Filing 1

COMPLAINT against All Defendants with Jury Demand ( Filing fee $ 400 receipt number 0090-4367715) filed by Ryan C Zimmerman. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Civil Cover Sheet, # 23 Summons, # 24 Summons, # 25 Summons)(Lerner, Scott)

Download PDF
EXHIBIT N quinn emanuel trial lawyers | washington, dc 777 Sixth Street NW, 11th Floor, Washington, District of Columbia 20001-3706 | TEL (202) 538-8000 FAX (202) 538-8100 WRITER'S DIRECT DIAL NO. (202) 538-8120 WRITER'S INTERNET ADDRESS williamburck@quinnemanuel.com December 23, 2015 VIA EMAIL AND U.S. MAIL Robert Corn-Revere Davis Wright Tremaine LLP Suite 800 1919 Pennsylvania Avenue NW Washington, D.C. 20006-3401 Re: Al Jazeera Dear Mr. Corn-Revere: We are writing further to our e-mail of December 18, 2015 regarding Al Jazeera’s planned broadcast of the false, unfounded, and defamatory allegation that our client Ryan Zimmerman has used a performance enhancing drug named “Delta 2.” As we previously stated, our client unequivocally and emphatically denies that he has used Delta 2 or any other performance enhancing drug. Should Al Jazeera publish this false and defamatory accusation, our client will suffer grave and irreparable harm to his reputation and to his existing and future business relationships. This falsehood constitutes, at the least, defamation, see, e.g., Pacquiao v. Mayweather, 803 F. Supp. 2d 1208, 1211-13 (D. Nev. 2011) (false statements that boxer used performance enhancing drugs support claim for defamation per se); tortious interference with contract, see NCRIC, Inc. v. Columbia Hosp. for Women Med. Ctr., Inc., 957 A.2d 890, 901 (D.C. 2008); and tortious interference with prospective economic relations, see PM Servs. Co. v. Odoi Associates, Inc., No. CIV.A. 03-1810 (CKK), 2006 WL 20382, at *35 (D.D.C. Jan. 4, 2006) (citing Bennett Enter., Inc. v. Domino's Pizza, Inc., 45 F.3d 493, 499 (D.C. Cir.1995)). Further, your refusal to identify the sole alleged source of this spurious charge or to provide any other information regarding the basis for this allegation demonstrates that Al Jazeera has no interest in getting to the truth of this matter. It is, therefore, clear that any false, defamatory, and destructive statement related to this matter that Al Jazeera publishes will be published with actual knowledge of its falsity or with reckless disregard as to its truth or falsity. We hereby demand that Al Jazeera immediately cease and desist from making false and injurious statements regarding Mr. Zimmerman’s alleged use of performance enhancing drugs. If you refuse to do so, our client will take any and all appropriate steps to protect his rights and quinn emanuel urquhart & sullivan, llp LOS ANGELES | NEW YORK | SAN FRANCISCO | SILICON VALLEY | CHICAGO | WASHINGTON, DC | HOUSTON | SEATTLE LONDON | TOKYO | MANNHEIM | MOSCOW | HAMBURG | PARIS | MUNICH | SYDNEY | HONG KONG | BRUSSELS interests, including, but not limited to, commencing litigation against Al Jazeera and Deborah Davies seeking monetary damages (including punitive damages), injunctive relief, and any other legal remedies available at law or in equity. Nothing contained herein shall be construed as a waiver of any of our client’s legal or equitable rights or remedies with respect to these matters, all of which rights and remedies are hereby expressly reserved. We ask that you contact me at (202) 538-8120 or on my cell phone at at your earliest convenience and in no event later than Thursday, December 24, 2015, to confirm that Al Jazeera will not broadcast these inaccurate and defamatory claims. If you are unable to reach me, please contact my colleague, Kevin Reed, at (212) 849-7160 or on his cell phone at . Sincerely, William A. Burck 2

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?