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STATUS REPORT (PHASE 1)
Dirk O. Julander, Bar No. 132313
doj@jbblaw.com
Catherine A. Close, Bar No. 198549
cac@jbblaw.com
M. Adam Tate, Bar No. 280017
adam@jbblaw.com
JULANDER, BROWN & BOLLARD
9110 Irvine Center Drive
Irvine, California 92618
Telephone: (949) 477-2100
Facsimile: (949) 477-6355
Attorneys for Defendants
KATHERINE MCNAMARA and
JEREMY WHITELEY
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
BREAKING CODE SILENCE, a
California 501(c)(3) nonprofit,
Plaintiff,
vs.
KATHERINE MCNAMARA, an
Individual; JEREMY WHITELEY, an
individual; and DOES 1 through 50,
inclusive,
Defendants.
Case No. 2:22-cv-002052-SB-MAA
DEFENDANTS’ STATUS REPORT
REGARDING OUTCOME OF
PHASE 1 RE: MOTION FOR
EVIDENTIARY AND MONETARY
SANCTIONS UNDER RULE 37
(Dkt. 98)
Trial: April 22, 2025[Assigned to the Hon. Maria A. Audero] Case 2:22-cv-02052-MAA Document 168 Filed 02/15/24 Page 1 of 15 Page ID #:5807
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STATUS REPORT (PHASE 1)
Pursuant to the Court’s August 11, 2021 Minute Order (Dkt. 120), as
amended by the Court’s September 14, 2023 Minute Order (Dkt. 138), Defendants
KATHERINE MCNAMARA and JEREMY WHITELEY (collectively
“Defendants”) provide the following Status Report Regarding Outcome of Phase 1
related to the Motion for Evidentiary and Monetary Sanctions Under Rule 37 (Dkt.
98).
As noted in the Court’s August 11, 2021 Minute Order (Dkt. 120), Phase 1
was designed to serve three purposes: (a) for Defendants to obtain the Discovery at
Issue, (b) to inform the Court regarding the nature and extent of prejudice to
Defendants from the inability to obtain the entirety of Discovery at Issue, and (c) to
inform the Court whether any of the Discovery at Issue has been spoliated. The
“Discovery at Issue” consists of the documents in the possession of BCS’s officers
and directors from whom BCS failed to collect documents as required by the
Stipulated Order re: Amended Joint E-Discovery Plan and Protocol for Discovery of
Electronically Stored Information (hereinafter the “EDO”). (Dkt. 41.) The
“Custodians” at issue in the EDO are Apryl Alexander, Deanna Hassanpour, Denette King, Dorit Saberi, Eugene Furnace, Jennifer
Magill, Jesse Jensen, Lenore Silverman, NB, and Vanessa Hughes (collectively the “Custodians”). (Dkt. 41, p. 2, ¶1.)
To facilitate the obtaining of the Discovery at Issue the Parties were ordered
to submit a stipulation regarding how Phase 1 would be carried out, which was later
entered as an Interim Court Order on August 22, 2023. (Dkt. 132.)
1. Status Regarding Step 1:
The Interim Order first required that BCS send evidence preservation letters
to each of the Custodians. (Dkt. 132, ¶1.) Because such letters are protected by the
attorney-client privilege, Defendants were not copied, but Defendants have no
reason to believe the letters were not sent.
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STATUS REPORT (PHASE 1)
2. Status Regarding Step 2:
Step 2 required that “BCS reach out to each of the Custodians, inform him or
her of the Court’s statements made during IDC 10, inquire as to whether he or she
possesses BCS-related documents in any of his or her personal data sources listed in
Paragraph 4.4 of the [EDO], and request a Declaration identifying which personal
data sources contain BCS-related documents and whether the Custodian is willing to
make the data source available to BCS for collection of such documents.” (Dkt. 132,
¶2.) Because such communications are protected by the attorney-client privilege,
Defendants were not participants, but Defendants have no reason to believe the
communications were not made.
The result of Step 2 was a mixed bag:
• Apryl Alexander, AC, Jennifer Magill, and Vanessa
Hughes executed declarations agreeing to search for documents from those
data sources which might contain any BCS-related documents.
• Jesse Jensen executed a declaration agreeing to search for documents
from certain data sources. Confusingly, the declaration also stated that Jensen
was unsure whether or not he even had some of the data sources.
