Lee v. Makhnevich et al

Filing 1

COMPLAINT against Aster Dental, Stacy Makhnevich. (Filing Fee $ 350.00, Receipt Number 465401023090)Document filed by Robert Allen Lee. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit)(rdz)

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Exhibit G PICERNO & ASSOCIATES, PLLC Attorneys At Law 36-40 Main Street-8uite 306 Flushing, New York 11354 Tel: (718) 445-1233 Fax: (718) 445-4405 _-\ng.:;o R Pi.::emo. Parmer Carri.: Zou. Legal Assistant Yincce Chan. Legal _--\ssistant Michael Stea, Andrea Blair, Jeffrey Davis, James Lisa, Of Of Of Of Counsel Counsel Counsel Counsel Robert Lee 2000 Lower Marlboro Road Huntingtov.TI, MD 20639 Re: South East Dental Suite Y. Robert Lee Violation of:Ylutual Confidentiality Agreement. ~otice to Cease and Desist Defamation, Slander and Libel Please be informed that we are the attorneys for South East Dental Suite with regards to the abovementioned matter. Please be advised that you have signed a Mutual Agreement to Maintain Privacy when you were enlisted as a patient on November 4,2010 willingly. In the Agreement, it clearly states that both Dentist and Patient will work to prevent the publishing or airing of commentary about the other party from being accessed via Internet, blogs, or other electronic, print, or broadcast media without prior written consent. You have agreed to refrain from directing or indirectly publishing or airing commentary upon Dentist and their practice. This Agreement was enforceable for a period of five (5) years from the Dentist's last date of service to Patient or three (3) years beyond any termination of the Dentist-Patient relationship, whichever period is longer. In the fifth (5th) paragraph ofthe Agreement, you have acknowledged that if you were to breach the Agreement, you would be liable to any and all compensation with regard to the consequential damages. In the final paragraph, you have signed that you have been given the opportunity to ask questions with regards to the Agreement and that you have received satisfactory and adequate explanations with regards to such. It is our understanding that you had an issue with the accounting department. Instead oftrying to settle the issue with the accounting department, you published defamatory commentaries on "Yelp", "DoctorBase", and "Vimo" communication with regards to Dr. Stacy Makhnevich and her office without any verification. With regards to the Mutual Agreement to Maintain Privacy, These posts were all tracked to be dated on August 24, 2011. Please be informed that accordin~ to The Ethics of Medical Justice / Dental Justice Agreements, under the Code of Internet Ethics. your comments are not considered constructive commentaries but rather as personal attacks to the office's well-being and reputation. Please be further informed that such posts directly violate the Mutual Agreement that you have signed. Your posted comments included damaging inferences which denigrate, defame, and cast aspersions upon the dentist and the dental office. Please allow this correspondence to inform you that all legal possible actions will be taken against you in which you "ill be responsible for any judgment made against you. -_.q).. lbfr.. ยท ~ ~ l/ --\ngd.o.R. Picemo, Esq.

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