Jive...

[European Lee]

You were a prick then and are still a prick now

Does this bring back any fond memories for you?

Brull Piccionelli Sarno Braun & Vradenburgh
A Professional Association
1925 Century Park East, Suite 2350
Los Angeles, CA 90067
Tel: (310) 553-3375
Fax: (310) 553-4120

November 13, 2001

Via FEDERAL EXPRESS and
EMAIL: [email protected]

Robert A. Sarno
E-mail: [email protected]
Direct Line: (323) 666-0485

Mr. Jive
(Deleted)
Vancouver, BC CAN V5N2R6

Re: RJB Telecom, Inc.; Robert Botto
Legal Action for Defamation/ Cease and Desist Notice

Mr.Jive : This law firm represents both RJB Telecom, Inc., the operator of the Maximum Cash (MaxCash) webmaster affiliate program, and Robert Botto, individually.

It has come to my clients' attention that you have been publishing false defamatory and malicious statements and accusations on the Internet directed against RJB Telecom, the Maximum Cash Program and Robert Botto. I have attached a copy of the text of the identical messages you posted on November 12, 2001 at the following urls: www.privatelabelresources.com and www.trafficswap.com. In both instances you posted these messages under the name "Jive". The email address for Jive is (deleted). I have also sent you a copy of this letter at that email address.

As I indicated, I have attached your statement in its entirety to this letter. Without going into all of the objectionable particulars of your statement, I would simply point out that you falsely accuse the Maximum Cash program as being fraudulent and that the owner of Maximum Cash, i.e., "RB" (Robert Botto) as being a "manipulator and a cheater" who is "scamming" participating webmasters by "shaving" traffic figures and "ripping" them off (i.e., defrauding them of commissions to which they are entitled). All of these allegations of wrong doing on the part of Robert Botto, RJB Telecom, Inc., and Maximum Cash are totally baseless, untrue and false. Your false statements are made either made with knowledge of the falsity of those statements or with a reckless disregard of the falsity of those statements. Moreover, your defamation falsely implies that Robert Botto is engaging in criminal conduct, and therefore constitutes libel per se.

This is to put you on notice that your false and slanderous statements and accusations against my clients constitute intentional defamation and tortuous interference with prospective business opportunities. Your false and defamatory statements, published in the chat rooms of web sites catering to adult webmasters, appear to be designed and calculated to inflict the greatest possible damage on my clients' business interests and reputation within the very industry that they do business.

On behalf of my clients I make a formal demand on you to immediately cease and desist from any further publication, either in writing or verbally, of defamatory and slanderous false statements and accusations against RJB Telecom, Inc., the Maximum Cash Affiliate Program, Robert Botto or any other person or persons associated with any of them.

If we determine that you make any further defamatory or slanderous statements regarding my clients, my law firm has been authorized to take all appropriate actions to protect their rights, including filing a complaint against you for your willful and malicious tortuous actions in which we will seek maximum monetary damages, including compensatory and punitive damages, injunctive relief and attorneys fees.

I note that your address is in Canada. Lest you mistakenly believe that your actions can not be punished or that you can escape liability because your residence is outside the United States, let me assure you that we are fully prepared to pursue this matter in the United States Federal District Court or, if necessary, to engage our Canadian attorneys to prosecute this matter against you directly in the appropriate Canadian courts.

Please henceforth direct all communications concerning this matter to the undersigned.
I look forward to your timely response, and thank you in advance for your anticipated cooperation. On the other hand, should you choose not be cooperative, rest assured that this law firm will vigorously and ardently pursue every legal avenue available to vindicate my clients' rights and secure full compensation for their damages.

I strongly urge you to contact me directly upon receipt of this letter to communicate your unconditional agreement to comply. If I do not receive a satisfactory response from you within 5 days of receipt of this letter I will proceed with filing a lawsuit against you.

This letter is written without prejudice to any rights of our clients, including, but not limited to, rights to injunctive relief, compensatory and punitive damages and attrorneys' fees.

Very truly yours,

Robert A. Sarno

For those of you with a Maxcash reseller account here is the full thread link:

http://forums.maxcash.com/showthread...=&view=&sb=&o=

Regards,

Lee

[Theo]

Yesterday Jive talked shit about cecash and the major billing processors. Now i see it's not the 1st time..

[<IMX>]

*yawn*
Why are you opening a new thread?

[Jive]

Originally posted by <IMX>
*yawn*
Why are you opening a new thread?

my name isn't Mr.Jive this isn't a legal Doc?
and ya, old news and No talking shit about C cash there's no money there.. only facts if there was any money believe me I'd been jammin my hits there way.. anyways Boo-Hoo.. Doggy doo.

[Brujah]

Does Jive ever have proof, or just talks a lot of bullshit ?

[ChrisH]

I remember that Lee. It was very funny. Still is lol...

[Jive]

Originally posted by ChrisH
I remember that Lee. It was very funny. Still is lol...

Chrissy still breathin,your still sniffin my cock after all these years?

and Bruhah who ever the fuck you are? get your nose outta my ass-hola..

[European Lee]

Hmm..

Jive... living proof what your folks told you would happen if you didnt turn up for school kids

Literacy does has its advantages afterall

Regards,

Lee

[Jive]

Originally posted by European Lee
Hmm..

Jive... living proof what your folks told you would happen if you didnt turn up for school kids

Literacy does has its advantages afterall

Regards,

Lee

Last message and will not waiste any more time on fags like you!
I feel sorry for you that you are unable to pay your debt's I see webmaster's complaining about you all the time? that your problem? you shouldn't be talking so big all the time then you wouldn't have any issues with anyone. nor anybody not trusting you.. Doogydoo you have always hand problems over the years.
clean up your act.. Yes, I understand there's a confused child trapped in side you..I don't care if your gay or Meloman is either!
Gay people lead troubled lives my opinion..
grow up Doogy-doo aka Lee.. good day.

[BJ]

[kmanrox]

who cares?