EXHIBIT 13TANNEBAUM TW Weiss ATTORNEYS AT LAW June 13, 2013, Mr. Phillip J. Pattee Assistant Bar Counsel State Bar of Nevada 600 E. Charleston Blvd Las Vegas, Nevada 89104-1563 RE: Grievance #SC13-049¢ / Jason Gibson. Dear Mr. Pattee: Having been admitted pro hac vice for the purpose of representing Mr, Randazza in this matter, please find below my response on behalf of Mr. Randazza’s to the above-mentioned inquiry. INTRODUCTION Mr. Gibson seeks Bar Discipline of his former General Counsel, Mare J. Randazza. Mr. Gibson, claims that “writing this complaint is not empowering or cathartic,” and that he “has not composed or submitted this complaint out of anger or spite.” That being the case, undersigned counsel will refrain from addressing the comments about Mr. Randazza failing a part of the Nevada Bar or the specious backhanded innuendo about him possibly cheating on his wife. Perhaps though, Mr. Gibson's “disappointed circumstances” “that have left me feeling compelled to do so” include the circumstance that Mr. Gibson is in the middle of arbitration with Mr. Randazza. ‘None of Mr. Gibson’s allegations warrant a serious look, as the explanations below will dispel any notion that Mr. Randazza engaged in any, much less a “host of questionable activities” or “unethical actions unbefitting a licensed attorney.” RANDAZZA’S “TERMINATION” Contrary to Mr. Gibson’s assertion that Mr. Randazza ("RANDAZZA") ended his relationship with Mr. GIBSON (“GIBSON”) by his abrupt resignation, he was actually terminated. RANDAZZA sent GIBSON, an e-mail stating that he would be forced to withdraw from representing Liberty Media Holdings LLC in active litigation if their relationship, which GIBSON had made openly hostile, did not improve, and that he had a suggestion for improving that relationship. GIBSON told RANDAZZ.A that he “accepted my resignation” and terminated RANDAZZA’S employment in his response. RANDAZZA’S ¢-mail in response stated that he did not resign, nor was it his intention to do so. See Exhibit A. step 150 West Flagler Sex Penthout Miami, Hosda 3313 “Welephne (305) 374-785, ‘Telefax: (305) 374-008 ‘Toll Free: (866) 3 85, info@rannebaumweiss.con . snewsanncbancoie cotRANDAZZA did not inquire about a full time job, GIBSON initially reached out and solicited RANDAZZA. (See Exhibit B.), RANDAZZA reached out to GIBSON to see his companies were still looking for in-house counsel. RANDAZZA initially inquired about what he could do to retain them and move on from his firm, which evolved into a discussion as to whether RANDAZZA should move in-house with them ~ a discussion they initiated. ‘THE $75,000 “BRIBE.” RANDAZZA used the term “bribe” for the $75,000 payment in the same sense as someone frustrated with their child says “I am going to kill you.” It was not a bribe, it was a term. “Oron” was a file-sharing website run by FF Magnat Limited, a Hong Kong limited company run by Russians living in Europe and the US. Liberty Media Holdings, LLC, Excelsior’s alter-ego that owns all of the intellectual property for the “Corbin Fisher” brand, sued the site for approximately $34 million in copyright inftingement damages. Liberty filed suit in mid-June; Oron settled in early July for $550,000. Part of the reason for this early success wes Liberty’s decision (at RANDAZZA’S urging) to seek a Mareva injunction in Hong Kong, as much of Oron’s money was held in banks outside the United States. From July through August 2012, Liberty and Oron litigated over whether the settlement agreement was actually a binding settlement agreement. In early August, the Court held that the settlement agreement was valid and entered judgment in Liberty's favor, which was collected from Oron’s PayPal account (and remains in RANDAZZA’S trust account today). ron appealed this decision. As part of a blanket resolution of the whole matter, Oron’s successor counsel suggested # payment that would include $75,000 for RANDAZZA to not represent others against the site. RANDAZZA did not seek or solicit this payment; it was offered by Oron’s counsel. In fact, this is a frequent issue in litigation involving Liberty. In RANDAZZA‘S first interaction with this attomey, Valentin Gurvits, Mr. Gurvits offered RANDAZZA a similar payment. RANDAZZA informed Mr. Gibson that Gurvits had offered. RANDAZZA that payment and Gibson asked what it meant. RANDAZZA explained to him that essentially he wanted to “bribe” RANDAZZA to never sue his client again. (This is in a case against TNAflix.com) GIBSON actually encouraged RANDAZZA to take it if this would facilitate the settlement with TNAflix. However, RANDAZZA explained to both Mr. Gurvits and GIBSON that RANDAZZA would not accept payment in exchange for a limitation on who RANDAZZA could represent or not represent in the future. No payment in the TNAflix case was made to RANDAZZA. ‘Subsequently, RANDAZZA had a case involving Liberty Media and Megaupload. In that case, ‘the attorney on the other side made a similar overture. He wanted to pay RANDAZZA an undisclosed sum in order to never sue his client again, RANDAZZA explained to him that he did not feel comfortable taking that offer. GIBSON was well aware that this had been offered and tried to encourage RANDAZZA to take it in order to facilitate settlement. Ultimately, it was taken off the table by the time the final settlement was made because RANDAZZA insisted upon TANNEBAUM IT'W! weiss ATTORNEYS AT LAW