Professional Documents
Culture Documents
March 14,2011
We are counsel to Nationwide Title Clearing, Inc. ["NTC"). I am notifying you that
your firm's website, www.foreclosurehamlet.org. contains materially false statements
regarding NTC, Bryan Bly, and Crystal Moore, claiming that NTC creates false documents
for financial institutions that are subsequently submitted to courts in mortgage foreclosure
proceedings. More specifically, your website contains the following postings which are
materially false and misleading:
This posting falsely accuses Crystal Moore of being a "criminal perpetrator" when
she executes documents on behalf of NTC. The posting must be removed immediately. In
addition, on November L9, 20L0, Sarasota Circuit Judge Rick DeFuria entered a temporary
and mandatory injunction against Christopher Forrest and The Forrest Law Firm, and all
persons acting in concert with either, enjoining those individuals from "posting, publishing,
disseminating, or maintaining materials from the video depositions of [Bryan Bly, Crystal
Moore, and Dhurata Doko] until further order by this Court." A copy of |udge DeFuria's
injunction is enclosed for your review.
Your November t7,2070, post may not refer to Ms. Moore's video testimony and
you must immediately remove all links or references to Mr. BIy, Ms. Moore, or Ms. Doko on
your website, www.foreclos urehamlet.org.
2. Your site's November 8,20L0, post contains a post with the heading
"Mortgage Fraud" that reads as follows:
Ms. Lisa Epstein
March \4,2077
Page 3
Not only does your post summarize Mr. Bly's deposition post which is in violation of
fudge DeFuria's injunction as stated above, your website falsely implies that it was
improper for Mr. Bly to sign numerous mortgage assignments each day as an officer of over
20 banks and mortgage companies, even though he was told there were corporate
resolutions from those companies authorizing him to sign as an officer of those banks and
mortgage companies. You go on to falsely imply that Mr. Bly was guilty of wrongful
conduct because he did not read the assignments before signing them and had no
knowledge of their contents. All of this of course, is posted under the heading "Mortgage
Fraud."
3. Your post of October LI,2010, entitled "Pigs Ass" wrongfully implies that any
documents created by NTC, Bryan BIy, or Crystal Moore should be presumed to be
false. The post states:
P
Many other mortgaqe servicing companies and foreclosure
firms have filed thousands of other wort.hfess, unfounded
Affidavits.
The statement that Mary Jo McGowan of NTC is a "fraudulent signer" and that the
"fraud . . . is coming out of Pinellas Counl5/" (where NTC has its offices) is false and
materially misleading. It must be removed immediately.
Complete copies of these website posts are attached hereto for your review.
can-go-a-long-way-for-the-media and learn the true facts concerning NTC and Mr. Bly.
I advise you that there is no exceptioin under the defamation law for "republishing"
posts from other internet sites. The law in Florida is that repetition of libelous material ii
actionable, even if the "republisher" refuses to vouch for its veracity. See Lewis v. Evens,
406 So. 2d 489 [Fla. 2d DCA 198U. Moreover, defamatory comments are actionable even if
made in internet "chat rooms," See Becker v. Hooshmand, B4I So. 2d 561
[Fla. 4th DCA
20031.
You must remove all references to Mr. Bly, Ms. Moore, NTC, or any of its other
employees within five [5J days of the date of the letter and cease and desist making any
false statements about Mr. Bly, NTC, or its employees, whether on the Internet or
otherwise.
To the extent that you contend that you published these comments in good faith; or
that their falsity was within the protective mechanism outlined in Section 770.02, Florida
statutes fwhich NTC disputesJ, NTC, Mr. Bly, Ms. Moore, Ms. Doko and Ms. McGowan hereby
demand that a full and fair correction, apology, or retraction be made as provided by law.
If you do not remove these false statements and cease your wrongful activity, NTC
intends to avail itself of all available legal remedies against you and anyone else associated
with www. foreclosu rehamlet.org.
"c(ruwuS e&."-
Michael B. Colgan
MBC/fts
Enclosures
04437-00100 62314O v2