SCHLAFLY CORI ANNE AS A DIRECT v. MARTIN EDWARD R JR Document 0051

Filed June 10, 2018

Back to SCHLAFLY CORI ANNE AS A DIRECT v. MARTIN EDWARD R JR, 3rd Judicial Circuit Court Case No. 2016MR000111

MOTION FOR ORDER TO SHOW CAUSE WHY NOMINAL DEFT SHOULD NOT BE

This document, first reported by ProPublica, reveals that former Interim U.S. Attorney Ed Martin intentionally conspired to attack a judge and generally planned to deceive a court while he was a licensed attorney.

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Page 1 IN THE CIRCUIT COURT
THIRD JUDICIAL CIRCUIT
MADISON COUNTY, ILLINOIS
ANNE SCHLAFLY CORI etal,
)
Plaintiffs,
)
v.
)
Cause No. 2016MRO00I11
EDWARD R. MARTIN, JR. tal,
)
Defendants.
J
PLAINTIFFS’ MOTION FOR ORDER TO SHOW CAUSE WHY
DEFENDANT EDWARD R. MARTIN, JR. SHOULD NOT BE
HELD IN CRIMINAL CONTEMPT OF COURT
Plaintiffs Anne Cori Schlafly, Eunie Smith, Cathie Adams, Carolyn McLarty, Rosina
Kovar and Shirley Curry (“Plaintiffs”), respectfully request that the Court enter an Order
requiring Defendant Edward R. Martin, Jr. (“Martin”) to show cause why he should not be held
in criminal contempt of this Court. In support oftheir motion, Plaintiffs state as follows:
INTRODUCTION
1. Plaintiffs first served requests for production on Martin and John Schlafly on
May 10, 2016. After nearly 2 years of delay, an agreed order, numerous conferral letters,
enforcement motions and hearings, this Court ordered on March 29, 2018 that Martin and John
Schlafly must produce responsive documents. Since April 19, 2018, Martin and defendant John
Schlafly have electronically produced documents on a rolling basis. This document production,
‘which is still incomplete and undergoing review by Plaintiffs’ counsel, has nonetheless disclosed
an underhanded scheme, orchestrated and carried out by Martin, to attack the integrity and
authority of this Court, prevent the administration of justice and bring the practice of law into
disrepute. Specifically, after an Order from this Court on October 20, 2016 (the “October 20
TRO”), Martin drafted attacks against this Court and directed his surrogate, Priscilla Gray, to
Case No. 2016MR0001 11
Page Lof11
suaa0nsse

Page 2 assail Judge Barberis publicly on social media in an effort to disparage this Court and improperly
influence its rulings. This conduct goes well beyond merely expressing disappointment in a
ruling by this Court. Martin's conduct amounted to ex parte communications with this Court
‘which sought to improperly influence ruling on a pending motion. In light of such conduct,
‘which first became known to Plaintiffs upon review of the electronic documents recently
produced by Martin and John Schlafly, Plaintiffs request that this Court require Martin to show
cause why he should not be held in criminal contempt of this Court
FACTS
Priscilla Gray Offers To Attack This Court
2.
On July 28, 2016, this Court entered its Order denying Martin's Motion to
Disqualify Plaintiffs’ Counsel Spencer Fane, LLP; Erik O. Solverud; Megan D. Meadows; and
Arthur D. Gregg (the “July 28 Order”). Because the July 28 Order was distributed to the parties
via U.S. Mail, Plaintiffs did not receive a copy of the Order until August 8, 2016.
3.
On August, 2016, Martin sent an email to Priscilla Gray, a former employee of
defendant Eagle Forum Education & Legal Defense Fund (“EFELDF”), attaching the July 28
Order:
P—————
————————————
Pe
i
En
Welost Ouageous, Call me.
A true and accurate copy of the email sent by Martin on August 8, 2016 is attached hereto as
Exhibit A and incorporated herein by reference.
Case No. 2016MR0001
11
Page2 of 11
stamens

Page 3 4. Approximately, thirty-five (35) minutes later, Priscilla Gray sent an email to
Martin and defendants Andrew Schlafly and John Schlafly offering to publicly attack Judge
Barberis and suggesting that they ghostwrite the attacks for her:
a
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A true and accurate copy of the email sent by Priscilla Gray on August 8, 2016 is attached hereto
as Exhibit B and incorporated herein by reference.
5. Notably, a few weeks thereafter, Martin purchased a laptop and shipped it to
Priscilla Gray. A true and accurate copy of the September 14, 2016 purchase invoice is attached
hereto as Exhibit C and incorporated herein by reference.
6. On October 20, 2016, this Court entered its October 20 TRO suspending Martin
as President of Eagle Forum and enjoining him from conducting any business on behalf of Eagle
out as the President of Eagle Forum to any third party.
Forum or holding himself
Case No. 2016MRO001 11
Page3of
11
sLasoress

