PUMPING THE LAW

Review of "Pumping Velvet" removed at the request of the filmakers lawyers @ www.novianlaw.com

Any questions about the removal of this review and the First Amendment? email: Josh@NovianLaw.com

Visit Lodger's Myspace Page. (Not affiliated or owned by filethirteen.com or norfolks.net)

From: Josh Mendelsohn Josh@NovianLaw.com
To: lodger@filethirteen.com
Sent: Tuesday, December 12, 2006 3:27 PM
Subject: FW: File Thirteen - Defamation

WE have not as yet received a response to the below. Unfortunately, should we not receive the same shortly, our client will be compelled to undertake litigation to resolve this matter. As such, kindly contact me via telephone at your earliest convenience. the foregoing is not intended as, nor shall it be construed as, a waiver of any of our client's rights or remedies, all of which are hereby expressly reserved.

Josh Mendelsohn

www.novianlaw.com

Novian & Novian, LLP
1801 Century Park East
Los Angeles, CA 90067
(310) 553-1222
(310) 553-0222
***********************************************************************
This message is intended solely for the use of the addressee(s) and is intended to be privileged and confidential. If you have received this message in error, please immediately notify the sender and delete all copies of this email message along with all attachments. Thank you.

-----Original Message-----
From: Josh Mendelsohn Josh@NovianLaw.com
Sent: Monday, December 04, 2006 1:00 PM
To: 'Lodger@filethirteen.com'
Subject: File Thirteen - Defamation

Please see the attached correspondence
Josh Mendelsohn

www.novianlaw.com

December 7, 2006 File No. 1034-5
VIA ELECTRONIC MAIL & U.S. MAIL
Norfolks.net

Re: Filethirteen.com - Defamatory And Improper Content

Dear Sir or Madam:
This office is litigation counsel to Aviddiva and Dustin Robertson (collectively referred
to herein as “Client”). This letter is being sent to notify you of the defamatory and dangerous
conduct and language contained on your domain www.filethirteen.com
Specifically, it has recently come to our attention that despite the fact that your client has
viewed the Film and attended a question and answer session where our Client was featured, your
client maliciously chose to publish purported statements of fact on the world wide web, which
are untrue and doubtlessly intended to expose our Client to hatred, contempt, ridicule, and
obloquy. What’s more, your client clearly intended to cause our Client to be eschewed and
avoided by the entertainment community, in an effort to damage his business and the significant
relationships related thereto.
Thus, putting aside the lack of common decency, morality and tact displayed your
customer’s web page, it is our position that the content displayed at
http://www.filethirteen.com/reviews/pumpingvelvet/pumpingvelvet.htm constitutes primarily
false and defamatory statements with respect to our client as it relates and that such content must
be withdrawn from the web immediately.
As you know, should Norfolks.net, being on notice of such wrongful content, and being
the registered owner of the relevant domain, is in a position from which it must take action to
remove this wrongful conduct from its domain. It is also our position that Norfolk.net is liable
Norfolk.Net

December 7, 2006
Page 2
for any damages sustained by our Client, should your company choose not to remove the
aforementioned page from the web.
Therefore, on behalf of our Client we hereby demand that you and those persons and/or
entities working with you or on your behalf immediately remove the above referenced webpage
from the worldwide web and refrain from making future use of the same. Accordingly, you must
immediately take corrective action to give notice to all parties that are acting for you or in
concert with you in connection with the unlawful actions that have been detailed herein.
Unless we receive written assurance from you or your counsel no later than by close of
business on December 14, 2006 that the aforementioned corrective steps have been taken, we
will have no alternative but to pursue all appropriate legal action against you in order to protect
our Client’s rights and goodwill, including without limitation, seeking general damages, special
damages, punitive damages and injunctive relief.
We therefore look forward to your immediate confirmation of your compliance with the
demands set forth herein above. The foregoing has been stated without prejudice to any of our
Client’s rights and remedies, all of which are hereby expressly reserved.
Very truly yours,
NOVIAN & NOVIAN, LLP
Josh Mendelsohn
JOSH MENDELSOHN
Cc: Client

www.novianlaw.com

Any questions about the First Amendment? email: Josh@NovianLaw.com

Lodger's Myspace page. (Not affiliated or owned by filethirteen.com or morfolks.net)