Ellie-Jean and Zach on WhatsApp 8/2/26, 8:30:19 PM
8/2/26, 8:30:19 PM
Good morning wow what a sleep I must have needed it
Morning, wildling
Yeah, same
Watching baseball is Pasadena with my secret family (it’s my son’s bday)
Ha totally kidding
Oh all good haha
Hanging out with Noah, my brother
Nice do u live wit him is that his house or urs
Ours.. so we have two house in Pasadena
Noah and his dogs are all here
And his gf lives here too
Aww
It’s all in a family trust
I’ll share pics and vids
The dogs are fun
8/2/26, 9:54:37 PM
8/2/26, 10:43:59 PM
I’ve just put you & max in an email -without Steve- to double check & get your approval for me to send this and if so when
Also, Holly flies up tomorrow so she is bringing my ID and I spoke to Katherine my tax advisor. She is reinstating my ABN number.
My AI prompt wrote it, so you have my thumbs up.. I recommend sending the demand letter at the same time
Hang on now, I’m confused
Ok, great.. we have people ready+wising to work
Let’s clear things up.. ask questions
Hang on so the demand letter is separate from this litigation hold
We’re sending out two emails
Correct, and they are both necessary
Yes
No, I fully understand why
Basically you’re saying “this is my go away number” which is 1.5M usd, which they’ll never pay
No, I fully understand. I get it.
What you’re really saying is the deal is dead bc you stopped paying and now the shoe is on the other foot mofos
Re: LITIGATION HOLD AND DEMAND TO PRESERVE EVIDENCE — McCandless Group, LLC / Fan Favour
Dear Mr. Pammanter:
As you are aware from our demand letter, Ms. Coffey — individually and with respect to content created by, featuring, or depicting her sisters Ruby-Lee Coffey, Holly-Daze Coffey, and Bonnie-Lou Coffey — has claims against you, McCandless Group, LLC, and Fan Favour arising out of the Website Development Agreement dated August 30, 2020 and your conduct thereunder. Litigation is reasonably anticipated. This letter is a formal demand that you immediately preserve all evidence relevant to that dispute.
Duty to Preserve.
You are now under a legal obligation to preserve all documents, data, and electronically stored information (“ESI”) that may be relevant to the anticipated litigation. This duty extends to material within your possession, custody, or control and to material held on your behalf by employees, contractors, agents, and third-party vendors. Effective immediately, you must suspend any document-retention, auto-deletion, overwriting, recycling, or purge policy or practice — automated or manual — that could result in the loss or alteration of relevant material, and you must take affirmative steps to preserve it in its native format with all metadata intact.
Materials to Be Preserved.
Without limiting the scope of your preservation obligation, you must preserve the following, for the period from January 1, 2020 to the present and continuing, as they relate to the websites, accounts, and content associated with or depicting Ellie-Jean Coffey, Ruby Lee Coffey, Holly Sue Coffey, and Bonnie-Lou Coffey:
* Websites and platforms — all websites, pages, subscription platforms, and applications operated for, associated with, or depicting any of the Coffeys, including site content, configuration, hosting data, and all backups and archived versions.
* Content files — all photographs, videos, images, and other media created by, featuring, or depicting any of the Coffeys, including original, edited, and derivative versions, thumbnails, and all associated metadata (creation and upload dates, EXIF, and file histories).
* Sales and revenue data — all subscription, transaction, sales, refund, and chargeback records; all gross-revenue and distribution calculations; and all data within the reporting software used to track revenue under § 2.1(a)(iii) of the Agreement.
* Financial and accounting records — ledgers, invoices, bank and payment-processor records, and all records of amounts collected, paid, withheld, or owed to any of the Coffeys, including records concerning the cessation of payments in and after January 2026.
* Subscriber and customer chats — all subscriber messages, chat logs, and direct-message threads conducted through the platform in connection with any of the Coffeys’ accounts, including any communications authored by you or by any employee, contractor, or agent in the name, voice, or persona of any of the Coffeys.
* Internal communications — all emails, text messages, and messaging-platform communications (including Slack, Microsoft Teams, Discord, WhatsApp, and similar) among McCandless Group, Fan Favour, you, Nicholas McCandless, and your employees, contractors, and agents concerning any of the Coffeys, their content, their compensation, the decision to cease payments, and the acquisition or transfer of the business.
