
Plaintiff

ANSWER
her

NO
Answer

Without

waiving

and

subject

to

said

supplements

as

follows

Plaintiff

anticipates

that

discovery

in

this

case

will

provide

further

information

concerning

the

information

sought

by

this

Interrogatory

and

as such

reserves

the

right to continue

to supplement

and/or amend her Answer The Defendants

to this Interrogatory

statements

were made

intentionally

and

recklessly

without

verification

of the

accuracy

of such

statements

and without

regard of the

falsity

thereof

The statements

place

Royle

in

false

position

by

attributing

false

conduct

to

Ms

19

Royle
with

namely

that

she

has

some

sort

of personal/inappropriate/sexual

relationship

Nick

Swisher

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
contend
to

NO
to

11

Describe

in

detail

any

other

damages

you

have

suffered

your

feelings

including

but

not

limited

to

distress

anguish and humiliation

as

result

of

the

statements

identified

in

your answer

to

Interrogatory

No
special

state

the

nature

extent

and

duration

of

the

alleged

injury

or

damage
financial

any

damages you

allege

are

due

to such

injury or

damage

any and

all

losses

related

thereto

the

reasons you contend

that

such

statements

were

the

proximate

cause

of

such

injury

or

damage
you

the

names and business and

addresses

of

all

health

care

providers

who

treated

for such

alleged

injuries

the

dates

of such

treatment

ANSWER
interrogatories

NO 11

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under the

guise

of

single

interrogatory

in contravention

of

the

limits

imposed by Rule

2-421

of

the

Maryland and

Rules

of

Civil

Procedure

The Interrogatory

as

worded

is

overly

broad

vague

ambiguous

as

it

does

not

define

the

phrase

damages
Plaintiff

.suffered

to

your

feelings

Without waiving

and

subject

to said

objections

refers to

Dr

Goldiners

letter

produced

in response

to the

Defendants

Request

for Production

of

Documents

Plaintiff

20

has suffered

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
medication

Maryland and

21204

Plaintiffs

damages Liebman

are

ongoing

as she

continues

to take

is

under

the

care

of

Dr

SUPPLEMENTAL
objections to the extent

ANSWER

NO

11 Without

waiving

and

subject

to

said

any responsive

information/documents

are

in the

immediate

custody possession

or

control

of the

Plaintiff

they have

been

produced

Plaintiff

will

supplement

this

Answer

with

any

further

information as soon

as

it

comes

into

her

custody

possession

or

control

Plaintiff

has

provided

all

of

Dr

Liebmans

contact

information

and

notes

that

the

Defendant

does

have

the

authority

to

subpoena

the

records

INTERROGATORY
those identified

NO 12
to the

Describe

in

detail

any

damages

other

than

in response

preceding

interrogatories

suffered

by you

as

proximate

result

of the

statements

identified

in your

answer

to Interrogatory

No
of

the

reasons

for

your
all

belief that

the

such

statements

were

the

proximate cause

any such

loss identify

persons

who you

contend

have knowledge

of such

loss and for each

person identified

state

the

substance

of that

persons

knowledge

21

ANSWER
Interrogatories

NO 12

Plaintiff

refers

to

and

incorporates

her

Answers

to

Nos

10 and 11

SUPPLEMENTAL ANSWER
damages
as supported

NO 12

Plaintiff

has

suffered

reputational

by

the

negative

comments
the

tweets

and

general

opinions held by

fans

who

have

heard

and

believe

statements

identified

herein

Additionally

Plaintiff

has been called

slut bitch
statements

and

other

insulting

names by

fans

who

have

heard

or read

the

Defendants

See Responses

to Requests

for Production

of

Documents

and Supplemental

Exhibit

INTERROGATORY
practitioner

NO 15
psychiatrist

Identify

any
health

doctor

physician

medical

psychologist

mental

counselor

or

mental

health

practitioner

that

you have ever and

for each

visited concerning

your mental

and/or emotional

health

in your

lifetime

person

identified

state

their full

name

address

phone

number

and

the

date and purpose

of any

such visit

ANSWER NO
seeks information that

15

Plaintiff

objects

to this

Interrogatory

as

it

is

overly

broad

and

is

not material

to the

instant

litigation

The

Interrogatory

is

not

reasonably

calculated

to lead

to the

discovery of admissible evidence

Without waiving and Liebman

See

and

subject

to

said

objection

Plaintiff

has

visited

Drs

Goldiner

Answer

to Interrogatory

No

11

SUPPLEMENTAL
and Liebman
in regard to

ANSWER
her
mental

NO

15

Plaintiff

has

visited

only

Drs Goldiner

and/emotional

health

22

INTERROGATORY
including but not limited

NO 16
letters

Identify

and

describe

all

communications

to

and correspondence

from members

of the

public

sent to

you

that

relate to

your work
Plaintiff

in Baltimore

Maryland broad

ANSWER

NO 16

objects

to

this

Interrogatory

as

it

is

overly

vague and ambiguous

as well as

unduly burdensome
term

as

it

seeks

for Plaintiff

to provide

all

communications
her

which

is

left

undefined

Plaintiff

has

ever

received

regarding

work

in

Baltimore

Maryland

Moreover

the

Interrogatory

seeks

information immaterial to the

instant

litigation

and

is

not reasonably

calculated

to lead

to the

discovery of admissible evidence

SUPPLEMENTAL
information
exists

ANSWER
is

NO

16 To

extent

responsive

documents and/or

and

in

the

immediate

custody

possession

or

control

of

the

Plaintiff

it

has

been produced

To

extent

information responsive

to this

Interrogatory

comes

into the

Plaintiffs

possession

it

will be

produced

to the

Defendants

Plaintiff

has

complied

with

the

Facebook

and

Twitter

Requests

of

the

Defendants

which

are

responsive

to this

Interrogatory See

Plaintiffs

Supplemental

Responses

to Production

of

Documents

INTERROGATORY
history With respect

NO 19
answer

Describe

in

detail

your

entire

employment
information

to your

to this

interrogatory provide

contact

for

the

individual

who

can

verify

your

employment
each

describe

your

work

responsibilities

identify

your

direct

supervisors

at

place

of

employment

the

dates

of each

employment

your job

title

including

any changes

during

employment

and

the reason

for your leaving

each place

of

eniployment

23

ANSWER
interrogatories

NO 19

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under the

guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of

the

Maryland

Rules of Civil Procedure

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

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
supplemental information

NO 19
was

Plaintiff

provides

the

following

Ms

Royle

transferred

from YES Network

to

MLB

Advanced

Media when

MLB

Advanced

Media purchased
eliminated

the

YES Network
Advanced

website

her

previous

employer Her

position

was

at

MLB

Media
the

She

received

job offer at

Sirius/XM Radio

to

continue

covering

the Yankees

and

Mets

Ms

Royle

worked

for Sirius/XM

Radio

after

YES/MLB

Advanced

Media

Ms

Royle received

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
for

CBS

lost

their flagship

rights

to the

Orioles

Ms

Royle was no longer able

to

work

MASN Ms

because

her position

there

was eliminated

Ms

Royle did not want to leave

CBS

Royle received

an

offer for

and accepted

the

co-hosting

job

on Baltimore

Baseball

Tonight

Orioles unofficial

pregame

show

24

INTERROGATORY 21
with

Identify

all

former

or

current

professional

athletes

whom

you

have

ever

been

inclined

in

personal

relationship

sexual

relationship

and/or

inappropriate

relationship

including

but

not limited

to

any

current

or

former

player

or

member
Football

of the

coaching

staff

or

management

in Major

League Baseball
National

the

National

League

the

National Basketball

Association

the

Hockey

League

Major

League Soccer

the

Arena

Football

League

the

PGA
or

Tour

the

AW World

Tour

NASCAR
i.e

any minor league

affiliate

of such

leagues

any

other minor professional

league

AAA

baseball

and

the

American Hockey number and

League
the dates

For each

person

identified

state theft full

name

address

phone

and nature

of

any such

relationship

ANSWER TO INTERROGATORY
Interrogatory as
it

NO 21

Plaintiff

objects

to

this

contains

several

interrogatories

each involving

separate

and

distinct

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 ANSWER
about relationships with

NO 21

Defendants

have made

false

statements

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
has not had

Without waiving

these

objections

and

subject

thereto

the

Plaintiff

any inappropriate
as those

and/or

sexual

relationships

with

either

Nick

Swisher

or Brian

Matusz

words

are defined in Plaintiffs Supplemental

Answer

to Interrogatory

No

20

INTERROGATORY whom you

have

NO 22

Identify

all

former or professional

athletes with

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
Basketball

in Major

League
the

Baseball the

National

Football

League

the

National

Association

National

Hockey

League

Major

League

Soccer

the

Arena

Football

League
of such

the

PGA Tour
or

the

ATP World
minor

Tour

NASCAR
league i.e

any minor league

affiliate

leagues

any

other

professional

AAA

baseball

and

the

Ameridan

Hockey

League
and
the

For

each

person

identified

state

their

full

name

address

phone number

dates

and nature

of

any such

relationship

ANSWER
interrogatories

NO 22

Plaintiff

objects

to

this

Interrogatory

as

it

contains

several

each involving

separate

and

distinct

issues under the

guise

of

single

interrogatory

in contravention

of the

limits

imposed by Rule

2-421

of

the

Maryland
instant

Rules of Civil Procedure

The

interrogatory

seeks

information immaterial to the

litigation

and

is

not

reasonably

calculated

to

lead

to

the

discovery

of

admissible

evidence

Further

the

Interrogatory

is

overly broad

vague

arid

ambiguous Answer

SUPPLEMENTAL ANSWER
Interrogatory

NO 22

See

Plaintiffs

Supplemental

to

No

21

26

SOLEMNLY AFFIRM
the

under

the penalties

of perjury

that

the factual

matters

stated

Ia

Answers

to Interrogatories

are true to the best of

my

information and belief

Brian

Goodman
Moylan PESSIN KATZ P.A

Alexandra

HODES

901 Dulaney Valley

Road

Suite 400

Towson Maryland

21 204-2600

410 410

938-8800 825-2493

Fax

Attorneys for Plaintiff

28
234620-1

Plaintiffs Supplemental Exhibit

2/24/20
his

10

On

Glenn Clarks blog Dte vFrrst4r

lists

Jen Royle as number

in

Top Sports Media Members We Wouldnt Mind Seeing Few Weeks In honor of Tons Kornheisers suspension from ESPN
have compiled
for
lists

Suspended For Glenn and Drew

of the

top

sports

media members

they want to see

suspended

few weeks

Drews

List

Jen Royle Glenn Clark Glenn Clarks Blog Comcast Morning Media Members
available
at

We Wouldnt Mind

Seeing

Show Tuesday Top 7-Sports Few Weeks Suspended For

0/02/24/comcast-morning-

http//wnst.net/wordpress/glennclark/20

show-top-7-sport-media-mernbers-we-want-to-see-suspended/
Original

See

Plaintiffs

and Supplemental

Responses

to Request

for Production

of Documents

4/26/2010
stereotypical qualified

On

his

blog
she
is

v5ite
Swisher

states that

Ms

Royles
states

hiring

was
is

because

an out-of-towner

He
that

later

that

she

not of

to ask any questions and insinuates outfielder

she frequents hang outs

Yankees

Nick
is

Jen Royle
105.7
duties

the

new

In typical of covering

0s beat reporter for Fan Fashion they hired

the

the

teams

flagship

radio

station the

an out-of-towner
if

to handle to hire

team In

all

fairness
.no

youre going

beat

reporter she might as well be pretty

offense

What
been
of

will Jen

Royle ask shes

MacPhail Answer
fan

Casey Shes not equipped

think

to even
if

ask anything
to the

Yankees

Maybe

she can ask MacPhail

hes

ever

Cobb Chop House in Manhattan Swishs favorite hang outs Drew

Forresters available

heard her say its one

Drew
from

Forrester
the

Blog
at

It

takes

20 minutes

Orioles

shouldnt run

challenge

flag

http//wnst.netlwordpress/drewforrester/20 shouldnt-run-from-the-challenge-flag/ Responses

to Request for Production

0/04/26/ittakesL20minutesorioles

See
of

Plaintiffs

Original

and

Supplemental

Documents
of an Orioles

5/19/2010

blogs that

Ms

Royles

description

game
she

character was wrong He later analogizes her to on the Jersey Shore because is disaster He states that he doesnt want her to do her job better

The
after

Ginsburg says Orioles touched up Royals bullpen Greinke departed for 10 inning win

APs

David

Supp Exhibit

000001

Supplemental Page

Exhibit

No

the

Orioles

did not

beat
cough
is

Zack Greinke
said

despite

what someone over win

at

105.7

cough

Jen Royle

They

did

however

game

started

by Zack

Greinke which

ALMOST

just as

good
with her

Edit from
similar to

GMC Some
disaster as

might say

Im obsessed
with

Theyre
The

right

Its

how many

of us are obsessed
that

Snooki

from Jersey Shore

Its just such

that as

how

can you possibly turn

to do her job

away

reality

is

much

say

want Jen Royle

better

probably

REALLY

dont want her

to
Mornings
Crabs and Beer available
at

Glenn Clarks Blog Wednesday

http //wnst.net/wordpress/glennclark/20

10/05/19/wednesday-mornings-crabs-and-

beer-102/ See
Production

Plaintiffs

Original

and Supplemental

Responses

to Request

for

of Documents.

6/5/2010

Glenn Clark tweets

local

GMC
Softball

journalist

in

town

is

apparently playing

in

Celebrity

Game
by

With aRavensplayer whose name they cant spell Royle from Twitter.com

Tweet

copied

Ms

8/5/2010

Casey Willett
training that

co-worker
in

and

CBS

employee
that

notifies

Ms
just

Royle

during Ravens her on the

air

camp

Westminster

MD
Ms PR

ripped
was

morning and are

field

now

calling

Royle

Jen Midol
called

crying on the Ravens

the

when
and

heard they had

segment Chad

Jen Midol on

morning

show Drew
incident

Glenn
the

Ravens

Steele

and Patrick

Gleason
following

and Mike Preston

the

from

Baltimore

Sun spoke

with

Ms

Royle

Comments
what
the

included that she

knew

nothing about the Ravens

and did not

know
Yankees

term blitz

meant

but that she

knew who

the

right fielder of the

was Nick Swisher See

Interrogatory

Plaintiffs

Second

Supplemental

Answer

to

No
later

Some time
shake

Nestor

came up

to

me
his

and introduced himself and reached out to

my hand
your
radio

declined to shake

hand

said because

station

has nothing good to say about

me

and

dont

appreciate

it

you dont even know

me

He

said

have

never said

word about you

cant

control

what

other

people

say

supp Exhibit

000002

Supplemental

Exhibit

Page

Isaid well

Im telling
away

you

now

and youre

the

owner

so

youre responsible

And
That ever

he walked

afternoon he went on the

air

and

told everyone

was

the

biggest bitch

he has

met Ms
Royle

Emailfrom

9/7/20

10

During

Ravens practice

Ms

Royle claims
that

that

told

media member/CBS co-worker

lied

Damon

Yaffe

on

my resume anddo
it is

not have

the

credentials/

experience

saw

have
stated

and do not deserve

that

to be covering

the

Ravens

Clark also allegedly didnt have

brutal listening to cover the

to her and inquired

why CBS

anyone
Letter to

better

Ravens
Gleason and Kevin

Ravens

sent

by Jen Royle to Chad Steele Patrick Ravens

Organization

Bryne employees
Response

of the Baltimore of

in late

2010 See

to Production

Documents

PRDR

000076-000078

9/12/2010

Drw

ao

and _____ tweet about her

believe

Glenn Clark Cant

front of everyone

JenRoyleMASNcalled me
thought

douchebag
meant

in

here tonight

working was not

for the

Yankees

class

Ms Royle

alleges her comment

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
truth
Tweets
cut

are worth

more than Glenn Clarks car

and copied

from Twitter

into letter

to

Ravens

Ms

Royle

asks

them

to

Ms Royle
confronting

stop

later

in the

day
was Crossing
the

confronted

Mr Mr

Clark and told him his tweet

line and was Extremely

unprofessional While
Forrester

Ms

Royle was
and yelled

Mr

Clark

walked by

the

altercation

Where

are your

boots

Ms
said

Royle Asked

Mr

No This

Clark to step outside

with

Drew

to talk

and Clark
and put

is

not the right then

place
inside

Drew
let

then said

Go

home

your boots on

first

come

and

me

buy you

drink

Supp

Exhibit

000003

Supplemental Page

Exhibit

After that another

media member_Jon
and

Gallo of

CBS

Sportsline informed including

Ms

Royle

Drew Fuck that bitch She

that

made comments
looks like
the

stripper

Shes

complete

idiot

And Drew
Letter to

Forrester

made

comment

Id

like to smell her

boots

Ravens

Jon

Gallo also confronted

the

Ravens

PR

staff Patrick talking

Gleason

and Chad Steele

and said would

If you

dont

tell

WNST

to stop

negatively

about Jen Royle

like to have

my seat changed

9/20/20

10

CJ

Spiller blogs on

WNST
First of all roles

Good

freakin

lord Shaddup Jen Roylel from

Jen we understand
spot here
in

you were demoted Podunkamore Shore not CojAed from

ports

New

York media

to your current
girl

You

talk like

high school

trying

out for the

Jersey

reporter

blog on

WNST.1 Drew
Ravens

9/21/20

10

After

brief encounter

with

Forrester

at

the

facility

where

Ms

Royles

at the water Royle was approached space and asked her how she was

cooler

Drew

Forrester

invaded

Ms

Ms

Royle did not respond Instead she

walked away Drew

Forrester

then yelled

to

Ms

Dont
Drew

you want

to

know how
tweets

am Ms

Royle

Wait where you going responded Not really

Royle

Forrester

later

girl

is

lucky

my

roid rage hasnt kicked

yet or

would have

snapped

her head

off
real

He

then tweets

It was

definitely to

water-cooler

moment

was shocked

at

the

way

she spoke

me

But

dig the

hell out of her

boots

Next

he tweets

Miss He He

America has
that
favorite

left

the

building without

apologizing

to

me.

