American Freedom Defense Initiative et al v. Suburban Mobility Authority For Regional Transportation (SMART) et al

Filing 50

MOTION to Compel Discovery by All Plaintiffs. (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1--Declaration of Robert J. Muise, # 3 Exhibit A--Plaintiffs' First Request for Production of Documents, # 4 Exhibit B--Defendants' response to Plaintiffs' First Request for Production of Documents and Certificate of Service, # 5 Exhibit C--Sample of emails produced by Defendants in response to Plaintiffs' First Request for Production of Documents, # 6 Exhibit D--Excerpts of the Deposition of SMART, # 7 Exhibit E--Email correspondence between and among counsel for the parties, # 8 Exhibit F--Privilege log produced by Defendants on June 5, 2013, # 9 Exhibit G--Revised privilege log produced by Defendants on June 11, 2013) (Muise, Robert)

EXHIBIT C

Chubb. Anthony
From:
Sent:

To:
Subject:

Chubb, Anthony
Wednesday, February 03, 2010 11 :58 AM
Gibbons, Beth
RE: SMART buses & Political Advertising

Typically, get out the vote drives are not political. HOWEVER ... it is worth noting that Roi
Chinn is a candidate for the Michigan State Senate in 2010. Targeted get out the vote drives
paid for by politicians could very well cross the line. I think we need more information
before we can respond to this one.
Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Avenue, Suite 600
Detroit, MI 48226
[phone]

This is an attorney client privleged communication.
-----Original Message----From: Gibbons, Beth
Sent: Wednesday, February 03, 2010 11:46 AM
To: Chubb, Anthony
Subject: FW: SMART buses & Political Advertising
Tony,
What are your thoughts on this one?
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

-----Original Message----From: GOP 2010 [mailto:[e-mail]]
Sent: Tuesday, February 02, 2010 4:33 PM
To: Hawkins, Robert B; Gibbons, Beth
Subject: Re: SMART buses & Political Advertising
Mr. Hawkins,
Thanks Robert.
I am apart of multiple diversity organizations and I would like to do a public announcement.
For example, this month is Black History Month as well as Chinese New Year. In southeast

oakland county, many minorities have been left out of mainstream media communication like
registering to vote.
I look forward to your response. Is this request political? Also, who can I FOIA to receive
this info from.
Roi Chinn
On 2/2/10, Hawkins; Robert B <[e-mail]> wrote:
> Hello Mr. Chinn,
>
> This brief message is a follow up to our conversation regarding the
> SMART system's policy on not allowing political advertising. I have
> copied the SMART marketing manager Beth Gibbons as discussed. You
> indicated that someone from SMART had given you my contact information
> and she would be able to offer any further clarity you may need
> regarding the misinformation that was passed along by the SMART Director that you
referenced.
>
> Kindest Regards,
>
>
> Robert B. Hawkins
> Sales Manager, Displays Division
> CBS Outdoor
> 88 Custer Ave.
> Detroit, MI 48202
>
> [phone] (ph) / [phone] (fax)
>
>

Progress ... Not Politics

2

Chubb. Anthony
From:
Sent:
To:
Cc:
Subject:

Chubb, Anthony
Wednesday, January 13, 2010 1:29 PM
Gibbons, Beth
Dryden, Elizabeth; Gordon, Avery
RE: Potential SMART advertiser

Beth,
Per our conversation, the advertisement as proposed does not violate any provlslons of our
advertising contract's restrictions on content, which are set forth in Section 5.07(B)of
the contract.
We do have to continue being very careful on this issue, and in making the determination
of whether proposed advertisements are simple information items, or cross the line and
make political statements.
Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Avenue, Suite 600
Detroit, MI 48226
[phone]
-----Original Message----From: Gibbons, Beth
Sent: Tuesday, January 12, 2010 4:48 PM
To: Chubb, AnthonYi Gordon, Avery; Dryden, Elizabeth
Subject: FW: Potential SMART advertiser
Importance: High
For your review. See link below in the original e-mail to view the ad.
ads are Godless ...

The title of the

Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226
-----Original Message----From: Hawkins, Robert B [mailto:[e-mail]]
Sent: Tuesday, January 12, 2010 4:34 PM
To: Gibbons, Beth
Subject: Potential SMART advertiser
Importance: High
Hello Beth,
The attached email provides a link for a potential advertiser who is displaying the copy
that they would like to run on the SMART system. Please review the proposed layout and let
me know if we can proceed with a contract.
Thanks,
Robert B. Hawkins
1

Sales Manager, Displays Division
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
[phone] (ph)

I [phone] (fax)

-----Original Message----From: Jende Huang [mailto:[e-mail]]
Sent: Tuesday, January 12, 2010 4:12 PM
To: Hawkins, Robert B
Subject: information about United CoR
Robert,
Glad we could connect today_
Here is the link to the national United CoR website: http://unitedcor.org/
Also, you can see some of the Portland bus ads here:
http://portland.unitedcor.org/node/40
Please let me know! Thanks much!
jende
Jende Andrew Huang
National Coordinator
United Coalition of Reason
www.unitedcor.org II 866.897.7248

2

Page 1 of2

From:

Chubb, Anthony

Sent:
To:

Wednesday, January 16, 2013 10:00 AM
Gibbons, Beth

Subject:

FW: Rockstar Games-Red Dead Redemption Game Launch 5/18

Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Street, Suite 600
Detroit, MI 48226
[phone]

from: Gibbons, Beth
Sent: Tuesday, April 06, 2010 4:06 PM
To: Dryden, Elizabeth; Chubb, Anthony
Cc: Gordon, Avery

Subject: RE: Rockstar Games-Red Dead Redemption Game Launch 5/18
The ad last year was posted but the gun was removed. I will request the gun-less version for our review. Thanks.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

from: Dryden, Elizabeth
Sent: Tuesday, April 06, 2010 1:53 PM
To: Gibbons, Beth; Chubb, Anthony
Cc: Gordon, Avery

Subject: RE: Rockstar Games-Red Dead Redemption Game Launch 5/18
I recall an ad that was not placed last year because of a gun. What does the gunless version look like?

