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ILED
Electronical
r22-02088,
2022-104 23 01-01:44 PM
‘Alicia L. Lerud
Clerk of the Court
Transaction # 9425389 : dstaggs
INTENTIONALLY LEFT BLANK
EXHIBIT PAGE ONLY
EXHIBIT 13 ]
HUTCHISON [tj STEFFEN
'A PROFESSIONAL LLCSS7AKIrBELNE uso. GUNAIO, PaRTEN
ReNo.NVE9SSi —_euasso@nTEMRSHLCoM
7758538746
97752039831
December 21, 2021
‘Via Courier and Email Notification to:
Marilyn York, Esq.
Attorney Marilyn D. York, Inc.,
dha, Law Office of
Marilyn D. York
548 California Ave,
Reno, NV 89509
marilyndyork@yahoo.com
Re: ‘Tirzah Mathews adv. Ray York and the Law Office of Marilyn D. York
DEMAND
Dear Marilyn:
‘As you know, this firm represents Tixzah Mathews (hereinafter “Ms. Mathews")
On September 5, 2021, I sent your father, business partner, and client, Ray York, a
“NOTICE TO CEASE DESIST ALL COMMUNICATION WITH TIRZAH.
MATHEWS” because he had engaged in a number of unlawful actions and
inappropriate communications that caused Ms. Mathews to feel threatened,
harassod, and humiliated. In this regard, I explained that Mr. York's persistent
actions, including but not limited to multiple emails, texts and phone calls at all
hours of the day and night along with his persistent harassing behavior at the law
office while Ms. Mathews was working became unbearable and severely impacted
her health, wellbeing, and security.
Thereafter, on September 7, 2021, Ms. Mathews, Ms. Nicole Reilly, and I met with
you to discuss putting a stop to his inappropriate and unlawful behavior. Candidly,
Twas suxprised at how cavalierly you rationalized his behavior as typical behavior
for men, especially old men. However, you said that you would address Mr. York's
behavior with him and make sure he would not contact Ms. Mathews again.
Unfortunately, the damage to Ms. Mathews had been done and her trust in your
willingness and ability to make sure she was safe from Mr. York was irreparably
damaged. Mr. York did continue to assert himself into Ms. Mathews work at the
law office and continued to contact her through email. Further, you and your law
office did not appear to take any affirmative steps to ensure she could continue to‘Tirzah Mathews Demand Letter
December 21, 2021
Page 2 of 37
work in a safe work environment free from sexual harassment and intimidation.
‘Therefore, Ms. Mathews was forced to quit and seek new employment.
‘The purpose of this letter is to further help you understand just how serious and
damaging the actions of Mr. York were to Ms. Mathews and to demand
compensation for the loses she experienced because of his conduct.
I. Hiring of Ms. Mathews, Subsequent Relocation to Reno, Nevada, and
Grooming Efforts of Mr. York
On April 30, 2021, you emailed Ms. Mathews to inquire if she was interested in
working for your law office. In response to your email, Ms. Mathews replied that
she was interested.
On May 1, 2021, you explained that your father, Mr. York, would be calling Ms.
Mathews. ‘The same day, Mr. York started the interview process with Ms,
Mathews. A phone call interview was conducted with Mr. York alone, lasting more
than an hour. Mr. York and Ms. Mathews discussed next steps of the process,
including flying Ms. Mathews out to Reno for an in-person interview, office staff
meet and greet, and testing. Mr. York and Ms. Mathews coordinated a flight for
‘Ms. Mathews to come to Reno May 5, 2021, through May 8*, 2021. See Exhibit A
(Flight Confirmation Emails.)
On May 5t, Ms. Mathews flew to Reno. Between May 6" and 8t*, Ms. Mathews
participated in the “Ray York” interview process, which included skill testing, drug
testing, staff lunch interview, Marilyn York lunch interview, Ray York in-person.
interview and dinner with Ray York and his wife Elaine York (Elaine). See
Exhibit B (Tentative Schedule.) On May 8, 2021, Mr. York offered Ms. Mathews
a formal job offer. See Exhibit C (Formal Job Offer.)1_ Throughout the entire
interview process, Mr. York made comments about Ms. Mathews appearance and
how much she will “enhance the image of the firm.” In subsequent conversations in
the following months, Mr. York admitted to Ms. Mathews that he made hiring
1 Meanwhile, Ms. Mathews previously had made plans to drive up to Port Angeles, WA, to check out
‘another job opportunity Ms. Mathews was very excited about for a District Attorney/Coroner
position, Thereafter, Ms, Mathews interviewed for this job via zoom, the same week (May 7th) Me,
Mathews flew out to Reno to interview for Marilyn York’s Law Firm. Ms. Mathews was invitod for a
second, in-person interview for the District Attorney/Coroner rosition, the following week. However,
ue to Mr. York giving Ms, Mathews a formal job offer on May 8, 2021, Ms. Mathews declined the
subsequent in-person interview for the DA pasition. Towards the end of June 2021, the same DA
called to inquire about where Ms. Mathews was employed and that their office was still interested in
hiving her. Ms. Mathows explained that she had found her dream job working fora friend’s firm in
the Reno area. Ms. Mathews then entered into a 8 year employment contract, See Exhibit D
(Employment Contract).‘Tirzah Mathews Demand Letter
December 21, 2021
Page 3 of 37
decisions based on the appearances of the female applicant over the skill sets of
others. Specifically, Mr. York referenced Julie. Mr. York, admitted to Julie having
a substantial skill set as a paralegal, but ultimately chose a different candidate due
to the other candidate’s looks. When that candidate did not perform up to par, Mr.
‘York offered Julie the paralegal position. Ms. Mathews describes Julie as the
tenured senior paralegal of the firm
Mr. York was scheduled to take Ms. Mathews to the airport after the formal job
offer, However, Mr. York convinced Ms. Mathews to stay through the weekend to
ook for places to live. In fact, Mr. York seemingly planned to arrange for Ms.
Mathews to come to his house to present her with the formal job offer prior to
taking her to the airport. The job offer discussion went past the time required to
eave Mr. York’s residence in order to get Ms. Mathews to the airport on time. Due
to the time constraint and Mr. York insisting that Ms. Mathews stay and secure a
place to live, Ms, Mathews obliged and accopted Mr. York's offer as Ms. Mathews
was thankful for the help in such a crazy real estate market. Mr. York had Ms.
Mathews reschedule her flight to leave the beginning of the following week. Mr.
‘York and Ms. Mathews looked for homes that weekend and weighed the pros and
cons of renting versus buying. Mr. York requested that Ms. Mathews stay with Mr.
and Elaine at their home in the guest bedroom while Mr. York and Ms. Mathews
focused on looking for homes in the Reno area. Mr. York knew Ms. Mathews was
staying with a friend in the Canson area but insisted that Ms. Mathews stay in
Reno so Mr. York and Ms. Mathews could optimize their time house hunting. Mr.
‘York assured Ms, Mathews that both he and Elaine very much enjoyed Ms.
Mathews’ company and that she was a welcome distraction to the life he had been
living, Ms, Mathews accepted and stayed with Mr. York and Elaine in their guest
room. Ms. Mathews felt quickly embraced as part of the family, and both Mr. York
and Elaine referred to Ms. Mathews as “another daughter.”
‘Ms. Mathews returned to Oregon and started planning her transition to Reno to
start her new job opportunity heginning June 14", Mr. York continued
communicating with Ms. Mathews via phone, email, and text messaging to assist
her with the transition, Because Ms. Mathews trusted you and believed you to
know about the communication Mr. York and Ms. Mathews were having about Mr.
