EXHIBIT AA 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 1 of 15
Navy SEAL must pay $4.SM for 

writing book death of Bin Laden: 

lawsuit 

BY STEPHEN REX BROWN 

NEW YORK DAILY NEWS Wednesday, Noveni>er 5, 2014, 8:37 R'v1 

Matt Bissonnette says he owes $4.5 million to the government for publishing his 

book, 'No EasyDay,'withoutpermission. (60 MINUTES/CBS NEWS) 

The Navy SEAL who wrote a first-hand account of the raid that 

killed Osama Bin Laden must forfeit $4.5 million to the 

government for publishing it without clearance, the shamed 

warrior revealed in a lawsuit against the lawyer he blames for the 

predicament. 

Matt Bissonnette, who wrote using the pen name Mark Owen, 

sued attorney Kevin Podlaski Wednesday for $8 million for 

allegedly advising him that he need not submit the manuscript of 

''No Easy Day" to the Department of Defense for review. 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 2 of 15
Podlaski claimed to have government clearance that allowed him 

to review documents for classified information, Owen charges in 

documents filed in Manhattan Federal Court. 

I 

NO 

112 

The author of 'No Easy Day' says his lawyer wrongly advised him that he did not 

need to submit the book to the Department of Defense for review prior to _ •• t.. 1l--t: --

(-/AFP/GETTY IMAGES) 

'The task (Podlaski) purported to undertake for the benefit of 

plaintiff and his writing team was absolutely contrary to law and 

doomed to failure from the start," documents read. 

Podlaski "had no legal right to substitute his judgment for that of 

the Department of Defense or other agencies of the United States 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 3 of 15
as to what is considered classified or otherwise sensitive 

information," the papers charge. 

Tue debacle forced Bissonnette to enter into a negotiated 

settlement with the government forfeiting ''the majority of all 

income he has received from his book as well as all future income 

he otherwise would have received," according to documents. 

Bissonnette, who also lost movie rights to the book, has suffered 

damages to his reputation that affected future speaking 

engagements and sales of his upcoming book, ''No Hero," he 

claims. 

''His reputation and his exemplary military record (have been) 

tarnished by the false accusation that he sought to profit from 

disclosure of classified or otherwise sensitive information," 

court documents read. 

Podlaski could not be reached. Tue Department of Justice did not 

immediately respond to Bissonnette 's statement that he'd reached 

a settlement with the feds. 

s brown@nydailynews.com 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 4 of 15
The Navy Seal Who Wrote A Book About 

The Bin Laden Raid Is Suing His Lawyers 

For $8 Million 

AP Larry Neumeister, Associated Press 

Nov. 6, 2014, 11:10 AM 3,060 

FACEBOOK LINKEDIN 

A former Navy SEAL who wrote a 

book describing the raid that killed 

Osama bin Laden sued his former 

lawyers Wednesday for malpractice, 

saying they gave him bad advice that 

tarnished his reputation, cost him his 

security clearance and caused him to 

surrender much of the book's income 

to the government. 

Using the pseudonym "Mark Owen" 

that he published the book under, 

Matt Bissonnette filed the lawsuit in 

federal court in Manhattan. His 2012 

book, "No Easy Day," prompted a 

Pentagon inquiry that evolved into a 

criminal probe by the Justice 

Department. 

TWITTffi 

Matt Bissonnette, author of "No Easy Day." 

CBS News/screenshot 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 5 of 15
Bissonnette seeks unspecified 

compensatory damages, saying his 

losses will amount to at least $8 

million after he agreed to surrender 

most of the book's proceeds. He said 

he also will lose consulting jobs, 

speaking engagements and future 

employment. 

Named as defendants were attorney 

Kevin Podlaski and the Carson 

Boxberger LLC firm in Fort Wayne, Indiana. Messages seeking comment were not 

immediately returned. 

Bissonnette said he acted on the advice of his former lawyers when he did not let the 

Department of Defense and other governmental agencies perform a pre-publication 

review of his book and when he relied on their advice that they had reviewed the 

book and removed all classified and sensitive information. 

The lawsuit said Bissonnette decided to write the book after realizing that others who 

did not know the accurate facts were writing about and discussing the daring May 

2011 raid by SEAL Team 6 in Pakistan that resulted in the killing of the head of alQaida and inspiration behind the Sept. 11, 2001, terrorist attacks. 

According to the lawsuit, Bissonnette always had intended to donate a substantial 

portion of proceeds from the book to charity and was always aware that the 

disclosure of sensitive information could put other SEALs in danger. 

