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07 APR 2014 01:32 pm R. POSTELL LISE RAPAPORT and SEAMUS P. McCAFFERY, h/w : : : Plaintiffs, : : vs.

: : INTERTRUST GCN, LP; : INTERSTATE GENERAL MEDIA, LLC : t/a INTERSTATE GENERAL MEDIA, also : t/a THE PHILADELPHIA INQUIRER, : also t/a PHILADELPHIA DAILY NEWS, : also t/a PHILLY.COM, also t/a : PHILLYDAILYNEWS.COM; WILLIAM : MARIMOW; CRAIG McCOY; SIGNE : WILKINSON; and MICHAEL DAYS : : Defendants. : COURT OF COMMON PLEAS PHILADELPHIA COUNTY

FEBRUARY TERM, 2014 No. 3044

JURY TRIAL DEMANDED

ORDER AND NOW, on this _____ day of April, 2014, upon consideration of Defendant Intertrust GCN, LPs Motion for Recusal of the Entire Bench of the First Judicial District, and Plaintiffs opposition thereto, it is hereby ORDERED that Defendants Motion is DENIED. IT IS

FURTHER ORDERED that the companion Motion for Recusal filed by Defendants William Marimow, Craig McCoy, Signe Wilkinson and Michael Days, to which Plaintiffs Response is due on April 21, 2014, is DENIED AS MOOT.

BY THE COURT:

__________________________________ J.

Case ID: 140203044 Control No.: 14032101

THE BEASLEY FIRM, LLC BY: Dion G. Rassias, Esquire Identification No.: 49724 1125 Walnut Street Philadelphia, PA 19107-4997 (215) 592-1000 (215) 592-8360 (Facsimile) LISE RAPAPORT and SEAMUS P. McCAFFERY, h/w : : : Plaintiffs, : : vs. : : INTERTRUST GCN, LP; : INTERSTATE GENERAL MEDIA, LLC : t/a INTERSTATE GENERAL MEDIA, also : t/a THE PHILADELPHIA INQUIRER, : also t/a PHILADELPHIA DAILY NEWS, : also t/a PHILLY.COM, also t/a : PHILLYDAILYNEWS.COM; WILLIAM : MARIMOW; CRAIG McCOY; SIGNE : WILKINSON; and MICHAEL DAYS : : Defendants. : COURT OF COMMON PLEAS PHILADELPHIA COUNTY

FEBRUARY TERM, 2014 No. 3044

JURY TRIAL DEMANDED

PLAINTIFFS RESPONSE TO DEFENDANT INTERTRUST GCN, LPS MOTION FOR RECUSAL OF THE ENTIRE BENCH OF THE FIRST JUDICIAL DISTRICT AND REQUEST FOR APPOINTMENT OF AN OUT-OF-COUNTY JUDGE PURSUANT TO PENNSYLVANIA RULE OF JUDICIAL ADMINISTRATION 701(C) I. INTRODUCTION Counsel for Defendant Intertrust GCN, LP (hereinafter Intertrust) has become recusal happy; this is now the third time counsel has filed a motion to recuse an entire bench/appellate panel from performing their sworn judicial responsibilities. As will be set forth more fully below, Defendant Intertrusts knee-jerk motion fails both procedurally and substantively. Procedurally, there has been no showing whatsoever that any judges in the First Judicial District, much less all the judges, are incapable of impartially performing their judicial responsibilities

Case ID: 140203044 Control No.: 14032101

under these circumstances.

Substantively, the light patchwork of non-compelling reasons

offered by Defendant Intertrust, taken individually or in the aggregate, simply does not rise to the level where recusal of the entire bench would be remotely appropriate. At best, the Motion assumes, incorrectly and very disturbingly, that all of the judges in the First Judicial District would be biased, prejudiced or compromised by virtue of the facts of this case, and therefore out-of-county help is needed. There are no actual facts, either direct or implied, that support such a wild and wide-sweeping condemnation of the integrity of all of the judges in the First Judicial District. Defendant Intertrusts Motion is as weak on the law as it is transparent in its effort to have the fate of this critically important case, which is predicated upon defining the boundaries of First Amendment misconduct, assigned to an out-of-county judge. With that, and in opposition to the instant Motion, the Plaintiffs state and aver as follows: 1. The averments contained in paragraph 1 are denied as stated. However, it is

admitted that this case was started by a Writ of Summons filed on February 27, 2014. As to the remaining averments involving Interstate General Media, those percentages are unknown to the Plaintiffs at this time and are therefore deemed denied and strict proof thereof is demanded at the time of trial. By way of further response, there should be no curiosity about any of the Defendants who have been named in this lawsuit. 2. The averments contained in paragraph 2 are denied as beyond the scope of

knowledge of the answering Plaintiffs and, furthermore, as completely irrelevant. Defendant Intertrust was served by personal service pursuant to the Pennsylvania Rules of Civil Procedure on March 12, 2014, and any other statement as to how or why Intertrust learned anything is irrelevant and immaterial.

Case ID: 140203044 Control No.: 14032101

3.

The averments contained in paragraph 3 are denied as stated. However, to the

extent that another filing by the Plaintiffs refers to the Motion for Pre-Complaint Discovery, it is admitted that in response to that Motion, the individual Defendants did, in fact, produce the identification of the 11 cases that they had been wrongfully withholding and keeping from the Plaintiffs for more than one year. By way of further answer, the two articles attached to the Motion as Exhibit A are an incomplete portrayal of the publications at issue and which form the basis of this lawsuit. Therefore, and despite the fact that a true and correct copy of the Complaint was served on Defendant Intertrust on March 25, 2014, the articles attached by Defendant Intertrust are deceptively incomplete, and this Honorable Court is respectfully directed to the compendium of publications attached to the Complaint, all of which publications are attached hereto as Exhibits 1 through 5. 4. The averments contained in paragraph 4 are denied as stated. By way of further

answer, there were phone calls between defense counsel and the staff of the Honorable Nina Wright Padilla on Wednesday, March 19, 2014, not one of which calls ever included Plaintiffs counsel. Plaintiffs learned of the phone calls only when their attorney appeared in Judge Wright Padillas courtroom for the previously scheduled oral argument on the then-pending Motion for Pre-Complaint Discovery. By way of even further answer, at the time of this filing, the Plaintiffs have requested the deposition of Defendants publisher Robert J. Hall (see Exhibit 6) and Defendant Signe Wilkinson (see Exhibit 7), and have also demanded a copy of Robert J. Halls March 4, 2013 email to Defendant Marimow, which email was clearly identified in court to the Honorable Patricia McInerney on November 15, 2013 by Defendants counsel, Sprague & Sprague (see Exhibit 8), and is referenced in the Plaintiffs Complaint at 23, and in footnote 1 on page 7.

Case ID: 140203044 Control No.: 14032101

5.

The averments contained in paragraph 5 are denied as stated to the extent that the

Defendants request for an out-of-county judge is again procedurally insufficient as it is not based upon an appropriate record, and is also substantively devoid of any compelling basis or fact. 1 6. The averments and characterizations set forth in paragraph 6 are denied as stated.