Page 4 7. On October 21, 2016, Priscilla Gray attacked Judge Barberis publicly on his
personal Facebook page:
(@) priscilla. Gray Tis “pro Fam” Judge Barbers is the one who
assists in the shuting down of pro-fe work by Phylis Schiafly's
organizations. He should have shut down the pro-abortion Anne
Coriwho obviously has planned to end Eagle Forum's effectiveness.
a5 a national pro-if leader. His rulings are confusing and they
stymie EF actvy in this crucial election year. Very suspicious that
Tis daughier has been coached in soccer by counsel for Anne Cori
(who told me she was pro-choice). Judge Barberis has coached
counsels daughter in soccer. A politician, he s, wih the LOWEST
ating for a judge In nos!
1y Eda
“True and accurate copies of comments posted by Priscilla Gray are attached hereto as Group
Exhibit D and incorporated herein by reference.
8 Later that evening Priscilla Gray forwarded an email containing a copy of her post
to Martin, John Schlafly, Andrew Schlafly, Bruce Schlafly and attomey Ian Northon. Within the
thread, Priscila stated:
11rd Bre pag he ators advrtin eo-Hofesy bibs. wi vero of comment nde
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Lodo Sobor a cored carats dng In srr. A plEcan hai,hs LOWEST ring gen Hilt
A true and accurate copy of the email sent by Priscilla Gray on October 21, 2016 is tached
hereto as Exhibit E and incorporated herein by reference.
Case No. 2016MRO0111
Page dof 11
sass

Page 5 9.
Martin then began drafting harassing missives attacking the October 20 TRO and
this Court and directing Priscilla Gray how to use them in a public attack on Judge Barberis:
On Fri, Oct 21, 2016at 7:44 PM, Ed Martin wrote:
Go slow and steady. Not too much of a flood. Make it organic.
‘Email his comments to others and say "is this right?”
Direct message him and play sweet / dumb... “i am not a lawyer but how can this happen?"
‘And "john and roger and others are grieving their mother's death... cant ths wait?"
On Oct 21, 2016 9:41 PM, "priscilla gray" com> wrote:
onit
On Fri, Oct 21, 2016 at 7:39 PM, Ed Martin wrote:
“Turn up the heat with others on his page. Call what he did unfair and rigged over and over.
He's doing it like hillary does ..
On Oct 21, 2016 9:38 PM, "Ed Martin” com> wrote:
Go back on his page and write "your ruling puts anne cori and her co plaintiffs in charge of
the enity they sued, Eagle Forum. How can the anne cori and the plaintiffs now be telling
the lawyers for defendant eagle forum how to defend themselves? That s not justice but a
rigged system. So, you gave them eagle forum by rigging it so anne cori is lawyer for both
sides. Shame on you and this broken legal system."
See email correspondence between Martin and Priscilla Gray on October 21, 2016, true and
accurate copies of which are attached hereto as Group Exhibit F and incorporated herein by
reference, pp. 1,3."
* Notably, the Heyl Royster REVISED Privilege Log dated May 17, 2018 contains reference to Martin's
attacks on this Court via Priscilla Gray. On October 23, 2016, Martin sen his atomey, Bary Nodlner an email
tied “Fwd: John Barberi replied to your comment on his lnk,” which is the tile of the October 21, 2016 email
chain between Martin and Priscilla Gray.
stamomess
Page Sof 11
Case No.2016MRO0111

Page 6 10. Priscilla Gray finally reported that, after repeatedly attacking Judge Barbers, she
had been blocked from further public posts on his Facebook page:
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sent
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eon
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‘well Fm blocked now. | did't see your email here lust now.
J
See Grp. Ex. F,p.1.
11. Notwithstanding Judge Barberis blocking her from publicly posting on his
personal Facebook page, Priscilla Gray confirmed to Martin that she would still be privately
messaging Martin's ghostwritten attacks to Judge Barbers:
—
So
Sobek
rdtowar
Fie, Ocoee 2,201 190 OT ©
Cananin
he Fo Bats phe tour comms cis nk.
private messaging hm that sweet ne
See Grp. Ex. F,p. 3.
Not An Isolated Incident
12. Martin's attempts to attack this Court through a surrogate (Priscilla Gray) appear
to be just one aspect of a calculated effort undertaken by Martin and others to exert improper
influence over this Court and these proceedings. These efforts include among other things,
Martin's disparagement of this Court immediately following the October 20 TRO. In fact, in a
Case No. 2016MRO00111
Page 6 of11
sLasones

Page 7 November 15, 2016 email to Martin, John Schlafly and Andy Schlafly, Bruce Schlafly (cotrustee of defendant Eagle Trust Fund and a director of EFELDF) weighed in on whether this
was proving to be a useful litigation tactic:
so
ro
Torte Noremer 15, 206 00 MST
fob Achiovni
personally would like to see the 3 of you unleash Emmett as the new c4 attomey to write,
speak, and litigate on behalf
of the new od. 1 thought his draft of his essay on the subject was
weld dos lat more good than airing public complaints about judge barberis handling of the
oldc4 case, in my opinion
Bruce
A true and accurate copy of the email sent by Bruce Schlafly on November 15, 2016 is attached
hereto as Exhibit G and incorporated herein by reference.
ARGUMENT
13. “It is well established law that all courts have the inherent power to punish
contempt; such power is essential to the maintenance of their authority and the administration of
judicial powers.” People v. Simac, 161 Ill. 2d 297, 305, 641 N.E.2d 416, 420 (1994)
14. The Illinois Supreme Court “has defined criminal contempt of court ‘as conduct
‘which is calculated to embarrass, hinder or obstruct a court in its administration of justice or
derogate from its authority or dignity, thereby bringing the administration of law into
disrepute.” People v. LAS, 111 Ill. 2d 539, 543, 490 N.E2d 1271, 1273 (1986) (quoting
People v. Javaras, 51 111. 2d 296, 299, 281 N.E:2d 670, 671 (1972)); Kaeding v. Collins, 281 Til.
App. 3 919, 924, 668 N.E.2d 572, 577 (1996); see also In re Marriage of Weddigen, 2015 IL
suas
Page 7 of 11
Case No. 2016MR0001 11

