Claimants Whistleblower Declaration & Objection To Arbitrators Order

The 10 Whistleblower Documents are discribed in Ex.
4 P38
1 SHARON O’DONNELL
2
[email protected]
287 S. ROBERTSON BLVD, #102
3 BEVERLY HILLS
CA, 90211
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Telephone: 213-980-0295
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6 Plaintiff, In Pro Per
9 JAMS
10 COUNTY OF LOS ANGELES
11
SHARON O’DONNELL, An Individual ) CASE NO. 1220070146

12
)
Plaintiff, )
13 vs. )
RIOT GAMES, INC. a business entity, form )
14 ) CLAIMANTS WHISTLEBLOWER
unknown, NICHOLAS LAURENT, an ) DECLARATION & OBJECTION TO
individual, and DOES 1 through 100 ) ARBITRATORS ORDER
15 )
inclusive,
)
16 Defendants. Arbitrator: Joel Grossman
)
)
17 ) Action filed: January 7th, 2021
)
18 )
)
19 )
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OBJECTION TO ARBITRATORS ORDER

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CLAIMANT, SHARON O’DONNELL’S WHISTLEBLOWER DECLARATION
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4 I, SHARON O’DONNELL, declare and state as follows:
5 1. I am the CLAIMANT in the above-captioned matter. I have personal knowledge of the facts
6 set forth in this declaration, and if called as a witness, I could and would competently testify to
7 them. The facts stated herein are true to the best of my knowledge, except as to those
8 matters stated on information and belief, and as to those matters, I believe them to be true.
9 2. Attached hereto as Exhibit 1 is this tribunal's sanctions award/order (“sanctions order”) of
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October 22, 2024 which I received via postal mail on or around October 26th, 2024. This
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orders me to pay $20,000 to respondents for my alleged publication of around “10
12 whistleblower documents” and return and delete (“destroy”) documents which respondents
13 designated as confidential or highly confidential, sent to me during the discovery of this case
14 which they claim were the subject of a protective order.
15 3. Attached hereto as Exhibit 2 is the original Protective order (“protective order”) on which the
16 sanctions are based. I only saw this document for the first time on or around June 14th,
17 2024—a week after my publications. This document was never signed by me nor was it
18 shared with me prior to June 14th, 2024. Nor does it state that sanctions would be imposed
19 for any violations. I was never provided the opportunity to contest any confidential or highly
20 confidential designations. I shared all these facts with this tribunal.
21 4. Attached hereto as Exhibit 3 is the Removal Order dated June 12, 2024 (“Removal Order”).
22 This order informed me that I would face sanctions if I did not comply with its directives. In
23 response, I immediately complied, unpublishing ALL materials regardless of any claims of
24 ownership, as I felt intimidated and threatened by the Respondents—To the extent that I
25 sought ex parte relief in the Superior Court. Attached hereto as Exhibit 8 is a copy of my Ex
26 Parte papers.
CLAIMANTS WHISTLEBLOWER DECLARATION

1 5. The “Sanctions order” orders me to remove any current publications but as already explained
2
to this tribunal, I immediately unpublished ALL materials on or around June 12th, 2024 upon
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receiving this tribunal's “removal order”—regardless of any alleged confidential designations
4 by respondents.
5 6. I will petition the Superior Court to vacate the “sanctions order” on multiple grounds for
6 vacatur and the matter is due to be heard on or before December 2nd, 2024.
7 7. In the interim I cannot pay the $20,000 as I am in receipt of no income. Although my rate as a
8
Business Development Executive exceeds $1,000 per hour, I have been focused on national
9 development including projects to help unlock third world countries from receiving Foreign
10 Direct Investment which can take 3–5 years before revenue is realized. Additionally, due to
11 the ongoing retaliation and defamation of me based on lies by the respondents—it has
12 hindered my ability to earn a living.
13 8. Between June 7th and June 12th, 2024, I allegedly published around “10 whistleblower
14 documents”—claimed to be subject of the protective order on which the sanctions are based.
15 My publications of June 7th, 2024 included an open letter to Congress, supported by two
16 books of evidence.
17 9. Respondents claimed I published “200 documents” subject to the protective order but upon
18 examination of Katherine Smith's “Violation index”-—the index was inflated with a repeat of
19 the same Bates numbers several times and only includes around 10 documents that I did not
20 have my own original copies of—established in discovery. I refer to these documents as “10
21 whistleblower documents”. Attached hereto as EXHIBIT 4 is an Index and description of these
22 “10 whistleblower documents”.
23 10. Any documents I allegedly published boil down to these “10 whistleblower documents” and
24 such documents are evidence of defendants violations of the the following laws;
25 i. CA Penal Code §118 (perjury)
26 ii. CA Penal Code §132 (presentation of false or ante-dated evidence)

