My attorney attempted to confirm receipt of this letter yesterday, however Squirrel Poop appears to be playing games. We’ve extended the deadline to reply until 12:00 noon today. However, Squirrel Poop appears to be taking legal advice from his campaign consultant — never a good idea.
January 20, 2011
Via Electronic Mail
Mr. Michael Ciftci
Post Office Box 21751
Tampa, FL 33622
Re: Cease and Desist & Request for Retraction
Dear Mr. Ciftci:
This law firm represents Mr. Chris Ingram and 411 Communications (collectively “Ingram”). This letter constitutes a demand for an immediate retraction in writing of false statements that were allegedly made by you against Ingram.
Your statement made on January 18, 2011, for publication, to The Daily Loaf, a blog by reporter Mr. Mitch Perry of Creative Loafing, was false and libelous concerning Ingram. You stated:
“I am truly baffled by Chris Ingraham’s bizarre rant. He seemed to agree with our positive vision for Tampa when he pitched me his political consulting services. I told him we were going in a different direction, which I assume elicited this troubling outburst. Mr. Ingraham’s shakedown tactics didn’t work with the Marco Rubio campaign and they won’t work with me.”
At the time you made the statement you knew it was false or libelous, and Creative Loafing published those statements. This conduct is actionable under Florida law. Your follow up statement published on your Twitter account on January 19, 2011, stated:
“We didn’t hire Chris Ingraham – so he attacks me in a bizarre rant? His shakedown tactics didn’t work with Marco Rubio campaign either.”
Your false statements, of which we have noted some of the more patent, malicious, and slanderous of the statements made by you, have caused and continue to cause harm to Ingram. Your statements, which have previously been brought to your attention, infer that Ingram is a person with whom commercial relations are undesirable and imputes conduct to him incompatible with the proper exercise of his lawful business.
Your defamatory statements may also rise to the level of tortious interference with business relationships enjoyed by Ingram. As such, they are actionable and expose you to the imposition of compensatory as well as the possibility of punitive damages.
Ingram would prefer to reach an amicable accommodation, rather than commence a lawsuit against you. However, the absence of a sincere effort on your part to resolve this matter, Ingram will be left with but few alternatives.
Therefore, Ingram hereby demands that you send the following written retraction to Mr. Adam Smith, St. Pete Times, Mr. William March, Tampa Tribune, Mr. Mitch Perry, Creative Loafing, and Terry Dolan, General Manager at Bay News 9.
“In my haste to respond to Chris Ingram’s Irreverent View column about my candidacy, I misspoke to the media about Chris Ingram. To set the record straight, Mr. Ingram and I have never discussed him working on my behalf or for my campaign for Tampa City Council District 3.”
Your failure to correct your erroneous and false statements and their repetition after notice of their falsehood constitutes further publication of libel. It also confirms your malicious intent. If you do not delete your Twitter post immediately, cease and desist from tortious interference and making false and malicious comments about Ingram and 411 Communications, and issue the retraction by 5:00 p.m. TODAY, Ingram will file a Complaint against you within five business days and will seek all remedies allowed pursuant to applicable law, including but not limited to an injunction against you, money damages, interest, and the recovery of attorneys’ fees and Court costs.
PLEASE GOVERN YOURSELF ACCORDINGLY.
C. Todd Marks, Esquire