From: "Meagan M. Talafuse" <mtalafuse@phippsortiztalafuse.

com>
Date: Apr 27, 2021 6:55 PM
Subject: IMMEDIATE DEMAND TO CEASE AND DESIST TO TPR AND PAUL
FLAHIVE
To: fernanda@tpr.org,fernando@tpr.org
Cc: dan@tpr.org,Gabe Ortiz <gortiz@phippsortiztalafuse.com>

Good evening,

I apologize for the late hour of this request, but this involves a matter of great urgency.

A person by the name of Paul Flahive who claims that he is a TPR reporter has been
harassing employees of Paramour, a rooftop bar and entertainment venue located in
San Antonio, Texas. Mr. Flahive is clearly attempting to fabricate a story we believe is
contradicted by police reports and physical evidence. We demand that Mr. Flahive
immediately cease his incessant and harassing phone calls and text messages.

Additionally (and disturbingly), we have reason to believe Mr. Flahive is posing as

Martin J. Phipps on the dating app Grindr in an attempt to extract information from
employee(s). Attached are screenshots of messages sent via Grindr that are
coincidentally about the same matter Mr. Flahive claimed to be investigating in his email
to Rich Wilner (cc Dan Katz at TPR) at 5:51 p.m. today (email also attached).

According to the employee contacted via Grindr, the person posing as Martin Phipps
was sending him messages from 2,500 feet away. The employee immediately reported
the harassment to Grindr. We are working with the app to obtain the IP address to
report the harassment to authorities.

We need to know by 9:00 a.m. tomorrow via direct response to this email whether you
will agree to cease and desist OR whether Mr. Flahive will sign an
affidavit tomorrow that disavows any knowledge of this despicable behavior. Otherwise,
we will file a motion tomorrow to stop this harassment.

Regardless of your response, please allow this email to serve as a litigation hold on all
evidence possessed by TPR and Mr. Flahive in his individual capacity, including
documents, electronic devices, data, emails, text messages, phone records, web
histories, and any other information on this issue.

We have no issue with and fully support investigative reporting based on the
facts. However, that is not the issue here. The police report and physical evidence are
the best evidence of the truth, not personal agendas.

Thank you for your attention to this matter.

Meagan M. Talafuse
102 9th Street
San Antonio, TX 78215
Main: (210) 340-9877
Fax: (210) 340-9899

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