First, Defendant Intertrusts Motion does not set forth the distinction among the several different trial divisions of the First Judicial District. The judges assigned to the Criminal Division do not interact professionally in terms of their judicial responsibilities with the judges assigned to the Civil Division, Family Court or Orphans Court. Plaintiff McCafferys work with the muchneeded reforms in the First Judicial District was focused entirely upon the Criminal Division. The Defendants pleading deliberately confuses what is otherwise a very clear distinction among the separate court divisions within the First Judicial District. Further, Plaintiff McCaffery was never a member of the Court of Common Pleas of the First Judicial District where this case is pending. Finally, in what can only be described as a desperate and ludicrous effort to

manufacture and contrive a potential bias, the Defendants refer to the fact that 24 years ago, a Philadelphia trial judge married the Plaintiffs, at a time when both Plaintiffs were lawyers and Plaintiff McCaffery had never even run for public office, much less been elected to any bench as a jurist. 7. The averments contained in paragraph 7 are admitted in part and denied in part. It

is admitted that the Honorable Daniel D. McCaffery is a judge in the First Judicial District, having won an election and then having assumed the responsibilities of a jurist approximately
1

A similar recusal request was filed by Sprague & Sprague on November 1, 2011 in the matter of First Judicial District of Pennsylvania, et al. v. Obermeyer Rebmann Maxwell & Hippel, et al., October Term, 2011, No. 4286; another request for the recusal of a Superior Court panel was filed by Sprague & Sprague on February 26, 2014 in the case of Castellani, et al. v. The Scranton Times, L.P., et al., Supreme Court of Pennsylvania Docket No.: 21 MM 2014.

Case ID: 140203044 Control No.: 14032101

three months ago. The Honorable Daniel D. McCaffery is assigned to the Criminal Division of the First Judicial District and does not work with or decide any civil cases of any nature whatsoever. There is nothing about Judge Daniel D. McCafferys role in the Criminal Division of the First Judicial District that would create any social and moral influences and concerns for any experienced, capable civil trial judge in the First Judicial District. 8. The averments contained in paragraph 8 are denied as improper and completely

speculative, and ultimately, they do not form a proper basis for the appointment of an out-ofcounty judge. This argument once again underscores how desperate the Defendant is to try to frame some lame analysis that can make their arguments look more substantive on paper than they are. The Defendant here runs from an obvious and uncontested fact in this case: the Plaintiffs do not dispute that referral fees were paid to Plaintiff Rapaport. But this case is about the false and misleading coverage that The Philadelphia Inquirer and The Daily News gave to these referral fees, all in an effort to smear the Plaintiffs. Indeed, Plaintiff McCaffery disclosed these referral fees as required by law; if he had not done so, there would have been nothing to smear him about in the first place. To suggest that the Defendant wants to depose the lawyers and firms about the referral fees makes no sense and is a transparent effort to create issues where there are none. 9. The averments contained in paragraph 9 are denied as, at best, preposterous. To

equate the Plaintiffs Complaint with the Traffic Court situation is completely out of line. Traffic Court has been investigated by federal authorities and numerous indictments have already been handed down, and trials are scheduled to begin in two months in federal court before the Honorable Robert F. Kelly. To suggest that whatever happened in Traffic Court now being adjudicated in federal court has any bearing whatsoever on the false light coverage pending in

Case ID: 140203044 Control No.: 14032101

state court, is nothing short of a primitive and misleading diversionary tactic.

Even the most

basic review of the dockets confirms that the Traffic Court cases are listed for trial in federal court beginning on May 19, 2014, before the Honorable Robert F. Kelly (see Exhibit 9 attached hereto), and have nothing to do with the First Judicial District. Finally, it is also worth stating that even though Philadelphias Traffic Court has been investigated and scrutinized over the last two years, there is no matter there that involves Plaintiff McCaffery. 10. The averments contained in paragraph 10 are denied as stated. By way of further

answer, Plaintiff McCaffery does not have any colleagues within the First Judicial District as averred. 11. The averments contained in paragraph 11 are denied as stated. Moreover, these

averments are denied as entirely premature. As noted in the Code of Judicial Conduct, judges should preserve the integrity and independence of the judiciary, and they should conduct themselves in a manner that promotes confidence in the integrity and impartiality of the judiciary. The Defendant, in a filing that is completely contrived, has thrown a libelous blanket over the entire First Judicial District by stating plainly that none of the judges there could be impartial, or have the integrity necessary to carry out their important judicial functions in an impartial manner. This is a highly improper and highly offensive predicate from which to begin any analysis, and it is just wrong. By that same standard, because all trial judges in the

Commonwealth of Pennsylvania come under the supervision of the Pennsylvania Supreme Court, the Defendants lame and strained argument would apply to each and every jurist throughout the Commonwealth, not just jurists in the First Judicial District. Instead, this

Honorable Court should apply the proper standard which allows any individual judge to whom this case may be assigned to make his or her own determination about recusal based upon that

Case ID: 140203044 Control No.: 14032101

individual jurists own belief and understanding about whether he or she will honor their oath to support, obey and defend the Constitution of the United States and the Constitution of the Commonwealth of Pennsylvania, and whether he or she will discharge the duties of his or her judicial office with fidelity. The Defendants Motion disgracefully and insultingly concludes that every judge in the First Judicial District is unable to do that. 12. While Rule 701(C) is correctly characterized by the Defendant, its application to

the instant case is disputed for all of the reasons set forth above. 13. It is respectfully submitted that the Defendants request for an out-of-county

judge fails both procedurally and substantively. There has been no showing whatsoever that not a single judge in the entire First Judicial District could be fair and impartial; without that initial critical showing, it is improper and unfair to presume that the entire bench is so tainted. Substantively, as set forth clearly above, the Defendants reasons for the recusal of the entire bench are thin, not grounded in well-reasoned or meritorious arguments.

Respectfully submitted, THE BEASLEY FIRM, LLC By: /s/ Dion G. Rassias DION G. RASSIAS Attorney for Plaintiffs

DATED: April 7, 2014

Case ID: 140203044 Control No.: 14032101

THE BEASLEY FIRM, LLC BY: Dion G. Rassias, Esquire Identification No.: 49724 1125 Walnut Street Philadelphia, PA 19107-4997 (215) 592-1000 (215) 592-8360 (Facsimile) LISE RAPAPORT and SEAMUS P. McCAFFERY, h/w : : : Plaintiffs, : : vs. : : INTERTRUST GCN, LP; : INTERSTATE GENERAL MEDIA, LLC : t/a INTERSTATE GENERAL MEDIA, also : t/a THE PHILADELPHIA INQUIRER, : also t/a PHILADELPHIA DAILY NEWS, : also t/a PHILLY.COM, also t/a : PHILLYDAILYNEWS.COM; WILLIAM : MARIMOW; CRAIG McCOY; SIGNE : WILKINSON; and MICHAEL DAYS : : Defendants. : COURT OF COMMON PLEAS PHILADELPHIA COUNTY

FEBRUARY TERM, 2014 No. 3044

JURY TRIAL DEMANDED

PLAINTIFFS MEMORANDUM OF LAW INTRODUCTION Defendant Intertrust GCN, LPs (hereinafter Intertrust) Motion for Recusal fails both procedurally and substantively. Procedurally, there has been no showing whatsoever that any judges in the First Judicial District, much less all the judges, are incapable of impartially performing their judicial responsibilities under these circumstances. Substantively, the light patchwork of non-compelling reasons offered by Defendant Intertrust, taken individually or in the aggregate, simply does not rise to the level where recusal of the entire bench would be remotely appropriate. At best, the Motion assumes, incorrectly and very disturbingly, that all of the judges in the First Judicial District would be biased, prejudiced or compromised by virtue of

