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20 Madison Avenue Now York, NY 10016 J 212. 867. 4466 BBWG Belkin Burden Wenig & Goldman, LLP x 212, 297. 1859 = Ag ATTORNEYS A T LAW 495 Post Rond East : Wessport, CT 06880 Tel 203.227.1534 Fre 203, 727.6044 CEASE & DESIST DEMAND February 16, 2016 BY FEDERAL EXPRESS AND EMAIL ‘Ted Cruz Cruz for President 24 Greenway Plaza, Suite 725 Houston, TX 77046 Chad C. Sweet Chairman, Cruz for President c/o The Chertoff Group 1399 New York Avenue, NW, Suite 900 Washington, DC 20005 Jeff Roe Campaign Manager, Cruz for President clo Axiom Strategies 1251 NW Briarcliff Pkwy, Suite 85 Kansas City, MO 64116 Re: Your Defamatory Attack Ad Dear Sit 1am counsel to Donald J. Trump for President, Inc. We recently had the opportunity to view your television commercial entitled “Supreme Trust” together with your accompanying statements in the media concerning my client's views (collectively, your “Attack Ad”) and, quite frankly, are dismayed by the depths the Cruz for President campaign will go to in an attempt to materially mislead the public. Simply stated, your Attack Ad is not only completely disingenuous, but replete with outright lies, false, defamatory and destructive statements and downright fabrications which you fully know to be untrue, thereby exposing you and the Cruz for President campaign to liability for damages and other tortious harm. For example, while your Attack Ad blatantly misrepresents to the public that Mr. Trump is “pro-choice”, nothing could be further from the truth. Belkin Burden Wenig & Goldman, LLP February 16, 2016 Page 2 Not surprisingly, a closer look at your Attack Ad reveals that the entire basis for your argument that Mr. Trump is “pro-choice” is based on an interview from Meet the Press that took place nearly two decades ago. That’s it. While a reputable organization would have at least had the deceney to use current information to suppor its vitriolic attack ad, you conveniently chose to leave out Mr. Trump's repeated “pro-life” position in a deliberate attempt to mislead the public into believing that it is reflective of Mr. Trump's current position — when, unquestionably, itis not. In other words, you lied. Mr. Trump is not “pro-choice”. This is the very definition of libel. Rest assured, however, we will not sit idly by and allow you or the Cruz Campaign to defame Mr. Trump by intentionally disseminating libelous statements you fully know to be untrue and, even worse, continue to purposely mislead the American people, Toward that end, unless we receive your prompt written assurances that you have stopped running the Attack Ad, ‘we will seek immediate legal action to prevent the continued broadcast of the Attack Ad and hold you jointly and severally liable to the fullest extent of the law for any damages resulting therefrom ... and will look forward to doing it. Please be guided accordingly. Very truly yours, Jeffrey L. Goldman