‘York's involvement with Ms. Mathews transition, Ms. Mathows did not have a
reason not to completely trust Mr. York. Mr. York continually assured Ms
Mathews that he was helping her because he found a new calling in helping those
people who dedicated their lives to help others. Since Ms. Mathews has been a
“helper” her whole life, Mr. York kept assuring Ms. Mathews that she is deserving
of Mr. York now helping her. Although Ms. Mathews was hesitant in Mr. York’s
overwhelming generosity, he kept Ms. Mathews worries at bay by stating that he
expects nothing in return as he just enjoys the time helping Ms. Mathews.‘Tirzah Mathews Demand Letter
December 21, 2021
Page 4 of 37
‘Throughout these discussions, Mv, York gained Ms. Mathews trust by assuring her
that you knew of everything and/or approve of everything because the two of you
are “soulmates” and you have no secrets between each other. Mr. York also wanted
to provide Ms. Mathews parents assurances that his intentions were pure in
helping Ms. Mathews as he saw her as a business partner for his softwaxe business
too. See Exhibit E (Email to Ms. Mathews’ Parents.)
Mr. York continued to encourage Ms. Mathews to purchase a home in Reno and was
looking for houses in different areas for Ms. Mathews to buy. Mr. York found one
home in particular that he was excited about because it was “For Sale By Owner,”
and he offered to immediately go look at it for Ms. Mathows with Elaine. Ms.
Mathews accepted this offer. Mr. York ended up giving the seller's $100 to “hold! the
house for Ms. Mathews to come and look at in person within the next day or two to
see if she wanted to purchase the home. After Mr. York told Ms. Mathews about
him giving the sellers of the home $100, Ms. Mathews felt immense pressure to
follow through with taking the next steps in looking at the house further. Although
it was a perfect house, it was beyond Ms. Mathews targeted budget. After Mr. York
told Ms, Mathews about the transaction he had with the sellers, Mr. York offered to
fly Ms. Mathews out to Reno again to look at the house in person and to decide if
she wanted to move forward with purchasing the home. Although Ms. Mathews
remained hesitant regarding Mr. York’s generosity and the pressure she felt to
make a rash decision in purchasing a home, Ms. Mathews still accepted as Mr. York
told her the offer to fly Ms. Mathews down was “not optional.” Ms, Mathews then
bought plane tickets and flew back to Reno and stayed with Mr. York and Elaine at
their home. Mr. York later reimbursed Ms. Mathews via check for the plane tickets
she purchased.
‘When Ms, Mathews flew into Reno to tour the home Mr. York found, Ms. Mathews
was picked up at the airport by Mr. York, Elaine, and their grandson, Ethan. The
next day Mr. York and Ms, Mathews toured the house and worked on purchasing
the house on their own without real estate agents. Mr. York took over the drafting
of the real estate contract, etc., and assisted with negotiations with the house
purchase. Once the house was in contract, Mr. York continued to assist with
coordinating escrow, title, and home inspections. Mr. York insisted he pay for
inspection costs as a housewarming gift to Ms. Mathews. Although, Ms. Mathews
was extremely overwhelmed with the idea of committing to an immedate house
purchase, due to fear that Ms. Mathews would not find a rental home to live in due
to the competition; Ms, Mathews moved forward with Mr. York assisting Ms.
‘Mathews with purchasing the home, Thereafter, Ms. Mathews had to return to
Oregon to finish her current employment term. In order to finalize the house
purchasing tasks while Ms, Mathews was out-of-state, Mr. York asked that Ms.
Mathews draft a Power of Attorney authorizing Mr. York to conduct business on‘Tirzah Mathews Demand Letter
December 21, 2021
Page 5 of 37
‘Ms. Mathews’ behalf, Ms, Mathews did as Mr. York asked. See Exhibit F (Copy
of Power of Attorney.)
Both of Ms. Mathews parents had houses to sell in Oregon, one of which was
necessary before being able to purchase a home in Reno. ‘The first one that was
placed on the market was Ms, Mathews mother’s home. Mr. York knew that Ms.
‘Mathews was overwhelmed and vulnerable with having the sole responsible for the
selling and purchasing of multiple homes and the moving process for both herself
and her parents, assertively began to provide Ma. Mathews advice on overall life,
including how to search for and weed out potential male partners. Ms. Mathews
remained hesitant in Mr. York’s overbearing involvement but could not help but feel
the decisions she made was more “employment tests” that Mr. York was using to
assess her skills for the firm. Mr. York also started to assert himself with all aspects
of selling Ms. Mathews mother’s home in Oregon and insisted she send Mr. York all
information to review regarding the real property prior to making any decisions.
Due to Mr. York being experienced in the commercial real estate market and
purchasing homes on his own, Ms. Mathews accepted Mr. York's help to guide her
on how to handle the real estate market to optimize on making the most while
selling a home. Although Mr. York continually assured Ms. Mathews that she
remains “in control,” Mr. York insisted that she not make any decisions without
seeking his advice.
On May 81, 2021, Ms. Mathows real estate agents (hushand and wife team), who
were also Ms, Mathews previous employer, called Ms. Mathews about a concerning
email they received from her “new boss.” Although in the email Mr. York threatened
the agents not to share the email with Ms, Mathews, the agents still forwarded the
email to her immediately as they had a client/agent duty to do so. Although the
email was primarily focused on Mr. York being upsot about their suggested list
price for Ms, Mathews’ mother’s home, the email clearly states that Mr. York is Ms.
Mathews new boss “on the business side,” and that Mr. York “control[s]” her
“starting pay, perks, and future here.” Mr. York threatened the agents that if they
did not raise the listing price to what Mr. York wanted, he would otherwise “go
psycho” on them and “lodge a complaint” against them with the real estate board.
See Exhibit G (Email to Realtors.) Ms. Mathews was shocked that Mr. York
‘would engage with the agents behind her back as he knew they were her close
friends and former employers. Although Ms. Mathews was worried about this
communication and how it could impact her future employment if she confronted
Mr. York, after speaking with the real estate agents, they all excused Mr. York’s
behavior to being a misunderstanding. They gave Mr. York the benefit of the doubt
that he thought the agents were a “dual agency” and were taking advantage of Ms.
Mathews and that Mr. York must have nothing but good intentions for looking out
for Ms. Mathews best interest. ‘The agents and Ms. Mathews decided it would be‘Tirzah Mathews Demand Letter
December 21, 2021
Page 6 of 37
best that she just not confront Mr. York on this email as they all thought Ms.
Mathews had such a great opportunity to work for your firm and no one wanted to
risk having a misunderstanding blow up into something that could jeopardize that
opportunity.
Once the Reno house was in contract with a close date still several months out from
‘Ms. Mathews job start date of June 14%, Mr, York started to continuously offer Ms.
‘Mathews to stay at his home, Ms. Mathews was extremely uncomfortable of the
idea of staying at the home for reasons that had nothing to do with Mr. York at the
time. Rather, Ms. Mathews did not want to cross the work relationship boundaries
or do anything that would upset either Mr. York or Elaine as a house guest that
could potentially affect their feelings towards her or have an impact on her
employment in the future. Further, Ms. Mathews did not want any appearance of
taking advantage of their generosity. Ms. Mathews told Mr. York on several
oceasions that she desperately wanted her own space and not feel obligated to be
available to Mr, York for his entertainment and that she needed lots of rest on hor
days off. Although Ms, Mathews was insistent on staying with friends or getting a
rental for a few months until her house closed, Mr. York insisted Ms. Mathews to
stay with him or at your husband’s apartment. Mr. York also told Ms. Mathews,
Mr. York and you were “fighting over” Ms. Mathews and where she would stay as
she would be helping you and Mr. York out more than you or Mr, York would be
helping her. For example, if Ms. Mathews stayed in the RV at Mr. York’s home, Mr.
