Refractive Surgery News

Glenn Hagele / USAEYES / CRSQA Threatens to File Frivolous Lawsuits Against Five Patients

LAW OFFICE OF
K. GREG PETERSON

March 2, 2006

VIA UPS OVERNIGHT DELIVERY

Brent Hanson
11 Wickersham Drive
Durham, NC 27713

Re:    Defamation of Glenn Hagele

Dear Mr. Hanson:

Glenn Hagele has retained our law firm in connection with written statements you have published or caused to be published either through public Internet forums, Internet websites you control, email, and/or conventional mail.  Demand is herewith made that you stop publishing the false statements concerning our client and that you take prompt corrective action, absent which we shall have no choice but to seek appropriate legal redress.

You have made written statements of fact, rather than opinion, that appear to violate Mr. Hagele's constitutional rights, place him in a false light, tend to injure and in fact do cause injury to our client's occupation and character, and/or expose him to hatred, contempt, ridicule or shame.  Moreover, we believe your written statements constitute defamation per se - all of which have caused our client substantial injury and interfered with his ability to conduct his business.

Mr. Hagele herewith demands of you the following: 

1. Immediately remove or cause to be removed all publicly accessible Internet newsgroup, bulletin board, or chat room statements about him, his employer, and/or his business associates, which may be decided by the court as defamatory and refrain from publishing or republishing any and all future statements that may be considered defamatory;
    

2. Immediately remove or cause to be removed those portions of all publicly accessible Internet web pages you control that include statements about him, his employer, and/or his business associates, which may be decided by the court as defamatory and refrain from publishing or republishing any and all future statements that may be considered defamatory;
    

3. Immediately privately retract all statements about him, his employer, and/or his business associates that may be decided by the court as defamatory and were distributed via email, conventional mail, or any other private means and refrain from publishing or republishing any and all future statements that may be considered defamatory.

This is your opportunity to resolve this matter without legal expense and exposure to liability and damages.  Mr. Hagele retains his right to all legal means to seek redress of losses caused by your prior acts, however, removal of your statements will mitigate damage already caused.

Accordingly, if the offending written statements are not removed or retracted within 72 hours, further legal action will be taken.

If you have any questions regarding the above referenced matters, please do not hesitate to call us.

Very truly yours,
James A. Clinchard

cc:    Glenn Hagele