Letter to Grand West March 15, 2001.

March 15, 2001

Michael E. Hendicks
Hendricks, Hendricks & Shakes
4055 Nonchalant Circle South
Colorado Springs, CO 80917
Dear Mr. Hendricks,
This letter is in response to your letter dated February 27, 2001, in which you "respectfully request" that your client, Grand West Financial, be immediately removed from our web site, www.NorthStar-Sucks.com, because you feel our opinions as stated on the web site are "defamatory" to your client.
In your letter, you cite "allegations" are made that Grand West Financial has "been engaged in a pattern of lies, deception, fraud, intimidation, and other criminal activities". This statement, as well as the other statement "alleging" that there is "an unprofessional and unethical relationship with NorthStar Builders", was taken out of context as presented in your letter.
What you omitted was that the web site presents our opinions based upon that which has happened to us, the public records we have read, and what others have had to say. You omitted "It is our opinion" and "have what appears" from your earlier quotes.
In any event, we feel we have more than adequate evidence to support our "allegations". Every incident that we have detailed has happened. Taken at their totality, we feel they present a solid foundation for our opinions as stated. We have not fabricated anything on that web site.
And to specifically address two points you made in your letter: damages and escalation.
We are curious as to how you will prove damages and from whence they originated. If there are losses, would it be because of a) our web site, b) your client's fiscal irresponsibility and threatening manner, or c) one of the many law suits pending against him?
As for escalation, I believe it is accurate to say that an attorney has an ethical responsibility to refuse to represent a client who is pursuing a false or a fraudulent law suit. Before pursuing this any further, ask your client the following questions:

Have you recently threatened anyone with foreclosure because their name was on the web site in question?
Have you recently gone to settlement with funding that failed to materialize?
Have you ever told a client that they were not getting any answers because of their attitude?
Have you ever threatened anyone in his office in the presence and partnership of Barbara Robbins from NorthStar?
Have you ever told anyone "NorthStar is one of the finest contractors in Teller County. You are doing fine. Back off."?
Have you ever told anyone that NorthStar will honor their contractual obligations and there is no reason to place money in escrow at settlement?
Does your client feel it is in the best interests of the homeowner to insist they go to settlement even though there is no final inspection or occupancy permit on the home?
Has your client ever provided a copy of an appraisal to the homeowner but intentionally left out the first two pages, the only two pages that have relevant information?

If your client answers "no" to any of these, he's lying. Take these questions, along with everything else, and you will see the same pattern we see. It is a cold hard fact of life that often the truth is defamatory. I would suggest you get past the first page of the website and see the substance of our complaints.
Your client will not be removed from the web site. Should your client decide to pursue this matter, we are sure you will point out to him the hopelessness of winning this. We have too much documentation and too many witnesses. As the plaintiff, he will have to prove we are lying. An impossible task because we are not. And we will counter sue him and your firm for pursuing a frivolous and fraudulent law suit.
As far as your suggestion to contact our attorney regarding this web site, we have gone over his head to the Bill of Rights of the Constitution of the United States. We believe you will find that the Freedom of Speech adequately covers this website and its contents.
Sincerely yours,

Michael Meadors
Karen Dudnikov
P.O. Box 87
Hartsel, CO 80449
Phone: 719-539-8032
cc: Grand west Financial, Ltd

Rebuttals
Karen and Mike are willing to give someone the opportunity to rebut anything said on this web site about them.
We will post that rebuttal, provided it is in good taste, sent it is to us in a format that can be copied, and it addresses the issues. We will not alter the rebuttal unless the content forces us to do so. Karen & Mike are the only ones responsible for the content of this web site. For those who really, really don't like what we say here, consider reading Paragraph I of the Colorado Court of Appeals decision concerning this web site, where the Court stated:
"...the website constitutes protected speech or press under the First Amendment."

	Michael Meadors Karen Dudnikov P.O. Box 87 Hartsel, CO 80449 Phone: 719-539-8032
cc: Grand west Financial, Ltd