Sent: Wednesday, July 29, 2020 1:50 PM
Cc: Joseph Tirello <[email protected]>
Subject: RE: Wilmington Trust v. Stoller Appeal
Mr. Stoller,
IMMEDIATELY remove my name and picture from your rentamark.net website and any other websites or social media where it may appear. You have a picture of me with my name and “CHARGED” written on top. Above that, it says “Kim R. Quam Charged with Home Title Fraud.” This is NOT TRUE. I have not been charged with fraud or any other crime.
Below that, you have a picture of my associate, Joseph Tirello. You wrote his name Joseph J. Tirello Jr and “charged with perjury” on his picture. IMMEDIATELY remove his name and picture from your rentamark.net website and any other websites or social media where it may appear. This is NOT TRUE. Mr. Tirello has not been charged with perjury or any other crime.
Further down the main page of your rentamark.net website, you have a heading saying “Kim R. Lepore, Lepore
We demand that you IMMEDIATELY remove my name, Mr. Tirello’s name, Mr. Zieve’s name and any other mention of us or the law firm of Zieve, Brodnax & Steele or ZBS Law, LLP from any and all websites.
Kim R. (Lepore) Quam
Managing Partner - Arizona
P: 602-282-6188 Ext. 203|F: 602-865-8086
[email protected]
AEAE RESPONSE:
LEGAL DISCLOSURE:
Kim R. Quam A/K/A Kim Lepore denies all charges. " You have a picture of me with my name and “CHARGED” written on top. Above that, it says “Kim R. Quam Charged with Home Title Fraud.” This is NOT TRUE. I have not been charged with fraud or any other crime." Ms. Kim R. Lepore-Quam, Mr. Joseph Triello, Les Zieve , the law firm of Zieve Brodnax & Steel. following attached Complaints which contain allegations only, all of the parties listed here have denied the charges and are considered innocent until proven guilty in a court of law. Any reference to Arizona Attorney Beth Mulcahy should be disregarded. as she has not be charged with anything.
To Prove Defamation Case?
What Do You Have To Prove? There are two things you have to prove to be true in order to win a case of defamation of character in the court of law. First of all, you have to prove without a doubt that what was said or written about you is not true. Once you have proved that the statement is, in fact, false you have to prove that the other person said the false statement with the intent of causing you some form of harm.
The Fair Reporting Privilege is a defense to any claim of Defamation
The Fair Report Privilege applies to the information contained on this web site.
“[T]he fair report privilege has two requirements: (1) the report must be of an official proceeding; and (2) the report must be complete and accurate or a fair abridgment of the official proceeding. [Citation.] *** For a publication to be considered a fair abridgment, the report must convey to readers a substantially correct account of the official proceedings. [Citation.] A reporter is not privileged to make additions of his own that would convey a defamatory impression or to indict expressly or by innuendo the veracity or integrity of any of the parties. [Citation.] Finally, it is the accuracy of the summary, not the truth or falsity of the information being summarized, that is the benchmark of the privilege. [Citation.]” (Internal quotation marks omitted.) Eubanks, 397 Ill. App. 3d at 749 (citing Solaia Technology, LLC v. Specialty Publishing Co., 221 Ill. 2d 558, 588-90 (2006)). ¶ 30
AEAE argues it reports on the law and law suits and it is the intent of AEAE to "fairly report" these official proceedings.
AEAE has the legal right to evaluate and rate attorneys, government officials, College educators, business leaders See JOHN HENRY BROWNE, et al., AVVO, INC., et al Case No. C07-0920RSL UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 18th day of December, 2007. A Robert S. Lasnik United States District Judge
VERITAS OMNIA VINCIT
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