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File:2025-09-10-Lisa-Haba-Team-NDA-Characterization-Contradicted-By-Agreement-And-Sarah-Statements.jpg

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Composite comparing paragraphs 371 and 372 of the Consolidated Third Amended Complaint, filed April 4, 2025, with defense exhibits filed September 10, 2025. The exhibits include Sarah’s January 7 & 8, 2019 negotiation of the NDA, her August 2019 recorded statements, and the mutual NDA signed January 18, 2019. The agreement contains no reference to grooming, rape, sexual conduct, or criminal concealment and expressly excludes disclosures required by courts, governmental agencies, or operation of law. Sarah’s own messages document her requesting protections, discussing the agreement before signing, denying grooming, and later describing her sex-for-signature language.

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