.1

also tweeted

her
further

two

teams

the

Yankees

and

Rays
ago Rumor
is

tweets
lost

power

at

WNST

about 40 minutes
the

someone saw

Jen Royle running

away from

building

hee

hee

Blog

no

longer

available

on website

Supp

Exhibit

000004

Supplemental Page

Exhibit

Finally he tweets

len doesnt know where Hopkins

Copied by len Royle from
Twitter.2

is.

.LOL

10

On

or about
in

10/1/2010

Drew

Forrester

leaned far back

in

his chair
at

at

the

Ravens

facility

Owings

Mills and eyed

that

Ms

Royle up and down

this

staring

her legs

Mr

Forrester

was well aware

Ms

Royle witnessed
past

Later in the press

Forrester yelled to

conference

room when

Ms

Royle walked Glenn

Mr

Clark

Clark

Dont

say anything of the press

past

We

dont want

to get

in trouble stared

again Upon
at

commencement
legs as she

conference

Clark and Forrester

Ms

Royles

walked

and laughed

Ms

Royle and

the

Defendants

have

personal knowledge

of

this

occurrence

10/8/2010
herself

Drew
tweet

1orjester

condemns Ravens

fan

jokingly encouraging

len to

kill

via

during the

Steelers the that

game
game
at

The fans tweet

appeared

to follow

Drews

jab that len was watching

critics

home
len to
kill

of her

authored

tweet

encouraged

herself

It

wasnt

joke It came across as very serious and len took it that way cant stress how wrong it is for anyone to EVER encourage response implore someone to end their life

in her or

Drew

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-withand Supplemental Responses

to

some-friday-mud/
Request

See

Plaintiffs

Original

for Production

of

Documents comment on

11/10/2010

bMw

st
Says
all

responds

to

his

blog

Anonymous
November

10th 2010

at

849

pm
the
silly

How

long will you

continue

cold war with

Jen Royle from The

Fan 105.7

DF Hey
that

len thanks
really

for stopping

by

Nice boots.. You should

know

kiddo

there

ISNT

cold war with

you in seven weeks. .ever since that day at the and asked how YOU were doing and you didnt respond and bad poison
spoke
to

havent talked to you when facility greeted YOU

told the

you
last

had
time

ivy and you said quote Sine

in

DONT CARE

Thats

you

media people

then youve carried on like town and nationally telling them how much

6-year old with

bunch of

weve

All

tweets

referenced

herein

are

no

longer

on

twitter

5upp

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Supplemental Exhibit Page

mistreated

you

.when you

in fact

havent blog

bothered

in about

and the truth is we you know the truth months Thanks for checking out my
picture

.next

week

Ill include

of Nick

Swisher

or Brian

Matusz

for

you
Drew
Forrester

Drew

Forresters
at

Blog Wednesday
11/01/1 Original

QA

In honor

of Brooks

Ill

take 21 questions

available

hlp//wnst.net/wordpress/drewforrester/20 rush-through-friday-mud/
to Request for Production

4/take-your-timeno-need-toand Supplemental Responses

See
of

Plaintiffs

Documents

11/18/2010

Didw

Irrester blogs that fans of herself

Fullerton

wont
as

get to star

meet Jen Royle

This

appears to be ajoke that she thinks

Come one come

Morning
Reaction

all to the hosts

Pub

tonight the

at

7pm when The

Rub

Elbows with

Stars

And no
It

that

doesnt mean youre going

to

meet Jen Royle

means were going

of

to

meet

YOU

and rub elbows

with

YOU

the

real

stars

WNST
Drew
Fullerton

radio and

WNST.net
Blog Tonights
at

Drew
begins

Forrester
at

Forresters

the

night

Our canned

food

drive

The

Pub available

http //wnst.net/wordpress/drewforrester/20

10/11

8/tonights-the-night-our-cannedOriginal

food-drive-begins-at-the-fullerton-pub/ Responses
to Request for Production

of

See Plaintiffs Documents

and Supplemental

11/26/2010

b.eW

Fonester

blogs that
that

Ms
is

Royle

is

not afan of Baltimore

in

sports

teams and he further

insinuates

she

interested

Yankees

outfielder

Nick

Swisher

Its no

secret

that

one of our local

radio

reporters

in

town isnt

fan of passed

Baltimore along
questions date

sports

teams

And

because

she isnt well

fairly

known here man

questionaire

to her with If

some

personal questions

One

of the

was this

you could been

ever have

handsome

take you out on

and

try to earn your

affection what would you want him to sucker for

wear

She

wrote

Well Ive
him

always

man

in

uniform so heres what

Id Drew

like

to look

like

Forresters Blog Stuff yourself with Friday

Mud

available

at

hap //wnst.net/wordpress/drewforrester/20

10/11 /26/stuff-yourself-with-fridayat

mud/

link goes

to

picture

of Nick

Swisher

http//www.zimbio .compictures/d3hjwdZlpYeLBostonRedSoxvNewYork

Supp

Exhibit

000006

Supplemental Page

Exhibit

Yankees/yXBAZYPbiOY/NickSwisher
Supplemental Responses
to Request

See

Plaintiffs

Original

and

for Production

of

Documents

12/29/2010 and says

Drew

Forrester

blogs about his best

of the best of Baltimore

for

2010

Best example of someone coming

alienating

to

town

like

bull in

china

shop

and
she got

he rself by pissing on

all

things

Baltimore

from the minute

Jen Royle

And

the vote

wasnt

close

Next topic
in

Drew

Forrester

Drew
at

Forresters

Blog

My

Best of the Best

2010 Dec 29
2/29/my-best-ofto

2010 available
the-best-in-2010/ Request

hup //wnst.networdpress/drewforrester/20

10/1

See

Plaintiffs

Original

and Supplemental

Responses

for Production

of

Documents how Drew

Forresters comments

Several

comments

on

the

blog show

affected

people

Steve Says
December 29th 2010
have
to
at

413

pm
us on Jen Royle
really

Oh

and while

you

.enlighten
all

Whats

her deal

and

what did she do

gamer

the

hate Dont

know much

about her..

DF Hatebad
Shes
immediately

word No

one

HATES

Jen Royle

dont know her deal

year and
II..

an out of towner
started

who showed up about how much talking

here earlier in the

the place

sucks

bhop Says December 29th 2010

at

102

pm

Supp

Exhibit

000007

Supplemental Page

Exhibit

Man

she specifically

dogged Baltimore
it

to

you What
up on
it

did she actually

say
to

DF

Brian err

or

is

Tom.
If

.She has specifically picked

dogged

Baltimore

anyone and everyone

attention

you havent

youre not paying

Stanton

Salter

Says
at

December

30th 2010

1207

pm
talk-show host bashing the very

Best example of
successflil

local

sports radio

marketing

efforts

of one of his employers sponsors

the

WNSTS
once again in

Drew

Forrester

completely

ripping

Maryland Jockey

Clubs Preakness

Preak 2010

On
so the

slogan slogan

Preakness

had about 100000 wouldnt comments

at

in attendance

worked

have

stooped

to this level

this however

Your negative

on here about Jen Royle

by posting reminded

me
you

of

how

unprofessional you are

times town

My

question
to learn

is

this.

.Who

are

to criticize

new young make

talent

in

trying

Perhaps

she did

few blunders upon anival

but she at least deserves

ropes dont know just

the

going
is

by what youre saying

getting

few breaks while she

on the other

comfortable
for

in her

new
as the

surroundings
it

You

hand

have

been here
Baltimore

long time and such

seems you have no problem bashing

traditions

0s
Ive

and Marylands

largest

sporting

event
sticking

The Preakness up
for the

For the kid in

record

never

even met Jen Royle

Only

new

town

bhop Says December 30th 2010

at

1259

pm
bunch
of other Baltimore
reporters

So she
openly
If

literally

stood about

around

and

talked

how much

she hated Baltimore Did that really ever heard

happen

so
is

thats got to be the weirdest thing Ive

It

interesting inclined

to note that to include Interesting

she had that

specific

much

of an affect

on you

that

you
her

were

section

in your

2010 review

to call

out unprovoked Baltimore

indeed

DF Anyone
10/1

who

is

critical

of

has an affect

Drew

Forrester

Drew

me Im from Baltimore Forresters Blog My Best of the Best

on

in

2010 available

at

http//wnst.net/wordpress/drewforrester/20

2/29/my-best-of-the-best-in-20

10/

Supp

Exhibit

000008

Supplemental Page

Exhibit

See Plaintiffs Documents

Original

arid

Supplemental

Responses

to Request

for Production

of

1/20 11

Drew

Forrester

sends
shirt

series

of tweets
is

saying that stuck-up

that

shed
snobby

look great in
tourist

nothing but

Nick Swisher
vacation

and that she

on

brief professional

here

tweets

she

is

ignorant

and clueless

while insulting

her bosses

who

thought

she was qualified

@WNST
at

Drew

So

Im handling
it..she

WNST.net

Hell

get

@mattvensel and jnroylemasn today might cry.. but its all good nonetheless

@WNST
great in

NOTjenrolemasn
shirt

jenrolemasn Drew Well

else

bet

youd

look

Nick Swisher

and nothing

LOL
you know where
is. to

@WNST
find

yoitschad
the

JenRoylcMASN Drew Well

one talking about

her Shell be

how

cute

A-Rod

JenRoyleMASN Drew Im
you were wearing
yesterday

exhausted

trying

to figure

out what perfume

You

smelled fantastic

@WNST
stuck-up

JenRoyleMASNDrew And
tourist on brief

think the

fact that

youre
is

snobby

professional

vacation

here

COMICAL too

@WNST
of-town

Nester

When Ravens
who

season
are

ends

Ill engage

w/ignorant

out-

genius

journalists

clueless For

now Im purple

focused

@WNST
Renegade

Nestor But Drew has been

.. real disgrace
is

KIND

to

Miss Yes

Jen

in corporate bosses

who

though

Mr Yeah theyre

qualified
Copied by Jen Royle from
twitter

1/11/2011

Drew

Forrester

tweets
that

that Jen

Royle

is

just

tourist in Baltimore

@WNST
Thats
her

Drew LOL

Jen Royle thinks Jen

Im obsessed
is

with

her
tourist

OPINION Heres my FACT

twitter

an out-of-towner

Copied by Jen Royle from

5upp

Exhibit

000009

Supplemental Page 10

Exhibit

___________

tweets

his agreement

with that assertion

ThiS. then threatens

out-of

towners

@WNST
Baltimore

Sparky4ddub and
try to tell

Drew Well

out-of-towners who come

sports is..

to

ME

about Baltimore

using your

word. .annoying

@WNST GMC Im glad

to

let

Drew

write

today he handled

it

well Kudos

him
Drew
Forrester Out-of-towners

@WNST
to pick

beware

.this

isnt

good week

on Baltimore http//bit.Iv.fK3hnH

@WNST
Drew Hey
worries..

@DamStone

its just like pro wrestling

JenRoyleMASN @lO57TheFan We all have role to

@mattvensel play

No

Copied by Jen Royle from

twitter

Drew

also posts

blog in which he states that and that he thinks

Ms

Royle has fanned flames

since

coming

to Baltimore

she has

good scent

Jen

Royle has been fanning

last

the

flames since

the

day she graced us with her

have
to admit that press

presence

spring

And
she

in

FULL

disclosure

she

SMELLED
wearing
.it

like

million

dollars yesterday at the

literally

Ravens

conference

Yesterday honestly

did grace us with whatever

she was

was glorious

When

you

arrive

in Baltimore

to

work
where
is

you cant come

the

in like

banshee

and kick

the

door

down
said

and say

son-of-a-bitch

Note
of the

Quick Jen who

that
It

No

it

wasnt Bowl

Brian

Matusz

think he said coach

Love
Ravens
with

those jeans

was Brian Billick you

Super
that

know

the

when

they

won

the

and the guy

into the

who was

so impressed

our small audience

he bought

station beware
.this

Drew week

Forrester
to pick
at

Drew

Forresters

Blog

Out-of-towners

isnt

good

on Baltimore
http//wnst.net/wordpress/drewforrester/20 11/01/il /out-of-towners Original and

available

bewarethis-isnt-a-good-week-to-pick-on-baltimore/ Supplemental Responses

to Request for Production

See
of

Plaintiffs

Documents

Supp Exhibit

000010

Supplemental Page
11

Exhibit

brew

continues

insulting

comments

in response to

comments

on

his

blog

Chris Says
January That

11th 2011 what

at

213

pm
he is eff the steelers and anybody from
sports

Drew

great blogger

pittsburgh

and stupid

bimbos from boston who no nothing about

of their looks
eff

and

only got their job because

em

all...

over4ODon
January

Says
2011

11th

at246pm
really have gall

These Daahnn
Laroche

Tahners

Did Royle ever

Pitt

eat

crow about

the

non-offer/signing
to believe

And

only

sburg

A-HOLE
good

would expect
the

anyone Ravens
aint

the use of bush-league might be alot things

wouldnt
mostly

incense

masses

of

Town
of

Flacco

but Bush-league

them The same way some

stir the this

high class journalistic

in

know provincial would

pictures to keep

massses
in

BIRDLAND

BIMBO had to How about some

subject

stirred up

Fridasys

MUID

bhop Says Januaryllth 2011

ill
at

1015 how

pm
rag

have

to agree about that in there

remember some bozo posting people thats when

stopped

column
reading

about

he hated homeless

man your
perfume.
wouldnt were

attacks

onjen

royle

are so pathetic

dude
the
if

dont know her comments

or read

her stuff but you really seem like

.thats borderline

man

obsessed

about her dude

creepy old

man

stuff

she were

you

be spending

nearly this

much

time on her

DF

First off if she

dude shed

never smell that good or look that good in those boots

Im obsessed
talk to people

about one thing an out-of-towner about Baltimore wrote

as sports

coming

in here and trying

to

when

she doesnt have any kind of

investment

in it

much
Blog

although

you

clearly

didnt read what

wrote
Drew week
Forrester
to pick
at

Drew

Forresters

Out-of-towners

beware

.this

isnt

good

on Baltimore
http//wnst.net/wordpress/drewforrester/20 11/01/11 /out-of-towners
Original

available

bewarethis-isnt-a-good-week-to-pick-on-baltimore/ Supplemental Responses

to Request for Production

See of Documents

Plaintiffs

and

Supp

Exhibit

000011

Supplemental

Exhibit

Page

12

rwthen
on

comments

that

Ms

Royle

prefers

other

cities

and

is

just in Baltimore

scholarship

As for
crabs

that

girl

at

105.7 she can and

Fells

try to write great

about

how much
the

she loves but the truth

years else and

and Sabatinos
is

Points

view of

sunset

of the matter

that

shes here on scholarship

in

She knows

that Three

from

now

her apartment
or

Baltimore

will be occupied or

by someone
other

shell be in Chicago

Los Angeles

Miami

or

some

ritzy place

where her
other

pretty smile and expensive

perfume

habit

will be part of

some

stations

budget

..
Since posted
this Jen

EDITfrom
ferocious

DF

at

535pm

has launched

into

Twitter

attack

claiming

among
talk
lot

other things

that Ill never cries

be

anything but baseball Baltimore

miserable small-time She should

small-time

show host who

over his
in

team
to be

know

about claiming
is

something

since she

on

the record saying she

had
in

numerous job 2009

in but

opportunities

when
because

she

ahem
gives

left

the

YES Network
to

chose

Baltimore

it

me

the chance

be

big fish

SMALL pond
Drew
Forresters

Drew week

Forrester

Blog
at

Out-of-towners

beware.

