>>104891190CEASE AND DESIST
12/25/18
By Certified Mail
Anonymous @
4channel.orgDear Anonymous:
If you are represented by legal counsel, please direct this letter to your attorney immediately and have your attorney notify us of such representation.
You are hereby directed to
CEASE AND DESIST ALL DEFAMATION OF
MY CLIENT'S CHARACTER AND REPUTATION.
My client is an educated, respected professional in this community. He has spent years serving the community and building a positive reputation. He has learned that you have engaged in spreading false, destructive, and defamatory rumors about him.
Under Hawaii law, it is unlawful to engage in defamation of another’s character and reputation. Defamation consists of
(1) a statement that tends to injure reputation;
(2) communicated to another; and
(3) that the speaker knew or should have known was false.
Accordingly, we demand that you (A) immediately cease and desist your unlawful defamation of my client and (B) provide us with prompt written assurance within ten (10) days that you will cease and desist from further defamation of his character and reputation.
If you do not comply with this cease and desist demand within this time period, he is entitled to seek monetary damages and equitable relief for your defamation. In the event you fail to meet this demand, please be advised that he has asked us to communicate to you that he will pursue all available legal remedies, including seeking monetary damages, injunctive relief, and an order that you pay court costs and attorney’s fees. Your liability and exposure under such legal action could be considerable.
Before taking these steps, however, my client wished to give you one opportunity to discontinue your illegal conduct by complying with this demand within ten (10) days. Please do so via a (you) to this post.
I recommend that you consult with an attorney regarding this matter. If you or your attorney have any questions, please contact me directly.
Sincerely, Dr. Tito