* Contracts and compliance records — the Agreement and any related, amended, or superseding agreements; all model releases and 18 U.S.C. § 2257 records for any of the Coffeys; and all documents concerning the acquisition or transfer of McCandless Group’s assets or obligations to Fan Favour or to you.
* Account and access logs — administrative, access, login, editing, and analytics logs for the relevant accounts, websites, and platforms.
* Marketing and social media — all social-media accounts, posts, and promotional materials associated with any of the Coffeys.
* Third-party-held data — any of the foregoing held by hosting providers, content-delivery networks, payment processors, marketing agencies, chat-service providers, or other vendors acting on your behalf.
Scope and Instructions.
This obligation applies to all systems, servers, cloud storage, databases, backup media, mobile devices, and personal accounts on which relevant material may reside, and to all custodians who may hold relevant material, including you, McCandless Group, Fan Favour, Nicholas McCandless, and your current and former employees, contractors, and agents. You must not delete, alter, migrate, reformat, wipe, or transfer any relevant material, and where necessary you must forensically image devices or accounts to prevent loss. Please forward this notice immediately to every person and entity within your organization or acting on your behalf who may possess or control relevant material.
Consequences of Failure to Preserve.
The failure to preserve relevant evidence — including the loss of ESI through the continued operation of automated deletion or overwriting — constitutes spoliation. Under applicable law, spoliation may expose you to serious sanctions, including adverse-inference instructions, evidentiary and issue sanctions, and monetary sanctions. We trust that will not be necessary and that you will take the preservation steps demanded here without delay.
Confirmation Requested.
Please confirm in writing, no later than 10 days after receipt, that you have received this notice, suspended any automated deletion or retention practices, and taken the steps necessary to preserve the material identified above, together with a description of those steps.
Nothing in this letter constitutes a waiver of any of Ms. Coffey’s rights, claims, or remedies, all of which are expressly reserved.
Sincerely,
Ellie-Jean Coffey and counsel
Dear Mr. Pammanter:
As you are aware from our demand letter, Ms. Coffey — individually and with respect to content created by, featuring, or depicting her sisters Ruby-Lee Coffey, Holly-Daze Coffey, and Bonnie-Lou Coffey — has claims against you, McCandless Group, LLC, and Fan Favour arising out of the Website Development Agreement dated August 30, 2020 and your conduct thereunder. Litigation is reasonably anticipated. This letter is a formal demand that you immediately preserve all evidence relevant to that dispute.
Duty to Preserve.
You are now under a legal obligation to preserve all documents, data, and electronically stored information (“ESI”) that may be relevant to the anticipated litigation. This duty extends to material within your possession, custody, or control and to material held on your behalf by employees, contractors, agents, and third-party vendors. Effective immediately, you must suspend any document-retention, auto-deletion, overwriting, recycling, or purge policy or practice — automated or manual — that could result in the loss or alteration of relevant material, and you must take affirmative steps to preserve it in its native format with all metadata intact.
Materials to Be Preserved.
Without limiting the scope of your preservation obligation, you must preserve the following, for the period from January 1, 2020 to the present and continuing, as they relate to the websites, accounts, and content associated with or depicting Ellie-Jean Coffey, Ruby Lee Coffey, Holly Sue Coffey, and Bonnie-Lou Coffey:
* Websites and platforms — all websites, pages, subscription platforms, and applications operated for, associated with, or depicting any of the Coffeys, including site content, configuration, hosting data, and all backups and archived versions.
* Content files — all photographs, videos, images, and other media created by, featuring, or depicting any of the Coffeys, including original, edited, and derivative versions, thumbnails, and all associated metadata (creation and upload dates, EXIF, and file histories).
* Sales and revenue data — all subscription, transaction, sales, refund, and chargeback records; all gross-revenue and distribution calculations; and all data within the reporting software used to track revenue under § 2.1(a)(iii) of the Agreement.
* Financial and accounting records — ledgers, invoices, bank and payment-processor records, and all records of amounts collected, paid, withheld, or owed to any of the Coffeys, including records concerning the cessation of payments in and after January 2026.