Page 8 App (4th) 150044, § 21, 42 N.E.3d 488, 495-96 (“[Clriminal contempt includes acts showing
disrespect for the court, or its orders, or processes, or tending to obstruct the administration of
justice.”) (internal citation omitted).
15. Martin's conduct in ghostwriting attacks to publicly assail this Court on Judge
Barberis’ personal Facebook page clearly demonstrates intent to embarrass, hinder and obstruct
this Court in its administration of justice. L.A.S., 111 TI 2d at 543; People v. Duf;, 2012 IL App
(5th) 100479, § 10, 970 N.E:2d 1281, 1285 (“The actions of the contemnor must be willful, as
criminal contempt requires intent.”). This is clear not only from the contemptuous conduct itself,
but from the surrounding circumstances as well. Kaeding v. Collins, 281 Ill. App. 3d 919, 924,
668 N.E.2d 572, 577 (1996) (“There need not be a specific manifestation of contemptuous intent;
rather, such intent may be inferred from the nature of the contemptuous act and surrounding
circumstances.”
16. First, as discussed above, Priscilla Gray offered to publicly attack Judge Barberis
and requested that Martin, Andrew Schlafly and John Schlafly ghostwrite drafts for such attacks.
Martin then proceeded to buy Priscilla Gray a laptop and, immediately after the receipt of the
October 20 TRO, drafted attacks for her to use publicly against Judge Barberis and this Court.
17. Second, Martin's attacks were intended to influence this Court’s decision on a
pending motion. On October 21, 2016, Eagle Forum filed a motion for supersedeas seeking to
stay the October 20 TRO. Thus, that motion was pending before this Court at the same time
TT ufient or the purposes of the present matin, the Appellate Count of ins, Fourth District
characterizes the distinction between “civil” and “criminal” as follows: “The distinction between civil and criminal
pas
or he co: of nal Tees ong. to. heat 1 pomof aon;
contempt consists of filing 0 do an ac ordered by fhe court or the benefit of another party.” In ré Marriage of
Miller, 88 11. App. 3d 370, 373, 410 N.E.24 649, 652 (1980).
Case No. 2016MRO001 11
Page§ of 11
stamoesa

Page 9 Martin was directing Priscila Gray how to admonish this Court about delaying the October 20
TRO:
On Fri, Oct 21, 2016 at 7:44 PM, Ed Martin wrote:
Go slow and steady. Not too much ofa flood. Make it organic.
Email his comments to others and say "is this right?"
Direct message him and play sweet / dumb ..."i am not a lawyer but how can this happen?”
‘And "john and roger and others are grieving their mother's death... can't this wait?"
Indeed, Martin's attacks amount to ex parte harassment ofthis Court 0 obtain a favorable ruling
on a pending motion. Such conduct perfectly encapsulates “disrespect for the court, o its orders,
or processes.” Weddigen, 2015 IL App (4th) 150044,1 21.
18. Third, Martin's attacks on Judge Barbers occurred amidst a broader litigation
strategy of “airing public complaints about judge barbers” to exert improper influence over this
Court and achieve ill-gotten results.
19. Fourth, and finally, Martin is an attomey licensed in Missouri. See Kaeding, 281
1. App. 3d at 924 (“Criminal contempt requires that the offender have actual or constructive
Knowledge of what conduct is forbidden; intent or, at least, knowledge ofthe nature of the act is
necessary.”) (emphasis added). As an officer of the court, Martin knows that attempting to
improperly influence a tribunal is forbidden. The Missouri Supreme Court Rules of Professional
Conduct, as well as the Illinois Rules of Professional Conduct, provide:
A lawyer shall not: (2) seek to influence a judge, juror, prospective juror or other
official by means prohibited by law; (b) communicate ex parte with such a person
during the proceeding unless authorized to do so by law or court order; [or] .. (4)
engage in conduct intended to disrupt a tribunal.
See Mo. Sup. Ct. R. Prof'l Conduct, R. 4-3.5; see also Il. Sup. Ct. R. Prof'l Conduct, R. 3.5.
11
Case No. 2016MRO001
Page 9 of 11
stamonese

Page 10 CONCLUSION
20. In light of the foregoing arguments and authorities, Martin should be ordered to
show cause why he should not be held in criminal contempt of this Court.
WHEREFORE, Plaintiffs Anne Cori Schlafly, Eunie Smith, Cathie Adams, Carolyn
MeLarty, Rosina Kovar and Shirley Curry respectfully request that the Court: (i) enter an Order
directing Edward R. Martin, Jr. to show cause, within five (5) days, why he should not be held in
contempt; (if) upon an insufficient showing of cause, enter an Order holding Martin in contempt
and imposing appropriate sanctions against him; and (i) grant such other or additional relief
as
the Court deems just and appropriate.
Respectfully submitted,
SPENCER FANE LLP
1s/ Erik O. Solverud
Erik O. Solverud #6231306
Megan D. Meadows #6314885
Eric D. Block #6315217
Arthur D. Gregg #6319204
IN. Brentwood Blvd. Suite 1000
St. Louis, MO 63105
(314) 863-7733
(314) 862-4636 (facsimile)
esolverud@spencerfane.com
‘mmeadows@spencerfane.com
eblock@spencerfane.com
agregg@spencerfane.com
ATTORNEYS FOR PLAINTIFFS.
11
Case No. 2016MR0001
Page 10 of11
suas