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1 iii. CA Penal Code §134 (preparation of false or ante-dated evidence)
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iv. CA Penal Code §182(a)(5) (obstruction of justice)
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v. FEHA Violations (Quid Pro Quo, Harassment, Retaliation)
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vi. CA Rules of Professional Conduct; Rule 3.3 (false statements by a lawyer)
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11. Defendants' violations of these laws are all supported by an overwhelming volume of
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evidence—5 files to be exact—which have been uploaded to the Superior Court. These
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violations are well established in Plaintiffs (1) Motion for Referral for Criminal Investigation, (2)
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Amended Petition to Vacate Arbitration Award and (3) Amended Opposition to Defendant's
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Petition to Confirm Arbitration Award . These “10 whistleblower documents” are also evidence
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of defamation of claimant which included over three smear campaigns between
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2021–2024–-outlined in (1) Claimants opposition to Respondent's Motion for Sanctions and
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(2) Claimants Open letter to Congress.
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12. Some examples of the defendant's unlawful behavior were captured in her open letter to
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Congress on June 7th, 2024 but since then have been further detailed in Claimants Motion
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for Referral for Criminal Investigation—For example Page 18-19 captures how both
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Laurent and Higgs (“HR Business Partner”) falsely testified that Claimant was made aware of
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“complaints” during the course of her employment which was not true to the extent that at
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least nine pieces of evidence irrefutably contradict this testimony. I uploaded this evidence
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within my five files of evidence with the Superior court.
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13. Additionally, Higgs testified that she prepared a compilation of “complaints” about Claimant
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during her employment—the document was identified on record as Ex. 133 [See Arbitration
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Exhibit list establishing this document as Bates 1160-1171]. The document appeared to
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be notes by Higgs regarding feedback about Claimants Communications that began to
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accumulate towards late 2019 from Claimants concerned coworkers. Higgs testified about
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each piece of feedback in her compilation explaining that she took notes from People who
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“complained” about Claimant, further explaining: “So the red text is specifically from what team or
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1 person that was from” (Arbitration Transcript, Day 4, at 1013:23–1022:24). Higgs testified she
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then emailed her compilation as an attachment in her email to Laurent on February 4th, 2020
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(Arbitration Day 4, at Tr.1022:25-1024:20). This testimony was false because at least two
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pieces of “feedback entries” on the compilation couldn’t have even been on the compilation at
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the time due to the date of origination being post February 4th, 2020. Furthermore another
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“feedback entry” on the compilation was noted as coming from “Comms” but upon post
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investigation it appears to be an identical extract from Laurent’s email to HR [Bates
8
1440]—-the email header is in french and matches. It's clear that Higgs fabricated Bates
9 1440 to make it look like it came from a “Comms” professional and then included it on her
10 compilation to fabricate evidence against Claimant. She never provided any evidence to
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support that these individuals reported feedback to her regarding the “highlight
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communications” on her compilation. However the compilation now establishes SEVERAL
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fabrications—both preparation and presentation of false or ante-dated evidence for a legal
14 proceeding in violation of CA Penal Code §132 and CA Penal Code §134. (Arbitration Day 4,
15
Testimony of Higgs, at Tr.1022:25-1024:1):
16
Q; So with 133, what did you do to this compilation?
17 A; I sent it to Nicolo. I wanted him to have everything in place that I had received.
Q: So let's turn to Exhibit 140….[Referring to BATES 1235] What is this email that you
18 sent to Nicolo on February 4, 2020?
A: This was the collection that we had just talked about, a collection of feedback I was
19 sending to him, and we call it a TLDR, but it's to give a high level summary of all the
people, all the teams and the issues that are being raised about Shari.
20 Q: So what was the, as you put it, TLDR here?
A: That she had not been responding to feedback, that it continues to pour in, and that
21 it's deeply concerning.
Q: Okay. And there's a hyperlink to the here portion. Is that hyperlinking the exhibit that
22 we just discussed?
A: Yes.
23 Q: Okay. Great. And Nicolo responds –
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14. Another example of the falsehoods I exposed concerns Laurent’s testimony regarding his trip
25 to Deer Valley in Summer 2019. Laurent testified that he remained in Deer Valley due to a
26 health issue and his counsel pleaded that upon his eventual return to Los Angeles, his father
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1 was at home. This testimony was intended to counter my claim that Laurent had arranged for
2 his family to be out of town and invited me over with the expectation of engaging in sexual
3 relations. However, Laurent’s testimony was false to the extent of perjury. In my Motion for
4 Referral for Criminal Investigation, pages 5-8, it substantiates with over eight pieces of
5 evidence (uploaded in evidence with the Superior court) that Laurent did indeed return home
6 alone during the period in question, despite his health issue, and that his father was never
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home during that period as Laurent had organized an extensive road trip for him—(Testimony
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of Laurent; Tr. 981:18-983:4); “except she forgot that it ended up not happening because I ended up
9 having an injury in Deer Valley, and I stayed in surgery in Park City. So the only time I came later was
10 because my dad was coming. And so there was no moment where I was alone at my house in that
11 summer. Although it was planned”. “But the situation was not even possible of what she's claiming”.
12 15. In my publications of June 7th, 2024 I was reporting the unlawful conduct to government and
13 law enforcement agencies–And made the tribunal aware of this.
14 16. I am a whistleblower protected under California Labor Code sections 1102.5 and 1106, as
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well as California Civil Code section 52.1 (the Bane Act).
16 17. I believe the “Sanctions Order” and other tactics deployed on me, spearheaded by defendants
17 Riot Games and Nicolo Laurent and their counsel, are an attempt to cover up (1) their
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unlawful conduct and (2) their continued efforts to prevent me from speaking out about their
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conduct.
20 18. I believe the enforcement of the “Sanctions order”, at any stage, could result in me being
21 charged with misdemeanors—Specifically the evidence destruction request. I understand that
22 if I destroy this evidence I will be in violation of Penal Code § 135 and 18 U.S.C. § 1519
23 which are misdemeanors.
24 19. I explained to this tribunal that these 10 documents were required for legal proceedings and
25 an investigation, and that these documents were reporting crimes and unlawful behavior to
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1 government and law enforcement agencies. I informed this tribunal that any request for me to
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destroy evidence would violate Penal Code § 135 and 18 U.S.C. § 1519.
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20. Attached hereto as EXHIBIT 5 are JAMS confirmation uploads which is evidence that I
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provided this tribunal with my (1) Motion for Criminal Investigation and my (2) open letter to
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congress outlining all of these findings.
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21. On October 28, 2024, the Superior court denied my motion for referral for criminal
7 investigation and my motion to enjoin the defendants as my filings were not legally or factually
8 sound. For example, The Honorable Elihu M. Berle stated “The motion for referral contains no
9 table of authorities as required by California Rule of Court 3.1113” (Tr. Oct. 28, 2024,
10 17:17–19). I understand that this denial has nothing to do with the substance of evidence to
11 establish the violations of the law committed by respondents—it’s merely a reflection of the
12 fact that I am a pro se litigant as my evidence to prove the perjury and evidence fabrication is
13 overwhelming but my ability to assert my rights and argue as a state bar level is limited.
14 Instead, the evidence I have gathered to support my claims will be addressed more
15 appropriately in my petition to vacate the arbitration award (of May 7th, 2024), due to be
16 heard on December 20, 2024.
17 22. As of November 1st, 2024 I have not received Defendant's evidence to support their claims of
18 my alleged publications of documents subject to the protective order—(See email
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correspondence between Claimant and Counsel regarding this (Exhibit. 6 & 7).
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23. I brought to this tribunal's attention that the Protective order was unlawful and a violation of
21 my rights such as not adhering to the Speak Out Act.
22 24. Before any ruling was made on the “Sanctions order” including the evidence destruction
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request, I suggested to the tribunal that there is still a need for key evidence to be presented
24 to the tribunal, such as (1) a declaration from my former counsel confirming they did not send
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me a copy of the protective order prior to October 2024 and (2) the production of exhibits from
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the defendants to support their allegations in their motion for sanctions (See Ex. 6). It appears
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1 that none of this evidence was obtained by me or even this tribunal prior to the ruling and thus
2
was a failure to hear evidence relevant to controversy.
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25. In the Motion hearing for these sanctions I witnessed respondents counsel, Katherine Smith
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of Gibson Dunn inform this tribunal that she didn’t even know what the “confidential”
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designations meant despite the fact that she wrote the protective order and that no real
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injuries had occurred resulting from my publications other than the fact that Laurent’s
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performance reviews painted him in a negative light. I believe this “injury” does not qualify as
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a violation under California Penal Code §132 or the protective order and the documents
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should have never even been designated as “confidential” or “highly confidential” to begin
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with. On the contrary and rather disturbingly, Laurents performance reviews support my
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claims of FEHA violations, particularly relating to the Hostile Work Environment. For example
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13 a Riot Games Co-Founder reviews Laurent as highly combative, argumentative, and
aggressive. Another Senior Executive noted for Laurent, “I gave you feedback on multiple
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occasions, but it felt like you were dismissive or unwilling to risk losing some sort of business
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advantage due to poor ‘soft skills.’ This is just one example of many across the company, and I would
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strongly encourage you to prioritize cultural values and work to eliminate hostile work environments”.
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Additionally, these performance reviews recorded Laurent’s own derogatory comments of his
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own coworkers, labeling Riot Games employees of lesser rank than him as “babies” and
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“a**holes". Laurent’s reviews also provide contrast to the ones he propagated out of context,
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about me, first, all over the internet—evidence of which I provided to this tribunal.
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26. I believe that I am entitled to ALL discovery documents pursuant to CCP § 2017.010, CCP §
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2031.010—including the response to my Request for Production of Documents (Ex. 8), as
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well as JAMS Rule 17, and No. 22 of the Protective order (as a pro se litigant).
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27. I believe the “sanctions order”, removal order and the protective order is unlawful pursuant to
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Cal. Civ. Code § 1599 and Cal. Civ. Code § 1667. I contend that these orders and actions
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are contrary to public policy and violate my rights.
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1 I declare under penalty of perjury under the laws of the State of California that the foregoing is
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true and correct to the best of my knowledge and belief.
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4 DATED: November 1st, 2024
6
Sharon O’Donnell
7 Claimant, In Pro Per
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SUMMARY OF EXHIBITS
10 EXHIBIT 1: “Sanctions Order”
EXHIBIT 2: Protective Order
11 EXHIBIT 3: Removal order
EXHIBIT 4: Index and description of the 10 WHISTLEBLOWER documents
12 EXHIBIT 5: JAMS confirmation uploads
EXHIBIT 6 & 7: Emails between Claimant, Counsel & Tribunal—RE: NO EXHIBITS?
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EXHIBIT 8: Plaintiff's Request for Production of Documents (RFP #1) to respondents
14 EXHIBIT 9: Plaintiffs Ex Parte papers to enjoin defendants
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1 OBJECTION TO ARBITRATORS ORDER
2 Claimant, Sharon O’Donnell (“Claimant”), hereby submits the following Objection to Arbitrator
3 Grossmans Sanctions order/award dated October 22nd, 2024.
4 Objection based on Grounds of Potential Criminal Liability: Claimant respectfully objects to
5 the Arbitrator’s order requiring the destruction and return of discovery documents on the basis that
6 compliance with this order would result in a violation of criminal statutes prohibiting the destruction
7 or evidence of crimes which are also required for legal proceedings. The documents in question
8 substantiate Defendants have committed violations of CA Penal Code §118, §132, §134, and
9 FEHA violations. The destruction of this evidence would not only compromise future investigations
and potential legal proceedings but would also expose Claimant to criminal liability where the
10
11 Penalty is a misdemeanor charge, which can result in fines and jail time. As such, any compliance
12 with the Arbitrators order is at risk of violating criminal statutes—Specifically, California Penal
13 Code § 135, and 18 U.S.C. § 1519.
14 Objection Based on Protected Acts of Reporting Unlawful Conduct: Claimant publications
15 constitute protected acts under California law which involve the reporting of Respondents’ unlawful
16 conduct to government and law enforcement agencies. Under California Labor Code section
17 1102.5, employees are protected from retaliation for disclosing information they reasonably believe
18 to be a violation of state or federal law. Furthermore, California Labor Code section 1106 extends
19 protections related to whistleblower activities and, California Civil Code section 52.1 (the Bane
20 Act) provides a civil remedy for interference with rights secured by the Constitution or laws of
21 California through threats, intimidation, or coercion.
22
23 Objection to Arbitrator's Refusal to Hear Pertinent and Material Evidence: Claimant objects to
24 the Arbitrator’s refusal to hear or obtain evidence that is directly relevant and material to the
25 controversy at hand. Specifically, Respondents alleged Claimant published “confidential” materials
26 on June 7th and July 10th; however, no evidence was presented to substantiate these claims.
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1 Furthermore, the Arbitrator failed to obtain evidence and/or a declaration from Claimant’s former
2 counsel—confirming Claimant was not provided with a copy of the protective order during the
3 period she was represented by them. This failure to secure essential evidence has severely
4 prejudiced Claimant by leaving her unable to effectively defend against allegations concerning her
5 alleged non-compliance with the protective order. The lack of evidence and failure to obtain
6 testimony that could have exonerated Claimant constitutes a denial of her right to a fair hearing
7
and undermines the integrity of the proceedings.
8
9 Objection Based on lack of knowledge governing Sanctions: Claimant objects to sanctions on
10 the grounds that they were not properly communicated or outlined in the Protective Order.
11 Specifically, the Protective Order does not state that sanctions can be imposed for any breach of
12 agreement. While the Removal Order references sanctions, Claimant fully complied with the terms
13 set forth in the Removal Order. Furthermore the protective order was never even provided to
14 Claimant until June 14th, 2024–a week after her publications and two days after she had already
15 complied with the removal order.
16
Objection Based on Inability to pay, Lack of Injury and Excessive Sanctions: Claimant
17
objects to the sanctions imposed on the grounds that no injury or harm was caused to
18
Respondents as a result of the publication. Respondents have not demonstrated any concrete or
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material damage resulting from Claimant's actions, and the absence of such injury undermines the
20
21 justification for imposing sanctions. Furthermore, the $20,000 sanctions imposed are excessive
and financially burdensome. Claimant does not have the means to pay the sanction which creates
22
an undue hardship. Imposing severe sanctions in the absence of proven injury is punitive rather
23
24 than remedial and is disproportionate to any alleged harm.
25 Objection Based on "Void Ab Initio" Due to Non-Compliance with the Speak Out Act:
26 Claimant objects to the validity of the Protective Order of February 2022 on the grounds that it is
27 "void ab initio" due to its failure to adhere to the requirements set forth in the Speak Out Act. The

