MiguelSouthwellKasimReed1

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    PARKS I

    CHESIN

    I

    WALBERT

    A

    PROFESSIONAL

    CORPORATION

    J Matthew Maguire,

    Jr

    [email protected]

    PERSONAL AND CONFIDENTIAL

    Via Certified

    Mail Hand

    Delivery

    M

    Kasim Reed

    Mayor, City

    of

    Atlanta

    55

    Trinity Avenue, Suite 2400

    Atlanta, Georgia 30303

    June 10, 2016

    Re: Miguel Southwell - Demand for

    Retraction of

    False

    and

    Defamatory Statements

    Dear Mayor Reed:

    75

    14th

    Street, 26th Floo

    Atlanta, GA 3030

    T:

    404.873.8000 F: 404 .873.805

    www.pcwlawfirm.com

    As you know, this law firm represents Miguel Southwell. Several media outlets covered

    the bizarre comments you made about Mr

    Southwell yesterday, including:

    I f

    he continues

    down this path, I m going to make public why he was fired. He knows that not only could I have

    fired him, I could have pressed charges against him. We also understand that you made other

    unreported comments about Mr. Southwell implying that he left the Miami Airport under a

    cloud.

    You are well aware that Mr. Southwell has not committed a crime, nor has he done

    anything that would justify termination for cause in Atlanta, Miami or anywhere else. Your

    statements have no basis in fact and were made in a knowing and malicious attempt to destroy

    our client's reputation and livelihood. As you have said many times, you are not afraid

    of

    litigation, so go ahead and make known your alleged reason for firing Mr. Southwell and we will

    let a jury judge your credibility.

    In the meantime, demand

    is

    made under O.C.G.A. 51-5-11 that you publicly retract

    these false and defamatory statements within seven (7) days of the date of this letter. The

    retraction must be effected in as conspicuous and public a manner as the slanderous statements

    themselves. O.C.G.A. 51-5-1 l(b)(l)(B). Your failure to do so exposes you personally to

    punitive damages.

    JMM:kt

    cc: Mark

    G

    Trigg, Esq. (Via email)

    Miguel Southwell (Via email)

    Lee Parks