Modify replied to Berryhill, but the original was not kept. The following reply from Berryhill quotes most of Modify's original mail. Single quoted material is Modify, doubled quoted material is Berryhill.

Date: Sun, 17 Sep 2000 23:08:27 -0400
From: "John Berryhill Ph.D. J.D." (
To: Modify (modify[at]
Cc: comega[at], jericho[at]
Subject: Re: Polite Request

: I hate to tell you but laws change from state to state but im sure you
: being the astute lawyer already know that.  Cause your better than
: everybody else.. right?

Now you can look up "long-arm statute" in your Cliff's notes on law.

: Why are you waiting then?  March yourself down to the Eastern District of
: Pennsylvania and file your complaint.  We simply retained a copy of the
: hacked page for our archive which we do for all of our hacked sites that
: we are alerted about.

I said that I understand your project.  Your project does not give you the
right to republish that page.  I have worked with the administrators of the
MMS site and other federal authorities to identify the author, whom you will
meet when you come to Philadelphia to argue unsuccessfully against
jurisdiction there.

: (READ: We didn't write it).

READ: It doesn't matter.

: : will be welcome to come to Philadelphia and to discuss the cases you cite on
: : your disclaimer page in that court.
: Uhhhhhh... yea, thats what I want to do with my free time.  I wonder how
: this case will turn out and what jurisdiction the state of Pennsylvania
: will have over a server that resides in AZ with its admins spanning across
: the United States.  Heck toss the government into the mix.  I'd be amazed
: if the court didn't laugh at you.  Heck, I'll pay for the price of air
: fare to see that.

Republishing defamatory information and posting the credit card number of an
individual in the state Pennsylvania renders you subject to jurisdiction in
Pennsylvania.  If you think that state lines provide some magic protection
against that, you are sorely mistaken.  But that will be your problem, not

You and your colleague have provided ample indications of your demeanor, and
your responses will be introduced on the issue of intent.

Have a nice day.

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