* Subscriber and customer chats — all subscriber messages, chat logs, and direct-message threads conducted through the platform in connection with any of the Coffeys’ accounts, including any communications authored by you or by any employee, contractor, or agent in the name, voice, or persona of any of the Coffeys.
* Internal communications — all emails, text messages, and messaging-platform communications (including Slack, Microsoft Teams, Discord, WhatsApp, and similar) among McCandless Group, Fan Favour, you, Nicholas McCandless, and your employees, contractors, and agents concerning any of the Coffeys, their content, their compensation, the decision to cease payments, and the acquisition or transfer of the business.
* Contracts and compliance records — the Agreement and any related, amended, or superseding agreements; all model releases and 18 U.S.C. § 2257 records for any of the Coffeys; and all documents concerning the acquisition or transfer of McCandless Group’s assets or obligations to Fan Favour or to you.
* Account and access logs — administrative, access, login, editing, and analytics logs for the relevant accounts, websites, and platforms.
* Marketing and social media — all social-media accounts, posts, and promotional materials associated with any of the Coffeys.
* Third-party-held data — any of the foregoing held by hosting providers, content-delivery networks, payment processors, marketing agencies, chat-service providers, or other vendors acting on your behalf.
Scope and Instructions.
This obligation applies to all systems, servers, cloud storage, databases, backup media, mobile devices, and personal accounts on which relevant material may reside, and to all custodians who may hold relevant material, including you, McCandless Group, Fan Favour, Nicholas McCandless, and your current and former employees, contractors, and agents. You must not delete, alter, migrate, reformat, wipe, or transfer any relevant material, and where necessary you must forensically image devices or accounts to prevent loss. Please forward this notice immediately to every person and entity within your organization or acting on your behalf who may possess or control relevant material.
Consequences of Failure to Preserve.
The failure to preserve relevant evidence — including the loss of ESI through the continued operation of automated deletion or overwriting — constitutes spoliation. Under applicable law, spoliation may expose you to serious sanctions, including adverse-inference instructions, evidentiary and issue sanctions, and monetary sanctions. We trust that will not be necessary and that you will take the preservation steps demanded here without delay.
Confirmation Requested.
Please confirm in writing, no later than 10 days after receipt, that you have received this notice, suspended any automated deletion or retention practices, and taken the steps necessary to preserve the material identified above, together with a description of those steps.
Nothing in this letter constitutes a waiver of any of Ms. Coffey’s rights, claims, or remedies, all of which are expressly reserved.
Sincerely,
Ellie-Jean Coffey and counsel
Can you send me this in email format because it has it written all nicely and perfectly spaced out and with different format that looks way more professional and when I put it through Notes and redo it it changes the format I think
So you would just have to put it back through your Claude and get her to copy paste, but in the nice writing she had it in
So, Claude is short for Claudia?
Got it, will do
Just double checking the demand letter is a confidential settlement agreement right?
The subject line should be “confidential settlement discussions”
Yep.
I like you fighting
Haha what
I will always help you kick ass.. it’s the only way to put these fuckers in their place
I’ve accidentally got sent from my iPhone in the first one, but oh well
I haven’t sent these to him yet
That’s not the biggest concern
Alright, no rush.. by tomorrow is fine
No lol but still professional wise
We have all week
Well his Monday is tomorrow
I’m excited
Time to crack the whip
Me too. Where the hell is Max?
He’s always so goddamn busy
He talks on the phone a lot
I need water
He recommended I copy Marta on all this
Thirsty bitch
How was your soup?
Didn’t have any LOL
I know that about you
Child, eat something
No, I’m literally actually thirsty
I can’t, wish I could, but shan’t. What part of shan’t don’t you understand Stanley?
The office
This Max’s assistant, who checks emails more frequently: [email protected]
Oh!!! okay well I’ll resend them with her. Oh no to her.
Do I send starting after that?
Oh, that’s just your thing
Copy everything after my signature
Your signature isn’t anywhere
perfect
And yes, I made the requested formatting changes and other slight edits
And copied Marta
Hang on I don’t think you need to add all of the emails to Matt. She’s just gonna be so confused and overwhelmed. I think it’s better if we just have the two and then they can get the gist of what we’re saying.
Marta* not Matt
Yeah I get it
Ok, ok
Formatting and “Holly-Daze” instead of “Holly-Sue”
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