State of New Hampshire Rockingham, Ss Superior

Filed File Date: 7/1/2020 3:17 PM Rockingham Superior Court E-Filed Document

STATE OF NEW HAMPSHIRE

ROCKINGHAM, SS SUPERIOR COURT

) BLYTHE BROWN, ) ) Plaintiff, ) Civil Action No. 218-2020-CV-00673 v. ) ) DANIEL GERHARD BROWN, ) ) Defendant. ) ) ) ) )

PLAINTIFF’S PARTIAL OBJECTION TO DEFENDANT’S EMERGENCY MOTION TO REDACT DEFENDANT’S HOME ADDRESS FROM THE PUBLIC DOCKET, SEAL THE MINIMALLY REDACTED COMPLAINT TEMPORARILY, AND FOR AN ORDER TO SHOW CAUSE WHY A MORE FULLY REDACTED COMPLAINT SHOULD NOT BECOME THE PUBLIC VERSION

1. Blythe Brown (“Plaintiff”) hereby partially objects to and opposes the “Emergency Motion”

filed by Daniel G. Brown (“Defendant”) on June 29, 2020, which seeks to redact Defendant’s

residential address from the publicly filed Complaint, and to seal in its entirety the publicly

filed redacted Complaint pending a hearing.

A. Defendant’s Address

2. With respect to Defendant’s request that his residential address be redacted from the publicly

filed Complaint, Plaintiff’s attorney has already informed defense counsel that she will assent

to the request, to the extent the Court approves it and allows Plaintiff to file a substitute

pleading redacting the address. (Exhibit 1 (Re: Brown v. Brown, June 29, 2020 at 4:45 p.m.)).

09821-00001/12218192.1

3. The circumstances that led to the inclusion of Defendant’s address are as follows. On June 29,

2020 at 8:24 a.m., Plaintiff first attempted to initiate this case by filing a Complaint (in both

sealed and redacted form) that did not include the Plaintiff’s and Defendant’s addresses.

(Exhibit 2 (Re: Filing Submitted for Case: 1209772; Envelope Number: 1209772, June 29,

2020)). However, at 12:23 p.m., the Court notified Plaintiff that the Court had rejected the

Complaint and related filings and requested that Plaintiff include the parties’ addresses in the

Complaint pursuant to Superior Court Rule 7(a). (Exhibit 3 (Re: Filing Returned for Envelope

Number: 1209772 in Case: 1209772, for filing Complaint - Civil, June 29, 2020)). Plaintiff

therefore updated the Complaint accordingly and, at 12:55 p.m., re-filed the Complaint and

related case filings. (Exhibit 4 (Re: Filing Submitted for Case: 1210694; Envelope Number:

1210694, June 29, 2020)). At 1:59 p.m., the Court accepted the Complaint and related case

filings, assigned a docket number to the proceeding, and entered the non-sealed Complaint on

the public record. (Exhibit 5 (Re: Filing Accepted for Case: 218-2020-CV-00673; Blythe

Brown v Daniel Gerhard Brown; Envelope Number: 1210694, June 29, 2020)).

4. Moreover, Defendant’s residential address is already publicly available. Defendant’s own

counsel recently publicly filed the Defendant’s residential address with the 10th Circuit, Family

Division in Portsmouth in a Petition to unseal certain information in anticipation of this very

lawsuit. (See In the Matter of Daniel G. Brown and Blythe G. Brown, 670-2019-DM-00341,

Daniel G. Brown’s Petition to Bring Forward and For Partial Unsealing of Certain Documents

at Introduction & ¶ 5, June 15, 2020)). Defendant’s residential address is also available on the

Internet and in public fora, and he has publicized his residence as well. (See, e.g., Exhibit 6

(“Dan Brown’s House,” Virtual Globetrotting, https://virtualglobetrotting.com/map/dan-

browns-house/view/google/ (providing photograph of Dan Brown’s residence, map with street

name and designation, and coordinates), last accessed June 30, 2020); Exhibit 7 (“Dan Brown

– Residence,” Wikimapia, http://wikimapia.org/14083316/Dan-Brown-Residence (providing

coordinates of Dan Brown’s residence); see also Exhibit 8 (Yahoo, “‘Da Vinci Code’ author

Dan Brown’s house is EXACTLY what you’d expect,” May 23, 2013,

https://www.yahoo.com/news/blogs/spaces/da-vinci-code-author-dan-brown-house-exactly-

180438425.html); Exhibit 9 (New York Times, “The World According to Dan Brown,” Sept.

30, 2017, https://www.nytimes.com/2017/09/30/books/dan-brown-origin.html)).

5. Notwithstanding the above, Plaintiff agrees to the redaction of both parties’ addresses, if

permitted by the Court.

