From: Galloway, Stephen

To: Mike Brooks

Cc: Keating, Reilley

Subject: RE: Brooks v. Agate Resources - Confidential Documents [SR-ACTIVE.FID3130539]

Date: Monday, December 21, 2020 11:12:14 AM

Mr. Brooks,

Please let us know when you are available to confer by phone on our motion. Otherwise, we will

inform the Court that you declined to confer and we will file the motion as opposed.

Stephen H. Galloway | Of Counsel

STOEL RIVES LLP | 760 SW Ninth Avenue, Suite 3000 | Portland, OR 97205

Direct: (503) 294-9369 | Mobile: (503) 367-6832

stephen.galloway@stoel.com | Bio | vCard | www.stoel.com

This email may contain material that is confidential, privileged, and/or attorney work product for the sole

use of the intended recipient. Any unauthorized review, use, or distribution is prohibited and may be

unlawful.

From: Mike Brooks <mibrooks@mac.com> 

Sent: Monday, December 21, 2020 10:51 AM

To: Galloway, Stephen <stephen.galloway@stoel.com>

Cc: Keating, Reilley <reilley.keating@stoel.com>

Subject: Re: Brooks v. Agate Resources - Confidential Documents [SR-ACTIVE.FID3130539]

I destroyed those records as I told you snd the Court. I have copies of records that were stolen on

September 20, 2017, and returned to me that are evidence in a Supreme Court appeal. I have other

records of Trillium selling patient records to employers, and secret records that are part of a federal

investigation. I’m pretty sure that you and the local court cannot make broad claims about

prohibiting me from ever whistleblowing or obtaining evidence if unlawful conduct by Centene and

its executives. That seems to be what you are trying to claim. Since I am filing other papers with the

Supreme Court right after Christmas, I will include your threats.

Mike Brooks

Sent from my iPhone

On Dec 21, 2020, at 10:40 AM, Galloway, Stephen <stephen.galloway@stoel.com>

wrote:

Mr. Brooks,

EXHIBIT 8 

Page 1 of 4

Case 6:14-cv-01424-MC Document 92-8 Filed 12/22/20 Page 1 of 4
On October 9, 2020, I sent you the attached letter demanding return of Agate

Resources’ confidential documents that you retained upon the termination of your

employment in 2013. I did not receive a response to the letter. Agate is now preparing

to file a motion in U.S. District Court to enforce the terms of the Protective Order

(which is included with the attached letter) and compel the return of Agate’s

documents.

Per Local Rule 7-1(a), we are required to confer with you before filing the motion.

Please let me know your availability between now and Wednesday for a brief phone

call to discuss the return of Agate’s documents.

Thank you.

Stephen H. Galloway | Of Counsel

STOEL RIVES LLP | 760 SW Ninth Avenue, Suite 3000 | Portland, OR 97205

Direct: (503) 294-9369 | Mobile: (503) 367-6832

stephen.galloway@stoel.com | Bio | vCard | www.stoel.com

This email may contain material that is confidential, privileged, and/or attorney work product

for the sole use of the intended recipient. Any unauthorized review, use, or distribution is

prohibited and may be unlawful.

<2020.10.09 Agate - Letter to Brooks re PHI.pdf>

EXHIBIT 8 

Page 2 of 4

Case 6:14-cv-01424-MC Document 92-8 Filed 12/22/20 Page 2 of 4
From: Mike Brooks

To: Galloway, Stephen

Subject: Re: Brooks v. Agate Resources - Confidential Documents [SR-ACTIVE.FID3130539]

Date: Monday, December 21, 2020 11:18:23 AM

destroyed those records as I told you snd the Court. I have copies of records that were stolen

on September 20, 2017, and returned to me that are evidence in a Supreme Court appeal. I had

other records of Trillium selling patient records to employers, and secret records that are part

of a federal investigation. I’m pretty sure that you and the local court cannot make broad

claims about prohibiting me from ever whistleblowing or obtaining evidence if unlawful

conduct by Centene and its executives. I have no idea if what records would even be included

with your gag order. Please provide a detailed list of items you claim as “privileged”.

Since I am filing other papers with the Supreme Court right after Christmas, I will include

your threats. None of the current records are or have anything to do with the Qui Tam claims

London, Leiman, Johnson, and Dugan were claiming in their suit, so I am not T all sure what

you are even talking about.

Mike Brooks

Sent from my iPhone

On Dec 21, 2020, at 10:51 AM, Mike Brooks <mibrooks@mac.com> wrote:

I destroyed those records as I told you snd the Court. I have copies of records that

were stolen on September 20, 2017, and returned to me that are evidence in a

Supreme Court appeal. I have other records of Trillium selling patient records to

employers, and secret records that are part of a federal investigation. I’m pretty

sure that you and the local court cannot make broad claims about prohibiting me

from ever whistleblowing or obtaining evidence if unlawful conduct by Centene

and its executives. That seems to be what you are trying to claim. Since I am

filing other papers with the Supreme Court right after Christmas, I will include

your threats.

Mike Brooks

Sent from my iPhone

On Dec 21, 2020, at 10:40 AM, Galloway, Stephen

<stephen.galloway@stoel.com> wrote:

Mr. Brooks,

On October 9, 2020, I sent you the attached letter demanding return of

Agate Resources’ confidential documents that you retained upon the

EXHIBIT 8 

Page 3 of 4

Case 6:14-cv-01424-MC Document 92-8 Filed 12/22/20 Page 3 of 4
termination of your employment in 2013. I did not receive a response to

the letter. Agate is now preparing to file a motion in U.S. District Court to

enforce the terms of the Protective Order (which is included with the

attached letter) and compel the return of Agate’s documents.

Per Local Rule 7-1(a), we are required to confer with you before filing the

motion. Please let me know your availability between now and

Wednesday for a brief phone call to discuss the return of Agate’s

documents.

Thank you.

Stephen H. Galloway | Of Counsel

STOEL RIVES LLP | 760 SW Ninth Avenue, Suite 3000 | Portland, OR 97205

Direct: (503) 294-9369 | Mobile: (503) 367-6832

stephen.galloway@stoel.com | Bio | vCard | www.stoel.com

This email may contain material that is confidential, privileged, and/or attorney

work product for the sole use of the intended recipient. Any unauthorized

review, use, or distribution is prohibited and may be unlawful.

<2020.10.09 Agate - Letter to Brooks re PHI.pdf>

EXHIBIT 8 

Page 4 of 4

Case 6:14-cv-01424-MC Document 92-8 Filed 12/22/20 Page 4 of 4