Rik Mehta To Phil Stilton and Shore News Network

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Azzolini Benedetti

Post Office Box 12


Florham Park, New Jersey 07932
Telephone (973) 966-5544
Facsimile (973) 966-6897
[email protected]

September 11, 2020

Mr. Phil Stilton


Editor, Shore News Network
6 Kennedy Court
Jackson Township, NJ 08527

Dear Mr. Stilton,

I have been retained by the Rik Mehta for U.S. Senate campaign, to respond to your e-
mail of today that is offering coordinated in-kind support to his campaign on your behalf
from yourself and the Shore News Network (SNN). Mr. Mehta and his campaign are not
interested in being associated with you or SNN, and therefore reject your offer and ask
that you immediately remove this ad, and any reference to Mr. Mehta from your
publication.

As you are, or should be aware, you and SNN conspired to commit slanderous and
false charges against Mr. Mehta, thus libeling Mr. Mehta and his campaign. You and
SNN also provided illegal unreported donations in support of one of Mr. Mehta’s primary
opponents, for which an FEC complaint has been filed against you.

We ask that you immediately remove the ‘banner ads’ that you have indicated you want
to provide to his campaign, as well as any other references to him and his campaign –
including, likenesses, images or logos.

Further, we request that you remove all previously published articles regarding Mr.
Mehta and / or his campaign – virtually all of which contain false and slanderous
information – such libel was even contained in articles published by SNN after the July
2020 Primary election.

You have published information that is unequivocally and demonstrably false and made
with actual malice within the meaning of the landmark case New York Times v. Sullivan
376 U.S. 254 (1964)1 and the New Jersey case of Lynch v. NJEA2.

1
Holds that perpetrator knew or should have known that a statement regarding a public figure was false or
reckless and published without any reasonable investigation as to the accuracy of the information.
2
Lynch v. NJEA, 161 N.J. 152, 166 (1999)
This illegal, intentional publication has caused, and will continue to cause, irreparable
harm to Rik Mehta and his campaign unless there are immediate actions to cease and
desist in distributing this false information and to mitigate the damages created by your
actions.

Per Lynch v. NJEA, 161 N.J. 152, 166 (1999), there is a three-pronged standard
regarding defamation per se that is met here: 1. False statement about a public figure
published / communicated to a third person, 2. Damaging to the subject’s reputation, 3.
Published knowingly or recklessly disclosing the false information.

We, therefore, demand that you immediately cease and desist in publishing and / or
broadcasting any information promoting Mr. Mehta and / or his campaign and or
publishing and / or broadcasting false and libelous statements or communicating any
other defamatory, slanderous or libelous information regarding Mr. Mehta and / or his
campaign in any form of media - spoken, written, visual and electronic. Further, we
demand that you immediately mitigate the damages already caused by removing the
previously referenced published information.

You will satisfy our demand that damages are mitigated by removing all materials
regarding Mr. Mehta that are currently published on SNN and any of its related
publications; and further, by not coordinating support with Mr. Mehta - as he has no
interest in being associated with you and / or SNN due to your past malfeasance
targeting him, as memorialized above.

Failure to comply with the requests herein will result in our taking immediate legal action
to enjoin your behavior and seek remedies through maximum compensatory and
punitive damages to the full extent of the law.

Very truly yours,

/s/ Alan J. Zakin

Alan J. Zakin

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