from: Gibbons, Beth
Sent: Tuesday, April 06, 2010 1:25 PM
To: Dryden, Elizabeth; Chubb, Anthony
Cc: Gordon, Avery

Subject: FW: Rockstar Games-Red Dead Redemption Game Launch 5/18

Importance: High
CBS is asking for our approval to post these ads on our buses or shelters. They have offered a version without
the gun. Please let me know your thoughts, if possible, today.
Thank you.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
bgibbons@smartbusorg

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Page 2 of2

535 Griswold Street, Suite 600
Detroit, Ml 48226

from: Hawkins, Robert B [mailto:[e-mail]]
Sent: Monday, April 05, 2010 12:00 PM
To: Gibbons, Beth
Subject: FW: Rockstar Games-Red Dead Redemption Game Launch 5/18

Importance: High
Hello Beth,
Please review the attached file and let me know if this would present an issue with buses or shelters. They are
looking for markets to move on and a quick response would be helpful.
Please note the question is with or without the cowboy's gun.
Thanks,

Robert B. Hawkins
Sales Manager, Displays Division
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
[phone] (ph) / [phone] (fax)

from: Gonzalez, Hector E
Sent: Monday, April 05, 2010 11:20 AM
To: Shilling, Rob M; Selby, Eric; Carlucci, Steve P; Bolton, Lee; Hawkins, Robert B; Bronson, Aaron; Ferguson,
Kenneth L

Subject: Rockstar Games-Red Dead Redemption Game Launch 5/18
Hello all please let me know if the attached creative can run in your market and if so can it run with or without the
gun? They have contracted in NY, LA & SF already last week so please let me know as soon as possible.
Thanks in advance everyone!

5/10-4 weeks
Miami-Bus Kings
Baltimore-Bus Shelters
Philly-Bus Shelters
Atlanta-Bus Kings & Shelters
Detroit-Bus Kings & Shelters
Washington DC-Kings
Cleveland-Kings
Thanks,
Hector

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3/12/2013

Page 1 of 1

From:
Sent:
To:
Subject:

Chubb, Anthony
Wednesday, January 16, 2013 10:00 AM
Gibbons, Beth
FW: Rockstar Games-Red Dead Redemption Game Launch 5/18

Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Street, Suite 600
Detroit, MI 48226
[phone]

From: Gordon, Avery
Sent: Thursday, April 08, 2010 12:23 PM
To: Dryden/ Elizabeth; Gibbons, Beth; Chubb, Anthony
Subject: Re: Rockstar Games-Red Dead Redemption Game Launch 5/18

I don't see any violation of the policy with this artwork.
----- Reply message ----From: "Gibbons, Beth" <BGibbons((l)smartbus.org>
Date: Thu, Apr 8,2010 10:28 AM
Subject: Rockstar Games-Red Dead Redemption Game Launch 5118
To: "Dryden, Elizabeth" <EDryden(7v,smartbus.org>, "Chubb, Anthony" <AChubb(Zvsmartbus.org>
Cc: "Gordon, Avery" <AGordon~smartbus.org>
Here is the version without the gun. Please advise.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

- - - _.._------

From: Hawkins, Robert B [mailto:[e-mail]]
Sent: Thursday, April 08, 20109:44 AM
To: Gibbons, Beth
Subject: FW: Rockstar Games-Red Dead Redemption Game Launch 5/18
Hello Beth,
Here is the image without the gun.

Robert B. :Hawkins
Sales Manager, Displays Division
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
[phone] (ph) / [phone] (fax)

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3/12/2013

Page 2 of 3

like to advertise its curriculum (or the fact that it exists) on our buses. Similar to the "Rock Star" ad, our
advertising guidelines prohibit advertising that promotes the sale of alcohol or tobacco. While I understand
that marijuana is not tobacco, I believe it is a form of a substance that can be dried and smoked similar to
tobacco. Both tobacco and marijuana are legal (pot for medical purposes). If the ad is not promoting the
sale of prescribed pot, but the classes surrounding the industry, what would a legal analysis be of the
situation?
Thank you very much for your consideration. I realize that you may have received bits and pieces of this
information over the last few days. It is my understanding that some of the issues are currently under review
while others are being presented for the first time. Because there are several in the process, I wanted to lay them
all out in one communication. We appreciate the legal department and know that you are very busy!!
Please don't hesitate to call me to discuss any of these items in more detail or to request more information.
Beth

From: Gordon, Avery

Sent: Thursday, April 08, 2010 10:54 PM
To: Dryden, Elizabeth; Gibbons, Beth; Chubb, Anthony
Subject: Re: Paramount - Kings w/Slight Extension

Let me clarify .... by "your's" you mean legal's. Can you tell me why is a review by legal being
requested? Do you have any analysis or recommendation of your own?
----- Reply message ----From: "Gibbons, Beth" <BGibbons((u'smartbus.org>
Date: Thu, Apr 8, 2010 4:28 PM ,Subject: Paramount - Kings w/Slight Extension
To: "Dryden; Elizabeth" <EDryden0:;snlartbus.org>, "Chubb, Anthony" <AChubb((z)s!nartbus.org>,
"Gordon, Avery" <AGordon(cV,smartbus.org>
For your review.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

From: Hawkins, Robert B [mailto: [e-mail]]

Sent: Thursday, April 08, 2010 4:22 PM
To: Gibbons, Beth
Subject: FW: Paramount - Kings w/Slight Extension
Beth,
Please look at the attached design.

Robert B. Hawkins
Sales Manager, Displays Division

tile:IIIS:/lnterdeoartmental%20Files/CBS%20Ads/Reviewe d%20Ads/RE%20Paramount%...

