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AYMAN A. DIFRAWI a/k/a ALEC DIFRAWI INTERNET SOLUTIONS CORPORATION, a Nevada corporation, Plaintiffs, vs. LES HENDERSON, DANIEL BRUCE SCALF a/k/a FRANK TORELLI, et al, Defendants. / JOINT TRIAL BRIEF OF DEFENDANTS HENDERSON AND SCALF CASE NO: 6:07-cv-1854-ORL-22KRS
Defendants Henderson and Scalf set forth in this trial brief a discussion of the evidence relevant to the claims asserted against them in this case by the Plaintiffs Ayman Difrawi and Internet Solutions Corporation along with certain legal issues with respect to those claims that they anticipate will arise at trial. Proposed findings of fact and conclusions of law are respectfully submitted herewith. Factual Background The Plaintiffs claim that the defendants made defamatory statements about them. The defendants are both authorities on issues of consumer fraud. Defendant Scalf has provided research material to Rip Off Report, one of the largest consumer feedback sites in the world, and is a forensic investigator.
a State Office of Consumer Affairs. Just a few of these include the National White Collar Crime Center. statute-barred and entirely without merit. The Tampa Bay Tribune. the Commodity Futures and Trading Commission. the Division of Aging and Seniors at Health Canada. over several years. the RCMP’s Nigerian Fraud Task Force. the San Antonio Texas Police Department. the Toronto Star. Petersburg Times.S. the Washington Post. USA Today. Smart Business magazine. the White Collar Crime Fighter. the Financial Times. attracted the international scrutiny of several mainstream media outlets that have Defendants’ Trial Brief 2 . the Nebraska Bankers Association and perhaps most applicably. Plaintiffs are high-profile public figures who have. the U. Defendants believe that the action is purely vexatious.Defendant Henderson operates a public awareness website and has written books dealing with the topic of consumer fraud. Plaintiff Difrawi is a twice-convicted criminal with a long history of running businesses that purport to offer employment opportunities to the general public when this is not the actual primary business model of his enterprises as listed in their promotional materials or corporate filings. securities officials. Conde Nast and the Pittsburgh Tribune Review. The Defendant’s site has been featured or referenced in newspaper articles on fraud around the world including the St. Over the past ten years Henderson has received glowing endorsements from consumer protection agencies. the Oklahoma Department of Securities. newspaper reporters. police forces and countless individuals from around the world. Administration on Aging. The Register (UK). the Christian Science Monitor. the Dallas County Sheriff's Department. if not decades.
Plaintiff ISC has even brought one of the cases which was heard by Judge Anne C. co-Plaintiff. or to profess his responsibility for its purported success. either to prevent discovery of his true ownership. Plaintiffs have initiated several related actions for defamation against other parties in other courts across the country and have openly debated this issue on public forums." Defendants’ Trial Brief 3 . He seems to switch on a whim. Defendants will show that any relevant statements regarding Alec Difrawi in “Under Investigation” and elsewhere were substantially true. Several such cases are running concurrent to this one. Plaintiff Difrawi alternately refers to himself as either a consultant or President and beneficial owner of the corporations he represents. Sullivan standard of "actual malice. Plaintiffs have failed to inform this court of such pendancy of related actions as well as deliberately failing to properly list related parties in their mandatory filings. thereby attracting even more public discussion of the entity. Case in point is his Internet Solutions Corporation. Conway to the televised Florida Supreme Court on March 3. In a perceived effort of silencing their critics. if not outright frauds. 2010.reported that the operations associated with Plaintiff Difrawi are primarily viewed as being designed to mislead the general public. and that both Difrawi and Internet Solutions Corporation are limited public figures and cannot satisfy the New York Times v.
