August 1, 2019

BY ELECTRONIC MAIL

Matthew Modine Richard Hadfield

Jodi Long Linda Harcharic
David Jolliffe Matt Kavanaugh
Pete Antico Diane Ladd
Ed Asner Esai Morales
Joe d’Angerio Ron Ostrow
Debbie Evans Patricia Richardson
Marie Fink Shaan Sharma
Frances Fisher Martin Sheen
Pamela Guest Jonathan Taylor Thomas

Re: Recent threats of litigation and other demands

Dear Mr. Modine, Ms. Long, Mr. Jolliffe,

Mr. Antico, Mr. Asner, Mr. d’Angerio, Ms. Evans,
Ms. Fink, Ms. Fisher, Ms. Guest, Mr. Hadfield,
Ms. Harcharic, Mr. Kavanaugh, Ms. Ladd,
Mr. Morales, Mr. Ostrow, Ms. Richardson,
Mr. Sharma, Mr. Sheen and Mr. Taylor Thomas:

I am writing to you as counsel for Gabrielle Carteris, Rebecca Damon, Clyde Kusatsu,
Liz Zazzi, Suzanne Burkhead, Samantha Mathis, Catherine Brown and Dan Navarro in their
individual capacities. This firm does not represent SAG-AFTRA.

Our clients believe that you, and/or individuals with whom you are acting in concert or
coordination, are once again attempting to interfere in SAG-AFTRA’s democratic process and
elections by threatening or supporting the threat of baseless litigation against SAG-AFTRA if it
does not remove Ms. Carteris from the election ballot for SAG-AFTRA National President as a
tactic to advance the candidacy of you and your supporters. We believe this latest threat comes
in the form of a July 28, 2019, letter from attorney Robert A. Allen. That letter threatens a
lawsuit against SAG-AFTRA unless Ms. Carteris is peremptorily removed from the ballot in the
current election. Our clients note that this tactic follows a long-term pattern of conduct in which
LEVY RATNER, P.C
August 1, 2019
Page 2

you and people working in concert and coordination with you have filed or supported the filing
of frivolous lawsuit after frivolous lawsuit.

As current and former fiduciaries to the Union by virtue of your service on its board(s),
you owe a duty of loyalty to SAG-AFTRA and have an obligation to protect the Union and its
membership. Violating these duties to further personal political ambitions and vendettas can be
construed as a violation of your fiduciary duty.

Our clients had hoped that the continued and repeated failure of your frivolous lawsuits
would cause you to focus instead on making your case through the democratic process. This
most recent threat to use a lawsuit to interfere in the elections and SAG-AFTRA’s democracy is
the final straw.

Our clients demand that you immediately cease and desist from using costly litigation at
the expense of SAG-AFTRA and its members as a tool to advance your own personal political
agenda. If you do not publicly retract or disavow in writing the threat of a frivolous and
unwarranted lawsuit and other demands, my clients have informed me that they will consider
other appropriate action to protect the integrity and resources of SAG-AFTRA and its election
processes, including legal action against you and other current and former board members for
breach of your fiduciary duty.

We look forward to your prompt response. This letter does not constitute a full or
complete recitation of the facts, our clients’ rights, positions, or remedies, all of which are
expressly reserved.

Sincerely yours,

Pamela Jeffrey

PCJ:jtr
cc: Gabrielle Carteris
Rebecca Damon
Clyde Kusatsu
Liz Zazzi
Suzanne Burkhead
Samantha Mathis
Catherine Brown
Dan Navarro