"He was devoted to not disclosing anything he thought could be used by America's 

enemies. To insure he complied with all his obligations of confidentiality, he sought 

out legal counsel to advise him," the lawsuit said. 

He said he was referred to Podlaski and the Boxberger firm by his literary agent and 

publisher, both located in New York. 

The lawsuit noted that Bissonnette referred to Podlaski and the firm when he said in 

the book that he hired a former special operations attorney to review the manuscript 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 6 of 15
to ensure no "forbidden topics" were mentioned. 

The lawsuit said Bissonnette has agreed as part of a negotiated settlement to forfeit 

to the U.S. government the majority of all income he has received from the book 

along with future income. It said the payment to the government has already 

exceeded $4.5 million. 

According to the lawsuit, Bissonnette will also lose all movie rights and income 

attributable to those rights, an amount believed to be in excess of $900,000. 

The lawsuit said the controversy has tarnished his reputation and "exemplary 

military record" by the false accusation that he sought to profit from disclosing 

military secrets and had cost him his security clearance for not submitting the book 

for review. 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 7 of 15
Ex-Navy SEAL sues lawyer, says bad advice 

about best-sel Ii ng Osama bin Laden book 

cost him millions 

POSTED NOV06, 2014 10:50 AM CST 

BY MARTHA NEIL 

[ Share J 5 

Recently profiled on 60 Minutes, a former Navy SEAL who wrote a best-selling 

book about the U.S. government raid that killed Osama Bin Laden wound up 

being federally investigated, his lawyer says. 

The issue: Whether Matt Bissonnette, writing under the pen name "Mark Owen," 

revealed government secrets in violation of the Espionage Act in his book, No 

Easy Day, attorney Bob Luskin told CBS News. 

Now Bissonnette, again using the Mark Owen moniker, has sued his former 

lawyer for malpractice. He says he was given bad advice about publishing the 

book without first allowing the feds to review it. That not only cost him his security 

clearance and millions in profits and movie rights he forfeited, in order to settle with the U.S. government, but 

damaged his reputation and hence his future earning potential through speaking engagements and the like, 

he alleges in the suit. 

It was filed Monday in federal court in Manhattan and seeks $8 million in damages. The Associated Press and 

the New York Daily News have stories. 

Named as defendants are attorney Kevin Podlaski and an Indiana law firm, Carson Boxberger. Indiana Bar 

Association records show that Podlaski now chairs the litigation department at another Fort Wayne, Indiana, 

law firm in which he is a partner. He also is a retired member of the U.S. Army Judge Advocate General's 

Corps. 

The defendants did not respond to requests for comment, the articles say, and the Department of Justice was 

not immediately available to confirm the information provided in the lawsuit about the settlement. 

The suit says Podlaski told the plaintiff that he had a government clearance and could review documents for 

classified information, but that wasn't what the law required, the Daily News reports. Hence, the review by the 

attorney "doomed to failure from the start," the complaint contends. 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 8 of 15
CBS/AP November 5, 20.1 4, 8:36 PN! 

Nayy SEAL who wrote book 

on bin Laden raid sues exattorneys 

8 Comment Share Tweet Stumble Email 

NEW YORK --A former Navy SEAL who wrote a book describing the raid that killed Osama 

bin Laden sued his former lawyers Wednesday for malpractice, saying they gave him bad advice 

that tarnished his reputation, cost him his U.S. security clearance and caused him to surrender 

much of the book's income to the government. 

Using the pseudonym "Mark Owen," the SEAL filed the lawsuit in federal court in Manhattan. 

His 2012 book, "No Easy Day," prompted a Pentagon inquiry that evolved into a criminal probe 

by the Justice Department, over whether the book disclosed classified information. 

Owen spoke with "60 Minutes" about the book twice, when it was released in 2012 and in an 

interview that aired just this past Sunday. 

"Did I disclose anything that would've put the guys in harm's 

way? That's absolutely not what I intended to do," Owen told 

Scott Pelley Sunday. "These are my brothers that I served beside 

for years. And a lot of them continue to serve. These are guys I 

had, you know, lived and died next to. These are not guys that I 

would want to sacrifice their security for any reason." 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 9 of 15
Play VIDEO 

SEAL under fire for wifing 

about bin Laden raid 

In the lawsuit, Owen seeks unspecified compensatory damages, 

saying his losses will amount to at least $8 million after he 

agreed to surrender most of the book's proceeds. He said he also 

will lose consulting jobs, speaking engagements and future 

employment. 

