ZIFFREN BRITTENFiAM LLP

ATTORNEYS AT LAW
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Jamie Afifi Jamey Cohen David Lande Mitchell Tenzer Kathleen Hallberg
Pam Black Melanie Cook David Nochimson Bryan Wolf Of Counsel
John G. Branca Samuel Fischer Benjamin Rubinfeld Miriam Yoo
Skip Brittenham Clifford W. Gilbert-Lurie P.J. Shapiro Julian Zajfen
Steven H. Burkow JeffHegedus Eric Sherman Kenneth Ziffren
David Byrnes Matthew M. Johnson Scott Sims
Logan Clare Wendy Kirk Gary Stiffelman
Dennis Luderer
Of Counsel
OUR REFERENCE NUMBER
June 18, 2014 361.26.21
VIA EMAIL
Mr. Charles Davis
davis.charles84@gmail.com
Re: Steve Tones
Dear Mr. Davis:
I am writing on behalf of my client Steve Jones in response to your email
addressed to him earlier today. Your letter falsely claims that Mr. Jones, in front of
you and a number of other people, stated that he had, in fact, sexually assaulted a
female fan after she had passed out in his home, and in the word you claim he
used, committed a "rape".
As you well know, Mr. Jones never said that he had, in fact, engaged in
such act. As was typical during production meetings of BrandX, participants,
including Mr. Jones, were encouraged to come up with fictitious story lines. In
that context, Mr. Jones suggested the "rape" story as the basis for a fictional
episode of BrandX. At no time did Mr. Jones state or imply, directly or indirectly,
that such an event had ever, in fact occurred. It was very clear to all present,
including you, that Mr. Jones was making up a fictitious story, not recounting
anything that had ever taken place.
Mr. Jones is shocked that you would threaten to publish an article as if it
were an admission by Mr. Jones of the commission of the crime of rape described
in his obviously fictional story. He does not understand what your motivation
would be, or why you would want to cause irreparable harm to his reputation.
And, he cannot fathom how you would have the gall to do so knowing that there
was a room full of witnesses who will testify that Mr. Jones never stated or implied
that, in fact, he had ever sexually assaulted or raped anyone. Whatever you
motivation might be, be advised that Mr. Jones pursue all legal remedies if you go
forward with the threat to provide an article for Salon (or anyone else) which
falsely portrays Mr. Jones as having committed the crime of rape.
Mr. Charles Davis
June 18, 2014
Page 2
On behalf of Mr. Jones, I hereby demand that you cease and desist from
writing and/ or publishing the story that you have threatened to deliver to Salon.
Should Salon or anyone else publish the story, or should you disseminate it in any
medium, including on the internet, Mr. Jones will immediately pursue all available
legal remedies against all involved, including you, Salon and any other participant
you, including suing you and Salon for libel, which will subject you to a
substantial award of damages including punitive damages.
This letter is written without prejudice to or waiver of Mr. Jones' claims,
rights, remedies and defenses, all of which are expressly reserved.
GS/sr/1206230.1/361.26.21.0