## EXHIBIT M From: Jeffrey Pagliuca Date: June 20, 2016 at 6:46:36 PM MDT To: Meredith , Laura Menninger Cc: Sigrid McCawley , Sandra Perkins , "brad@pathtojustice.comi (brad@pathtojustice.com)" Subject: Re: 2016-06-17 Ltr to Menninger enc Giuffre005614-Giuffre006279 It is unfortunate that you waited until the night before Detective Recarey's deposition to dump all of this discovery on me. I expect that you had this information for many years, indeed, Mr. is mentioned in the discovery. I am not in a position to be able to adequately review it before the deposition. I expect that means that we may need to keep the deposition open pending my review of the documents. Also, it appears to be a continuing problem that you list documents in your 26(a) disclosures but do not produce them even though we make multiple requests for the documents. This behavior is prejudicial and impeding out ability to adequately prepare for depositions and trial. Again, please produce all of the documents listed in your 26(a) disclosures as required. From: "Meredith corn>" Date: Monday, June 20, 2016 at 6:57 PM To: Laura Menninger , Jeffrey Pagliuca Cc: Sigrid McCawley , Sandra Perkins , "brad@pathtojustice. corn" Subject: 2016-06-17 Ltr to Menninger enc Giuffre005614-Giuffre006279 Counsel, Please see the attached. Thanks, Meredith The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client pnwlege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination. distnbubon. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. Iv.11