T
TESSER & RUTTENBERG
Guest
TESSER & RUTTENBERG
*****
Los Angeles, California 90025
TEL: (***) ***-****
FAX: (***) ***-****
Writer's Direct Dial
(***) ***-****
May 1, 2003
VIA EMAIL ([email protected])
David Tseng
*****
Santa Monica, California 90404
RE: www.morrissey-solo.com
Dear Mr. Tseng:
This firm represents "freeyourself". Our client has become aware that you run a website located at www.morrissey-solo.com which currently displays a thread of user postings regarding our client's alleged activities on the discussion forum on your site, that contains numerous falsehoods, unfounded rumors and outright lies.
As our client was attending an event, held in his honor, at the "Star & Garter" last nite, he is clearly innocent of the charges levelled against him by the tedious bore known as "Bertie", and therefore we put it to you that her postings and the content contained therein are defamatory, libelous and actionable.
Might we also suggest that, as she appears to genuinely believe that our client is responsible for every negative post on your site, it may be a good idea if you told her to get a life and stop being such a paranoid loser.
Your accommodation of and specific allowance for the continued transmission of such material is not only in violation of Federal, State and local regulations, but a violation and infringement of our client's rights, and may subject you to criminal as well as civil liability.
In light of the foregoing, we demand that you immediately remove the posting thread that contains all such defamatory content. We further demand that you immediately provide us with written assurance that you will comply with this request and will continue to monitor and remove any and all additional postings or content that contains similar or other defamatory statements. Should you fail to comply with the foregoing by 11:00 PM today (May 21, 2005), be advised that our client is prepared to hold you personally liable for such actions and will seek to have your entire website completely shut down.
We have not set forth each and every claim our client may have, and we expressly reserve on his behalf all rights, privileges and remedies with respect to these matters. We emphasize that our client views this as a matter of the utmost gravity and is prepared to take all steps necessary and appropriate to protect his reputation. Failure to remove such content will be deemed a willful infringement of our client's rights and will leave our client no other choice but to enforce his rights through litigation. Given the seriousness of this matter, we look forward to your prompt response and cooperation.
Sincerely,
TESSER & RUTTENBERG
By: /s/ Jason J. Liberman
Jason J. Liberman
JJL/ws
Cc: freeyourself
*****
Los Angeles, California 90025
TEL: (***) ***-****
FAX: (***) ***-****
Writer's Direct Dial
(***) ***-****
May 1, 2003
VIA EMAIL ([email protected])
David Tseng
*****
Santa Monica, California 90404
RE: www.morrissey-solo.com
Dear Mr. Tseng:
This firm represents "freeyourself". Our client has become aware that you run a website located at www.morrissey-solo.com which currently displays a thread of user postings regarding our client's alleged activities on the discussion forum on your site, that contains numerous falsehoods, unfounded rumors and outright lies.
As our client was attending an event, held in his honor, at the "Star & Garter" last nite, he is clearly innocent of the charges levelled against him by the tedious bore known as "Bertie", and therefore we put it to you that her postings and the content contained therein are defamatory, libelous and actionable.
Might we also suggest that, as she appears to genuinely believe that our client is responsible for every negative post on your site, it may be a good idea if you told her to get a life and stop being such a paranoid loser.
Your accommodation of and specific allowance for the continued transmission of such material is not only in violation of Federal, State and local regulations, but a violation and infringement of our client's rights, and may subject you to criminal as well as civil liability.
In light of the foregoing, we demand that you immediately remove the posting thread that contains all such defamatory content. We further demand that you immediately provide us with written assurance that you will comply with this request and will continue to monitor and remove any and all additional postings or content that contains similar or other defamatory statements. Should you fail to comply with the foregoing by 11:00 PM today (May 21, 2005), be advised that our client is prepared to hold you personally liable for such actions and will seek to have your entire website completely shut down.
We have not set forth each and every claim our client may have, and we expressly reserve on his behalf all rights, privileges and remedies with respect to these matters. We emphasize that our client views this as a matter of the utmost gravity and is prepared to take all steps necessary and appropriate to protect his reputation. Failure to remove such content will be deemed a willful infringement of our client's rights and will leave our client no other choice but to enforce his rights through litigation. Given the seriousness of this matter, we look forward to your prompt response and cooperation.
Sincerely,
TESSER & RUTTENBERG
By: /s/ Jason J. Liberman
Jason J. Liberman
JJL/ws
Cc: freeyourself