Case 2:18-cv-00763-RFB-NJK Document 5-2 Filed 04/26/18 Page 1 of 3

EXHIBIT 2
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January 22, 2017

Michael Vannah.
Vannah & Vannah
400 South Seventh Street, 4th Floor
Las Vegas, NV 89101

Via Email

Mr. Vannah:
We are in receipt of your correspondence setting forth the claims of your client, Mr. Pegg, and appreciate
your patience in receiving this response.
As an initial matter, please know that we have met Mr. Pegg on numerous occasions, and have always
found him to be competent and pleasant. We were thus surprised when his security detail failed to
maintain the safety of those at the press conference, including Mr. McGregor. We were further surprised
to learn that Mr. Pegg openly stated his intention to sue Conor McGregor in the immediate aftermath of
the event.
As I discussed with Ms. King of your office, there are publically-available videos that plainly negate your
assertion that Mr. Pegg was injured by any projectile during the referenced press conference, and a room
full of witnesses who will testify that Mr. Pegg continued his duties without so much as wincing, let alone
injury that day, and thereafter. Numerous witnesses advised that in the minutes after the press conference,
Mr. Pegg had already plotted his personal gain via this threatened lawsuit. To the extent you believe you
need any additional information to complete your investigation, let us know and we will provide it
promptly.
The videos show that Mr. McGregor was the target of the aggressors, among whom Mr. Pegg was
standing. The videos plainly show numerous projectiles being thrown at Mr. McGregor from Mr. Pegg’s
immediate vicinity—and Mr. Pegg failing to restrain those individuals. If there is fault to be found, it lies
squarely with Mr. Pegg and the other professional security, and those whom Mr. Pegg could have, and
should have, escorted out or restrained.
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Should Mr. Pegg file the meritless suit, we will not hesitate to seek all available sanctions. Nevada Rule
of Civil Procedure 11 mandates that the court “shall impose […] an appropriate sanction,” which may
include attorney's fees to the prevailing party. NRCP 11. “It is the intent of the Legislature that the court
... impose sanctions pursuant to Rule 11 of the Nevada Rules of Civil Procedure in all appropriate
situations to punish for and deter frivolous or vexatious claims and defenses because such claims and
defenses overburden limited judicial resources, hinder the timely resolution of meritorious claims and
increase the costs of engaging in business and providing professional services to the public.” Trustees v.
Developers Surety, 120 Nev. 56, 63, 184 P.3d 59, 63 (2004). We believe this to be directly relevant to
Mr. Pegg’s threatened litigation.
Please further know that if the complaint is filed, we will counter- and cross-claim against all appropriate
parties, including your client who was charged with, and failed to provide, security on behalf of the
MGM. Please further understand that we will not allow Mr. Pegg to simply dismiss the action; we will
continue to seek all sanctions and pursue all remedies available to our client, including his attorneys’ fees
and costs.
It is our firm belief that the threatened lawsuit is nothing more than a tactical device to extort money from
our client. Mr. Pegg’s failure to maintain the safety of those in attendance at the press conference was the
root cause of the ensuing exchange. That he immediately, and publically, threatened to sue, and his
demand for a remarkable 74 times his alleged damages, underscore the frivolous and abusive nature of his
actions.
Should Mr. Pegg choose to proceed with filing the lawsuit, it will only prove costly and embarrassing to
Mr. Pegg, his employer and others who were charged with securing the press conference.

Sincerely,

Jennifer Goldstein
Paradigm Sports