Case ID: 140203044 Control No.: 14032101

the facts of this case, and therefore out-of-county help is needed. There are no actual facts, either direct or implied, that support such a wild and wide-sweeping condemnation of the integrity of all of the judges in the First Judicial District. Defendant Intertrusts Motion is as weak on the law as it is transparent in its effort to have the fate of this critically important case, which is predicated upon defining the boundaries of First Amendment misconduct, assigned to an out-of-county judge. FACTUAL BACKGROUND Defendants are all involved with the publication of The Philadelphia Inquirer, The Philadelphia Daily News and Philly.com. These Defendants have wrongfully, deliberately and repeatedly placed the Plaintiffs in false light through several smear-piece articles and a loathsome caricature appearing in the above-referenced publications. This case was started by a Writ of Summons filed on February 27, 2014. All of the Defendants were served with the Writ of Summons by personal service pursuant to the Pennsylvania Rules of Civil Procedure on March 12, 2014. Plaintiffs Civil Action Complaint, which includes counts for false light and defamation, was filed on March 25, 2014 and served on all Defendants via electronic filing and/or hand delivery on March 26, 2014. LAW AND DISCUSSION Defendants request for an out-of-county judge is procedurally insufficient as it is not based upon an appropriate record, and is also substantively devoid of any compelling basis or fact. 1

A similar recusal request was filed by Sprague & Sprague on November 1, 2011 in the matter of First Judicial District of Pennsylvania, et al. v. Obermeyer Rebmann Maxwell & Hippel, et al., October Term, 2011, No. 4286; another request for the recusal of a Superior Court panel was filed by Sprague & Sprague on February 26, 2014 in the case of Castellani, et al. v. The Scranton Times, L.P., et al., Supreme Court of Pennsylvania Docket No.: 21 MM 2014.

Case ID: 140203044 Control No.: 14032101

Recusal is required whenever there is substantial doubt about a jurists ability to preside over a matter impartially. Dennis v. Southeastern Pennsylvania Transportation Authority, 833 A.2d 348 (Pa. Cmwlth. 2003). Canon 3(C)(1) of the Code of Judicial Conduct states that [j]udges should disqualify themselves in a proceeding in which their impartiality might reasonably be questioned[.] There is nothing in Defendants Motion other than the

unsubstantiated averments themselves that reasonably demonstrates that substantial doubt exists regarding the First Judicial Districts judges ability to remain impartial. First, Defendant Intertrusts Motion does not set forth the distinction among the several different trial divisions of the First Judicial District. The judges assigned to the Criminal Division do not interact professionally in terms of their judicial responsibilities with the judges assigned to the Civil Division, Family Court or Orphans Court. Plaintiff McCafferys work with the much-needed reforms in the First Judicial District was focused entirely upon the Criminal Division. The Defendants pleading deliberately confuses what is otherwise a very clear distinction among the separate court divisions within the First Judicial District. Further, Plaintiff McCaffery was never a member of the Court of Common Pleas of the First Judicial District where this case is pending. Furthermore, Plaintiff McCaffery does not have any

colleagues within the First Judicial District as averred. Finally, in what can only be described as a desperate and ludicrous effort to manufacture and contrive a potential bias, the Defendants refer to the fact that 24 years ago, a Philadelphia trial judge married the Plaintiffs, at a time when both Plaintiffs were lawyers and Plaintiff McCaffery had never even run for public office, much less been elected to any bench as a jurist. The Honorable Daniel D. McCaffery is assigned to the Criminal Division of the First Judicial District and does not work with or decide any civil cases of any nature whatsoever.

Case ID: 140203044 Control No.: 14032101

There is nothing about Judge Daniel D. McCafferys role in the Criminal Division of the First Judicial District that would create any social and moral influences and concerns for any experienced, capable civil trial judge in the First Judicial District. Additionally, to equate the Plaintiffs Complaint with the Traffic Court situation is completely out of line. Traffic Court has been investigated by federal authorities and numerous indictments have already been handed down, and trials are scheduled to begin in two months in federal court before the Honorable Robert F. Kelly. To suggest that whatever happened in Traffic Court now being adjudicated in federal court has any bearing whatsoever on the false light coverage pending in state court, is nothing short of a primitive and misleading diversionary tactic. Even the most basic review of the dockets confirms that the Traffic Court cases are

listed for trial in federal court beginning on May 19, 2014, before the Honorable Robert F. Kelly (see Exhibit 9 attached hereto), and have nothing to do with the First Judicial District. Finally, it is also worth stating that even though Philadelphias Traffic Court has been investigated and scrutinized over the last two years, there is no matter there that involves Plaintiff McCaffery. As noted in the Code of Judicial Conduct, judges should preserve the integrity and independence of the judiciary, and they should conduct themselves in a manner that promotes confidence in the integrity and impartiality of the judiciary. The Defendant, in a filing that is completely contrived, has thrown a libelous blanket over the entire First Judicial District by stating plainly that none of the judges there could be impartial, or have the integrity necessary to carry out their important judicial functions in an impartial manner. This is a highly improper and highly offensive predicate from which to begin any analysis, and it is just wrong. By that same standard, because all trial judges in the Commonwealth of Pennsylvania come under the supervision of the Pennsylvania Supreme Court, the Defendants lame and strained argument

Case ID: 140203044 Control No.: 14032101

would apply to each and every jurist throughout the Commonwealth, not just jurists in the First Judicial District. Instead, this Honorable Court should apply the proper standard which allows any individual judge to whom this case may be assigned to make his or her own determination about recusal based upon that individual jurists own belief and understanding about whether he or she will honor their oath to support, obey and defend the Constitution of the United States and the Constitution of the Commonwealth of Pennsylvania, and whether he or she will discharge the duties of his or her judicial office with fidelity. The Defendants Motion disgracefully and insultingly concludes that every judge in the First Judicial District is unable to do that. CONCLUSION It is respectfully submitted that the Defendants request for an out-of-county judge fails both procedurally and substantively. There has been no showing whatsoever that not a single judge in the entire First Judicial District could be fair and impartial; without that initial critical showing, it is improper and unfair to presume that the entire bench is so tainted. Substantively, as set forth clearly above, the Defendants reasons for the recusal of the entire bench are thin, not grounded in well-reasoned or meritorious arguments.

Respectfully submitted, THE BEASLEY FIRM, LLC By: /s/ Dion G. Rassias DION G. RASSIAS Attorney for Plaintiffs

DATED: April 7, 2014

Case ID: 140203044 Control No.: 14032101

VERIFICATION I, Dion G. Rassias, hereby state that I am counsel for Plaintiffs in this action, and I am authorized to make this verification on behalf of Plaintiffs. I verify that the statements made in the foregoing Response are true and correct to the best of my knowledge, information and belief. I understand that the statements are subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.