2d 113. 2005 are barred by the statute of limitations.D. Fla. *3 (11 Cir. 60 F. Plaintiff’s claims based on statements allegedly made by the Defendants prior to November 21.A.2d 1294. Although Plaintiffs commenced their action on November 21. the plaintiffs had two years from the accrual of their causes of action in which to file suit. Erickson & Kupfer. v. Florida courts have held that a cause of action for defamation accrues on publication of the allegedly defamatory material. 629 So. and therefore are not actionable under the single publication rule. Under the statute of limitations. Plaintiff Difrawi seeks damages against the Defendants for activities which allegedly occurred at some date prior to 2004 and which he has been fully aware of since that time.Stat (2000) (“Actions Defendants’ Trial Brief 4 . Roth. 2001 WL 34395880. Johnson. Therefore. 1999). MOST OF PLAINTIFFS’ CLAIMS WILL QUICKLY FAIL DUE TO STATUTE OF LIMITATIONS RESTRICTIONS Chapter 95. See Molenda v. Dessasau v. Nugent. 2001) (not reported) (citing Wagner. P.11 4(g) of the Florida Statutes regarding the statute of limitations for torts related to libel and slander limits the period by which the plaintiffs may pursue a legal remedy to two years.11(4)(g). Any statements made on or after November 21. 2005 were simply repetitions of the earlier ones. Cook.Supp.1993))..CONCLUSIONS OF LAW I. The two-year limitation period begins running on the date the statements were made. 114-15 (Fla. 1302-03 (S.Fla. Flanagan. 2007. Romano. Hoechst Celanese Corp. not new publications. See § 95.
the time within which an action shall be begun under any statute of limitations runs from the time the cause of action accrues. . P. 1993). . Stat. 900 Defendants’ Trial Brief 5 . . “Aligning ourselves with other courts that have considered the question.” Wagner. (g) An action for libel or slander. each time another internet user accesses the defamatory statement. 2d at 115.E.07 applies “to all civil litigants.”).07 applies when defamatory matter is posted on the internet is. Supp. 465-66 (N. . Fla. Stat. . elsewhere in these statutes. 629 So. see also Lane v. shall be deemed to have accrued at the time of the first publication or exhibition or utterance thereof in this state. Flanagan. (2000) (“Except as provided .” § 770. even though the defamatory matter remains accessible and later “hits” actually occur. Erikson & Kupfer. (2000) (“The cause of action for damages founded upon a single publication or exhibition or utterance . (4) WITHIN TWO YEARS. . Strang Communications Co. Romano. 2d 113. See Firth v. The issue is whether posting on the internet is “a single publication.”). 2d 897. . .031. State.07. 775 N.A. so that any cause of action accrues on posting. Roth.07.” Wagner. – . Johnson. 629 So. Fla. Nugent. we reject appellants’ argument that a defamatory statement is republished. 2002) (holding “each ‘hit’ or viewing of the [defamatory item on the internet is not] a new publication that retriggers the statute of limitations.Y. however. . v. 297 F.. “A cause of action for defamation accrues on publication. See also § 770.2d 463.” and that the statute of limitations runs from the initial posting on the internet). § 95. 115 (Fla. . apparently a question of first impression in Florida. so that the limitations period begins anew. How section 770. both public and private.”). in defamation actions.other than for recovery of real property shall be commenced as follows: . Section 770.
v. Louis J. Traditional Cat Ass’n Inc.E.Y. Van Buskirk v. 24. .. “To hold otherwise and treat internet publications differently would result in the endless retriggering of the statute of limitations. at *1 (Mass.2d 856.D.Case #C8937/05) Defendants’ Trial Brief 6 . David Michael Karl et al Case No.” Abate v. the article w[as] posted online on the Defendant’s website”). 13 Cal. 2d 719. Davis. Canada for a series of defamatory postings he made and afterwards received a judgment against Difrawi and others. Miss. Cox Enters. 858 (Ga.. Super.(N. (Superior Court of Ontario . 26. 243 F. Ct. Rptr. Aug. 2003) (holding that where article was published in a magazine and then posted online on the defendant’s website. 593 S. 2000 WL 1206732. New York Times Co. 404 (Cal. 1D03-4651. App. Dr.N. 2003). Inc. 2005 Defendant Henderson was compelled to bring suit against Difrawi in Ontario. (48-2004-CA-4844-O. the date that . 724 (W.D. . Ct. Although a later hit may mean another person will see the defamatory material for the first time. McCandliss v. .” (Jack Rudloe et al v. Florida First District Court of Appeal) Difrawi even seeks to bring forward similar claims to that which have already appeared in a case dating from 2004 brought by his former business associate. 2004). Ky. at *1-2 (S. 2004 WL 293903. the “claims began to run at the latest on . 2004). . Supp. Gilbreath. 2000). App. 2004). an analogous situation obtains when a library patron checks out a book published years earlier. against the same Defendants. Jan. 3d 353. Pearlman. On June 27. 9th Judicial Circuit) During 2004 Difrawi established a series of websites whose sole purpose was to discredit the Defendants’ consumer advocacy efforts by defaming them. Maine Antique Digest. Mitan v.D..
