THE MUSCOVITCH LAW FIRM

Via Email: nik@nikrichie.com, legal@thedirty.com, thedirty.com@domainsbyproxy.com May 4, 2012
Hooman Karamian aka Corbin Grimes aka Nik Richie dba “Dirtyworld.com” 3200 North Central Avenue, Suite 2000 Phoenix, AZ 85012 14442 N 100th Way Scottsdale, AZ 85260 DIRTY WORLD, LLC dba THEDIRTY.COM and/or THEDIRTYARMY.COM 3411 Silverside Road Rodney Building #104 Wilmington, DE 19810 DIRTY, INC. P.O. Box141 Phoenix, AZ 85001-0141 THE DIRTY, LLC 3002 N. Arizona Aevnue, Suite 9 Chandler, AZ 85225 Hooman Kaeamain aka Corbin Grimes aka Nik Richie DIRTY WORLD ENTERTAINMENT, LLC 4453 E Pleasant Run Scottsdale, AZ 85258 DIRTY SCOTTSDALE, LLC 14362 N. Frank Lloyd Wright Blvd., Suite 1000 Scottsdale, AZ 85260 DIRTY ENTERTAINMENT, LLC c/o William J. Bastian, II 6526 E. Kings Avenue Scottsdale, AZ 85254

Dear Mr. Richie:

RE:

JADE ALEXANDER v. Hooman Karamian et al.

We are the solicitors for Ms. Jade Alexander.

446 Eglinton Avenue West, Toronto, Ontario Canada M5N 1A5 zak@muscovitch.com

Telephone (416) 9245084 Fax (416) 9206306 www.muscovitch.com

ZAK MUSCOVITCH, BARRISTER & SOLICTOR cont‟d 2

This letter constitutes Notice of Libel pursuant to the Libel and Slander Act of Ontario regarding the publication of devastingly defamatory material located on the website, TheDirty.com (the “Website”), which you own and/or operate, and which is specifically located at the following Internet URL‟s: 1. http://thedirty.com/2011/10/princess-jade/ (“Princess Jade”, dated October 14, 2011); and 2. http://thedirty.com/2011/10/ottawas-number-one-sloot/ (“Ottawa‟s Number 1 Sloot”, dated October 19, 2011); (“collectively referred to herein as the “Defamatory Content”). The Defamatory Content is defamatory in its entirety, including but not limited to the following defamatory statements in particular: “Princess Jade” 1. That our client is “Ottawa‟s biggest liar and slut around”; 2. That our client “lost all her girlfriends because she sleeps with everyone‟s boyfriend”; 3. That our client “slept with [someone‟s] boyfriend; 4. That our client is “bipolar”; 5. That our client is a “tramp”; 6. That our client has done “the cruelest things to people” Ottawa‟s Number 1 Sloot 7. That our client “will let whoever pays attention to her slam her 75 lb fish smelling ass”; 8. That our client „cheats on her boyfriend‟ and “sleeps around with anyone who looks at her”; 9. That our client is a “nut case”; 10. That our client “needs to be medicated”; 11. That our client “will stop at nothing to ruin anyone who crosses her path”; and 12. That our client is a “gross pig” and “fake bitch”. In addition to the foregoing, there are numerous additional comments posted below the “articles”, which are also clearly defamatory. All of the above statements are false and are severely damaging to our client‟s reputation. These malicious and reckless defamatory statements impugn the good reputation of our client and are mean

ZAK MUSCOVITCH, BARRISTER & SOLICTOR cont‟d 3

and were understood to mean inter alia that our client is a liar, a cheat, unethical, dishonest, immoral, lacks integrity, and is mentally ill, all of which is absolutely false. As a result of your misconduct and defamation of our client, as aforesaid, is entitled to damages pursuant to the Libel and Slander Act of Ontario. In the event that you fail to immediately remove all of the Defamatory Content from the Website and anywhere else under your care and/or control, your non-action will also cause further aggravated and punitive damages. The fact that our client is domiciled in Ontario, the fact that our client‟s reputation exists primarily in Ontario, the fact that our client sustained damages in Ontario, the fact that you specifically targeted Ontario by creating section on the Website specifically for and about Ontario residents, and the fact that you specifically solicit submissions from Ontario residents, all results in a “real and substantial connection” with Ontario for the purposes of suing you in Ontario. We understand that you have faced cases in the United States in the past, and have sometimes relied upon your “First Amendment” rights and the Section 230 of the Communications Decency Act, however neither of those laws exist in Canada, and our laws on defamation are very strict. There is a reverse onus which would require you to prove all of the statements which you published on the Website are true, and there is no applicable defense of “fair comment” when it comes to statement of false and defamatory facts, as has been done in this case. Furthermore, a website publisher is liable for everything that he publishes, no matter whether it is so-called user generated content, or not. Accordingly, once an Ontario judgment is obtained against you for substantial damages, all legal fees (under the Canadian system), we would seek to enforce it against your property wherever it is situate, and local courts would be bound to enforce an Ontario judgment due to the legal principle of comity which is widely invoked between Canadian and U.S. courts. We would thereby be able to seek any and all assets, including but not limited to your domain name. We would also join all applicable defendants who may have personally acted in a fashion which does not enable them to hind behind a corporate veil. If the Defamatory Content is not removed within seven (7) days of the date of this letter, we will proceed accordingly without further notice.

GOVERN YOURSELF ACCORDINGLY. THE MUSCOVITCH LAW FIRM

Per: Zak A. Muscovitch Encl. ZM/cm

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