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not tay ber own

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"The only thing necessary for the triumph of evil is for good men to do nothing"
Edmund Burke


This email was received from kara Davis on Wednesday, January 2, 2008. It is recreated here in its entirety with some spacing added to make it more readable.

Subject: Re: Brandon and Andrea Poole - reply
From: Kara Davis karadavis35@yahoo.com
Date: Wed, Jan 02, 2008 12:22 pm
To: karen@tabberone.com

Ms. Dudnikov,

The name of my law firm is irrelevant to this case. I will not disclose this information to you due to privacy.

They are not basing any claims solely on the suspicious emails that you have received. Their claims are based on the libelous comments on your site. As you have stated on your site, your information is based on "fact" and opinion but what you do not understand is, when you are basing your information on facts, you must prove they are in fact, facts and supply the reader with proof of the fact. Otherwise, it's considered heresay and subject you to damages if a lawsuit is then filed against you. Andrea does not have to prove that they are not facts, you have to prove they are facts and furnish proof of your facts.

Your site is not informative when you come to the "Hall of Shame" page, it is then considered a hate and harassment page and a judge will agree as it does not contain anything informative, it contains links of people and businesses who in your opinion, have done something wrong to you or someone else, and this is your way of seeking revenge on them, either directly or indirectly by tarnishing their name or business which is punishable by law if one of them were to take you to court referring to article 22 of the Fair Trade Act.

We have also acquired emails from individuals stating you have emailed them through ebay inquiring about completed transactions between them and Tinytotsnteens. We have contacted ebay regarding these and will be faxing them over to them.

If you are inclined to believe they are persuing a case against you solely on emails, you are sadly mistaken.

They will be obtaining court orders to have the information on your site removed. They will be obtaining a court order to have your website shut down, and will be sending it to godaddy.com since your site is registered with them. You will not be allowed to run another hate website.

They are also waiting for responses/statements from other individuals on your "Hall of Shame".

Since you are not military and obviously do not understand what Opsec is, you are not permitted to list any names, addresses or locations of active-duty military members on any website due to security reasons.

You have also committed copyright infringement by stealing/using/borrowing trademarked/copyrighted work depicting the logo of Tinytotsnteens without permission.

Because you are not using it for "informative" purposes, you are subject to damages.

I don't think you have brushed up on the laws or consulted an attorney on this matter. Like I have stated, a smart attorney would advise you to avoid going to court and just cease and desist because as it stands right now, their case against you is very strong. Their command would not persue the matter if they felt it was a waste of time as the military does not work that way.

Kara Davis

----- Original Message ---- From: "karen@tabberone.com"
To: Kara Davis karadavis35@yahoo.com
Sent: Saturday, December 29, 2007 12:18:43 PM
Subject: RE: Brandon and Andrea Poole - reply

We were simply attempting to confirm your status as a paralegal. The name of your law firm will be revealed during discovery should the Pooles file.

We are not "required by law" to provide the Pooles with any "documentation" unless they take this into court. If they are basing their claims of defamation upon our refusal to furnish these emails and such, and it appears they are doing exactly that, they are in deep trouble.

Karen Dudnikov
Michael Meadors