Dover & Dixon
A Professional Corporation
Attorneys at Law
425 West Capitol
Suite 3700
Little Rock, Arkansas 72201
June 7, 1996
VIA FACSIMILE 1-909-925-4550 Certified/Restricted
Integrity Films
Pat Matrisciana, President
P.O. Box 220
Winchester, CA 92596
RE: Obstruction of Justice: The Mena Connection
Dear Mr. Matrisciana:
Thank you for your facsimile of June 4, 1996.
If you will review my initial request, you will see that I requested to
be provided with the factual basis and verification process for the
statements pertaining to Jay Campbell and Kirt (sic) Lane. Your letter,
however, only provides conclusions such as you "are comfortable with the
contents of [the] video", that the story was "researched and
investigated for more than two years", and that "a great deal of care
was taken that the information presented be credible and verified."
Your conclusions fall well short of my request and the burden-of-proof
required in a court of law.
If you have "sufficient evidence" to support the statements regarding
my clients, why not disclose it now so that a potential defamation
action can be properly evaluated? We do not want to sue anyone who has
complied with the requirements of the First Amendment and other
applicable laws. Your letter, however, simply highlights our belief
that there was no factual basis or verification process for making the
false statements.
If you do not provide the requested information within ten (10)
business days we will deem your silence as an admission to a lack of
compliance with the law and will immediately initiate a lawsuit. You
will receive no more notices from this firm.
Very truly yours,
DOVER & DIXON
M. Darren O'Quinn
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