1933. FAILURE TO PROVIDE NOTICE UNDER STATUTE 770. given this preponderance of interactivity between the Plaintiffs and the Defendants. This is something that the Plaintiffs failed to do with regards to either defendant. the plaintiff shall.In apparent retaliation for that litigation. PLAINTIFFS’ CLAIMS WILL FAIL AS REGARDS THOSE THAT ARE REPRESENTATIVE OF THE INTERESTS OF DEFUNCT NON-PARTIES Plaintiffs make numerous references to allegedly defamatory statements made by the Defendant Henderson and Scalf about various defunct modeling agencies such as Trans Continental Talent. Clearly. periodical. Accordingly. Difrawi was fully aware of the allegedly defamatory statements arising from 2003 that he wishes to revive at this time. or other medium.01 Florida Statute 770.01 requires that before any civil action is brought for publication or broadcast. those libel and slander allegations contained in Plaintiff’s complaint that are time-barred will fail. contrary to the application of any statutory limitations which should prevent him from doing so. at least 5 days before instituting such action. Difrawi initiated the current action for the sole purpose of harassing the Defendant Henderson and suppressing the factual criminal background and deceptive business practices of the Plaintiff from consumers. 16070. when they went bankrupt under the direction Defendants’ Trial Brief 7 . III. CGL 1936 Supp. of a libel or slander. yet not one of these entities have operated since 2003. specifying the article or broadcast and the statements therein which he or she alleges to be false and defamatory. serve notice in writing on the defendant. in a newspaper. Options Talent and Wilhelmina Scouting Network. II.
even orders of this court. Since these non-existent corporations could not possibly be listed as co-Plaintiffs at this time. if not impossible. V. Without some substantiation of the damages claimed. that the Plaintiff Difrawi has legal standing to represent their interests either now.of then owner Louis J. Pearlman. or at any time in the past. it is highly unlikely. IV. PLAINTIFFS’ CLAIM FAILS TO PROVIDE PARTICULARS OR EXHIBITS IN SUPPORT OF QUANTUM OF DAMAGES Despite repeated requests. Defendants’ Trial Brief 8 . Plaintiffs have also failed to specifically identify the statements they feel are defamatory in any exhibits they wish to present. assurances of compliance. including materials bearing on the nature and extent of injuries suffered as alleged. the Plaintiffs have failed to provide to the Defendants any evidence of a computation of damages claimed. nor did they sufficiently plead those they now claim to bring at trial. the action cannot stand. At no time did Difrawi have an ownership position in any of these limited liability corporations. PLAINTIFFS HAVE FAILED TO SUBSTANTIATE CLAIMS THAT CERTAIN STATEMENTS WERE MADE AT ALL The Plaintiffs have brought forward no evidence whatsoever to suggest that either Defendant have made any statements about the Plaintiff ISC at any time. or their proximate cause. beyond mere hearsay.
2d 454 (Fla. true or so substantially true as to negate any defamatory sting. Milkovich v. or occupation or charged that Plaintiff committed a crime. Lorain Journal Co. Ct. A statement is in some significant respect false if its substance or gist conveys a materially different meaning than the truth would have conveyed.. The Defendants shall prove that such a statement would invariably be based on truth and that the more persuasive force and effect of the entire evidence in the case does not support the claim of the Plaintiffs. reputation.S. 1.VI. 4th DCA 1990). Defendants will show the context in which any statement was made and rely upon the court to disregard any minor inaccuracies that do not affect the substance of the statement. in fact. Inc. 497 U. Plaintiffs have not yet shown that defendants’ statement concerning either Plaintiff was in some significant respect a false statement of fact* and tended to expose Plaintiff to hatred. or contempt or tended to injure Plaintiff in his business. 568 So. ANY PUBLICATIONS OF THE DEFENDANTS WERE NOT FALSE AND DEFAMATORY Although the Plaintiff ISC has produced no evidence or specifics to substantiate its claim in any way. There can be little doubt that anything anyone who has researched him might say about the Plaintiff Difrawi would be predominantly defamatory in nature. ridicule. Florida Medical Center. the Defendants rely upon being able to show that the defamatory statements of others regarding ISC are. New York Post Co. Defendants’ Trial Brief 9 . *In some instances a statement of opinion may be interpretable as a false statement of fact expressly stated or implied from an expression of opinion. v. 2695 (1990). 110 S..