B. Plaintiffs’ Publicly Filed Complaint Should Not Now Be Sealed

6. Plaintiff’s Complaint is on the public record and has been since 1:59 p.m. on June 29, 2020.

(Exhibit 5 (Re: Filing Accepted for Case: 218-2020-CV-00673; Blythe Brown v Daniel

Gerhard Brown; Envelope Number: 1210694, June 29, 2020)). Nevertheless, Defendant

moves that the Complaint—in its entirety—should be sealed pending a hearing. Plaintiff

opposes the motion.

7. Under Superior Court Rule 13B (a)(2) and New Hampshire case law, Defendant bears a heavy

burden of proving that the Complaint should be confidential. See Superior Court Rule 13B

(a)(2) (“The burden of proving that a document or a portion of a document should be

confidential rests with the party or person seeking confidentiality.”); see also Associated Press

v. State, 153 N.H. 120, 129 (2005) (“We have repeatedly held that . . . under the constitutional

and decisional law of this State, there is a presumption that court records are public and the

burden of proof rests with the party seeking closure or nondisclosure of court records.”)

(quoting Douglas v. Douglas, 146 N.H. 205, 208 (2001)); Petition of Keene Sentinel, 136 N.H.

121, 127 (1992) (“the presumption is strongly in favor of open judicial proceedings and

unsealed records”) (quoting Keene Publishing Corp. v. Keene District Court, 117 N.H. 959,

962 (1977)).

8. Defendant has not met his high burden for a wholesale interim sealing of the operative pleading

in this case. Defendant vaguely claims that “the Complaint continues to contain information

that the Family Division indicated, at the parties’ request, was to remain sealed.” (Def. Mot.

at 2). However, Defendant has not identified which information or portions of the Complaint

should be subject to further redactions, if any, thereby leaving both the Plaintiff and the Court

completely up in the air. Vague, conclusory claims of “embarrassment” do not satisfy the first

stage of meeting the heavy burden that applies, which is to spell out just what the Defendant

wishes to withhold from public view. He has not even attempted to do so, and for that reason

alone, the Court should deny the Motion.1

9. Additionally, Defendant’s requested sealing in this case would be an extraordinary measure,

particularly in light of the redactions that Plaintiff already has made. As provided in Plaintiff’s

Motion to Seal filed on June 29, 2020, portions of the Complaint quote or refer to the

Defendant’s Financial Affidavit, which was filed in the 10th Circuit, Family Division in

Portsmouth (the “Circuit Court”) during the parties’ divorce proceedings. Plaintiff moved to

seal those portions of the Complaint in order to comply with RSA 458, § 15-b(II), which

prohibits the knowing disclosure of “a financial affidavit to any person not authorized to obtain

the financial affidavit.” As also stated in Plaintiff’s Motion to Seal, on December 4, 2019, the

1 Superior Court Rule 11(c) obligates a moving party to certify to a good faith attempt to obtain concurrence to the relief sought before filing a motion. Without knowing what portions of the Complaint the Defendant wants to redact from the public document, Plaintiff has no way of knowing whether an accord could have been reached.

Family Division sealed the parties’ divorce file and related documents, including the parties’

Financial Affidavits. As provided in Plaintiff’s Motion to Seal, for this additional reason

Plaintiff redacted the statements from the Financial Affidavit from the publicly-filed

Complaint.

10. Defendant’s attempt to piggyback on the sealing of the parties’ divorce file in the Circuit Court

fails for at least two reasons.

11. First, the October 2, 2019, motion to seal is largely directed to “confidential sensitive

information regarding financial matters” and their “confidential and sensitive financial

information [and] their personal and identifying information” in that respect. (Def. Mot.

Exhibit A, ¶ 4). The Circuit Court’s Order, (Def. Mot. Exhibit B), similarly focuses on the

same subjects.

12. The Complaint now before this Court does not disclose any of the information that was sealed

as part of the Browns’ divorce proceedings. Rather, it is brought under RSA 458, § 15-b,

which expressly allows a party “aggrieved by a false statement in a financial affidavit” to “file

a civil action for money damages.” Indeed, Defendant now seeks to seal the entire Complaint,

while at the same time publicly commenting on the lawsuit and the contents of the Financial

Affidavit that is at the center of this dispute. (Exhibit 10 (People, “Author Dan Brown's Ex-

Wife Files Suit Accusing Him of Using Marital Assets to Fund Affairs,”

https://people.com/books/dan-brown-ex-wife-lawsuit-removing-assets-fund-multiple-affairs/,

June 30, 2020)); Exhibit 11 (Boston Globe, “Ex-wife of ‘Da Vinci Code’ author Dan Brown

alleges he led a double life,” https://www.boston.com/culture/local-news/2020/06/30/author-

dan-brown-ex-wife-lawsuit, June 30, 2020)). Apparently, Defendant seeks, on the one hand,

to completely silence Plaintiff’s allegations in her Complaint, and on the other hand, to

simultaneously inject into the public forum Defendant’s purported side of the story. Defendant

cannot have it both ways.

13. Second, Defendant’s demand for a wholesale sealing of the Complaint, with no specificity,

falls far short of meeting the high burden of proof necessary to keep this case completely out

of public view pending a hearing. See Petition of Keene Sentinel, 136 N.H. at 126 (“the

presumption is strongly in favor of open judicial proceedings and unsealed records”).

