VIA EMAIL AND CERTIFIED MAIL August 1, 2023 Attn: Scott C. Smith City Attorney City of Laguna Niguel 30111 Crown Valley Parkway Laguna Niguel, CA 92677 Best Best & Kreiger, LLP 18101 Von Carmen Avenue Suite 1000 Irvine, CA 92612 Dear Mr, Smith: Re: Cease and Desist for Defamation of Character and Online Harassment Lam Ofiees of Michelle R fakoo
This letter serves as a formal notice to the City of Laguna Niguel (the "City"), including specifically Mayor Pro Tem Stephanie Oddo and Council Member Ray Gennawey, to immediately cease and desist from making defamatory statements(s) about me. Additionally, please instruct the City and its Council to cease and desist from the continued cyber harassment of me, including by removing the harassing YouTube video from all City related sites and materials, including those shared by the City Council Members. The City, acting through Mayor Pro Tem Stephanie Oddo and Council Member Ray Gennawey, during its July 26, 2023, which was aired live on Cox Cable Channel 853, AT&TU Verse Channel 99 and on the City's YouTube Channel at www.youtube.com/cityoflagunaniguel, and available to be rebroadcasted and shared on the City's YouTube Channel made several untrue, harassing and/or misleading statements including, but not limited to the following: Referring to my demand as a, "disingenuous demand". Stating that I was not, "operating in good faith". 34189 PCH, Suite 204 Dana Point, CA 92629 (949)606-2674 Stating that the demand letter sent by me to the City on behalf of my client represented, "the kind of lawyering that gives lawyers a bad name". Repeatedly referring me to as, "Jackson-Brough" when that is never how I have referred to myself nor have I ever used such hyphenation on the California State Bar web page. Using the pronoun, "he' when I have never utilized that pronoun. Stating that I am, presenting myself as an angry wife". Stating that I am committing political retaliation." Calling me a "bad actor".
The false and harassing statement(s) and personal attacks are unfounded, and have questioned my character and professional integrity causing harm to my businesS reputation among my clients. Please be apprised that the City must immediately cease and desist from making further defamatory and harassing statements and has five (5) days to remove all defamatory and harassing statement(s) from the City website, City YouTube sites, and City Councilmember's written statements, including those posted on any other social media platforms, and issue me an apology. Additionally, I suggest that in your role as the City Attorney you encourage the City Council Members to enroll in additional gender bias training for the abhorrent display of sexism exhibited by the City. This is my final notice to you before I take legal action against the City as well as certain members of the City Council, If you would like to discuss the matter, please do not hesitate to contact me at (949) 606-2674.
CC: Mayor Kelly Jennings Mayor Pro Tem Stephanie Oddo Council Member Ray Gennawey Council Member Foster "Gene" Johns Council Member Stephanie Winstead Tamara Letourneau, City Manager Marissa Asistin, City Clerk, 2 Sincerely,
Michelle RJaçkson, Esq.