Named as defendants were attorney Kevin Podlaski and the Carson Boxberger LLC firm in 

Indiana. Messages left by the Associated Press seeking comment were not immediately returned. 

Owen said he acted on the advice of his former lawyers when he did not let the Department of 

Defense and other governmental agencies perform a pre-publication review of his book and 

when he relied on their advice that they had reviewed the book and removed all classified and 

sensitive information. 

Play VIDEO 

Did Mark O\r.en's book 

"No Easy Day" give away 

secrets? 

U.S. 

"From the beginning, I've always tried to do the right thing," 

Owen said on "60 Minutes." "Had we purposely tried to go 

around what my obligations were, absolutely I should be held 

accountable. But the fact is I didn't. I hired a lawyer with my 

own money off to the side because I wanted to do the right 

thing. I got horrible advice and I've dealt with that for the past 

two years." 

The lawsuit said Owen decided to write the book after realizing 

that others who did not know the accurate facts were writing 

about and discussing the daring May 2011 raid by SEAL Team 6 

in Pakistan that killed the head of al Qaeda, who was the 

inspiration behind the Sept. 11, 2001, terrorist attacks in the 

According to the lawsuit, Owen always had intended to donate a substantial portion of proceeds 

from the book to charity and was always aware that the disclosure of sensitive information 

could put other SEALs in danger. 

"He was devoted to not disclosing anything he thought could be used by America's enemies. To 

insure he complied with all his obligations of confidentiality, he sought out legal counsel to 

advise him," the lawsuit said. 

Play VIDEO 

Owen said he was referred to Podlaski and the Boxberger firm 

by his literary agent and publisher, both located in New York. 

The lawsuit noted that Owen referred to Podlaski and the firm 

when he said in the book that he hired a former special 

operations attorney to review the manuscript to ensure no 

"forbidden topics" were mentioned. 

The lawsuit said Owen has agreed as part of a negotiated 

settlement to forfeit to the U.S. government the majority of all 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 10 of 15
A "much vviser'' Mark 

Ov\en speaks out 

income he has received from the book, along with future 

income. It said the payment to the government has already 

exceeded $4.5 million. 

According to the lawsuit, Owen will also lose all movie rights and income attributable to those 

rights, an amount believed to be in excess of $900,000. 

The lawsuit said the controversy has tarnished his reputation and "exemplary military record" 

by the false accusation that he sought to profit from disclosing military secrets and had cost him 

his security clearance for not submitting the book for review. 

© 2014 CBS Interactive Inc. All Rights Reserved. This material may not be published, broadcast, rewritten, or 

redistributed. The Associated Press contributed to this report. 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 11 of 15
Navy SEAL Author of Bin Laden Raid 

Book Sues Attorneys for Malpractice 

By Joseph Perry I November 10, 2014 

Matthew Bissonnette, a former Navy SEAL who wrote the book "No Easy 

Day,"is suing his former lawyers for malpractice. 

According to CBS New York, Bissonnette, whose pen name is Mark 

Owen, alleges that his former attorneys told him that the federal 

government did not need to perform a pre-publication review of his book, 

which describes the 2011 raid that killed Osama Bin Laden. He later 

relied on their advice that they told him they had performed prepublication review themselves and removed all classified and sensitive 

government information. Bissonette alleges that his former attorneys' 

guidance "prompted a Pentagon inquiry that evolved into a criminal 

probe by the Justice Department," which "tarnished his reputation, cost 

him his security clearance and caused him to surrender much of the 

book's income to the government," as well as ruined his '"exemplary 

military record' by the false accusation that he sought to profit from 

disclosing military secrets." 

Bissonette claims he had to forfeit $4.5 million to the government for 

following his attorneys' advice and publishing his book without the 

government's permission. 

The former Navy SEAL seeks unspecified compensatory damages, but 

claims his losses are at least $8 million, partly because he believes his 

tarnished reputation will cause him to lose consulting positions, speaking 

engagements, and other future employment opportunities. 

Since book publishers are in the book business, they are not strangers to 

pre-publication reviews, which are reviews undertaken by attorneys to 

prevent defamation lawsuits. I have had the privilege of assisting in prepublication during some of my internships, and it's quite an interesting 

process, during which an editor will ask an attorney to read a manuscript 

for any libelous statements. The attorney looks for any false statements of 

facts or opinions that may be construed as false statements offact. 