.this

isnt

good

to pick on Baltimore

available

http //wnst.netlwordpress/drewforrester/20

11/01/11

/out-of-towners-bewarethis
Original

isnt-a-good-week-to-pick-on-baltimore/2/ Supplemental Responses

to Request

See

Plaintiffs

and

for Production

of

Documents own

1/15/20

11
is

Drew

posts

picture

asking

viewers

to write

their

caption that

implies he

saying

Ms

Royle

is

failure
is

Someone
You Drew
Friday

from 105.7 who

subject

fan of Friday

Mud
it

sent

me THIS PICTURE

yesterday and in the

line of the e-mail

read

Lay-Up

Ill

say

can caption this

one

Im leaving

it

alone
to rush through

Forrester

Drew Foresters Blog Take

at

your time. .no need

Mud

available

http //wnst.net/wordpress/drewforrester/20

11/01

14/take-

your-timeno-need-to-rush-through-friday-mud/ content/uploads/2010/03/failure.jpg over her

picture

link to http //confidentl of

.com/wp
taped
to Request

woman

with

FAILURE
Responses

mouth See
of

Plaintiffs

Original and Supplemental

for Production

Documents

Supp Exhibit

000012

Supplemental

Exhibit

Page

13

1/20/2011
conflict

___________
of interest for

answers

question on

DCRTV.com
the

that

it

would be
for

Ms

Royle

to date

player on people

team she covers

the

MASN

The question he responded

well aware
effect that

to stated

on

team and

MASN
sleeping with of
this

employqs were
demonstrating Brian

she has been dating an Orioles claims that

pitcher
is

the

of the Defendants

Ms

Royle

Matusz Dave Hughes

and the Plaintiff have personal knowledge

at

incident previously

available

http//www.dcrtv.com/davetvl.html

1/21/2011

Drew
link
is

Forrester picture

blogs with of
sign

link to

sign that
is

ruined

Ms

Royles

2010 The Drew

saying

Welcome
2010

to Baltimore

Hon
day
at

The

sign that

ruined Sen Royles Forresters

entire

RIGHT
better

HERE
the 11/01/21/friday-

Forrester

Drew
at

Blog

Friday

Mud

is

than

beach available

http //wnst.net/wordpress/drewforrester/20

mud-is-better-than-a-day-at-the-beach

link to
10/1 sign saying

http//www.baltimorebrew.compublish/wp-content/uploads/20 welcome-to-baltimore-katrina-krauss.jpg
picture

2/honto

of

Welcome

Baltimore

Hon See
of

Plaintiffs

Original

and Supplemental

Responses

to Request

for Production

Documents

BALIIMORE

1/26/2011

PtewFc
that

tester states in response

to

comments

on

his blog that

is

the

only qualification

Ms

Royle has

to be in Baltimore

Magazine

that

she

5upp

Exhibit

000013

Supplemental

Exhibit

Page 14

works here He makes

herself

also says

he

likes the

way

she.smells

and questions

why

she

smell good around

athletes

Al Says
January

26th 2011

at

848 am
Baltimore

How
the

embarrassed

should

Magazine be

for promoting

certain

sports personality as one of Baltimores most eligible singles Shouldnt

criteria

be that Baltimore

singles

should

actually

be from Baltimore

or an

active

member

of the Baltimore

Second question
friends horrible

When

said

community Baltimore single commented

all from out of state is shouldnt Baltimore
to add spring

how
agreed

all

her

and back tracked

her

to include

how
up
the

magazine
retraction

picture

Magazine

offer

community

of their mistake waited

until the

her
travel issue to highlight
all

Perhaps they shouldve the tourist

sites
is

of

in

and around town

suited
is

DE

This

question better

for Baltimore as long as

Magazine and

their

selection

committee

My

guess

you

WORK
so

in Baltimore

youre
sticker

eligible

havent

seen the other

sexy

singles

dont know how

scratch

our girl

got in but too bad the magazine didnt have

and sniff

.if

you know what

mean

Thats

her best attribute by

far

.1

Kristen Says January

26th 2011

at

1149 am
actually
air

Drew
always
sports

Have

you ever

met and shes

is

talked

with Jen Royal or do you

disrespect

her on the

because

female

and

according

to

smells

really nice

which

your

way

of saying she doesnt

you know

but because time of day

she smells nice

she has

ajob
like

She probably doesnt give her

you

the

and thats why you dont

DF Youre
sports

funny Each

but Ill humor you

more Ive

talked

to Jen

Royle on

several

occasions

time shes been condescending knows

is

snarky unfriendly and snobby

think she
said

sports

Ive

that

she doesnt

NEVER once said she didnt know know BALTIMORE And because
at all

What Ive

of that she has no

historical

perspective

on

the

Orioles

and

Ravens

My

remarks

about

how

great

she smells. .those

to ask

are

COMPLIMENTS
on smelling
decide

She always
that great

smells great

Youd
admit

have

her

why

she

insists

around

bunch winner

of athletes

Thats

not for

me to

But she always

smells like

that

Supp Exhibit

000014

Supplemental Page 15

Exhibit

Drew

Forrester

Drew

Forresters going
to

Blog Back

in the

saddle again 21 Questions available

at
1-

Returns

Update Were
See

OVERRRRR-T.LME
11/01 Original

http//wnst.netlwordpress/drewforrester/20 questions-returns Request

Plaintiffs

/26/back-in-the-saddle-again-2

and Supplemental

Responses

to

for Production

of

Documents
Baltimores
outfit

1/28/2011-

Diew
to

Forrester

states in his blog that

own

Jen

Royle

showed up

photo

shoot with nearly

all

Nick

Swisher

By

now

Im sure

of you have
features

Baltimore
as one

Magazine which

up the latest copy of Baltimores own Jen Royle of

picked

MASN

of our citys Sexy Singles

Evidently

Jens photo magazine

shoot didnt go so

well

When

she arrived

at

the

location the

staffer

handed her an
something

outfit and that

asked

her to get dressed

little

think depicts

allow Jen to wear

the editor wouldnt my style THE CLOTHES SHE BROUGHT TO THE PHOTO

Royle replied But better Fortunately

brought

SHOOT
Drew
Forrester
at

Drew

Forresters

Blog

Just in the

nick of time its Friday

Mud
is

available

http/wnst.networdpressdrewforrester20

11/01/28/just-in-the-nickoutfit

of-time-its-friday-mud
available Plaintiffs
at

link provided

shows Nick Swish

below and

hap product.images .fansedge coml3 2-30/32-303 54-F.jpg See to Request for Production of Original and Supplemental Responses

Documents

In the

comments

to the

blog someone responds

responds
that

on January

29th to insults about

Jen Royle

and Drwotresthf

she could

handle it

malt Says
January

29th 2011

at

1130 am

Supp Exhibit

000015

Supplemental

Exhibit

Page

16

do think

the jen royle

stuff

is

funny

along with

everything
tail

else but

also

agree you definitely kindergarten pig pull thing going on towards her totally crushing on her for good reason looks not personality
the

have

pull

brett favre

on her

thats

my advice

but do

it

from

pre paid phone

DF Whatever.
no reason you
for actually

.shes from Boston. .she can handle

little

chiding

Theres

me to have crush on anyone Im married And trust me once meet her the crush-thing ends Shes boorish snobby and
real

caustic

Other that that shes

peach
nick of time its Friday 11/01/2

Drew

Forrester
at

Drew

Forresters

Blog

Just in the

Mud
to

available

http//wnst.net/wordpress/drewforrester/20

8/lust-in-the-nick-

of-time-its-friday-mud

Request few

for Production

See of Documents
on

Plaintiffs

Original

and Supplemental

Responses

other

comments Says

the

blog are insulting

Tom

January

28th 2011

at

1142 am
too
it

Methinks

he doth protest
are tired

much

Usually

enjoy your blog

but the Jen with her

Royle jokes

Keep

to yourself if

youre

that

obsessed
so

Ive met her once myself and shes

pretty nice

though

dont blame

you

Good

luck with the pain though

better

Vicodins

are your

friend with

DF Methinks
how
silly tell
it is

you need

sense of
to

humor
in like

Im

only obsessed china

for

an out-of-towner

come

bull in

shop

and try to
.11

me and

you

if

you know anything..

about Baltimore

sports

Steve Says

January28th 2011

at

141

pm
so disappointed
lot

Another pathetic This crap

Royle jab

huh Tm
for

Man

once

again you look so

but you
lost

know
is

speak

of other

WNST
the

followers
girl

me
hope

just too

immature and stupid Leave the complex

has gotten

alone

She does

good job Your someday

Jen

inferiority

best

of

you buddy you

bitter
is

fulfills

your wildest dreams second glance

and says hello

to

guarantee

shes never given you

yet to

and thats
Its all

why youre
personal

Youve

make

sports
its

related

attack

on her

which
if
it

irrelevant

and

borderline

creepy Good luck

DF Well

means

Supp

Exhibit

000016

Supplemental

Exhibit

Page 17

anything to
Is

you

Im GREATLY
professed

disappointed in Its

you

Sports related

attack

that

what you said Are you on dope

to Baltimore this place

ALL

sports related chief She

came

to be beneath

her then

quietly

went

about bragging nothing have

the for

how much

she missed

New

me And
how
back
all

then shes tried to

York and how this place has tell lYlE and you but you dont
feel about the

balls to speak

Orioles pair sure

and
get

up. .1 do how the community should we want to do is cry about our baseball

team Grow
thing. fun
.not
at

and
if

to

me when
it

youre not smitten

is

And
all

one other

youve

figured to

out or not but the blog

light-hearted
like

about poking
at

people Its meant blog

be

took
little

jab
girl

Glenn

in the to Jenny for

.you dont see him whining

see her
at

Say

hey

me

when you
StevenB

the water fountain

at

105.7

today

Says

January28th 2011 Nothing

at2S4pm
here as
different tourist and nothing things

for her to see are so

here for her

for another

professionally

two

bro

will root

And

wish

was Jen

could

smell as nice

as you say she does Guess Ill never

know
John

Says 28th 2011

the at

January

1054

pm

Keep up
stand

good work with

Mud

and keep

up

the

Jen jokes because

cant

her
Drew
Forresters

Drew

Forrester
at

Blog

Just in the

nick of time its Friday

Mud
to

available

http //wnst.net/wordpress/drewforrester/20

11/01/28/just-in-the-nick-

of-time-its-friday-mud Request
for Production

of

See Plaintiffs Documents

Original

and Supplemental

Responses

2/22/2011
is

J$j comments
pretty face other

that the

only reason
that
is

Ms
is

Royle has been employed

not qualified
to discuss the

because she has

and breasts

she

Orioles or any

team because

Ms

Royle

woman
me
on
the

RoyleJ What did Nestor

say about

air

Its

len

texting

from

CBS
Herneker He went on
baltimore
or

30 minute

tirade saying yer not

from
the orioles

and

dont

care

about the

team

yer not qualified

to talk about

any

other gotten

team

for that matter because

youve

the jobs that

have

is

because

youre have

woman

and

the

only reason

pretty face

and breasts And

5upp

Exhibit

000017

Supplemental Page 18

Exhibit

that people in baltimore that tells the

that

support that programming theyre

indirectly orioles that

are contributing

to the

economic
is

decline

because

hurting his station

which

the

only station

truth about the targeting

in this

city and they get blacklisted there but

Same
ii

old the love

crap He was

anyone

wasnt from baltimore over drew

called

were
so

only one that him and that jackass controversy but

Plaintiffs
this

out by
cringe

name.Im
cuz

stem fan

was

time that

made me

hate that

guy See
of

Original

and Supplemental

Responses

to Request

for Production

Documents
3/29/2011

Drew

responds

to

comments

about

Ms

Royle

in

blog sarcastically

Mike

from Carney Says

at

April 29th 2011 always have

103

pm
is

believed that the voice

just

from

the

vote You dont vote you dont

voice And thats

did
all

fact stop
great
all

When

the

Jen bashing
telling

Except
it is

for the

hidden

of town reporters vote for anyone

bow
they
theft
is

out there
in

we

get

message about out it If dont

DF

because

stink

my opinion
and
.1

absolutely
criticize
it

still

have

the

right to critique

in-office the

performance

if

necessary

That

my friend

REAL

fact

Purple Kelly Says April 29th 2011

at

539

pm
addition to this city

Love

Jen shes

welcome
Jen

hope she

stays around

long time

DF Huh
Drew

who
Blog No
stunner here.
.Friday

Drew
hot as

Forrester

Forresters

Mud

is

back and

firecracker

http//wnst.netlwordpress/drewforrester/201

1/04/29/noPlaintiffs Original

stunner-herefriday-mud-is-back-and-hot-as-a-firecracker/

See
of

and Supplemental

Responses

to Request

for Production

Documents

3/30/2011

fiblogs
can search anywhere on the
that internet

You
truth

you

like

and you

will not find

tell

shred of evidence

weve

ever said or done

anything more than

the

about her journalism Mills

skills literally

and her outlandish behavior have hundreds

social

in social

media

and in Owings

We

and hundreds media

that

of public
frankly

pronouncements made by Miss Royle via would make any WNST.net

hiring

quite

employee an

ex

employee

And

yes

do the

and

firing here at

WNST

Supp

Exhibit

000018

Supplemental Page 19

Exhibit

Miss Royles
and she
is

feelings

have been
based
daily
it

hurt

by thousands

of people

in Baltimore

quite

fighter

on what we read from her public work Her

fans

blog reiterates that on and the like

basis as she calls out

jerks

Baltimorons
just like this

You

can check

for yourself Its quite

public

blog Apparently shes only decided

Perhaps its because
like shell get her to sue us here at

WNST.net
its because

were

direct local

competitor

perhaps

she feels
extract

name

in the

newspaper and shell eventually

the attorney fees

some money out of us

dealing with
loser
this

Win

or lose

and

my

time spent

nonsense today

will certainly

be draining

my piggy

bank so

Im

beginning

no matter the outcome rumors about her Not

of this frivolous

case
Not

But

to spread vicious

me Not

this

staff

EVER

at

WNST.nt You wouldnt

world

have

wanted
advice
guilt

to hear to

my

reaction lawsuit

to

who

gave

me
this

settle

that

anyone in my professional didnt have any merit and

and somehow admit

where

there

is

none
locally nationally

Ive been

doing

for 27 years as

professional

on the internet We dont spread rumors We dont gossip We dont lie And were unabashedly able to own up to ANYTHING we officially report via
any of our media properties
at

