Re: Private and Confidential, in response to our meeting.

Dear Mr. Aldous:

I am writing as litigation counsel to Professor Lawrence Krauss. It has come to my attention that you and Buzzfeed have engaged in an outrageous and protracted defamation campaign against Professor Krauss, including both libel and slander. Buzzfeed's campaign has been malicious, undertaken with absolute reckless disregard for the truth, and despite repeated disprovals of the falsehoods you continue to harmfully disseminate. Your defamatory efforts have also been undertaken, for reasons known only to you and your colleagues, with the intention of tortiously interfering with the contracts of Professor Krauss, and Buzzfeed has unfortunately succeeded in this malignant purpose. We have both testimony and documents from a litany of well respected third parties that provide overwhelming evidence of your and Buzzfeed's malfeasant attacks on Professor Krauss. We are still tallying the damage.

You and Buzzfeed will immediately cease and desist from further defamatory statements regarding Professor Krauss, and you and Buzzfeed will immediately cease and desist from any further efforts to tortiously interfere with Professor Krauss' contracts. If you and Buzzfeed are unwise enough to ignore this notice to cease and desist from the actions described above, the appropriate legal response will be swift. Notwithstanding the foregoing, all legal rights are reserved.

If you have more harassing emails or any prospective communication you wish to transmit to Professor Krauss, you are instructed to send them to me as he is now represented by counsel. If your or Buzzfeed's counsel, whomever they may be, wish to send me a letter in response to the above, be aware that I may, depending on its contents and because I would be obligated to forward it to my client, consider such letter to also constitute a trigger of the above and react accordingly. Professor Krauss has suffered enough abuse at your hands without commensurate consequences.

Sincerely,

Adam Waldman

Dear Naimah et al:

Attached you will find a letter from my attorney, along with a letter he sent to Buzzfeed earlier in this week regarding the defamatory and false story they were planning on printing. The story was then published yesterday morning. I wanted to add to his letter, to reiterate our concern about how your office was planning to follow up on the false and defamatory third-party allegations from Buzzfeed. Because this was initiated by an online entertainment news outlet with a clear agenda and established record of propagating false allegations about me, rather than by any of the individuals they refer to as sources, this should not be considered a credible allegation worthy of investigation. I believe that our initial discussion was sufficient to settle this matter.

Whether or not you agree with this, there are two things I think are important to establish.

Firstly, that the University should not propagate what can be false allegations from such a source by presenting them directly to current and/or former employees or to others. To do so would be to further their libelous agenda, as Mr. Waldman has emphasized. In this regard, I would appreciate seeing copies of the correspondence you might send to current or former employees about this in the process of carrying out and concluding your investigation.

Secondly, I reiterate once again that the Origins Project environment is supportive, candid, frank, honest, and productive, with all employees being treated with respect, as well as being supported and mentored. I am proud of our team, and I believe they feel the same way.

Thanks for your attention to these letters.

Lawrence Krauss

H= all:

I just wanted to clarify this further, in case it=wasn't completely clear. I am not being represented by Adam =is a vis the University investigation. He is advising me regarding b=zzfeed issues in case there is litigation required regarding Buzzfeed. =AO So I haven't retained legal counsel for the University Investig=tion. Just so you know. You should continue to contact me if there =ny further questions, developments, etc. Thanks again.

Lawrence

FYI, just got back on wifi and reading now.

Mr. Waldman,

Your client, Lawrence Krauss, copied me on his February 23rd email communication to the Office of Equity and Inclusion. I am writing to convey the University's position on its responsibility to conduct administrative investigations into allegations of conduct that would violate institutional policy, if true. Because Dr. Krauss has retained legal counsel, I am writing directly to you. You may forward my communication on to your client. Without having first secured your permission, I did not think it was proper for me to copy him on this reply.

Our policy on the Prohibition Against Discrimination, Harassment, and Retaliation (ACD 401) and its accompanying procedures (P20) directs the Office of Equity and Inclusion to conduct prompt and equitable investigations. Among the points stated are that the Office accepts anonymous complaints as well as direct complaints. University employees are required to cooperate with any investigation or allegations of violations of this policy. Providing false or misleading information or failing to cooperate may result in disciplinary action. Individuals making a complaint or participating as a witness in an investigation cannot be retaliated against. Any employee who engages in retaliation will be disciplined. The Office of Equity and Inclusion does not make any findings until such time as it determines that it has completed its fact gathering.

Our courts recognize that participants in an administrative investigation have a privilege against a defamation charge. In Paros v. Hoemako Hospital, 140 Ariz. 335, 681 P.2d 918 (Ct. App. Div. 2 1984), the court recognized that the employer's response to a notice of charge of discrimination filed with the Equal Employment Opportunity Commission was absolutely privileged. In Miller v. Servicemaster by Rees, 174 Ariz. at 520, 851 P.2d 240, 243 (Ct. App. Div. 1 1993), the court recognized the existence of a conditional privilege for employees to report perceived acts of sexual harassment as public policy dictated that employees must be protected from workplace sexual harassment. Cited approvingly, Carey v. Maricopa County, 2009 WL 750225 (D. Ariz. 2009). Both Paros and Miller were cases concerning discrimination and harassment under Title VII. In addition to its obligations under Title VII, the University must also operate its educational programs and activities to be free from gender discrimination under Title IX.

The Office of Equity and Inclusion will proceed with its investigation as outlined in ACD 401 and P20. The Office will not provide your client with its investigative file. We look forward to Dr. Krauss's continuing cooperation.

Regards,

Cynthia L. Jewett
Senior Associate General Counsel
Arizona State University
480.965.4550

heres =hat this says. i lawrence krauss will tell you how i thi=kyou should conduct your investigation , if at all. and = would like to participate in it. repsonse. go fuc= yourself. we will not share the file , all complaints a=e proteced from defamation and you must continue to cooperate.