/s/ Dion G. Rassias DION G. RASSIAS Dated: April 7, 2014

Case ID: 140203044 Control No.: 14032101

CERTIFICATE OF SERVICE I, Dion G. Rassias, hereby certify that I caused a true and correct copy of the foregoing to be served via first class mail, postage prepaid, upon: Richard A. Sprague, Esquire Joseph R. Podraza, Jr., Esquire Brooke Spigler Cohen, Esquire Alan Starker, Esquire Neal R. Troum, Esquire Christopher P. Spina, Esquire Sprague & Sprague The Wellington Bldg., Suite 400 135 South 19th Street Philadelphia, PA 19103 Attorneys for Defendant Intertrust GCN, LP Amy B. Ginensky, Esquire Michael A. Schwartz, Esquire Michael E. Baughman, Esquire Raphael Cunniff, Esquire Eli Segal, Esquire Kaitlin M. Gurney, Esquire Pepper Hamilton, LLP 3000 Two Logan Square 18th and Arch Streets Philadelphia, PA 19103-2799 Attorneys for Defendants William Marimow, Craig McCoy, Signe Wilkinson and Michael Days Interstate General Media, LLC 801 Market Street, Suite 300 Philadelphia, PA 19107

THE BEASLEY FIRM, LLC BY: /s/ Dion G. Rassias DION G. RASSIAS, ESQUIRE Attorney I.D. No.: 49724 1125 Walnut Street Philadelphia, PA 19107 (215) 592-1000 (215) 592-8360 (facsimile)

DATED: April 7, 2014

Case ID: 140203044 Control No.: 14032101

EXHIBIT P-1
Case ID: 140203044 Control No.: 14032101

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INQUIRER STAF? WBTER

Over the last decade, tbe sife of Peonsylraia Supreme Court Justice Seanus P. McCafiery his chiefiudicial aide has re ceived 18 pannents as eferral fees for co'nnecting bw fims

witb clients. In te most neoent payment,


McCatreqt/s wife' lawYer Lise Rapaporq received $tezlmo her fee from a settment in-a multimilliondollar ndical ralpractice case. Court records and McCaf-

fer'/s state-mandated public nansialdisclosure forme list the 18 instances in cric his
wife received a rcferral fee. A tswyer frr e cowb, and br:s $ith te funs, say tb

ftes tre rutine and prqer But tbe high courds cbiefju* tice, Ronald D. Castillg gestioned Rapapods making referrals, as did some legal experts @ata by Tbe Inguirer. Castille said tbey aised tbe potential for "couflicts of interst and tbe appearance of im: pmpriety arisig hom adge's staff employee practicing law while receiving feir c( -pensation while employed in a judicial chamber, and especia in
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Cstilte and McCafrery have in recent months, persona and pmfesbeen bitterly at odds

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Case ID: 140203044 Control No.: 14032101

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Jry Gry do, e fosd d e w.di$add Pbflddple frq ki4 enks h l.fy & WilqeAhWb ftq Sed h H rdd Ff]s &m l@Et br srdwrH@ttu {fb eid . slff kFldt ldE'm&t@" hDd didnt tu trs

Mcc'fferl/s ger or the

1@ brc Xr@ o the l6iDg side of m 4FL t irdffilMe!"hdd. affibiF@ifcjustiq' Iam sid of Mccfery "l Abnham c' Reid! @bir of tl het hi. thint heb a fir tbe Philadclphira fe of Fc e dry t6 log: RodEhild, sid k r{d tBut ChI S. Ra Ji, a Paoli d *tdd i 92. tut lsrywo bl 2 , dd cle$ed the W for mu W' he td d bom ut lbe G Ed& he sid. fer f*. Tl 6 @ntiDued lwiw efter d it ho %d I km bot it,I eould @b haE4ddbbrueb od e pfed Dgt" Reic Ne in d eiL 'Ibe slf," Ke si oua Fid rcr sigif-

kp!@ldbakb.w. h the , Fod@ E@ llle I!4uiF fr* sqtc 4 ie 6ed si 2W on beha of a tu si tu mpl Feb. Nofhl Phihdelph @uple e a jdiq M.Cry b Fid who bd &le the sn to Sr.
i 200r after h had a Fssi Th 6t sF d@6 mitel tloryhgiAheantid.a dng. By the tire tlE boy @e hodq it sid, he'd k dsetd by hepdic enqhditis, which lert hh Mble to lk, 1! frral f*B 6 app la[y dryed, le8ly bid, oD Mccafej/s fmchl.discl irnticnt, ad epilqtic E fotu h 2m3. e F he The ms setdd fo! f/s ru & th. apFb bcrrb. lh illio. Fodemt E kepl a re o sch f3 drirg hb tlid of ur RaFp ived i ys o Pbiladehia Mu- te third of a third." licipd Cot, @diDg to his The boy's pts siged dislo fo@, iocludiry the dmet ihd spened out si y kFF s a ihe tot RFpd. The shry in ldici Cd fuily dslind to @ffint h On m offidl M reb6ite for F&n or by phone. th se bq kFp lis hl his l! Rsri8 sid the slf * r Ir working for fte fmily ws "very sef at the SupDe Co. Se gie* hs d- anEpts to @n&d heE. dss d "ChDbe of ,us Fodm,tuabdfhtewieE Mcc6ery" rsm d!s St., Phil- $id oily, .Th ly is do i* delphi& sue" *i tu fral fe. He h lhe sitq kpp @ did ot e,abote o! M ftlshe hs m DFci hlow-up pho cals o that or oih. e "b@ I have ro pikte cliets," I 66is'lene! he Hls tlrm, wblcb chaged mte that oe tFFn "bq e6dtim6, isli$edB wo'ldryriti! the ffi syth, e $lre of Eferral incme fo pndciry Ss tupped h.' Rp i 23, 2W, 2G, hblic ifoetio bout the 2009, d i lhe malprcti

ffiiE jrdi:is ard*t, Rpporf b aid $t95 E naFFt b ror*ed f the @ ajudicl aide si W. fu tht, 6he % e ai@ dittd&ryturtued i! FiEte pEdi fo B

tr96c9 Fdy. 8

ief adetje

&stopheis Hoital for Chil-

blesi.

dn

h h Moflrc, Mccfery ha i6 of s trylrysl eid e in@ o Efed EltiNhip to jdge up f*bePdMdaphatiy *t F in *e te! @e i! 08 ed . b.forc i s SuFrior Co@ tr apRb inwhiry Fc Ro the Supeid dd cle, McCfry wted k I N@@bet Fly qticizd Phitradeltie fm's in @ i6t Fidm pir Como Pt Cod Jdge A forerpoli ofr, Mc{f- 3 ed eith it i rbid. AI& L k6hko fo. failry b lq bse a Philadelphi Mu- "I fl W @ndmt ttat N nicipal Co idge in 1994. He 6m 6ed iely !d apryri- dcl* i a tht hjr wifq bcge *ig on e # SUF atelt dth spd to lhtu ma! lary4 mrkcd ha l d!fdi e inswe copey ior Cou h 2 d od th t4" kich sid. io a md.deiqjw ismuit SupE@ Co in 2008, He d kFp mried in frbsrolrfr* 6 sl'dd empoy f 1990. His wife, 61, h odsOf ihc @ fiD thd Fili io defedFdte d ftom lamd ig peral-iqjry si$. RefeUiveEiry and lw degree Fom the Uniw$ity of Pry1El fs did not phy !ole. tror rc. Tehlo als faid Judicial rues gdem rcfere d hs eife! p1ry6 on hi6 f* somshar d futh @liclG fom. He rcndy late the pcti of w by em6ffid tt oDisi{e 6li!g plo of the @fr s,Bte adedd Dods vith state For one th9, tlre rul6 *ipuMdeid . lte tht oDly hrye fre aDpi @ otd it8 irc ferrl fs. "dtuapproval" of ftshko, W with the ule quiing t8h bi6 rite hd b! a appq ftom a chiefjsde, o. law i the ic sit beforc @n plici$ 6vr tu pG hiaedwFnsshad of lw by mdrys. ftry iry h E68. sy aid mut frd obbin prcrl om the judge who sFlbtrhko doclied 6ment for fts dde vise6 thm I lkFpol @, tbt @t 1lEshlo si8ned spdi9 she solld hve ded Wie iq judg b cvil suib i Philasion pci jsw t@ h6 te dephiq b sught b kee hbhd, wlo % s her sFri. ing suc . fhe Sp@e sr. I hi5 le$et Fsias Sd CoM i4d @d lshko at makhg refrms ms ot ftlo cieil @t, 6edively d pEqici fl. otig hiE. fccaffery ws eory the ji detd XoomraeBftr5rl bshiEffi@e4@ itr f the f-ms that ived ferEls froD kFFrt lad6 of hJryhi8h@, 6ve dd ot re@ td tel+ si8led l}crhko h*JMd* phoe c.lls. Lw6 with tle @, hisjob 20ys sidheB prcvidd $re iriomaq r be d beme a jud. don b rould not te udelyiq 6* r ry how mucb .on,*.o6 * r*o]li* RaFprt had ived. 2!549421o. itwiw, Per S. Fied- ws ud @ obligadoD @ ftudr of te Fied@ itigeb bo te FfeFl f6. crucq@pjllnM.m. Schume {fm i! MoDtgomery tux ale 6id h did tut b &rrty, dd he Fold l@k hb [ Uctfry w obli8td ro lqir l dld hph the relemt 6s. Ee did F ddo* the fees, thow he sid $oMbn conldutd to ths dlcl
slmdiog

