March 07, 2008
Sent by: [Private]
Cadwalader, Wickersham & Taft LLP
New York, NY, 10281, US
General Counsel and Legal Coordinator
Wikimedia Foundation, Inc.
San Francisco, CA, 94107, USA
Sent via: email, fax, and e
Re: Defamation of Solomon Trujillo
Dear Mr. Godwin:
We represent [individual] and are writing to demand that defamatory statements that appear on Wikipedia immediately and permanently be removed from the following URL:
Specifically, an anonymous user (IP 22.214.171.124) (the "anonymous user") has since at least March 1, 2008 repeatedly inserted the following false and defamatory language in the referenced article:
This false and defamatory assertion has been repeatedly removed, but the anonymous user keeps replacing the false and defamatory language.
We demand that Wikipedia and Wikimedia permanently remove the above language from the article, including all of its history pages, and to permanently block the anonymous user from editing the page by 7 o'clock eastern time today. If Wikipedia and Wikimedia do not remove the improper language by that time, and take the steps necessary to block its being reinserted, Mr. [individual] intends to commence litigation against Wikipedia and Wikimedia on Monday, March 10, 2008.
Very truly yours,