1 Speak Out Act mandates since January 2022 specific language to protect a party’s right to speak
2 out about unlawful conduct, including but not limited to sexual harassment or assault, and to
3 ensure that protective orders or confidentiality agreements do not suppress such rights. The
4 Protective Order in question did not include the necessary language to comply with these statutory
5 protections. As a result, the Protective Order should be deemed null and void from the outset for
6 failing to conform to the legislative intent and statutory language required under the Speak Out Act.
7
Objection based on Claimants rights to discovery documents: Claimant respectfully objects to
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the request for her to destroy documents on the basis of respondents' claim that they were
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designated as “confidential” or “highly confidential” when being provided to her during the discovery
10
of this case. Claimant is entitled to obtain discovery of all relevant documents regardless of their
11
designations pursuant to:
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● California Code of Civil Procedure §§ 2017.010 and 2031.010—these documents were in
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response to Claimant's Request for Production of Documents in the first place.
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● JAMS Rule 17 provides for fair and equitable exchange of information during discovery.
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● Paragraph No. 22 of the Protective Order provides Claimant with the right to certain
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discovery documents as her own counsel (pro se litigant).
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● Fourteenth Amendment—due process rules are meant to protect persons not from the
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deprivation, but from the mistaken or unjustified deprivation of life, liberty, or property.
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20 Claimant reserves all rights, including the right to respond.
21
DATED: November 1st, 2024
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24 Sharon O’Donnell
Claimant, In Pro Per
25
26
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EXHIBIT 1
EXHIBIT 2
1 teims included herein, and agree that such Stipulation and Protective Order will be effective as of the
2 Effective Date.
3 This Stipulation and Protective Order may be executed in counterparts.
4 DATED: February 4, 2022
5 GIBSON, DUNN & CRUTCHER LLP
6
7
By:
8 Catherine A. Conway
Katherine V.A. Smith
9 Tiffany Phan
10 Attorneys for Respondents RIOT GAMES, INC. and
NICOLO LAURENT
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12
13
DATED: February i, 2022
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15
By:
16 Timothy B. Sottile
Michael F. Baltaxe
17 Victoria Felder
Kasra B. Ramez
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Attorneys for Claimant SHARON O'DONNELL
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STIPULATION AND PROTECTIVE ORDER-CONFIDENTIAL AND HIGHLY CONFIDENTIAL DESIGNATIONS
February 8 Joel Grossman
EXHIBIT 3
JAMS ARBITRATION: REF. NO.: 1220070146
O'Donnell, Sharon,
Claimant(s)
and ORDER RE: REMOVAL OF