• Dee Anna Hassanpour, Dorit Saberi, and Denette King executed
declarations stating that they did not have BCS-related documents.
• Eugene Furnace, SK, MH, and Lenore Silverman
failed to execute declarations as part of Step 2.
• BCS had originally failed to collect documents. As detailed below, Defendants believe that some critical
responsive documents that were in the possession of have been lost, including the original screen shots taken by
NBduring her investigation into the alleged deindexing.
However, since had previously produced
the documents still in their possession pursuant to subpoenas and sat for
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STATUS REPORT (PHASE 1)
depositions, the parties agreed that they would be excused from signing
declarations.
3. Status Regarding Step 3:
Step 3 required that, “for each Custodian who indicates that he or she
possesses BCS-related documents on one or more of his or her personal data sources
and is willing to make the data source(s) available for collection, BCS shall collect
the documents from the identified data source(s) dating from January 2021 to the
present, run the agreed-upon search terms to locate any potentially responsive
documents in accordance with the EDO, and produce any such documents on a
rolling basis to Defendants, identifying the Custodian from whom they were
collected, which production shall be complete by no later than September 9, 2023.”
(Dkt. 132, ¶3.) This deadline was subsequently extended to October 3, 2023. (Dkt.
138, ¶1.)
As detailed in the previous section, Apryl Alexander, Jesse Jensen, AC, Jennifer Magill, and Vanessa Hughes executed declarations agreeing to
search for documents from at least some of their data sources.
• Apryl Alexander: BCS produced documents purporting to be from
Apryl Alexander. Defendants currently do not have evidence that the
production is incomplete.
• AC: Despite her declaration stating that she would search
for documents, BCS never produced any additional documents purporting to
be from AC.
• Jesse Jensen: Despite his declaration stating that he would search for
documents, BCS never produced any additional documents purporting to be
from Jesse Jensen.
• Jennifer Magill: BCS produced documents purporting to be from
Jennifer Magill. As discussed below, Defendants have a good faith reason to
believe that the production is incomplete.
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STATUS REPORT (PHASE 1)
• Vanessa Hughes: BCS produced documents purporting to be from
Vanessa Hughes. As discussed below, Defendants have a good faith reason to
believe that the production is incomplete.
4. Status Regarding Step 4:
Step 4 allowed Defendants to issue subpoenas to any of the Custodians if (1)
the Custodian did not provide a declaration in Step 2 or (2) Defendants have a
reasonable basis to believe that the Custodian has additional responsive documents
that were not produced. (Dkt. 132, ¶4.) As detailed below, Defendants attempted to
serve the subpoenas, but their efforts were largely unsuccessful because many of the
custodians either actively avoided service or, in one case, completely ignored a
subpoena that was validly served:
• MH: MH was personally served with a
subpoena at her home in Texas on September 25, 2023. On October 30,
2023, H responded to the subpoena by executing a Certification
of No Records, stating that she “relinquished all accounts owned by
BCS upon resigning.”
• Lenore Silverman: Lenore Silverman was personally served with a
subpoena at her home in California. Following service, Lenore
Silverman provided some documents and a declaration stating that she
resigned from the board of directors of Breaking Code Silence in June
2023 “when it became apparent that all energy being directed toward
litigation regarding matters not directed toward helping children and
teens.”
• SK: SK was successfully personally served
with a subpoena on September 26, 2023, at her place of work in
Nevada. Despite being served, SK ignored the subpoena.
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STATUS REPORT (PHASE 1)
• Eugene Furnace: Five attempts were made to serve Eugene Furnace at
his confirmed residence (his name is on the mailbox) but, because he
lives in a gated apartment complex, the process server could not gain
entry. The process server conducted short stakeouts in an effort to gain
entry, each of which were unsuccessful.
• Jesse Jensen: Numerous unsuccessful attempts have been made to
serve Jesse Jensen with the subpoena at his home in Utah. It is clear
that he is actively evading service. Though it appeared that he was
home during several attempts, he consistently refused to answer the
door. At one time, his wife was approached leaving the house by the
process server and she ignored him entirely. The process server
conducted various stakeouts in the hope that Jensen would leave the
house at some point, but none were successful.
• Vanessa Hughes: Numerous unsuccessful attempts have been made to
serve Vanessa Hughes with the subpoena and it is clear that she is
actively evading service. Though it was confirmed that she was home
several times, Hughes refused to come to the door and, on one
occasion, even instructed her “worker” to enter the house through the
backyard so that the process server (who was standing next to the
worker) could not serve her with the subpoena.
