HOWARD v. AL JAZEERA AMERICA, LLC et al

Filing 1

COMPLAINT against All Defendants with Jury Demand ( Filing fee $ 400 receipt number 0090-4367752) filed by RYAN JAMES HOWARD. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Civil Cover Sheet, # 23 Summons AL JAZEERA AMERICA, LLC, # 24 Summons LIAM J. COLLINS, # 25 Summons DEBORAH DAVIES)(Herman, Andrew)

EXHIBIT N

quinn emanuel

trial lawyers | washington, dc

777 Sixth Street NW, 11th Floor, Washington, District of Columbia 20001-3706 | TEL [phone] FAX [phone]

WRITER'S DIRECT DIAL NO.
[phone]
WRITER'S INTERNET ADDRESS
[e-mail]

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
Howard 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. Howard’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
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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 [phone] 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 [phone] or on his cell phone at
.

Sincerely,

William A. Burck

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