WNST.net
our product
it is

But were
marketplace

also not strangers

to pointing out that telling

the

best

in the

every day

and

ou why

and proving
If

every day with

tell

our passion

industriousness certainly

and accountability

we dont

you how

good we are we

dont

expect our competition out-of-town

to do it talent into the

And when
marketplace Especially

our competitors bring inferior

were when

going

to point

it

out
be so brazen
to the

any media

member would
so openly
is

about loving

the

Yankees
serving

and
the

Red Sox and

community

disrespectffil

community

theyre

that

literally

feeding

them

No

one

at

WNST.net
close

has ever written

or said

what

these

allegations

suggest

Not even

We
do

said Jennifer

Royle doesnt know

as

much

about Baltimore

sports

as

we

We

said

shes

lacking

information and professionalism

which

if

youve

followed

her on Twitter

youd

see

why weve come

to that

conclusion

5upp

Exhibit

000019

Supplemental

Exhibit

Page 20

Shes
the

public

figure

She has

fan page on Facebook

She chooses

to

go on

radio

and serve up her opinions about our sports culture

to fight with

And

she every

chooses
single

Baltimoreans

and local sports fans

seemingly

day

of her

life

on

the

internet

The

truth

is

this

is

frivolous

case filed by
for herself

woman who
suing the

is

trying sports

to

come

to Baltimore

and make

name

by

best

media
day she

compan
arrived
hurt

in Baltimore

for pointing out sports

its

what

weve known
and

since

the

Shes
is

not

Baltimore
to injure

expert

now

she has her feelings agents and fans

and

trying

WNST

partners

employees

by
Nestor

trying

to take

money from
Aparicios

my company
Blog An
indictment of local journalism
at

Aparicio

Nestor

Heres

our side of baseless

Royle

WNST

lawsuit

available

http //wnst.net/wordpress/nestoraparicio/20

11/03/30/an-indictment-of-local-

journalism-here%E2%80%99s-our-side-of-baseless-royle-v-wnst-lawsuit/
Plaintiffs Original

See
of

and Supplemental

Responses

to Request

for Production

Documents Comments on

blog Says
at

BmoreBobRob
March 30th 2011

1139 am
big steamer
all

love

how you
did

guys took

over her and

what you

someone better
being
qualified

wrong Was she qualifed to do the Yes can see where you have
but
think

now you wonder job No Was there

right to

knock

her for not

of professionalism over people and

treat like

you guys went too far You really crossed the line Its like you want to act like Howard Stern and dump all
fun of people but then you want the same people to
journalist

make

you

are
it

Ted Koppell
both

respected

and opinion

maker

You cant
.1

have

ways

Tom

Says
at

March3lst 2011 As much as hate

1059 am
someone who worked
surprised
it

to see

so hard to create

all

that

they

have you cant actually be warned to stop long before

came
blasting

by this Dollars to donuts you were

this

ever got to blue sky

crisis

point

cant imagine

lawsuit

out of the
is

clear epic

You

act like this

some

So Royle

calls in

you
still

out

for repeatedly

trashing

her reputation

and

ability to

do her job

difficult

economy

to

Supp

Exhibit

000020

Supplemental Page 21

Exhibit

find

employment

in and

you have

the

nerve to be

angry Youre

worried
essentially

shes going
trying to

to take the

everything
to her

you have

from you but you were

do

same

by

attempting to

make

everyone

believe

she was

an unemployable tramp Joe of Bel Air makes

great point

Karma

is

bitch

Maybe youll win

for

maybe
another

youll lose but

vicious

bet this will

make you

think twice before you go on

smear campaign and

THAT

is

win

any

woman who

ever has to work in Baltimore

See

Plaintiffs

Original

and Supplemental

Responses

to Request

for Production

of

Documents

6/4/2011 Baltimore

blogs
Sports Expert of the

in

honor

of Jen Royle not being

what he

considers

In honor
had
trouble together this

fact that the

reporter from

the

FM
we

sports

station

in

town

fmding Towson University yesterday

bucket
list

thought

wed

put

for our

Tuesday

Top

which came on

Wednesday

week
was

Todays Tuesday Top

Consider Yourself

topic

The Top

Things

You Need To Do To
hope
its self

Baltimore

Sports

Expert As always

explanatory Glenn Clark Glenn Clarks Blog Morning Reaction Tuesday Top Things You Need To Do To Consider Yourself Baltimore Sports Expert available at
http //wnst.net/wordpress/glennclark/20 11 /05/25/morning-reaction-tuesday-top-7-

things-you-need-to-do-to-consider-yourself-a-baltimore-sports-expert/
Plaintiffs Original

See
of

and Supplemental

Responses

to Request

for Production

Documents Drew
Boston and compares Jen Royle
is

6/10/2011 another

Forrester

blogs

insulting

to

media person

insinuating

Ms

Royle
pained

unintelligent the fact that the

Speaking
allowed Stanley
the

of Boston

Im quite
it

by

Canucks and

have

Bruins back in the series

Finals to even

having

won Game

of the

Cup

up

at

2-games apiece

know

.trust

me

know

Anytime someone

or something

from Boston experiences

even

morsel of success

its disheartening things to

They dont deserve anything good

out of that hell-hole
are

The only acceptable Damon The Country

his

come

The Cars Malt

Club

of Brookline

where

Curtis

Strange

won

one of

two U.S Opens

and Steve Carell

Everyone and everything

Supp

Exhibit

000021

Supplemental Page 22

Exhibit

else. .sucks of Bostons

Well
heritage

OK

need

to take

that the

back
record

apologize voted
is

THIS times

PART
at

didnt suck

Im

sure

and will

youve now concentrate

side

heard by

now

that

For Mark

981

Viviano

leaving his post

sports

105.7

solely

on

his duties

as the

anchor and

at

Channel

13 On guy
.and

note

Ill mention

that

Mark
less

is

solid citizen

good Vivianos

hope he enjoys his means case

new

stressful life

Anyway
talk host

departure

The Fan

is

looking

for

new

sports

As

is

always

the

Im hearing
As
to

rumors
their

and theyre just that rumors

about
for

his replacement

has become

custom

105.7 execs are looking with their sports

someone

out-of-state

come
it

in and

wow

everyone

knowledge
Carolina

Rumor
and
that
is

has

theyve centered

their search

on

native

of South with

THIS GIRL RIGHT

the lead

HERE

passed

her interview
talk

flying colors

and

candidate

to take records

over
are

Vivs

show

gig
edition

Drew
Friday

Forrester

Drew

Forresters

Blog Hit

short.

.but this

of

Mud

sure

isnt available

at

hap //wnst.netlwordpress/drewforrester/20
edition-of-friday-mud-sure-isnti

11/06/1

0/hit-records-are-shortbut-this-

first link to
at

video

of the

Red Sox

blowing

the

1986 World
http to

Series available

//www.youtube.comlwatchvghQ
video of
girl

VU12T1 8Efeaturerelated
in

second
at

link

giving

bad answer

Miss Teen

USA

available

http//www.youtube.comlwatchvlj3iNxz8Dww for Production of Documents Request

See

Plaintiffs

Response

to

Comment on rwTthiesters

blog

states

that Jen

Royle

references

are

common

Mike
June

from Carney Says

2011
at

10th

921 am
The

Finding the Royle references

in

Mud

is

like

fmding

the

toy

in

the

cereal

box Love it
think

DF Huh
pitch..

To borrow

line

from Bull

Meat

just

think youre thinking too

Durham. .dont much But have fun

.but this edition

with

it
Drew
Forresters
at

Drew
Friday

Forrester

Blog Hit

records

are

short

of

Mud

sure

isnt available

hflp //wnst.net/wordpress/drewforrester/20

11/06/1

0/hit-records-are-shortbut-thisOriginal

edition-of-friday-mud-sure-isntl

See

Plaintiffs

and Supplemental

Responses

to Request

for Production

of

Documents

Supp Exhibit

000022

Supplemental

Exhibit

Page

23

6/11/2011
reporters

Ms
who

Royle

contacts

__________

to complain that

that

Glenn

Forrester

told

knew
told

about Jerry

Coleman

he had

reliable

source from the player

Warehouse

him

that

Ms

Royle had

relationship

with

Hi Greg
Sorry to
reporters reliable
bitter

you with this.. But Drew Forrester told some was sleeping with Matusz and is now saying it came from
guarantee

