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Email Exchange Between Reese Boyd III & Bob Sakayama

All emails were sent 20-21 November 2009
Scroll down and read from the bottom up.

Mr. Sakayama:

My correspondence and subsequent email to you were not intended to be
and were in no way libelous to you. Certainly no offense was intended
by any of our communications, and I apologize if any was taken.

Like any thorough lawyer would have, I have attempted in this process
to secure all the potential loose ends that I saw as existing or
potentially developing, through a fairly simple and straightforward
memorandum settlement agreement, without making a "federal case", so
to speak, out of what appeared as though it should have been a
relatively simple matter to resolve.

My apologies if my correspondence or email was taken as offensive;
again, no offense was intended.

As you may be aware, parties are generally afforded wide latitude in
the settlement negotiation process to "clear the decks" of all issues
between the parties, and certainly nothing said between the parties in
such context may be slanderous, nor is it admissible in a court of
law. I would reiterate to you now that these in fact are settlement
discussions, that nothing said here has been (or can be) slander or
libel, and that nothing said here is admissible in any court
proceeding. We are, and have been, merely attempting to resolve a
dispute (if that is what this can be called) that should be (it would
appear) relatively solvable through a simple discussion between the

In the interest of such resolution, and so that the parties may "move
on", so to speak, DSL Marketing has agreed to issue a check to you for
payment of your outstanding balance, in full. This check will be
noted as "payment and settlement in full" with respect to the
referenced account, a step well within my client's rights under
applicable law. Whether you choose to cash the check is certainly
your decision; however, it will be deemed at law as payment in full
and settlement of all claims related to your account with DSL
Marketing when endorsed or deposited by the payee.

Again, whether or not you are willing to sign a general release and
non-disparagement agreement, which apparently you are not, it is
incumbent upon me to remind you that any effort to libel, slander or
otherwise harm my client will be dealt with immediately by DSL
Marketing to the fullest extent of any remedy available to them at
law. (Again, this remark is not intended to imply that you have
engaged in any unlawful or tortious conduct, or that we believe you
will engage in such conduct. It is merely a statement of fact, and
one that any competent lawyer would make under such circumstances.)

We will advise when the check has been forwarded. Should you have
further questions, please do not hesitate me.