CONFIDENTIAL DOCUMENTS FROM
PUBLIC WEBSITES OR SOCIAL
Riot Games Inc. et al., MEDIA
Respondent(s).
Reference is made to the Stipulation and Protective Order issued by the Arbitrator on February 8,
2022, and signed by counsel for Claimant Sharon O’Donnell and counsel for Respondent Riot Games. The
Protective Order allows the parties to designate certain documents as Confidential or Highly Confidential,
and prohibits the dissemination or publication of any such documents to the public, or to any individual not
covered by the Protective Order.
It has come to the Arbitrator’s attention that Claimant O’Donnell has placed on her website
https://sapemvmt.weebly.com/ documents or summaries of documents which were deemed either
“Confidential” or “Highly Confidential” when exchanged during the course of this Arbitration. Posting any
such documents or summaries of documents on a public website or on social media or any other forum or
providing them to anyone other than those permitted to see them under the terms of the Protective Order
constitutes a violation of the Protective Order. Any violation of the terms of the Protective Order can give
rise to serious monetary sanctions. Such sanctions may already be awarded, and further sanctions may be
issued for any further violation of the terms of the Protective Order. Pursuant to paragraph 21 of the
Protective Order, the Arbitrator retains jurisdiction to enforce the terms of the Protective Order even after
the Proceeding has terminated.
IT IS HEREBY ORDERED that Claimant Sharon O’Donnell immediately remove from any public
website or social media any documents or summaries of documents which were designated as Confidential
or Highly Confidential. Substantial monetary sanctions will be issued for every day, commencing on June
13, 2024, on which the Confidential or Highly Confidential documents remain on any public website or on
social media.
IT IS SO ORDERED this 11th day June, 2024
_____________________________
Joel M. Grossman, Arbitrator.
-1-
ORDER RE: REMOVAL OF CONFIDENTIAL DOCUMENTS FROM PUBLIC WEBSITES OR SOCIAL MEDIA
EXHIBIT 4
Exhibit #1 to Declaration of Sharon O’Donnell
Riot’s Bates # Brief Description Reason for my publication
1 400– 421 Mr. Laurent’s 2018 performance review These documents (1–3) are subject to waiver by
conduct doctrine as Laurent propagated my
performance review first, and in a false light (see
2 922- 941 Mr. Laurent’s 2015 performance review Answer ¶ 28 & propagation Exhibits). Evidence of
the hostile environment at Riot Games—-supporting
3 1030-1035 Mr. Laurent’s 2010 performance review my FEHA Violations. Evidence in support of
defamation of O’Donnell—outlined in (1) Claimants
opposition to Respondent's Motion for Sanctions and
(2) My Open Letter to Congress.
4 1160- 1171 HIGGS (HR) feedback Compilation about Ms. O’Donnell (Higgs testified she emailed These documents (4—11) are evidence of
this as an attachment to Laurent on February 4th, 2020). violations of all or some of the below
Multiple fabrications found post hearing. violations—outlined in the (1) Motion for
Criminal Investigation, (2) Amended Petition to
5 1198- 1200 HIGGS email to Riots Legal Department for potential advice regarding Laurents’s perf.
Vacate Arbitration Award and (3) Amended
Review of O’Donnell “not in the system”–sent July 15th 2020—sent one day prior to
Opposition to Defendant's Petition to Confirm
expiration of O’Donnells separation agreement.
Further emails of January 2021 are redacted.
Arbitration Award. These documents are also
evidence of defamation—outlined in (1)
6 1230- 1233 Email from Laurent to Higgs on July 15th, 2020- Laurent sends feedback about Claimants opposition to Respondent's Motion for
O’Donnell. Note: O’Donnell debunked these as fabrications in Appendix 1/Superior Sanctions and (2) My Open Letter to Congress.
Court Filings.
Violations
7 1235 Feb/13/2020 Laurent responding to Higgs email of Feb/4/202 re: Higgs Feedback 1. CA Penal Code §118 (perjury)
Compilation on O’Donnell. 2. CA Penal Code §132 (presentation of false or
8
ante-dated evidence)
1239 Nov. 2020/O’Donnell email to Laurent to requests mtg “I think it's time to have a sit
down on some areas that I"m really upset in working with you on” (HR included)
3. CA Penal Code §134 (preparation of false or
ante-dated evidence)
9 1241 & 1243 Hsiung email to Laurent Oct 2020, falsely accuses O’Donnell of 4. CA Penal Code §182(a)(5) (obstruction of
communication issues. Laurent defended O’Donnell to Hsiung. justice)
5. FEHA Violations
10 1431 Email of March 2020 from Hsiung to Laurent regarding O’Donnell’s termination mtg. 6. CA Business & Professions Code § 6068
7. CA Rules of Professional Conduct; Rule 3.3
11 1152-1153 Jan/2019 Feedback from Ms. Young re: Scheduling time with Laurent.
EXHIBIT 5
24/10/2024, 11:35 Gmail - JAMS Access New Notifications
Sharon O'Donnell <[email protected]>
JAMS Access New Notifications