396 N. Because "[t]he meaning of these statements is imprecise and open to speculation . 220. are mere hyperbole.E.S. 1002 (1979). 111 L. 110 S.2d 1 (1990). 229." Nat'l Ass'n of Gov't Employees. 2695. at 312.E. In Milkovich v. 2695. Lorain Journal Co. which are alleged to be defamatory. DEFENDANTS MADE NO ARTICULABLY FALSE STATEMENTS ABOUT THE PLAINTIFFS Defendants will show that any alleged statements make no "articulably false statement" about Difrawi or ISC and thus cannot support a defamation claim.Ct.2d at 1027. Falwell. 1. Corp. Broad." "loose" and "figurative" finds constitutional protection by this doctrine.2d 996. v. 99 Defendants’ Trial Brief 10 . 485 U.2d 6 (1970) (describing the statements at issue as "rhetorical hyperbole" and "a vigorous epithet"). . 6.S. though pejorative. 108 S.Ct. the Supreme Court clarified that First Amendment protection for speech that potentially harms the reputation of others takes shape essentially in two lines of cases.Ed. are "too vague to be cognizable as the subject of a defamation action.Ct.Ct. Speech properly categorized as "rhetorical hyperbole. See id.Ct. 497 U. 398 U." Id. 379 Mass.Ed.. Cent. 90 S.. 46. at 16. v. 435 N. 876. 1537. at 16-17. Bresler." Cole. The Supreme Judicial Court has recognized that certain statements about a plaintiff. [t]hey cannot 131 be proved false" and therefore "cannot be held libellous. 110 S. 2695 (citing Greenbelt Cooperative Publishing Assn. 26 L. Inc. 110 S. or two free speech doctrines. 386 Mass. One doctrine "recognize [s] constitutional limits on the type of speech which may be the subject of state defamation actions." "parody.VII.S. Hustler Magazine v. Defendants will also show that certain statements. .
at 50.Ct. 41 L.2d 41 (1988) (outlining constitutional protection of parody). 94 S. 94 S. PLAINTIFFS’ DEFAMATION CLAIMS RELATED TO SELF-ADMITTED TRUTHS Central to this action. 418 U.S. I." Id. 000 victims remains unpaid. 180 (Fla.Ed. Austin. the court should not waste its time with patently unsustainable claims. see also Art. 2d 170. 760 So. (Second Amended Complaint at 31. Plaintiff Difrawi has two major federal criminal convictions. at 20. 108 S. VIII. 485 U.Ct. 2770 (quoting Falwell. Such statements are immune from defamation actions. 264. 2770. This doctrine "provides protection for statements that cannot `reasonably be interpreted as stating actual facts' about an individual. Ramlawi. Letter Carriers v. 51) Since truth is arguably the ultimate defense. Plaintiff Difrawi brings forward claims for defamation regarding statements made in Henderson’s book regarding his extensive criminal history and encounters with law enforcement. Lipsig v. § 4. 3rd DCA 2000) . Const. convicted and incarcerated for fraud-related offenses related to non-existent job opportunity offers for which a restitution order in the amount of over $2 million for 13. While he seeks to sugarcoat or omit the finer details. 876) (alterations omitted). He was convicted in DC on a charge of conspiracy to commit mail.Ct.S.L.2d 745 (1974) (describing statements at issue as being used "in a loose figurative sense")).Ed. the Plaintiff himself admits this in the Second Amended Complaint at paragraph 102. Fla. There is simply no disputing the fact that Mr. Difrawi is a convicted criminal who was arrested. wire and bank fraud in violation of 18 Defendants’ Trial Brief 11 .
numerous companies under his control.C. In fact. LA Times) and on national television programs focusing on consumer protection dating back from the early 1990’s up to the present day. factual and uncontestable statements should fail due to judicial admission. 1995. direction or involvement have received negative media coverage in countless mainstream papers (Washington Post. cunning liar.S. Therefore. F. S. F. supposition that Henderson and Scalf have conspired to control the media is ludicrous. There can also be no disputing the fact that Mr. that case number is Criminal No. (Dateline. David Elliot. (Second Amended Complaint at 131. S. and the plea was entered on November 8.04 (1) Third Degree Felony. testified under oath that Difrawi had orchestrated several job scams in addition to a variety of other fraudulent acts meant to deceive the public. despite the plethora of negative mainstream media coverage. 371. Criminal Case 9114205.03 (1) (a) Second Degree Felony. His business partner at the time.) It should also be noted that not once in the past fifteen years. Hillsborough County 13th Judicial Circuit Court. Difrawi is a public figure with a reputation so besmirched by his own activities that his reputation is indefensible. 827.. job scammer. but factually non-existent. Difrawy has also been indicted and prosecuted for 1) Aggravated Child Abuse. WFTV Action 9) That the Plaintiffs seek to blame this negative coverage on the Defendants through some purported. 827. Prosecuted by Eric Holder Jr. 94-0162. and 2) Child Abuse. has either Plaintiff brought a civil action for Defendants’ Trial Brief 12 .U. any claims related to the suggestion that Difrawi is a convicted criminal. accused child abuser or other truthful.
