Stephanie Adams and Her Hack Attorney Are Scared to Answer our Discovery Questions

If you'll remember a couple of months ago we asked for your help in coming up with questions you wanted us to ask Stephanie Adams during the discovery phase of her lawsuit against us. It seems like Stephanie doesn't like some of the questions very much, her attorney is trying to get us to agree to a joint confidentiality agreement.

Martin S. Siegel, Esq.

Brown Rudnick Berlack Israels LLP

7 Times Square

New York, NY 10036

Re: Adams v. Polins

Dear Mr. Siegel:

I have just returned from Eastern Europe and am writing in response to your proposed confidentiality stipulation.

You want an agreement that either party may designate as confidential any "information that: (i) may not be obtained from other sources, (ii) could injure such party's personal, trade or business interests should be disclosed."

First, while you have set this up as a joint stipulation, I can advise you that there is no relevant information which we will seek to treat as confidential, therefore what you seek really is a favor for your side, not a joint protection.

Second, I am unclear whether the comma in the quoted passage is intended to be an "and" or and "or".

Either way, however, it seems that you want to be able to shield any information which Ms. Adams might think to be embarrassing. I am familiar with confidentiality agreements which protect trade secrets or propriety information. I have never known of an agreement which threw a blanket of secrecy over information simply because it could injury a party's personal interests.

Such an agreement would be particular strange in a situation where the party seeking to protect her privacy is suing for alleged injury to her reputation. Your client has put her reputation on the line.

However, it may be that I am reacting to your choice of words and not your real request. The answers to my seventy or so interrogatories are either due or all but due, and by now you must have your responses pretty much prepared. You know, as I do not, which specific interrogatories give you concern.

Why don't you let me know what it is that you are concerned about by reference to specific interrogatories?

And, why don't you now give me answers to those interrogatories you do not seek to keep secret.

Sincerely yours,

Neal Johnston

NJ:ig

cc. James Poling

What are you scared of Stephanie? You sued us? Answer the fucking questions already!