1 Timothy B. Sottile, Esq.

SBN: 127026
Michael F. Baltaxe, Esq. SBN: 129532
2 Payam I. Aframian, Esq. SBN: 299345
3 Victoria V. Felder, Esq. SBN: 304894
SOTTILE BALTAXE
4 28632 Roadside Drive, Suite 100
Agoura Hills, California 91301
5 Telephone: (818) 889-0050; Facsimile: (818) 889-6050
6 Attorneys for Plaintiff Sharon O’Donnell
7
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
8
FOR THE COUNTY OF LOS ANGELES
9
10 SHARON O’DONNELL, an individual, CASE NO.: 21STCV00596

11 Plaintiff, [Assigned to Hon. Elihu M. Berle in Dept.

6]
12
vs.
13 DECLARATION OF PLAINTIFF
RIOT GAMES, INC., a business entity exact SHARON O’DONNELL IN SUPPORT
14 form unknown, NICHOLAS LAURENT, an OF HER OPPOSITION TO
individual and DOES 1 through 100, inclusive, DEFENDANTS’ EX PARTE
15 APPLICATION FOR AN ORDER
Defendants. SETTING A STATUS CONFERENCE
16
DATE: March 17, 2021
17 JUDGE: Elihu M. Berle
DEPT.: 6
18
[Filed Concurrently with Plaintiff’s
19 Opposition to Defendant’s Ex Parte
20 Application & Declaration of Michael F.
Baltaxe]
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I, Sharon O’Donnell, declare as follows:
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I am an individual over the age of eighteen and a resident of Los Angeles, California.
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I am the Plaintiff in this action. If called upon to testify, I would and could competently testify to
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25 the following based on my personal knowledge under penalty of perjury.

26 1. I have read and reviewed the Defendants’ Ex Parte Application seeking an order setting a
27 Status Conference.
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DECLARATION OF PLAINTIFF SHARON O’DONNELL IN SUPPORT OF HER OPPOSITION TO
DEFENDANTS’ EX PARTE APPLICATION FOR AN ORDER SETTING A STATUS CONFERENCE
 1 2. The Ex Parte Application alleges that I have engaged in “witness tampering” and
2 “harassment of potential witnesses”. The Application also claims that I have offered an individual
3
compensation for testifying on my behalf, encouraged individuals to file lawsuits against the
4
Defendant Nicholas Laurent (“Laurent”), and encouraged individuals to threaten witnesses on my
5
behalf.
6
7 3. None of those claims are true.

8 4. I have not engaged in witness tampering whatever that might mean.

9 5. I have not engaged in harassment of potential witnesses whatever that might mean.
10 6. I have never offered an individual compensation for testifying on my behalf.
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7. I have never encouraged individuals to file lawsuits against the Defendant Laurent,
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although the person identified as Doe 1 did ask me on more than one occasion about her filing a
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lawsuit against the Defendant Laurent.
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15 8. I have never personally threatened a witness or encouraged anybody to threaten witnesses

16 on my behalf.

17 9. As the Court is no doubt aware that there are several lawsuits which have been filed
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against the Defendant Riot by many female employees. They generally allege gender
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discrimination, as does my case, including a class action in which the DFEH has intervened.
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10. These cases, including my case, have all been the subject of extensive news coverage.
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11. I have also thoroughly reviewed the Declarations of these “witnesses” which are attached
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23 as Exhibits A and B to the Declaration of Defense Counsel Catherine A. Conway. None of these

24 witnesses have identified themselves for me or the court but have rather been identified as Doe 1 or
25 Doe 2.
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12. I believe I know the identities of both Doe 1 and Doe 2 from the contents of their
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Declarations and the fact that the Defendant Laurent has only two employees. I am fairly certain
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DECLARATION OF PLAINTIFF SHARON O’DONNELL IN SUPPORT OF HER OPPOSITION TO
DEFENDANTS’ EX PARTE APPLICATION FOR AN ORDER SETTING A STATUS CONFERENCE
 1 that they both were directly employed by the Defendant Laurent in his household and were
2 never employees of the Defendant Riot.
3
13. I have read the Declaration of Doe 1 which is attached to the to the Declaration of
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Defense Counsel Catherine A. Conway as Exhibit A. I am confident I know who that is but will
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not mention her name in my response.
6
7 14. She was never employed by the Defendant Riot, but was at one time employed by the

8 Defendant Laurent personally in his household.

9 15. We did interact before I left the Defendant Riot and I did help her with her
10 immigration paperwork. I considered her a friend.
11
16. She called me in the spring 2020 and told me that she was in the process of being fired
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by the Defendant Laurent. She felt this was unfair. I helped her get an interview for another
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possible job.
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15 17. We met after the interview. She told me that she thought she was being fired because she

