You are on page 1of 2

DESENA & PETRO

ATTORNEYS AT LAW
197 LAFAYETTE AVENUE
HAWTHORNE, NEW JERSEY 07506
__________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________
Phone 973-304-1073 Benjamin P. De Sena*
Fax 973-859-7864 *Member of N.J. and N.Y. Bar
Patricia M. Petro**
**Member of N.J. Bar

April 22, 2010


Tumblr, Inc.
419 Park Avenue South, Suite 807
New York, New York 10016

Re: Your hosted website:


“Howwelldoyouknowyourmoon.tumblr.com
DEMAND TO CEASE AND DESIST

TO WHOM IT MAY CONCERN:

Please be advised that I am the attorney for Kook Jin Moon a/k/a Justin
Moon and the matter of libelous and defamatory statements appearing on the
website hosted by you has been referred to my office for legal action.

Please be advised that most of the material on this website contains libelous
and defamatory statements concerning various persons, and, as such, you should
shut this site down immediately. Pertaining to my client, allegations pertain to
children born out of wedlock, affairs, and other matters. At this point specific
reference is made to a posting dated April 8, 2010 containing these libelous
statements and there are other defamatory statements concerning my client.
However, as I have above stated, this entire website is devoted to making false,
defamatory and libelous statements concerning various persons.

Demand is hereby made that you shut down this site immediately.
Alternatively, all references to my client Kook Jin Moon a/k/a Justin Moon should
be removed immediately, however, if you fail to shut this entire site down
immediately, future damage will be incurred by my client and others.

Please be further advised that the libelous and defamatory statements


pertaining to my client are libel and defamation per se under the law due to the
nature and subject of the defamatory statements.

In some instances on this web site, references are made to “anonymous


writers” or other such references, but, under the law, use of such cannot insulate a
party from liability for libel and defamation.

My client intends to take legal action without delay. Please advise as to


what action you intend to take.

Very truly yours,


Benjamin De Sena
Benjamin De Sena
BPD:op
Sent by email to info@davidville.com and Sent Certified Mail, RRR
c. Justin Moon

You might also like