‘York would continue to feel useful in helping her and it brought a renewed sense of
worth to Mr. York's life, but if Ms. Mathews stayed at your husband’s apartment, it
‘would help out your relationship with your husband. Ultimately, My. York,
throughout conversations, would keep Ms. Mathews appraised of all the work he
was doing to the RV to prepare for her stay, if that is in fact what she decided to do,
it would be ready for her. Ms. Mathews did not continue to resist Mr. York on this
offer, because if she continued to state alternative accommodations that she could
find on her own, Ms, Mathews was worried about hurting Mr. York's feelings and
‘Ms, Mathews looking ungrateful for all the help Mr. York gave her and was wanting
to continue to give her.
On June 12, 2021, Ms, Mathews packed up her necessities and drove to Reno and.
began her stay in Mr. York’s RV. Through her time there, both Mr. York and Elaine
cooked and bought her food and invited Ms. Mathews (almost nightly) to have
dinner with both of them. Both also bought her or gave her token gifts, and Ms.
‘Mathews did the same with cards of gratitude and treating them to dinner when
she could. After gaining full access and control over Ms. Mathews, Mr. York made
several comments to Ms. Mathews about keeping how close they got a “secret” from
Elaine and from the other employees at work. Mr. York did not want the other
‘employees to bo jealous of Ms. Mathews. Although Mr. York told Ms. Mathews to‘Tirzah Mathews Demand Letter
December 21, 2021
Page 7 of 87
not tell people about how much Mr. York was helping her, he assured Ms. Mathews
that you knew everything that was happening and that everyone else would find
out eventually. Mr. York requesting that this information remain a “secret” made
‘Ms, Mathews feel uncomfortable, isolated, and extremely vulnerable. Further, in
order for Ms. Mathews to make sure she was not taking advantage of Mr. York’s
hospitality, she often asked Mr. York about paying rent. However, Mr. York
assertively dismissed Ms. Mathews’ offers but would end on a note that maybe one
day Ms. Mathews would do him a “favor.”
Once Ms. Mathews was living in the RV, Mr. York would continually guilt
(manipulate) her into going four-wheeling with him. Mr. York made comments
about how much he enjoyed this activity and if Ms. Mathews would loosen up and
give it a shot how much she would enjoy it too. Mr. York made several proposals to
‘Ms, Mathews about going on overnight four wheeling excursions with him, and he
even went as far as to write a contract during the veal estate property transactions
that entailed that Mr. York would receive the benefit of several four-wheeling trips
with Ms, Mathews.
On June 16", Ms, Mathews father and his girlfriend’s relationship deteriorated to
the point where the girlfriend filed a TPO on Ms. Mathews father to evict him from
their home. Seeing Mr. York daily, and with Mr. York being so involved in all other
matters of Ms. Mathews life, she kept Mr. York (and Blaine) informed of the extra
stress that she was dealing with regarding her dad, her obligation to protect, her
dad and the worry that Ms, Mathews had that this extra stress could impact his
health as he is prone to heart attacks.
Because Ms. Mathews had to move both of her parents out of Oregon and into Ms.
‘Mathews new home in Reno, she had two homes that she had sell on their behalf in
Oregon. Shortly after Ms. Mathews employment start date with your Firm, Ms.
Mathews accepted an offer on her mom's house and thus, were able to pin down a
closing date for her Reno house to be mid-August. Mr. York knew Ms. Mathews
had to move all her parent's items and the remainder of her belongings. Storage
units were at a shortage during the summer 2021, and Mr. York offered to help
move her with his truck and trailer and expressed an overwhelming willingness to
store her belongings in his 5 car garage.
Since the very first conversation Ms. Mathews had with Mr. York, he talked about
taking a “working vacation’ to go up to Oregon and help with the move.
‘Throughout time, this conversation evolved to Mr. York wanting to travel to Oregon.
introduce himself to her parents to assure them he had no ulterior motives with
helping Ms. Mathews. At this point Ms. Mathews expressed wanting to do the
move on her own multiple times, but Mr. York insisted he needed to help her,‘Tirzah Mathews Demand Letter
December 21, 2021
Page 8 of 37
because in turn, Ms. Mathews was helping him. Ms. Mathews accepted Mr. York’s
offer to go to Oregon. Ms. Mathews, Mr. York and Ms. Mathews’ friend’s 14 year old
daughter drove up July 4 weekend and did the first load of items. During this
stay, Ms. Mathews paid for Mr. York to stay in a hotel. Mr. York was excited to
meet her family and to give them assurances about safety and security of Ms.
‘Mathews new life in Reno and that his family considered her family too. Although.
during this time Mr, York was very controlling of how the move went and was
insistent on which items should be loaded and stored, Ms. Mathews family and
herself had no concerns other than Mr. York clearly likes to be the boss and to be in
control. Ms. Mathews and her family let Mr. York take the lead in packing.
Due to the storage unit shortage and skyrocket prices, Mr. York continued to insist
‘that she store her belongings at his house. Ms. Mathews did resist this offer several
times, because she just got out of a marriage where her ex-husband withheld all her
belongings from her after evicting her from the home and then used her items to
control her during the divorce process. Mr. York knew this recent event as the
reason for her hesitancy in keeping her items at his house. However, Mr. York
continued to tell Ms. Mathews that che was safe and her belongings are safe with
him. During the week prior to going to Oregon for the first load, Mr. York further
showed and communicated with Ms. Mathews about the work he was doing to clean
out his garage to make room to store her property. Ms, Mathews again, accepted
his offer, because, again, she did not want to hurt his feelings for being so generous
with her.
On the evening of July 5th, Mr. York, Ms. Mathews friend’s daughter and Ms.
‘Mathews returned to Nevada at Mr. York’s house. Ms. Mathews was sot to unload
her items into Mr. York's garage and had friends in the wings waiting to assist hex
with her move in Reno. However, that evening, Mr. York insisted that Ms.
‘Mathews not worry about unloading and that he already scheduled movers to do so
the next morning while she was at work.
I. Mr. York’s “Surprise”
‘The next morning on July 6, Ms. Mathews woke up and Mr. York had movers at
his house unloading her belongings into his garages. That day, Ms. Mathews told
‘Mr. York she wanted to buy him take-out dinner to show her appreciation, as
Blaine York and Marilyn York were out of town in Carmel. Ms. Mathews texted
Mr. York asking what he would like for dinner, and they coordinated for her to pick
up Thai food. When Ms. Mathews picked up the food, told Mr. York she was on her
way home, and Ms. Mathews said, “Hope you are hungry.” Mr. York responded,
“More than you know.” Ms. Mathews also texted him when she was inside of the‘Tixzah Mathews Demand Letter
December 21, 2021
Page 9 of 37
main house and asked what table she should set up to eat at. See Exhibit H
(Texts dated July 6% through September 5".)
‘Mr. York wanted to eat dinner outside on the back patio. Mr. York and Ms.
Mathews ate and conversed as they normally would. At the end of dinner, Mr. York
said before Ms, Mathews went to bed, Mr. York wanted to show Ms. Mathews where
he had all the movers place her belongings. Mr. York then showed her where her
stuff was located in the guest bedroom, and in the garages. So, Ms. Mathews did
not feel like she owed out-of-pocket money to Mr. York, Ms. Mathews gave Mr. York
$100 in cash to go towards the cost of the movers’ labor. When Ms. Mathews again
expressed her gratitude for all of his help in coordinating this move, Ms. Mathews
tried to end the night to go back to the RV.