source in the warehouse

in court
is

Drew

is

going

to throw

that

source under the bus

this

to

make

himself look innocent

Any

idea

who

warehouse source
this

and can you please

to rest

confirm you did your part in

putting

ridiculous

rumor

Again Tm
but
its

very very sorry

for the

drama

and
if

you know

love you to pieces

verydisheartening
directly

and

disturbing

these

kind of false accusations

come

from

the

organization

especially

when

was an employee of

MASN
Thank

you

Jen
Email from Jen Royle

that he does not believe __________ replies

there

was

real source

would love

to

know who
have

this supposed

source is

doubt

he has

one
about

No
it

one

know would

spread such
it

rumor

spoke

with
clear

Monica

and she doesnt spoke

know where
in spring

came from And

that

was

to her after

Brian and

training

wouldnt

mongering and
doubt
is

specifically

mentioned

this

any rumor item She agreed and have

tolerate

no

doing

whatever

she can to

curtail

the

spread of false rumors As

other

am

have heard no such rumors about you

or any

media members

this

season
Email from Greg Bader See
Request
for Production Plaintiffs Original

and

Supplemental

Responses

to

of

Documents

6/16/2011 undercutting
his

tweets

about sale of discount tickets

that

to

Gold Club

strip

club

argument

Ms

Royles Ravens

outfits are trashy

22812

PM

Supp

Exhibit

000023

Supplemental

Exhibit

Page 24

Nestor Ever been

Available

to

NOW

GoldClubon Route4o Wanna go

Plenty of cool
twitter

1/2

price
to save

www.wnst.net/youpon
from

places

Baltimore

Copied

by Jen Royle

Unknown

Dates

Drew
season

Forrester

t-weets

at

the

beginning

of the 2010
for

Ravens

RT
You

@wnst Drew Good news

can follow our tweets tweets
live live

BALT
sent

you guys in from the stadium Appears

to be

or

Jen Royles around

from her

couch
twitter

9/27/10

Copied from 2010

by Jan Royle comments

On

or about September

on

blog that
short

he does not understand

why Jen

Royle

wear
be on
the

skirts

and boots to games knowing

she

wont

TV

and

that

its pretty cold assertions

is

outside
that

This demonstrates
is

Defendants
because she

Ms

Royle

employed only
otherwise

an attractive

female but

is

unqualified for her

job
Coleman from Fox on
with
or about

Drew
July

Forrester

tells

Jerry

2010
he had

You

know shes hooking up

also allegedly told

Matusz
Coleman
that

right Drew
that

Forrester

Jerry

reliable source in the Warehouse Orioles offices

Jerry

can and

confirm Warehouse
Defendant
incident
Forrester

Coleman
of
this

have

personal knowledge

Supp Exhibit

000024

PLAINTIFFS EXHIBIT
Dianne Royle

Mother

knowledge

of Plaintiffs

career

and

personally

droyleconicast.net

Beth

Royle

Sister-in-law

knowledge

of Plaintiffs

career

and

personally

bethroyle.79gmail.com Dave Boss CBS Radio knowledge

Labrozzi

of Plaintiffs

professional

career

dave.labrozzi@cbsradio.com

Bob

Philips

Boss

CBS Radio knowledge

of Plaintiffs

professional

career

bob.philips@cbsradio.com

Jim Cuddihy

Former boss

MASN

knowledge

of Plaintiffs

professional

career

jcuddihymasnsports.com

John Angelos
contact

Former boss MASN/Orioles

is

knowledge
immediate

of Plaintiffs

professional

career

information

not in the Plaintiffs

possession

custody or control

Jim Duquette

Friend/Co-worker

knowledge

of Plaintiffs

professional

career

jrduqettecomcast.net

Ken Weinman

Friend/Co-worker

knowledge

of Plaintiffs

professional

career

ken.weinman@cbsradio.com Conn
of Plaintiffs

Jeremy

Friend/Co-worker

knowledge

professional

career

jcole5545@aol.com

Scott

Garceau

Friend/Co-worker o.com

knowledge

of Plaintiffs

professional

career

scott.garceaucbsradi

Bob Haynie

Friend/Co-worker

knowledge

of Plaintiffs

professional

career

bob.hayniecbsradio.com

Damon

Yaffe

Friend/Co-worker

knowledge

of Plaintiffs

professional

career

damon.bulldog.yaffegmail.com Ed Norris
of Plaintiffs

Friend/Co-worker

knowledge

professional

career

ed@l057thefan.com

Bruce

Cunningham
is

Friend/Co-worker

knowledge

of Plaintiffs

professional

career

contact

information

not in the Plaintiffs

immediate

possession

custody or control

Keith Mills information

employee
is

at

WBAL

knowledge
immediate

of Plaintiffs

professional or

career

contact

not in the Plaintiffs

possession custody

control

Exhibit

000001

Jerry

Coleman

Formerly

of

FOX

1370

AM

knowledge

of Plaintiffs

professional

career

301-

12-5800

Jon Gallo

Formerly

of

CBS

Sportsline knowledge

of Plaintiffs

professional

career

443-695-

2226

Casey career

Willett

WBAL

and

formerly of

CBS Radio knowledge

of Plaintiffs

professional

dwill77@aol.com

Exhibli

000002

JENNIFER ROYLE
Plaintiff

IN

THE

CIRCUIT

COURT

FOR NASTY
1570

SPORTS LLC

et

al

BALTIMORE
CASE

CITY

Defendants

NO 24-C-11001571

NOTICE OF SERVICE OF DISCOVERY HEREBY CERTIFY

Supplemental
that

on

this

8th

day

of July

2011

copy

of the

foregoing

Answers

to Interrogatories

directed

to Jennifer

Royle on behalf

of

WNST

SPORTS MEDIA
prepaid to

LLC

one

of

Defendants

was mailed

via

first-class

mail postage

Charles

Tobin Esquire

Drew
Holland

Shekman Esquire Knight LLP Avenue

20006

2099 Pennsylvania
Suite

N.W

100

Washington

D.C

202

955-3000 for Defendants

Attorney

1Qt50
Brian

Goodman
Moylan PESSIN KATZ P.A

Alexandra

HODES

901 Dulaney Valley

Road

Suite 400

Towson Maryland

21204-2600

410 410

938-8800 825-2493

Fax

Attorneys for Plaintiff

EXHIBIT
July

10

15 2011

Letter

to Plaintiffs

Counsel

Holland
2099
Pennsylvania Knight

Krnght
NW
Suite

Avenue LLP

100

Washington

DC 20000

202.955.3000

202.955.5564

Holland

www.hklaw.com

CHARLES

TQSIN

202

419-2539

charIes.tobinhkjaw.eom

July

15 2011

Brian

Goodman Esq
Pessin

Member Hodes
901

Katz P.A
Suite

Dulaney Valley Road

400

Towson

MD

21204

Dear

Mr

Goodman

This

is

to

confirm

our telephone

conference

today

During

our discussion
in the

asked

for

you

to

confirm

that

the

allegedly false statements

to are

numbered

1-18 enumerated
constitute

Ms

Royles Supplemental
that

Answer

Interrogatory actionable

Number

served on July

only statements

she contends

in this litigation

You

confirmed

that

our understanding

is

correct

Based on Maryland Rule

that

representation

we do

not intend

at this

time to pursue

motion under

1-341

Sincerely

HOLLAND

KNIGHT

LLP

Charles

Tobin

CDThje

lO477977vl

EXHIBIT
to

11

Composite Exhibit of Plaintiffs

Responses and Supplemental Responses

WNSTs

Document Requests

JENNIFER ROYLE
Plaintiff

IN

THE

CIRCUIT

COURT

FOR NASTY
1570

SPORTS

LLC et

at

BALTIMORE
CASE

CITY

Defendants

NO 24-C-11001571

PLAINTIFF JENNIFER

ROYLES RESPONSES TO

WNST SPORTS MEDIA LLCS FIRST REQUEST FOR DISCOVERY OF DOCUMENTS ELECTRONICALLY STORED INFORMATION AND PROPERTY
Jennifer

Royle

Plaintiff

by

her

attorneys

Brian

Goodman

and

Alexandra

Moylan

of

Modes

Pessin

Katz P.A responds

to

First

Request

For

Discovery

of

Documents

Electronically

Stored

Information

and Property propounded and

as follows

to her

by

WNST

Sports

Media LLC

one of the Defendants

states

INTRODUCTION
The
based following responses
represent the Plaintiffs to

present date

knowledge
Discovery
the right

on

discovery
trial

investigation

and

trial

preparation
Plaintiff

investigation and
to rely

preparation

are continuing

expressly

reserves

upon

further

information adduced

upon completion
or

of discovery

investigation

and

trial

preparation

and

to supplement

amend

her responses in light thereof

Plaintiff

objects
is

to to

the

portions

of the

requests

purporting
the extent

to

dictate

the

maimer

in

which
are

Plaintiff

produce

documents
or
at

To

that will

responsive

documents documents

in

her

possession

available

for inspection

custody and copying

control
the or
offices

Plaintiff

make

such

of

Modes
copies

Pessin

Katz
as

P.A

at

such

time as counsel
available

may

mutually

agree

will provide

to counsel

they become

GENERAL RESPONSES AND OBTECTIONS

Plaintiff

objects

to each or

and every Request

prepared

to the
in

extent

the

Request
of

seeks

work

product

information

materials

contemplation

litigation

information or communications
or communications

protected

by the

attorney-client privilege Plaintiffs

privilege or the

information mental
or

protected by the accountant-client

or legal theories of the

opinions

impressions
other

conclusions

attorneys

accountants

representatives

Plaintiff

objects

to each or

and every Request

prepared

to the in the

extent

the

Request
of

seeks

work

product

information

materials

course

settlement

discussions

Plaintiff

does

not waive

any
or

protections

or of

privileges

these

Requests

Inadvertent
of such

production
or

exposure

any such
other

to by responding document shall not of objection

to

constitute the

waiver

privilege

immunity

or of any

ground

admissibility

of such

documents

or of any

information contained

therein

Plaintiff

objects

to each

and every Request

case
this

to the

extent
is

the

Request

seeks
to

information that
the

is

not relevant

to this

or information that

not

likely

to lead

discovery of admissible evidence in

case

Plaintiff

objects

to

each

and

every

Request
repetitious

to the

extent

the

Request

is

overly

broad
the

unduly burdensome
that the

harassing purport
to

vague
the

and/or ambiguous
of

and

to

extent

Requests

require

disclosure

information

beyond

the scope

of admissible evidence

under the Federal Rules of Civil Procedure

Plaintiff

objects of the

to these

Requests Rules

on
of

the Civil

grounds

that

they exceed

and/or

are

in

contravention

Federal

Procedure

and

the

Discovery

Guidelines

Plaintiff

objects or

to

these

Requests

to

the

extent

they

seek

information
technical

regarding
financial

trade

secrets

other

confidential

commercial

proprietary

or business

information

Statements
as

that that

responsive

documents

will be produced that

shall not be read

an acknowledgment
possession

such documents exist but only

or control
at

they will be

produced

if

in the

custody

of Plaintiff the
offices

Documents
of

are immediately

available

for your

inspection Suite

and copying

Hodes
attorneys

Pessin
for

Katz

901

Dulaney
costs

Valley

Road

400 Towson Maryland

21204

Plaintiff

Copying

will be borne

by

the Plaintiff

Plaintiff

objects to the

to each

of these

Requests
privilege

to the

extent

that

Plaintiff

seeks

information
doctrine

subject

attorney-client privileges

and/or

attorney

work
of of

product any such

or other shall of

applicable

Inadvertent production
of such of privilege

or exposure

document ground

not constitute
to the

waiver

objection

admissibility

such

or immunity or any other documents or of any information

234664-1

contained

therein

Unless
to

expressly

noted

to the

contrary

the

following responses
that

do

not include references

or

any document

subject

to such

privileges

were generated
of other separate

received

by

Plaintiff

after this the

matter was referred

of privilege
if

to counsel

schedule
in

documents withheld
writing

on

grounds

any

will be provided

Plaintiff Plaintiff

has

not yet completed

file

discovery in Responses

this
if

lawsuit

and

therefore
additional

reserves

the

right to

Supplemental

and when such

information comes into her possession

By
objections to
its

providing admission

the

information

requested grounds

Plaintiff

does

not

waive
or

into evidence for objections

on

the

of relevance

materiality

on

any

other

proper grounds

Neither production of
is

Plaintiffs

agreement
or as

to

produce
or

nor

her

objections
of

to

the or

any
to

information be construed

documents
an

any
or

category

information
that

documents

admission category

acknowledgement

any

information or documents exist within such

or categories

Plaintiff

objects

to any

Request

to

the

extent

that

it

requests

disclosure

of

information banned
objects the to the extent

and/or
any

protected seeks

from

disclosure

by law and

Specifically

Plaintiff

Request

disclosure

of information the

which

is

protected by
Shield

First

Amendment
Code

of the

United

State

Constitution

Maryland
State 297

Law

See

Md
413

Ann

Courts

Judicial

Proc

9-112

Tofani

Md

165 465

A2d

1983
These
objections to are hereby general

incorporated response

into each

specific

objection

and
is

response not

Citation of any

particular general

and any

specific

objection

below

waiver

of the

objections

not cited therein

Plaintiff

reserves

the

right to

modify and supplement

of the

her

responses
is

and

objections of that

to

Defendants Requests

and

response to any

Requests

not

waiver

right

RESPONSES REQUEST
relate to the

NO NO

All

documents and conununications

which

refer

reflect

or

Defendants

RESPONSE
broad

Plaintiff

objects

to the

foregoing Request

as

it

is

overly

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
Defendant

NO NO

All

documents and communications

between

you and any

RESPONSE

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
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively and with

burden than

the

Plaintiff

Without

waiving

these

objections

to

the

extent

non-privileged

and non-protected responsive

documents

exist

they will be produced

REQUEST
anyone
concerning

NO
the

All subject

documents
matter of
this

and

communications

between

you

and

lawsuit

234664-1

RESPONSE

NO

Plaintiff

objects

to the

foregoing Request

as

it

is

overly

broad unduly burdensome harassing vague and/or ambiguous

voluminous

as

it

requires

Plaintiff

to

produce

documents

that

are

unrelated

to

the

allegations

of

the

Complaint Moreover
period for which such

Plaintiff

objects

to

this

Request

as

it

does

not specify

time

documents

and communications

are

sought

The Request

as

worded
Further

is

not reasonably

calculated

to lead

to the

discovery of admissible evidence

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

with

by

the

Defendants

more conveniently

less

expensively

and

less

burden

than

by

the

Plaintiff

REQUEST
relate to

NO

All that

documents and communications you have

been

which
in

refer

reflect

or

your

contention

defamed

as

alleged

Count

of

your

Complaint

RESPONSE NO
it

Plaintiff

objects

to the

foregoing

Request

to the

extent

seeks

disclosure

of information

which

is

protected

by the attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in

anticipation

of

litigation

Plaintiff

objects

to the

extent

this

Request

seeks documents or information already in the custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by

the

Plaintiff

or

by

this

Request

Without waiving

these

objections

to

the

extent

other

non-privileged

non

234664-i

protected

responsive

documents

exist

the

will be

produced

Plaintiff

refers Defendant

to Exhibit

attached

to Plaintiffs

Answers

to Interrogatories

REQUEST
relate to

NO

All that

documents and communications you have been portrayed

in

which
false

refer

reflect

or in

your
of

contention

light as

alleged

Count

III

your Complaint

RESPONSE NO
REQUEST
relate to your

See Response

to Request

No.4
which

NO NO

All

documents and communications

refer

reflect

or

Answer

to Interrogatory

No.4

RESPONSE
REQUEST

See Response

No
which
refer
reflect

NO

All

documents and communications

suffered

or

relate to your contention that

you have

emotional distress

RESPONSE NO
it

Plaintiff

objects

to

the

foregoing Request

to the

extent

seeks disclosure

of information

which

is

protected by the attorney-client

privilege

the

attorney

work-product

doctrine

and or
extent

created

in anticipation

of

litigation

Without

waiving

these

objections

to

the

non-privileged

and non-protected

responsive

documents

exist

they will be produced

REQUEST
relate to

NO

All

documents and communications

within Royle your
control

which

refer to the

reflect

or

any Twiuer.com
but not limited

account
to

from 2008
For
all

present

including
shall

Jen
obtain

and @JenRoyleMASN
history including information by sending

this

request
sent

you

obtain from Twitter account

fax to

complete

account
this

tweets
written

by you
to

from each
Twitter

You may

request
of

by

415-222-9958
identification

signed

by

you

together

with

copy

valid

government-issued

card

RESPONSE
broad

NO

Plaintiff

objects

to the

foregoing Request

as

it

is

overly

unduly burdensome harassing vague and/or ambiguous voluminous documents

that

as

it

requires

Plaintiff

to

produce

are

unrelated

to

the

allegations

of

the

Complaint

as

Plaintiff

uses

this

medium

daily

pursuant

to

her professional

duties

234664-1

Moreover

the

Request

fails

to define

in

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

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by

the

Plaintiff

Twitter will

then send

you

confirmation

to the

email address they have

for

you on

file

which

will

authorize Twitter to release

to

you

the

requested

information

REQUEST
former professional professional Major

NO
athlete

All

documents and

communications

with

any

current

or

from 2000
but
is

to the present

For the purposes

current the

of this question

athlete includes Baseball National

the

not limited
Football

to any League League

or former

player
Basketball

in

League
the

National

National
the

Association

Hockey
minor

League

Major

Soccer any i.e

Arena

Football of the

League
such

the

PGA
or

Tour
any

the other

ATP World Tour

NASCAR
league

minor league

affiliate

leagues

professional

AAA

baseball

and

American Hockey

League
Plaintiff

RESPONSE NO
broad

objects

to the

foregoing Request

as

it

is

overly

unduly burdensome harassing vague and/or ambiguous

voluminous

as

it

requires

Plaintiff

to

produce

documents

that

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the

Plaintiff

objects

to the extent

this

Request

seeks

disclosure

of

information which

is

protected

by

the

First

Amendment
Code

of

the

United

State

Constitution

and

the

Maryland

Shield

Law

See

Md

Ann

Courts

Judicial

Proc
extent

9-112 Tofani

State 297

Md

165 465 A.2d 413

1983

Plaintiff

objects

to

the

this

Request

seeks

documents

or

information already

in the

custody

or

234664-1

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by and

the Plaintiff

REQUEST
former player

NO 10
present

All

documents
coaching

communications

with

any

current

or

member

of the

staff or

management

in Major

League Baseball

from 2000

to the

RESPONSE NO 10

Plaintiff

objects

to the

foregoing Request

as

it is

overly

broad unduly burdensome harassing vague and/or ambiguous

to

as

it

requires

Plaintiff

produce

voluminous

documents

that

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the Plaintiff

objects

to the

extent

this

Request

seeks

disclosure

of

information which

is

protected

by

the

First

Amendment
Code

of

the

United

State

Constitution

and

the

Maryland

Shield

Law

See

Md

Ann

Courts

Judicial

Proc

9412

Tofani

State 297

Md

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
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by and

the Plaintiff

REQUEST
former player
baseball

NO 11

Ail

documents
coaching

communications

with

any

current

or

member

of the

staff or

management

in the

New

York Yankees

organization

from 2000

to the present

RESPONSE NO 11

Plaintiff

objects

to the foregoing

Request

as

it

is

overly

broad unduly burdensome harassing vague and/or ambiguous

to

as

it

requires

Plaintiff

produce

voluminous

documents

that

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the

Plaintiff

objects

to the extent

this

Request

234664-1

seeks disclosure

of

information which

is

protected

by

the

First

Amendment

of

the

United

State

Constitution

and

the

Maryland

Shield

Law

Md

Code

Ann

Courts

Judicial

Proc
extent

9-112 Tofani

State 297

Md

165 465 A.2d 413

1983

Plaintiff

objects

to

the

this

Request

seeks

documents

or

information already in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by
the

the

Defendants

more

conveniently

less

expensively

and with

burden than by and

Plaintiff

REQUEST
former
baseball

NO 12

All

documents
coaching
to the

communications
or

with
in the

any

current

or

player

member

of the

staff

management

New

York Mets

organization

from 2000

present

RESPONSE NO 12

Plaintiff

objects

to the foregoing

Request

as

it

is

overly

broad unduly burdensome harassing vague and/or ambiguous

to

as

it

requires

Plaintiff

produce

voluminous

documents

that

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the

Plaintiff

objects

to the

extent

this

Request

seeks disclosure

of

information which

is

protected

by

the

First

Amendment

of

the

United

State

Constitution

and

the

Maryland
297

Shield

Law

See

Md

Code

Ann

Courts

Judicial

Proc
extent

9-112 Tofani

State_

Md

165 465 A.2d 413

1983

Plaintiff

objects

to

the

this

Request

seeks

documents

or

information already in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by and

