LAW OFFICES OF

LIPPE & ASSOCIATES

ATTORNEYS AND COUNSELORS AT LAW

A PROFESSIONAL CORPORATION

EMIL LIPPE, JR."t PLAZA OF THE AMERICAS, SOUTH TOWER "BOARD CERTIFIED
600 N. PEARL STREET, SUITE S 2460 CIVIL TRIAL LAW AND
PLAZA OF THE AMERICAS CIVIL APPELLATE LAW,
DALLAS, TEXAS 75201 TEXAS BOARD
OF LEGAL SPECIALIZATION
(214) 855-1850

FACSIMILE: (214) 720-6074

t ALSO ADMITTED URL: http://www.texasIaw.com

IN COLORADO AND
DISTRICT OF COLUMBIA

October 29,2010

VIA EMAIL AND CERTIFIED MAIL,

RETURN RECEIPT REQUESTED
#70011140000397957309
John M. Phillips and
The Breakthrough Sports Agency
12100 Sunset Hills Rd., Suite 130
Reston, Virginia 20190

Re: Your blog comment or article concerning Willis & Woy Sports Group, 1.1.; "
and Jordan Woy v, Horace Smith and LaShonta Smith a/Ida Shonta Od'
Cause No. 10-13288, in the 68th District Court, Dallas County, TX

Dear Mr. Phillips:

This law firm represents Willis & Woy Sports Group, LLC ("WWSG"), and has been ~s
to contact you concerning your comments concerning the above-referenced lawsuit which
understand that you are in the process of attempting to publish in a law review article.

The portion of your article which we have seen is the paragraph beginning with "Wh~r : is
any sense of responsibility?" and includes the following statement: "Woy & Willis' age: y
committed $ fraud, but they seek to hide behind the actions of their employee, a director of scout~' g
no doubt." Your comment also alleges that the actions of any employee can be foreseen, and refi rs
to allegations that WWSG desires to add thirty (30) athletes in 2010, saying that it "sounds like:th, y
cannot adequately manage the ones they have." 'I
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Your comments are factually inaccurate, and either based upon speculation and conjec~Je,
or are simply being made maliciously for the purpose of defaming, disparaging, and subje~ti~g
WWSG to scorn and ridicule in the community and profession. i :~

First of all, if you are alleging, or seeking, to imply in any fashion whatsoever, that ww~b
either has claimed or plans to suggest that any of the players whom it has under contract have Jy
financial risk arising from the unauthorized transactions of Mr. Smith, such speculation is absolute y
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 John M. Phillips
October 29,2010
Page 2

false and unsupported. In fact, WWSG took immediate action upon learning of Smith's
unauthorized behavior, first suspending and then firing him, and has begun steps designed to
forestall any liability on the part of the players because, of course, the players in question ~ere
unaware of Smith ' s actions and had not approved the same. WWSG takes its responsibilities toward
its players whom it has under contract very seriously, and under no circumstances will tolerate any
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improper behavior subjecting its players to unauthorized, unethical, or otherwise improper liabiHty
or exposure of any source whatsoever. i
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The facts are that Horace Smith acted completely on his own in violation of all establis~ed
procedures ofWWSG and without the knowledge, approval, authority or consent of his emploter,
that as soon as any indication was received of his activity, he was immediately placed uwon
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suspension, and as soon as the investigation determined that the accusations were accurate, Srriith !
was terminated as an employee. Further, WWSG has, at his own considerable expense undertaken
immediate affirmative action to obtain a court injunction against further improper actions by Smhh,
rrcovery of all damages incurred as a result of his actions, and to obtain immediate injunctive re~ief
and recovery of all damages incurred. WWSG will take all steps necessary to avoid harm to anI[ of
the athletes whom it represents, to recover any damages caused by Smith's unauthorized activlty,
and to prevent future such occurrences. WWSG has not, as your article falsely accuses, sought to
avoid responsibility but rather is seeking to deal affirmatively with all of the issues raised by t~is
course of conduct, solve the problems, remedy the damage, and prevent future such activities fr~m '
taking place. Thus, rather than hiding from the truth, WWSG is taking affirmative action, ~nd
dealing properly and forcefully with the problems that have occurred, and taking all action availa~le
under law to resolve these issues. '

We therefore demand that you cease all future publication of any articles, blogs, or statemehts
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which either state or imply, directly or indirectly, that the actions of Horace Smith were done un~er
the authority or with any knowledge or approval ofWWSG and further demand that you retract a1nd
refrain from any further publication of allegations or implications that WWSG is in any sertse
whatsoever exposing any of its players to potential liability to third parties. We specifically demand
that you not publish any remark or utterance alleging or implying that Jordan Woy, or WWSG
"committed fraud." We consider this a violation of defamation laws and my clients will undertake.
all necessary means to protect their legal rights with respect to the publication of such remarks. In .
the event that you have already published or distributed such remarks to a third party we demand that •
they, along with the other defamatory remarks identified herein, be immediately retracted.

We will appreciate your prompt compliance with these demands. To the extent applicable, .
we also ask that you provide us with a true and correct copy of any and all retractions. We assume I

as a sports agent, professional and licensed attorney that you will share the same commitment to the .
truth and professionalism as Willis & Woy.
John M. Phillips
October 29, 2010
Page 3

Very truly yours,

LAW OFFICES OF LIPPE & ASSOCIATES

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