LEVENTHAL, MULLANEY & BLINKOFF, LLP

ATTORNEYS AT LAW
15 REMSEN AVENUE
ROSLYN, NEW YORK 11576
TELEPHONE: (516) 484-5440

STEVEN G. LEVENTHAL MARTHA V. SMITH, RA

THOMAS J. MULLANEY CRISTINA GONCALVES, PA
JEFFREY L. BLINKOFF

October 10, 2023

Mr. Jeffrey Smith

140 Keyes Ave
Watertown NY 13601

Ms. Sarah Compo Pierce

283 Thompson Blvd
Watertown NY 13601

Re: NOTICE TO CEASE AND DESIST

Dear Mr. Smith and Ms. Compo Pierce:

You both have falsely, maliciously and publicly accused Mr. Simao of the crime of
bribery. As you know or should know, Penal Law Section 200.03 provides that:

A person is guilty of bribery in the third degree when he confers, or offers or agrees to
confer, any benefit upon a public servant upon an agreement or understanding that such
public servant's vote, opinion, judgment, action, decision or exercise of discretion as a
public servant will thereby be influenced.
Mr. Simao offered to contribute to a charity of your choice solely in exchange for
information identifying the person or persons responsible for the eponymous City of Watertown
Meme Page. In making the offer, Mr. Simao did not seek to influence any official action.
On May 22, 2023, Mr. Smith responded to an email message in which Mr. Simao
expressed concern about the Meme Page. Mr. Smith stated unequivocally that: “… this [the
Meme Page] has nothing to do with City of Watertown.” Ms. Compo Pierce was a recipient of
Mr. Smith’s email message and knew, as Mr. Smith did, that Mr. Simao’s offer of a charitable
contribution was not made to induce any official action by either of you nor by the City of
Watertown. Yet you both continued, at public meetings and in press releases, interviews and
email messages, to maliciously defame Mr. Simao.
Smith and Compo Pierce -2- October 10, 2023

It is well settled that a false claim of criminal misconduct is per say libelous. You both
stand personally responsible for the well documented, malicious and defamatory statements that
you widely disseminated.
You are hereby placed on notice to cease and desist in these tortious actions and to
preserve all related records and other evidence, including but not limited to email
correspondence, text messages, Facebook pages and other statements posted to social media.
Please provide a copy this letter to your insurance carriers and your personal attorneys.

Very truly yours,

Steven G. Leventhal

Via email:
Mr. Jeffrey Smith: mayorjeffsmith@gmail.com
Ms. Sarah Compo Pierce: Sarahvcompo@gmail.com
and via U.S.P.O. Express Mail Overnight