A.-rTm

Case ID: 140203044 Control No.: 14032101

EXHIBIT P-2
Case ID: 140203044 Control No.: 14032101

,. r . I

dolfo since he Stepped down Feb. 28 and became the lrst pope to rerign in 600 years.

th;;td

ietiat n cagtel c-n-

SAves

From the moment he rryas elected, Francis, 76, made clear he wuld go visit him, refusing in a way to let Benedict remain "hidden from the world" as h had
intended. Wearing a white quilted jacket

Fnncl rnd Benedlct greet on the helipad of

over his white cassock to

guard

Castel Gandolfo. brought a gft. "They told me it's the Madonna of Huriility;'he told gentleness" of his predecessor "humility and Benedict, acknowledging

Francls df

cmwd

t!nto the

against the spring chill, Benedict greeted Francis on the helipad of the Castel Gandolfo gardens as soon as the Papal helicopter landed. They embraced and clasped hands. And in a series of ges-

said. The two used a longer side o the car, thg traditional kneeler in the pows.and prayed of the place ofthe pope, while Bnedic{ side-bY-slde, the papdl *neell' tures that followed, Benedict sat on the left. llthen they en- facing the altar left vacnt. It riras a gesturc,that, 10.dys made clear tlit he conslderd .terrd the chapel inside the palazFtancis to be pope while Ilancie m to pray, Benedict tried to di- into Flsncis' papacy, is.becommade clear he considered his rect tanck to the papal lxreeler ing rnutihe: a shunning of the happings of the papacy ln favor predecessor to be very mch a in the frcrit, but Francis.refused. Ihking Benedict'3 hands and of coiegial an simple stYle revered bmther and equal..

Ilaveling from the helipad to the palazzo, Benedict gave Francis te seat on the right-hand

drawing him near, Francis.eaid, "No, we are brcthers,? Irrbadi

there
marltable

Fffiffi
I)
I

EfilitttPltr*.I

mnwnmn(qavE|ril

ffi ffi ffi ffi


rNFT'NITI

nmUll: ffi latc

tolrl lues ln 0lo.

Radnnt's
By Amand le Itters ond Mrik Scolfom
ssOCTATED PRE38

putshinnperl

- A sh0d. ow of a dlfferent kind ie hanging over hnxsutawCINCINNflT ney Phil. Authorltiee. ln sttll-frgid Ohio have issued an 1ln-

dictrhent" against the

famed groundhog, who

prodlcted an earlY sPring when he didn't see his hadon after emerging
Pennsylvania on Feb' 2.

fmm his lair in Western


Spring arrived Wednday, and temprturcs are still hovering in the 30s in

the

Brckeye

state and

much of the Northeast. While it's not the coldest spring on record, ifs e
Amerlcn Sood 5 degreee below nor-

tns cltn, rld


,rshe

W
opllonsl,
,

upto

l0l

& ftna UJ,

ffi
ttrE

mrll

tfo({h

8:30

fi, to

ftnmcOn
In
Supremc.
$earnus .

ls

4.con- theSupltme

te

Cort 1hear-

of tte 'Jutice

ffit
AEE

w)l
PLAINTIFF'S EXHIBIT

ffi.ffi
coltt&

all
ltofl

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l.f

-.-..,,-..,-.-.;|,.. :,. | :.-;

Case ID: 140203044 Control No.: 14032101

EXHIBIT P-3
Case ID: 140203044 Control No.: 14032101

TAKI A LOK!

tRtt Atffss ALt l]\lttil fil Uti lt{tB5lTt:

lN0UlRER.[0]'l

fi$;

1,'"li,:'.iJ"-riil

il mf a pfria "lluqniueu
T\resday, June 11,2013

lnquireacom

$rn.6il mu

c i rsnlr

F'BI Probes
lmuler Erduslve: Referral fees the Pa. justice's wife received are focus. Castille raises Ethics Act issue.
BvCaigR Mc{oy
INQU]RR STFII WRITT:R

The FBI is investigating Pennsylvania Supreme Coun Justce Seamus P. Mccaffery over fees his wife received for referring c[ents to personal-injrrry law frrms, Tte Inquirer has leamed.

The investigation is examining 19 referral fees paid to Lise RapaPort, the justiee's wife and his chief aide for most of the last 16 years, according to sevral people with direct knowledge of the investigation. In March, Ttre Inquirer reported that Rpaport received an $821,000

referral fee in 2012 afrer a Philadelphia law firm successfully settled a multimillion-dollar medical-malpractice caseDion G. Rassias, an ttomey for It could not be determined whether the justice and his wife, called any the rwo investigations were related. suggestion that there ws a federa Municipal Coun, the lowertier in ivestigation "complete Donsense." the Philadelphia judicial system, He also said McCaffery has not hears drunkendiving casei and midone "anything at all improper." nor criminal and civil violations. 'You're indulging rumors without lhe federal inquiry iato Municipal See loClftnT on A6 any facts, which is sad," he said.

ryon

ees
Justlc. S..mG
P,

Ilccrff.fy

In N.J.,

srxue forUS.
Senate
Of four Democrats and two

Republicans who filed, one remains the odds-on favorite.