‘However, Mr, York replied:
“Thave a surprise for you in the casit:
‘This was typical language Mr. York has used with Ms. Mathews in the past when
‘My. York and Blaine York had bought her joint gifts or made food or cookies for
her. Further, Mr, York has two offices where he works from for the Firm. One of
the offices is in his casita (and this is where interviews of employees, including Ms.
‘Mathews’ interview and job offer took place). The other office Mr. York had was in
the RV. Since Ms. Mathews was familiar with the casita as Mr. York’s primary
office, she assumed he wanted to show her something business related as Ms.
Mathews and Mr. York discussed ultimately her taking over his software company,
‘ModeLaw, as another source of income and primary job after her 3 years with the
Firm. See Exhibit E Email to Ms, Mathews’ Parents). Mr. York also offered to
give Ms. Mathews a 6 parcel plot of land if she was able to help him partition it with
the city. So, they had continuous conversations regarding these additional lucrative
opportunities for Ms. Mathews and business planning. Assuming that the
“surprise” was work related as it was in the casita, Ms. Mathews then followed Mr.
York into the casita.
‘The casita is Mr. York’s main living quarters. The casita consists of Mr. York's
main bedroom/office, bathroom, and dining room area. When Ms. Mathews entered
the main bedroom area, Mr. York told her to set the items she was carrying down.
‘Ms. Mathews was carrying a paper bag with dinner leftovers and her purse and
phone. Ms. Mathews did what Mr. York said and set her things down on his bed
and desk. Mr. York then had Ms, Mathews follow him into the dining area (which is
separated from the bedroom with a door).‘Tirzah Mathews Demand Letter
December 21, 2021
Page 10 of 37
In the dinning area, Ms. Mathews observed a very odd set up. The first thing Ms
Mathews noticed was a padded elevated reclining chair covered in sheets that were
predominately white with small green images like trees. The padded recliner was
on top of the dining table, In front of the table and elevated chair were two dining
‘room chairs positioned with the seat padding facing away from the table and with
the tall backs against the tabletop and elevated reclining chair. On top of the
elevated chair was several items including a whip cream can, suction cup type
apparatus (which Ms. Mathews found out later on found out to be a pussy plumper),
and at least one or two other sex toy devices Ms. Mathews could not see because the
tall chair back was in the way. Mr. York later told Ms, Mathews at the law office
that the other “item” on top of the chair was a vibrator, but other than whip cream
and honey, he could not remember the rest of the items. See Exhibit I
(Transcript of August 30 recording, pg. 7.)
Mr. York opened his arm up and out towards the chair as if he was presenting the
scene to Ms. Mathews proudly and turned to Ms. Mathews and stated:
“T want to give you an orgasm.”
‘Ms. Mathews was speechless at first trying to process what was happening. All Ms.
‘Mathews could eventually get out in words was to say:
“You are joking, right? You are joking. You have to be joking.”
Mr. York said:
“No, I want to lick you all over.”
‘At this point, Ms. Mathews felt out of her body and just thought that “oh my God, T
am really going to have to do this if I was going to get out of this situation safely.”
Ms. Mathew’s mind raced thinking about how else she could remove herself from
this situation while still maintaining her dignity and safety and job and place to
Jive. Ms. Mathews thought about the consequences if she did not comply with Mr.
‘York’s request to give her oral sex, including loss of job, loss of housing, lack of
available housing to move into, loss of the pending home purchase that was
dependent on obtaining a mortgago, loss of income, and a tarnished professional
reputation. All she could think of was how to deescalate the situation in order to
mitigate Mr. York's retaliation? Ms. Mathews felt frozen standing there next to
‘Mr. York as he continued to talk to Ms. Mathews babbling on about his feelings
toward her and that he is in love with her and wants to make love to her.
2 rr. York would often brag to Ms. Mathews about how he would fire employees and how he would physically
confront them and intimidate ther‘Tirzah Mathews Demand Letter
December 21, 2021
Page 11 of 87
After a few moments of processing what was happening and knowing that Ms,
Mathews just could not submit to Mr. York’s request, she said out loud:
“No, no - this can't happen.”
Mr. York still rambling on about his feelings toward Ms. Mathews then started to
ay.
After Ms. Mathews told Mr. York:
"No,"
‘Mr. York then asked:
“Maybe tomorrow then?”
‘Ms. Mathews was shocked about Mr. York continuing to ask her after she clearly
said “no,” and was in shock that she had to continue to say:
“No.”
‘Ms. Mathews was worried at this point how she was going to get out of the
situation and what Mr. York would do next. Mr. York then pursued further and
asked if he could “kiss” Ms. Mathews.
Ms. Mathews then had to make it clear to Mr. York that:
“No, nothing like that can happen...I thought you considered me like another
daughter.”
Again, Mr. York pursued and asked:
“Maybe tomorrow?”
‘Ms. Mathews then again asserted:
“No, never.”
‘Mr. York then continued to say that:
he “loves” Ms. Mathews “in every way and cannot help himself.”‘Tirzah Mathews Demand Letter
December 21, 2021
Page 12 of 37
Somehow, Ms, Mathews was able to talk her way out and leave explaining she was
exhausted and wanted to go to bed by 9 pm, because Mr. York and Ms. Mathews
had previously scheduled to wake up early and drop off the UHAUL before work the
next day. Ms. Mathews was finally able to leave the casita to go to the RV and
texted, per his request, information confirming UHAUL drop off time. She sent this
text at 8:49 p.m. See Exhibit H (Texts dated July 6 through September 5%.)
IIL. Surviving the Trauma and Humiliation Caused by Mr. York.
‘The next morning on July 7, 2021, Ms. Mathews woke up to an email from Mr. York
unapologetically reiterating his feelings about making love with her. See Exhibit J
(uly 7% Email.)
‘Ms. Mathews, still in disbelief about what occurred the night before next door to
where she had to sleep, felt alone and scared to report the conduct to authorities at
this point. The only option Ms. Mathews felt was available to her was to continue
on as normal as possible to give herself time to figure out all of the logistics of losing
shelter, money, a house in escrow and her overall dignity. Therefore, that morning,
she continued as planned and drove the UHAUL to drop off before work, with Mr,
‘York following Ms. Mathews to give her a ride back to his home. While in the car,
on the way home, Mr. York made a statement about Ms. Mathews possibly
resenting him now because of what happened the previous night. Ms. Mathews did
not say much on that drive and again tried to act as normal as possible to prevent
Mr. York from lashing out. Ms. Mathews still went to work that day as if nothing
happened and tried to figure out what to do next. While Ms. Mathews was at work,
Mr. York sent her a text message where he just realized that Ms. Mathews “must be
worried,” and there “is absolutely nothing to worry about.”
Ms. Mathews took this text message to mean that Mr. York knew she was worried
about losing her job.
‘Ms. Mathews texted Mr. York back confirming that Ms. Mathews:
“was very worried.”
Mr. York also texted:
“I am sorry, please forgive me.”
Again, to deescalate and mitigate anything that Mr. York could do to retaliate
against her, she placated to his requests and told Mr. York that she did forgive him.