3/12/2013

Gi

Beth

From:

Sent:
To:

Subject:

Toth, Toni
Friday, October 30, 2009 10:08 AM
Gibbons, 8eth
RE: Macomb County "Report Drunk Drivers" campaign

Beth,
Please let me know when you hear back. Thanks.
Toni Toth
Executive Secretary, External Affairs, Marketing and Communications SMART
535 Griswold St. Suite 600
Detroit, MI 48226
P: 313.223.2349
F: 248.244.9025
[e-mail]

-----Original Message----From: Gibbons, 8eth
Sent: Friday, October 30,2009 9:58 AM
To: Dryden, Elizabeth; Toth, Toni
Subject: RE: Macomb County "Report Drunk Drivers" campaign
Beth,
This was approved by you, Avery and Tony Chubb for posting on the buses. Is there another reason to meet?
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

-----Original Message----From: Dryden, Elizabeth
Sent: Friday, October 30, 2009 8:31 AM
To: Gibbons, Beth; Toth, Toni
Subject: RE: Macomb County "Report Drunk Drivers" campaign

Please schedule time for rich, jim' steve, fred and @ to review before thursday. I will rearrenge my schedule if necessary.
please excuse typos, this email is being sent from my Treo
-----Original Message----From: "Gibbons, 8eth" <[e-mail]>
To: "Dryden, Elizabeth" <[e-mail]>
Sent: 10/28/094:07 PM
Subject: FW: Macomb County "Report Drunk Drivers" campaign

Let's discuss ...
8eth Gibbons
1

SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, M I 48226

-----Original Message----From: Hawkins, Robert B [mailto:[e-mail]]
Sent: Wednesday, October 28, 2009 2:52 PM
To: Gibbons, Beth
Subject: FW: Macomb County "Report Drunk Drivers" campaign
Hello Beth,
Please review and let me know if your team has a problem with this creative.
Thanks,
Robert B. Hawkins
Sales Manager, Displays Division
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
[phone] (ph) / [phone] (fax)
-----Original Message----From: Carroll, Tom F
Sent: Wednesday, October 28, 2009 1:46 PM
To: Hawkins, Robert 8
Subject: Macomb County "Report Drunk Drivers" campaign
Any problems with this copy on SMART Macomb? Thank you.
Tom Carroll
VP Michigan Region
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
313-556-7120 (direct)
313-872-8066 (fax)

2

Gibbons, Beth
From:
Sent:
To:
Subject:

Hawkins, Robert B [[e-mail]]
Thursday, October 29, 2009 11 :27 AM
Gibbons, Beth
RE: Macomb County "Report Drunk Drivers" campaign

Thanks
Robert B. Hawkins
Sales Manager, Displays Division
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
[phone] (ph) / [phone] (fax)

-----Original Message----From: Gibbons, Beth [mailto:[e-mail]]
Sent: Thursday, October 29, 2009 11 :22 AM
To: Hawkins, Robert B
Cc: Dryden, Elizabeth; Chubb, Anthony; Gordon, Avery
Subject: RE: Macomb County "Report Drunk Drivers" campaign
Robert,
The ads are approved.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

-----Orig ina I Message----From: Hawkins, Robert B [mailto:[e-mail]]
Sent: Wednesday, October 28, 2009 2:52 PM
To: Gibbons, Beth
Subject: FW: Macomb County "Report Drunk Drivers" campaign
Hello Beth,
Please review and let me know if your team has a problem with this creative.
Thanks,
Robert B. Hawkins
Sales Manager, Displays Division
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
[phone] (ph) / [phone] (fax)
-----Original Message----From: Carroll, Tom F
1

Sent: Wednesday, October 28, 2009 1:46 PM
To: Hawkins, Robert B
Subject: Macomb County "Report Drunk Drivers" campaign
Any problems with this copy on SMART Macomb? Thank you.
Tom Carroll
VP Michigan Region
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
313-556-7120 (direct)
313-872-8066 (fax)

2

Gibbons, Beth
From:
Sent:
To:
Subject:

Dryden, Elizabeth
Wednesday, March 03, 2010 10: 18 AM
'Schanel Moses'; 'Kimberly C. Zitny'
FW: Godless Advertising on SMART buses

Fyi. .. 1 will call you. Crains has called - Bill Shay - he will write about this, but not about the positive things SMART is
doing?

From: Dryden, Elizabeth
Sent: Wednesday, February 10, 2010 7:00 PM
To: Brown, Steve
Cc: Gibbons, Beth; Chubb, Anthony; Gordon, Avery
Subject: FW: Godless Advertising on SMART buses
Steve,
We have what may be a controversial advertisement coming up and are providing you with the information below to
forward to Board members as a head's up. Beth Gibbons and Tony Chubb worked together to prepare the information
contained below.
Beth
-~-------------.----

On January 12, 2010 CBS Outdoor sent an e-mail requesting SMART's review of a potential client from the United
Coalition of Reason. The United Coalition of Reason is a national organization that works to raise the visibility of local
groups in the community of reason. Nationally, they have conducted campaigns which highlight the fact that non-atheists
live in every community across America.
The campaign kicked off in 2009 in the form of billboards. See sample ad below. The first public transit ads appeared in
August 2009 in Des Moines, Iowa's DART system. Within one week the ads were pulled from the buses then re-posted
voluntarily by the DART transit system. The campaign has appeared in several markets as either a billboard or public
transit ads including: Baltimore, Maryland; Boston, Massachusetts; Cincinnati, Cleveland and Columbus, Ohio; Chicago,
Illinois, Dallas-Fort Worth and Houston, Texas; Des Moines, Iowa; Morgantown, West Virginia; Newark, New Jersey; New
Orleans, Louisiana; New York, New York; Philadelphia, Pennsylvania; Phoenix, Arizona; Portland, Oregon; San Diego,
California, and Tulsa, Oklahoma.

The ad has been reviewed by SMART's legal department to see if it violated the content restriction policy in the bus
advertising contract. Based on legal's review it was determined there is no violation of Section 5.07(B) of the contract.
They have further advised Constitutional First Amendment free speech rights require that SMART not censor free speech
before the ads appear on our buses. See below for a copy of the advertising guidelines section 5.07 B & C. SMART has
given CBS Outdoor the approval to run these ads and will begin to appear on SMART buses beginning February 22,
2010.

1

5.07

Advertising Guidelines
B.

Restriction on Content
In order to minimize chances of abuse, the appearance of favoritism, and the risk of imposing upon a captive
audience, Offeror shall not allow the following content:
1.
2.
3.
4.
5.

