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80

South 8th

St

r eet I

DS

Cent

e r . Suite 1650 Minne ap olis, MN 55402 6 1 2.605.40

98

6 1 2.60 5.4099

Ch

i cago Office 415 North

LaSa

lle Street Suite 502 Chicago. IL 606

54

312.222.0660 312 . 222. 165 6

RULE 408

CONFIDENTIAL

COMMUNICATION

FOR SETTLEMENT

PURPOSES ONLY

V I

EMAIL

AND U.S.

MAIL

Angela Padilla Associate general Counsel, Litigation employment Ange l a . pad ill a @ u ber . com

Re : Richard Jacobs v . Uber

Dear Ms . Padilla:

h lunen l w

EMP

LOY

MEN

T

CONSUMER YIHISTLEBLOWER

May 5 , 2017 During our communications last week you requested that we make our client availa ble for an interview to assess the scope

o f

our client' s allegations and the facts supporting th em. I indicated to you that we did not inte n d

to

produce our client but that we would

be

happy to provide additional informat i on. Specifically, you said that you are interested in fully investigating the co nduct our client obse rved at Uber that he feels was illegal

or

improper. Even more specifically, you i ndica ted tha t our client's assertions regarding destru ctio n , spoliation an d manipul ation

o f

discovery do cume nt s were

o f

particular concem. That is because this typ e

o f

conduct would

be

contrary to your own directives to managers and la wye rs with whom you deal for purposes

o f

liti gation holds. Finally, you said that you wanted

to

ha ve a clearer understand i ng

o f

what happened to give rise

to

our client's employment-related claims. With this understanding

o f

what you are see king, we provide the information below.

We

begin with a

brief

summary

o f

Richard Ja co b

s'

background and expertise, followed

by

an overview

o f

the organizationa l structure relevant

to

und erstand in g hi s experie nce s . This is

H

1

I I

f

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W . •

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ft