exposes you to punitive damages to punish such misconduct by making an example of you to deter such future misconduct by you and others. Conspiracy, collusion, ot combination to commit tortious conduct constitutes an additional basis for liability against each of you and would be an aggravating factor in a legal action against you.
Correlatively and in the alternative, you are liable to Mr. Bellord for invasion of his privacy by placing him before the public in a false light. To wit, your statements implicating Mr. Bellord in the killing of Mr. Shim falsely porlray Mr. Bellord as an irresponsible driver of a boat that killed Mr. Shim due to speeding in an area frequented by swimmers. Such allegations are highly offensive to a reasonable person and you had knowledge or acted either intentionally or in reckless disregard as to the falsity of the published matter and the false light in which it would place Mr. Bellord.
On behalf of Mr. Bellord, demand is hereby made upon you to immediately retract and correct any and all defamatory statements made by you accusing Mr. Bellord of being involved in the killing of Mr. Shim. You must publish a statement expressly withdrawing and expunging your defamatory statements on the same forum where the statements were originally made, including the Facebook page where you published the statement dated January 24,2016 and the Cult Education Institute site where you published the February 4,2016 statement. You must take any and all actions necessary to remove the statements from the Internet and to apologize publicly to Mr. Bellord for your wrongdoing. You must also compensate Mr. Bellord for the harm to his reputation, the emotional distress caused him by your conduct, and the expenses he has incurred in addressing your wrongdoing. Mr. Bellord rvill accept $25,000, in addition to the retraction and correction of the statements, in order to resolve his claims against you now before filing suit. If he is compelled to sue you, we will advise him to seek substantial punitive damages to set an example to deter future defamatory statements like yours.
Demand is made that you immediately comply with this letter on or before N{.ay 12 2016. If the demand expires without compliance, we will recommend that our client pursue legal action against you and any other parties responsible for Mr. Bellord's defamation. If you are willing to
publish a retraction of your defamatory statements, we insist on first reviewing your retractions to ensure that they completely remove the defamatory taint to Mr. Bellord's reputation.
We look forward to your timely try to undo the harm you have caused
V
King
Enclosure cc: client (w/encl)
D
V/innicki
Henry Jolicoeur - IT IS IMPORTANT TO KNOW THAT SIDDHA... ... [www.facebook.com]
Correlatively and in the alternative, you are liable to Mr. Bellord for invasion of his privacy by placing him before the public in a false light. To wit, your statements implicating Mr. Bellord in the killing of Mr. Shim falsely porlray Mr. Bellord as an irresponsible driver of a boat that killed Mr. Shim due to speeding in an area frequented by swimmers. Such allegations are highly offensive to a reasonable person and you had knowledge or acted either intentionally or in reckless disregard as to the falsity of the published matter and the false light in which it would place Mr. Bellord.
On behalf of Mr. Bellord, demand is hereby made upon you to immediately retract and correct any and all defamatory statements made by you accusing Mr. Bellord of being involved in the killing of Mr. Shim. You must publish a statement expressly withdrawing and expunging your defamatory statements on the same forum where the statements were originally made, including the Facebook page where you published the statement dated January 24,2016 and the Cult Education Institute site where you published the February 4,2016 statement. You must take any and all actions necessary to remove the statements from the Internet and to apologize publicly to Mr. Bellord for your wrongdoing. You must also compensate Mr. Bellord for the harm to his reputation, the emotional distress caused him by your conduct, and the expenses he has incurred in addressing your wrongdoing. Mr. Bellord rvill accept $25,000, in addition to the retraction and correction of the statements, in order to resolve his claims against you now before filing suit. If he is compelled to sue you, we will advise him to seek substantial punitive damages to set an example to deter future defamatory statements like yours.
Demand is made that you immediately comply with this letter on or before N{.ay 12 2016. If the demand expires without compliance, we will recommend that our client pursue legal action against you and any other parties responsible for Mr. Bellord's defamation. If you are willing to
publish a retraction of your defamatory statements, we insist on first reviewing your retractions to ensure that they completely remove the defamatory taint to Mr. Bellord's reputation.
We look forward to your timely try to undo the harm you have caused
V
King
Enclosure cc: client (w/encl)
D
V/innicki
Henry Jolicoeur - IT IS IMPORTANT TO KNOW THAT SIDDHA... ... [www.facebook.com]