11 messages
[email protected] <[email protected]> Mon, Oct 14, 2024 at 2:31 PM

To: [email protected]
Dear Sharon ,
Here are all of the new Notifications within JAMS Access.

Click here to login to JAMS Access to see the Notifications.
Log Notification Time
Ex. 25 – Counsels public exposure_ Roberta Kaplan–NY Times 05:30 PM

Article; law firm resignation expose.pdf is uploaded to case (ET)
O'Donnell, Sharon vs. Riot Games Inc. et al. #1220070146 by
Sharon O'Donnell
Ex. 26 – Counsels public exposure_ Roberta Kaplan_ Times Up 05:30 PM

ceases operations .pdf is uploaded to case O'Donnell, Sharon vs. (ET)
Riot Games Inc. et al. #1220070146 by Sharon O'Donnell
Ex. 17 – Counsels public exposure_ Facebook re_ Gibson Dunn.pdf 05:30 PM

is uploaded to case O'Donnell, Sharon vs. Riot Games Inc. et al. (ET)
#1220070146 by Sharon O'Donnell
https://mail.google.com/mail/u/2/?ik=86e1455c00&view=pt&search=all&permthid=thread-f:1812926554542833954&simpl=msg-f:1812926554542833954&simpl=msg-f:1812926625634205213&simpl=msg-f:1812926711642353694&… 1/12
24/10/2024, 11:35 Gmail - JAMS Access New Notifications
Thanks,
JAMS Access Team
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[email protected] <[email protected]> Mon, Oct 14, 2024 at 2:32 PM

To: [email protected]
Dear Sharon ,
Here are all of the new Notifications within JAMS Access.

Click here to login to JAMS Access to see the Notifications.
Log Notification Time

Ex. 21 – Counsels public exposure_ Roberta Kaplan Article (NY 05:31 PM
Times).pdf is uploaded to case O'Donnell, Sharon vs. Riot Games (ET)
Inc. et al. #1220070146 by Sharon O'Donnell
https://mail.google.com/mail/u/2/?ik=86e1455c00&view=pt&search=all&permthid=thread-f:1812926554542833954&simpl=msg-f:1812926554542833954&simpl=msg-f:1812926625634205213&simpl=msg-f:1812926711642353694&… 2/12
EXHIBIT 26
24/10/2024, 11:28 Gmail - O'Donnell v Riot Games, et al. - JAMS Ref No. 1220070146
O'Donnell v Riot Games, et al. - JAMS Ref No. 1220070146

Sharon O'Donnell <[email protected]> Wed, Oct 23, 2024 at 1:10 AM
To: "Fischer, Lauren M." <[email protected]>
Cc: "[email protected]" <[email protected]>, Estefania Alonso <[email protected]>, Matthew Ramos <[email protected]>, "Conway,
Catherine A." <[email protected]>, "Smith, Katherine V.A." <[email protected]>, "Phan, Tiffany" <[email protected]>, Mike Baltaxe
<[email protected]>, Timothy Sottile <[email protected]>, "[email protected]" <[email protected]>, Jessica Huizar
<[email protected]>
Hello Arbitrator Grossman,
I have informed opposing counsel that I am unable to open the PDFs from their recent uploads, and I imagine you may be encountering the same issue.
I would also like to bring another matter to your attention upon reviewing the documents we can see:
The $20,000 in sanctions is, essentially, for the publication of 10 documents (refer to Exhibit 1b, O'Donnell) between June 7th and June 12th (on a website
with no real traffic). The tribunal has indicated that it believes I was aware of the protective order at the time because it was referenced by counsel Conway
in a transcript from 2022. However, I did not receive or see the protective order itself until June 14, 2020, as stated in my supplementary declaration #2. I
request that myself or the tribunal ask counsel Mike Baltaxe to confirm this by either:
1. Waiving attorney-client privilege on this matter so that Mike can provide any additional documentation he may have to prove otherwise, or
2. Submitting a declaration from Mike clarifying that he never sent me a copy of the protective order before October 16th, 2024.
Regarding the documents allegedly posted on July 10th, 2024, for "one day" (see Motion for Sanctions, page 11, line 4), this refers to an apparent snippet
from Laurent's 2010 performance review; see Respondents: Ex. 1 - Violation Index. I already possessed my own copies of the remaining documents.
However, I cannot review the evidence as it does not open for me, and therefore, I cannot verify this alleged screenshot or confirm that it was posted on
July 10th, 2024. I contest the existence of this publication as I have never seen it. Even if such a video was posted for "one day," it was allegedly posted on
the Sape website (with no real traffic), and counsel has provided no evidence to substantiate the claim that it was posted on July 10th. How can we be
certain it was not posted between June 7th and June 12th along with the other documents giving their history of lying? For example; there was no other
breach of the removal order, as counsel's claims were shown to be false according to the evidence.
In conclusion, the $20,000 sanctions are being imposed for the publication of 10 documents over a five-day period during which I should be able to further
prove that I did not possess the protective order. The burden of proof is on the respondent to demonstrate that I published Laurent's 2010 performance
review on July 10th, 2024, and they have not provided sufficient evidence to support this claim.
https://mail.google.com/mail/u/2/?ik=86e1455c00&view=pt&search=all&permmsgid=msg-a:r2791178947716738316&dsqt=1&simpl=msg-a:r2791178947716738316 1/3
24/10/2024, 11:28 Gmail - O'Donnell v Riot Games, et al. - JAMS Ref No. 1220070146
For ease of reference you might like to revert to;
Respondents: Ex. 1 - Violation Index.pdf

