Office of Attorney General ( OAG ) Right-to-Know Officer 15 th Floor, Strawberry Square Harrisburg, PA 17120

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1 STANDARD RIGHT-TO-KNOW REQUEST FORM Office of Attorney General ( OAG Right-to-Know Officer 15 th Floor, Strawberry Square Harrisburg, PA DATE OF REQUEST MAY 6, 2016 REQUEST SUBMITTED BY (rtkl@attorneygeneral.gov NAME OF REQUESTOR SIMON CAMPBELL STREET ADDRESS 668 STONY HILL RD #298 CITY/STATE/ZIP YARDLEY, PA parighttoknow@gmail.com Definitions The litigation with Fina means the litigation shown in Attachment A in which Kathleen Kane Michael Miletto (both employees/officials of the Attorney General s office were sued in their official capacities also their individual capacities. Littler Mendelson shall mean the law firm of Littler Mendelson, P.C. /or any of the four individual attorneys shown in Attachment B. Pursuant to Pennsylvania s Right-to-Know Law ( RTKL 65 P.S et seq. please send me copies of the following records: 1. Any all taxpayer-paid insurance policies that provide coverage to the OAG for any type of legal claim that could be made against the OAG including, but not limited to, the litigation with Fina. 2. A copy of any all retention agreements/contracts Rule 1.5(b written communication 1 between Littler Mendelson the OAG (or an insurance company/broker that was used as the basis for Littler Mendelson to enter an appearance in the litigation with Fina on behalf of Kathleen Kane Michael Miletto in their official capacities. 3. A copy of any all retention agreements/contracts Rule 1.5(b written communication between Littler Mendelson the OAG (or an insurance company/broker that was used as the basis for Littler Mendelson to enter an appearance in the litigation with Fina on behalf of Kathleen Kane Michael Miletto in their individual capacities. 1 The expression Rule 1.5(b written communication in Request Items 2 3 refers to Rule 1.5(b of the Rules of Professional Conduct for attorneys in Pennsylvania ( When the lawyer has not regularly represented the client, the basis or rate of the fee shall be communicated to the client, in writing, before or within a reasonable time after commencing the representation. 1

2 4. All invoices generated sent to date by Littler Mendelson to the OAG (or an insurance company for legal representation services provided on behalf of Kathleen Kane Michael Miletto in their official capacities in the litigation with Fina. 5. All invoices generated sent to date by Littler Mendelson to the OAG (or an insurance company for legal representation services provided on behalf of Kathleen Kane Michael Miletto in their individual capacities in the litigation with Fina. 6. Evidence that the invoices generated as described in Request 4 have been paid (e.g. canceled check image, online banking screenshot image, etc.. 7. Evidence that the invoices generated as described in Request 5 have been paid (e.g. canceled check image, online banking screenshot image, etc.. 8. The name salary of the OAG official upon whose ultimate authority Littler Mendelson was retained as counsel to Kathleen Kane Michael Miletto in their official capacities in the litigation with Fina. 9. The name salary of the OAG official upon whose ultimate authority Littler Mendelson was retained as counsel to Kathleen Kane Michael Miletto in their individual capacities in the litigation with Fina. Please respond to the specificity of the requests (i.e. please provide an itemized response to each of the nine (9 itemized requests. DO YOU WANT COPIES? YES DO YOU WANT TO INSPECT THE RECORDS? NO DO YOU WANT CERTIFIED COPIES OF RECORDS? NO DO YOU WANT TO BE NOTIFIED IN ADVANCE IF THE COST EXCEEDS $100? YES OPEN-RECORDS OFFICER: FOR AGENCY USE ONLY I have provided notice to appropriate third parties given them an opportunity to object to this request DATE RECEIVED BY THE AGENCY: AGENCY FIVE (5 BUSINESS DAY RESPONSE DUE: **Public bodies may fill anonymous verbal or written requests. If the requestor wishes to pursue the relief remedies provided for in this Act, the request must be in writing. (Section 702. Written requests need not include an explanation why information is sought or the intended use of the information unless otherwise required by law. (Section