16 was hospitalized for exhaustion. She also told me that she was contemplating filing a lawsuit

17 against the Defendant Laurent for that and other reasons. I do not believe I discussed my lawsuit
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with her at the time which was not filed until January 2021.
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18. I have read Paragraph 6 of her Declaration. Some portions are not true. In the summer
20
of 2020, she contacted me and asked me to meet her, and we decided to meet at a restaurant.
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During the meeting she told me all the ways she felt she was being mistreated by the Defendant
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23 Laurent. She asked if she had a case and I told her to speak to a lawyer. She also told me that she

24 thought the media should know about how the Defendant Laurent was treating her. We also
25 discussed that he wanted her to sign a severance agreement.
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19. During our meeting she described two inappropriate instances of sexual conduct by
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Defendant Laurent, among many other things. One of them took place in his home in Pacific
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DECLARATION OF PLAINTIFF SHARON O’DONNELL IN SUPPORT OF HER OPPOSITION TO
DEFENDANTS’ EX PARTE APPLICATION FOR AN ORDER SETTING A STATUS CONFERENCE
 1 Palisades. The other incident occurred at his condominium in Deer Valley. She described the
2 incident in Pacific Palisades as an incident where he touched her breast. She described herself as
3
shocked. As to the Deer Valley incident she described that he brushed up against her and she felt
4
his privates when he did so.
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20. During our meeting I observed her writing in a notebook.
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7 21. She caught an Uber after our meeting and as she was leaving she asked me whether I

8 thought if she sued “Sir Nicolo” that he would come after her. I told her yes.

9 22. She contacted me many times after the initial meeting in the summer of 2020 usually by
10 phone. During these calls she repeatedly asked me if she should proceed with her lawsuit against
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Mr. Laurent and I would tell her she needed to be really strong and to seek counsel.
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23. Her statements in her declaration that she would never file a lawsuit against the
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Defendant Laurent is not true. She discussed the possibility with me not only at that initial meeting
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15 but also several times later. I also recall that during some phone calls she told me that she was

16 consulting with attorneys.

17 24. She later texted me portions of her handwritten notes discussing what had occurred to her
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with the Defendant Laurent.
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25. I did give her name to a journalist who was publishing a story in Wired as a possible
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witness. She had previously told me she wanted to share her story with the press.
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26. The journalist from Wired told me that she never spoke to her.
22

23 27. I do not recall giving her phone number to any other journalist.

24 28. I have read her Declaration at Paragraph 10. When I called her it was always from my
25 own line. I have not asked her several times to help with my lawsuit.
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29. She also called me to help her find an apartment.
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30. I have read her Declaration at Paragraph 11. The contents are untrue. I never told her that
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DECLARATION OF PLAINTIFF SHARON O’DONNELL IN SUPPORT OF HER OPPOSITION TO
DEFENDANTS’ EX PARTE APPLICATION FOR AN ORDER SETTING A STATUS CONFERENCE
 1 I would share money from the lawsuit or anything like that if she were to testify against the
2 Defendant Laurent. I never discussed anything like that with her or anybody else. I never told her
3
that if she filed a lawsuit, she would 100% get money from the Defendant Laurent. I would have no
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idea if that were so.
5
31. I have read her Declaration at Paragraph 13. The contents are also untrue. I never asked
6
7 her to “join “my lawsuit. There would be no reason for that as she was not an employee of the

8 Defendant Riot. I never said to her that if she joined the lawsuit she could make $500,000 or

9 anything like that. I never discussed anything like that with her.
10 32. I have read the Declaration of Doe 2 which is attached to the to the Declaration of
11
Defense Counsel Catherine A Conway as Exhibit B. I am confident I know who that is but will not
12
mention her name in my response.
13
33. She was never employed by the Defendant Riot but is I believe employed by the
14
15 Defendant Laurent personally in his household.

16 34. I did meet this witness during my employment at Riot.

17 35. I have never spoken to her or tried to speak to her since July 2020
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36. I have not called her or communicated with her from any phone since July 2020.
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37. I have not tried to reach her in any fashion since July 2020.
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38. I have not asked anybody to call or communicate with her.
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39. I do not consider her to be a possible witness in my case.
22

23 40. I did not give her name or contact information to my lawyers.

24 41. I did not call her from any blocked number.