5. Prejudice/Spoliation:
Jesse Jensen
Jesse Jensen is the Chief Information Security Officer for BCS. BCS listed
Jesse Jensen as a percipient witness in their Initial Disclosures. He was also
identified as one of the primary investigators into the alleged deindexing of BCS’s
website.
As detailed above, Jesse Jensen executed a declaration stating that he would
search for responsive documents, but he never produced any additional documents.
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STATUS REPORT (PHASE 1)
Defendants attempted to serve Jesse Jensen with a subpoena, including initiating
stake outs, but Defendants’ attempts were unsuccessful because Jesse Jensen was
actively avoiding service.
Defendants believe that Jesse Jensen is withholding or has destroyed many of
the most critical documents in the case. First, on October 5, 2023, during an
informal discovery conference, BCS’s counsel Jason Leuddeke explained to the
Court that Jesse Jensen’s failure to produce documents was taking longer than
expected because Jesse Jensen could only search for documents at night and the
number of documents that Jesee Jensen had to produce was “voluminous.” Thus,
there are apparently hundreds (if not thousands) of documents in Jesse Jensen’s
possession that have not been produced.
Second, at his deposition, Jesse Jensen testified that he advised all of BCS
leadership to use the Signal chat application and personal emails for BCS business.
Jesse Jensen testified that he personally had “somewhere between probably 50 and a
few hundred” Signal conversations related to the Defendants and this lawsuit. To
date, Jesse Jensen has produced none of these Signal chats. As stated in the Court’s
order, the fact that other Custodians may have produced Signal conversations, does
not excuse Jesse Jensen’s failure. (Dkt. 132, ¶3.)
Third, at his deposition, Jesse Jensen also testified that he had possession of a
WordPress website backup made during the time of the alleged deindexing incident,
that he had not produced the backup, and that no one from BCS ever asked him to
produce it. To date, this backup still has not been produced. Notably, the WordPress
backups that BCS previously produced are not sufficient as BCS did not produce the
backups made during the time of the alleged deindexing.
Fourth, in his deposition, Jesse Jensen testified that he created screenshots at
the time of the alleged deindexing and that he believes that he still has the originals.
After the deposition, Defendants’ counsel reached out to Tamany Bentz to inquire
about the missing screenshots. Ms. Bentz replied with several bates numbers.
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STATUS REPORT (PHASE 1)
However, upon inspection of the metadata, these screenshots either were not created
by Jesse Jensen or were not from the time of the alleged deindexing.
Fifth, BCS never produced any of the following data sources for Jesse Jensen
which presumably would have responsive documents:
o Emails from his personal email after April 2022
o Cell phone contents
o Text Messages
o Apple Messages
o iCloud
o Computer contents
o Signal chats
o Google Drive Contents

was the Chief Communications Officer and Webmaster
for the website at Breaking Code Silence between 2022 and March 2023. NB was identified (along with Jensen) as the other primary investigator of
the alleged deindexing.
Defendants have reason to believe that documents that were in NB’s possession while she was still working at BCS have since been
destroyed. Specifically, NB sat for a deposition after being served
with a subpoena in March 2023. In her deposition, she admitted to taking various
screenshots during the alleged deindexing and deleting the original screenshots.
BCS has produced various screenshots which were purportedly taken NB; however, none of the screenshots that have been produced by BCS are
the originals with the original metadata. It appears that BCS was only able to locate
those screenshots that were attached to emails or sent through Slack. 1

1
In its portion of the joint statement on the motion for evidentiary sanctions, BCS identified 10
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STATUS REPORT (PHASE 1)
Metadata in CFAA cases is extremely important. Typically, in a cyberhacking case, evidence is preserved in its original format and a hash is taken of each
file to prove that it had not been tampered with and provide a non-repudiation
method. The metadata alone provides information such as the creation time/date of
the file, last modification date (to prevent tampering), owner, etc. Unfortunately, in
this action, none of this was done. BCS never preserved the original digital evidence
with the metadata or even created a hash of the original file to show that the files
had not been tampered with since creation. As a result, Defendants have been
unfairly prejudiced since there is no way of knowing whether the files produced
have been tampered with.