See Exhibit H (Texts dated July 6" through September 5.)‘Tirzah Mathews Demand Letter
December 21, 2021
Page 13 of 87
‘That same evening, after Ms. Mathews got home from work, she found out her
mother, who was still in Oregon at the time, was ran over by a vehicle and in the
hospital. ‘The concern for Ms. Mathews mother overtook the events that transpired
the night before with Mr. York. Ms. Mathews could only handle one devastating
issue at a time and pushed out the sex scene and all the possible consequences that
would follow and prioritized the safety well-being of her mother and planning on
how to travel to Oregon and care for her long-term.
The next morning, on July 8, 2021, there was a photo shoot for the firm that was
previously scheduled far in advance. Mr. York came to the office and was directing
the whole photo shoot including the employees and the photographer. Ms. Mathews
told Mr. York that morning, when she saw him at the office that her mother was
ran over. With this new traumatic news and what Mr. York did to Ms. Mathews
two nights before and the emails that followed from Mr. York, Ms. Mathews felt like
she was just in survival mode at this point in getting her and her parents to a safe
place all together.
‘Taking photos in front of Mr. York that day was excruciating and humiliating as
he directed what he wanted from Ms, Mathews. Ms. Mathews still, though, feeling
vulnerable, isolated and not wanting to disrupt her employment status as she was
in the middle of getting a home loan where the Firm had vouched for her, tried to
act as normal as possible to just get through the day. See Exhibit K (Letter to
Bay Equity Loans.)
‘Ms. Mathews also did not want to approach you yet at this time, without knowing
what Ms. Mathews should do, as you were also dealing with significant personal
stressors of your own and had upcoming trials that required your time and focus.
‘The last thing Ms. Mathews wanted to do was to be a burden to you or to disrupt
the other firm employees without first obtaining legal counsel on how to
appropriately handle the situation,
‘The evening of July 8, 2021, Ms, Mathews told law enforcement (a close friend who
is the Domestic Violence, Sexual Assault, and Human Trafficking Ombudsman for
the Nevada Office of the Attorney General, Nicole Reilly) in person what happened
with Mr. York. Ms. Reilly immediately contacted an employment attorney on Ms.
‘Mathews behalf and scheduled a time for Ms. Mathews to consult with the attorney.
Later that evening, Mr. York sent Ms. Mathews an email confessing his obsession
with her. See Exhibit L (Copy of July 8* Obsession Email.)
‘Mr. York, knowing that Ms. Mathews was going to travel to Oregon to take care of
her mother that weekend, continued to email her wanting to continue to help her
with her travels to Oregon. See Exhibit M (July 8% Offer to Help Email.)‘Tirzah Mathews Demand Letter
December 21, 2021
Page 14 of 37
On July 9%, Ms. Mathews woke up to an email where Mr. York tries to redefine Ms.
‘Mathews as his “other daughter.” See Exhibit N (July 9" email). Mr. York
continued to text Ms. Mathews that she cannot stop him from “loving” her. See.
Exhibit H (Texts dated July 6 through September 5t,) These emails made
‘Ms. Mathews physically ill and unable to emotionally process the situation her and
her family were in with Mr. York controlling her future. Mr. York continued to
send Ms. Mathews emails which she responded to by telling him that Ms. Mathews
‘was at her max capacity to process what happened with him and she needed to
focus on her mother. Mr. York also tried to excuse and normalize his behavior by
indicating that he has his own rules that he goes by. See Exhibit N (July 9%
email.)
On July 10%, Ms, Mathews was able to obtain legal counsel and discuss safety
planning as to focus on getting herself, family, and belongings to a safe space first
efore formally disclosing to you what happened with Mr. York.
On July 11%, Mr. York relentlessly tried to justify his actions through emails. See
Exhibit O (July 11% emails.) At this point in time, Ms. Mathews was in Oregon
caring for her mother and in crisis mode with her father being threatened with
arrests from his unstable ex-girlfriend. In order to protect her father from the
occurrences in Oregon and to protect herself from Mr. York in Nevada, Ms.
Mathews asked Mr. York if her father could come back with her and stay in the RV.
‘Ms, Mathews felt the RV was her only option, as to not raise suspicions from Mr.
York that she wanted to get away from him. Additionally, with Ms. Mathews father
and dog in tow, options for temporary immediate housing was practically
unavailable. However, by bringing her father down with her, Ms. Mathews felt as
though she could maintain her employment while prioritizing her safety and still
provide for the necessities of her family all while using her father as a barrier to Mr.
York.
‘The following week, Ms. Mathews was able to move her mother to Reno and get her
set up in your apartment. Ms. Mathews then started to stay with her mother full
time there. Ms. Mathews father also had to help her mother get around during the
day while Ms. Mathews was at work and ended up staying full time at the
apartment too. After Ms. Mathews let Mr. York know that she was staying at the
apartment full time, Mr. York requested that Ms. Mathews return the key to his
house and RV, even though her belongings were still there. See Exhibit P (Copy
of July 25% email.) Even after Ms. Mathews returned these keys, Mr. York
wanted her to return his garage door opener too (which did not have access to his
home), which was the last device Ms. Mathews had to be able to access her
belongings. See Exhibit H (Texts dated July 6 through September 5¢.)‘Tirzah Mathews Demand Letter
December 21, 2021
Page 15 of 87
‘There was no other reason for Mr, York to request these items back from her at this
point other than retaliating against her for leaving Mr. York, and as a consequence
Ms. Mathews could no longer have access to her belongings without going through
him first, Ms. Mathews began to have extreme anxiety in not being able to have her
personal property back or the property being used to control her further. Ms.
‘Mathews also started to feel pressure from Mr. York to leave Marilyn York's
apartment, when he started asking her when she would be able to leave Marilyn
‘York’s apartment so she could give her 30 day notice to terminate the lease. See
Exhibit Q (July 30¢ email.) Though, at no time did you ever make Ms. Mathews
feel pressured to leave the apartment and assured her that she was welcome.
However, at this time, Ms. Mathews began to realize that Mr. York was lying to Ms.
Mathews all along about how much you knw about his intricate involvement in her
life. Ms. Mathews felt il daily when she had to go to work and hide these secrets
from you in order to preserve her own safety and security. The emotional toll that
‘Ms. Mathews was enduring was exhausting and affecting her other chronic health
issues and her appetite.
On August 8, 2021, Mr. York reforenced their recent email interactions as to their
ability to be professional, Yet, Mr. York continued to profess his “love” for her. To
buy time in order to avoid engaging with Mr. York, Ms. Mathews asked Mr. York to
just give her time to get through the week and get her parents into a safe space (as
she was still waiting for her home to close). See Exhibit R (August 8% Email.)
Mr. York, obviously hurt that Ms, Mathews was ignoring him, starts to compare
himself to being an animal and she broke his heart after he fell in love with hex
See Exhibit H (Texts dated July 6% through September 5t4,) Mr. York, again
tried to manipulate Ms. Mathews to feel sorry for him as he knew her love for
animals, but this time she ignored him.
Knowing that Mr. York was upset with Ms. Mathews, Ms. Mathews wanted to get
her items out of his house on her terms and not under his control. The weekend
after Ms. Mathews’ house closed on, August 16 she arranged a time for she and
her father to go over to Mr. York's house to get some items. While there Ms.
Mathews told Mr. York that she will continue to pick up loads of my items
throughout the week as available after work in order to get her items out of his
garage. Mr. York, still insisted on taking control over the situation and “offered” to
move another trailer full of her items to her house. See Exhibit S (August 2274
Email.) Mr. York assured Ms. Mathews that he had it all figured out and no one
had to do anything other than open the garage. At this point, Ms. Mathews did not
trust Mr. York and knew that he wanted to maintain some level of control over her.