Jonathau lbnari
and Clris lllordcs
I{qUTRER STFF WRITERS

md polls ey one- candidate akeady


has a huge head start

WSHINGTON

The eld is set,

iu the race to become New Jersefs next senator. Six candidates four Denocrats and t'o Repubcans filed Monday to ru! in the special election to replace Sea. ank R, lutenberg, a DeEocr?t who died June 3. Most of te nmes we aredy knoc,. On the Democratic side ae Newark Mayor Cory Bookef, U.S. Rep. Rush Holt, Assembly Speaker Sheila Oliver of Essex County, and U.S. Rep. Ftank Pallone. Conservatirre leader Steve lnegan and Alieta Eclg a doc. tor ftom Souerset County, are run. ning for the Republican nomination. Booker has long ben seen as thti favorite, but tn'o independent po[s released Monday show how large his initial azntage appears to be. A Quinnipiac University poll found See SEIllE on A2

Grand jury, to look clty Case ID: 140203044


r.^ll-.t No.: ..*Control r. 14032101

(: I illolrRttl

cd

investigates McCaffey over wife's refenal fees


:

ItiltitllrtTt

fM Al
Cou

ib
cd tht

Sdh llltl tt
l ^ pnel

ves

ieengwih
on

dment6

immigtid

flto

^cr

Inunigration
mts ae set
WSHNCmN - S6. roil prpd {ordry lor the ait w!6 id the fl

f ry lar. t6 wbi l i Perytia, pald to @sE a 9yq for bridg . dint b a ftn iftbo litis{d l s @tuL lrpicly, dE e&rrine hW &$ a lhid of
rrl
gal
Suct

fucd

in

Clvl[ ct
onStudy

the st

of a bqnbim n 8ghdtd3 al-Aeen neighboood

sM/e

k[
5?in norft lraq
@ bohlas .&cd eF rd ed rim Iq on M6ds blry ld 6' !plo ed ffidlDg. tbe ddllst dDtid ol vlo
ro hit

ary

S@t6o aldsalkmigl{ior bll, redying


nd&& on @tan
dar sEoaty, bck 8ca, nd h6th@ @vega

rios issu6 ltrc{ding o

InqE R$is $id lh6 sfe's wifc 6 sugh


oul by clicD6 ba@ sh is lWr vith "xl-

InoMrchtlffiThe

tD t 6ms tltd lhe rcferatr frcF Raprpon, d&dbed thc fr 6 mde d pIr

ciFls

peid to t m, Rsirq aoru wilh prls-

fe

AAGIA

*,t

wrc of

6iv.d

for la dvic md thd citizdhip to s she in 0m refcd thm llmilio! poplc hcre ile to other b*yt. gy Bol eog crydPennsti qrif J8.

al

mrk6 th tudonb lmigEtion ls sd offar cv{ft-

p vo vos $chc&drd fo114drymPFG dudffiBb otncil:y lwdate 6 n@ f@ Mrd il th m!& o

lcnt rcpuHi nd r8.


ntic

il

ib.

aidq whose referl fsfrom lw

tr6ft

Co{t Jtdka

3s

e ll.Crltr, i 2008 with vi Lse (pF, hs ahef tkaret ssue. u&!r&Eor/9tus&,

tb" uy ri

Rs6s Sd it fom oleffi of Rp?o, dting b vhs ehe i pvatc ptulice, eght her out

rFoliw

ferybsadMtlydeed
sBong rlo chargd j!ry, and

uvowenl {e

s rot

tion to tel litigntr boqt


the

te idimenbin.

by

rofcr fe6. fn the E

in M$h

tbckcF iuitfy ar. ed E4*or.go ly h the @miry, the @cd thei siehE m polie d

Th nd

fte I 6l wil @ in e fouovlrg daF dd wkq Repubicr s. b ofs d!n6 tb?


soyddftlthbill
by

ed ro

$$ 6iy

l{ccaffry

sffiry &16 s@bl.d b cotd! rb vlolq blockiDg a key ad i . e Fe ad iptltc a fm6 Su. 'dw in tb"3lehold of ri iwt
Mosul afte the bls

afy p6b d

s@t.

d a lw

t ofl

in lrq

h6

in favor. So@ uay p$; orh6 alMdysbeisdir


Ei$d

en th

thry

@t

blcd tb.t a cou Mld bc @dig it a judi-

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6& ffipb Hl ii
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e

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by Sn, Jole

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fq rb6

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Ritig h*dg s@n'

AP

quiM@bo{9" rity befd 4! @ ob6n pe@t Bide

lrry Reid (E, Nd) dis 56d d a 'ispU"ine inwiw


misd F

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d l.lodry f6 CrJford 6ii3ffidllw t. diMi$tt'oli D pGrionan fmiE hw tutqriG th fp M oar.bir.Mud ry olt dE ilrl{ By *o, ji6 cqF{ thc wy lor Xin rd lNfmlhmo qxthirmiy ta! ffi" mn trkt ri Ffib FFtty @tti. llG rul Mr rh{ q* het ro rhr &u of Ap. F ro d<ld. sder rhl lo(nt rld f Fn tl rh.rr r.rif cp ir u[ drr!d. tll pnmc Co oFnad thc
WSIINGITON

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Case ID: 140203044 Control No.: 14032101

EXHIBIT P-4
Case ID: 140203044 Control No.: 14032101

srclrE

wtKtilsoil

B $rnrrte @r Jrd$ fit'htnsq 4 gtrplols {r trerv) in hischarnbe 16...

SIGNE WILKINSON

The Philadelphia lnquirer (wilkins@phillynews.com)

PLAINTIFF'S EXHIBIT

P. 4

Case ID: 140203044 Control No.: 14032101

EXHIBIT P-5
Case ID: 140203044 Control No.: 14032101

INOUIRER EXCLUSIVE

mhhwfrrms
The Supreme Court justice and fees paid to his wife are the subject of federal subpoena^s.
By Ctnig

hrobeof

R ll{c0oy

INQUIRER STAFF WRITER

nnsylvada Justlce Seamus McCaffery. Authorities seek information from law firms on
referral fees and campaign donations. roM GRALTsH / Stan

In the ongoing federal investigation of Sate Supreme Court Justice Seamus P. Mcaffery
pmsecutons have seryed zubpoe-

nas on numerous law frms, seeking detailed infomation


PLAINTIFF'S EXHIBIT

about referal fees paid to McCaffeds wife. Vetemn defense lawyer John \il. Moris, who represents one of the eight frrms refemed cases by McCaffe4/s wife, Lise Rapaport, said his client turned over records liast montth. The federal grand jury subpoenas to law frrms.also dernanded information about campaign donations to McCaffery according to Morris and Charles E. Schmidt Jr., a top attorney n'ith
See

]trClffiT on 418

?.5

Case ID: 140203044 Control No.: 14032101

-..

t,

was
dis-

law-

Phila.

to li

f:

the in
forfri intervffi

with TIre

this

ye

In-

2oA3;,

ecomat least

oe

consideran auto,

cases by Rapa. preme federal

one of

the lawyer'

Caffery and

to identi-

over to cochair of

did dis-

over

of years
a dient

Case ID: 140203044 Control No.: 14032101

EXHIBIT 6
Case ID: 140203044 Control No.: 14032101

THE BEASLEY FIRM, LLC BY: Dion G. Rassias, Esquire Identification No.: 49724 1125 Walnut Street Philadelphia, PA 19107-4997 (215) 592-1000 (215) 592-8360 (Facsimile) LISE RAPAPORT and SEAMUS P. McCAFFERY, h/w : : : Plaintiffs, : : vs. : : INTERTRUST GCN, LP; : INTERSTATE GENERAL MEDIA, LLC : t/a INTERSTATE GENERAL MEDIA, also : t/a THE PHILADELPHIA INQUIRER, : also t/a PHILADELPHIA DAILY NEWS, : also t/a PHILLY.COM, also t/a : PHILLYDAILYNEWS.COM; WILLIAM : MARIMOW; CRAIG McCOY; SIGNE : WILKINSON; and MICHAEL DAYS : : Defendants. : COURT OF COMMON PLEAS PHILADELPHIA COUNTY

