ALBERT G. MARQUIS
PRLS AUREACH
‘ALL a Levy
AVECEM HIGREE
TERRY A COFFING
JAY FOUN.
Scorra MARQUIS
TACK CHEN TEIN JAA
FRANK ML FLANSBURG I
MARY DRURY
CRAIG ANDERSON
DAVIDA COLVIN
TERRY A MOORE
GERALDINE BARRETTO.KO
MARQUIS &/AURBACH
ATTORNEYS AT LAW
rect ine (792 207.6098
‘lec fx (70) 886-3008
ema haraye@arquleautbach com
Micaes ECHOLS
NICHOLAS b_cROSBY
‘SHANE W. CLAYTON
MATIMEWT. CeCIL
SCOTTA KNIGHT
JASON M, GERBER
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BRAN HARDY
(AYRE m STOLBERG
SALLY U GALA
RAG F ROBINSON
SOSHUA D CORRELL
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Contd. MOORE
ERIN: GARNETT
TYE HANSEN
JOSHUA BENSON
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‘CANDICE € RENKA
sonar Sacco
‘OF COUNSEL
ENDELEE LEASCHER WORKS
April 30, 2010
‘Via Certified Mail and USPS Electronic Postmark to
‘TroyDooly@MLMHelpDesk.com
‘Troy Dooly
P.O. Box 6101
Miramar Beach, Florida 32550
Re: Notice to Cease and Desist Intemet Defamation on www.mlmhelpdesk.com
Our File No. 11429-2
Dear Mr. Dooly:
Please be advised that our firm has been retained by Globalverge, Inc. (“Global Verge”)
to investigate and take legal action against you for the series of unwarranted and defamatory
attacks against it made by you and your visitors on your website www.mlmhelpdesk.com.
Global Verge has created an exciting new dimension in business through an exclusive
business model which allows it to provide products and services at wholesale to its e-associates
while also allowing the e-associates to sell the same products and services at retail. In fact,
Global Verge offers products and services individuals use every day in many areas of their lives
such as security, power, travel, water and communication. ‘The bottom line is that Global Verge
offers a one of a kind business model that allows individuals to financially succeed. Global
Verge has worked 10 establish a reputation for the quality of its services and customer
satisfaction and your unwarranted actions and baseless accusations have damaged that reputation
and adversely affected our client's business.
You have posted many false and misleading comments about our client. Such statements
made in reference to Global Verge and its officers are utterly false and without merit, and may
constitute business disparagement and defamation per se. Additionally, you appear to actively
10001 Park Run Drive « Las Vegas, Nevada 89145 + Phone: 702.382.0711 + Fax: 702.382.5816 + www.marquisaurbach.com‘Troy Dooly
April 30, 2010
Page 2
encourage and solicit defamatory statements about Global Verge and its officers from the
customers on your website. Such conduct may subject you to civil liability to Global Verge and
its officers. However, you state on your website:
‘As always, we welcome Global Verge to respond with proper documentation
‘And if they have a different side to the story, I will give my word to publish it.
We want to encourage vigorous debate on this website and if I'm in the wrong, 1
will be the first to admit it, Currently, I have no reason to believe otherwise than
what I’ve already written about Global Verge and until I'm given new
information, | will not acquiesce to threats of a legal action.
While your attempts to spread libelous and defamatory material about our client have
caused setious and irreparable injury to it, its reputation, and its business, our client and this law
firm are zealous advocates for legitimate free speech, and we believe that the Internet is an
important medium for dissemination of accurate and truthful information and for fair comment
on issues of interest, Thus, rather than spend money pursuing an action against you for
defamation, my client would rather test the veracity of your proclamation that if there is “a
different side to the story. 1 will give my word to publish it .. . and if I'm in the wrong, I will be
the first to admit it.” Below are the real stories on Activation King Wireless (“AK W”), Chris
Greco (“Greco”), Zer1 Communications, Inc, (*Zer01") and Benjamin K. Piilani (“Pilani”)
‘Also, addressed below are responses to your continuing accusations and placement of Global
Verge on your “MLM Scam Alert List”,
ACTIVATION KING WIRELESS AND CHRIS GRECO.
On January 21, 2010 you posted statements under the heading “Global Verge Shut Off
By Their Wireless Provider Activation King Wireless Because Of Money Owed.” This
statement is wholly false. First and foremost, Global Verge never used AKW as its wireless
provider, As set forth in the attached agreement, Global Verge contracted with, what it believed
to be, All Wireless Services, Ine,’ Rather, Global Verge has since learned that Greco set up a
fraudulent bank account under the name All Wireless Services, Inc. Through this account Greco
stole thousands of dollars from Global Verge. When this was discovered Greco was confronted
and, rather than return the ill-gotten funds, submitted to you and others allegations of a lawsuit
filed by AKW (the fictitious firm name utilized by Greco’s South Carolina based corporation
The Unlimited Wizard Cellular, Inc.).? A closer look at the Civil Cover Sheet proffered by
Greco and others as evidence of such a suit finds that Greco pulled a form civil cover sheet
available to the public from the United States District Court for the Southern District of New
* See Exhibit 1, attached hereto.
? See Exhibit 2, attached hereto.Troy Dooly
April 30, 2010
Page 3
York’s website and filled it in with false information.’ Of note, Greco identified the attorney of
record for AKW as “Max Weinberg” of the law firm of “Weinberg Kohler and (sic) associates”.
AA simple search of licensed attomeys in New York show that there is no Max Weinberg nor the
law firm of Weinberg Kobler and Associates.’ Further, search of the United States District Court
records shows that neither AW, Unlimited Wizard Cellular, Ine, or Global Verge are a party to
any current federal litigation.>
In a comment you posted in response to aforementioned story on January 24, 2010 at
6:38 pm you stated “I just can't fathom anyone in their right mind would publish what Chris has
published if it was not true. that would truly take this saga to a whole new level.” Welcome to
the new level, However, this should not be a surprise to you given your recent “MLM Breaking
Wireless News” report that Greco was caught defrauding MLM wireless distributors.
As you are well aware, when reporting you should check always your sources. It is sad
how often you cited to Greco as a reliable source. Now, you can understand how anyone, even
you, can be duped by scammers within the MLM Wireless arena.
ZERO1 AND PLAN:
With respect to your continuing commentary on the Zer01 and Piilani issues, enclosed is
a copy of a Motion for Summary Judgment filed by my office on April 16, 2010. This Motion
is supported by exhibits which evidence the real facts related to the incident with Zer01
Communications, Inc. (“Zero01”) and Benjamin K. Piilani (“Pilani”). We encourage you to
read the Motion and review the exhibits attached thereto. We are confident that you will see a
chain of events strikingly different that those you have proffered to your readers.
For example, you will see that many individuals and companies were enamored with the
prospect of Zerol’s claims including LAPTOP Magazine which awarded Zero! Best Overall
Product in its Best of CTIA Wireless 2009. Rather than gawk at the new technology Global
‘Verge moved into action to procure for its members the newest technology offered by Zer01 and
Piilani. If this technology had worked and made it to market Global Verge and its members
would have been hailed as innovators. Unfortunately, despite their promises and awards, Zerol
and Piilani failed to actually create a viable product. Thus, the innovator became the ridiculed,
2¢ Exhibit 3, attached hereto, A civil cover sheet form can be obtained at
hatp:/www znysd.uscourts govicases’show.php?db=forms&
* See Exhibit 4 attached hereto
* See Exhibit 5, attached hereto,
® See Exhibit 6, atached hereto.