Billy Santoro Defamation Warning

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JOHN ANTHONY TAYLOR, ESQUIRE TAYLOR LEGAL COUNSEL (Practicing Exclusively in Massachusetts) ‘18 CENTRAL SQUARE ausove (Soa) 7003008 (ax) arwoie Tan (17 ‘wos trun cress) Seat Ehw. pc. Noses 0 Tavcon (1810-52) Shomone Seer Praeuni Tarcon eee to) Saunrapoe mia ea ‘Atos Tamwon (879 068) ; intreare ‘Roni Yaron iotet660) April 9, 2018 543068 (ra Mr. Zachary Sire, dib/a STRSUPGAYPORN, via email only Re: Leah Bassett vs. Monica Jensen, d/b/a Ni lle et als Dear Zach and his faithful readers/followers: 1am the attomey representing Leah Bassett in the above-referenced lawsuit that has been featured in several of Zach's posts since its filing in the U.S. District Court of Eastern Massachusetts on March 26th. | am forwarding this "open letter" to Zach's blog site in the expectation that it will reach the attention of Billy Santoro and most, if not all, of the other actors/models who have participated over the past 3+ years in the 150+ porn films created by Mile High Media under its Icon Male and Transsensual tradenames. Since I have noticed that many of his posts generate a lively discussion per the ensuing comments section, other readers/followers are obviously welcomed to review and weigh in on the points raised in this letter as well. With that in mind, I will number the balance of this letter for easier reference, 1.) Having followed Zach's periodic posts about the activities of Mile High Media's controversial writer/director "Nica Noelle", most particularly re het 2014-15 presence on Martha's Vineyard, 1 have not previously felt any occasion to volunteer any response or {information that Leah and I have acquired about those activities, - at least prior to "going public" with the federal lawsuit which he, rather remarkably, reproduced in full one day after it had been filed, (2.) On 3/29/18, Zach published a post, headlined "In Wake Of Feces Vineyard’ Lawsuit Against Nica Noelle And Icon Male, Billy Santoro Goes On Libelous Tirade Against Helix, CockyBoys, Men.com, And Naked Sword’, in which your opening sentence begins: "He's undoubtedly been forbidden from speaking about the recently filed lawsuit ‘against his employer Nica Noelle and her studio Icon Male, but that's not stopping gay porn star Billy Santoro from speaking out in other bizarre, libelous ways..." ‘While Zach's expectation that Mr. Santoro (aptly abbreviated as "B.S." hereafter) would have been advised by his stated employer to refrain from any public comments about the PROVIDING LEGAL SERVICES FOR SEVEN GENERATIONS lawsuit was seemingly well-founded, B.S. actually decided instead to label Leah as both “homophobic” and "transphobic” on his ‘personal billyleakedit.com website on the following day! As purported support for his churlish claim that Leah is a "viciously homophobic and transphobic woman", B.S. quotes a passage from the Mile High-associated Defendants! response letter, dated 11/17/15, to the initial "demand letter", dated 10/06/15, in which their attomey wrote in pertinent part: "based upon the language and tone of your letter, you make clear your client's threats are based on her disdain and personal animus toward the homosexual and transsexual community." Those two letters were attached as Exhibits to the Verified Complaint, along with my reply letter, dated 11/27/15, categorically denying that any homophobic sentiments were driving my client's issues with Mile High's unauthorized uses of her personal residence. B.S. chose to "ignore" that reply letter, presumably because accurate and truthful "reporting" was neither his, nor by extension, Nica/Mile High's intentions. Rather, deliberately engaging in "hate speech" directed against a woman, whom he's never met or spoken with, was the goal. Beyond the fact that I, alone, was the author of that demand letter (and it is not my usual practice to let my clients ghost-write or edit my work product, except in those instances where they will be personally signing it under oath as a "verified" document), BSS. also chose to "ignore" the fact that Mile High's attomey has never repeated that initial homophobic suggestion in any of her ensuing letters and emails in the intervening 21/2 years.' Again, why let accuracy and truth "get in the way" of malevolently-intended hate speech? (G.) Anyone who has reviewed the Complaint should have noted that it did not include a Count for Defamation of Leab's reputation and character. While that passage quoted by B.S. was libelous in nature, it too was written by a lawyer rather than by any of the named Mile High-associated Defendants, and, as stated, was never repeated.” It didn't really seem like a genuine issue, -- until B.S. decided to post on social media his " As the actual author ofthat initial demand letter, I have been a life-long member of the socially progressive Unitarian-Universalist faith, and would present my credentials as a supporter of individual freedom and gay rights over those of B.S. any time. As an early example in my professional career, I ‘successfully represented a gay male couple in 1981 in overturning a written policy that had been enacted by Massachusetts’ Department of Social Services which prohibited any gay individual from being approved as either a foster parent or an adoptive parent of any child under that agency's jurisdiction, Talso daresay that I ‘knew personally, and represented professionally, far more gay males in the 1980s who suecumbed to AIDS back when that disease was both a death sentence and 2 grim one. That said, this lawsuit springs from the shocking lack of common respect, decency, and transparency that the Mile High Defendants exhibited in 2014-15, and continuing to the present, towards my client's personal and property rights; not from some ‘goal of engaging in gay-bashing, ® For those of your readers who may be unclear on the terminology, "defamation" is the actionable offense'tort, encompassing both “libel” and "slander", False and harmful statements directed at a specific individual without justification or privilege in written form are libelous, while such statements expressed ‘orally are slanderous, =f puerile opinion and claim that Leah Bassett is a. "vicious" homophobe/transphobe. B.S. hhas now changed that calculus. He has defamed my client in a manner and on a platform that will not be tolerated, Jeaving open whether I will add him and a new Count for Defamation to the existing Complaint, or sue B.S. in a separate action on Leah's behalf. One factual issue that I would like B.S., and/or his Mile High employer, to voluntarily address per this open letter is whether he was acting in his individual capacity as a "blogger for profit" when he posted that false and hateful accusation, or as an allied shill/agent for the Mile High- associated Defendants that employ him as Icon Male's production manager, or both? (4.) Anyone who has reviewed the Complaint may also have noted Footnote 3, which reads: "At present, the Plaintiff is disinclined to sue the estimated 30+ ‘actors/models! who were present on her residential premises for the commercial pornography purposes on a film by film basis, but she feels differently about Mile High's other Vineyard-based crewmembers/employees and its other third-party distributors besides TLA Entertainment and Gamma Entertainment.” Conversely, in the Knapic v Lucas Entertainment et als lawsuit that was chronicled on Zach's site, that female plaintiff and her attorney did choose to name all of the actors who had participated in those two unauthorized pom shoots on Ms. Knapie’s premises.’ Leah did not want to go that route, despite the standard litigation theorem of "the more co-defendants, the merrier” in terms of prospective damages awards, That decision was fueled by two factors: (2,) She is a professional artist herself, dependent largely on irregular, freelance assignments over the past 20+ years, and she viewed the majority of actors who participated in the unauthorized porn shoots on her premises as freelance artists themselves, albeit in a quite different genre; and, (b.) She was favorably influenced by the promptness with which “Joshua Darling" both acknowledged and apologized for his role in those unauthorized activities on her premises, as well as those several actors who voluntarily came forward at Joshua's request in order to provide written accounts as to their respective "roles" in the porn shoots on Leah's premises. She came away satisfied that the actors were not the primary culprits here, and did not merit being sued as Co-defendants. That hardly bespeaks of a woman who is viciously homophobic/transphobic. Itis, however, a tactical decision that could be reversed over the coming ‘weeks/months. In that regard, I have prevailed upon my client in letting me issue what could be construed either as an invitation or as an ultimatum to those actors who participated in any of those Vineyard-based shoots in 2014-15: Anyone who initiates contact with me by email within the next 30 days will be assured of "a pass" from being named as a Co-defendant, provided that he/she agrees to being a cooperative witness and provides a voluntary and truthful written statement as to the circumstances of his/her > Coincidentally, her attomeey was named Lacy Taylor, although we knew of no actual kinship per my several phone and email communications with Lacy while that lawsuit was on-going, presence on the Vineyard and/or on Leah's premises at Niea Noelle/Mile High's behest.* (S.) Without wishing to unduly increase the length of this letter, a review of some of the more specific grievances outlined in the Verified Complaint merit some mention in further debunking B.S.'s bogus claim that the lawsuit stems from some viciously- motivated homophobia/transphobia on my client's part. It is an indisputable fact that both Leah's lease signed by Mile High's then employee/agent, Joshua (attached as Complaint Exhibit 1(B)), and her town's zoning ordinance, prohibited any commercial uses in a zoned Residential District without a Special Permit. Beyond that over-arching breach, the Mile High Defendants "stiffed" her out of the last three months' rent and utilities due under the lease; "trashed" her premises (including quite literally the 25 large bags worth of rotting and non-

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