ATTENTION BRIONY WOLF




CEASE AND DESIST


2/12/2018
Sent via Email to
brionywolf@gmail.com
Cape Town, South Africa

Dear Briony Wolf

If you are represented by legal counsel, please direct this letter to your attorney immediately and have your attorney notify me of such representation.

You are hereby directed to CEASE AND DESIST ALL DEFAMATION AND TARGETED CYBER-STALKING / HARASSMENT AGAINST MYSELF, REBECCA A. RODRIGUEZ.

I am an accomplished filmmaker and animal advocate. I have spent years successfully creating filmed content, helping animals and rescue organizations around the world and building a positive reputation. I am aware that you have engaged in targeted harassment, cyber-stalking and defamation as a means of spreading false and destructive rumors about me and in an effort to extort money from me.

Under South African law, it is unlawful to:
  • a.     Defame another living person which is defined as “any unlawful, intentional false communication, either written or spoken, that harms a person’s reputation; decreases the respect, regard, or confidence in which a person is held; or induces disparaging, hostile, or disagreeable opinions or feelings against a person.” “Publishing” means almost any form of communication, spoken or written or even a non-verbal statement, such as an image that is communicated to at least one person apart from the plaintiff. Something is considered to be published not only by the person who originated it, but also by anyone who subsequently repeats it. Clearly, the liability for defamation is potentially very wide, a scope that reflects the law’s investment in human dignity and reputation in particular.
  • b.      Commit Crimin Injuria by “Unlawfully, intentionally and seriously impairing the dignity of another”. “An example of crimin injuria would include verbally insulting or abusing, stalking, or threatening to harm someone, or making known a person’s privileged or private information without their prior consent. Ridiculing someone’s ethnicity using racially offensive language, or ridiculing someone’s religious affiliation, sexual identity or sexual preference, may constitute crimin injuria, especially where such ridicule causes emotional or psychological harm to others.
  • c.     Commit Fraud by impersonating an individual and representing yourself accordingly.


In addition, you could be charged criminally and/or civilly with:


  • Harassment, which means directly or indirectly engaging in conduct that the  respondent knows or ought to know (a) causes harm or inspires the reasonable belief that harm may be caused to the complainant or a related person by unreasonably (i) following, watching, pursuing or accosting of the complainant or a related person, or loitering outside of or near the building or place where the complainant or a related person resides, works, carries on business, studies or happens to be; (ii) engaging in verbal, electronic or any other communication aimed at the complainant or a related person, by any means, whether or not conversation ensues; or (iii) sending, delivering or causing the delivery of letters, telegrams, packages, facsimiles, electronic mail or other objects to the complainant or a related person or leaving them where they will be found by, given to, or brought to the attention of, the complainant or a related person;
  • Extortion, which is defined as a person unlawfully and intentionally obtaining some advantage either of a patrimonial or a non-patrimonial nature, from another by subjecting him or her to pressure which induces him or her to submit to the taking.


Your false statements that defame me, infringe on my right to dignity, constitute harassment against me, serve as attempted extortion and reflect your impersonation of me are contained in numerous blogs, social media pages and posts on the internet. All of which has been preserved as evidence for presentation in court, if necessary.

The known locations of your published harassment against me and evidence of the crimes you are committing, can be found at:


  1. You have publicly claimed that I have committed crimes that I have not committed nor been charged with.
  2. You have publicly threatened to report me to law enforcement for the fabricated crimes.
  3.   You have demanded that I give money to the NGO that you support, CEE4Life, that they are not entitled to.
  4. You have publicly cast suspicion against my lawful business practices.
  5. You have publicly cast suspicion against me within my professional circles.
  6. You have fabricated and published false information about me and my business practices.
  7. You have directly and publicly impersonated me.
  8. You have published numerous humiliating insults about me.
  9. You have publicly harassed me and my associates.


 Accordingly, I demand that you

a.      immediately cease and desist your unlawful defamation
b.      remove all content related to me and my associates
c.       provide me with prompt written assurance within ten (10) days that you will cease and desist from further defamation of my character and reputation and
d.      Provide a written apology for the defamation of character and reputation you directed against me.

If you do not comply with this cease and desist demand within this time period, I will finalize my relationship with a legal representative in Cape Town, South Africa and seek monetary damages and equitable relief for your offenses against me.

In addition, I will submit my prepared complaint to the South African Police and the South African Fraud Prevention Service for the serious offenses of cyberstalking / harassment, attempted extortion and fraud.

In the event you fail to meet this demand, please be advised that I will pursue all available legal remedies, including seeking monetary damages, injunctive relief, and an order that you pay court costs and attorney’s fees.

Before taking these steps, I am giving you one opportunity to discontinue your illegal conduct by complying with this demand within ten (10) days. Accordingly, please sign and return the attached Defamation Settlement Agreement within ten (10) days to:

Rebecca A. Rodriguez
PO Box 643
La Center, WA 98629
rebecca@oneanimalworld.com

If you doubt the validity of my claims, I recommend that you consult with an attorney in South Africa, as I have done. If you or your attorney have any questions, please contact me directly.

Sincerely,

Rebecca A. Rodriguez
PO Box 643  La Center, WA 98629

_________________


CEASE AND DESIST COMPLIANCE AGREEMENT

I, Briony Wolf, do hereby agree to stop harassing, cyberstalking, impersonating, defaming and attempting to extort money from Rebecca A. Rodriguez, which are in violation of Rebecca Rodriguez’s rights and of South African Law. I understand that this is my final chance to cease these activities. I understand that Rebecca A. Rodriguez potentially has the right to pursue legal action against me relating to my engagement in these activities, but she will not pursue those rights in contemplation of my compliance with this written demand. I further understand that Rebecca A. Rodriguez has not waived her rights and may pursue legal remedies against me if I fail to abide by this agreement. I understand that this agreement is not specifically limited to the activities named herein. I will not engage in any activity now or in the future done for the purpose of stalking, harassing, defaming or extorting money from Rebecca A. Rodriguez. I furthermore agree not to engage in any activity, regardless of its official title, that is done in violation of Rebecca A. Rodriguez’s legal rights. If I fail to cease performing these activities, Rebecca A. Rodriguez may pursue legal action against me in accordance her legal rights. This agreement acts as a contract between Briony Wolf and Rebecca A. Rodriguez. Forbearing enforcement of legally enforceable remedies is sufficient consideration to support this agreement. This agreement represents the entire agreement between the parties. Any statements made orally, written, or otherwise which are not contained herein shall have no impact on either parties’ rights or obligations elaborated in this agreement.

Date ____________________

________________________
Briony Wolf

________________________
Signature


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