07/11/2013

AX08 - Offer to take down blog

Ms. Frankfurt
John
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To: Simon Smith <Simon.S@psblaw.co.uk>

26 September 2013 12:07

Dear Mr Smith
This is to acknowledge that I am in receipt of your letter dated 31 August. I also acknowledge service of the
Claim from the Court and have informed the Court of my intention to defend.
I am in the process of consulting in order to issue a counter-claim for harassment by your client as evidenced
by numerous communications from her. Whilst I am also mindful that my reporting of this affair is protected
under the Human Rights Act and Article 10 of ECHR, I am also of the opinion that in her premeditated and
long campaign to deceive me by creating a false alias to offer me friendship and even a job that did not exist,
your client has been in breach of Article 8 of the same Act; ironically, her actions constitute a grave and cruel
campaign of harassment.
I am somewhat baffled as to the precise nature of the purported claims against me, as your letter of complaint
briefly mentions defamation (but not libel), harassment, invasion of privacy and infringement of copyright. Your
letter is in no way compliant with any Pre-Action Protocol and your issuing of a Claim against me is
accordingly premature and in breach of Protocol. I will draw this to the attention of the Court at the earliest
juncture.
I also put you on notice of my intention to make an early application for security for costs against your client
on the basis she is not domiciled in the United Kingdom.
With regard to the final point in your letter, and without admission of liability, I am prepared to remove the
audio-clip of the voicemail message your client left on my phone after ringing me numerous times to the
extent that I have had to change my phone number. I believe that everything I have stated on my blog post is
truthful and factual; however, if your client takes issue with any of the facts as reported, please detail these
and if I have made any error regarding the facts that I describe I will remove any erroneous details.
Furthermore, in a sincere effort to resolve this matter at the outset and to avoid incurring further substantial
costs for either party, I am prepared to remove the blog post in its entirety, subject to a written apology from
your client for the very real distress her unsolicited pursuit of me under the alias Matthew Spitz has caused
to me and to my family, and a written undertaking never to contact, or attempt to contact, me again, in any
form or medium, or under any name, persona or alias.
Yours sincerely
John
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