WHITEBOOK AND GADDIS ATTORNEYS AT LAW 3005 SHADOW MOUNTAIN CENTER '5840 S, MEMORIAL DRIVE TULSA, OKLAHOMA 7414s (CHARLES A. WHTTEBOOK. 1908-199 1MLEPHONE 9 4505 SLAYTON ® GADDIS ow ns39 (Also Admitted CA) #48 CONFIDENTIAL SETTLEMENT COMMUNICATION***##* September 25, 2015 Bryan Cave, LLP ATTN: Roger Myers 560 Mission Street 25" Floor San Francisco, CA 94105 ‘ Re: Potential Litigation: Leah Kahn dba Indi Logistics v. PandoMedia Dear Mr. Myers Per our prior conversation on September 18, 2015, my firm has been retained to represent the interests of Leah Kahn, d/b/a Indri Logistics, and her ongoing dispute with your client — PandoMedia, The dispute concerns unpaid invoices for services rendered by Ms. Kahn for the benefit of PandoMedia, Previously, on July 22, 2015, proof of said invoices and the amounts owed were presented to your client. In response to this production, on or around July 25, 2015, the parties met and conferred. During this negotiation, PandoMedia requested three invoices be reduced. Ina good faith attempt to quickly resolve this matter, Ms. Kahn agreed and reduced the three invoices accordingly. PandoMedia did not dispute the amounts owed on any remaining invoices. ‘Subsequently, on or around September 3, 2015, a second offer of settlement identifying the reduced invoices, waiver of attorney's fees, and the removal of the $7,000 bonus due to my Client was sent to PandoMedia. This reduced offer of settlement was conditioned on a ten (10) day payment period. Again, the purpose of this good faith settlement offer was to quickly resolve this dispute. The demand as presented on September 3, 2015 was for $48,193.49, In response to the September 3, 2015 offer of settlement, on September 9, 2015, your client sent a libelous email clearly designed to intimidate and harass my client. See Enclosed. ‘Asa result of your client's refusal to timely pay my client for services rightfully performed, my client revokes the prior offer of settlement and presents the following offer of settlement:1. Payment from PandoMedia in the amount of $65,000 for unpaid invoices, bonuses, and attorney's fees incurred to date, and 2. Execution of a mutually drafted Settlement & Release Agreement containing, among other provisions, release of claims for both parties, and non-disparagement and confidentiality clauses. The monetary payment as identified in item # 1 shall be due within ten (10) days of execution of the Settlement & Release Agreement. This offer expires on October 5, 2015. Upon expiration, I shall cause to be filed in the Superior Court of San Francisco County a civil action seeking all appropriate damages, At this juncture, your client is in possession of all necessary documentation evidencing the services performed by my client at the direction of PandoMedia, as well as the outstanding amounts owed to Ms. Khan. However, should you need additional documentation I am available at your convenience, Finally, given Bryan Caye’s addition to this matter, | am hopeful no further communications like the one from Mr. Carr will be permitted as they will not be tolerated by my office. Furthermore, any attempts by Mr. Carr or PandoMedia to libel or slander Ms, Kahn (as threatened) will result in further civil actions. Tlook forward to hearing from you. Respectfully, arFrom: Paul Carr Date: Wed, Sep 9, 2015 at 1:11 PM Subject: Indri Logistics To: Cc: Leah Kahn , Sarah Lacy Dear Ms Copenhaver, ‘We received your letter this moming, dated September 3, 2015. Previously we had provided you with clear evidence of dishonesty and fraud By your client, and have given you ample opportunity to acknowledge mistekes and to file legitimate invoices. You have failed to do so and instead persist in your attempt to extort Pando for ‘many tens of thousands of dollars in fraudulent/incorrect fees. ‘We have absolutely nothing to hide in this matter, and have nothing to fear from allowing a court to uncover the {ull facts regarding your client's behavior, and our dealings with her. Accordingly, this matter will be handled from here by our attomeys at Bryan Cave. You will be hearing from them shortly. Furthermore, it is now abundantly clear that you are fully complicit in your client's attempts to extort us. Accordingly we are immediately filing a complaint with the Califomia State Bar regarding your professional conduct. Please be aware that, in the interests of full transparency with our readers, it is Pando's policy to publish any and all legal threats we receive and any formal response Issued by our attomeys on our behalf. (See, for example, here: https://pando.com/2014/04/23/chatham-asset-management-just-sent-pando-this-seven-page- legal-threat -written-by-marty-mad-dog-singer! and here: https://pando.com/2014/05/13/heres-pandos-formallegal- response-to-marty-mad-dog-singers-attempt-to-shut-down-our-reporting/). Any civil complaint filed by your office will be shared with readers in accordance with this policy, along with any relevant supporting documentation. 5 Please also note, in light of our serious concems over your own conduct in this matter and to ensure that your client is fully aware of our position, | am copying her into this email. In previous correspondence you intimated that this is something that isn't permitted by law but, as I'm sure you are aware, that is absolutely not the case. ‘And now, itis with great relief that we hand you and your client over to the capable hands of our attomeys. They'll take it from here. : Sincerely, Paul Carr Editorial Director Pando tpssimal ood. com/maiiXyi= 28k 4B402deb068 views pt8cal=LeahX2OKabnBsearch= cath 4fs80724248bDRsimI=1DE072d24BLS 1