C.

Political or political campaign advertising.
Advertising promoting the sale of alcohol or tobacco.
Advertising that is false, misleading, or deceptive.
Advertising that is clearly defamatory or likely to hold up to scorn or ridicule any person or group of
persons.
Advertising that is obscene or pornographic; or in advocacy of imminent lawlessness or unlawful violent
action.

Review of Advertising Content
Before displaying any advertising, exhibit material, or announcement which Contractor believes may be in
violation of Section 5.07.B, "Restriction on Content," Contractor shall first submit the material to SMART for
review. SMART shall make the final determination as to all violations of Section 5.07.B.

2

From: Chubb, Anthony

Sent: Wednesday, January 27, 2010 10:05 AM
To: Gibbons, Beth; Gordon, Cindy; Dryden, Elizabeth

Subject: RE: Detroit CoR Publicity Campaign Update-> pictures of ads
With the final modifications, there is still no violation of Section 5.07(B) of the contract.

Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Avenue, Suite 600
Detroit, MI 48226
[phone]

From: Gibbons, Beth

Sent: Tuesday, January 26, 2010 12:54 PM
To: Chubb, Anthony; Gordon, Cindy; Dryden, Elizabeth

Subject: FW: Detroit CoR Publicity Campaign Update-> pictures of ads
Please confirm we are moving forward with this advertiser based on the message below.
8eth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

From: Hawkins, Robert B [mailto:[e-mail]]

Sent: Tuesday, January 26, 2010 12:16 PM
To: Gibbons, Beth
Cc: Carroll, Tom F

Subject: FW: Detroit CoR Publicity Campaign Update-> pictures of ads
Beth,
Please see the attached message do you feel that this changes anything in terms of approval if they were to use one of
the messages bellow?

Robert B. IIawkins
Sales M.anager, "Displays DivisioIl
CBS ()utdoor
88 Custer Ave.
[)etroit, MI 48202
[phone] (ph) / [phone] (fax)

From: Ruthe [mailto:[e-mail]]

Sent: Tuesday, January 26, 2010 11:57 AM
To: Hawkins, Robert B

Subject: FW: Detroit CoR Publicity Campaign Update-> pictures of ads
2

From: Ruthe [mailto:[e-mail]]
Sent: Tuesday, January 26, 2010 4: 17 AM
To: '[e-mail]'; 'Frank Burejsza'; 'Jefferson Seaver'; 'Jennifer Beahan'
Cc: 'Fred Edwords'; 'Jende Huang'
Subject: Detroit CoR Publicity Campaign Update
Arlene, Frank, Jeff and Jen,
Please have another look through DetroitCoR.org to see if you find any errors and/or want any changes made before
we're listed on UCoR. I hope to have the logos linked to corresponding home pages soon.
We're ready to make our final decisions about advertising! United CoR would like to sponsor a one month contract of
six king, and six queen, exterior SMART bus ads for Detroit CoR. We can launch as soon as 2/22/10 unless you would
prefer a later date.
SMART operates out of three terminals; Macomb County, Oakland County and Western Wayne County. Would you like
to see our ads evenly distributed on routes out of all three terminals?
Would you prefer (Don't Believe ... ' or (Are you good .. ,'?
Earlier launched local CoRs used:

New York and Boston customized their subway interior signs:

3

Gibbons. Beth
From:
Sent:
To:
Subject:

Dryden, Elizabeth
Friday, July 24,20091:17 PM
Gibbons, Beth
RE: Pinckney Pro Life

What is it?
please excuse typos, this email is being sent from my Treo
-----Original Message----From: "Gibbons, Beth" <[e-mail]>
To: "Chubb, Anthony" <[e-mail]>; "Gordon, Avery" <[e-mail]>
Cc: "Dryden, Elizabeth" <[e-mail]>; "Brown, Steve" <[e-mail]>
Sent: 7/24/09 1:00 PM
Subject: FW: Pinckney Pro Life
CBS Outdoor is requesting our approval of the content of the attached is a shelter ad. I have attached the contract and
also incorporated the pertinent section below. Please provide to me your input as to whether this violates any part of
section 5.07 B.
Thank you.
5.07

Advertising Guidelines
A.

Rate Card

Contractor shall develop a Rate Card which establishes a schedule of rates at which advertising
space will be sold. The Rate Card shall be forwarded to SMART within 30 days of the award,
quarterly, and 30 days prior to any changes to the rates throughout the course of this Contract.
S,

Restriction on Content

In order to minimize chances of abuse, the appearance of favoritism, and the risk of imposing upon
a captive audience, Offeror shall not allow the following content:
1.
2.
3.
4.

Political or political campaign advertising.
Advertising promoting the sale of alcohol or tobacco.
Advertising that is false, misleading, or deceptive.
Advertising that is clearly defamatory or likely to hold up to scorn or ridicule any person or
group of persons.
5. Advertising that is obscene or pornographic; or in advocacy of imminent lawlessness or
unlawful violent action.

C.

Review of Advertising Content
Before displaying any advertising, exhibit material, or announcement which Contractor believes may be in violation of
Section 5.07.B, "Restriction on Content," Contractor shall first submit the material to SMART for review. SMART
shall make the final determination as to all violations of Section 5.07.B.

Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

1

From: Hawkins, Robert B [mailto:[e-mail]]
Sent: Friday, July 24, 2009 12:04 PM
To: Gibbons, Beth
Cc: Carroll, Tom F
Subject: FW: Pinckney Pro Life
Any problem with this copy?

