Todd V. McMurtry tmcmurtry@HemmerLaw.com February 1, 2019

Re:

John Doe, et al. v. XXXXXXX

Kenton County Circuit Court Case No. TBD Demand that Relevant Information be Preserved

Dear XXX, Our law firm represents the family of Nick Sandmann regarding the unfortunate incident in Washington D.C. on January 18, 2019, and the XXXXX’s response to sam e (the “Sandmann M atter”). I write on behal f of our clients to notify you of your obligation to preserve information that may be relevant to potential l itigation between our clients and the XXXXX. Please forwa rd this letter to your legal counsel immediately. Please preserve all information that may be relevant to the Sandmann Matter. If our clients pursue litigation , we intend to serve t he XXXXX with discovery requests to access your computer networks and systems, and to seek the production of relevant documents

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and communications.

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Accordingly, you

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“Document” means all writings or recordings of any kind in the form of pictures , letters, words, or numbers, or their equivalent, set down by handwriting, typewriting, printing, photostatting, photographing, magnetic impulse, mechanical or electronic recording, or other form of data compilation, including but not limited to, all agreements, correspondence, records, ledgers, contracts, bills, invoices, bills of lading, inventories, financial data, memoranda, notes or other writings, formal or informal in nature, accounting and financial records, diaries, minutes, agendas, publications, calendar s, telephone pads, t elephon e logs, bulletins, directives, logs, listings, statements, telegrams, drafts, work papers, paper and magnetic tapes, computer disks and printouts, CD-Rom discs, electronically or magnetically stored information or data, microfiche, microfilm, charts, graphs, maps, schematics, videotapes, drawings, blueprints, topographical surveys and photographs, in your actual or constructive possession, custody or control or of which you have knowledge of the existence, and whether prepared, published or released by you or any other person or entity. The term “document” shall include any copy, which differs in any respect from the original or

other versions of the document, such as copies containing notations, insertions, corrections, marginal notes or any other variations.

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