You are hereby notified that you must cease and desist from using social media such as Facebook, Twitter, Instagram and / or any other form of communications that mentions, refers to, talks about, complains about, makes allegations against or make any reference of any kind to Carole Pope, CMA's English Mastiffs, CMA'S PAINT HORSES, LITTLE PATCH OF HEAVEN PAINTS to any person, organization, business, not for profit entity, breeders, the Humane Society of the United States, state, county, city and / or town animal control and management entities, and / or state, county, and / or town animal humane organizations, and / or to any citizen of the Unites States, and / or to any citizen, animal rights, animal humane organizations, government controlled animal management entities, and / or breeders in all other countries.
If you do not heed this warning immediately, you will be sued in Federal Court for Slander Per Se for monetary damages.
You have attacked my client's and her business ventures with clear intent to cause her economic damage and emotional distress.
You are obviously unaware and / or have chosen to ignore the fact that all charges against my client have been dismissed, her Mastiffs returned to her, her horses returned to her, and that I will be pursuing on her behalf a lawsuit against the persons and entities that unlawfully took her property.
You have continued to make numerous threats toward my client and published those threats on social media to various persons and websites almost on a daily basis. You have made numerous slanderous statements about my client that are easily documented.
You filed a false report with Pay Pal claiming that my client did not refund you the money that you put down to reserve a Mastiff puppy. Puppies were born on June 3, 2017 and you decided that you did not want a puppy. You were then refunded not only your full deposit but also refunded the $100 donation that you made for my client's horses.
Pay Pal who denied services to my client because of your false claim. Once Pay Pal learned that you had in fact been refunded all of your money they reinstated their services to my client.
You have cyber stalked my client.
You have used false profile names to defame my client.
You falsely claimed, posting to Pets4you, that I had been harassing you when in fact you, on numerous occasions, called my office even after being told not to and leaving voice mail messages slandering my client.
You sent private messages to my client's business and personal contacts on Facebook, slandering my client.
If and when you violate this Cease and Desist Notification, you will be sued.
Do not contact me. Do not contact Carole Pope and / or any of her family members, and / or her business enterprises.
/s/ I. Marshall Pinkus, Attorney for Carole Pope and her animal business enterprises.