MH
MH served as the Chief Procedural Officer at BCS between 2022
and early 2023. As outlined above, MH originally did not execute a
declaration. After she was personally served with a subpoena, H responded to
the subpoena by executing a Certification of No Records. Defendants have a good
faith reason to believe that MH either has, or once had, responsive
documents and that the documents are either being withheld by BCS’s current
leadership or have been spoiled.
First, as outlined in Jeremy Whiteley’s Motion for Summary Judgment,
BCS’s entire theory of liability rests on the faulty assumption that only a handful of
people had administrative access to Google Search Console around the time of the
alleged deindexing and that, of those people, Defendants are the most likely persons
documents by bates numbers which BCS purports to be the original screenshots taken by NB. The metadata for each of these screenshots shows Jesse Jensen (not NB) as the custodian and is missing critical information such as the date the screenshot
was taken and whether the screenshot had been modified. As such, BCS clearly has not produced
the original screenshots with the original metadata. It appears possible that what BCS produced
were the screenshots that Jesse Jensen received as attachments to an email from NB, but without the original metadata, Defendants cannot be assured that the screenshots
were not modified and cannot tell when the screenshots were taken.
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STATUS REPORT (PHASE 1)
to have caused the deindexing. MH was one of the few other persons
who had administrative access to the Google Search Console. Yet, with the
exception of one small group Slack chat, neither BCS nor MH produced
any communications to or from MH discussing whether MH
had accessed the Google Search Console. Responsive documents likely exist,
especially since Jesse Jensen identified MH as one of the persons
involved in the investigation.
Second, documents produced by other custodians reveal that MH
used her personal email address to communicate with BCS leadership about the
Defendants and this litigation. MH failed to produce any of the emails
from her personal account. Once again, the fact that others may have produced the
communications, does not excuse MH from producing the
communications.
Third, at her deposition, NB identified MH as the
person in charge of managing the Google Analytics to track website traffic. Later, in
support of Defendants’ motions for summary judgment, NBsigned a
declaration stating that the Google Analytics had been deactivated preventing BCS
from being able to tell whether it lost any web traffic as a result of the alleged
deindexing. However, neither MH nor BCS produced any documents
regarding the Google Analytics being deactivated.
Lenore Silverman
Between January 2022 and June 2023, Lenore Silverman served on the Board
of Directors of Breaking Code Silence. She is listed as the Secretary and the Chief
Financial Officer for Breaking Code Silence on the Statement of Information filed
with the Office of the Secretary of State of California.
Silverman originally failed to provide a declaration. After being served with a
subpoena, Silverman produced a number of mostly irrelevant documents and
executed a declaration that she was not in possession with any other documents. As
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STATUS REPORT (PHASE 1)
detailed below, Defendants have a good faith reason to believe that either Silverman
is not being truthful or, more likely, that the responsive documents are being
withheld by BCS’s current leadership or have been spoiled.
First, per BCS’ bylaws, the board secretary would be responsible for the
creation of all board meeting minutes. This means that Silverman should have been
the custodian responsible for all board meeting minutes. Yet, neither BCS nor
Silverman produced any BCS meeting minutes for 2022 or 2023.
Second, according to Jennifer Magill’s 30(b)(6) deposition testimony, Lenore
Silverman was a board member prior to the start of litigation and directly voted in
favor of this litigation. However, no communications between Silverman and BCS
that reflected any discussion or vote about litigation has ever been produced.
Third, from the productions of others, Defendants know of at least a couple
emails were sent to Lenore Silverman related to Defendants and this action. Lenore
Silverman never produced these communications.
Jennifer Magill
Jennifer Magill is BCS’s CEO and was an officer and board member at the
time of the alleged deindexing. Despite Magill’s claimed willingness to provide
documents from all of her data sources, including Facebook, and despite her later
deposition testimony that she produced all Facebook messages to BCS’s counsel, no
Facebook messages from Magill as the custodian were ever produced in discovery,
not even a single chat. When asked at her deposition why her Facebook messages
were not produced, she testified that she assumed they were produced since they
were collected by BCS’s counsel.
In addition, the Signal chats produced from Magill were woefully incomplete,
containing very obvious cut-off conversations with Jesse Jensen about Defendants
(cut off in mid-sentence).
