---------- Forwarded message ----------

From: Mario Nicolais <marionicolaisesq@gmail.com>

Date: Mon, Jul 3, 2017 at 1:31 PM
Subject: Re: OS 2017-0006 - CIW v. DCRCC
To: Matt Arnold <campaignintegritywatchdog@gmail.com>

Mr. Arnold -

I have reviewed your proposal with DCRCC officers and they will not sign the non-disparagement agreement
you have proposed. It is far too broad, extending well beyond the scope of this case. It is an absolute deal-
breaker for them.

Consequently, your current offer is rejected.

Mario

On Thu, Jun 29, 2017 at 11:46 AM, Matt Arnold <campaignintegritywatchdog@gmail.com> wrote:
...

Mario -

sounds like we're on track for a settlement.

Some form of non-disparagement agreement is probably necessary; the public attacks on CIW and
its officer have to stop.
I'm open to narrowing the scope to encompass only past campaign finance cases involving CIW
and/or officer Matt Arnold.
Agreed that putting past disparagement behind us and focusing on the future and winning in 2018 is
the preferable goal.
Can we discuss by phone?

Matt

On Thu, Jun 29, 2017 at 8:13 AM, Mario Nicolais <marionicolaisesq@gmail.com> wrote:

Mr. Arnold -

I have had the chance to review these documents with my clients and they are willing
to accept the Proposed Stipulated Judgment. However, they do not see a need for the
non-disparagement agreement. They don't believe it is your intention to disparage the
DCRCC any further, but have concerns about the breadth of the agreement.

If it is acceptable to CIW to stipulate to the judgement you have proposed without the
accompanying non-disparagement agreement, please let me know and we can
hopefully put this matter behind us. I know the officers of the DCRCC would like to
focus on the future and 2018 elections rather than litigation.

Mario
On Mon, Jun 19, 2017 at 4:48 PM, Matt Arnold <campaignintegritywatchdog@gma
il.com> wrote:

Mr. Nicolais,

certainly. Had sent these earlier to the previous DCRCC registered agent,
who forwarded them to the current chair.

I believe the proposed settlement is more than fair, and would save all
parties the time and expense of a hearing and further proceedings.

Attached:

1) proposed Joint Motion for Stipulated Judgment

2) proposed Joint Stipulated Judgment
3) proposed Joint Non-Disparagement Agreement

Let me know your thoughts on whether the proposed settlement

documents can form the basis of a negotiated disposition of the case.

Regards,

On Mon, Jun 19, 2017 at 2:03 PM, Mario Nicolais

<marionicolaisesq@gmail.com> wrote:

Mr. Arnold -

If you would please forward me your proposed settlement

documents, I would appreciate it. Thank you.

Mario

On Mon, Jun 19, 2017 at 2:01 PM, Matt Arnold

<campaignintegritywatchdog@gmail.com> wrote:

Mr. Nicolais,

thought I'd detected your writing style in the

DCRCC motion.
Have you been engaged as the Establishment
attorney in all cases opposing CIW?
Curious as to who's picking up your tab.

Have you reviewed the draft stipulated judgment

and motion provided to the DCRCC as a
proposed settled resolution to this matter?
Or do you prefer to proceed to hearing and bilk
your client (whoever that actually is) for more
fees before increasing your loss ratio?
Hoping that you might eventually win a case
against me is probably not the most efficient use
of your client's resources.
;-)

Regards,