14. WHEREFORE, Plaintiff requests partial denial of Defendant’s Emergency Motion to Redact

Defendant’s Home Address From the Public Docket, Seal the Minimally Redacted Complaint

Temporarily, and for an Order to Show Cause Why A More Fully Redacted Complaint Should

Not Become the Public Version.

Respectfully submitted,

Blythe Brown

By her attorneys,

By her attorneys, Counsel for Plaintiff Blythe Brown

Dated: July 1, 2020 /s/ Harvey J. Wolkoff Harvey J. Wolkoff** Aliki Sofis** Kathleen Marini** QUINN EMANUEL URQUHART & SULLIVAN, LLP 111 Huntington Avenue, Suite 520 Boston, MA 02199 Tel: (617) 712-7100 [email protected] [email protected] [email protected]

**pro hac vice pending

/s/ Joseph D. Steinfield Joseph D. Steinfield (NH Bar No. 18721) 130 Court Street Keene, NH 03431 Tel: (617) 285-3937 [email protected]

Certificate of Service

I hereby certify that on this date I am sending a copy of this document as required by the court. I am electronically sending this document through the court’s electronic filing system to all attorneys and to all other parties who have entered electronic service contacts (email addresses) in this case. I am also sending the document by email and regular mail to Joan A. Lukey, Choate Hall & Stewart LLP, Two International Place, Boston MA 02110.

/s/ Joseph D. Steinfield Joseph D. Steinfield, Bar No. 18721 130 Court Street Keene, NH 03431 (617) 285-3937 [email protected]

EXHIBIT 1 From: Harvey Wolkoff Sent: Monday, June 29, 2020 4:54 PM To: Lukey, Joan Cc: Joseph Steinfield; Aliki Sofis Subject: Brown v. Brown Attachments: Notification of Service, Filing, or Court Documents for Case: 218-2020-CV-00673, 1210694, Blythe Brown v Daniel Gerhard Brown for filing Complaint - Civil; FW: Filing Returned for Envelope Number: 1209772 in Case: 1209772, for filing Complaint - Civil

Joan,

As you know, we provided you with a close version of the Complaint that was filed today back on May 22, 2020. During our conversations over the last several weeks, you did not mention any issues to me with respect to sealing or redacting any information contained in the Complaint. I made clear that we would be publicly filing (although we did redact certain information, as you know), and you requested a week ago Friday only that I serve you a courtesy copy on the day of filing so that there was no delay in your receiving it. we followed your instructions.

I would have been happy to redact the defendant’s address from the public version of the complaint, and still am. Please note however that we first attempted to file the Complaint without either of the parties’ addresses, but we received notice that the Court rejected our filing at 12:23 PM and requested that we include the parties’ addresses in the Complaint pursuant to Superior Court Rule 7(a). Please see attached. Accordingly, we updated the pleading pursuant to the Court’s rules and requirements. As you will see from the date stamp on the as-filed operative pleading, the Complaint was re-filed with the Court as of 12:55 PM today. Based on the notice we received from the Court, the Court then accepted the pleading and entered it into the public record as of at least 2:00 PM today. Please see attached.

Finally, with respect to Mr. Brown’s address, his address and images of his residence are publicly available, including on Google and WikiMapia. So, filing under seal would not have been effective anyway.

Thank you, and please let me know if you have questions.

Harvey.

Harvey Wolkoff Partner Quinn Emanuel Urquhart & Sullivan, LLP 111 Huntington Avenue, Suite 520 Boston, MA 02199 617.712.7108 Direct 617.620.4023 Cell [email protected] www.quinnemanuel.com

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EXHIBIT 9 6/30/2020 The World According to Dan Brown - The New York Times

https://nyti.ms/2fEZQ30

PROFILE The World According to Dan Brown

By Sarah Lyall

Sept. 30, 2017

RYE BEACH, N.H. — Anyone who has read Dan Brown’s work — and with 200 million copies of his books in print, you know who you are — is familiar with his signature technique of inserting little chunks of expository information into the narrative. Among the topics addressed in his latest thriller, “Origin”: the wide-ranging talents of Winston Churchill, the elusive appeal of abstract art, the exciting peculiarities of Gaudi’s Sagrada Familia cathedral and the latest insane developments in the world of artiﬁcial intelligence.

This is central to the Brown approach, because he himself prefers literature that is instructive and, ideally, not wholly invented. “I feel like if I’m going to take time reading, I better be learning,” he said recently. He was sitting in his large and cunningly designed house here in the New Hampshire countryside. Of his novels, he said: “This is the kind of ﬁction I would read if I read ﬁction.”

“Origin” is Mr. Brown’s eighth novel. It ﬁnds his familiar protagonist, the brilliant Harvard professor of symbology and religious iconography Robert Langdon, embroiled once more in an intellectually challenging, life-threatening adventure involving murderous zealots, shadowy fringe organizations, paradigm-shifting secrets with implications for the future of humanity, symbols within puzzles and puzzles within symbols and a female companion who is super-smart and super-hot.