Page 11 CERTIFICATE OF SERVICE
The undersigned hereby certifies that on June 4, 2018, I electronically filed and
transmitted the foregoing document with the Clerk of the Court for the Third Judicial Circuit,
Madison County, Illinois, using File & ServeXpress system; and 1 further certify that the
individuals in this case, named below, were served this document by transmitting a copy from
‘my e-mail address to all primary and secondary e-mail addresses of record designated by those
individuals on June 4, 2018:
James P. Sanders
Barry S. Noeltner
Jessica A. Powers
Richard K. Hunsaker
Zachary R. McMichael
Alisha Sheehan
SmithAmundsen LLC
Heyl, Royster, Voelker & Allen
1205. Central Ave, Suite 700
105 West Vandalia Street, Suite 100
St. Louis, MO 63105
Edwardsville, IL 62025
jsanders@salavwus.com
broeltner@heylroyster
com
Ipowers@salawus.com
thunsaker@heylroyster.com
zmemichacl@salawus.com
ashechan@heylroyster.com
Attorneys for Defendant Eagle Forun
Attorneys for Defendants
EdwardR. Martin, Jr. and John F. Schlafly
Nelson L. Mitten
Paul A. Grote
Riezman Berger, P.C.
7700 Bonhomme, 7" Floor
St. Louis, MO 63105
nlm@riezmanberger.com
pag@riezmanberger.com
Attorneys for Defendants Eagle Trust Fund,
Eagle Forum Education and Legal Defense
Fund, Kathleen Sullivan, Estate of Phyllis
M. Schlafly and Andrew L. Schlafly
Case No. 2016MRO001 11
Curtis Niewald
Farrell & Martin
220 Salt Lick Road
St. Peters, MO 63375
com
Curtis@farrellandmartin
Attorneys for Defendant Eagle Trust Fund by
and through its Co-Trustees
_Is/
Michelle
M. Delaney
Page 11 of 11
Stamos

Page 12 secs
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Welost Outrageous. Call me.
errr Forwarded message rw
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rovsterhey
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‘Subject: Order re: Motion to Disqualfy [IWOV-HRVA FID2593220)
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the Court
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attached for your file and review. It is very unfortunate to say that adopted Spencer Fane's proposed order,not
‘agree with this ruling. It should be noted that the Judge almost wholly
‘except for changing paragraph 24.
Order was
Lalked to Barry, and hei incredibly displeased with the timing of the Order. As you'll ses,tthe
was not until this
entered on July 28, 2016. However, we never received a copy of the Order from the Court.entered
and 1 wen fo
that an order had been
‘morning that the Court made a notation on the online docket sheetpurpose.
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Exhibit A
‘SUBJECT TO AGREED PROTECTIVE ORDER
MARTINJSCHLAFLY-00565261

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On Wed, Sep 14, 2016 at 11:20 AM, priscilla gray wrote:
‘Computer Receipt fom Newegg.
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at 9:28 AM
Date: Wed, Sep 14, 2016
Subject: 266071823
To: *Puray9!1 @samail com”
Dear Edward R Martin Jr,
Thank you for shopping at Newegs.
a apy for you record,
This 5 the invoke and receipt for your recent order. Please keep
Invoice Summary:
Your Sales Order Number: 266071623
Order Date: 07/25/2016
Order Totals $425.47
Billing Information
Eaward & Martin
p.0.80x 618
alton, 62002
United states
s18-a62.5015
Exhibit C
TO AGREED PROTECTIVE ORDER
‘SUBJECT
MARTINJSCHLAFLY-00215894

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On Fri, Oct 21, 2016 at 7:44 PM, Ed Martin Go slow and steady. Not too much ofa flood. Make it organic.
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On Fri, Oct 21, 20168 7:39 PM, Ed Martin “Turn up the heat with others on his page. Call what he did unfir and rigged over and over.
He's doing it ike hillary does
com> wrote:
On Oct 21, 2016 9:38 PM, "Ed Martin" anne cori and hr co plaintifs in charge of
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PDF Page 1	PlainSite Cover Page

PDF Page 2	IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS ANNE SCHLAFLY CORI etal, ) Plaintiffs, ) v. ) Cause No. 2016MRO00I11 EDWARD R. MARTIN, JR. tal, ) Defendants. J PLAINTIFFS’ MOTION FOR ORDER TO SHOW CAUSE WHY DEFENDANT EDWARD R. MARTIN, JR. SHOULD NOT BE HELD IN CRIMINAL CONTEMPT OF COURT Plaintiffs Anne Cori Schlafly, Eunie Smith, Cathie Adams, Carolyn McLarty, Rosina Kovar and Shirley Curry (“Plaintiffs”), respectfully request that the Court enter an Order requiring Defendant Edward R. Martin, Jr. (“Martin”) to show cause why he should not be held in criminal contempt of this Court. In support oftheir motion, Plaintiffs state as follows: INTRODUCTION 1. Plaintiffs first served requests for production on Martin and John Schlafly on May 10, 2016. After nearly 2 years of delay, an agreed order, numerous conferral letters, enforcement motions and hearings, this Court ordered on March 29, 2018 that Martin and John Schlafly must produce responsive documents. Since April 19, 2018, Martin and defendant John Schlafly have electronically produced documents on a rolling basis. This document production, ‘which is still incomplete and undergoing review by Plaintiffs’ counsel, has nonetheless disclosed an underhanded scheme, orchestrated and carried out by Martin, to attack the integrity and authority of this Court, prevent the administration of justice and bring the practice of law into disrepute. Specifically, after an Order from this Court on October 20, 2016 (the “October 20 TRO”), Martin drafted attacks against this Court and directed his surrogate, Priscilla Gray, to Case No. 2016MR0001 11 Page Lof11 suaa0nsse