or

the

Plaintiff

REQUEST
former
baseball

NO 13

All

documents
coaching
to the

communications

with
in the

any

current

or

player

member

of the

staff

management

Baltimore Orioles

organization

from 2000

present

234664-1

RESPONSE

NO

13

Plaintiff

objects

to

this

Request

as

it

is

overly

broad

unduly burdensome
voluminous

harassing

vague

and/or ambiguous

as

it

requires

Plaintiff

to

produce

documents

that

are unrelated

to the

allegations

of the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery

of

admissible

evidence

Further

the

Plaintiff

objects

to

the

extent

this

Request

seeks

disclosure

of

information which

is

protected

by the

First

Amendment

of

the

United

State

Constitution

and

the

Maryland

Shield

Law

See

Md

Code

ArirL

Courts

Judicial

Proc
extent

9-112

Tofani

State 297

Md

165 465 A.2d 413

1983

Plaintiff

objects

to

the

this

Request

seeks

documents

or information already

in the custody

or control

of

the

Defendants

or

which may be obtained

less

by

the

Defendants

more conveniently

less

expensively

and with

burden than by documents

coaching
to the

the

Plaintiff

REQUEST
former
football

NO 14

All

and
or

communications

with
in the

any

current

or

player

member

of the

staff

management

Baltimore

Ravens

organization

from 2010

present

RESPONSE
broad

NO

14

Plaintiff

objects

to the foregoing

Request

as

it

is

overly

unduly burdensome harassing vague and/or ambiguous voluminous documents

unrelated

as

it

requires

Plaintiff

to

produce

that

are

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the

Plaintiff

objects

to the

extent

this

Request

seeks disclosure

of

information which

is

protected

by

the

First

Amendment
Code

of

the

United

State

Constitution

and

the

Maryland
297

Shield

Law

See

Md

Ann

Courts

Judicial

Proc

9-112 Tofani

Statefl

Md

165 465 A.2d 413

1983

Plaintiff

objects

to

the extent

this

Request

seeks

documents

or

information already in the

custody

or

10
234664-1

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by

the

Plaintiff

REQUEST
relate to

NO 15

All

documents and communications

which

refer

reflect

or

your resume audition tape

demo

reel

or the

like

from 2000

to the present

RESPONSE NO 15
unduly burdensome
harassing

Plaintiff

objects

to

this

Request

as

it

is

overly

broad

vague and/or ambiguous

information
that neither

Further

Plaintiff

objects

to

the

extent

the

Request

seeks

is

relevant

to

the

pending

litigation

nor

likely

to lead

to

the

discovery of admissible

evidence

Without waiving

these

objections

and

to the

extent

responsive

documents

exist

they will be produced

REQUEST
relate to your

NO 16

All

documents and communications

which

refer

reflect

or

employment with CBS Radio Baltimore and/or

105.7

The Fan

RESPONSE NO 16

Plaintiff

objects

to the foregoing

Request

as

it

is

overly

broad unduly burdensome harassing vague and/or ambiguous documents

that are unrelated of the

as

it

requires

Plaintiff

to

produce

to the

allegations

Complaint Moreover which

such

Plaintiff

objects

to

this

Request

as

it

does

not specify

time

period

for

documents

and

communications

are

sought
of

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery

admissible

evidence

Further

the

Request

seeks

disclosure

of

information

which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in

anticipation

of

litigation

Plaintiff

objects

to

the

extent

this

Request

seeks

documents

or

information

already in the

custody

or control

of the

Defendants

or

which may be obtained

with
less

by the

Defendants

more conveniently

less

expensively

and

burden

than

by

the

Plaintiff

Without waiving

these

objections

to

the

extent

that

non-privileged

and

non

11
234664-1

protected

documents

exist

and

are

in the

possession

of

the

Plaintiff

they will

be

produced

REQUEST
relate to your the

NO 17

All

documents and communications

the

which

refer

reflect

or

employment with

Mid-Atlantic Sports Network

from January

2010 to

present

RESPONSE
broad

NO 17

Plaintiff

objects

to the

foregoing Request

as

it

is

overly

unduly burdensome harassing vague and/or ambiguous documents

that

as

it

requires

Plaintiff

to

produce

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not reasonably

calculated

to

lead to the 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

these

objections

to the

extent

that non-privileged

and non-protected documents

be produced

exist

and

are in the

possession of the Plaintiff

they will

REQUEST
relate to your

NO 18 NO

All

documents and communications

which

refer

reflect

or

employment with

MLB

Advanced

Media from 2006

to the present

RESPONSE

18

Plaintiff

objects

to the

foregoing Request

as

it

is

overly

broad unduly burdensome harassing vague and/or ambiguous

to

as

it

requires

Plaintiff

produce

documents

that

are

unrelated

to

the

allegations

of

the

Complaint The
of admissible

Request

as

worded

is

not reasonably

calculated

to lead

to the

discovery

12
234664

evidence

Further

the Request

seeks

disclosure

of information

which

is

protected by the

attorney-client

privilege

the

attorney

work-product

doctrine

and/

or

created

in

anticipation

of litigation

Plaintiff

objects

to the

extent

this

Request

seeks

documents

or

information

already

in

the

custody

or

control

of

the

Defendants

or

which

may

be

obtained

by

the

Defendants

more conveniently

less

expensively

and with

less

burden

than by the Plaintiff Without waiving

these

objections

to the

extent

that

non-privileged

and non-protected documents

be produced

exist

and

are in the

possession

of the

Plaintiff

they will

REQUEST
relate to your

NO 19

All

documents and communications

which

refer

reflect

or

employment with

XM Satellite
Plaintiff

Radio Holdings

from 2008

to the present

RESPONSE

NO

19

objects

to

the foregoing

Request

as

it

is

overly

broad unduly burdensome harassing vague and/or ambiguous documents

that

as

it

requires

Plaintiff

to

produce

are

unrelated

to

the

allegations

of

the

Complaint

The

Request
evidence

as

worded

is

not reasonably

calculated

to lead

to the

discovery of admissible

Further

the Request

seeks

disclosure

of information

which

is

protected by the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in

anticipation

of litigation

Plaintiff

objects

to the

extent

this

Request

seeks

documents

or

information

already

in

the

custody

or

control

of

the

Defendants

or

which

may

be

obtained

by

the

Defendants

more conveniently

less

expensively

and with

less

burden

than by the Plaintiff Without waiving

these

objections

to

the

extent

that

non-privileged

and non-protected
be produced

documents

exist

and

are in the

possession

of the

Plaintiff

they will

13
234664-1

REQUEST
relate to your

NO 20

All

documents and communications

the

which
Sports

refer

reflect

or

New

employment York Yankees Baseball

with

Yankees

Entertainment

and

Network

or the

organization

from 2003

to the present

RESPONSE NO 20
broad

Plaintiff

objects

to the

foregoing Request

as

it

is

overly

unduly burdensome harassing vague and/or ambiguous documents

that

as

it

requires

Plaintiff

to

produce

are

unrelated

to

the

allegations

of

the

Complaint The
admissible

Request

as

worded

is

not reasonably

calculated

to lead

to

the

discovery

of

evidence

Further

the

Request

seeks

disclosure

of information

which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in

anticipation

of litigation

Plaintiff

objects

to the

extent

this

Request

seeks

documents

or

information

already

in

the

custody

or

control

of

the

Defendants

or

which

may

be

obtained

by

the

Defendants

more conveniently

less

expensively

and with

less

burden

than

by

the

Plaintiff Without

waiving

these

objections

to the

extent

that

non-privileged

and non-protected
be produced

documents

exist

and

are in the

possession

of the

Plaintiff

they will

REQUEST
relate to insinuate that

NO 21
are

All

documents and communications

statements competent
that for state

which

refer

reflect

or

your contention

that

WNST made
qualified or

implicate or otherwise your

position as

you

not

journalist

Complaint

X20
Plaintiff

RESPONSE NO 21
disclosure of

objects

to

the

foregoing

Request

as

it

seeks

information

which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in anticipation

of litigation

Plaintiff

objects

to the

extent

this

Request

seeks documents or information already

in the

custody

or

control

of

the

Defendants

or

which

may

be

obtained

by

the

Defendants

more

14
234664-1

conveniently

less

expensively

and with

less

burden than by

the

Plaintiff

considering

most

of the

communications

relating to

this

Request

were published by

the

Defendants

on

the

WNST

website

and/or made on

their

own

radio

shows

Without

waiving

these

objections

to the extent

that

non-privileged

and non-protected documents

exist

and

are

in the

possession of the

Plaintiff

they will be produced

Plaintiff

also refers Defendant

to Exhibit

attached

to Plaintiffs

Answers

to Interrogatories

REQUEST
reflect

NO 22
to

AU
contention

documents
that

and

communications statements
sexual

which

refer or

or

relate

your
that

WNST made
in personal

implications
inappropriate

otherwise insinuated
relationships

you

are

involved

and/or

with multiple professional

athletes Complaint

20
Request
as
it

RESPONSE
disclosure of

NO 22

Plaintiff

objects

to the

foregoing

seeks

information

which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in anticipation

of

litigation

Plaintiff

objects

to the extent

this

Request

seeks

documents

or information already in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by

the

Plaintiff

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

to Exhibit

attached

to Plaintiffs

Answers

to

lnterrogatories

REQUEST
relate to

NO 23

All

documents and communications

which
against

refer

reflect

or e.g

your

contention

that

WNST

threatened

violence

you

see

Complaint

T24d

15
234664-1

RESPONSE NO 23
disclosure of

Plaintiff

objects

to

the

foregoing

Request

as

it

seeks

information

which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in anticipation

of

litigation

Plaintiff

objects

to

the

extent

this

Request

seeks documents or information already in the custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden

than

by

the

Plaintiff

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

to Exhibit

attached

to Plaintiffs

Answers

to Interrogatories

REQUEST
relate to

NO 24
answer

All

documents and communications

of the

which
any
of

refer the

reflect

or

your
in

contention your

any
to

Defendants

knew
that

that the

statements

identified subjectively the

Interrogatory as to the truth

No
of falsity as to
its

statement statement
falsity

was

false

entertained

doubts

of the

or published

statement

with

high degree

of awareness

probable

RESPONSE NO 24
disclosure of

Plaintiff

objects

to

the

foregoing

Request

as

it

seeks

information which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in anticipation

of

litigation

Plaintiff

objects

to the

extent

this

Request

seeks documents or information already

in

the custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and

with

burden

than

by

the

Plaintiff

Further

Plaintiff

objects

to

this

Request

to

the

extent

it

calls

for evidence

and documents

that

will be used

solely for purposes

of

impeachment
16

Without

waiving

these

objections

to

234664-1

the

extent

that

non-privileged

and

non-protected

documents

exist

and

are

in

the

possession

of the

Plaintiff

they will be produced

REQUEST
relate to

NO 25
or

All

documents and communications

articles
letters

which

refer

reflect

or

newspaper
tapes videos

magazine

bulletins editor or

flyers

computer form

printouts
or printed

broadcast material
that

transcripts

to the to the

similar broadcast in any

published

from January
or published

2003 by anyone

present

regarding

you

were broadcast

other

than Defendants

RESPONSE NO 25

Plaintiff

objects

to the foregoing

Request

as

it

is

overly

broad unduly burdensome harassing vague and/or

to

ambiguous

as

it

requires

Plaintiff

produce

voluminous

documents

that

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery

of admissible evidence

Further

the

Request

seeks

disclosure

of

information

which

is

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 and

less

expensively

and

with

less

burden than by

the

Plaintiff

Without waiving

subject

to these

objections

see

Exhibit

attached

to Plaintiffs

Answers

to Interrogatories

REQUEST

NO 26

All

documents and communications

of the

which

refer

reflect

or
ill

relate to your contention that any

Defendants
in

acted

with

common law

malice

will or spite in making any of the statements

your answer

to Interrogatory

No
as
it is

RESPONSE NO 26
broad

Plaintiff

objects

to the foregoing

Request

overly

unduly burdensome harassing vague and/or ambiguous voluminous documents

that

as

it

requires

Plaintiff

to

produce

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

17
234664-Ti

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

with
less

by

the

Defendants

more conveniently

less

expensively

and

burden than by
statements

the

Plaintiff

Without waiving

these

objections

and

subject

thereto

the

and

written

materials

summarized

in

Exhibit

speak

for

themselves

and

to

the

extent

other

non-privileged

non-protected

documents

exists

they will be produced

REQUEST
relate to

NO 27

All

documents and communications you

have
suffered in your

which
to

refer

reflect

or as

your

contention

that

proximate result of the statements

identified

damage answer to

your

reputation

Interrogatory

No
as
it is

RESPONSE
broad
unduly

NO 27

Plaintiff

objects

to

the

foregoing Request

overly

burdensome

vague
is

and/or

ambiguous

Further

the

Request

seeks

disclosure

of

information

which

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in anticipation

of

litigation

Plaintiff

objects

to the

extent

this

Request

seeks

documents

or information already

in the custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and

with

burden than

by

the

Plaintiff

Without

waiving

these

objections

and

subject

thereto

to

the

extent

non-privilege

and

non

protected documents exist they will be produced

REQUEST

NO 28

All

documents and communications

suffered

which

refer

reflect

or

relate to your contention

that

you have

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
See Response

RESPONSE NO 28 REQUEST
reflect

to Request

No
which
refer

NO 29
the

All

documents
that

and

communications conduct

or

relate

to your

contention

any

Defendants
in society

was

extreme and

outrageous

and beyond

bounds

of decency

60
as
it is

RESPONSE NO 29

Plaintiff

objects

to the

foregoing Request

overly

broad unduly burdensome vague and/or ambiguous

lead

The Request

as

worded

is

not

reasonably

calculated

to

to

the

discovery

of

admissible

evidence

Further

the

Request

seeks

disclosure

of

information which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in

anticipation

of

litigation

Plaintiff

objects

to the

extent

this

Request

seeks

documents

or

information

already in the

custody

or

control

of the

Defendants

or

which may be obtained

less

by

the

Defendants

more conveniently

less

expensively

and with

burden

than

by

the

Plaintiff

Without waiving

these

objections

and

subject

thereto

the

statements

and

written materials

summarized

in Exhibit

speak

for themselves

and

to the

extent

other

non-privileged

non-protected documents exists they will be produced

REQUEST

NO 30

All

documents and communications

Plaintiff

which

refer

reflect

or

relate to your contention

that

has

suffered

and

will continue

to suffer

severe

and extreme emotional distress 1J62

RESPONSE
REQUEST
relate to health

NO 30
All

See Responses

to Requests

No

and 29

NO 31
or

documents and communications

medical
practitioner that

which

refer

reflect

or

any doctor

physician mental

psychologist

psychiatrist

mental

counselor

health

practitioner in

you have

ever visited

concerning

your mental

and/or

emotional health

your

lifetime

19
234664-1

RESPONSE NO 31

Plaintiff

objects

to the foregoing Request

as

it

is

overly

broad unduly burdensome harassing vague and/or documents

unrelated

ambiguous

as

it

requires

Plaintiff

to

produce

that

are

to

the

allegations

of

the

Complaint.

The

Request

as

worded
the

is

not reasonably

calculated

to lead

to the

discovery of admissible

evidence

Further

Request

seeks

disclosure

of information

which

is

protected by the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in

anticipation

of litigation

Without

waiving

these

objections

and subject

thereto

Plaintiff

refers Defendant

to Responses

to Requests

No

and 29

REQUEST
relate to

NO 32
public

All

documents and communications

but not limited
that relate to letters to

which

refer

reflect

or

communications
of the

including
sent to

and correspondence
in

from

members Maryland

you

your

employment

Baltimore

since

2009

RESPONSE
broad

NO 32

Plaintiff

objects

to the

foregoing Request

as

it

is

overly

unduly burdensome voluminous

harassing vague

and/or

ambiguous

as

it

requires

Plaintiff

to

produce

documents

that

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the

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

20
234664-1

REQUEST
place

NO 33

Produce
to

for inspection
all

and copying

at

mutually

agreeable

and time complete

access

Facebook.com

accounts within your control

RESPONSE NO 33
unduly burdensome and
is

Plaintiff

objects

to this

Request

as

it

is

overly

broad

not

reasonably

calculated

to

lead

to

the

discovery

of

admissible evidence

Further

the Request

seeks

information which

is

not relevant

to the

allegations

in the

Complaint

REQUEST
place

NO 34

Produce

for inspection access

and copying
to
all

at

mutually

agreeable within

and lime complete

and uninhibited

Twitter.com

accounts

your control

RESPONSE NO 34

See Response

to Request

No

Brian

Goodman
Moylan PESSIN KATZ P.A

Alexandra

HODES
Towson

901 Dulaney Valley

Road

Suite 400

Maryland 21204-2600

410 410

938-8800 825-2493

Fax

Attorneys for Plaintiff

21
234664-I

JENNIFER ROYLE
Plaintiff

IN

THE

CIRCUIT

COURT

FOR NASTY
1570

SPORTS

LLC et

BALTIMORE
CASE

CITY

Defendants

NO 24-C-11001571

NOTICE OF SERVICE OF DISCOVERY HEREBY

Reponses
to

CERTIFY

that

on

this

2nd day

of

June 2011

copy

of the

foregoing

First

Request

For

Discovery

of

Documents on

Electronically

Stored

In.formation

and

Property

directed

to

Jennifer

Royle

behalf

of

WNST SPORTS
to

MEDIA

one of Defendants

was mailed

via

first-class

mail postage prepaid

Charles

Tobin Esquire

Drew
Holland

Shenkman
Knight

Esquire

LLP Avenue
20006

2099 Pennsylvania
Suite

N.W

100

Washington

D.C

202

955-3000 for Defendants

Attorney

Brian

Goodman

Kimya Behbahani HODES PESSIN

901

KATZ P.A
Suite 400

Dulaney Valley Road

Towson Maryland

21204-2600

410 410

938-8800 825-2493

Fax

Attorneys for Plaintiff

JENNIFER ROYLE

IN

THE

Plaintiff

CIRCUIT

COURT

FOR NASTY
1570

SPORTS LLC

et

BALTIMORE
CASE

CITY

Defendants

NO 24-C-11001571

ROYLES SUPPLEMENTAL RESPONSES TO WNST SPORTS MEDIA LLCS FIRST REQUEST FOR DISCOVERY OF DOCUMENTS ELECTRONICALLY STORED INFORMATION AND PROPERTY
PLAINTIFF JENNIFER
Jennifer