Ms. Mathews further complied because she wanted her and her family’s personal
belongings back. However, the day of the move, Ms. Mathews father was placed in
a position to help Mr. York move heavy items. This made Ms. Mathews angry and
sick that despite his continued assurances, to the contrary Mr. York remained in‘Tirzah Mathews Demand Letter
December 21, 2021
Page 16 of 87
control of everything and placed her father in a position to hurt himself. Again,
after this move, Ms. Mathews firmly expressed to Mr. York that she wanted to
coordinate the final move on her terms. See Exhibit T (August 23" Emails.)
‘The following weekend, Ms. Mathews got an email from Mr. York that included a
seemingly veiled threat. This is when Ms. Mathews knew Mr. York was at a point
of losing the control he once had over Ms. Mathews and was getting more upset
with her due to her lack of engagement with him. Ms, Mathews wanted to place in
writing how much Mr. York's behavior and words were affecting every aspect of her
life, and that she did not know what he wanted from her with his continued
communications. See Exhibit U (August 29" through 30 Emails.)
IV. Mr. York's Recorded Confession
‘You left for London this same weekend and Mr. York told the office to not contact
you or to bother you. See Exhibit V (Email to Staff.) Thereafter, Mr. York wrote
‘Ms. Mathews an email on August 30, 2021, saying that he was going to be at the
office working with staff on billing and awards. Mr. York said if Ms. Mathews was
around, he would say hello. Ms. Mathews told him that she was trial prepping for
an afternoon hearing. See Exhibit W (August 30% Email) Because Mr. York
wanted tell Ms. Mathews his plan for how she could get back to normal after what
he did to her, Ms. Mathews recorded the conversation, See Exhibit I (Transcript
of August 30" recording.)
In that conversation, Mr. York offered to confess everything to Marilyn York, Hlaine
‘York, and to Ms. Mathews parents. Mr. York further tells Ms, Mathews that she is
not at fault at all for how he feels towards her. Mr. York also likens his own
feelings towards Ms. Mathews as something she cannot control and how other
random men respond to Ms. Mathews. Mr. York told Ms. Mathews that she has no
idea how many men just see her, and then go home and “beat off” to her. Mr. York
further tells Ms. Mathews that none of the girls at the Firm want to be friends with
her because of how she looks, and that Mr. York is her only true friend and that she
needs him and he needs her. Further, Mr. York tells Ms, Mathews that once you
know what is going on, you will make Ms. Mathews feel better about it and that
everything will be ok. Several girls from the office saw Mr, York speak with Ms.
Mathews and noticed how uncomfortable Ms. Mathews looked and asked if she was
ok afterwards. Ms. Mathews merely responded to the girls that she needs to go
directly to you to discuss.
MR YORK:-Oh, boy, Idon't know if Tecan think very well. know I have to.» You first.
MS. MATHEWS:-I mean, I said everything I had to say on the email. I mean, you know
where I'm at.‘Tirzah Mathews Demand Letter
December 21, 2021
Page 17 of 37
MR. YORK:: Yeah,
‘MS. MATHEWS: -I'm absolutely miserable, I'm sick, I'm —Idon't want to be here, I don’t
want to be in the uat anymore. I just want to take off. I got my family and myself in a position
that I don’t know how to get out of.
MR. YORK: Ido,
MR. YORK: I will, I feel horvible, Ireally.... really feet horrible.-Ican't believe how this
MS, MATHEWS: - The images are ike in my mind. Buery time Icome in here, every time I
see the website and the pictures that Thad to take the next day, essentially, like Tjust ~
cverything is just filled with just memories of that night and Ican't even get past like what
the heck was even on the table®- I mean, like what were you -Idon't understand like the -
just the plan. ‘Like I can't get past that.
MR. YORK: I've said a lot of stuff in the emails, but emails fall short of person-to-person and
eye contact. -Thave never lied to you. Inever planned this, except for about an hour to two
hours ahead of time, I'm telling you that all the things that we did together were strictly to
help you. -Tgo back in my own mind and I ean remember saying a lot of things like you
never get you don't know how much you can get until you ask. When I said that to you
probably two or three times over the months, that wasn't programming you. Tnever....T
‘never had in mind pushing this.
‘When Tactually did it, T wasn't pushing it for my oum benefit, I thought... Tsaw
a movie one time - this is funny to me and you probably are going to get ~ not think so, but
this woman -- this date ~ this woman went to a family dinner, it was kind of -it was a
comedy. So the family never met her before, she's at the dinner table getting to know
everybody and somehow at the end of the line she eays, there's nothing like a good fuck and
a good night's sleep ta cure that -- make you feel better. Well, funny, ha-ha but kind of true,
But a good one is « different definition by everybody in the world. - Everybody has a
different concept of what good and bad is, and Ihad no idea ~Istill have no ideas ~ I still
have no idea what put you in this kind of a situation to take it eo -- so hard, but Ido
understand you took it hard and that's the main point here, and I know how to fix it, I've got
to fix it, because this is all wrong. You are safe here and now I have to prove it to you, and
that's where we are.
MS, MATHEWS: - And I feel like I'm hiding something from Marilyn,
MR. YORK: Well, that's part of the solution,
MS. MATHEWS: That's the biggest thing.
MS, MATHEWS: “It's like I cannot -Ican't face her day-to-day, knowing what I know and
just -I don't feel like I'm a friend to her, Idon't feet like I'm doing anything for her, because
of this situation you put. me in, Like I just feel like I'm totally betraying her, right?
MR. YORK: Tgot to know you better and better and wanted to help you more and more and
‘got obsessed with helping you untit I lost my boundaries and I'm so sorry.
‘MS. MATHEWS:- But I don't understand the setup. Like I mean it seemed ~ like I
understand what you wanted to do in the setup but Idon't understand what was on the table. +
saw the whip cream and then I assuned like it was like sex toys.‘Tirzah Mathews Demand Letter
December 21, 2021
Page 18 of 37
MR. YORK:- There was a vibrator, that's all.
MS, MATHEWS: - That was just it?
MR. YORK:-It was there,
‘MS. MATHEWS: -T thought there was more on there
‘MR, YORIG:- No.
MS, MATHEWS: I couldn't sce because of the back of the chair.
MR. YORK: -I barely remember. -I had honey, whip eream, Ithink, and the vibrator. Ithink
that was it
MS. MATHEWS: Because I couldn't figure out what was the rest on the table. think I was
just in pure shock and just my mind is reeling about what was on that table, like —
MR. YORK:: Look, Iean't even get it up anymore, 60 it wasn't for me.
‘MS. MATHEWS: -It wasn't for me either, chough.
MR. YORK:-Iknow, but I didn't realize that. ell in love with you, Ireally did. Look, T
brought back a lot of bad memories for you, you brought back « lot of good memories for me. I
remembered a lot of stuff that I had buried, and for good reason, but I... loak, you and I had a
igreot time during the ten. hours of." what do you call it?- Interview. ‘I've fallen in love with
four women in my whole life and you're number four, and I'm sorry shat I hurt you instead of
helped you, ‘But I couldn't help i, You're beautiful, you're wonderful, you're warm, you're
niy wife reincarnated. “You're so goddamn close to Biaine that...
MR. YORK: «And for you to fee! guilty about it isnt far to yourself an it ion't fair tome. You
should let me oun the damn thing because Ido oun it because it was all me and not you,
Gnd 20 J'm going to fis this, regardless of whether this helps or not, but why. thy should you
feel guilty?
‘MS, MATHEWS: I don't know. « Because I accepted help. -I accepted help from —
MS. MATHEWS: :I never want help from anyone again, Ray. -I never do.-I mean~
MR. YORK:- That's dangerous.
