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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
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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:
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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.
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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
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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!
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“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
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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 <edmartini 191@gmail.com> 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" <pgay911@gmail.
com> wrote:
onit On Fri, Oct 21, 2016 at 7:39 PM, Ed Martin <edmartinl 791@gmail.com> 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” <edmarin1791@smail 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.
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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.
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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:
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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
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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:
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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
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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).
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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 <edmartin] 791 @amail.com> 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
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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.
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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
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was Motion the 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. due 10. bad Atlania in stuck is Barry on done was this he courthouse to obtain copy. Ths, it seems plan. We game immediate an together put and today Order the review will We airline.
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@email com> On Oct 21, 2016 9:41 PM, “priscill gry” para nit On Fri, Oct 21, 2016 at 7:39 PM, Ed Martin <edimarin] 91 @emsil com> 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” <edma co plains in charge of Go back on his page and write "your ruling puts anne cor and he plaints now be telling th and cor anne the can How he entity they sued, Eagle Forum, the lawyers for defendant eagle forum how to defend themselves? That is not justice but a rigged system. So, you gave them eagle forum by rigging it so anne cori is lawyer for both
on you and this broken legal system.” Sides. Shame
wrote:
y11 @ermail com> 21, 2016 9:31 PM, "priscils gry” <para Oct hava Ondont Roger's small1 which ho reptes down below.
a can eo my f post ee Forwarded message re <updatetpripaipl @facsbookil cone From: Facebook Date Fri, Oct 21, 2016 20720 PM Subject ohn Barbers replied to your comment on is lnk.
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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
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