CEASE AND DESIST
To who it may concern at deathmetal.org
This letter represents Shawn Wright. If you are represented by legal counsel, please direct this letter to your attorney immediately and have your attorney notify us of such representation.
You are hereby directed to:
CEASE AND DESIST ALL DEFAMATION OF
SHAWN WRIGHT AND HIS BAND/GROUP BESTIAL EVIL’S CHARACTER AND REPUTATION.
Shawn Wright is an educated, respected professional in the music community. He has spent years serving the community in his profession and building a positive reputation. Shawn Wright has learned that you have engaged in spreading false, destructive, and defamatory rumors about him and his band. As a host of the domain “deathmetal.org” you are continuing to support the defamation of character by allowing such information to be presented on the website.
Under Maryland law, it is unlawful to engage in defamation of another’s character and reputation. Defamation consists of
(1) a statement that tends to injure reputation;
(2) communicated to another; presented on a website with images and
(3) that the speaker knew or should have known was false information.
Your defamatory statements consist of homophobic imagery, false information about Shawn, as well as defamatory statements about his band and his ideals presenting false representations of Shawn Wright and Bestial Evil on a large scale to the public.
Accordingly, we demand that you (A) immediately cease and desist your unlawful defamation of Shawn Wright/Bestial Evil and (B) provide us with prompt written assurance within ten (10) days that you will cease and desist from further defamation of Shawn’s character and reputation.
If you do not comply with this cease and desist demand within this time period, Shawn Wright, is entitled to seek monetary damages and equitable relief for your defamation. In the event you fail to meet this demand, please be advised that Shawn Wright has asked us to communicate to you that she will pursue all available legal remedies, including seeking monetary damages, injunctive relief, and an order that you pay court costs and attorney’s fees. Your liability and exposure under such legal action could be considerable.
Before taking these steps, however, my client wished to give you one opportunity to discontinue your illegal conduct by complying with this demand within ten (10) days. Accordingly, please sign and return the attached Defamation Settlement Agreement within ten (10) days to the email provided.
I recommend that you consult with an attorney regarding this matter. If you or your attorney have any questions, please contact us.
The referenced “Defamation Settlement Agreement” was not attached to the email.