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 O

quinn emanuel

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

WRITER'S DIRECT DIAL NO.
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December 26, 2015
VIA E-MAIL
[e-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:
Further to our letter of December 23, 2015 on behalf of our client Ryan Howard, we now
understand that Al Jazeera’s false and defamatory putative story alleging that Mr. Howard has
used performance enhancing drugs is premised on statements by Charles Sly that were relayed to
Al Jazeera by Liam Collins. We are further aware that Mr. Sly has unequivocally advised both
you and Deborah Davies in writing that these purported statements are false. Public sources
available to Al Jazeera also make clear that Mr. Collins is a known fraudster, who is currently
under a 14-year ban imposed by the United Kingdom’s Financial Services Agency (the “FSA”)
from serving as a director of any business entity after the FSA found that he ran what was in
effect a Ponzi Scheme that defrauded investors. See, e.g.,
http://www.thisismoney.co.uk/money/celebritymoney/article-2409740/Britains-Got-Talent-starLiam-Collins-handed-bankruptcy-ban-duping-investors-property-scam.html. Mr. Collins also
has a dubious history of publicity seeking, including an announced (but never consummated) bid
to purchase Michael Jackson’s Neverland Ranch and a campaign to join the UK Olympic
bobsledding team. Furthermore, public sources in the UK reported that, post-multi-million
dollar bankruptcy, he has even “busked” in Glasgow dressed in an Iron Man costume,
purportedly to fund his wedding. See, e.g.,
http://www.thescottishsun.co.uk/scotsol/homepage/news/5441426/Iron-Moan.html.
There can be no conclusion but that the sources for Al Jazeera’s statements regarding Mr.
Howard’s alleged use of performance enhancing drugs are patently unreliable. Moreover, we
have no doubt that Al Jazeera is well aware that its sources are untrustworthy and fallacious;
quinn emanuel urquhart & sullivan, llp
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indeed, Mr. Sly has explicitly disavowed his statements, which we understand were
surreptitiously recorded by Mr. Collins. Al Jazeera’s reliance on such sources, and its publication
of false and defamatory statements based thereon, would constitute malice. See, e.g., Biro v.
Conde Nast, ___ F. 3d. ___, 2015 WL 8103736, at *4 (2d Cir. Dec. 8, 2015) (reliance on
unreliable sources supports an inference of malice); Makaeff v. Trump University, LLC, 26 F.
Supp.3d 1002, 1008 (S.D. Cal. 2014) (same).
We, again, demand that Al Jazeera immediately cease and desist from making false, injurious
and defamatory statements regarding Mr. Howard’s alleged use of performance enhancing drugs.
We further request that you confirm you are authorized to accept service of process on behalf of
Al Jazeera, Deborah Davies, and Mr. Collins, in the event that Al Jazeera proceeds with
publication of these statements, despite its knowledge of their falsity. If you are not authorized to
accept service on behalf of Ms. Davies or Mr. Collins, please provide us with the names and
contact information of their attorneys as soon as possible.
Mr. Howard expressly reserves, and does not waive, any and all rights and remedies.

Sincerely,

/s/ William A. Burck

William A. Burck

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