Robert B. Hawkins
Sales Manager, Displays Division
CBS Outdoor
88 Custer Ave.
Detroit, MJ 48202
[phone] (ph) / [phone] (fax)

From: Coyne, Greg P
Sent: Friday, July 24, 2009 11:58 AM
To: Hawkins, Robert B
Subject: Pinckney Pro Life
Hi Robert,
Here is the art work. You're thoughts?
Thanks,
Greg
Greg Coyne
CBS Outdoor
88 Custer Ave
Detroit, MI 48202
Phone: [phone]
Fax: [phone]
Cell: 248-470-4818

2

Chubb, Anthony
From:
Sent:
To:
Subject:
Attachments:

Chubb, Anthony

Importance:

High

Friday, May 14, 2010 3:25 PM
Sisson, Mark
FW: Leaving Islam
leavingislam2.jpg

Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Avenue, Suite 600
Detroit, MI 48226
[phone]
-----Original Message----From: Gordon, Avery
Sent: Friday, May 14, 2010 2:00 PM
To: Chubb) Anthony
Subject: FW: Leaving Islam
Importance: High

-----Original Message----From: Dryden, Elizabeth
Sent: Friday, May 14, 2010 11:32 AM
To: Gordon, AverYj 'John Swatosh'
Cc: Gibbons, Bethj Ynclan, Brenda
Subject: FW: Leaving Islam
Importance: High
Avery,
We were notified that a request has been made for the Islamic advertisement that Beth G.
forwarded a month ago. CBS Outdoor has requested SMART review for posting. After removing
the ads Miami-Dade Transit asked the County Attorney General for an opinion. While we don't
believe we need to do that, let's meet to discuss/meet with ACCESS about this, something to
think about. Let me know you thoughts and if we can meet today to discuss.
This is the same ad as was removed from the Miami-Dade transit system in April. The link is
below.
http://www.miamiherald.com/2010/04/16/1581903/miami-dade-transit-says-it-will.html
The ads were reinstalled on May 3.
http://cbs4.com/local/Fatwa.Miami.Dade.2.16S420S.html
http://www.nbcmiami.com/news/local-beat/Miami-Buses -92009094.html

The group that paid for these ads supposedly filed suit against Miami-Dade transit.
http://www.jihadwatch.org/2010/04/religious-liberty-bus-ad-campaign-update-were-suing-miamidade-transit----please-help-us-fight-for-t.html
In this blog) it states the campaign will go national and they are looking for money to
support the campaign.
http://atlasshrugs2000.typepad.com/atlas shrugs/2010/04/sioa-legal-victory-miami-bus·"adsroll-out-in-bigger-numbers-than-before.html
Beth

2

Chubb, Anthony
From:

Chubb, Anthony
Thursday, March 15, 2007 10:42 AM
Hightower, Melissa
RE: new flight club images

Sent:
To:
Subject:

Melissa,
I think that this proposed advertisement is acceptable based upon the SMARTIT AG agreement on content restriction as
set out in section 3.08(A).
-Tony

From: Hightower, Melissa
Sent: Thursday, March 15, 2007 9:23 AM
To: Dirks, Dan; Gordon, Avery
Cc: Chubb, Anthony
Subject: FW: new flight club images

Importance: High
In response to the request below, I recommend we approve the attached graphic for on bus advertisement. Dan, I will
await your decision.
Gentlemen, this is time sensitive.
Thanks

Melissa V. Hightower
Manager of Marketing

fi.5Nl1Ui'7

For Our Community

3i

192 -office

248-244-8701

from: Deena Gardner [mailto:[e-mail]]
Sent: Wednesday, March 14, 20079:11 AM
To: Hightower, Melissa
Subject: FW: new flight club images

Hi Melissa,
I think Mark mentioned that 1'm working with a client that wants to advertise for Flight Club, which is a very
upscale Gentlemen's Club in Inkster. I wanted to get some feedback from you on the creative they would like
to use to see if this will be acceptable. Please advise- thanks for your help.
By the way, this new system of tracking the buses has been great. Thanks for this useful tool.
Deena

(j)eena CE. gardner
Account Executive
Transit Advertising Group I International Outdoor

Chubb, Anthony
From:
Sent:

To:
Cc:
Subject:

Chubb, Anthony
Tuesday, March 13,200712:57 PM
Hightower, Melissa
Gordon, Avery
Flight Club Advertisement

Melissa,
I think that according to the law and SMART policy, we need to review the proposed Flight Club advertisement for its
content, just as any other proposal. To reject it based solely upon the company that is making the proposal would
certainly be questionable, Constitutionally speaking. The SMARTITAG contract advertising guideline regarding this issue
is at Section 3.08 (A)(3)(c), which prohibits material which is "obscene or pornographic."
If you have time, please give the legal department a copy of the proposed ad.
On an unrelated issue, I was driving down Woodward yesterday and came upon SMART bus number 22367. It has a full
. wrap advertising Metro PCS. The wrap is in terrible condition, several chunks have fallen off, and one part was so
dilapidated that it was dragging on the ground. Under Section 3.09(A) and undoubtedly in other parts of the contract,
SMART makes it clear that it is our intention to have advertising that is aesthetically pleasing ... this bus clearly is failing in
that regard. Just FYI.
Let me know if you have any questions,
-Tony
Anthony Chubb
Law Clerk - SMART
660 Woodward Avenue
First National Building, 9th Floor
Detroit, MI 48226

1

Chubb. Anthony

Subject:

Chubb, Anthony
Wednesday, July 23, 2008 5:46 PM
Gibbons, Beth
Gordon, Avery; Horner, Toby; [e-mail]; [e-mail]
RE: Bus Transit Advertising contract review

Importance:

High

From:
Sent:

To:
Cc:

Beth,
I am out of the office until August 1st. I am looking at the document now, but without the convenience of having my file.
The important changes that I had were incorporated in the general terms and conditions, which were not touched during
this revision.
Changes I did notice:
Section:
1.35(A): There should not be a "guaranteed minimumtl box for "Residual advertising". It will only be done on a percentage
split.
5.04: Some buses have 30 Feet vs. 30 Inches as the available space. Also, why do the 35' and 40' buses have less
length on the curb side than do the 29'? I think that some numbers are reversed here.
5.07(B): Though I do not have my notes with me, I know that the first sentence at the very beginning of this Section,
which I added, is missing. If you cannot find it in your notes, please let me know.
5.08(A)(a): we need to add that they have "reasonable" access to all buses. I don't want them to claim this contract gives
them a right to demand 25 iine hauis at a time.
5.08(A)(c): [in response to your comment]: I would prefer that this said, after the first sentence: "Standard procedure
shall be that contractor gives the SMART Marketing Program Manager 7 days [or whatever time period you want]
advance notice to reserve buses for advertising additions, repairs, or removals. In extreme and limited circumstances for
special events, this time frame may be reduced to 48 hours, in the sole discretion of SMART."
I hope this helps. If you have any questions on Thursday or Friday, please call my cell phone at [phone].

