IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION DANIEL M. SNYDER, Plaintiff, Civil Action No. 2011 CA 003168 B Judge Todd E. Edelman v. Next court date: July 29, 2011 CREATIVE LOAFING, INC., CL Event: Initial scheduling conference WASHINGTON, INC. (d/b/a WASHINGTON CITY PAPER); and DAVE MCKENNA, Defendants. PRAECIPE FOR CONTINUATION OF SPECIAL MOTION TO DISMISS THE COMPLAINT: EXHIBITS 101150 TO AFFIDAVIT OF ALIA L. SMITH, ESQ. Due to size restrictions, Defendants have had to submit multiple filings. Please consider this a continuation of Defendants’ Special Motion to Dismiss the Complaint. Dated: June 17, 2011 Respectfully submitted, BAKER & HOSTETLER, L.L.P. LEVINE SULLIVAN KOCH & SCHULZ, L.L.P. By: /s/ Bruce D. Brown By: /s/ Jay Ward Brown Bruce D. Brown (D.C. Bar No. 457317) Seth D. Berlin (D.C. Bar No. 433611) Mark I. Bailen (D.C. Bar No. 459623) Jay Ward Brown (D.C. Bar No. 437686) Washington Square, Suite 1100 Alia L. Smith (D.C. Bar No. 992629) 1050 Connecticut Avenue, N.W. 1050 Seventeenth Street, N.W., Suite 800 Washington, DC 200365304 Washington, D.C. 20036 Telephone: (202) 8611660 Telephone: (202) 5081100 Facsimile: (202) 8611783 Facsimile: (202) 8619888 [email protected]; [email protected]; [email protected], [email protected] [email protected] Counsel for Defendant Dave McKenna David M. Snyder (pro hac vice pending) DAVID M. SNYDER, P.A. 1810 S. MacDill Avenue, Suite 4 Tampa, FL 336295960 Telephone: (813) 2584501 Facsimile: (813) 2584402 [email protected] Counsel for Defendant CL Washington, Inc. ! ! ! "#$%&%'!()(! Sign In Register Now Subscribe Mobile Multimedia Today's Paper Going Out Guide Jobs Cars Real Estate Rentals Classifieds NEWS LOCAL POLITICS OPINIONS SPORTS Business Arts & Living Search The Washington Post washingtonpost.com > Sports > Redskins > Redskins Insider » E-mail Jason with comments, ideas and questions Complete football coverage • Redskins home • Game Center • The Shanahan playbook • The League On Twitter: RedskinsInsider and PostSports | Facebook | E-mail alerts: Redskins and Sports | RSS POST PRO PICKS The Skins Flunk Economics Sign up today for Post Pro Spent a long night working on a story for Sunday's paper, and have Picks, The Post's free, interesting stuff to blog about tomorrow - someone remind me, please, by weekly NFL pick 'em game, where you can win great posting a comment saying "Andyman" - but wanted to get this up tonight. prizes, form groups to play I had a copy of this article emailed to me from the American Enterprise against your friends, see Institute For Public Policy Research. The resident scholar there, Kevin A. how you fare against our Hassett, took an economist's eye to the NFL, and wrote an article experts or just play for fun. Register at comparing the Redskins and the Patriots. http://washingtonpost. com/pro-picks Here is the full link: http://www.aei.org/publications/filter.all,pubID.25173/pub_detail.asp TEXT ALERTS And here are some excerpts from the article to get you going For breaking Redskins "It is nearly impossible to derive surplus from the veteran free-agent news, text "REDSKINS" market, since you are paying market wages. While injuries and to 98999 emergencies might require some veteran signing, the draft is the only place to build a winning team. INSIDER LIVE So economics would predict that teams would uniformly put an enormous Join Rick Maese, Dan Steinberg and LaVar effort into perfecting their drafts, and avoid sinking excessive dollars into Arrington every Tuesday for costly free agents. In fact, this model predicts very well the behavior of Redskins Insider Live. one team, the New England Patriots. Their head coach, Bill Belichick, The show will air live at 10:30 a.m., can be viewed who received his undergraduate degree in economics from Wesleyan in its entirety at University in Connecticut, has been an artist at squeezing value-added http://washingtonpost. out of his draft picks, and has won three of the last five Super Bowls." com/redskinsinsiderlive all week and is available for Later, he compared the Pats' approach to the Skins. He doesn't pull any Sponsored Links download at the links punches: below. "Belichick keeps winning because so many others in the league behave 100% Legal Golf 'Trick' Subscribe 4 Bad Golfers Wanted To Test Trick To Add 30+ Yards To Drives! so strangely. Two economists, Cade Massey of Yale and Richard Thaler GolfFuel.com iTunes of the University of Chicago, studied years of draft history and found that teams make systematic errors that reflect a serious economic illiteracy. Coaches and general managers place too high a value on the top few INSIDER ON TWITTER Penny Stock Jumping 3000% picks, and too low a value on picks a bit further down. Join our 100% Free Newsletter & get Penny Stock Picks that Even more Redskins info jump high! -- in short bites. The Washington Redskins are perhaps the leading exemplar of this www.AwesomePennyStocks.com @RedskinsInsider tendency toward irrationality. Last spring, for example, the Redskins gave up key draft picks for high-priced veteran players. An especially silly Buy a link here @HyperSkins trade gave the Jets three Redskins' picks: in the second and sixth rounds Network News this year and in the second round next year. The trade left the Redskins SEARCH THIS BLOG with only one pick in the first three rounds this year. Friends' Activity Go To compound this error, the Redskins filled their roster with mediocre, high-priced veterans, dropping $35 million on safety Adam Archuleta, $32.5 million on defensive lineman Andre Carter, $31 million on wide RECENT POSTS receiver Antwaan Randle El, and $25 million on wide receiver Brandon Mike Shanahan and Clinton Portis meet Lloyd--none of whom has ever been in the Pro Bowl. about remarks 9 Redskins, Texans The problem for economics is that teams like the Redskins continue to defenses vary exist, and are not driven out by competitive forces. They confound our Ankle injury limits Albert ability to model for two reasons. First, it is impossible to conceive of what Haynesworth in foolish thing the Redskins might do next. Second, their behavior can alter practice the decision framework for the fully rational teams. If the Redskins are Kyle Shanahan: Former pupil Matt Schaub going to bid up the prices of all wide receivers, for example, then a team !" 'knows the game' like the Patriots has to adjust (as they did) and load up on cheaper pass- LaRon Landry says 18 catching tight ends. tackles are not enough # The Redskins are not driven out of business because there is a high !$ Entries By Category demand for football in Washington, and the NFL has a monopoly. A % & 3-4 defense wisely run team cannot enter Washington and compete for Redskins Albert Haynesworth fans." '() Andre Carter * Quick Randoms: Have the Redskins LBs made a play of note all Anthony Armstrong season? Marcus's fumble recovery Sunday doesn't really count, does it? Brandon Banks " Someone refresh my memory ... Caught some gossip show on VH1 +, Brian Orakpo while flipping channels and they were asking a "celebrity" - in this case !! Bruce Allen the woman who "won" Flavor of Love - about 'ol Kid Bro Sweets. Guess Carlos Rogers there were some rumors out there that this female - Delisious (I think Chris Cooley that's how she spells it) - left Flavor Flav for CP. When grilled about Clinton Portis Portis, she said: "I don't know that man from a can of paint." Is that a real Dallas Cowboys expression, or is this woman particularly gifted at turning a phrase? View More Activity Daniel M. Snyder By Jason La Canfora | November 22, 2006; 1:03 AM ET DeAngelo Hall Devin Thomas " #$ $ $ Donovan McNabb Fred Davis Save & Share: Free agency Previous: Who They Are, And Where They Are Going Jammal Brown Next: In The Interest of Accuracy (My Last Blog About Ryan Clark and Dan Snyder) Jason Campbell Jason Reid Jim Haslett Sponsored Links Kareem Moore Mom Is 55, Looks 30... Kyle Shanahan Her clever $5 wrinkle therapy angers Botox Doctors. Find Out How! FDXNews8.com LaRon Landry Larry Johnson 100% Legal Golf 'Trick' 4 Bad Golfers Wanted To Test Trick To Add 30+ Yards To Drives! London Fletcher GolfFuel.com Malcolm Kelly Mike Shanahan $500,000 Life Insurance No Exam Necessary. Same- day coverage as low as $6.month. Free Quotes Minicamp USAcoverage.com NFL Draft Buy a link here Offensive line Polls Preseason schedule Comments Rex Grossman Running backs This sounds scary - but how did it work for George Allen? What are the differences Santana Moss between now and then, in practice? Special teams There was no true free agency then, no salary cap either, but he traded all kinds of Statistical analysis picks for guys like Dave Butz (no Pro Bowls), John Riggins (no Pro Bowls then, I believe), Calvin Hill (past his prime, but still good), Billy Kilmer, etc. I know I'm not Trent Williams listing a host of other guys. His whole belief was in getting proven vets. Willie Parker collective bargaining I'd like to see IF that can be measured against this era. negotiations I still believe the Skins can make this work, but I'd rather see them build through the drug probe draft for some consistency among the players, et al. offseason workouts Posted by: BulletsFan | November 22, 2006 1:46 AM | Report abuse preseason games quarterbacks training camp Jesus Christ. We've got nerds debating why we suck now. Even worse than that, wide receivers we've got ECON nerds debating it! Full Category Archive I don't know how this franchise can sink lower than this.