As do all of Mr. Brown’s works, the new novel does not shy away from the big questions, but rather rushes headlong into them. Here the question is: Can science make religion obsolete?

As the story begins, Edmond Kirsch — “billionaire computer scientist, futurist, inventor and entrepreneur” — is preparing to present a new discovery to an eager crowd (and to the world, via the internet) at the Guggenheim Bilbao in Spain. He has promised that this announcement, the details of which are enticingly withheld until the very end of the book, will upend people’s view of religion by proving irrefutably that life can be created using the laws of science, thus excising God from the equation. (The theory is real, borrowed from the M.I.T. physicist Jeremy England.)

“Origin,” is to be published by Doubleday Oct. 3, with an initial printing of 2 million copies, eventually extending to several dozen countries in 42 languages, according to the publisher. Readers will ﬁnd in it a familiar swirl of big ideas and nonstop action, so that those who aren’t enchanted by the erudition can ﬁnd relief in the plot, and vice versa.

Mr. Brown, 53, spent four years writing and researching the book. He is nothing if not disciplined. He rises at 4 a.m. each day and prepares a smoothie comprising “blueberries, spinach, banana, coconut water, chia seeds, hemp seeds and … what’s the other kind of seed?” he asked. “Flax seeds, and this sort of weird protein powder made out of peas.” He also makes so-called bulletproof coffee, with butter and coconut oil, which he says changes “the way your brain processes the caffeine” so as to sharpen your mind.

His computer is programmed to freeze for 60 seconds each hour, during which time Mr. Brown performs push-ups, situps and anything else he needs to do. Though he stops writing at noon, it’s hard for him to get the stories out of his head. “It’s madness,” he said of his characters. “They talk to you all day.”

Patricia Wall/The New York Tiimes

https://www.nytimes.com/2017/09/30/books/dan-brown-origin.html 1/3 6/30/2020 The World According to Dan Brown - The New York Times Mr. Brown’s books have made him rich, but he does not have the aura of a rich person. His house, concealed behind gates, is not so much the home of a ﬂashy millionaire as that of a person with the means to alter his surroundings in any wildly idiosyncratic way he (and his wife) want to.

He showed me around on condition that I didn’t present the house as “incredibly ostentatious.”

No, more like fantastically bonkers. Push a button on a library shelf, and it swings around to reveal a secret shelf that contains the first Brown book (“The Giraffe, the Pig, and The Pants On Fire,” written when he was 5) and an exotic scientific-looking object that turns out to be the antimatter prop used in the film of “Angels and Demons.” Touch the corner of a painting in the living room, and it slides aside to expose a hidden room whose walls are decorated with gold records, awarded to Mr. Brown as a result of vast audiobook sales in Germany.

Outside a bathroom is an antique Bible opened to Job 38:11 — “Hitherto shalt thou come, but no further.” (“That means it’s occupied,” Mr. Brown said.) The inside of the door is covered top to bottom with a replica of a page from one of Leonardo da Vinci’s notebooks, written in backward handwriting. “It’s one of his famous quotes, which you cannot read until you close this door and position yourself on the toilet or at the sink and read it in the mirror,” Mr. Brown said.

Here is Leonardo’s celebrated painting “The Virgin of the Rocks,” or at least the reproduction used in the ﬁlm of “The Da Vinci Code.”

Also, look over there. It’s the “Mona Lisa,” smiling enigmatically from her canvas on a different wall.

“That’s a reproduction too, to save you from asking,” Mr. Brown said. (Such is the power Mr. Brown can exert on an institution that even the haughty Louvre, which has the real paintings, offers “Da Vinci Code”-themed tours and admits on its website that the book and ﬁlm have increased “Mona Lisa’s” popularity.)

The house is also full of paintings, sculptures and unexpected additional works by Mr. Brown’s wife, Blythe, who has a taste for the macabre. A dining room sideboard contains a tableau featuring taxidermied animals like a fox and a pheasant; a table in the kitchen holds a Hieronymus Bosch-like sculpture replete with tiny skeletons and other objects churning together in a hellish conﬁguration.

“Blythe has a ﬁxation with death,” Mr. Brown said cheerfully. “Once she literally took me on a date to a cemetery.” The two met more than 20 years ago in Los Angeles, where Mr. Brown moved after graduating from Amherst College. He grew up in Exeter, N.H., and went to high school at Phillips Exeter Academy, where his father taught math. (I was at the school as well and knew him slightly.)

At the time, Mr. Brown was a not-successful musician; his future wife, more than a decade older than he is, was the director of artistic development at the National Academy for Songwriters. Because of their unequal work relationship, they dated in secret for seven years, Mr. Brown said, at one point even attending the Grammys together, along with fake dates, to conceal the romance.