Tony

from: Gibbons, Beth

Sent: Tue 7/22/2008 7: 31 PM
To: Jensen, Karen; Couwlier, Chuck; Chubb, Anthony; Gordon, Avery; Jacques, Paul
Cc: Jones, Hayes; Dryden, Elizabeth
Subject: Bus Transit Advertising contract review
Everyone!!!
Attached is the newly revised, updated, reformatted, clean version of the Bus Transit Advertising Contract. Please review
the sections which apply to your department and/or the sections you participated in helping revise (Tony - most things,
Karen - a lot of things, Paul - everything).
If you have any other changes please make them using Track Changes and send back to me no later than Friday, July
25. After review, Hayes will schedule the Board sub-committee meeting.

I appreciate all your efforts revising this document into a much more concrete, concise contract (I am sure Avery you will
have a comment about that!).
Thanks,
Beth Gibbons
Sfv1ART

Progian; Manager

313.2232112 313.461.4523 - Cell

535 Griswold Street. Suite 600
Detroit. MI 48226

2

Page 1 of3

Chubb, Anthony
From:

Gordon, Avery

Sent:

Wednesday, January 27, 2010 9:53 AM

To:

Chubb, Anthony

Subject: RE: Detroit CoR Publicity Campaign Update-> pictures of ads

This is the same thing we've gotten now for the third time, right? Maybe the names have
changed. In any event, I agree, there's nothing new here.
From: Chubb, Anthony
Sent: Tuesday, January 26, 2010 3:41 PM
To: Gordon, Avery
Subject: FW: Detroit CoR Publicity Campaign Update-> pictures of ads
Avery,
8eth accidentally sent this to Cindy Gordon instead of you ... to me, the analysis doesn't change.

Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Avenue, Suite 600
Detroit, M I 48226
[phone]

From: Gibbons, Beth
Sent: Tuesday, January 26, 2010 12:54 PM
To: Chubb, Anthony; Gordon, Cindy; Dryden, Elizabeth
Subject: FW: Detroit CoR Publicity Campaign Update-> pictures of ads
Please confirm we are moving forward with this advertiser based on the message below.
8eth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

From: Hawkins, Robert B [mailto:[e-mail]]
Sent: Tuesday, January 26, 2010 12: 16 PM
To: Gibbons, Beth
Cc: Carroll, Tom F
Subject: FW: Detroit CoR Publicity Campaign Update-> pictures of ads
8eth,
Please see the attached message do you feel that this changes anything in terms of approval if they were to use

1127/2010

Page 2 of3

one of the messages bellow?

Robert B. Hawkins
Sales Manager, Displays Division
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
[phone] (ph) / [phone] (fax)
From: Ruthe [mailto:[e-mail]]

Sent: Tuesday, January 26, 2010 11:57 AM
To: Hawkins, Robert B
Subject: FW: Detroit CoR PubliCity Campaign Update-> pictures of ads

-- -_..._---_ .... _-_...

__ _._--_._..__ __._.. _.__.. _-_._----_._._- -- ......_
..

..

- _... _ _ -..- -.---.
.. .....

.....

__. _. _. __ ......_..-_.-._

..•.... _._- .. '-"._ ... - .

.......

_---._ .._..... _........• _.- ....•.. _--_. __ ... - ....... _ _..•.•.....•..• _.. _.
..........

From: Ruthe [mailto:[e-mail]]

Sent: Tuesday, January 26, 2010 4: 17 AM
To: '[e-mail]'; 'Frank Burejsza'; 'Jefferson Seaver'; 'Jennifer Beahan'
Cc: 'Fred Edwards'; 'Jende Huang'
Subject: Detroit CoR Publicity Campaign Update
Arlene, Frank, Jeff and Jen,
Please have another look through DetroitCoR.org to see if you find any errors and/or want any changes made
before we're listed on UCoR. I hope to have the logos linked to corresponding home pages soon.
We're ready to make our final decisions about advertising! United CoR would like to sponsor a one month
contract of six king, and six queen, exterior SMART bus ads for Detroit CoR. We can launch as soon as 2/22/10
unless you would prefer a later date.
SMART operates out of three terminals; Macomb County, Oakland County and Western Wayne County. Would
you like to see our ads evenly distributed on routes out of all three terminals?
Would you prefer 'Don't Believe ... ' or (Are you good ... '?
Earlier launched local CoRs used:

Newer launches are using:

1/27/2010

Page 3 of3

New York and Boston customized their subway interior signs:

I'm looking forward to your responses. Isn't this exciting!?!
Ruthe
2486267537
ps: Fred and Jende ... please let me know if we need to revise anything here.

1/27/2010

Page 1 of3

Chubb, Anthony
From:

Gibbons, Beth

Sent:

Wednesday, January 27,201010:11 AM

To:

Chubb, Anthony; Gordon, Cindy; Dryden, Elizabeth

Subject: RE: Detroit CoR Publicity Campaign Update-> pictures of ads
Thank you.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

From: Chubb, Anthony

Sent: Wednesday, January 27, 2010 10:05 AM
To: Gibbons, Beth; Gordon, Cindy; Dryden, Elizabeth
Subject: RE: Detroit CoR Publicity Campaign Update-> pictures of ads
With the final modifications, there is still no violation of Section 5.07(8) of the contract.

Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Avenue, Suite 600
Detroit, MI48226
[phone]

From: Gibbons, Beth

Sent: Tuesday, January 26, 2010 12:54 PM
To: Chubb, Anthony; Gordon, Cindy; Dryden, Elizabeth
Subject: FW: Detroit CoR Publicity Campaign Update-> pictures of ads
Please confirm we are moving forward with this advertiser based on the message below.
8eth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

From: Hawkins, Robert B [mailto:[e-mail]]

Sent: Tuesday, January 26, 2010 12: 16 PM
To: Gibbons, Beth
Cc: Carroll, Tom F

1127/2010

Page 2 of3

Subject: FW: Detroit CoR Publicity campaign Update-> pictures of ads
Beth,
Please see the attached message do you feel that this changes anything in terms of approval if they were to use
one of the messages bellow?

Robert B. Hawkins
Sales Manager, Displays Division
CBS Outdoor
88 Custer Ave.
Detroit, MI 48202
[phone] (ph) / [phone] (fax)
From: Ruthe [mailto:[e-mail]]

Sent: Tuesday, January 26, 2010 11:57 AM
To: Hawkins, Robert B
Subject: FW: Detroit CoR Publicity Campaign Update-> pictures of ads

---------------------------------------------- ._-----_.-_.- ---- --------_._--- --------- - - -----.----- .. _-_.--.---_._-------- ---.-- .. --- ._. --- -- ------.. - -_. --_._._-_ ..----- -_._----------- --- ----------. ------_..--_._-- --._--------_._-.-- ---------_ ... _--_._-- --.

From: Ruthe [mailto:[e-mail]]

Sent: Tuesday, January 26, 20104:17 AM
To: '[e-mail]'; 'Frank Burejsza'; 'Jefferson Seaver'; 'Jennifer Beahan'
Cc: 'Fred Edwards'; 'Jende Huang'
Subject: Detroit CoR Publicity Campaign Update
Arlene, Frank, Jeff and Jen,
Please have another look through DetroitCoR.org to see if you find any errors and/or want any changes made
before we're listed on UCoR. I hope to have the logos linked to corresponding home pages soon.
We're ready to make our final decisions about advertising! United CoR would like to sponsor a one month
contract of six king, and six queen, exterior SMART bus ads for Detroit CoR. We can launch as soon as 2/22/10
unless you would prefer a later date.
SMART operates out of three terminals; Macomb County, Oakland County and Western Wayne County. Would
you like to see our ads evenly distributed on routes out of all three terminals?
Would you prefer (Don't Believe ... ' or 'Are you good ... '?
Earlier launched local CoRs used:

1/27/2010

Page 3 ot 3

New York and Boston customized their subway interior signs:

I'm looking forward to your responses. Isn't this exciting!?!
Ruthe

2486267537
ps: Fred and Jende ... please let me know if we need to revise anything here.

1127/2010

Chubb, Anthony
From:
Sent:
To:
Subject:
Attachments:

Chubb, Anthony
Wednesday, January 16, 2013 10:00 AM
Gibbons, Beth
FW: Rockstar Games-Red Dead Redemption Game Launch 5/18
RDR2_NoGun_F. PDF

Is this sequence in your files? I believe they offered it with the gun, we denied it, and then they amended it and we
approved it without the gun.

Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Street, Suite 600
Detroit, MI 48226
[phone]

From: Gibbons, Beth

Sent: Thursday, April 08, 2010 10:28 AM
To: Dryden, Elizabeth; Chubb, Anthony
Cc: Gordon, Avery
Subject: FW: Rockstar Games-Red Dead Redemption Game Launch 5/18
Here is the version without the gun. Please advise.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

From: Hawkins, Robert B [mailto:[e-mail]]

Sent: Thursday, April 08, 2010 9:44 AM
To: Gibbons, Beth
Subject: FW: Rockstar Games-Red Dead Redemption Game Launch 5/18
Hello Beth,
Here is the image without the gun.

RobertB.

88 Custer

!S

h}

Chubb. Anthony
From:
Sent:
To:
Subject:

Chubb, Anthony
Monday, August 04, 2008 10: 10 AM
Gibbons, Beth
RE: Final Bus Transit Advertising contract

Beth,
I am sorry, I have no idea how this language dropped out of 5.07(A). It should be replaced in its entirety by the following:

5.07 ADVERTISING GUIDELINES

A. RESTRICTIONS ON ADVERTISING
In order to minimize chances of abuse, the appearance of favoritism, and the risk of imposing upon a captive audience,
Offeror shall not allow the following content:
1.
2.
3.
4.
5.
6.

Political or political campaign advertising.
Advertising promoting the sale of alcohol or tobacco.
Advertising that is false, misleading, or deceptive.
Advertising that is clearly defamatory or likely to hold up to scorn or ridicule any person or group of persons.
Advertising that is obscene or pornographic; or in advocacy of imminent lawlessness or unlawful violent action.
Advertising that is insulting to SMART's services, patrons, and or employees.

Tony

From: Gibbons, Beth
Sent: Friday, July 25, 2008 7:16 PM
To: Couwlier, Chuck; Jacques, Paul
Cc: Jones, Hayes; Dryden, Elizabeth; Jensen, Karen; Gordon, Avery; Chubb, Anthony
Subject: Final Bus Transit Advertising contract

Final version for review at the Board Sub committee meeting.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit. MI 48226

Chubb, Anthony
Chubb, Anthony
Thursday, July 08,2010 10:17 AM
Gibbons, Beth; Gordon, Avery; Dryden, Elizabeth
RE: ABC

From:
Sent:
To:
Subject:

This decision turns on whether the proposed advertisement is "obscene" per section. 5.07. I
believe an argument can be made that the proposed ad is repulsive by reason of crass
disregard of moral or ethical principles, and should therefore be rejected. Avery makes the
final decision. I'd ask for alternative graphics.
Tony
From: Gibbons, Beth
Sent: Wednesday, July 07, 2010 4:05 PM
To: Chubb, Anthony; Gordon, Avery; Dryden, Elizabeth
Subject: FW: ABC
For review and discussion.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell

[e-mail]<mailto:[e-mail]>

535 Griswold' Street, Suite 600

Detroit, MI

48226

From: Hawkins, Robert B [mailto:[e-mail]]
Sent: Wednesday, July 07, 2010 12:17 PM
To: Gibbons, Beth
Subject: FW: ABC
Beth,
Please see the email that I have attached and let me know your thoughts.
This is something that I should respond to no later than mid-day tomorrow.
Thanks,
Robert B. Hawkins
Sales Manager) Displays Division