but instead used that of first Three Stars Media and most recently The Internet Company. One need only look so far as the Plaintiffs’ in-house counsel’s email address to verify this supposition. X. This shall be only the latest name change made by a marketing consultant business operated by Mr. Plaintiff suggests on-going harm being caused when potential businesses or employees search for the name Internet Solutions Corporation but fails to state that all recruitment efforts no longer use the name of the defunct corporation. STATEMENTS A FAIR REPORT OF MATTERS OF PUBLIC RECORD Damages shall not be awarded in a libel action for the publication or broadcast of a fair and true report of matters of public record. ANY DAMAGES MITIGATED BY ACTIONS OF OTHERS OR THE PLAINTIFFS THEMSELVES The Plaintiffs assert that the generalized warnings posted by the Defendant are solely responsible for unproven. none of which claim any affiliation to each other. Difrawi in the past four years. choosing instead to stifle free speech through a continuous stream of vexatious litigation against numerous individuals from around the world who lack the financial resources of Difrawi or his operating entity of the moment.Nicholson@internet-company. (Myra. in this case The Internet Company. unquantified damages. formerly Three Stars Media. formerly Internet Solutions Corporation.com) IX.defamation against any media outlet or the Better Business Bureau. yet consistently fail to acknowledge their simultaneous nationwide litigation against numerous other defendants for the very same claims and purported damages. operating out of the same address Defendants’ Trial Brief 13 .
On the second count. Plaintiffs arguments fail if the court determines that they "invited attention and comment" through either their position or conduct. XI. Plaintiff ISC has established numerous “the truth about” websites designed solely for the purpose of airing their side of the public controversy surrounding their interaction with hundreds of thousands of job applicants. When a discardable corporation has a purposely-limited lifespan. not including the roughly four thousand variants of his affiliated websites or the multitude of fictitious and unregistered entities purporting to be actual corporations but lacking registration or official status. In determining whether an individual is a public figure. its ownership diminishes the value of its reputation far more than any outside influence ever could. Plaintiffs openly advertise themselves as representing Fortune 500 companies and as being a leader in their industry. DEFENDANTS WILL SHOW THAT THE PLAINTIFFS ARE LIMITED PURPOSE PUBLIC FIGURES First of all.with the same staff. Defendants’ Trial Brief 14 . since a claim for defamation per se is unavailable to limited public figures the first count of the complaint shall fail. the court should examine the nature and extent of the individual's participation in the particular controversy giving rise to the defamation. once this is proven. One of its fictitious business names is actually the Consumer Business Bureau. neither defendant Henderson nor defendant Scalf are liable for defamation because: (1) the plaintiffs are public figures as a matter of law and (2) the plaintiffs cannot show by clear and convincing evidence that either defendant acted with actual malice when any allegedly defamatory statements were made.
but that overwhelming evidence suggests that they are almost irrefutably true. Anyone. Inc. Defendants’ Trial Brief 15 . would reasonably have concern about this company’s activities after reading the deluge of negative mainstream media reports or assessing the volume of posted concerns on a multitude of online forums unrelated to the Defendant Henderson’s website.Plaintiff Difrawi has promoted his virtues online as both a congressional candidate and a strong supporter of free speech on the Internet. but for the Plaintiffs and loyal staff. or so close to being accurate. Not only will the Defendants produce evidence of local newscasts in Orlando which question the activities of the Plaintiff in the public eye. Defendants’ free-right commentaries on the activities of the Plaintiffs were a matter of national public interest which elevated the Plaintiffs to public figure status long ago. the issue is not so much that the alleged defamatory statements might be improbable. As regards the issue of malice one often refers to “when the publisher’s allegations are so inherently improbable that only a reckless man would have put them in circulation…” Here. going so far as to create a charitable non-profit Florida corporation by the name of Internet Decency Foundation. that no actionable harm could arise from making them. but also several examples of national news coverage from esteemed media outlets suggesting that the Plaintiffs are running a dubious and questionable operation which affects job-seekers nationwide and generates widespread public interest.