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STATUS REPORT (PHASE 1)
Vanessa Hughes
Vanessa Hughes is BCS’s current Board President and was the CEO at the
time of the alleged deindexing. BCS has listed Vanessa Hughes as a percipient
witness on the Rule 26(f) report and in its Initial Disclosures. Hughes was also
originally one of the 30(b)(6) witnesses for BCS on numerous categories until she
claimed she was medically unable to sit for deposition and her categories were
reassigned.
Vanessa Hughes executed a declaration stating that she would search for
responsive documents and, subsequently, did produce additional documents. As
detailed below, Defendants have a good faith reason to believe that Vanessa
Hughes’s document production is incomplete and that many of the documents have
been withheld or spoiled.
First, the Complaint alleges that BCS first discovered that its website was not
appearing on Google Search after one of its volunteers made changes to the website
and then ran a search on Google so she could see how the changes look. At the
deposition of BCS’s PMQ, Jennifer Magill revealed that Vanessa Hughes was the
volunteer making changes to the website shortly before the alleged deindexing was
discovered. Defendants strongly believe that Vanessa Hughes (who is not
technically savvy) likely caused the website to be deindexed while making changes
to the website through her own carelessness and technical ineptitude. To date,
Vanessa Hughes has not produced the documents showing the changes that she was
making to the website or her discovery of the deindexing.
Second, the totality of Vanessa Hughes’s Facebook production is only 4 chat
chains with Defendants. Vanessa Hughes’s production is incomplete. At a
minimum, other custodians have produced over a dozen more chats with Vanessa
Hughes and persons other than Defendants.
Third, although Vanessa Hughes produced some of her Signal
communications, there is evidence that Vanessa Hughes utilized Signal’s
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STATUS REPORT (PHASE 1)
“disappearing messages” feature to shield documents from discovery. Critically,
Chelsea Papciak testified at her deposition that she and Hughes had discussions
about Defendants that were automatically deleted through the disappearing message
feature. Additionally, in one of the Signal chats produced, it appears that the
disappearing messages feature was utilized for an extended period of time to shield
conversations between Vanessa Hughes and Jenna Bulis.
Defendants believe that other Signal chats were either shielded through the
disappearing messages feature or that BCS simply failed to produce them. Notably,
Hughes produced a screenshot of her list of Signal chats which revealed a group
chat with Chelsea Papciak and the other defendants in the Papciak action. Vanessa
Hughes failed to produce this Signal chat. Additionally, there are large month-long
gaps in the Signal chats between Vanessa Hughes and Jesse Jensen which appear to
have been purposefully omitted.
Fourth, Vanessa Hughes’s declaration states that she would search for
responsive documents from WhatsApp and Zoom logs, but no responsive
documents from these sources were ever provided. Defendants know from their time
at BCS that Vanessa Hughes regularly used Zoom to conduct BCS business.
Fifth, Vanessa Hughes’ declaration states that her counsel had already
produced documents from her iCloud, but BCS has not actually produced such
documents.
Sixth, Vanessa Hughes did not produce any of her communications with
Athena Kolbe. Documents produced by BCS reveal Vanessa Hughes
communicating with others advising them that she was having Athena Koble take
screenshots of Defendants’ social media activities throughout 2022. Some of the
screenshots were produced, but no emails, texts, or chats showing Kolbe sending
them to Hughes or any of the surrounding conversations about Defendants were
produced. At the deposition of Chelsea Papciak, Chelsea Papciak confirmed that: (1)
Athena Kolbe contacted Chelsea Papciak and Jenna Bulis to entice them to assist
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BCS in suing Katherine McNamara for a large insurance payout; and (2) Vanessa
Hughes also contacted Chelsea Papciak and Jenna Bulis to discuss bringing a
lawsuit against Katherine McNamara and sharing the proceeds from that action with
Chelsea Papciak. It strains reason to believe that Vanessa Hughes and Athena Kolbe
both independently discussed this topic with Chelsea Papciak without talking to one
another. Responsive communications between Vanessa Hughes and Athena Kolbe
have likely been withheld.
DATED: February 15, 2024 JULANDER, BROWN & BOLLARD
By: /s/ M. Adam Tate
M. Adam Tate
Catherine Close
Attorneys for Defendants
KATHERINE MCNAMARA and
JEREMY WHITELEY
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CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of February, 2024, I electronically filed
the foregoing paper(s) with the Clerk of the Court using the ECF system which will
send notification to all parties of record or persons requiring notice.
/s/ Helene Saller
Helene Saller
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