Pre-publication review can be implemented for both fiction and nonfiction books; however, from my experience, I have noticed that editors 

request more non-fiction books for pre-publication review. This may be 

because non-fiction books are about real events and real people, and 

reported facts can sometimes also be false. A potentially defamed 

person can easily point to the words in the story and claim, "I've been 

defamed. It says so right there in this book." This may be harder in fiction 

where the author can presumably make anything up, notwithstanding that 

fiction authors can still be sued for defamation (e.g., a person believes 

he or she is a particular character that portrays him or her in a false light). 

Nevertheless, pre-publication review is quite common in book publishing. 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 12 of 15
Moreover, when publishers attempt to publish books about the 

government, there is a second stage to pre-publication review in which 

the federal government routinely vets manuscripts in order to redact any 

classified or sensitive information that may harm national security. 

Thus, I would like to know why Bissonnette's attorneys supposedly 

advised him that the government did not need to perform a prepublication review, especially considering that he participated in the raid 

that killed Osama Bin Laden and "decided to write the book after 

realizing that others who did not know the accurate facts were writing 

about and discussing the daring May 2011 raid by SEAL Team 6 in 

Pakistan that resulted in the killing of the head of al Qaeda and 

inspiration behind the Sept. 11, 2001, terrorist attacks." They knew the 

government would want to make sure that Bissonnette's version of the 

2011 raid did not hamper national security, and they had nothing to gain 

from advising Bissonnette to forgo pre-publication review. Their alleged 

misstep could easily have been avoided. 

I will be eagerly waiting to see what happens in this case. 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 13 of 15
Indiana lawyer sued by author who detailed 

mission that killed Osama Bin Laden 

POSTED 6:52 PM, NOVEMBER 11, 2014, BY RUSS MCQUAID, UPDATED AT07:23PM, NOVEMBER 11, 2014 

FACEBOOK 8 TWITTER REDDIT EMAIL GOOGLE PINTEREST 

This is an archived article and the information in the article may be outdated. Please 

look at the time stamp on the story to see when it was last updated. 

INDIANAPOLIS, Ind. (Nov. 11, 2014)-- "No Easy Day: The Firsthand Account 

of the Mission that Killed Osama Bin Laden" is a bestseller by a former Navy 

Seal who broke the story of the mission that killed the USA's most wanted 

terrorist. 

It also landed the author in hot water with the Pentagon and now he's suing 

his former Indiana lawyer for bad advice about not getting Defense 

Department approval for his manuscript. 

Author Mark Owen, who is actually retired Navy Seal Matt Bissonnette, is 

USDC IN/ND case 1:15-cv-00334-SLC document 138-27 filed 10/26/17 page 14 of 15
"Defendants told Plaintiff ... Plaintiff had no obligation to submit the Book to 

the Department of Defense or any other agency for a pre-publication review," 

reads the lawsuit filed in Southern District of New York. "Defendants claimed 

to have special expertise in dealing with military law and special operations 

issues. 

"Defendants apparently did not know what non-disclosure agreements 

someone in Plaintiff's position would have signed and failed to undertake any 

efforts to independently verify which secrecy, non-disclosure agreements 

Plaintiff had executed with the U.S. Government." 

The lawsuit alleges the legal strategy, "was absolutely contrary to law and 

doomed to failure from the start," and put the author into, "a conflict with the 

U.S. Government that he could not win." 

Retired U.S. Army Col. Jim White said he has no sympathy for 

Owen/Bissonnette. 

"When you get that security clearance it clearly states, 'You cannot share this 

information.' We are vetted, we're investigated, the United States has said, 

'We're going to give you information. We're going to trust you with that 

information and it's understood that you don't share that information.'" 

White, a lecturer at IUPUI, said after 30 years in the military he knows that, 

"you fully understand that you can't share that information. To this day, like 

those who have served on active duty and those who have been in the 

military for a long time, I know classified information, but, you just don't share 

that and that is fully understood and that is just information you take to your 

grave. 

"I'm sure he had operational knowledge. I can tell you that in my time in Iraq I 

had operational knowledge that I certainly couldn't share with you and can't 

come back and share with the public.'' 

Robert Shannon, an attorney representing Podlaski and his former law firm, 

told Fox 59 News, "There are certainly some factual misrepresentations 

(and) we denied some of those assertions in the lawsuit and my client will 

prevail.'' 

Owen/Bissonnette claims in his lawsuit that he wrote "No Easy Day'' to set 

the record straight and to benefit the committment of his fellow Seals and 

honor the memory of fallen comrades. 

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