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The Hon. Robert P. Patterson, Jr.

United States District Court in the Southern District of New York 500 Pearl Street New York, NY 10007

February _, 2014

The Hon. Sally Quillan Yates United States Attorney for the Northern District of Georgia Richard B. Russell Federal Building 75 Spring Street, S.W. Suite 600 Atlanta, GA 30303-3309 Re: Request for investigation of possible criminal activity Dear U.S. Attorney Yates: I write to refer to your Office, for criminal investigation, Leonard Rowe of Duluth, Georgia. Mr. Rowe, who brought a lawsuit in this Court more than 15 years ago, has recently filed commercial liens in the amount of hundreds of millions of dollars against a number of the attorneys who were involved in the lawsuit. Mr. Rowe had no valid basis for filing these liens, and it appears that he may have filed the liens in order to extract payment from his targets. The lien filings, moreover, violated a Permanent Injunction Order entered by this Court against Mr. Rowe, and took place after I cautioned Mr. Rowe that he could be in serious trouble if he filed liens. Mr. Rowes course of conduct may constitute acts of criminal mail fraud, wire fraud, extortion and/or other crimes committed within the Northern District of Georgia. The events giving rise to this referral are as follows: Mr. Rowe filed a lawsuit in this Court in 1998. He and the other Plaintiffs, all involved in concert promotion, alleged that several prominent talent agencies and concert promotion companies had discriminated against them on the basis of their race and committed antitrust violations. Sonnenschein Nath & Rosenthal LLP (now a part of Dentons LLP) initially represented Mr. Rowe. One of the Defendants was The William Morris Agency, a predecessor of William Morris Endeavor Entertainment, LLC (WME), which was and still is represented by Loeb & Loeb LLP (Loeb). In 2005, I entered summary judgment for Defendants, dismissing Mr. Rowes claims. See Rowe Entmt, Inc., et al. v. William Morris Agency, Inc., et al., Case No. 98 Civ. 8272, 2005 U.S. Dist. LEXIS 75 (S.D.N.Y. Jan. 5, 2005). The United States Court of Appeals for the Second Circuit affirmed my decision, 167 F. Appx 227 (2d. Cir. 2005), and the United States Supreme Court denied a petition for certiorari, cert. denied, 549 U.S. 887.

Starting in November 2013, Mr. Rowe began contacting (by U.S. mail and email) attorneys from Loeb and Dentons (and some former Dentons attorneys) who appeared in the Rowe case, threatening to file hundreds of millions of dollars in commercial liens against them, Loeb, Dentons and WME. Mr. Rowe also communicated identical threats to Loeb and Dentons attorneys who had no involvement in his case. Some of these communications contained affidavits that were notarized in Gwinnett County, Georgia and listed an address for Mr. Rowe in Johns Creek, Georgia (although he appears to live in Duluth). In these initial communications, Mr. Rowe stated that he would file liens unless he received Full Payment or settlement (Case No. 98-cv-8272-RPP (S.D.N.Y.); Docket Number 867-1). In response to Mr. Rowes initial communications, WME moved this Court on November 22, 2013 for an Order temporarily restraining Mr. Rowe from, among other things, filing liens against WME, Loeb and Loeb attorneys, and further contacting WME, Loeb and Loeb attorneys about this long-concluded case. I granted the Temporary Restraining Order (TRO, Docket Number 865), finding that WME and its attorneys faced the risk of irreparable harm because baseless commercial liens are easy to file, difficult to expunge, and can cause unquantifiable harm to ones credit rating and reputation. On November 27, 2013, on the same basis, I entered a TRO prohibiting Mr. Rowe from filing commercial liens and taking similar actions against Dentons, its attorneys and certain former attorneys who were involved in this case (Docket Number 873). WME and Dentons also moved to permanently enjoin Mr. Rowe from continuing his threatened course of conduct. Mr. Rowe sent a letter to this Court opposing the injunction, but offered no valid basis for his threats to file, collectively, more than a billion dollars in commercial liens (Docket Number 878). Following a December 6 hearing at which Mr. Rowe did not appear, I granted WMEs and Dentons respective motions for a permanent injunction. The following month, Mr. Rowe sent (again by U.S. mail and email) Commercial Affidavits to WME, Loeb, Dentons and many of the same people he threatened in November 2013. Mr. Rowe also sent an email to Dentons Chief Executive and Chairman, stating that he would file liens if Dentons did not amicably come to the table. As with the prior round of communications, some of these communications contained affidavits that were notarized in Gwinnett County, Georgia and listed a return address for Mr. Rowe in Johns Creek, Georgia. On January 15 and January 17, respectively, WME and Dentons filed motions to hold Mr. Rowe in contempt of Court. I held a hearing on these motions on January 24, during which hearing Mr. Rowe participated by phone. Mr. Rowe offered no valid justification for mailing Commercial Affidavits to WME and numerous attorneys, in violation of the Permanent Injunction Orders prohibition against Mr. Rowes communicating about the litigation that ended years ago. Mr. Rowe and I conversed in open Court for more than an hour. I cautioned Mr. Rowe against getting himself into further trouble by carrying out his threat to file liens. Mr. Rowe offered no assurances that he would refrain from filing liens. I concluded the hearing by informing Mr. Rowe that I held him in contempt of Court for sending prohibited communications, and asked that he submit an affidavit attesting to his finances so that I could determine the appropriate monetary sanction.
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Shortly thereafter, WME and Dentons informed me that Mr. Rowe had nevertheless filed liens against several Loeb attorneys and Dentons attorneys (Docket Numbers 915 and 918). Mr. Rowe informed them of these liens by email, and said he would be filing liens in cities throughout America, and had already completed, or was in the process of completing, lienfilings in such places as Erie County, New York, DeKalb County, Georgia and Alameda County, California. There is no valid basis for the liens Mr. Rowe has filed. There is no evidence that any of the people he has threatened owes him any debt. There may be a basis to conclude that Mr. Rowe understands that no debts are owed to him, and that he is filing false liens with the intent to extract a payment from his targets so that he will stop. The lien filings, moreover, are likely to harm the credit ratings of those who are the subject of the liens. Mr. Rowe has conveyed these threats via the U.S. mail and the wires (email). There is thus reason to investigate Mr. Rowe for possibly having committed the crimes of mail and wire fraud (18 U.S.C. 1341 and 1343), as well as extortion (18 U.S.C. 1875). Venue may be proper in the Northern District of Georgia because, as part of his course of conduct, Mr. Rowe has used the U.S. mail and wires to transmit documents and communications from the Northern District of Georgia into New York, and has filed commercial liens in Georgia. Thank you for your attention to this matter.

The Hon. Robert P. Patterson, Jr.