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July 31, 2000 VIA E-MAIL
Dear Mr. Wittenberg: Re: YMCA of Greater Toronto v. Uriel Wittenberg I represent the YMCA of Greater Toronto, together with Mr. Richard Bailey, Lesley Davidson and Greg Miller some of its officials. You have libelled each of them to various degrees in various documentation by suggesting they lie, are dishonest, act in bad faith and are corrupt. These are terrible libels. When you consult your legal counsel he or she will tell you that the damages (which are at large), could be immense and that you have no defence in suggesting that the individuals and the organization act in such a vile and despicable way. When you take this letter to your counsel he or she will ask where you have written such ill-advised and damaging remarks. You will of course refer him or her to your correspondence with Mr. Charlie Orr, and e-mails of May 14th and 16th to Linda Cottes, May 29th to Nicole Sinclair, June 5th, 6th and 7th with Derek DeCloet, letter of May 26th to members of the YMCA Board of Directors and Metro-Central Advisory Committee and Management Reform Campaign Memoranda, which contain the aforesaid libellous allegations. It is one thing to have differences of opinion, it is another to engage in character assassination. The purpose of this letter is to tell you to stop engaging in such libelous rhetoric. If you persist, the Court in any future action will be informed of the contents of this with prejudice letter, which will serve to increase damages. Yours very truly,
Julian Porter, Q.C.,
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