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)

Exhibit G

PICERNO & ASSOCIATES, PLLC
Attorneys At Law
36-40 Main Street-8uite 306
Flushing, New York 11354
Tel: [phone] Fax: [phone]
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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.

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--\ngd.o.R. Picemo, Esq.