25 42. I never asked anybody to call her and claim that they were an assistant to my lawyer or
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anything like that.
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43. I never told anybody to contact her for any reason. I never told anybody to tell her that I
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DECLARATION OF PLAINTIFF SHARON O’DONNELL IN SUPPORT OF HER OPPOSITION TO
DEFENDANTS’ EX PARTE APPLICATION FOR AN ORDER SETTING A STATUS CONFERENCE
 1 wanted to talk to her or to meet her right away or at all.
2 44. I never told anybody to contact her and tell her that she could get money from the
3
Laurents if she helped me with the lawsuit. I do not think she could help me with the lawsuit.
4
45. I personally never called her or contacted her and told her that I wanted to talk to her, or
5
meet her, or that she could get money from the Laurents, or called her a bitch or made any of the
6
7 vile threats set forth in Paragraphs 8 and 9 of her Declaration.

8 46. I never gave anybody her number to call and intimidate her or to make threats or to do

9 any of the things set forth in Paragraphs 8 and 9 of her Declaration.

10 47. I have no idea who would have made these calls.
11
48. The first time I heard of these is when I read the moving papers.
12
13

14 I declare under penalty of perjury under the laws of the State of California that the
15 foregoing is true and correct.
16 Executed this 17th day of March, 2021, at Los Angeles, California.
17

18 ________
SHARON O’DONNELL
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DECLARATION OF PLAINTIFF SHARON O’DONNELL IN SUPPORT OF HER OPPOSITION TO
DEFENDANTS’ EX PARTE APPLICATION FOR AN ORDER SETTING A STATUS CONFERENCE
 1 PROOF OF SERVICE
2
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3
I am employed in the County of Los Angeles, State of California. I am over the age of 18
4 years of age and not a party to the within action. My business address is 28632 Roadside Drive,
Suite 100, Agoura Hills, CA 91301.
5
On March 17, 2021, I served, in the manner indicated below, the foregoing document
6 described as DECLARATION OF PLAINTIFF SHARON O’DONNELL IN SUPPORT OF
HER OPPOSITION TO DEFENDANTS’ EX PARTE APPLICATION FOR AN ORDER
7 SETTING A STATUS CONFERENCE on the interested parties in this action by placing true
copies thereof enclosed in a sealed envelopes, at Agoura Hills, California, addressed as follows (or
8 as stated on the attached Proof of Service Mailing List):
9 SEE ATTACHED SERVICE LIST
10
[] (BY MAIL) I caused such envelopes with postage thereon fully prepaid to be placed in the
11 United States mail at Agoura Hills, California. I am “readily familiar” with the firm’s
practice of collection and processing correspondence for mailing. Under that practice, it
12 would be deposited with the U.S. Postal Service on that same day in the ordinary course of
business. I am aware that on motion of the party served, service is presumed invalid if
13 postal cancellation date or postage meter is more than one (1) day after date of deposit for
mailing in affidavit (C.C.P. § 1013(a)).
14
[XX] (BY ELECTRONIC MAIL) The document listed above was transmitted via electronic
15 mail to the e-mail addresses set forth above, or as stated on the attached Proof of Service
Mailing List. The transmission was reported as complete and without error (C.C.P. §
16 1010.6(a)(2)).
17 [] (BY OVERNIGHT COURIER): I caused the above-referenced document to be delivered
to GLS for delivery to the addresses on the attached service list.
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[] (BY PERSONAL SERVICE) I caused such envelopes to be delivered by hand to the
19 offices of the addressees (C.C.P. § 1011(a)(b)).

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* * * * *
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[XX] (STATE) I declare under penalty of perjury under the laws of the State of California that
22 the foregoing is true and correct.
23 [] (FEDERAL) I declare that I am employed in the office of a member of the bar of this
24 Court, at whose direction the service was made.

25 EXECUTED on March 17, 2021, at Agoura Hills, California.

26
/s/ Rachna Arhi
27 RACHNA ARHI
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DECLARATION OF PLAINTIFF SHARON O’DONNELL IN SUPPORT OF HER OPPOSITION TO
DEFENDANTS’ EX PARTE APPLICATION FOR AN ORDER SETTING A STATUS CONFERENCE
 1 SERVICE LIST
GIBSON DUNN & CRUTCHER LLP Attorneys for Defendants RIOT GAMES,
2 Catherine A. Conway, Esq. INC. and NICHOLAS LAURENT
Katherine V.A. Smith, Esq.
3 Tiffany Phan, Esq.
4 333 South Grand Avenue
Los Angeles, CA 90071
5 Telephone: 213.229.7000
Facsimile: 213.229.7520
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DECLARATION OF PLAINTIFF SHARON O’DONNELL IN SUPPORT OF HER OPPOSITION TO
DEFENDANTS’ EX PARTE APPLICATION FOR AN ORDER SETTING A STATUS CONFERENCE