Among other features of their house: a shirt signed by the members of Germany’s 2014 World Cup-winning soccer team; a cantilevered staircase built right out of the wall, with no supports from above or below; and two pillars that are exact replicas of those in Rosslyn Chapel in Scotland, which appeared in “The Da Vinci Code” and was quickly overrun by Brown enthusiasts searching for the Holy Grail.

Downstairs, there’s a medieval suit of armor, moved here after an unsuccessful sojourn in a more prominent spot.

“We built a niche for it in the library, and it was just overkill,” Mr. Brown said. “It sort of felt like ʻPirates of the Caribbean’ or something.”

Mr. Brown does not have a lot in common with Edmond Kirsch, the futurologist and entrepreneur of his book, but they do share a car: the Tesla Model X, the least expensive version of which costs about $80,000. Among other things, it can drive and park itself.

Its owner seems a little bit bemused to ﬁnd himself in possession of such a rareﬁed object. “I’m not a car person,” he said. “Three years after ʻThe Da Vinci Code’ came out, I still had my old, rusted Volvo. And people are like, ʻWhy don’t you have a Maserati?’ It never occurred to me. It wasn’t a priority for me. I just didn’t care.”

Eventually, he bought a Lexus hybrid SUV, and then after that a Tesla sports car, which also did not sit easily with him.

“I felt like a jerk,” he said. “ I felt like I needed a gold chain and a ponytail or something. This one feels like the minivan of Teslas.”

He and I got into the car, which indeed looked kind of minivan-esque until it accelerated from 0 to 60 in under three seconds, right in the (not very long) driveway, and then switched lanes by itself on the highway.

We were on the way to Exeter, where Mr. Brown was going to a service in honor of his mother, who died several months ago. (“Origin” is dedicated to her; her initials, C.G.B., appear, very faintly, on the back cover of the book.) Mr. Brown credits his father, now 81, with instilling in him a love of science, math and intellectual puzzles, and his mother, who was religious but became disillusioned with church politics, with instilling in him a wonder for the mysteries of the world.

Though Mr. Brown comes out strongly in favor of science, both in person and in his novels, he cannot give up the possibility that there is something else out there.

“It’s probably an intellectual weakness,” he said, “but I look at the stars and I say, ʻthere’s something bigger than us out there.’ ” https://www.nytimes.com/2017/09/30/books/dan-brown-origin.html 2/3 6/30/2020 The World According to Dan Brown - The New York Times

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A version of this article appears in print on Oct. 2, 2017, Section C, Page 1 of the New York edition with the headline: Dan Brown, In a World Of His Own

https://www.nytimes.com/2017/09/30/books/dan-brown-origin.html 3/3 EXHIBIT 10 6/30/2020 Author Dan Brown's Ex-Wife Files Suit Alleging Affairs | PEOPLE.com

Author Dan Brown's Ex-Wife Files Suit Accusing Him of Using Marital Assets to Fund Affairs

Blythe Brown accused her ex-husband Dan Brown of living "a proverbial life of lies” in a new lawsuit

By Rachel DeSantis

June 30, 2020 04:09 PM

https://people.com/books/dan-brown-ex-wife-lawsuit-removing-assets-fund-multiple-affairs/ 1/5 6/30/2020 Author Dan Brown's Ex-Wife Files Suit Alleging Affairs | PEOPLE.com

Blythe and Dan Brown in 2006 PHOTO: GEORGE PIMENTEL/WIREIMAGE

https://people.com/books/dan-brown-ex-wife-lawsuit-removing-assets-fund-multiple-affairs/ 2/5 6/30/2020 Author Dan Brown's Ex-Wife Files Suit Alleging Affairs | PEOPLE.com Author Dan Brown’s ex-wife has led suit against him, alleging The Da Vinci Code scribe “lived a proverbial life of lies” during their marriage, and removed substantial funds from their marital assets in order to conduct affairs with multiple women.

Blythe Brown accused Dan, 56, of various wrongdoings in the lawsuit, which was led in Rockingham Superior Court in New Hampshire on Monday and has been obtained by PEOPLE.

As rst reported by the Boston Globe, Blythe's suit said her claims are based upon Dan’s “unlawful and egregious conduct” over the last few years of their marriage, which ofcially ended in December 2019.

The lawsuit portrays Blythe — who married Dan in 1997 — as a supportive partner who helped her husband recognize and pursue his talents as a writer, and who even contributed “key themes and critical ideas” to his novels, including the premise of the 2003 smash hit The Da Vinci Code.

“The relationship between Blythe and Dan was based on mutual trust, respect and honesty — or so she believed,” the suit said. “As it turns out, for the last several years of their marriage, Dan engaged in a systematic pattern of deception and lies.”

Blythe said Dan conducted affairs with various women, including a hairdresser, a political ofcial and his personal trainer, beginning in 2014, and concealed funds that constituted assets of their marriage to hide his trysts.

