Our client “Loro Parque Corporation” has given us instructions to pursue judicial actions against you, as a consequence of the

report, elaborated and signed by you as the author titled “Report in the Physical and Behavioural Status of Morgan, the Wild-Born Orca held in captivity at Loro Parque, Tenerife Spain, which is going to be used in the judicial process under way through the Dutch authorities, related to the permissions of the orca identified as “Morgan”. En said report or study, which has been elaborated without the knowledge and no consent of my client, the mercantile entity “Loro Parque S.A.”, a series of assertions and opinions, which are absolutely false, due to lack of veracity, pretending to tergiversate reality, with the clear intention of causing a damage to the reputation of Zoological Park Loro Parque , and in particular, to the work that is has been doing for several years with the group of orcas in their facilities. The utilization and manipulation which is done in the mentioned report, against my client, only seek or has as objective, to cause the most damage possible to its public image and reputation of Loro Parque, this can be confirmed by the divulgation of the document through the wb, with the author’s consent, and as such can be found in the site http://timzimmermann.com/, in which the said document is reproduced in its integrity. It is clear that your intervention as author of the report, constitutes the beginning of a programmed campaign against my client, by several groups or organizations, that take it as element of proof or justification for their conduct,. The mentioned report, is no doubt full of fallacies, writing it with the knowledge that it would be circulated through the web, and in that way having a lie and a fallacy, by increasing its divulgation achieve or reach the level of an opinion against my client’s facilities. You will understand that the entity “LORO PARQUE S.A.” cannot and will not consent that you, backed up in as assumptions of knowledge, sustain, promulgate and subscribe a report, filled with fallacies, with the evident intention of causing damage to my client, so we request, that you immediately, in a 48 hour term, proceed to withdraw the report, retracting of all its contents, utilizing for this the same means of divulgation, manifesting the falseness of it, and your error in assuming its authorship, or else we will initiate the appropriate judicial actions, so that the competent legal authorities, adopt the necessary and opportune measures, to repair the damaged you’ve cause and the one that might have been caused by a campaign in the media, caused by said document. Among other aspect, some of the false statements in the document, in brief, are: 1. That Loro Parque maintains the most dysfunctional and aggressive group of orca of all of the ones that are under human care 2. That the Loro Parque staff lacks the experience and adequate knowledge to maintain orca in captivity 3. That Loro Parque lies in a blatant way when it affirms that Morgan has integrated with the group of orca and is hiding information 4. That Loro Parque is not incompliance with European law and the CITES rules by using Morgan in public presentations Affirming all of this is totally inadmissible and that is why we cannot consent or allow, the use of reputation damaging campaigns, to burden mi client, which, in its

assuredness, of having always acted and collaborated with the authorities to achieve the best conditions for Morgan. Take this document as a requirement for you to rectify and withdraw your report as per the exposed terms.

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