JOHN ANTHONY TAYLOR, ESQUIRE
TAYLOR LEGAL COUNSEL
(Practicing Exclusively in Massachusetts)
‘18 CENTRAL SQUARE
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‘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 GENERATIONSlawsuit 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,
=fpuerile 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-