CBS Outdoor
88 Custer Ave.
Detroit, M1 48202
[phone] (ph) / [phone] (fax)

From: Lewis, Carol R
Sent: Tuesday, July 06, 2010 7:17 PM
To: Canley, Bryan; Berkwitz, Shari; Carlucci, Steve P; Carroll, Tom F; Hawkins, Robert B;
Mucurio, Nicole L; Danneil, Marcus; Bolton, Lee
Subject: ABC
Hi there ABC is promoting a new show for the Fall called 'My Generation.' They've begun running TV ads
and would like to run the same creative on their outdoor.
The premise of the show is that in 2000, a documentary crew followed a group of high
schoolers from Greenbelt High School in Austin, TX as they prepare for graduation, then
revisits these former classmates ten years later as they return home to rediscover that just
because they're not where they planned doesn't mean they're not right where they need to be.
As these classmates return home to revisit their old hopes for their future, they'll discover
that, even if you don't get exactly what you thought you wanted out of life, it's not too
late to get what you need. Some of the characters are the 'overachiever', ' the beauty
queen', 'the jock', 'the brain', 'the nerd', etc
The copy will have a tag line and then a snap shot of that particular character.
There will be multiple copy/taglines and one of which uses the word sex, so they wanted to be
sure it's ok.
There will be nothing suggestive or inappropriate in the visual.
The tagline with sex (the nerd character) says:
I'd really like to have sex before I'm a father.
ABC My Generation
Thursday Sept 23rd
I was able to get a picture from their TV ad, see attached, so you get an idea of the general
creative.
*This is a different tagline (I had sex with you on prom night. Meet your son) J but it gives
you how simple the copy is.
(and it's just 1 of 9 different copy)
[cid:image001.jpg@01CB1DED.6212E050]
They do not yet have their outdoor to submit as they are working on it now, and wanted to run
this by us before they move forward.
So please let me know if you foresee any issues (on displays media).
Thanks
Carol Lewis
CBS Outdoor

2

Chubb, Anthony
From:
Sent:
To:
Cc:
Subject:

Chubb, Anthony
Tuesday, February 02, 2010 5:48 PM
Gibbons, 8eth
Dryden, Elizabeth; Gordon, Avery
RE: Detroit CoR Publicity Campaign Update-> pictures of ads

i am sorry Beth, I have a hearing on Thursday that has precluded me from writing an explanation on this topic. The reality
is that all advertisements are reviewed against the content restriction policy in the contract If they don't violate it, they are
approved. This advertisement did not violate the policy, and was therefore published.

Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Avenue, Suite 600
Detroit, MI 48226
[phone]

From: Gibbons, Beth
Sent: Tuesday, February 02, 2010 3:00 PM
To: Chubb, Anthony
Subject: RE: Detroit CoR Publicity Campaign Update-> pictures of ads
Tony,
Were you able to get this done? I didn't see anything since this and didn't know if you had sent something to Beth
directly. Let me know.
Thanks.
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street. Suite 600
Detroit. MI 48226

From: Chubb, Anthony
Sent: Thursday, January 28, 2010 5:06 PM
To: Dryden, Elizabeth; Gibbons, Beth
Subject: RE: Detroit CoR Publicity Campaign Update-> pictures of ads
I will write something up tomorrow ©

Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Avenue, Suite 600
Detroit, MI 48226
[phone]

Chubb. Anthony
From:
Sent:
To:
Cc:
Subject:

Chubb, Anthony
Wednesday, January 13, 2010 10:02 AM
Gibbons, 8eth
Gordon, Avery; Dryden, Elizabeth
RE: Potential SMART advertiser

Beth,
Let's meet briefly, with the exact advertisement copy that is being requested) and review
this against our content policy. Let me know what time is convenient for you.
Anthony Chubb
Assistant General Counsel
SMART
535 Griswold Avenue, Suite 600
Detroit, MI 48226
[phone]

-----Original Message----From: Gibbons, Beth
Sent: Tuesday, January 12) 2010 4:48 PM
To: Chubb, Anthony; Gordon, Avery; Dryden, Elizabeth
Subject: FW: Potential SMART advertiser
Importance: High
For your review.
are Godless ...

See link below in the original e-mail to view the ad.

The title of the ads

Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street, Suite 600
Detroit, MI 48226

-----Original Message----From: Hawkins, Robert B [mailto:[e-mail]]
Sent: Tuesday, January 12, 2010 4:34 PM
To: Gibbons} Beth
Subject: Potential SMART advertiser
Importance: High
Hello Beth,
The attached email provides a link for a potential advertiser who is displaying the copy that
they would like to run on the SMART system. Please review the proposed layout and let me know
if we can proceed with a contract.
Thanks,

Chubb. Anthony
From:
Sent:
To:
Subject:

Chubb, Anthony
Wednesday, March 18,20092:34 PM
Gibbons, Beth
RE: Summit/Next Day Air Creative

This promotion has survived the scrutiny of Legal and Hayes ... Approved.
Tony

from: Gibbons, Beth
Sent: Tuesday, March 17, 20094:55 PM
To: Chubb, Anthony
Subject: FW: Summit/Next Day Air Creative
Importance: High
Any problems with this?
Beth Gibbons
SMART Marketing Program Manager
313.223.2112 - Office
313.461.4523 - Cell
[e-mail]
535 Griswold Street. Suite 600
Detroit, MI 48226

from: Hawkins, Robert B [mailto:[e-mail]]
Sent: Tuesday, March 17, 20094:18 PM
To: Gibbons, Beth
Subject: FW: Summit/Next Day Air Creative
Importance: High
Hello Beth,
Please review the attached file which contains creative for an upcoming movie and please let me know if we can tell the
client to proceed with printing the materials for a pending shelter buy.
Thanks,

Robert B. I-Ia'\-vkins
Sales Manager, IJisp lays Division
CBS Outdoor
88 Custer Ave.
Detroit,Ml 48202
3) 556-71]5 (ph) I

872-8066