PDF Page 3	assail Judge Barberis publicly on social media in an effort to disparage this Court and improperly influence its rulings. This conduct goes well beyond merely expressing disappointment in a ruling by this Court. Martin's conduct amounted to ex parte communications with this Court ‘which sought to improperly influence ruling on a pending motion. In light of such conduct, ‘which first became known to Plaintiffs upon review of the electronic documents recently produced by Martin and John Schlafly, Plaintiffs request that this Court require Martin to show cause why he should not be held in criminal contempt of this Court FACTS Priscilla Gray Offers To Attack This Court 2. On July 28, 2016, this Court entered its Order denying Martin's Motion to Disqualify Plaintiffs’ Counsel Spencer Fane, LLP; Erik O. Solverud; Megan D. Meadows; and Arthur D. Gregg (the “July 28 Order”). Because the July 28 Order was distributed to the parties via U.S. Mail, Plaintiffs did not receive a copy of the Order until August 8, 2016. 3. On August, 2016, Martin sent an email to Priscilla Gray, a former employee of defendant Eagle Forum Education & Legal Defense Fund (“EFELDF”), attaching the July 28 Order: P————— ———————————— Pe i En Welost Ouageous, Call me. A true and accurate copy of the email sent by Martin on August 8, 2016 is attached hereto as Exhibit A and incorporated herein by reference. Case No. 2016MR0001 11 Page2 of 11 stamens

PDF Page 4	4. Approximately, thirty-five (35) minutes later, Priscilla Gray sent an email to Martin and defendants Andrew Schlafly and John Schlafly offering to publicly attack Judge Barberis and suggesting that they ghostwrite the attacks for her: a ky eons po a heb chlc baa0 dg Now wo rw wit i ge von. bookmay hve ben Teh GPs ar haar 4 ue somatin te hn i ply ronan ons copy 1h ates 1 ot oatack samba plfct coward) a at Wo couaavo mado is vacation mdb Temi mgs coms Too acaion UNC aon and hae riod acces fo i et anager prot Tame A true and accurate copy of the email sent by Priscilla Gray on August 8, 2016 is attached hereto as Exhibit B and incorporated herein by reference. 5. Notably, a few weeks thereafter, Martin purchased a laptop and shipped it to Priscilla Gray. A true and accurate copy of the September 14, 2016 purchase invoice is attached hereto as Exhibit C and incorporated herein by reference. 6. On October 20, 2016, this Court entered its October 20 TRO suspending Martin as President of Eagle Forum and enjoining him from conducting any business on behalf of Eagle out as the President of Eagle Forum to any third party. Forum or holding himself Case No. 2016MRO001 11 Page3of 11 sLasoress

PDF Page 5	7. On October 21, 2016, Priscilla Gray attacked Judge Barberis publicly on his personal Facebook page: (@) priscilla. Gray Tis “pro Fam” Judge Barbers is the one who assists in the shuting down of pro-fe work by Phylis Schiafly's organizations. He should have shut down the pro-abortion Anne Coriwho obviously has planned to end Eagle Forum's effectiveness. a5 a national pro-if leader. His rulings are confusing and they stymie EF actvy in this crucial election year. Very suspicious that Tis daughier has been coached in soccer by counsel for Anne Cori (who told me she was pro-choice). Judge Barberis has coached counsels daughter in soccer. A politician, he s, wih the LOWEST ating for a judge In nos! 1y Eda “True and accurate copies of comments posted by Priscilla Gray are attached hereto as Group Exhibit D and incorporated herein by reference. 8 Later that evening Priscilla Gray forwarded an email containing a copy of her post to Martin, John Schlafly, Andrew Schlafly, Bruce Schlafly and attomey Ian Northon. Within the thread, Priscila stated: 11rd Bre pag he ators advrtin eo-Hofesy bibs. wi vero of comment nde oprah EOWA Pt dev ofp ory Phys Sts va. Fay ig Gober he ne who ests onsshut is pans 1 nd Eig Fos stein.He sho move Shidoho rationcordingGatadwh eycoiculy eer. sl EF achin i calwesocio aa Hi nog vaneay akonl re oe Sho). ro ash 5 (4h Cor And ary pion hte oht kbas cnhd soct oy ounl fr Lodo Sobor a cored carats dng In srr. A plEcan hai,hs LOWEST ring gen Hilt A true and accurate copy of the email sent by Priscilla Gray on October 21, 2016 is tached hereto as Exhibit E and incorporated herein by reference. Case No. 2016MRO0111 Page dof 11 sass

