AMERICAN ARBITRATION ASSOCIATION -------------------------------------------------------- X MARCUS I.

WASHINGTON, : Claimant, -against: :

: AAA Case No. 13 160 01426 12 WILLIAM MORRIS ENDEAVOR ENTERTAINMENT, LLC, formerly known as the WILLIAM MORRIS AGENCY, INC., : JEFFREY MEADE and SARAH : WINIARSKI, Respondents. : -------------------------------------------------------- X [PROPOSED] ORDER ON PARTY SUBMISSIONS, DISCOVERY AND CONDUCT It is hereby Ordered that the parties to the above-captioned proceeding adhere to the following rules regarding written submissions, discovery and conduct during the course of this proceeding: Requirements for any written submission 1. All parties and counsel shall avoid unnecessary motion practice and shall be

required, prior to the making of any motion or submission, to submit a letter to the Arbitrator of no more than three pages in length (double-spaced) setting forth the nature of the relief sought. 2. No motion or submission shall be made, or be considered by the Arbitrator, or

need be responded to, unless the Arbitrator has approved , in advance, the filing of same. 3. All written submissions are to be double-spaced, with a short “Statement of the

Issues” section at the beginning explaining the issues the submission is discussing.


Maximum length for a submission is 10 pages (excluding exhibits), double-

spaced, unless a request is made to the Arbitrator, and the Arbitrator grants such request prior to the submission, for a longer page limit. 5. 6. No single footnote may be longer than 100 words. A party must send an arbitration-related submission or communication through

the AAA case manager, and may not send a submission or communication directly to the Arbitrator unless asked by the AAA or the Arbitrator to do so. 7. Unless the Arbitrator orders otherwise, or a party requests and is granted a longer

period, a party has 7 business days to respond to another party’s motion or submission. 8. The Arbitrator, in his discretion, may disregard a written submission that fails to

comply with the foregoing rules or issue such other order as he deems just and proper. Discovery 9. Any discovery request must first be submitted to the Arbitrator, who will rule on

the propriety of the request(s) after giving the opposing party or parties 3 business days to object or otherwise respond to the request(s). The Arbitrator may, in his discretion, approve, modify or deny any discovery request, and may impose appropriate limitations on the total number of document requests and interrogatories that a party may make. 10. All discovery requests must be made on or before November 15, 2013. A party

must be given a minimum of 15 business days to respond to any discovery request. Conduct requirements 11. A party must confine himself to discussing the claims and defenses asserted in the

case. A party may not, for instance, make threatening, defamatory or disparaging remarks about

a participant and/or employees of the American Arbitration Association; provided, however, that the criticism of another party’s factual assertions or legal arguments is permitted. 12. Each party and counsel shall respect the policy objectives of Rule 9 of the AAA

Rules for Employment Cases. A party may not breach the confidentiality of the arbitration by, among other things, discussing the case or posting case documents on the Internet; transmitting documents or information learned from the case to non-participants1; making defamatory or disparaging remarks about a participant to a non-participant; and/or publicizing the case in any other way. 13. No party or counsel shall tape any telephonic conference with counsel or the

Arbitrator without having provided advance notice of doing so.


_____________________________ ARBITRATOR DAVID L. GREGORY Date: October _, 2013

Non-participant includes all persons and entities other than parties to this proceeding; any attorney acting on behalf of any party; any employee, former employee, agent or former agent of any party; the Arbitrator; any deponent or witness; and any person retained to perform arbitration-related services for a party.

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