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prtl12,2012

BYHAND & U.S. MAIL

Mr. Joseph Muto 127 Roebling Steet, Apt. 2 Brooklyn, New York 11211

NOT ['OR PUBLICATION

Re:
Dear Mr. Muto:

Joe Muto/Gawker

We represent Fox News Network LLC. On April l0,2ll2,Gawker publicly announced that it had hired you, while you were still a Fox News employee, to be a mole within Fox News for Gawker. Gawker ran a story that day conceming Fox News based on iformation that you obtained while working at Fox News. Gawker further announced that the story was merely the "inaugural column" of the "Fox Mole," and that the "Fox Mole" would be providing Gawker with regular dispatches from inside of Fox News for publication.

You have since admitted that you are Gawker's "Fox Mole." Fox News terminated your
emplonnent today.

Be advised that your admissions ae admissions of likely criminal and civil wrongdoing on both your and Gawker's part, which will be the subject of further extensive investigation. Fox News will pursue its rights and remedies in the appropriate legal forums.

You should immediately stop providing information and videos to Gawker that you unlawfully obtained while employed at Fox News, and retum them to Fox News. You should immediately stop writing columns based on information that you unlawfully obtained while employed at Fox News. You should also immediately take all necessary steps to preserve all documents and information that may be relevat to your hire and employment at Gawker
including, but not limited to, any personnel documents; your discussions, whether vrrritten or ora.l, with anyone at Gawker; any information that you provided to Gawker or written by you for

A.TLANI^'

FIRM:18417802V1

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Mr. Joseph Muto April12,2012

Page 2

possible future publication; any Fox News documents that you provided to Gawker; and any documents that you took from Fox News.

The term "documents" covers all computer files and written, recorded or graphic materials of every kind including: (a) all forms of communication, information or data recorded or conveyed through physical or electronic means, (b) all written documents, including drafts, copies of documents that are not identical duplicates of originals, handwritten notes, calendar entries, and the like, (c) all electronic data o files maintained electronically (e,g., on laptops,
PCs, PDAs or Blackberries, portable or removable drives, CDs or DVDs, and servers), including e-mail, presentations, spreadsheets, and databases, regardless of whether or not a paper version also exists, and (d) all voicemails and instant messages.

If you have

any questions, please contact me or my partner, Bany Asen.

BA:bhc

cc:

Dianne Brandi, Esq. Barry Asen, Esq.

FIRM:18417802v I