FEBRUARY TERM, 2014 No. 3044

JURY TRIAL DEMANDED

NOTICE OF DEPOSITION TO: Interstate General Media, LLC 801 Market Street, Suite 300 Philadelphia, PA 19107 PLEASE TAKE NOTICE that, pursuant to Rule 4017.1 of the Pennsylvania Rules of Civil Procedure, Plaintiffs by and through their attorneys will take the deposition of Robert J. Hall, before a person duly authorized to administer oaths at The Beasley Firm, LLC, 1125 Walnut Street, Philadelphia, PA 19107, commencing at 9:00 a.m. on April 14, 2014 and continuing from day to day until completed. The deposition will be conducted pursuant to the Rules of Civil Procedure and will be conducted before a notary public or other officer authorized to administer oaths. The deposition

Case ID: 140203044 Control No.: 14032101

will be recorded by stenographic and/or videographic means, audiotape, and real time interactive transcription (LiveNote). The deposition (including any videotape, audiotape, and/or transcript or recording of same) may be used for all purposes permissible under the Rules of Civil Procedure and the Rules of Evidence. Pursuant to the Pennsylvania Rules of Civil Procedure, the witness is instructed to bring with him any and all documents that relate to his concerns and criticisms regarding The Inquirers coverage of the Plaintiffs in general, and Defendant Marimows editorial coverage of the Plaintiffs in particular. You are invited to attend and participate.

THE BEASLEY FIRM, LLC

BY: /s/ Dion G. Rassias DION G. RASSIAS Attorneys for Plaintiffs Dated: March 27, 2014

Case ID: 140203044 Control No.: 14032101

CERTIFICATE OF SERVICE I, Dion G. Rassias, hereby certify that I caused a true and correct copy of the foregoing to be served via first class mail, postage prepaid, upon: Richard A. Sprague, Esquire Joseph R. Podraza, Jr., Esquire Brooke Spigler Cohen, Esquire Alan Starker, Esquire Neal R. Troum, Esquire Christopher P. Spina, Esquire Sprague & Sprague The Wellington Bldg., Suite 400 135 South 19th Street Philadelphia, PA 19103 Attorneys for Defendant Intertrust GCN, LP Amy B. Ginensky, Esquire Michael A. Schwartz, Esquire Michael E. Baughman, Esquire Raphael Cunniff, Esquire Eli Segal, Esquire Kaitlin M. Gurney, Esquire Pepper Hamilton, LLP 3000 Two Logan Square 18th and Arch Streets Philadelphia, PA 19103-2799 Attorneys for Defendants William Marimow, Craig McCoy, Signe Wilkinson and Michael Days Interstate General Media, LLC 801 Market Street, Suite 300 Philadelphia, PA 19107

THE BEASLEY FIRM, LLC BY: /s/ Dion G. Rassias DION G. RASSIAS, ESQUIRE Attorney I.D. No.: 49724 1125 Walnut Street Philadelphia, PA 19107 (215) 592-1000 (215) 592-8360 (facsimile)

DATED: March 27, 2014

Case ID: 140203044 Control No.: 14032101

EXHIBIT 7
Case ID: 140203044 Control No.: 14032101

THE BEASLEY FIRM, LLC BY: Dion G. Rassias, Esquire Identification No.: 49724 1125 Walnut Street Philadelphia, PA 19107-4997 (215) 592-1000 (215) 592-8360 (Facsimile) LISE RAPAPORT and SEAMUS P. McCAFFERY, h/w : : : Plaintiffs, : : vs. : : INTERTRUST GCN, LP; : INTERSTATE GENERAL MEDIA, LLC : t/a INTERSTATE GENERAL MEDIA, also : t/a THE PHILADELPHIA INQUIRER, : also t/a PHILADELPHIA DAILY NEWS, : also t/a PHILLY.COM, also t/a : PHILLYDAILYNEWS.COM; WILLIAM : MARIMOW; CRAIG McCOY; SIGNE : WILKINSON; and MICHAEL DAYS : : Defendants. : COURT OF COMMON PLEAS PHILADELPHIA COUNTY

FEBRUARY TERM, 2014 No. 3044

JURY TRIAL DEMANDED

NOTICE OF DEPOSITION TO: Amy B. Ginensky, Esquire Michael A. Schwartz, Esquire Michael E. Baughman, Esquire Raphael Cunniff, Esquire Eli Segal, Esquire Kaitlin M. Gurney, Esquire Pepper Hamilton, LLP 3000 Two Logan Square 18th and Arch Streets Philadelphia, PA 19103-2799 PLEASE TAKE NOTICE that, pursuant to Rule 4017.1 of the Pennsylvania Rules of Civil Procedure, Plaintiffs by and through their attorneys will take the deposition of Signe Wilkinson, before a person duly authorized to administer oaths at The Beasley Firm, LLC, 1125

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Walnut Street, Philadelphia, PA 19107, commencing at 9:00 a.m. on April 11, 2014 and continuing from day to day until completed. The deposition will be conducted pursuant to the Rules of Civil Procedure and will be conducted before a notary public or other officer authorized to administer oaths. The deposition will be recorded by stenographic and/or videographic means, audiotape, and real time interactive transcription (LiveNote). The deposition (including any videotape, audiotape, and/or transcript or recording of same) may be used for all purposes permissible under the Rules of Civil Procedure and the Rules of Evidence. Pursuant to the Pennsylvania Rules of Civil Procedure, the witness is instructed to bring with her any documents that she relied upon, consulted or reviewed with respect to her creation of the caricature more fully identified as Exhibit P-2 to the Plaintiffs Complaint. You are invited to attend and participate.

THE BEASLEY FIRM, LLC

BY: /s/ Dion G. Rassias DION G. RASSIAS Attorneys for Plaintiffs Dated: March 27, 2014

Case ID: 140203044 Control No.: 14032101

CERTIFICATE OF SERVICE I, Dion G. Rassias, hereby certify that I caused a true and correct copy of the foregoing to be served via first class mail, postage prepaid, upon: Richard A. Sprague, Esquire Joseph R. Podraza, Jr., Esquire Brooke Spigler Cohen, Esquire Alan Starker, Esquire Neal R. Troum, Esquire Christopher P. Spina, Esquire Sprague & Sprague The Wellington Bldg., Suite 400 135 South 19th Street Philadelphia, PA 19103 Attorneys for Defendant Intertrust GCN, LP Amy B. Ginensky, Esquire Michael A. Schwartz, Esquire Michael E. Baughman, Esquire Raphael Cunniff, Esquire Eli Segal, Esquire Kaitlin M. Gurney, Esquire Pepper Hamilton, LLP 3000 Two Logan Square 18th and Arch Streets Philadelphia, PA 19103-2799 Attorneys for Defendants William Marimow, Craig McCoy, Signe Wilkinson and Michael Days Interstate General Media, LLC 801 Market Street, Suite 300 Philadelphia, PA 19107

THE BEASLEY FIRM, LLC BY: /s/ Dion G. Rassias DION G. RASSIAS, ESQUIRE Attorney I.D. No.: 49724 1125 Walnut Street Philadelphia, PA 19107 (215) 592-1000 (215) 592-8360 (facsimile)

DATED: March 27, 2014

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EXHIBIT 8
Case ID: 140203044 Control No.: 14032101