3 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA FRANK NOONAN RANDY FEATHERS RICHARD A. SHEETZ, JR. E. MARC COSTANZO FRANK FINA Plaintiffs CIVIL ACTION: JURY TRIAL DEMANDED 2:15-cv v. KATHLEEN KANE Office of the Attorney General, 16 th Floor Strawberry Square Harrisburg, PA MICHAEL MILETTO Office of the Attorney General, 16 th Floor Strawberry Square Harrisburg, PA CHRISTOPHER BRENNAN 801 Market Street Philadelphia, PA PHILADELPHIA DAILY NEWS 801 Market Street, Suite 300 Philadelphia, PA PHILADELPHIA MEDIA NETWORK (DIGITAL LLC 801 Market Street, Suite 300 Philadelphia, PA PHILADELPHIA MEDIA NETWORK, LLC 801 Market Street, Suite 300 Philadelphia, PA Defendants.

4 31. At all times relevant to this lawsuit presently, defendant Kathleen Kane has been the attorney general for the Commonwealth of Pennsylvania. She is sued individually in her official capacity. 33. At all times relevant to this lawsuit, Defendant Michael Miletto ( Miletto was an investigator for the Pennsylvania Office of Attorney General ( OAG. Miletto is a citizen of resident the Commonwealth of Pennsylvania with a place of business at Office of the Attorney General, 16 th Floor Strawberry Square, Harrisburg, Pennsylvania. He is sued individually in his official capacity. 9

5 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Frank Noonan, et al., Plaintiffs, v. Kathleen Kane, et al., Defendants. Civil Action No. 2:15-cv HB ENTRY OF APPEARANCE Please enter my appearance on behalf of Defendants Kathleen Kane Michael Miletto in the above-captioned matter. November 19, 2015 /s/ Richard R. Harris Richard R. Harris (PA Id Edward T. Ellis (PA Id Rachel Fendell Satinsky (PA Id Littler Mendelson, P.C Cherry Street Suite 1400 Philadelphia, PA Tel: Fax: Attorneys for Defendants Kathleen Kane Michael Miletto 1

6 Case 2:15-cv HB Document 8 Filed 11/19/15 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Frank Noonan, et al., Plaintiffs, v. Kathleen Kane, et al., Defendants. Civil Action No. 2:15-cv HB ENTRY OF APPEARANCE Please enter my appearance on behalf of Defendants Kathleen Kane Michael Miletto in the above-captioned matter. November 19, 2015 /s/ Edward T. Ellis Richard R. Harris (PA Id Edward T. Ellis (PA Id Rachel Fendell Satinsky (PA Id Littler Mendelson, P.C Cherry Street Suite 1400 Philadelphia, PA Tel: Fax: eellis@littler.com rharris@littler.com rsatinsky@littler.com Attorneys for Defendants Kathleen Kane Michael Miletto 1

7 Case 2:15-cv HB Document 9 Filed 11/19/15 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Frank Noonan, et al., Plaintiffs, v. Kathleen Kane, et al., Defendants. Civil Action No. 2:15-cv HB ENTRY OF APPEARANCE Please enter my appearance on behalf of Defendants Kathleen Kane Michael Miletto in the above-captioned matter. November 19, 2015 /s/ Rachel Fendell Satinsky Richard R. Harris (PA Id Edward T. Ellis (PA Id Rachel Fendell Satinsky (PA Id Littler Mendelson, P.C Cherry Street Suite 1400 Philadelphia, PA Tel: Fax: eellis@littler.com rharris@littler.com rsatinsky@littler.com Attorneys for Defendants Kathleen Kane Michael Miletto 1

8 Case 2:15-cv HB Document 18 Filed 12/17/15 Page 1 of 2