FAX: (973) 259-1398 February 15, 2012 Myerowitz, Jeffrey & Glidden, LLC 75 Woodland Road Bloomfield, NJ 07033

Mr. Myerowitz, Please be advised that I have received the Subpoena Ad Testificandum and Subpoena Duces Tecum from your firm. As I have stated when deposed by other attorneys involved in case Docket No L-4874-10, I am restrained under a legal and binding contract with Liberty Humane Society and the guidelines set within that contract. Your office has a copy of this contract for reference as to its provisions in that I am not at liberty to disclose. So that I do not place myself in a position whereby I breach any legal contract, I assert my rights to require Liberty Humane waive their rights under this contract prior to me giving oral testimony or providing documentation whether it be in a deposition or a court.. Without that release from the contract provisions, I maintain my right to silence unless ordered by the court to do otherwise. If court ordered, I would then retain my own legal counsel for advice throughout the process of depositions and testimony. Please be advised that this is the same information that has been and continues to be shared with all attorneys involved in Docket No L-4874-10, both for the plaintiffs and defense. In recap, I am willing and able to give whatever deposition or testimony that is required should Liberty Humane Society waive the restrictions of the contract or it is court ordered. I do, however, maintain my right to NOT waive my rights under this contract and will expect Liberty Humane Society to abide by the conditions of the contract. Please feel free to refer to the contract for a listing of my rights and guarantees. Furthermore, as to the recently received Subpoena, I am not available on Thursday, February 23, 2012, due to a business conflict that cannot be changed with such short notice. I also request that any and all future depositions, should they be required, take place in Morris County at a time that is convenient for me. I understand that this is my right as someone giving testimony in a deposition. I work in Morristown and would happy to meet someone in that location. I await word from you if there are any next steps.

Janet Russell P.S. Please note that this letter will be sent to you certified mail along with this fax.