From: "John Berryhill Ph.D. J.D." (
To: (comega[at], (modify[at], (jericho[at]
Subject: Polite Request
Date: Sat, 16 Sep 2000 14:15:47 -0400

Okay, here's the deal.

I understand your project and I read your disclaimer.

Unfortunately, you are not similarly positioned to an ISP, and I am quite
familiar with the law in this area.

I am asking you politely to take down the following material:

If the material is not taken down by November 30, 2000, then I am walking
from my office to the US District Court for the Eastern District of
Pennsylvania, and I am filing a complaint against you for defamation.  You
will be welcome to come to Philadelphia and to discuss the cases you cite on
your disclaimer page in that court.

An ISP is a carrier of information and does not have editorial control over
the information.  You do.   I am a practicing attorney, and it is not my job
to give you a legal education.  In whatever source you are learning about
defamation law, look in the index under "republication", and that might be of
interest to you.


John B. Berryhill, Ph.D. J.D.
Dann, Dorfman, Herrell, & Skillman P.C.
1601 Market St. , Suite 720
Philadelphia, PA 19103
(215) 563-4100 voice
(215) 563-4044 fax

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