RELATED VIDEO: Justin Bieber Files $20 Million Defamation Lawsuit Against 2 Women Who Accused Him of Sexual Assault

In a statement to PEOPLE, Dan says he was “stunned” by Blythe’s “false claims,” and that he had been fair and truthful to her in their divorce settlement, through which he said she received more than half of their holdings.

"I have no heart to dispute my former wife in public, nor do I take pleasure in having to do so in court," he says, adding that the suit was "written without regard for the truth."

"For reasons known only to her and possibly her lawyer, Blythe Brown has created through this suit a ctional and vindictive account of aspects of our marriage

https://people.com/books/dan-brown-ex-wife-lawsuit-removing-assets-fund-multiple-affairs/ 3/5 6/30/2020 Author Dan Brown's Ex-Wife Files Suit Alleging Affairs | PEOPLE.com designed to hurt and embarrass me," he adds.

One of his alleged mistresses was a horse trainer in Holland whom Blythe had initially hired to travel to the U.S. to help the couple train their Friesian horse, the suit said.

The woman — who is referred to as “JP” — allegedly became a friend of the family and had an affair with Dan for six years. The suit said he’d take money out of his and Blythe’s accounts to buy her “extravagant gifts” and nance a horse training business for her in Holland.

Blythe said that she reluctantly moved out of her and Dan’s New Hampshire home in August 2018 after he became “exceedingly contentious” and asked for a divorce on the grounds that they had “grown apart,” the suit said.

RELATED: Angels and Demons: What's Fact – or Fiction?

Brown said in his statement that the couple shared little in common by the end of their marriage, and that he'd asked Blythe to enter marriage counseling three times, which she allegedly refused.

As the couple worked out their divorce on the nancial terms he requested, Dan was secretly “siphoning funds from their accounts and assets for his own benet,” according to the suit.

Blythe said she only recently learned of her ex-husband’s double life, and when she confronted him, he allegedly admitted to his indelity and to using “substantial” sums of their money to carry on the affairs. He is also accused of lying under oath in his nancial afdavit.

Additionally, the suit claimed that Dan told Blythe he did not have any projects in the pipeline, but that he actually has several in the works, including a TV series called Langdon, which is based on novels the couple “created together,” and from which he stands to make millions.

Blythe says her ex-husband’s actions have made it hard to sleep and eat, and have left her in “signicant emotional distress.”

https://people.com/books/dan-brown-ex-wife-lawsuit-removing-assets-fund-multiple-affairs/ 4/5 6/30/2020 Author Dan Brown's Ex-Wife Files Suit Alleging Affairs | PEOPLE.com “This lawsuit is about standing up for myself and asserting my self-worth,” Blythe says in a statement to PEOPLE. “I have continually tried to absorb the shocking truth withheld during our divorce that Dan had been leading a double life for many years during our marriage, all while coming home to me. I trusted this man for decades as my life’s love. We worked so hard together, struggling to build something meaningful. With great success came our promises to each other that we would not let it change us or our life together. I don't recognize the man that Dan has become. It is time to reveal his deceit and betrayal. After so much pain, it is time for truth. It is time to right these wrongs.”

Her attorney Harvey J. Wolkoff adds in a statement that Blythe intends to hold Dan “accountable for his dishonesty” via the lawsuit.

Meanwhile, in Dan's statement, he says that he stands by “truthfulness” of the nancial afdavit he signed, and that it was a complete list of the couple’s assets at the time.

"As part of the settlement agreement we reached, all of our assets as of that date were listed in writing. That document became part of the signed decree when we divorced in 2019. I swore to the truthfulness of what was contained on that list, and I stand by that nancial statement today. We were very fortunate that we equally were blessed with very substantial assets with which to move forward after that," he says. "I am stunned that now, years later, Blythe is seeking even more, and making false claims in her attempts. I also am saddened that there is not enough goodwill from 21 years of marriage to temper her unfortunate actions."

His attorney Joan Lukey has led a motion on his behalf to unseal condential nancial information in the divorce settlement in order to refute Blythe’s claims, the Globe reported.

https://people.com/books/dan-brown-ex-wife-lawsuit-removing-assets-fund-multiple-affairs/ 5/5 EXHIBIT 11 6/30/2020 Ex-wife of ‘Da Vinci Code’ author Dan Brown files suit claiming ‘unlawful and egregious conduct’ - The Boston Globe

●BREAKING WATCH LIVE: DR. ANTHONY FAUCI BREAKING: WATCH LIVE: DR. ANTHONY TESTIFIES ABOUT REOPENING FAUCI TESTIFIES ABOUT REOPENING BEFORE SENATE COMMITTEE BEFORE SENATE COMMITTEE Ex-wife of ‘Da Vinci Code’ author Dan Brown ﬁles suit claiming ‘unlawful and egregious conduct’ "I have continually tried to absorb the shocking truth withheld during our divorce that Dan had been leading a double life..."

