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Edward B. Friedman Response #3 to Ronald J. Riley

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  ----- Original Message -----
From: "Lisa Reckner Miller" <>
To: "'Ronald J Riley'" <>
Sent: Tuesday, October 03, 2000 3:51 PM
Subject: RE: Riley defamations

Dear Mr. Riley:

I am available tomorrow at 10:30 a.m. or 11:30 a.m. to speak with you
and Mr. Levy, who based on our previous conversations, I understood to
be your legal counsel in this matter.  As it appears that Mr. Levy is
familiar with defamation law, to the extent that you have provided Mr.
Levy copies of all of the content that you have published on and related web pages together with my letter of
September 20, 2000
, he should be aware of the basis for our claim.
Simply stated you have published unprivileged defamatory statements
and/or innuendo which have caused and continue to cause harm to the
reputations of this law firm and myself.  You are on notice that the
statements and innuendo are false and demand has been made upon you to
cease and desist.  Again, I insist that you immediately remove all
references to Edward B. Friedman, Friedman and Friedman and the
defamatory statements and innuendo relating to the Neustel litigation
from your web site.  If these references on your web site are not
removed, I will have no choice but to seek my own legal remedies.

I do not wish to engage in further correspondence with you on this
issue, as doing so only leads to your attempt at self-justification
while the defamation continues.  You have repeatedly claimed to be a
journalist, which I do not believe to be true.  You claim to only be
reporting on public records, which even after the most cursory review of
your web pages is clearly shown to be untrue.  Furthermore, even if you
were able to support your assertion that you are a journalist reporting
on public records, this does not vest you with the right to defame
Friedman and Friedman and Edward B. Friedman.

In addition, you also continue to misstate the substance of our prior
conversations.  We have not reached a compromise on any issue, and I
continue to insist that all statements relating to Friedman and Friedman
and Edward B. Friedman, and all innuendo relating to Friedman and
Friedman and Edward B. Friedman, including the references to the Neustel
litigation, be removed from your website. 

In a final attempt to resolve this matter I have agreed to discuss this
matter with you and Mr. Levy.  I have not had a change of heart, as you
suggest.  On the contrary, as I informed you in our first conversation I
have been willing to give you a reasonable period of time to remove the
defamations.  This period has long since passed and the defamation
continues to be published and continues to cause harm.  You leave me
with few choices.  Please let me know at what time tomorrow you want to
have the discussion with Mr. Levy.

Very truly yours,
Edward B. Friedman

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