Fogler, RubinofF LLP. Barristers & Solitons ‘99 Wellington Stet West Fogler, “ct | Rubinoff Te 164649100 Fn st 082 LLP wr foglerscom Reply To: Michael Donsky Direct Dial: (416) 942-8849 Toll Free: (866) 861-9700 July 14, 2020 E-mail: MDonsky@Foglers.com OurFileNo. 20/4395 VIA PERSONAL SERVICE AND VIA EMAIL AT HITELEVEN.BLOGGER@GMAIL.COM Matthew Wells 323 Lonsdale Rd Toronto, ON MgV 2X3 Dear Mr. Wells Re: __ Your Blog on http://battlelight. blogspot.com/ under the Name “HitEleven" We have been retained by Merger Law Associates Limited ("MLAL") and Julius Csurgo in relation to various entries you have made on your blog that are false, defamatory, or both. Accordingly, we are providing you with this notice pursuant to Section 5(a) of the Libel and Slander Act R.S.0. 1990, Ch. L.22 (the "Act”) We are advised that you are the individual with ownership and control of the web log operating at httpy/battlelight. blogspot.com/. As such, we are directing this notice to you. This is a preliminary notice. Both we and our clients reserve the right to serve you with a further notice under s. 5(a) of the Act. That said, we fully intend to rely upon this notice whether as subsequent notice is delivered or not. In accordance with s. 5(2) of the Act, we hereby notify you that our clients take issue with the following statements made on the Blog and claim they are libelous of our clients, 2. On June a4, 2020, you wrote on the Blog that , "Mr. Csurgo and Mr. Shea ... and their firm, Merger Law Associates Ltd, have been implicated in a number of seeming “boiler room’: type stock scams, and are so untrustworthy that the UK Financial Service Authority has issued a warning about them.” In fact, neither of our clients ~ neither Mr. Csurgo nor MLAL ~ has ever been involved in any boiler room-type stock scam. The allegation that they have been, as in the Blog, is false and defamatory. Further, we are not aware of any UK Financial Service Authority warning about Mr. Csurgo.Fogler | Rubino? Page 2 of 4 am" 2. On lune 26, 2010, you stated in your Blog that "Merger Law Associates Ltd" is an international firm with Toronto roots has engaged in what looks to be widespread stock fraud, promoting several (possibly shoddy) companies via various telemarketing scams. " In fact, MLAL has never been engaged in ‘widespread market fraud” or other market fraud. Nor has MLAL ever promoted companies, shoddy or otherwise, through “telemarketing scams". To suggest otherwise, as does the Blog, is false and defamatory. 3. On June 26, 2010, while discussing Julius Csurgo, Preston Shea and MLAL's alleged interest in Equity Capital, the Blog states that: “Mr. Csurgo and Mr. Shea own almost exactly 33% of the company. And this is a firm that they are shilling via telemarketing fraud." [Emphasis added] Jn fact, neither of our clients, Mr. Csurgo nor MLAL, have "shilled” any company or firm “via telemarketing fraud" or any other fraud. The statement is blatantly defamatory. 4. On June 20, 2010, the Blog refers to MLAL as being "at the epicenter of this scam" referring to what is termed a “telephone solicitation scam" and referring to firms “doing the calling and firms that are being pedaled by the sellers" The impression given that MLAL is somehow involved in a "scam", either involving telephone solicitation or otherwise, isa false impression and defamatory. 5. On June 22, 2020, the Blog refers to "Uranium 308 and the Vita Sweet/Afterwire" as “part of the same stock scam, being perpetrated by the same groups.” Then, the Blog refers to the "The evidence [as being] all there." That evidence is expressly stated to include "the links to Julius Csurgo" as if any "link" to Mr. Csurgo was evidence of a "stock scam". The impression given that Mr. Csurgo's very linkage to a project is evidence of a scam is demonstrably untrue and blatantly defamatory 6. On June 22, 2030, the Blog refers to Mr. Csurgo as making "an amazing return on his investment" and possessing “tens of millions of pounds of share capital in Corporate Bourse”. It then complains of the "the sheer jump in value here [as being] remarkable.” The Blog then immediately refers to there being “more that you can do with one of these companies than just enjoy the lofty jump in share capital" and suggesting that “there are plenty of other innocent folks you can lure into further traps." The clear impression given is that Mr. Csurgo “lures” innocent folks into "traps". This is a false impression and blatantly defamatory.Page 3 of 4 7. On June 22, 2020, the Blog refers to Mr. Csurgo as being one of the “big fish in this scam" The clear impression given is that Mr. Csurgo is not only a scam artist but one of the persons directing some alleged scam. Both of these allegations are false and blatantly defamatory. 8. On June 23, 2020, the Blog alleges that "Mr. Csurgo or one of his associates" had been trying to intimidate the writer of the blog. The impression that Mr. Csurgo "or one of his associates" is trying to intimidate the writer of the blog is false and defamatory. Rather, Mr. Csurgo, is pursuing his response through the court system and this very letter is in furtherance of that aim. To the extent the writer of the blog considers this to be "intimidation" it can only be as a result of the writer's knowledge of his false and defamatory statements about Mr. Csurgo and MLAL. 9. On June 27, 2020, the Blog references MLAL being “implicated in the illegal selling of shares of various other U.K.-based companies" This isa false statement and defamatory of MLAL. a0. On June 27, 2020, the Blog also states tat MLAL "was (and perhaps still is) making incredible sums of money off of the companies that they are promoting through their illegal business activity in the U.K." This is a false statement and defamatory of MLAL. MLAL is not engaged in any “illegal business activity" in the UK or otherwise Each of the said statements, separately and collectively, expressly and by way of innuendo, are false and defamatory statements in that 2. They suggest that Mr. Csurgo andjor MLAL are dishonest; 2. They suggest that Mr. Csurgo and/or MLAL are untrustworthy; 3. They suggest that Mr. Csurgo and/or MLAL are engaged in criminal andjorillegal activity; 4. They suggest that Mr. Csurgo and/or MLAL are willing to act unethically to further their ‘own agendas and to do so at the expense of others. Both Mr. Csurgo and MLAL are incurring and have incurred damages as a result of the aforementioned false and defamatory statements, Regarding Mr. Csurgo, these damages include damages to his feelings and reputation. Because a reputation of integrity and honesty is essential to his success in his field, he is suffering damages to both his existing and prospective client base Damages to MLAL, owing to the effect on MLAL's reputation, are complementary and additional to those suffered by Mr. Csurgo.| Hogler saa" Please make arrangements immediately to publicly retract all statement on the blog regarding Mr. Csurgo and MLAL and apologize to them on the Blog. As well, we direct you to remove all references to.either party in your blog other than the retraction and/or apology. We reserve the right to commence litigation against you regardless of any apology or retraction, but assure you that in the absence of an apology or retraction, the damages claimed will be significantly higher. Please govern yourself accordingly. Please direct your response, if any, to the writer's attention, Yours truly, FOGLER, RUBINOFF LLP Michael Donsky/*” MDipk ce. client dons WpData\surge,Julus|Batleight 204295\CorespondenceiDraftsLeter to Batllight doc ‘nylo10 33000