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try to coerce him into resigning his partnership and agreeing to a lifetime gag order
vis-à-vis firm employees. (Lewis Decl. ¶ 63).
x Legal Malpractice. Viable claims have been pled.
x Criminal. As noted, the LNYC uses “potentially” throughout. (See e.g., LNYC ¶¶
36, 166, 184)
b. One of the Firm’s partners struggles with substance abuse.
Previously refuted and ignored by PB. (See LAC Falsehoods Chart at Rows 3, 4, 5, 6, 7, 8,
Exhibit 7. The chart was annexed as Exhibit B to the Original Complaint in this Action.)

x This is yet another unspecific allegation. In any event, the partner is Managing
Partner John Pierce, who is on the signature block.
On August 9, 2018 – 7:20 p.m. Pierce and his personal assistant Schaefer-Green were
having a quarrel in Boston. Schaefer-Green’s text speaks for itself.
LSG text to Pierce and Lewis on August 9, 2018.

August 19, 2018 – Pierce and Lewis had scheduled a meeting on a Sunday for 11:30
a.m. at the Mondrian Hotel. Pierce no-showed. By 4:30 p.m., Pierce had still not
surfaced. Lewis was concerned. LSG shared information about Pierce and the
specific medication that she should not disclose, however, both she and Pierce
frequently did. LaVigne’s response to Lewis sharing the same speaks for itself.

August 19, 2018 – Lewis texts with LaVigne including a screen shot from LSG

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August 20, 2018 – 9:03 p.m. LSG was concerned about Pierce’s drinking, so was
Lewis as there was a big meeting the next morning.
LSG text to Lewis as he was leaving and refence the “breakfast” (meeting)
scheduled for the next morning -- August 20, 2018

August 21, 2018 – 8:40 a.m. LaVigne had used personal and professional contacts
to set up and expedited in-person meeting with a funding entity. Lewis picked Pierce
up at his hotel and it was plainly evident that Pierce was still inebriated. LaVigne
checked in as Lewis and Pierce as they were en route in an Uber.

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LaVigne texts with Lewis on August 21, 2018

August 29, 2018 – LaVigne and Lewis could not locate Pierce. Most of the text
exchange is self-explanatory. The part about “fell asleep on lax floor,” is a reference
to Pierce announcing to the firm on Slack that he had fallen asleep on the floor at the
Los Angeles airport. Pierce then asked in the same message if anyone had a “lint brush.

LaVigne and Lewis texts on August 29, 2018

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