By Mark Shanahan Globe Staff, Updated June 30, 2020, an hour ago

Author Dan Brown and his now ex-wife Blythe Brown. E. CHARBONNEAU

Author Dan Brown, the New Hampshire native whose 2003 novel “The Da Vinci Code” is one of the bestselling books of all time, is being sued by his ex-wife, who claims he https://www.bostonglobe.com/2020/06/30/lifestyle/ex-wife-da-vinci-code-author-dan-brown-files-suit-claiming-unlawful-egregious-conduct/?event=even… 1/7 6/30/2020 Ex-wife of ‘Da Vinci Code’ author Dan Brown files suit claiming ‘unlawful and egregious conduct’ - The Boston Globe engaged in “unlawful and egregious conduct” that amounted to a “proverbial life of lies” during the last several years of their marriage.

In a bombshell lawsuit filed Monday in Rockingham Superior Court in New Hampshire, Blythe Brown alleges that the 56-year-old author, to whom she was married from 1997 until last December, “secretly siphoned” off vast sums of money “to conduct sordid, extra-marital affairs” with women, including a Dutch horse trainer on whom he lavished extravagant gifts.

Blythe Brown is suing the author for misrepresenting the couple’s wealth in a sworn financial affidavit he signed as part of their divorce agreement, and for intentional and negligent infliction of emotional distress.

“This lawsuit is about standing up for myself and asserting my self-worth. I have continually tried to absorb the shocking truth withheld during our divorce that Dan had been leading a double life for years during our marriage, all while coming home to me,” Blythe Brown told the Globe in a statement Monday. “I trusted this man for decades as my life’s love. We worked so hard together, struggling to build something meaningful... I don’t recognize the man that Dan has become. It is time to reveal his deceit and betrayal. After so much pain, it is time for truth. It is time to right these wrongs.”

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In a statement, Dan Brown told the Globe he’s “stunned” that his ex-wife is “making false claims” and says he was fair and truthful in their divorce settlement.

“On the day that Blythe and I married, I never remotely thought that we eventually would grow so far apart,” he wrote.

Brown, who was raised in Exeter, N.H., and graduated from Amherst College, was a songwriter and, briefly, a teacher, before taking up writing full-time. His first three novels didn’t find an audience, but “The Da Vinci Code” did. A fast-paced thriller about a fictional Harvard “symbologist” who investigates a murder at the Louvre and stumbles upon an ancient society that guards dark secrets about Jesus and the Holy Grail, the book was an international sensation. It has sold more than 80 million copies and been adapted into a movie, starring Tom Hanks, which has grossed more than $760 million worldwide. In all, Brown’s seven novels have sold more than 250 million copies.

In her lawsuit, Blythe Brown says she was not merely a bystander to her ex-husband’s phenomenal success. She claims she was the “lead researcher” and “developed the premise of the critical concepts, historical emphases, and complex plot twists” for “The Da Vinci Code” and for all of Brown’s subsequent books, a string of bestsellers that includes “The Lost Symbol,” “Inferno,” and “Origin.” Together, she says, the couple “brainstormed the storylines and plot twists” of the novels. (Blythe Brown says she also helped with “Angels & Demons,” which was published in 2000, before “The Da Vinci Code,” but republished later.)

In interviews, Dan Brown has spoken often about his ex-wife’s role in crafting his books. In 2017, he told the Daily Mail: “I was writing about the Louvre and the Grail, but it was Blythe who said I should write about Mary Magdalene, too. I probably wouldn’t have written [The Da Vinci Code] without her. She’s a great researcher.” And in the https://www.bostonglobe.com/2020/06/30/lifestyle/ex-wife-da-vinci-code-author-dan-brown-files-suit-claiming-unlawful-egregious-conduct/?event=even… 3/7 6/30/2020 Ex-wife of ‘Da Vinci Code’ author Dan Brown files suit claiming ‘unlawful and egregious conduct’ - The Boston Globe acknowledgements of “The Da Vinci Code,” the author cites: “my wife, Blythe — art historian, painter, front-line editor, and without a doubt the most astonishingly talented woman I have ever known.”

In her lawsuit, Blythe Brown includes a sworn statement made by her ex-husband in an unrelated 2005 legal action in England alleging he plagiarized portions of “The Da Vinci Code.” In that case, which Brown won, the author credited his then-wife for refining the themes and plot of the bestselling book.

“[Blythe Brown] lobbied hard for me to find a way to use a theory which concerned the legend of the Holy Grail — the so-called ‘bloodline theory’... Initially, I was reluctant... finding it too incredible and inaccessible to readers — I thought it was a step too far,” Brown says in the court filing. “However... after much discussion and brainstorming with Blythe, I eventually became convinced that I could introduce the idea successfully.”

Despite his celebrity — Brown was one of TIME’s 100 Most Influential People in the World in 2005 — his public persona is conspicuously cerebral. In a 2004 profile of the author, The Guardian described him as “mundane,” “unexciting,” and “not exactly a riot of hedonism,” suggesting that biographers would be disappointed if they investigated Brown with as much verve as his fictional hero, Robert Langdon, searches for the holy grail.

