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to ABC. Dkt. 61-9 at M2U00003, 1:24-1:37, 5:30- 5:56, 8:14. This incident is discussed in
more detail at Dkt. 69 at 16-18.
4. On November 23, 2010, Slate filed a lawsuit against Tyra Rasmus,
Kamaus wife, again in D.C. Superior Court, by filing a claim for a Civil Protection Order that
automatically entitled him to free counsel. That lawsuit was initially settled via a no-admission
consent order, though it appears that may now be contested. Dkt. 69-24.
Slate Renews this Case Pro-Se
After he began litigating this action pro se in January 2011, Slate quickly proceeded to
lay the groundwork for using these collateral actions to attempt to discredit and intimidate
witnesses here. On February 2 and 3, 2011 Slate sent Defendants counsel several bizarre e-
mails saying that a warrant existed for Kamaus arrest, that D.C. police were demanding that no
information about this warrant be publicly disclosed, and that Defendants counsel would be
guilty of obstruction of justice if they disclosed the existence of the warrant on the public
record.
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Notably, this was shortly after the motion for civil contempt that Slate had filed against
Kamau on essentially the same issue was denied by the D.C. Superior Court on January 14,
2011. Dkt. 29-20 at 16. The day after he sent these e-mails, on February 4, 2011, Slate issued
five different subpoenas to Kamau from this case including one for his personal tax records.
He also subpoenaed two of Kamaus prior employers for personnel records dating back to the

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Dkt. 64-3 (I am talking about the criminal warrant for your witness Diop Kamau (AKA
DONALD CARLOS JACKSON) issued by Judge Abrecht of the DC Superior Court on August 28,
2010. I have advised you that a detective with the Metropolitan Police Department has expressed to me
that if any information, beyond that which is public, concerning this warrant is relayed to Mr. Kamau it
will impede law enforcement's ability to serve the warrant.); id. (2/3 at 2:46: I have specifically
requested, based on an explicit request from the Metropolitan Police Department Detective, that Kamau
not be given any information concerning the warrant until the detective is able to locate and serve him.
Do you agree not to disclose details of the warrant to your fugitive witness Kamau?).
Case 1:09-cv-01761-BAH-DAR Document 94-1 Filed 09/02/11 Page 28 of 42