Just another walk in the park :)

[Leon]

Mr. Leon Luckey
eonl@flash.net
via electronic communication, only

Re: Mr. Frank Prisco/Piedmont Sports

Dear Mr. Lucky:

Please be advised that I represent Mr. Frank Prisco. It has come to my attention that there is an Internet “thread/forum” that disparages my client and/or his business, Piedmont Sports. We demand that you immediately cease and desist having, holding and/or engaging in any Internet, telephonic, written and/or electronic discussions regarding my client. We further demand that you remove all of the “thread” that discusses my client and/.or his business.
This correspondence will serve as your legal notice under the provisions of Pennsylvania and Federal law to cease all communication with any parties in regard to my client. If you fail to heed this notice, I will file a formal Complaint against you.
Your egregious conduct is considered Trade Libel and is actionable and compensable. The publication of a disparaging statement concerning the business of another is actionable where: (1) the statement is false; (2) the publisher either intends the publication to cause pecuniary loss or reasonably should recognize that publication will result in pecuniary loss; (3) pecuniary loss does in fact result; and (4) the publisher either knows that the statement is false or acts in reckless disregard of its truth or falsity. As your counsel would advise, an action for trade libel is calculated to protect against derogatory statements that affect the marketability of a party's goods or services. Surely, these careless, false, slanderous postings have done exactly that.



Page -2-
August 25, 2011


I trust that these actions will cease. If you should have any questions and/or concerns please do not hesitate to contact me. Give this very important matter the attention it deserves.

Very Truly Yours




______________________________
Stephanie J. Brown, Esquire

SJB/sb
cc: Mr. Frank J. Prisco