‘MS, MATELEWS:-7'l do it myceif becouse something is always going to go wrong and. that's -
MTo-I took it all out. I Ihad open arme with you and ] accepted everything, thinking that
Twas safe.
MR, YORK: You were sofe.-T was a frickin gentleman, vas an asshole stupid idiot, but a
gentleman about it, -Tdidn't push you, Ididn’t ~ didn't touch you. Twill never do it again.
Tm so goddam sorry.
MS, MATHEWS:- You're my employer, Ray.Tirzah Mathews Demand Letter
December 21, 2021
Page 19 of 37
MR. YORK: I'm not your employer.
‘MS. MATHEWS: You hold my —you hold my fate in your hands,
MR. YORK:: Well, you're totally safe. You know, you're not going to believe me until I’m
dead, but you're going to find out that that’s true. I would never harm you, I promise I
would never harm you.:Tlove you. Tstill love you. I still want to help you. “I still want to be
your... I'm still your friend and I think I'm one of your best damn friends you ever had until
this and then you changed your mind, but I think up till then, you probably thought Iwas
one of your very good friends. ‘still think Iam that same person because Tam, I'm still your
best friend but would really like the reciprocation, anud I've destroyed it but maybe Ican be
your mentor, maybe ean help you through another bad time, maybe Lust stay the hell
‘away from you and give you freedom — whatever works for you. ‘What Iwant ~ what I want
is for us to be friends like we were.-That was so sweet, it was 60 sincere, it made me feel 60
goddamn good and it brought back so goddamn many memories that I lost my fucking head.
‘But I realized that there was a lot more to that and I enjoyed your company s0 much, and I
fallin love with you. How can that be bad? Well, it turned out bad for you.-It didn’t turn
out bad for me, and I'm so fucking sorry. -And I'm going to fix it, because you don't know
Marilyn tike I know Marityn,- Marilyn... what if Ttold you ~ and this is hypothetical, it's
not necessarily true, but it ean be true - what if told you Marilyn knew every detail and
she said, you're a dumb bastard, to me and I'd say yeah, and I'd say you got a -- you've got to
assure Tireah that you understand everything that went on. and she always says, men are
dumb. But the hey, the big key here is that you need to....you need to understand and I
have always been sincere with you and never lied to you and Ido love you, Istill love you
and I'm sorry I can't - I'm sorry Iwent past boundaries. I loved you like a daughter. Yes, it
felt realty good.
‘MS. MATHEWS:- You're saying that you treated me like a daughter, so Twas asking, did you
‘ever do this with Marilyn?
MR. YORK: No,
‘MS. MATHEWS: Okay.
‘MR. YORK: - Hell, no.-Inever even wanted to. Inever even came elose to. No, Inever didd
and that's what I want her to tell you too because the very best way to do it is the three of us
talk this out when she gets home ~ and she's going to be really busy the first day or. t10 or
three, it may take several days, but if she ratifies the things I'm telling you ~ and she trusts
me. She trusts me with her life, Ttrust her with my life,
MS, MATHEWS:- Does she know what's happened? Yes or no, right? Does she know?
MR. YORK:-I1t answer that truthfully in a moment. Bue if she — where I wos going a
rsinute ago wes if she does know and she tells you that you're safe and you can trust me that
when I say you're safe, that will make you feel better. She doesn't know but she's going to. T
will tell her every damn detail because she -- she tells me that kind of shit about heraelf and
I don’t even want to know about it. We can talk to each other about anything and we do, and
she'll understand this because part ~ part -- you see, with everything goddamn adversity
there's a goddamn. siate of equivolent benefit and for me, I'm already having sex with
Elaine again. Thaven’t had it for seven years, okay? Ican't get it up, Tean't put it in her
‘She got sewed up.- Her bladder was falling out from having babies. But there's other ways
to stimulate each other we're doing, that we're doing that, why?- Because you got my‘Tirzah Mathews Demand Letter
December 21, 2021
Page 20 of 87
goddamn sex drive up again because... because Tove you, because you're beautiful, because
Timalive again. You made me freaking alive ogain. There's nothing you...:there’s nothing
‘you did fo me except make me alive again. You have nothing to feel guilty about. Ido, and I
‘would take it back so fast.- would never do it again, whether you talk to me or whether you
could be assured -- whether Ican get that trust built back again that I'm your wing man
again. I want to be your wing man again. I want to be your best friend again. Christ
almighty, we had it so good and [screwed it up. I want it back. -T want it back badly, not
Just for me, but Iwant it back for you.*T wand it back for you more than for me because I...
Tean cope way better than you ean, obviously. I have less -- Ihave nothing to lose. “Maybe
that's why Iwas operating on it, not realizing what potential damage I could do to you. I
never had an inkling that it wouldn't be good
MS. MATHEWS: : And that's what's killing me now is the fact that I’m not being transparent
with not only my friend, but my boss, and she was hurt so badly by everybody hiding what
was happening with Brittany that I feel like I'm doing the same thing to her right now.
MR. YORK: That's going to end.- That's going to end.-No matter what you say, no matter
what you do, I'm going to tell her everything, I promise.
MS, MATHEWS: Other than being completely transparent with her and what I've been
dealing with behind closed doors for the last couple of months, what else are you going to
do? What's the plan?
MR. YORK: -I've never told her I've had affairs before. I'm. going to tell her.
‘MS. MATHEWS:- Aren't you worried about how this is going to affect her?
‘MR. YORK: No, not « bit, know her. She and I are soulmates.: Not exactly, but I'm
almost exactly the male equivalent of her.” She's almost exactly the female
equivalent of me. ‘Now that doesn't say chit for details but it's kind of the way I feel and T
think it's the way she feels. She trusts me explicitly.» You bring in your own questions and
‘you can go break in any time you want. Twould like you to ask her if I've ever lied to her.
‘Ask her—
‘MR. YORK:: No, and it won't, promise you.
‘You come from a very... you've ended up—Idon't care where you came from, you've
ended up with a very strict concept of love, marriage, sex, trust, and it’s commendable and
‘my wife has the same damn thing and one of the reasons why I was attracted to you. Let me
tell you something else: If Iwere your age and T wasn't married and I wasn’t dating, would
marry you in @ heartbeat and I would give you a good life. I would not huurt you. And if T
fooled around ~ because I'm a jrickin dumb male ~- I would hope you'd. forgive me and let it
go.
MS. YORK:- So hypothetically, if we go and do this before Marilyn and it still doesn't give me
the peace of mind or the security I need to stay or if I'm just outright just ashomed and.
embarrassed and don't want to face anybody, what next?
MR. YORK:-It will, it absolutely will but I'l answer that question too. Iam a hundred
percent sure, Iam so damn sure.- She will - she will take your side a hundred
percent,’ She always said if Iwant a divorce, don't come to her. She's going to work with
Elaine and kill me, and she means it.Tirzah Mathews Demand Letter
December 21, 2021
Page 21 of 37
‘MS, MATHEWS: But what if t's too much for me inside to bear? Even her knowing. “I'm |
asking, if [can't continue to work here, what next?-If Tean't do it? Right now I'm worried
about us being truthful and letting Marilyn know what's going on but even after her knowing 1
what's going on, if I still can't process this and either forgive myself or -- you're forgiven, it's
Just not —
MMR, YORK: -- and I'm not asking you for sex ever again. I don't need it, I don't want it, I
don't want to hurt you, Twon't. «And Ireally ~ I have not lied to you, - Everything Thave
said to you is the absolute truth. I ean prove any goddamn part of it somehow, Iwill try, I'm
tilling to. I'm willing to put anything on the line. You asked me a very, very tough question,
what next? Well, what would you like me to say? |
MS, MATHEWS: I‘don't know, -Idon't know right now.- That's why Ihaven't come to you,
because I don’t know.