Claimants: Ex. 1b - Violation index (attached to supplementary declaration #1)
Thank you for your attention to these matters.
Kind regards,
Sharon O'Donnell
On Mon, Oct 21, 2024 at 7:22 PM Fischer, Lauren M. <[email protected]> wrote:
Arbitrator Grossman,
Thank you for your time today. This email confirms that Respondents finished uploading the exhibits that we discussed to JAMS All Access shortly after 1 pm PT today;
please let us know if you have any trouble accessing the documents, or if there is anything else we can assist with. Thank you.
Best,
Lauren M. Fischer
Associate Attorney
T: +1 213.229.7983
[email protected]
GIBSON DUNN
Gibson, Dunn & Crutcher LLP
333 South Grand Avenue
Los Angeles, CA 90071-3197
https://mail.google.com/mail/u/2/?ik=86e1455c00&view=pt&search=all&permmsgid=msg-a:r2791178947716738316&dsqt=1&simpl=msg-a:r2791178947716738316 2/3
EXHIBIT 37
24/10/2024, 11:34 Gmail - O'Donnell, Sharon vs. Riot Games Inc. et al. - JAMS Ref No. 1220070146
O'Donnell, Sharon vs. Riot Games Inc. et al. - JAMS Ref No. 1220070146
Phan, Tiffany <[email protected]> Wed, Oct 23, 2024 at 6:30 PM
To: Sharon O'Donnell <[email protected]>, "Fischer, Lauren M." <[email protected]>
Cc: "Smith, Katherine V.A." <[email protected]>, "Conway, Catherine A." <[email protected]>, Matthew Ramos <[email protected]>, Timothy Sottile
<[email protected]>, Estefania Alonso <[email protected]>, "[email protected]" <[email protected]>, "[email protected]"
<[email protected]>, "[email protected]" <[email protected]>, "Teasdale, Raychel" <[email protected]>, "Eckert, Kristina"
<[email protected]>, "Luskin, Roark" <[email protected]>, Alejandra Cervantes <[email protected]>
Ms. O’Donnell,
We have not heard from anyone else about any access issues.
We will not be providing any additional materials for these already resolved motions.
Tiffany Phan
Partner
T: +1 213.229.7522
[email protected]
GIBSON DUNN
333 South Grand Avenue, Los Angeles, CA 90071-3197
From: Sharon O'Donnell <[email protected]>

Sent: Tuesday, October 22, 2024 12:15 PM
To: Fischer, Lauren M. <[email protected]>
Cc: Smith, Katherine V.A. <[email protected]>; Conway, Catherine A. <[email protected]>; Phan, Tiffany <[email protected]>;
Matthew Ramos <[email protected]>; Timothy Sottile <[email protected]>; Estefania Alonso <[email protected]>;
https://mail.google.com/mail/u/2/?ik=86e1455c00&view=pt&search=all&permmsgid=msg-f:1813756990264608888&dsqt=1&simpl=msg-f:1813756990264608888 1/23
24/10/2024, 11:34 Gmail - O'Donnell, Sharon vs. Riot Games Inc. et al. - JAMS Ref No. 1220070146
[email protected]; [email protected]; [email protected]; Teasdale, Raychel <[email protected]>; Eckert,
Kristina <[email protected]>; Luskin, Roark <[email protected]>; Alejandra Cervantes <[email protected]>
Subject: Re: O'Donnell, Sharon vs. Riot Games Inc. et al. - JAMS Ref No. 1220070146
Hello, I’m reaching out regarding your new PDF uploads to the JAMS portal. Unfortunately, the files don’t seem to open. For example, when I attempt to access Exhibits 12-16 (File ID: 985595), several PDFs are displayed, but none of them open.
Hello,
I’m reaching out regarding your new PDF uploads to the JAMS portal. Unfortunately, the files don’t seem to open. For example, when I attempt to access Exhibits 12-16 (File
ID: 985595), several PDFs are displayed, but none of them open. This issue appears to be consistent across all your recent uploads. Assuming others are having the same
problem, could you please look into resolving this?
Additionally, do you have the actual video file referenced in your motion (opposed to screenshots)? If so, could you kindly provide that as well?
Many thanks for your attention to these matters.
Best regards,
Sharon O'Donnell
On Mon, Oct 21, 2024 at 4:40 PM Fischer, Lauren M. <[email protected]> wrote:
Ms. O’Donnell,
The URLs for the two videos embedded on the last page of Exhibit 12 appear at the bottom of page 6 in the Declaration of Katherine V.A. Smith.
Best,
Lauren M. Fischer
Associate Attorney
T: +1 213.229.7983
[email protected]
GIBSON DUNN
https://mail.google.com/mail/u/2/?ik=86e1455c00&view=pt&search=all&permmsgid=msg-f:1813756990264608888&dsqt=1&simpl=msg-f:1813756990264608888 2/23
EXHIBIT 8
1 Timothy B. Sottile, Esq. SBN: 127026
Michael F. Baltaxe, Esq. SBN: 129532
2 Nicole C. Burgos Romero, Esq. SBN: 340942
3 Robert J Golde, Esq. SBN: 303155
SOTTILE BALTAXE
4 28632 Roadside Drive, Suite 100
Agoura Hills, California 91301
5 Telephone: (818) 889-0050; Facsimile: (818) 889-6050
6 Attorneys for CLAIMANT Sharon O’Donnell
7
JAMS
8
9 SHARON O’DONNELL, an individual,

