JAMES P.

HEALOW
Attorney at Law
526 Highland Park Drive
Billings, Montana 59102
Telephone (406) 671-4116
Facsimile (406) 254-8448

January 3, 2017

Ms. Emily Jones

MATOVICH, et al.
POB1098
Billigs, MT 59103-1098

Dear Ms. Jones:

Tom Hauptman gave me your letter of 12/28 for reply. Did you and/or your client actually harbor
fantasies of intimidating this guy? Seriously? Well, we are not amused. The rage-fueled laughter now
having quieted, there are just so many things to say that I can hardly fathom how to proceed. So, in no
particular order of importance, please note the following.

1. You "forgot" to attach to your letter the phantom non-disclosure agreement that Tom has never
seen, much less endorsed, whereby he would have agreed to preserve the sanctity of your client's
precious trade secrets. Please provide that at your earliest convenience. Nor have you cited any
common law or statutory obligation prohibiting Tom from broadcasting as widely as he deems
fitting any information which was delivered to him spontaneously and without solicitation,
whether proprietary or not. Your client has no legitimate expectation, reasonable or even
unreasonable, that Tom would consider such information confidential or lift a single finger to
preserve its secrecy. Finally, you provide no explanation of under what conceivable authority
you would propose to hold Tom liable in damages arising from his compliance with the
compulsion of a court-sanctioned subpoena, even were it regarding information which your client
had not already, by gratuitously dumping it in Tom's lap, voluntarily placed into the public
domain.

2. You surely realize that Tom has for many years been one of Montana's most-prolific contributors
to Republican candidates. The correct posture for persons such as your client to adopt when
approaching persons such as Tom is not to threaten him or make demands of him, but rather to
obsequiously inquire whether they please may have leave to enjoy the pleasure of licking Tom's
boots. Right now, Tom deems your client not worthy of that base indulgence. Tom is not at all
inclined to "leave it at the office" regarding this affront. Your client chose to make this personal;
and Tom chooses to take it personally . Tom is offended and incensed to have been treated so
shabbily by your client. His anger at Mr. Eaton by far eclipses his anger at Gene Jarussi, which a
week ago I wouldn't have thought possible. Accordingly, unless and until Mr. Eaton has righted,
to Tom's subjective satisfaction, the wrong that he he has, through you, visited upon Tom, any
candidate or group which retains Mr. Eaton in any capacity will by that act be signing away any
likelihood of receiving any financial support from Tom.
 3. As no doubt a fan of Montana's statutory Maxims of Jurisprudence, you must realize that the law
does not require Tom to perform idle acts. Mark Parker informs me that his motion to quash in
the same matter succeeded only in the Judge directing the subpoena altered in some insignificant
fashion, not quashed. Accordingly, any effort by Tom to quash his subpoena would be nothing
if not idle.

4. Tom is a businessman, not an altruist. No good businessman would squander his own money to
protect what may or may not be an asset, in which he owns no interest. Tom will not volunteer a
penny of Hauptman money to protect an Eaton alleged asset. If Mr. Eaton wants his fancied
confidentiality preserved he has every necessary measure of standing sufficient to empower him
to take whatever steps may be appropriate (short of making more silly demands of Tom) to
protect that confidentiality, on his own behalf and on his own dime. I understand Eaton is very
well-acquainted with an attorney whom he can perhaps induce to perform that work cheaply.
Eaton could even, if he wants Tom involved as a moving party, have the decency to do what he
should have done in the first instance (and still may if he so wishes)--which is offer to, at Eaton's
expense, retain counsel to represent Tom in seeking to quash the subpoena. If your client wishes
to pursue this avenue, Tom has only a couple of simple requirements, those being (a) his counsel
will be neither you nor anyone affiliated with you, and (b) the only attorney-client matter Tom's
counsel may share with Mr. Eaton is attorney fees and the payment thereof by Mr. Eaton.

5. We already know that you won't be again contacting Tom directly, because Tom's attorney
absolutely does not consent. Please instruct Mr. Eaton that neither does Tom ever wish to hear
from him or any of his clients again unless the insult of your letter has first been rectified. Tom
requires that (with one exception) Mr. Eaton, 47 North Communications, all other entities in
which Mr. Eaton holds any interest, and all clients represented by any of the above, strike Tom's
name off their mailing/solicitation lists. The one and only instance in which Tom will welcome
any communication from your client would be one addressed to Tom in my care, in the form of a
sincere and profuse apology accompanied by proper atonement. As of right now, proper
atonement would be a check to compensate Tom for my fees to date of $680, plus as an
additional token of Mr. Eaton's contrition a couple cases of above-the-top-shelf red wines.
Obviously, the cost of atonement will snowball commensurate with whatever further
aggravation and ticks of my timeclock that your client causes Tom to suffer.

Tom intends to make a complete return on his subpoena on the 12th, as he is compelled to do. Feel free
to notify me before then regarding anything further you have, provided it (unlike your 12/28 letter) bears
some actual substance. If your hubby wishes to pay for counsel to represent Tom in taking any other
tack, have that attorney contact me well before the 12th.

Very trul yours,

JAMES P. HEALOW