Defendants’ Trial Brief 16 . moral. and in discharge of a public or private duty. In the case at hand you have a well-known authority on consumer fraud writing a carefully researched book that mentions the plaintiff Difrawi. XII. A conditional privilege may be recognized only where the statement is made in good faith. responsible investigation to negate the existence of gross irresponsibility or malice as a matter of law. Such persons are not liable without proof of “express malice”. DEFENDANTS HAD A QUALIFIED PRIVILEGE TO MAKE STATEMENT Even if the statements can be shown to be false. apart from the question or its abuse. or social duty in regard to a certain subject. the Defendants had a qualified privilege to make a false defamatory statement since they had reason to speak about either Plaintiff to an appropriate audience on a particular subject or occasion. and in an honest belief in the truth of the statement. Privilege exists where "circumstances are such as to lead any one of several persons having a common interest in a particular subject matter correctly or reasonably to believe that facts exist which another sharing such common interest is entitled to know.” Whether there was a privilege.Defendants rely on a thorough. when speaking to another “having a corresponding interest or duty. a convicted criminal with a history of consumer fraud offences. The qualified privilege is granted to one having an interest or a legal. may be determined by the court if the evidence is undisputed. without malice.
or that he had serious doubts then as to its truth. about the matter in issue. 1440 (9th Cir.3d 1430.3d at 1129. any stage of judicial proceedings. This principle "assumes.1995) ("Where a publication sets forth the facts Defendants’ Trial Brief 17 . Defendants’ alleged defamatory statements regarding Difrawi’s criminal charges are also privileged for those that reflect statements made in the course of. 55 F. thus making it clear that the challenged statements represent his own interpretation of those facts and leaving the reader free to draw his own conclusions. Any statements made outside the book were made in furtherance of protecting the general public from being victimized by the suspicious activities of the Plaintiff in his business dealings with consumers." Partington. without hesitation. If anyone can be shown to be malicious it is the Plaintiffs themselves.3d at 1157.You also have a forensic investigator providing research to a large consumer protection website. Yagman. Standing Committee v. that the factual basis itself is true. 310 F. explicit. Not only is there no evidence that is precise. NEITHER DEFENDANT CAN BE SHOWN TO HAVE ACTED WITH MALICE There is no clear and convincing evidence which shows that either defendant knew when any purportedly defamatory statement was made that it was false. lacking in confusion. XIII. When an author outlines the facts available to him. and of such weight that it produces a firm belief or conviction. or pertinent to. but there appears to be no evidence whatsoever. 56 F." Flowers. however. those statements are generally protected by the First Amendment.
Coming to the logical conclusion that the historical activities of the Plaintiff make him a despicable character does not make one malicious.Rptr. 145 F.3d at 438.underlying its statement of opinion and those facts are true. merely observant. It is a 512-page book that documents the research involved in its preparation through a listing of footnotes over forty pages long. Franklin. Respectfully submitted this 6th day of March 2010." (internal quotations and alterations omitted)). Dodds. 10 Cal.3d at 1067 (noting that opinions based on disclosed facts are not actionable "where the underlying facts are not actionable because they are nondefamatory" and "where [the underlying facts] are not actionable because there is an absence of actual malice"). Henderson’s book is not a pamphlet prepared on the spur of the moment. ____________________________________ Les Henderson ____________________________________ Daniel Bruce Scalf Defendants’ Trial Brief 18 . the Constitution protects that opinion from liability for defamation.
CERTIFICATE OF SERVICE An unsigned copy of this trial brief was submitted in WordPerfect compatible format to the Judge’s chambers via email this date. 2010. the foregoing has been mailed to the clerk of the Court for filing and uploading to the CM/ECF system which will send a notice of electronic filing to Myra Nicholson at myra@mnicholson-law. FL 32835 ______________________________________ Les Henderson 2072 Fire Route O Azilda. Orlando.com . I further certify that I mailed the foregoing document by first-class mail to Myra Nicholson 1743 Park Center Drive. Dove Wing Way Peoria. AZ 85383 Fax: 623-399-4030 Self-Represented Defendants Defendants’ Trial Brief 19 .com ________________________________ Daniel Bruce Scalf 12125 W. Ontario. Canada P0M 1B0 Tel: 705-983-9060 Fax: 866-801-1150 info@crimes-of-persuasion. I HEREBY CERTIFY that on this 8th day of March.
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