“The life and times of Dan Brown imply not every tale has a sting,” wrote The Guardian.

But Blythe Brown claims in her suit that she noticed changes in her husband in 2014: “He started to act distant, dressed differently, and instigated arguments... over inconsequential matters for no apparent reason.” In 2018, Blythe Brown says, her husband told her he was unhappy in the marriage and wanted a separation. According to the lawsuit, Brown told his wife they’d “grown apart,” but could “remain best friends.”

Blythe Brown says she reluctantly moved out of the couple’s home in Rye Beach, N.H., in August 2018. She claims Brown wanted to avoid “a protracted public [divorce] https://www.bostonglobe.com/2020/06/30/lifestyle/ex-wife-da-vinci-code-author-dan-brown-files-suit-claiming-unlawful-egregious-conduct/?event=evendi ” d “ d d” h h h i f h i di h h d “f ll … 4/7 6/30/2020 Ex-wife of ‘Da Vinci Code’ author Dan Brown files suit claiming ‘unlawful and egregious conduct’ - The Boston Globe proceeding” and “persuaded” her that, at the time of their divorce, she had “full knowledge” of the vast wealth the couple had accumulated during their marriage.

“This was untrue,” the lawsuit states. “Dan had, for a number of years, secretly siphoned funds from their marital assets, at least in part to finance his activities with his mistresses, including... a young horse trainer who lived in Holland.”

The horse trainer is a Friesian horse specialist and talented dressage rider whom Blythe Brown brought to the United States from Holland in 2013 to train a Friesian horse owned by the Browns. The lawsuit states that after the Browns’ divorce was finalized, in December 2019, Blythe Brown discovered that her ex-husband had begun an affair with the horse trainer, identified in the suit by the initials “JP,” in 2014 while the trainer was recuperating from shoulder surgery at the couple’s home in New Hampshire.

Unbeknownst to his then-wife, according to the lawsuit, Brown secretly took large sums of money from the couple’s accounts to buy gifts for the horse trainer, including a prize- winning Friesian horse named “LimiTed Edition” whose price tag was $345,000, as well as a new car, a two-horse transport truck, and renovations to the woman’s apartment in Holland.

“The net effect of these transgressions substantially reduced the marital estate,” according to the lawsuit.

The suit states that in January 2020, Blythe Brown confronted her ex-husband about the secret wire transfers and he replied: “I’ve done bad things with a lot of people.” Brown, according to the suit, admitted having an affair with a local hairdresser and also with the horse trainer, telling his ex-wife that his relationship with the horse trainer “has and will continue.”

According to the lawsuit, Blythe Brown subsequently discovered that Brown had used marital assets to finance affairs with “a political official” at the couple’s vacation home on https://wwwA .bostonglobe.com/2020/06/30/lifestyle/ex-wife-da-vinci-code-author-dan-brown-files-suit-claiming-unlawful-egregious-conduct/?event=evenill d i h hi l i … 5/7 6/30/2020 Ex-wife of ‘Da Vinci Code’ author Dan Brown files suit claiming ‘unlawful and egregious conduct’ - The Boston Globe Anguilla, and with his personal trainer.

The lawsuit further claims that, at the time of the couple’s divorce, Brown told his wife that he didn’t have any upcoming projects. Blythe Brown says she later learned that

Brown was working on several new projects, including a television series, “Langdon,” based on the novels the couple “created together” and which NBCUniversal Studios has picked up.

“Dan stands to make millions from these projects, which is undoubtedly why he hid them from Blythe,” the lawsuit states.

“Blythe Brown agreed to a quiet divorce last year from her longtime husband Dan Brown,” her attorney, Harvey J. Wolkoff, Boston head of Quinn Emanuel, said in a statement. “Only afterward did she learn that, for years, he had been deceiving her. Blythe asks that her ex-husband be held accountable for his dishonesty. She hopes for a legal reckoning with the harm inflicted by his conduct.”

Brown, meanwhile, insists the financial affidavit he signed was a complete list of the couple’s assets at the time of the divorce.

“I swore to the truthfulness of what was contained on that list, and I stand by that financial statement today,” Brown said in his statement to the Globe. “We were very fortunate that we equally were blessed with very substantial assets with which to move forward after that.”

Through his attorney, Joan Lukey, Brown has filed a motion to unseal the confidential financial information in the divorce settlement to rebut his ex-wife’s claim that he concealed assets during their marriage.

“I am saddened that there is not enough goodwill from 21 years of marriage to temper her unfortunate actions,” he said.

https://www.bostonglobe.com/2020/06/30/lifestyle/ex-wife-da-vinci-code-author-dan-brown-files-suit-claiming-unlawful-egregious-conduct/?event=even… 6/7 6/30/2020 Ex-wife of ‘Da Vinci Code’ author Dan Brown files suit claiming ‘unlawful and egregious conduct’ - The Boston Globe Mark Shanahan can be reached at [email protected]. Follow him on Twitter @MarkAShanahan

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