THE BEASLEY FIRM, LLC BY: Dion G. Rassias, Esquire Identification No.: 49724 1125 Walnut Street Philadelphia, PA 19107-4997 (215) 592-1000 (215) 592-8360 (Facsimile) LISE RAPAPORT and SEAMUS P. McCAFFERY, h/w : : : Plaintiffs, : : vs. : : INTERTRUST GCN, LP; : INTERSTATE GENERAL MEDIA, LLC : t/a INTERSTATE GENERAL MEDIA, also : t/a THE PHILADELPHIA INQUIRER, : also t/a PHILADELPHIA DAILY NEWS, : also t/a PHILLY.COM, also t/a : PHILLYDAILYNEWS.COM; WILLIAM : MARIMOW; CRAIG McCOY; SIGNE : WILKINSON; and MICHAEL DAYS : : Defendants. : COURT OF COMMON PLEAS PHILADELPHIA COUNTY

FEBRUARY TERM, 2014 No. 3044

JURY TRIAL DEMANDED

PLAINTIFFS FIRST REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANT INTERTRUST GCN, LP Plaintiffs hereby propound the following First Request for Production of Documents pursuant to all applicable Pennsylvania Rules of Civil Procedure upon Defendant Intertrust GCN, LP to be answered within thirty (30) days from the date hereof, and then supplemented in accordance with all applicable rules and authorities. I. REQUEST FOR PRODUCTION OF DOCUMENTS A. Instructions 1. As used herein, "documents" shall mean all writings of any kind, including

the originals and all non-identical copies, and preliminary drafts, whether different from the

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originals by reason of any notation made on such copies or otherwise, including without limitation correspondence, memoranda, notes, transcripts of any deposition or any proceedings, diaries, statistics, letters, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, certificates, drawings, plans, interoffice and intra-office communications, telephone calls, meetings or other communications, bulletins, printed matter (including newspapers, magazines and other publications, and articles and clippings, therefrom), press releases, computer tapes and printouts, teletypes, telexes, telecopies, invoices, ledgers, worksheets (and all drafts, alterations, modifications, changes and amendments of any of the foregoing), scans, X-rays, test results, representations of any kind (including without limitation, photographs, charts, graphs, and microfiche, microfilm, videotape, or film recordings) and electronic, mechanical or electrical records or representations of any kind (including without limitation, tapes, cassettes, discs, recordings) or transcriptions thereof. 2. The term "all documents" means every document as defined herein in

Paragraph 1 above, which can be located, discovered or obtained by reasonably diligent efforts, including without limitation all documents possessed by: (a) you or your counsel; or (b) any other person or entity form whom you can obtain such request or which you have a legal right to bring into your possession by demand. 3. addressed. 4. If any request for documents is deemed to call for the production of "You" and "your" refers to the party to whom the document requests are

privileged or work product materials and such privilege or work product is asserted, provide the following information: (a) the reason for withholding the document;

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(b)

a statement of the basis for the claim of privilege, work product or

other ground for nondisclosure; and (c) a brief description of the document; including (i) (ii) (iii) the date of the document; number of pages, attachments and appendices; the names of its author, authors or preparers and an

identification by employment and title of each such person; (iv) (v) the present custodian; and the subject matter for the document, and in the case of any

document relating or referring to a meeting or conversation, identification of such meeting or conversation. 5. If any document requested herein was at one time in existence, but has been

lost, discarded or destroyed, identify in writing each document and prove the following information: (a) (b) (c) destroyed); (d) the identity of all persons authorizing or having knowledge of the the date or approximate date it was lost, discarded or destroyed; the circumstances and manner in which it was lost, or destroyed; the reason or reasons for disposing of the document (if discarded or

circumstances surrounding the disposal of the document; (e) document; and (f) the identity of all persons having knowledge of the contents thereof. the identity of the person(s) who lost, discarded or destroyed the

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6.

This document shall be deemed continuing until the time of trial, and must

be supplemented as appropriate. 7. The following documents should be produced to the offices of counsel for

Plaintiffs at The Beasley Firm, 1125 Walnut Street, Philadelphia, PA 19107.

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II.

DOCUMENT REQUEST 1. Please provide a copy of the March 4, 2013 email referenced in the Plaintiffs Complaint, along with a chain of custody affidavit for the document for the period of time it has been under the control of Sprague & Sprague.

THE BEASLEY FIRM, LLC By: /s/Dion G. Rassias DION G. RASSIAS Attorney for Plaintiffs

DATED: March 27, 2014

Case ID: 140203044 Control No.: 14032101

CERTIFICATE OF SERVICE I, Dion G. Rassias, hereby certify that I caused a true and correct copy of the foregoing to be served via first class mail, postage prepaid, upon: Richard A. Sprague, Esquire Joseph R. Podraza, Jr., Esquire Brooke Spigler Cohen, Esquire Alan Starker, Esquire Neal R. Troum, Esquire Christopher P. Spina, Esquire Sprague & Sprague The Wellington Bldg., Suite 400 135 South 19th Street Philadelphia, PA 19103 Attorneys for Defendant Intertrust GCN, LP Amy B. Ginensky, Esquire Michael A. Schwartz, Esquire Michael E. Baughman, Esquire Raphael Cunniff, Esquire Eli Segal, Esquire Kaitlin M. Gurney, Esquire Pepper Hamilton, LLP 3000 Two Logan Square 18th and Arch Streets Philadelphia, PA 19103-2799 Attorneys for Defendants William Marimow, Craig McCoy, Signe Wilkinson and Michael Days Interstate General Media, LLC 801 Market Street, Suite 300 Philadelphia, PA 19107

THE BEASLEY FIRM, LLC BY: /s/ Dion G. Rassias DION G. RASSIAS, ESQUIRE Attorney I.D. No.: 49724 1125 Walnut Street Philadelphia, PA 19107 (215) 592-1000 (215) 592-8360 (facsimile)

DATED: March 27, 2014

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EXHIBIT 9
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Case 2:13-cr-00039-RK Document 144 Filed 02/24/14 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA v. MICHAEL J. SULLIVAN (01) MICHAEL LOWRY (02) ROBERT MULGREW (03) WILLIE SINGLETARY (04) THOMASINE TYNES (05) MARK A. BRUNO (06) HENRY P. ALFANO (08) ROBERT MOY (09) ORDER AND NOW, this 24th day of February , 2014, it is hereby ORDERED that the abovecaptioned case is SPECIALLY LISTED for trial to commence on May 19, 2014 at 9:30 A.M. in Courtroom 11-B, U.S. Courthouse, 601 Market Street, Philadelphia, PA. Trial is expected to last 45 days. Counsel in this matter are attached for the duration of this trial. Trial counsel are: Henry E. Hockeimer, Jr. Esq. Terence Grugan, Esq. Jessica Moltisanti Anthony, Esq. William A. Destefano, Esq. Terri A. Pawelski, Esq. Angela Halim, Esq. William Brennan, Esq. Louis R. Busico, Esq. Vincent P. DiFabio, Esq. Tara S. Sarosiek, Esq. William M. McSwain, Esq. Carmen C. Nasuti, Esq. Paul J. Hetznecker, Esq. Denise S. Wolf, AUSA Anthony Wzorek, AUSA BY THE COURT: /s/ Robert F. Kelly
ROBERT F. KELLY, J.

: :

CRIMINAL ACTION NO. 13-039-

Case ID: 140203044 Control No.: 14032101