Law Offices of Jeffery A. Whitney & Associates
1875 I Street N.W.
phone (202)422-0713 fax
(202)429-9574
May 8, 2006
Mr. Taylor *******
******************, NW
Sent
via:
Re: Cease and desist defamatory statements and use of image and likeness on DUMPSKINNER.COM website
Dear Mr. *******:
We are contacting you on behalf of our client, Mr. Sinclair Skinner. It has come to our attention that statements made by you, including those on the website DUMPSKINNER.COM, have damaged the reputation and character of Mr. Skinner. After reviewing the activity of your site over the last two weeks, we believe that your actions are defamatory and constitute libel per se. As owner and operator of the website, we insist that you immediately cease operation of the website and remove all defamatory content regarding Mr. Skinner. We further also insist that you refrain from making or in any way publishing further defamatory statements about Mr. Skinner.
Statements constituting libel per se are automatically actionable as a matter of law. Although we take notice that you have recently altered the content of your site, the fact that you already published libelous material, but have now removed a portion of the content, does not negate Mr. Skinner's claims. In this case, Mr. Skinner's reputation and ability to seek employment has been damaged by your conduct. We are confident that if you consult any experienced attorney, you will be advised that such statements may subject you to liability.
Our request is, therefore, a very reasonable one. Immediately cease operation of the DUMPSKINNER.COM website and any other website with similar defamatory content for which you are wholly or partially responsible. We also insist that you cease and desist from using any images or likeness of Mr. Skinner.
We welcome the opportunity to discuss this matter with your counsel, and thank you for your immediate attention to this matter. We will consider this matter resolved if the DUMPSKINNER.COM website is removed and no new content posted by May 15, 2006. Please understand that this legal representation for Mr. Skinner is in no way related to the campaign to elect Adrian Fenty for Mayor.
Sincerely,
(signature)
Jeffery A. Whitney, Esq.
cc: *******.com, web host provider