REFERENCE NO: 1220070146
10 CLAIMANT,
11 [Assigned to Arbitrator Joel Grossman]
vs.
12 CLAIMANT SHARON O’DONNELL’S
RIOT GAMES, INC., a business entity exact REQUEST FOR PRODUCTION OF
13 form unknown, NICHOLAS LAURENT, an DOCUMENTS (SET NO. 1) TO
individual and DOES 1 through 100, inclusive, RESPONDENT RIOT GAMES, INC.
14
Defendants.
15
16
Action Filed: January 7, 2021
17 Hearing: December 11, 2023
18
PROPOUNDING PARTY: CLAIMANT SHARON O’DONNELL
19
RESPONDING PARTY: RESPONDENT, RIOT GAMES, INC
20
SET NO: ONE
21
Pursuant to Rules 17 of the JAMS Employment Arbitration Rules & Procedures,
22
CLAIMANT SHARON O’DONNELL hereby requests that RESPONDENT RIOT GAMES,
23
INC. produce for inspection and copying the documents specified below to SOTTILE BALTAXE,
24
28632 Roadside Drive, Agoura Hills, California 91301, within 30 days from the date of service of
25
this request.
26
27
-1-
28 CLAIMANT SHARON O’DONNELL’S REQUEST FOR PRODUCTION OF DOCUMENTS (SET NO. 1) TO
RESPONDENT RIOT GAMES, INC.
_
1 INSTRUCTIONS
2 This demand seeks only DOCUMENTS which are described and requested herein and
3 which presently repose in the possession, custody or control or otherwise accessible to
4 DEFENDANTS or their agents, representatives, or counsel.
5 In the event that YOU are not able to produce all of the DOCUMENTS requested, produce
6 those DOCUMENTS which YOU are able to provide, and state the reason for YOUR inability to
7 provide the remainder. If any requested DOCUMENT was, but no longer is, in YOUR possession,
8 custody or control, identify the DOCUMENT (stating its date, author, subject, recipient, intended
9 recipient, custodians, and specific location); explain the circumstances by which the DOCUMENT
10 ceased to be in YOUR possession, custody or control; and identify (stating the PERSON’s name,
11 employer, title, business address and telephone number, and home address and telephone number)
12 all PERSONS known to have or believed to have the DOCUMENT or a copy of the DOCUMENT
13 in their possession, custody or control.
14 DOCUMENTS called for by this demand are required to be organized and labeled to
15 correspond with the categories of the demand.
16 If any DOCUMENT is withheld under a claim of privilege, provide the following
17 information with respect thereto:
18 a) The identity of the PERSON who signed it over or whose name it was sent or issued
19 and the identity of the PERSON for whom it was directed;
20 b) The date of the DOCUMENT;
21 c) The identity of the PERSON who has custody or possession of the DOCUMENT;
22 d) The nature and substance of the DOCUMENT with sufficient particularity to enable
23 the court and parties to identify the DOCUMENT;
24 e) The basis in which any privilege is claimed; and,
25 f) Whether any non-privileged matter is included in the DOCUMENT.
26
27
-2-
_
1 DEFINITIONS
2 1. “DOCUMENTS” means all originals, drafts and copies which differ in any way from
3 the original, as well as any and all written, recorded, inputted, or graphic matter, whether produced
4 or reproduced by handwriting, magnetic recording, photograph, photostat, printing, disk, tape,
5 typewritten, writing or any other means and includes without limitation all accountant statements,
6 agreements, appointment books, analysis, bank statements, bills, books, business records,
7 calendars, cards, checks, charts, claims files, computer input, hardcopy, computer printouts,
8 computer tapes, contracts, correspondence, credit memoranda, diaries, documents, drafts, e-mail,
9 expense accounts, films, financial statements, handwritten notes, invoices, journals, ledgers, letters,
10 logs, memoranda, memorials in any form of telephone conversations, minutes, notes, notices,
11 pamphlets, papers, purchase orders, personnel records, receipts, recordings, reports, telegrams,
12 voicemail recordings, and any other written or electronic representation thereof as well as any
13 carbon or photostatic copy of such material in YOUR possession, custody or control.
14 2. “YOU” or “YOUR” refers to Respondent RIOT GAMES INC., its partnerships, counsel,
15 partnerships, subsidiaries, agents, representatives, employees, union leaders, union members, and
16 any other person or entity acting on its behalf.
17 3. “LAURENT” refers to Respondent Nicolo Laurent
18 3. “CLAIMANT” refers to SHARON O’DONNELL, the CLAIMANT in this action, Case
19 Reference NO. 1220070146
20 4. “EVIDENCE OR REFER TO” means in whole or in any part, referring to, constituting,
21 embodying, reflecting (whether directly or indirectly), identifying, stating, evidencing,
22 summarizing, describing or mentioning so that no document shall fail to be produced because of a
23 limiting interpretation of the terms “evidence or refer to.”
24
25
26
27
-3-
_
1 ITEMS/DOCUMENTS TO BE PRODUCED
2 REQUEST FOR PRODUCTION NO. 1:
3 CLAIMANT‘s entire employment file.
5 Any and all DOCUMENTS showing, describing, explaining, pertaining to or relating to
6 CLAIMAN T’s job duties while employed by YOU.
8 Any and all DOCUMENTS pertaining or relating to CLAIMANT’s job performance while
9 employed by YOU, including but not limited to performance appraisals or evaluations,
10 commendations, awards, and/or letters of thanks, recognition or appreciation or any other similar
11 DOCUMENTS.
13 Any and all DOCUMENTS which in any way criticize CLAIMANT’s work performance.
15 Any and all DOCUMENTS which in any way are complimentary of CLAIMANT’s work
16 performance.
18 Any and all DOCUMENTS received from any third party, including co-workers, which
19 were in any way critical of CLAIMANT.
21 Any and all procedures, memoranda, employment/personnel manuals or handbooks,
22 instructional materials, or other DOCUMENTS which EVIDENCE OR REFER TO YOUR
23 policies and procedures governing employment conditions, or any kind, in effect during
24 CLAIMANT’s employment by YOU.
25
26
27
-4-
_
2 Any and all employment handbooks YOU contend CLAIMANT received while employed
3 by YOU.
5 Any and all DOCUMENTS which EVIDENCE OR REFER TO training or instructions
6 provided by YOU to managers, supervisors and/or human resource personnel in CLAIMANT’s
7 region or work unit, relating or pertaining to YOUR discrimination policies and harassment policies.
9 Any and all DOCUMENTS which would evidence or reflect CLAIMANT’s work
10 schedule while employed by YOU.
12 Any and all DOCUMENTS showing, describing, pertaining to or relating to the wages
13 and/or other forms of compensation earned by CLAIMANT during CLAIMANT’s employment by
14 YOU, including but not limited to wages, bonuses, stock options, deferred compensation, pension
15 benefits, retirement plans, medical or other insurance, etc.
17 Copies of any Form W-2s YOU gave to CLAIMANT.
19 Any and all payroll records pertaining to CLAIMANT from 2016 to her last day of
20 employment.
22 Any and all DOCUMENTS received by your Human Resources Department from
23 CLAIMANT.
25 Any and all DOCUMENTS sent by your Human Resources Department to CLAIMANT.
26
27
-5-
_
2 Any and all DOCUMENTS evidencing you ever took any disciplinary measures or steps
3 against CLAIMANT.
5 Any and all electronic mail between LAURENT and CLAIMANT.
7 Any and all correspondence, including but not limited to e-mails, letters, and memoranda,
8 between CLAIMANT and any other member of management.
10 Any and all written warnings YOU gave to CLAIMANT.
12 Any and all DOCUMENTS evidencing that any oral warnings were given by YOU to
13 CLAIMANT.
15 Any and all DOCUMENTS which EVIDENCE OR REFER TO any oral complaints
16 CLAIMANT made to YOU for any reason.
18 Any and all written complaints by CLAIMANT made to YOU for any reason.
20 To the extent not requested above, any and all documents received from, sent to, or
21 pertaining to CLAIMANT during her employment with YOU.
23 Any and all DOCUMENTS that YOU have sent to CLAIMANT since the last day she
24 was employed by YOU.
26 Any and all DOCUMENTS of any kind relating or pertaining to the person who took over
27
-6-
_
1 CLAIMANT’s position.
3 Any and all DOCUMENTS that reflect or relate to any statements made by any person
4 relating to any of the allegations contained in CLAIMANT’s Complaint, including but not limited to
5 written statements, notes of interviews, tape recordings of any and all oral statements and/or
6 interviews; transcriptions of any tape recordings of any and all oral statements and/or interviews;
7 reports regarding the results of any and all interviews or investigations; or correspondence relating to
8 the allegations contained in the Complaint.
10 All DOCUMENTS which EVIDENCE OR REFER TO any complaints made to YOU by
11 other employees about LAURENT, including but not limited to sexual harassment or harassment
12 based on sex.
14 Any and all DOCUMENTS relating to any investigation by YOU relating to any complaint
15 made by an employee about LAURENT relating to sexual harassment in the past 10 years.
17 Any and all DOCUMENTS relating to disciplinary actions taken against LAURENT by
18 CLAIMANT’s complaint(s) of sexual harassment.
20 Any and all DOCUMENTS relating to disciplinary actions taken against LAURENT for
21 any complaints of sexual harassment.
23 Any and all DOCUMENTS showing or describing the position(s) held by LAURENT
24 while employed by YOU between 2010 through present.
26 All DOCUMENTS evidencing or reflecting the hours CLAIMANT worked each day.
27
-7-
_
2 All DOCUMENTS which EVIDENCE OR REFER TO any complaints CLAIMANT
3 made to YOU about not taking meal and rest breaks.
5 Any and all signed witness statements in YOUR possession relating to this matter.