Royle

Plaintiff

by

her

attorneys

Brian

Goodman
to

and

Alexandra

Moylan

of

Hodes

Pessin

Katz P.A responds

Stored Information

First

Request

For

Discovery

of

Documents

Electronically

and Property propounded and

states as follows

to her

by

WNST

Sports

Media

LLC

one of the Defendants

Supplemental Responses

REQUEST
reflect

NO.1
Defendants

All

documents

and

communications

which

refer

or relate to the

RESPONSE NO.1
broad unduly burdensome voluminous

Plaintiff

objects

to the foregoing

Request

as

it

is

overly

harassing

vague and/or ambiguous

that

as

it

requires

Plaintiff

to

produce

documents

are

unrelated

to

the

allegations

of

the

Complaint Moreover
period for which such

Plaintiff

objects

to

this

Request

as

it

does

not

specify

time

documents and communications

calculated to lead to the

are

sought The Request

admissible

as

worded

is

not reasonably

discovery

of

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

SUPPLEMENTAL RESPONSE NO.1

hereto

See

Supplemental

Documents

attached

REQUEST NO.2
Defendant

All

documents and communications

between

you and

any

RESPONSE

NO

Plaintiff

objects

to

this

Request

as

overly

broad

unduly

burdensome vague and/or ambiguous documents and communications

as

it

fails

to define

time period for which all

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
less

be

obtained

by

the

Defendants

more conveniently

less

expensively and with

burden than

the

Plaintiff

Without waiving documents

these

objections

to the

extent

non-privileged

and non-protected responsive

exist

they will be

produced

SUPPLEMENTAL RESPONSE NO.2

this

To

the

extent

the

information sought

in

Request

is

in the

Plaintiffs

immediate

possession

custody

or

control

it

has been

produced

in

the

Supplement
with

Documents

attached

Plaintiff

reserves

the

right

to

supplement

this

Response

additional

responsive

documents

254497.1

REQUEST NO.3
anyone concerning
the

All

documents

and

communications

between

you

and

subject

matter of

this

lawsuit

RESPONSE

NO

Plaintiff

objects

to

the

foregoing

Request

as

it

is

overly

broad unduly burdensome voluminous

harassing

vague and/or ambiguous

that

as

it

requires

Plaintiff

to

produce

documents

are

unrelated

to

the

allegations

of

the

Complaint Moreover which such

Plaintiff

objects

to

this

Request

as

it

does

not specify

time

period

for

documents and communications

calculated lead to the

are

sought The Request

as

worded
Further

is

not reasonably

to

discovery of admissible evidence

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

with
less

by

the

Defendants

more conveniently

less

expensively

and

burden

than

by

the

Plaintiff

SUPPLEMENTAL RESPONSE NO.3

documents sought
in this

To

the

extent

non-privileges responsive

Request

are

in the

immediate

possession

custody

or control

of

the

Plaintiff

they

have

been

produced

herewith

Plaintiff

reserves

the

right

to

supplement

this

Response

with

additional

responsive

documents

REQUEST
relate to

NO.4

All

documents and communications

which

refer

reflect

or

your

contention

that

you have

been

defamed

as

alleged

in

Count

of your

Complaint

254497.1

RESPONSE NO.4
seeks disclosure

Plaintiff

objects

to

the

foregoing

Request

to

the

extent

it

of information

which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in anticipation

of

litigati

on

Plaintiff

objects

to the

extent

this

Request

seeks

documents

or information already

in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than

by

the

Plaintiff

or

by

this

Request

Without

waiving

these

objections

to

the

extent

other

non-privileged

non-

protected responsive

documents

exist

the

will be

produced

Plaintiff

refers Defendant

to Exhibit

attached

to Plaintiffs

Answers

to Interrogatories

SUPPLEMENTAL RESPONSE NO.4

documents
are in the

To

the

extent

non-privileged

responsive

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 which
reflect

REQUEST
relate to

NO

All

documents and communications

refer

or

your

contention

that

you have

been

portrayed

in

false

light as

alleged

in

Count

III

of your

Complaint
See Response

RESPONSE NO.5

to Request

No.4
the

SUPPLEMENTAL RESPONSE NO.5

documents
are in the

To

extent

non-privileged

responsive

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

254497.1

REQUEST NO.6
relate to your

All

documents and communicatiQns

which

refer

reflect

or

Answer

to Interrogatory

No.4 No.4
To

RESPONSE NO.6

See Response

SUPPLEMENTAL RESPONSE NO.6

documents
axe in the

the

extent

non-privileged

responsive

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 which
reflect

REQUEST NO.8
relate to

All

documents and communications

refer

or

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

RESPONSE

NO

Plaintiff

objects

to

the

foregoing

Request

as

it

is

overly

broad unduly burdensome voluminous

harassing

vague and/or ambiguous

unrelated

as

it

requires

Plaintiff

to

produce

documents

that

are

to

the

allegations

of

the

Complaint Moreover

as

Plaintiff

uses

this

medium

daily

pursuant

to

her professional

duties

the

Request

fails

to define

in

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

control

of

the

Defendants

or

which

may

be

obtained

by

the

Defendants

more

254497.1

conveniently

less

expensively

and with

less

burden than by

the

Plaintiff

Twitter will

then send

you

confirmation

to the

email address they have

for

you on

file

which

will

authorize Twitter

to release

to

you

the

requested

information

SUPPLEMENTAL RESPONSE NO.8

instructions in the

Plaintiff

has

complied

with

the

Request

and

will

supplement

this

Response

as

the

documents

become

available

REQUEST NO.9
former
professional athlete

All

documents

and

communications

with

any

current

or

from 2000

to the

present

For the

purposes

of this

question

professional

athlete includes

but

is

not limited

to any

current

or

former

player

in

Major

League

Baseball

the

National

Football

League

the

National

Basketball

Association

the

National

Hockey

League

Major

League

Soccer

the

Arena

Football

League
such

the

PGA Tour
or

the

ATP World
minor

Tour

NASCAR
league

any

minor league

affiliate

of

leagues

any

other

professional

i.e

AAA

baseball

and

the

American Hockey

League

RESPONSE

NO

Plaintiff

objects

to

the

foregoing

Request

as

it

is

overly

broad unduly burdensome voluminous

harassing vague

and/or ambiguous
unrelated

as

it

requires

Plaintiff

to

produce

documents

that

are

tO

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the

Plaintiff

objects

to the

extent

this

Request

seeks disclosure

of

information which

is

protected

by

the

First

Amendment
Code

of

the

United

State

Constitution and the Maryland

Shield

Law

See

Md

Ann

Courts

Judicial

Proc

9-112

Tofani

State 297

Md

165 465 A.2d 413

1983

Plaintiff

objects

2544971

to

the

extent

this

Request

seeks

documents

or

information already in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by To

the Plaintiff

SUPPLEMENTAL RESPONSE NO.9

documents
exist

the

extent

non-privileged

responsive

and

are in the

immediate

possession

custody

or control

of the

Plaintiff

they have been produced herewith

REQUEST
former player

NO 10

All

documents

and

communications

with

any

current

or

member

of the

coaching

staff

or

management

in Major

League

Baseball

from 2000

to the

present

RESPONSE

NO 10

Plaintiff

objects

to the foregoing

Request

as

it

is

overly

broad unduly burdensome voluminous

harassing vague

and/or ambiguous
unrelated

as

it

requires

Plaintiff

to

produce

documents

that

are

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the

Plaintiff

objects

to the

extent

this

Request

seeks disclosure

of

information which

is

protected

by

the

First

Amendment
Code

of

the

United

State

Constitution and the Maryland

Shield

Law

Md

Ann

Courts

Judicial

Proc
extent

9-112 Tofani

State 297

Md

165 465 A.2d 413

1983

Plaintiff

objects

to

the

this

Request

seeks

documents

or

information already in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by
the

the

Defendants

more

conveniently

less

expensively

and with

burden than by

Plaintiff

254497.1

SUPPLEMENTAL RESPONSE
documents
exist

NO 10

To

the

extent

non-privileged

responsive

and

are

fri

the

immediate

possession

custody

or control

of the Plaintiff

they have been produced herewith

REQUEST NO.11
former player

All

documents

and

communications

with

any

current

or

member

of the

coaching

staff or

management

in the

New

York Yankees

baseball

organization

from 2000

to the

present

RESPONSE
broad

NO 11

Plaintiff

objects

to the

foregoing Request

as

it

is

overly

unduly burdensome voluminous

harassing

vague and/or ambiguous

that

as

it

requires

Plaintiff

to

produce

documents

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the

Plaintiff

objects

to the

extent

this

Request

seeks disclosure

of

irtformation

which

is

protected

by

the

First

Amendment

of

the

United

State

Constitution and the Maryland

Shield

Law

See

Md

Code

Ann

Courts

Judicial

Proc
extent

9-112

Tofani

Staj

297

Md

165 465 A.2d 413

1983

Plaintiff

objects

to the

this

Request

seeks documents or information already in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by To

the

Plaintiff

SUPPLEMENTAL RESPONSE
responsive

NO 11
immediate

the

extent

non-privileged

documents

exist

and

are in the

possession

custody

or control

of

the

Plaintiff

they have been produced herewith

254497.1

REQUEST
former player

NO 12

All

documents

and

communications

with

any

current

or

member

of the

coaching

staff

or

management

in the

New

York Mets

baseball

organization

from 2000

to the

present

RESPONSE

NO 12

Plaintiff

objects

to the

foregoing Request

as

it is

overly

broad unduly burdensome

harassing

vague and/or ambiguous

that

as

it

requires

Plaintiff

to

produce

voluminous documents

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

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

Md

Code

Ann

Courts

Judicial

Proc
extent

9-112 Tofani

State 297

Md

165 465 A.2d 413

1983

Plaintiff

objects

to

the

this

Request

seeks documents

or

information already in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by To

the Plaintiff

SUPPLEMENTAL RESPONSE
responsive

NO 12
immediate

the

extent

non-privileged

documents

exist

and

are in the

possession

custody

or control

of

the

Plaintiff

they have been produced herewith

REQUEST
former player

NO 13

All

documents

and

communications

with

any

current

or

member

of the

coaching

staff

or

management

in the

Baltimore Orioles

baseball

organization

from 2000

to the

present

RESPONSE

NO 13
harassing

Plaintiff

objects

to this

Request

as

it

is

overly

broad

unduly burdensome

vague

and/or ambiguous

as

it

requires

Plaintiff

to

254497.1

produce voluminous documents The

that

are unrelated

to the

allegations

of the

Complaint

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery

of

admissible

evidence

Further

the

Plaintiff

objects

to

the

extent

this

Request

seeks

disclosure

of information

which

is

protected

by

the

First

Amendment

of the

United

State

Constitution

and

the

Maryland

Shield

Law See Md

Code

Ann Courts
Plaintiff

Judicial

Proc
extent

9-112

Tofani

StateS 297

Md

165 465 A.2d 413

1983

objects

to the

this

Request

seeks

documents

or information already in the

custody

or control

of

the Defendants

or

which may be obtained burden than by

by

the

Defendants

more conveniently

less

expensively

and with

less

the

Plaintiff

SUPPLEMENTAL RESPONSE
responsive

NO 13
immediate

To

the

extent

non-privileged

documents

exist

and

are in the

possession

custody

or control

of

the

Plaintiff

they have been produced herewith

REQUEST
former player

NO 14

All

documents

and

communications

with

any

current

or

member

of the

coaching

staff

or

management

in the

Baltimore Ravens

football

organization

from 2010

to the present

RESPONSE
broad

NO 14

Plaintiff

objects

to the

foregoing Request

as

it

is

overly

unduly burdensome voluminous

harassing

vague and/or ambiguous

that

as

it

requires

Plaintiff

to

produce

documents

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

discovery of admissible evidence

Further

the

Plaintiff

objects

to the

extent

this

Request

seeks

disclosure

of

information which

is

protected

by

the

First

Amendment
Code

of

the

United

State

Constitution and the

Maryland

Shield

Law

See

Md

Ann

Courts

10
254497.1

Judicial

Proc
extent

9-112

Tofani

State1

297

Md

165 465 A.2d 413

1983

Plaintiff

objects

to

the

this

Request

seeks

documents

or

information already in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

arid with

burden than by To

the

Plaintiff

SUPPLEMENTAL RESPONSE
documents
are in the

NO 14

the

extent

non-privileged

responsive

immediate

possession

custody

or

control

of the

Plaintiff

they

have produced

here in The

letter

was produced with

Plaintiffs

Original

Responses

to

Request

for Production

of

Documents

REQUEST

NO 21

All

documents and communications

which

refer

reflect

or

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
Plaintiff

RESPONSE
disclosure of

NO 21

objects

to

the

foregoing

Request

as

it

seeks

information

which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in anticipation

of

litigation

Plaintiff

objects

to the

extent

this

Request

seeks

documents

or information already in the custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by

the

Plaintiff

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

11
254497.1

in the

possession

of the

Plaintiff

they will be produced

Plaintiff

also refers Defendant

to Exhibit

attached

to Plaintiffs

Answers

to

Interrogatories

SUPPEMENTAL RESPONSE
documents
are in the

NO 21

To

the

extent

non-privileged

responsive

immediate

possession

custody

or

control

of

the

Plaintiff

they

have been produced herewith

Plaintiff

reserves

the

right to supplement

this

Response

as discovery in the

instant

matter

is

ongoing which
reflect

REQUEST
relate to

NO 22

All

documents and communications

refer

or

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
Request
as
it

RESPONSE
disclosure of

NO 22

Plaintiff

objects

to

the

foregoing

seeks

information

which

is

protected

by

the

attorney-client

privilege

the

attorney

work-product

doctrine

and/or

created

in anticipation

of

litigation

Plaintiff

objects

to the

extent

this

Request

seeks

documents

or information already in the custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by

the

Plaintiff

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

to Exhibit

attached

to Plaintiffs

Answers

to Interrogatories

12
254497.1

SUPPLEMENTAL RESPONSE
documents
are in the

NO 22

To

the

extent

non-privileged

responsive

immediate possession

custody

or

control

of

the

Plaintiff

they

have

been produced herewith

Plaintiff

reserves

the

right to

supplement

this

Response

as discovery in the

instant

matter

is

ongoing which

REQUEST
relate to

NO 23

All

documents and communications

refer

reflect

or

your

contention

that

WNST

threatened

violence

against

you

see

e.g

Complaint

T24d

RESPONSE
disclosure of

NO 23
which

Plaintiff

objects

to

the

foregoing

Request

as

it

seeks

information

is

protected

by

the

attorner-client

privilege

the

attorney

work-product

doctrine

and/or

created

in

anticipation

of litigation

Plaintiff

objects

to the

extent

this

Request

seeks

documents

or information already in the

custody

or

control

of

the

Defendants

or

which

may
less

be

obtained

by

the

Defendants

more

conveniently

less

expensively

and with

burden than by

the

Plaintiff

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

to Exhibit

attached

to Plaintiffs

Answers

to Interrogatories

SUPPLEMENTAL RESPONSE
documents
are in the

NO 23

To

the

extent

non-privileged

responsive

immediate

possession

custody

or

control

of

the

Plaintiff

they

have

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 documents
arid communications