PDF Page 6	9. Martin then began drafting harassing missives attacking the October 20 TRO and this Court and directing Priscilla Gray how to use them in a public attack on Judge Barberis: On Fri, Oct 21, 2016at 7:44 PM, Ed Martin wrote: Go slow and steady. Not too much of a flood. Make it organic. ‘Email his comments to others and say "is this right?” Direct message him and play sweet / dumb... “i am not a lawyer but how can this happen?" ‘And "john and roger and others are grieving their mother's death... cant ths wait?" On Oct 21, 2016 9:41 PM, "priscilla gray" wrote: onit On Fri, Oct 21, 2016 at 7:39 PM, Ed Martin wrote: “Turn up the heat with others on his page. Call what he did unfair and rigged over and over. He's doing it like hillary does .. On Oct 21, 2016 9:38 PM, "Ed Martin” wrote: Go back on his page and write "your ruling puts anne cori and her co plaintiffs in charge of the enity they sued, Eagle Forum. How can the anne cori and the plaintiffs now be telling the lawyers for defendant eagle forum how to defend themselves? That s not justice but a rigged system. So, you gave them eagle forum by rigging it so anne cori is lawyer for both sides. Shame on you and this broken legal system." See email correspondence between Martin and Priscilla Gray on October 21, 2016, true and accurate copies of which are attached hereto as Group Exhibit F and incorporated herein by reference, pp. 1,3." * Notably, the Heyl Royster REVISED Privilege Log dated May 17, 2018 contains reference to Martin's attacks on this Court via Priscilla Gray. On October 23, 2016, Martin sen his atomey, Bary Nodlner an email tied “Fwd: John Barberi replied to your comment on his lnk,” which is the tile of the October 21, 2016 email chain between Martin and Priscilla Gray. stamomess Page Sof 11 Case No.2016MRO0111

PDF Page 7	10. Priscilla Gray finally reported that, after repeatedly attacking Judge Barbers, she had been blocked from further public posts on his Facebook page: —_—nm fom er sent Fim, October 21.206 659M COT Tw eon Sled Reb ho Sst ped you commer on ik. ‘well Fm blocked now. \| did't see your email here lust now. J See Grp. Ex. F,p.1. 11. Notwithstanding Judge Barberis blocking her from publicly posting on his personal Facebook page, Priscilla Gray confirmed to Martin that she would still be privately messaging Martin's ghostwritten attacks to Judge Barbers: — So Sobek rdtowar Fie, Ocoee 2,201 190 OT © Cananin he Fo Bats phe tour comms cis nk. private messaging hm that sweet ne See Grp. Ex. F,p. 3. Not An Isolated Incident 12. Martin's attempts to attack this Court through a surrogate (Priscilla Gray) appear to be just one aspect of a calculated effort undertaken by Martin and others to exert improper influence over this Court and these proceedings. These efforts include among other things, Martin's disparagement of this Court immediately following the October 20 TRO. In fact, in a Case No. 2016MRO00111 Page 6 of11 sLasones

PDF Page 8	November 15, 2016 email to Martin, John Schlafly and Andy Schlafly, Bruce Schlafly (cotrustee of defendant Eagle Trust Fund and a director of EFELDF) weighed in on whether this was proving to be a useful litigation tactic: so ro Torte Noremer 15, 206 00 MST fob Achiovni 1 personally would like to see the 3 of you unleash Emmett as the new c4 attomey to write, speak, and litigate on behalf of the new od. 1 thought his draft of his essay on the subject was weld dos lat more good than airing public complaints about judge barberis handling of the oldc4 case, in my opinion Bruce A true and accurate copy of the email sent by Bruce Schlafly on November 15, 2016 is attached hereto as Exhibit G and incorporated herein by reference. ARGUMENT 13. “It is well established law that all courts have the inherent power to punish contempt; such power is essential to the maintenance of their authority and the administration of judicial powers.” People v. Simac, 161 Ill. 2d 297, 305, 641 N.E.2d 416, 420 (1994) 14. The Illinois Supreme Court “has defined criminal contempt of court ‘as conduct ‘which is calculated to embarrass, hinder or obstruct a court in its administration of justice or derogate from its authority or dignity, thereby bringing the administration of law into disrepute.” People v. LAS, 111 Ill. 2d 539, 543, 490 N.E2d 1271, 1273 (1986) (quoting People v. Javaras, 51 111. 2d 296, 299, 281 N.E:2d 670, 671 (1972)); Kaeding v. Collins, 281 Til. App. 3 919, 924, 668 N.E.2d 572, 577 (1996); see also In re Marriage of Weddigen, 2015 IL suas Page 7 of 11 Case No. 2016MR0001 11

PDF Page 9	App (4th) 150044, § 21, 42 N.E.3d 488, 495-96 (“[Clriminal contempt includes acts showing disrespect for the court, or its orders, or processes, or tending to obstruct the administration of justice.”) (internal citation omitted). 15. Martin's conduct in ghostwriting attacks to publicly assail this Court on Judge Barberis’ personal Facebook page clearly demonstrates intent to embarrass, hinder and obstruct this Court in its administration of justice. L.A.S., 111 TI 2d at 543; People v. Duf;, 2012 IL App (5th) 100479, § 10, 970 N.E:2d 1281, 1285 (“The actions of the contemnor must be willful, as criminal contempt requires intent.”). This is clear not only from the contemptuous conduct itself, but from the surrounding circumstances as well. Kaeding v. Collins, 281 Ill. App. 3d 919, 924, 668 N.E.2d 572, 577 (1996) (“There need not be a specific manifestation of contemptuous intent; rather, such intent may be inferred from the nature of the contemptuous act and surrounding circumstances.” 16. First, as discussed above, Priscilla Gray offered to publicly attack Judge Barberis and requested that Martin, Andrew Schlafly and John Schlafly ghostwrite drafts for such attacks. Martin then proceeded to buy Priscilla Gray a laptop and, immediately after the receipt of the October 20 TRO, drafted attacks for her to use publicly against Judge Barberis and this Court. 17. Second, Martin's attacks were intended to influence this Court’s decision on a pending motion. On October 21, 2016, Eagle Forum filed a motion for supersedeas seeking to stay the October 20 TRO. Thus, that motion was pending before this Court at the same time TT ufient or the purposes of the present matin, the Appellate Count of ins, Fourth District characterizes the distinction between “civil” and “criminal” as follows: “The distinction between civil and criminal pas or he co: of nal Tees ong. to. heat 1 pomof aon; contempt consists of filing 0 do an ac ordered by fhe court or the benefit of another party.” In ré Marriage of Miller, 88 11. App. 3d 370, 373, 410 N.E.24 649, 652 (1980). Case No. 2016MRO001 11 Page§ of 11 stamoesa