Any and all DOCUMENTS referencing to any sexual harassment claims against YOU in
7
8 the past five years.
10 Any and all DOCUMENTS referencing to any sex based harassment claims against YOU
11 in the past five years.
12
REQUEST FOR PRODUCTION NO. 37:
13
Any and all DOCUMENTS referencing to any failure to pay wages claims against YOU in
14
the past five years.
15
16
17 SOTTILE BALTAXE
Dated: October 11, 2023
18
By /s/ Nicole C. Burgos Romero
19
NICOLE C. BURGOS ROMERO, ESQ.
20 Attorneys for CLAIMANT
21
22
23
24
25
26
27
-8-
_
1 PROOF OF SERVICE
2
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3
I am employed in the County of Los Angeles, State of California. I am over the age of 18
4 years of age and not a party to the within action. My business address is 28632 Roadside Drive,
Suite 100, Agoura Hills, CA 91301.
5
On October 11 , 2023, I served, in the manner indicated below, the foregoing document
6 described as CLAIMANT SHARON O’DONNELL’S REQUEST FOR PRODUCTION OF
DOCUMENTS (SET NO. 1) TO RESPONDENT RIOT GAMES, INC. on the interested
7 parties in this action by placing true copies thereof enclosed in a sealed envelope, at Agoura Hills,
California, addressed as follows (or as stated on the attached Proof of Service Mailing List):
8
SEE ATTACHED SERVICE LIST
9
10 [] (BY MAIL) I caused such envelopes with postage thereon fully prepaid to be placed in the
United States mail at Agoura Hills, California. I am “readily familiar” with the firm’s
11 practice of collection and processing correspondence for mailing. Under that practice, it
would be deposited with the U.S. Postal Service on that same day in the ordinary course of
12 business. I am aware that on motion of the party served, service is presumed invalid if
postal cancellation date or postage meter is more than one (1) day after date of deposit for
13 mailing in affidavit (C.C.P. § 1013(a)).
14 [XX] (BY ELECTRONIC MAIL) The document listed above was transmitted via electronic
mail to the e-mail addresses set forth above, or as stated on the attached Proof of Service
15 Mailing List. The transmission was reported as complete and without error (C.C.P. §
1010.6(a)(2)).
16
[] (BY OVERNIGHT COURIER): I caused the above-referenced document to be delivered
17 to GLS for delivery to the addresses on the attached service list.
18 [] (BY PERSONAL SERVICE) I caused such envelopes to be delivered by hand to the
offices of the addressees (C.C.P. § 1011(a)(b)).
19
20 * * * * *
21 [XX] (STATE) I declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.
22
[] (FEDERAL) I declare that I am employed in the office of a member of the bar of this
23
Court, at whose direction the service was made.
24
EXECUTED on October 11, 2023, at Agoura Hills, California.
25
26 /s/ Nicole C. Burgos Romero

NICOLE C. BURGOS ROMERO
27
-9-
_
1
2 SERVICE LIST
GIBSON DUNN & CRUTCHER LLP Attorneys for Defendants RIOT GAMES,
3 Catherine A. Conway, Esq. INC. and NICHOLAS LAURENT
Lauren Fischer, Esq.
4 Katherine V.A. Smith, Esq.
Tiffany Phan, Esq.
5 [email protected]
[email protected]
6
[email protected]
7 [email protected]
8 Los Angeles, CA 90071
Telephone: 213.229.7000
9 Facsimile: 213.229.7520
KAPLAN HECKER & FINK LLP Attorneys for Defendants RIOT GAMES,
10 Roberta A. Kaplan, Esq. INC.
Gabrielle E. Tenzer, Esq.
11 [email protected]
[email protected]
12 350 Fifth Avenue, Suite 7110
13 New York, New York 10118
Telephone: 212.763.0883
14 Facsimile: 212.564.0883
15
16
17
18
19
20
21
22
23
24
25
26
27
- 10 -
_

Claimants Whistleblower Declaration & Objection To Arbitrators Order

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Claimants Whistleblower Declaration & Objection To Arbitrators Order

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The 10 Whistleblower Documents are discribed in Ex.

6 Plaintiff, In Pro Per

SHARON O’DONNELL, An Individual ) CASE NO. 1220070146

OBJECTION TO ARBITRATORS ORDER

4 I, SHARON O’DONNELL, declare and state as follows:

14 which they claim were the subject of a protective order.

20 confidential designations. I shared all these facts with this tribunal.

23 response, I immediately complied, unpublishing ALL materials regardless of any claims of