REQUEST
relate to

NO 26

All

which

refer

reflect

or

that your contention 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

RESPONSE

NO 26

Plaintiff

objects

to

the

foregoing Request

as

it

is

overly

broad unduly burdensome voluminous

harassing

vague and/or ambiguous

that

as

it

requires

Plaintiff

to

produce

documents

are

unrelated

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

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

with
less

by

the

Defendants

more conveniently

less

expensively

and

burden than

by

the

Plaintiff

Without

waiving

these

objections

and

subject

thereto

the

statements

and

written

materials

summarized

in

Exhibit

speak

for

themselves

and

to

the

extent

other

non-privileged

non-protected

documents

exists

they will be produced

SUPPLEMENTAL RESPONSE
responsive

NO 26

To

the

extent

non-privileged

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

REQUEST
relate to

NO 32

All

documents and communications

which

refer

reflect

or

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

RESPONSE

NO 32

Plaintiff

objects

to the foregoing

Request

as

it

is

overly

broad unduly burdensome voluminous

harassing

vague and/or ambiguous

unrelated

as

it

requbes

Plaintiff

to

produce

documents

that

are

to

the

allegations

of

the

Complaint

The

Request

as

worded

is

not

reasonably

calculated

to

lead

to

the

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

SUPPLEMENTAL RESPONSE
documents
axe in the

NO 32

To

the

extent

non-privileged

responsive

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 and copying

REQUEST
place

NO 33

Produce

for inspection

at

mutually

agreeable

and time complete

access

to all

Facebook.com

accounts within your control

RESPONSE

NO 33
and
is

Plaintiff

objects

to

this

Request

as

it

is

overly

broad

unduly burdensome

not

reasonably

calculated

to

lead

to

the

discovery

of

15
254497.1

admissible evidence

Further

the

Request

seeks information which

is

not relevant

to the

allegations

in the

Complaint

Plaintiff

reserves

the

right to

supplement

as responsive

documents become

available

SUPPLEMENTAL RESPONSE
documents
are in the

NO 33

To

the

extent

non-privileged

responsive

immediate

possession

custody

or

control

of the

Plaintiff

they

have been produced herewith

REQUEST
place

NO 34

Produce

for inspection

and copying

at

mutually

agreeable

and time complete

and uninhibited

access

to

all

Twitter.com

accounts

within

your control

RESPONSE

NO 34

See Response

to Request

No.8
extent

SUPPLEMENTAL RESPONSE
documents
are in the

NO 34

To

the

non-privileged

responsive

immediate

possession

custody

or

control

of the

Plaintiff

they

have

been produced

herewith

Plaintiff

has

complied

with

Defendants

Request

and

will

supplement

this

Response

as the

responsive

documents become

available

ftQLYJPPL
Brian

Goodman
Moylan PESSIN KATZ P.A

Alexandra

HODES

901 Dulaney Valley

Road

Suite 400

Towson Maryland

21204-2600

410 410

938-8800 825-2493

Fax

Attorneys for Plaintiff

16
254497.1

JENNIFER ROYLE

IN

THE

Plaintiff

CIRCUIT

COURT

FOR NASTY
1570

SPORTS LLC

et

BALTIMORE
CASE

CITY

Defendants

NO 24-C-11001571

NOTICE OF SERVICE OF DISCOVERY HEREBY CERTIFY

Supplemental Reponses
to that

on

this

day

of July

2011

copy

of the

foregoing

First

Request

For Discovery

of

Documents

Electronically

Stored

Information

and

Property

directed

to

Jennifer

Royle

on

behalf

of

WNST

SPORTS MEDIA
to

one of Defendants

was mailed

via

first-class

mail postage prepaid

Charles

Tobin Esquire Shenlcman

Knight Esquire

Drew
Holland

LLP Avenue
20006

2099 Pennsylvania
Suite

NW

100

Washington

D.C

202

955-3000

Attorney for Defendants

Crcein-cin/
Brian

Goodman
PESSIN

Kirnya Belibahani

HODES

KATZ
Road

PA
Suite

901 Dulaney Valley

400

Towson Maryland

21204-2600

410 410

938-8800 825-2493

Fax

Attorneys for Plaintiff

EXHIBIT
Listing of Jennifer available

12

Royles Friends

from her Personal

Facebook Page

Jennifer

Royle

Jennifer

Royle

Friends

Add

Friend

Fraraeosuoesee

LJ

FjJ

Info

ft

Friends

Friends

901
Craig Minervini

Kimberly

Synnott

Ken

Weinmen

Jeremy Conn

Catherine

Toner

Mary Koenig

Milenesi

Scott

Garceeu

Chris

Tiliman

Melissa Chusid Skidmore

Hope

Anita

Marks

Report/Block

This

Person

Create

an

Ad

lee

In

30

Presate
Link any

American

https//www.fscebook.com//jennlferroyleskfriendsvfrlends

1104434

AM

Jennifer

Royle

Aaron

Wilson Add Frlenj

Express emong
Glee the the

Cerd
first

end be
to see

3D
only

Concert
in

Movie
Click

thsetere
link

here

end

nowl

Adam

Dillon

Adam Gerstenhaber
WFAN

RAdd

Adam

Harlor Add
Friendj

Adam

Jacobs

LAdd

FrieJ

Adam Orlando
Add

Ftd

Adam

Rubin Add
Friend

Adam Scotch

Add
Aditi

Friend

Kinkhabwala

Add_rri

Agnes

Roache

dFrlend

Aishlinn
Loyle

Eileen

sidy

High

Schoul

unrwcan

Cd

Agenj

Alan Zirmor

Addnd
Alanna

LI
Albert

Adriend

Antonucci Add
Friend

Albino Riganello Add

FrieJ

kN

Alex Lanzetta
Major

League

Seseba

Alex

Ripley

Add

Friend

Alfred

McKeever
Friend

https//www.fecebook.com/

/jenniferroyleskfriendsvfriends

104434

AM

Jennifer

Royle

Alfred

Aceves

dFrien1

Alice
oyola

Drayfahl Mayand

Ad
Brown

Fdendj

Alicia
Major

Mullin eajue
Basebat

dFrIend

Alison

Powers Add
Friend

Alison

Schuermann
Add
Friend

Allen

Lamb

Allison AHoy

Bacon

Marsh
Promotions

Marketnq

Add Friend

Allison

Weitzman
Add_Frienjj

Amalie
Northwestern

Benjamin

Amanda

Best Add
Friend

Amanda

Zinobile

Easter Add_Frien

Amy

Carpenter

Amy

Figueredo

Garland fljdd_Friendj

Amy

Nathan

dienj
Zalneraitis

Amy

Add

Friend

Andrew
St Johns

Crusco
UMass

Amherst

Add_Fr3

Andrew
.Spnrtsher

Fegyveresi
New
York

Add

Friend

Andrew

Goldberg

%Zrieni

hftps//www.facebook.com//jennifer.rOyIeskfriendsVfriefldS7/26/2011

104434

AM

Jennifer

Royle

Andrew
Case

Ibrahim
Jules
lopkins

Western

Add
Friendj

Andrew

Marchand Add_Fid

Andrew
BC

Mclaughlin Add

Fiij

Andrew

Oshman

Andrew
NYU

Scheer Add
Friend

Andrew

Shelton

II
Andrew
Stetka
Harford

EiAdd

Friendi

LI

CBS

Radio

CC

Add

Friendj

Andy Snakovsky
Add
Friend

Angel

Valentina

Burce Add Friend

Angela

Porcello

Add

Friend

Anita

Marks Add
Friend

1A

Ann Marie

Donaldson

Ediend
Anthony
Ohio

Castrovince

RAdd

Anthony
1311

DiComo
Add
Friend

Anthony

Causi Add
Friendi

Anthony

Taffuri

Arian

Gerstel

Burtman
Ad riend

Ashley
Majni

Brilliant Baseba

Lnour

Lf3.AddF

https//www.facebook.com/I/jennifer.roylesk$riendsVfriendS

104434

AM

Jennifer

Royle

Ashley

Scharge

rrien1
Audrey

DeWys

McLaughlin

Frid
FrIend

Barbara

Cady

Barry

Bloom

dFrien
Basche
SportsNet

Warner
New
york

Add

Frj

Becky

BaItzelI

Giesing
Friend

Becky

Weiss

Graham

riend
Ben Baisden

dd
r.rv

Friend

Ben

Goessling
ty

Ilnivur

iidd Ffni

Ben

Grubbs

FrienJ
Ben
-un

Masur
to

Benjamin

Uam

Gilmore Add

Friej

Bernadette

Ela

Maragnano

Beth

Morissette

Osha fliidd_Friej

Beth

Royle Add
Friend

Bethany

Anderson

Rosinha
len

Betsy

Brown

Bernbaum

Betsy

Mel

Fanchiang Add
Friend

https//www.facebook.com/l/jennifer.roYIeskfriendsVfriendS

104434

AMI

Jennifer

Royle

Betsy

Wall

dnd

______

Bill

Cook

Bill

Gluvna
Green

Bowling

Bill

Ladson

Fend
dFriend

Bill

Meth

Bill

Rosenzweig

Friend
Bill

Stetka
Orioles

Baltimore

Billy

OBrien

dd

Friend

Blakely Cain H.1AddFflnd

Blayke
Indiana

Scheer
Yes

Network

riend

Bob

Eyre

n1
dd
Friend

______

Bob

Flaynie

Bob

l-lerzog

dFriend

Bobby

Aguilera

fl

Bobby

Goldwater

Bobby Santucci
Friend

Brad
GB

Needleman
Ellis

Richard

dd
N5

Friend

ii

Brad
Aleska

Stearns
Anch
Concordio

Add

Friend

https//wwwfacebook.com//jenflifer.rOYleSkfriefldsWfrieflds

104434

AMI

Jennifer

Royle

Brady
XM

Gardiner
Rado
Holdings Maryland

Sateiita

Friend

Brandon

Fairbanks Add Frienj

Brandon

Tierney

Frlej

Brenda

Sansone Add

FII

Brendan

Li
Brendon

Cawley

RdFrIen
Ayanbadejo

lAdd

Frj

Brent

Harris

r.r
Add
Friend

Brent 14

Heroux Add
Friend

-J

Brent XM
Sicoite

Gambill
Rado
Holdirga

cwis

XM

Sntellte

Padk

Aen1

Bret

Devich

dd

Friend

Brett
Dirkinsor

Hollander

idiienIj

Brian

Bray Add
Friend

Brian

Gerald
.1.3

Add

Friend

Brian

Goodman

Brian

Heyman
Add
Friend

Brian

Lavery

Li
Brian

rien
drlenJ

Lewis

Bridget

Fialo

iAddFiiend

https//www.facebook.com//ieflnlfer.rOYleSkfriendsV4riefldS

104434

AM

Jennifer

Royie

Bridget
the Star

Wentworth
Ledger

Quinn

dd
iidd

Friend

Britney

Caruso
Friend

Brittany TheStreet.com

Umar

riend
Add

Broc Jackson
Friend

rnn
Bruce

Cunningham
Add

FrII

Bryan

lioch

Aend
Bryan
CBS Rado

Levy
Dear
nar.rrel

Con

rrurricatiom

ddend
Add Friend

Bryan

McCarthy

C.

Nitkowski
ti

Add

Friend

Cameron

White

c1

Addnd

______

Carlos Medeiros
ti

Add

Fri

Carly
SportLNet

Lindsay New York

Add

Friend

Carol

Perry Harner Add

Friend

Carolyn Nangle

CaIdwell

dinenj
Carolyn Pyne Bohnenberger Add
Frienil

rn

Carolynne

Kish

TiMeni
Carrie

Bonanno

dFrlenj
Carrie

Sheldon-Hicks Add Friend

https//www.faceboOkCOrfl/t/jenflifer.rOyieSkfriefldsVfriends

104434

AM

Jennifer

Royte

Caryn

Pace
rti

Li
Casey
Major

Add

Friend

Stern
Basebat

League

dFrIend

Casey

Willett

Add

FFIJ

Catherine Toner

AddiJ
Cathy Danner-Connole

iFrienF

Catie

Webster

RTAjend

Celes

Lee Ybarra Add

Friendj

Chad

Steele

Add

FrienjJ

Chad

Terry Add

Chantre

Randolph

Charles

Dowd

RdTrien1

Charley Steiner

RAdiend
Rice Reale Add
Friendi

Chelsea

St
Chris

McKinley

Fr
Add
Friend

Chris

Montpetit

Chris

Phillips

1AddFrien1

Chris

Pollucci

Add

Friend

Chris

Red

tAdd

Friend

https/fwww.facebook.com//jennifer.royieskfriendsVfriends

104434

AM

Jennifer

Royte

Chris

Rossomando

Frlend
Chris

Russo

dFend
Chris Yes

Shearn

Notwoik

Friend

Chris

Tillman

jjAdd

Frlej

Chris

Tyler

Merluzzo

Chris UPeno

Wilder

Frj
Wragge

Chris

Christa

Robinson Add
Friend

Christian

Roberts Add
Friendl

Christina The
Corcoran

Abad
Group

______

Christina

Crespo Add
Friend

Christine

Palomba

rienJ
Christine

Strand

Cook

AddFnendJ

Christopher
Major

Begley

Leaquo

Basebah

ddFren

Christopher

Cady

1Aiend

Christopher

LJrciuoli

Ad1rienj

Chuck

Dickemann

Addfnj

Chuck

Wilson Add Friend

https//www.facebookcom//jennifer.rOYIeSkfriefldsV4riefldS

104434

AM

Jennifer

Royle

Cindy
Major

League

Anzel Baseo

Add

Fn

Cindy

Jackson

1111
Cj

tt

Add

Friendj

Papa

Clara

Malafarina Add
Friend

Claudia

Porcello

Campbell

dnd
Add Friefj

Colleen

Ferrick

Minon

Colleen Folan
Iron

Mosley Add Frien7

Mountan

Connie
Rutgers

Schwab

flAddFneJ

Corey

Sansone

.4
Craig

tAddd

Cimini

rienJ
Craig

Germain

dFriend

Craig

Heist

Add

Friendi

Craig

Minervini

Add

Friendi

Crystal

Moroney
Add
Friend

ta

Curt Ferg
Stevensus University

dd
Add

Friend

Damien
Majo

Spellman
Baseba Friendj

League

Damon

Santostefano Add
Friend

Damon

Yaffe Add Friend

https//www.facebook.com//jennifer.royleskfriendsVfriends

104434

AM

Jennifer

Royle

______

Dan Duquette

Rdd

Friend

Dan
Major

Gentile League Basebat

nd
Friend

Dan Gerstein
Harvard

Dan Kolko
DeNware

Add

Friend

Dan Martin

Adend
Dan L.a__I
Pratt

ddend

Dan Rams

dFriend
Dan Sarro
R-wbok
interraticrrs

Addjfd

Dana

Iloiles

Add

Friend

_j
Dana Kaplan
Add_Frienj

Dana Schoenfeld
Add

Fid

Dana Zweig

Becker Add
Friend

Dani Modelevsky

Toole Add
Friendi

Daniel

Guernsey Add Frienj

Yes Network

Daniel

Kruchkow
Add
Frtendj

Daniel

Lombardo

enj
Walsh

Danielle

Roberts

El

Iiprornise

Danielle CorneD

Visco Add
Friend

https//www.facebook.com/I/jenniferroyleskfriendsVfrieflds

104434

AMJ

Jennifer

Royle

Danny Turco

Dante

Carnevale Add

Dara

DeCando

dFriend

Dara

Glick

Rosenberg
Frlendj

Dara

Zilin

Evans

Aend

Daren

Gray

FrieJ

Dave

Burgess Add
Friend

Dave

Racaniello

L_
Add Add

Friend _J

Dave

Sims

FrieJ

David

Aifreds

Add_Frieni

David

Blecman

Add

Friend

David

Ginsburg Add

Frifl

David

Goff Add

Frien

David

Goyea
Add

Fd
Friendj

David

Henri
.j

Add

David

Horn

dFrien1
David Katz

David
Major

Cohen
Baseba CoIurnbt

Laaoue

https//www.facebook.com//jennifer.royleskfriendsvfriends

104434

AM

Jennifer

Royle

David

Lennon

RAdriend

David
FSPN

Picker

.ifldFrienJ

David

Schultz

dFend
David Schuster

Friend
David
North

Smullin

Texas

RiddFdendj

David

Szen

______

David

Volpe

riend
Debbie

St John

iend
Deborah Knight Snyder Add Friend

Deborah

Stratton Add
Friend

Deidra

DeAngelis

Ruvido

Della

Dufresne

cl

Add FrienJ

Denise

Porcello

Add

Friendi

Derek

Beatty 1jAddFriendl

Derek

Hallal

Derek

Litsey

Derek

Prendergast

Addn
Add

Derrick

Hall

Frii1

https//www.facebook.com/

/jenniferroyleskfriendsvfriends

104434

AM

Jennifer

Royle

Diana
NYIJ

Parente Friend

Diane

Alvarez
Friend

Dianne

Borriello

Royle Add

Friej

Dominic

Amore
Add
Friend

Don Jamieson
Add

Donna

Porcello

%ZFrieni1

Dora

Melissa

Vargas

L_Add

Friend

Doreen

Prendergast Add
Friend

Doug Reaves
it

Add

Friend

Drew

Katz Add_Frienj

Ln

Stntord

Drew

Sarver
it

Add

Friend

Duke

Castiglione

Frie

Ed

Cohen

fl

ltIdd

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______

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IN THE CIRCUIT COURT FOR BALTIMORE CITY MARYLAND

Civil Division

JENNIFER ROYLE
Plaintiff

Case

No

24C11001571

NASTY

1570

SPORTS LLC
Defendants

et

al

PROPOSED ORDER
Upon

WNST
and
for

Sports

Media

LLCs

Motion

to

Compel

Plaintiff

to

Respond

to

Written

Discovery

an

Award

of Costs

and

Incorporated

Memorandum 2011

of

Law

and

any

opposition

thereto

it

is by this Court this

____ day
is

of

ORDERED
her supplemental

that

Plaintiffs Complaint

limited

to

the

18

allegedly

false

statements

in

response

to

Interrogatory

No

and

it

is

ORDERED
regarding her

that

within

10

days

the Plaintiff

shall

answer

Interrogatory

Nos

21

and 22

involvement

in

personal

sexual

and/or

inappropriate

relationships

with

professional

athletes and

it is

ORDERED
Document
Request

that within

10

days

the

Plaintiff

shall

produce

all

documents

responsive

to

Nos

10

11 12

13 and 14

or

alternatively

if

she

asserts

the

reporters

privilege

that

she produce

privilege

log consistent with Discovery

Guideline

5c

and

it

is

ORDERED
her

that

within

10

days

the

Plaintiff

shall

produce

for

inspection

and copying

personal Facebook
and

account

or alternatively

produce her complete

downloaded

personal

Facebook

account

it

is

ORDERED
within her responses

that

within

10 days

the

Plaintiff

shall

identify

the

unnamed

individuals

to

Interrogatory

Nos

10

and 12 and

it

is

ORDERED
has not provided
to

that

Plaintiff

is

prohibited

from introducing

into

evidence

any materials she

the Defendants

within

the

10

days provided

in

the Courts

Order and

it

is

ORDERED
costs in responding

that

the

Plaintiff

shall

pay

the

Defendants

reasonable

attorneys

fees

and

to

her discovery

deficiencies

Circuit Court Judge

Copies to

Charles

Tobin

Drew

Shenkman KNIGHT LLP

HOLLAND

2099 Pennsylvania

Ave N.W

Suite 100

Washington D.C 20006

Brian

Goodman
PESS1N

Esq

Alexandra

Moylan

Esq

HODES
901

KATZ P.A
Road
Suite 400

Dulaney Valley Maryland

Towson

21204-2600