PDF Page 10	Martin was directing Priscila Gray how to admonish this Court about delaying the October 20 TRO: On Fri, Oct 21, 2016 at 7:44 PM, Ed Martin wrote: Go slow and steady. Not too much ofa flood. Make it organic. Email his comments to others and say "is this right?" Direct message him and play sweet / dumb ..."i am not a lawyer but how can this happen?” ‘And "john and roger and others are grieving their mother's death... can't this wait?" Indeed, Martin's attacks amount to ex parte harassment ofthis Court 0 obtain a favorable ruling on a pending motion. Such conduct perfectly encapsulates “disrespect for the court, o its orders, or processes.” Weddigen, 2015 IL App (4th) 150044,1 21. 18. Third, Martin's attacks on Judge Barbers occurred amidst a broader litigation strategy of “airing public complaints about judge barbers” to exert improper influence over this Court and achieve ill-gotten results. 19. Fourth, and finally, Martin is an attomey licensed in Missouri. See Kaeding, 281 1. App. 3d at 924 (“Criminal contempt requires that the offender have actual or constructive Knowledge of what conduct is forbidden; intent or, at least, knowledge ofthe nature of the act is necessary.”) (emphasis added). As an officer of the court, Martin knows that attempting to improperly influence a tribunal is forbidden. The Missouri Supreme Court Rules of Professional Conduct, as well as the Illinois Rules of Professional Conduct, provide: A lawyer shall not: (2) seek to influence a judge, juror, prospective juror or other official by means prohibited by law; (b) communicate ex parte with such a person during the proceeding unless authorized to do so by law or court order; [or] .. (4) engage in conduct intended to disrupt a tribunal. See Mo. Sup. Ct. R. Prof'l Conduct, R. 4-3.5; see also Il. Sup. Ct. R. Prof'l Conduct, R. 3.5. 11 Case No. 2016MRO001 Page 9 of 11 stamonese

PDF Page 11	CONCLUSION 20. In light of the foregoing arguments and authorities, Martin should be ordered to show cause why he should not be held in criminal contempt of this Court. WHEREFORE, Plaintiffs Anne Cori Schlafly, Eunie Smith, Cathie Adams, Carolyn MeLarty, Rosina Kovar and Shirley Curry respectfully request that the Court: (i) enter an Order directing Edward R. Martin, Jr. to show cause, within five (5) days, why he should not be held in contempt; (if) upon an insufficient showing of cause, enter an Order holding Martin in contempt and imposing appropriate sanctions against him; and (i) grant such other or additional relief as the Court deems just and appropriate. Respectfully submitted, SPENCER FANE LLP 1s/ Erik O. Solverud Erik O. Solverud #6231306 Megan D. Meadows #6314885 Eric D. Block #6315217 Arthur D. Gregg #6319204 IN. Brentwood Blvd. Suite 1000 St. Louis, MO 63105 (314) 863-7733 (314) 862-4636 (facsimile) esolverud@spencerfane.com ‘mmeadows@spencerfane.com eblock@spencerfane.com agregg@spencerfane.com ATTORNEYS FOR PLAINTIFFS. 11 Case No. 2016MR0001 Page 10 of11 suas

PDF Page 12	CERTIFICATE OF SERVICE The undersigned hereby certifies that on June 4, 2018, I electronically filed and transmitted the foregoing document with the Clerk of the Court for the Third Judicial Circuit, Madison County, Illinois, using File & ServeXpress system; and 1 further certify that the individuals in this case, named below, were served this document by transmitting a copy from ‘my e-mail address to all primary and secondary e-mail addresses of record designated by those individuals on June 4, 2018: James P. Sanders Barry S. Noeltner Jessica A. Powers Richard K. Hunsaker Zachary R. McMichael Alisha Sheehan SmithAmundsen LLC Heyl, Royster, Voelker & Allen 1205. Central Ave, Suite 700 105 West Vandalia Street, Suite 100 St. Louis, MO 63105 Edwardsville, IL 62025 jsanders@salavwus.com broeltner@heylroyster com Ipowers@salawus.com thunsaker@heylroyster.com zmemichacl@salawus.com ashechan@heylroyster.com Attorneys for Defendant Eagle Forun Attorneys for Defendants EdwardR. Martin, Jr. and John F. Schlafly Nelson L. Mitten Paul A. Grote Riezman Berger, P.C. 7700 Bonhomme, 7" Floor St. Louis, MO 63105 nlm@riezmanberger.com pag@riezmanberger.com Attorneys for Defendants Eagle Trust Fund, Eagle Forum Education and Legal Defense Fund, Kathleen Sullivan, Estate of Phyllis M. Schlafly and Andrew L. Schlafly Case No. 2016MRO001 11 Curtis Niewald Farrell & Martin 220 Salt Lick Road St. Peters, MO 63375 com Curtis@farrellandmartin Attorneys for Defendant Eagle Trust Fund by and through its Co-Trustees _Is/ Michelle M. Delaney Page 11 of 11 Stamos