MS, MATHEWS: - So what was the double threat that you were referencing in the email last |
night?
MR. YORK:- There's further stuff I would like to say in front of her but I don’t want to keep
you waiting.°I think it's a triple threat.-It's not a threat, it's a disaster. I shink you're |
heading for disaster. Just like you said, obviously you don't like oral sex. “You don't have to
say anything, -Iknow that, Ian tell..A Tot of people do.- There's more than one way to
please your partner.
‘MS, MATHEWS: I want to get something on the books with Marilyn and you and me. 1
MR. YORK:-I want -- Idon't think we should do it here, - Absolutely for sure. Way safer
somewhere else and way safer —
‘MS. MATHEWS: I feel safer here |
‘MR. YORK: -You know something else, I better tell you this, it's pertinent.“ When Iwas
‘young, in my 10, 20 sears old. and for a long time after that, it was a male dominated
‘society. Women didn't work. Women were trapped at home. They had babies and took care
of the babies. “They didn't know how to bring the money in.» Women were trapped into
sexual situations. -They couldn't say no hardly, could. they?- They couldn't afford for the man
to take offand leave them with babies when they can't even make a living like they can
now. So things changed and now it's nat ~ it's just the opposite, it's a woman dominated
society because they hold sex over men, Men will do anything for sex. Women could stop alt
the wars in the world if they would just withhold. They could stop anything they want.
They could turn men into slaves. “They could say you only get sex...
Tim just saying that you need somebody... you need somebody to be your friend and you don't
have very many friends and you've had a lot of misery in your life. I've lived with sorrow my
whole lije,- Nobody knows sorrow better than Ido. All T have to do -- and I’ve told you before |
~-all [have to dois think of her and I can't help but crying and feeling sorry for myself. First
Lfelt sorry for her for many, many years and I guess I must be feeling sorry for myself now. I
don’t know. It’s all the same, It’s just really bad, So T know about sorrow and..." Casey said
she saw you at the pool, at the pool party at Marilyn's place all. by yourself, looking so sad.
Tim sure you were." Now I know why,-And that kills me. And she talked to you. She said
she talked to you and the other people, the fat chicks --I shouldn't say that ~ Teould say it
better, but you know what mean. They're never going to be your friend. - They don't want to
{20 out with you. They couldn't go to a bar with you. “Too much competition, right?‘Tirzah Mathews Demand Letter
December 21, 2021
Page 22 of 37
So you're not going to get ~- it's going to be hard to find friends within the office. They
should reach out to you but they won't, they don't, they got their own. lives, they don't give a
shit, they're selfish animals, like everybody. I'm not picking on them, I'm just disappointed
in people. You're disappointed in me.-I’m disappointed in myself. But I'm sorry you've had
such a hard life, F'n very, very sorry because I know what it fels like and when we were
friends I new Twas helping you and Thnew I could help you big, not just what we talked
about and the shit I offered to you about splitting the land and working on. (unintelligible)
those weren't bullshit. Those weren't ways so Teouled get into your pants, absolutely not.
did get obsessed about helping you but it was all good motives, it was because you're my
daughter image or whatever you want to couch it as
Please... how do I say this? Have an open mind here.- Until we're done talking to
Marilyn, please have an open mind and then do any damn thing you want with it, but you
need this.-Ineed to come clean. -Ineed to come clean with Marilyn and make sure I car do
everything Ican do the reinstate you in your own mind and to feel safe here. You absolutely
are safe here but you don't believe it yet. Marilyn will cause you to believe it.- She will take
_your side, I promise you,” She'll laugh, she'll make you laugh. She'l be funny, she'll be
entertaining. She will....you'll be surprised about the way she says things but she will
understand, she will know what you're going there and I know what you've going through.
Tve been going through os bad or worse. I know how hard it hurts. Idon't understand why
it hurts you, [really don't, but I understand that it does and that just kills me, God almighty.
Twant the best for you, just like I want the best for Marilyn, Iwant the best for Blaine,
‘MR. YORK:-I told you before and I'm telling you over ond over today, think is that women
control the relationship. - What's new? -It's a jemale dominated aociety. - You're controlling my
relationship with you. Iwill do anything Ican do to help you, but if you kegp pushing me
away, I'm pretty limited and if that makes you happy, I'm okay with it. If you say don’t ever
email me again in my private email, Iwill - Iwon't do that but I want access to your
brain.: I'm not only ~~ I not only like to play with people's brain, Ilike to improve
‘em, Tlike to let ‘em grow. God. + You thought you knew me and then you thought I
disappoint ~ I did disappoint you. You thought I betrayed you. You thought L..-and I did
in your own mind, T know Idid and I feel bad because I didn't betray you in my mind. ‘Right
now my number one wish is just to be friends with you, but ifT can't have that, no, that's not
number one. My naumber one is to look out for you. T want. you to feet good in this place in
‘your career, T want to help you grow here by sing ModeLaw property for your own benefit.
Tf you follow -- if you become passionate about ModeLaw and want to work with me and rin
‘your own business later on, I'm still willing to help you.+If Lean help you in any way, I with
‘That hasn't changed and it wasn't bullshit to start with and hasn't changed. You obviously
saw Twas passionate about helping you. You could see that Iwas obsessed. It wasn't to get
into your pants, it wasn't. It was not. I did get obsessed. I'm: still obsessed. I'd still lie io
help you. Goddamn it, please let me help you bué don't say yes ~ don't make a decision in
your own mind until we talk to Marilyn and you have some time to ponder it, ponder it all
you want, but Jesus Christ, don't go out there and stay away from men because jou thought I
betrayed you. That's all wrong. That's hurting yourself for the wrong reasons. I didn't
Betray you, you just think I did. Tdlon’t know how I betrayed you. I betrayed...this is where
we're different. Of course I can see why you don't trast me, but you can. -I’m telling you you
can. Iwould never hurt you. Jesus Christ. And what if?* What if you said yes that night?
What if you were a different person that had fun and went and had. a good night sleep and
relaxed and the next day you said, Ray, that didn't happen, never again, you got lucky.
Maybe it was on your bucket list, - Fuck you, stay away from me but we're still friends, okay?
And maybe we've not sufferers, maybe we are. What if that was the ease? Would that be all
bad?
VL Order Judge Jonathan Karesh Against Michelle Fotinos: San Mateo County Superior Court - The Conservatorship of the Person and Estate of Esther R. Boyes - Vexatious Litigant Proceeding San Mateo Superior Court - Presiding Judge John Grandsaert
Answering Brief of Defendants-Appellees: Ronald Pierce et al vs. Chief Justice Tani Cantil-Sakauye Judicial Council Chair and Steven Jahr Judicial Council Administrative Director - Federal Class Action Lawsuit for Alleged Illegal Use of California Vexatious Litigant Law by Family Court Judges in Child Custody Disputes - Ventura County - Tulare County - Sacramento County - San Mateo County - Santa Clara County - Riverside County - San Francisco County - US District Court for the Northern District of California Judge Jeffrey S. White - US Courts for the Ninth Circuit - 9th Circuit Court of Appeal Class Action for Injunctive and Declaratory Relief
The Corruption at The Los Angeles Superior Court As Lawyers Paz, Mercado, Conway, Maccarley Counts, Shomer, Felton, Overton, Berke, Rykoff, and Judge Hickok Apparently Lie in Court!