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ATLANTA
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LoS
ANGELES
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VALLEYWASHINGTON
DC
October
22,2019
VIA
EMAIL
Brandon
Ambrosino
210
Phillips
Mill
Lane
Newark, Delaware
l97ll
Re:
Liberty University
and
Mr.
Jerry
Falwell,
Jr.
Dear
Mr.
Ambrosino:
The undersigned
represents
Liberty University
( LU )
and
Mr.
Jerry
Falwell,
Jr.
( Mr
Falwell ).
You
have
and
continue
to
publicly
defame
LU
and
Mr.
Falwell
with
a
series
of
claims
for
which you
have
no
factual
basis,
that
are
based
on
knowingly
misrepresented facts, or
which you
have
just
made
up.
It
is clear
from
the evidence that we
have
thus far uncovered that
these falseand
defamatory
statements
were
made
with
actual
malice
and an
intent
to
harm
LU
and
Mr.Falwell.Most recently, our investigation
has
revealed that on October
7,2019
you participated
in
a
public
forum
at
Villanova University
in which you
published the
following
false
and
defamatory
claims,
among
others:
1.
LU
is
oonot
a
school
but
a
real
estate
hedge
fund
that
operates
as
a
for-profit
entity through its fundraising, on-line
educational program, endowment's real
estate
investments,
and
in
other ways
in
violation
of its
stated
mission
and
not-for-profit
status. In
fact,
LU
provides
a
quality, legitimate,
accredited
not-for-profit
education consistent
with
its
mission
and
tax
status;
LU's
real
estate
investments account
for
no more
than
l0%
of its
endowment
(which is
in
line
with
and
much lower
than most other
university
endowments);
and
most
of LU's
real
estate
investments
are
contiguous to the school
and
supportive
of
its mission,
unlike
most real
estate
investments
at
other
universities
that
are
wholly
unrelated
to their
educational mission.
2.
Mr. Falwell
breakfs]
the
law,
is
comrpt,
exploits
people
for money,
'ouses
the gospel against
them,
engages
in
self-dealing,
and
improperly
uses
his leadership
position
toenrich
himself
and
his
family
and
friends
at
the
expense
of
LU;
is similar to
the
fictional
comrpt
preacher
Elmer Gantry
and
the actual
comrpt
embezzlq
and
felon
James
Baker,
and has
a
faith
that is
racist. In
fact,
Mr.
Falwell
does
not break the
law,
engage
in corrupt or
self-dealing,
exploit
people
for
money,
use
the gospel
against
people,
abuse
his
position to improperly
enrich
himself
or his
family
and
friends, or practice
a
racist
faith
or
hold
racist
views.
Moreover,
only