PDF Page 13	secs Ft Oe re tonto Dont OUR FBS Welost Outrageous. Call me. errr Forwarded message rw com> rovsterhey ‘From: "AlishaL. Biesinger" 79) @amail nt To: "Ed Martin" . "Barry $. Noslner”

PDF Page 14	PR———— [pee— ove sss he avscmn A T— SUBJECT TO AGREED PROTECTIVE ORDER WARTINISCHLAFLY 0886242

PDF Page 15	— sone pe Mardin Aus 2016 1.05 dy Ser 8 ce pasty ae “Tis Judge. wow Now we know a Aberal Judge may have been the beter choice Well GOP are iberals—Phylls wrote the book. somethingto aftack ths judge. As a non involved party \| vil happy itething to fot copy the parts on tis. scumbag hata major cowardly pofical We could have made i vacation miserable Help me by drafting someting. Iwi sand tto my press contacts.and have ited access to wif at onagenarian paronis' homo. mon vacaton in VAIDC area TO AGREED PROTECTIVE ORDER ‘SUBJECT MARTIN-JSCHLAFLY-00187705

PDF Page 16	eee ——— Wedsest, Sse 14,2016 1135341 COT sor sabes ery Thanks. El On Wed, Sep 14, 2016 at 11:20 AM, priscilla gray wrote: ‘Computer Receipt fom Newegg. —ermeeen- Forwarded message = at 9:28 AM Date: Wed, Sep 14, 2016 Subject: 266071823 To: *Puray9!1 @samail com” Dear Edward R Martin Jr, Thank you for shopping at Newegs. a apy for you record, This 5 the invoke and receipt for your recent order. Please keep Invoice Summary: Your Sales Order Number: 266071623 Order Date: 07/25/2016 Order Totals $425.47 Billing Information Eaward & Martin p.0.80x 618 alton, 62002 United states s18-a62.5015 Exhibit C TO AGREED PROTECTIVE ORDER ‘SUBJECT MARTINJSCHLAFLY-00215894

PDF Page 17	Shipping formation orca Gray 2400 2005t ox?Huene me ort CA 83041-2923 Unites ses presvne:r) y + SRR e ee —_ e————————— Invoice Number: 11153504 Invaico Date: 712612016 13:02:25Wt tem st Fe 1s15 HOsoatea7 Laptop Lenovo 36. WindowsGB 6.1 Touehicreen1.70 Gr) 4400Cor156°15 42100 GraphsIne TS 1 Sinan Tio. Eran BURA gcc ase Racycing AS 34 Match Quaid ts rice 8:53 NOTE 34:21 Teese se osm seo 10 sow Payment summary: TO AGREED PROTECTIVE ORDER ‘SUBJECT MARTINJSCHLAFLY-00216895

PDF Page 18	Paymant Term: visa Subtotals $2.99 I Giftwrap: Shipping and Handling: Total Sip Austen: $-52.57 S850 5000 sus Eggpoints: 000 Total Amount: sa25.47 Newegg 2001 racking Your Order: S09502426181 Us Bias. you have any questions o need further assistance, leas vist our Customer Service Contac TO AGREED PROTECTIVE ORDER SUBJECT MARTIN-JSCHLAFLY-00215896

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PDF Page 24	———— —_ br a—— —— forepaNm pe by rin comme canto toyo as het met Tones wel im backed now. \| dit so your email hrs ust now. com> wrote: 91 @gmail inl On Fri, Oct 21, 2016 at 7:44 PM, Ed Martin ant com> wrote: 191 @gmail rin] On Fri, Oct 21, 20168 7:39 PM, Ed Martin wrote: On Oct 21, 2016 9:38 PM, "Ed Martin" wrote 9:31emall 21, 2016 On Oct have "dont Rogers You can see my pest 0 which he repli dow belo. cere. Forwarded message =r @facebooknail com> Group Exhibit F T0 AGREED PROTECTIVE ORDER ‘SUBJECT MARTIN-JSCHLAFLY-00253724

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PDF Page 26	. _—r fo — i FOP Jr . pivte messaging him hat sweat ine On Fr, Oct 21, 2016 at 7:44 PM, E4 Martin wioe: Goslow and seady. Not too much ofa flood. Make it argaric. Email his comments to thers and say is tis right?” Direct message him and play sweet/ dumb..." am nota lawyer but how can this happen” ‘And john and roger and thers ae grieving thet mother’s death. can his wait?" s) wote: @email com> On Oct 21, 2016 9:41 PM, “priscill gry” para nit On Fri, Oct 21, 2016 at 7:39 PM, Ed Martin wrote: “Turn up the heat with others on his page. Call hat he did unfair and rigged over and over. He's doing it ike hillary docs com> wrote: riol 791 @amail On Oct 21, 20169:38 PM, "Ed Martin” 21, 2016 9:31 PM, "priscils gry”

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PDF Page 28	EEN aI EE Vom eet AM CST ber 15, 208 1606 Turia, Nover sont Io SE, dy Shut Ems an Arran aes sues 1 personally would like to se the 3 of you unleash Emmett as the new c4 attomey to write, speak, and litigate on behalf of the new od. I thought his draft of his essay on the subject was. good. This would do a lot more good than airing public complaints about judge barberis handling of the. old c4 case, in my opinion Bruce ‘Sent from Yahoo Mail for iPhone Exhibit G TO AGREED PROTECTIVE ORDER ‘SUBJECT MARTIN-JSCHLAFLY-00688232


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