Yours sincerely,

Reese Boyd III

cc: Trey Harris

On Nov 20, 2009, at 10:42 PM,

> Mr. Boyd,
> Regarding your document:
> According to counsel, your informal email explanation of your
> intention is
> not reflected in the language of your document, and we view this
> email as
> an attempt to roll back a legal misstep. There is no doubt that your
> document implies malfeasance and corrupt behavior on my part. I
> consider
> those implications libelous, as is the attempt to coerce me to agree
> to
> terms that suggest future unlawful behavior. I have no intention of
> signing it and am seeking an opinion as to whether we have an issue to
> support further actionable recourse.
> In addition to the implied criminality evident everywhere within your
> document, the attempt to silence me is one I reject out of hand. We
> retain, and intend to exercise, our right to publicize the nature,
> substance and background of this dispute, and will do so relying on
> the
> truth, not defamation, libel or slander, and will do so within the
> law.
> Your threat of legal action compounds the existing damage and, when
> placed
> in the proper context, only increases the odds that this story will
> gain
> traction, and that your client will be further damaged by it.
> Your involvement is especially disturbing since your client is
> attempting
> to use your influence to impose conditions on the payment of a long
> outstanding debt, while placing a curtain around his own
> malfeasance. We
> reject all such conditions. I am confident that the motives behind
> your
> document will not be viewed favorably once the facts are known. Out
> of
> professional respect for you, and knowing you've only heard one
> side, I
> will set the record straight, because your understanding is at odds
> with
> the truth, and the misstatements and misconceptions expressed in your
> document are manifold.
> Regarding the facts:
> We unwound a Google penalty for this client in February 2009. It was
> caused by coding errors made by your client's staff. What you need to
> understand is that we corrected this problem without ever accessing
> his
> servers or other infrastructure. All the work for the unwind was
> done by
> his staff, with our guidance. We never had access. WE NEVER HAD
> So it is ludicrous to assume that we can "undo" anything as alluded
> to in
> your document since we do not have access to his secure server
> environment. To claim such a thing demonstrates irresponsible
> ignorance,
> and grossly misleads the argument. I am deeply offended by your
> implied
> criminality.
> This is also true for your other specious accusations - that we
> could use
> computers to corrupt infrastructure or gain control of rankings
> somehow,
> or that we could disrupt the ability of 3rd parties to access
> websites.
> These are outrageously bogus claims that reveal a disturbing level of
> paranoia about the internet infrastructure. All of your implied
> malfeasance and the inclusion of these specific accusations in your
> document are at best offensive, unreasonable, and unwarranted. They
> are
> libelous and inflame rather than lead to resolution.
> If his staff has once again inadvertently triggered a penalty, then
> there
> is a precedence that needs to be looked at closely before assuming
> that
> responsibility lies elsewhere. Any attempt to blame me and
> therefore not
> pay an outstanding debt because of some misplaced notion of my
> capability
> is outlandish and deserves severe pushback. We reject this notion
> and you
> must not be misled by your client's inexcusable ignorance.
> All attempts to collect the unpaid balance were fruitless, and there
> were
> many. However, each attempt provided an opportunity to discuss said
> balance, but instead promises of payment were proffered. Those
> promises
> were later revealed to be lies. So any request to, at the last
> minute,
> "discuss" this debt is pointless, and will not occur. Your client's
> intention was always to defraud.
> Multiple excuses, all later confirmed to be lies were told directly
> to me
> regarding the reasons for non-payment. These tales included the
> despicable act of blaming others, including former employees. These
> are
> innocents who we knew were completely out of the loop, and they were
> never
> present to defend themselves against the false accusations made by
> your
> client. I have maintained good relationships with these people who
> will
> confirm these facts as I have stated them. From them we know of other
> vendors who were similarly defrauded of their fees. There is a
> pattern
> here of unethical behavior of which you may be unaware.
> Regarding resolution:
> Because my deadline was ignored, resolution is no longer a simple
> matter
> of payment of fees owed. But to not appear unreasonable, I am open
> to any
> proposal in which unconditional payment is the first step.
> This is now a matter of principle for me. Something your client
> does not
> understand.
> Bob Sakayama
> TNG/Earthling, Inc.
> 110 West 86th Street
> NYC 10024 USA
> 212 799-4181
>> Mr. Sakayama:
>> I apologize for the email, but in the interest of time I am
>> responding
>> to your correspondence informally. For the record, I am not
>> suggesting anything in my earlier correspondence, except my client's
>> desire to be clear that his payment of your invoice will in fact end
>> the acrimony between the parties, and that you will not use your
>> knowledge of his businesses and infrastructure that you gained in the
>> course of your work for him to harm him in the future, and that there
>> will likewise be no disparagement by either party of the other going
>> forward.
>> It's is certainly not my client's desire to "go to war", so to speak,
>> over such a relatively modest sum of money. My client is simply
>> trying to resolve the concerns he had, when he attempted to have a
>> discussion with you previously concerning your invoice, the end
>> result
>> of such effort being the matter escalated to a level of acrimony that
>> my client was not comfortable with and could not resolve. I was then
>> asked to assist in resolving the matter, which at that point appeared
>> to have escalated beyond proportion.
>> My understanding of the facts, if it will assist you, is that my
>> client expressed a desire to discuss some questions about the invoice
>> in question, and that you expressed no interest or willingness to
>> speak with him about his questions, upon which you then began to send
>> a series of emails to my client that were generally of a threatening
>> tone or import. If the tone of your emails was misinterpreted, and
>> you in fact mean no harm to my client, then there is no issue, and no
>> reason for my client not to pay your invoice so that we can all put
>> this discussion behind us. I simply need to confirm if that is the
>> case.
>> The only other request I included in my letter was my request for
>> your
>> assurance that you will agree to the general non-disparagement terms
>> suggested therein (which again, is not an issue from my client's
>> perspective, as my client has no intention of disparaging you in any
>> case).
>> If you would like to state your position in any way differently the
>> formulation I have suggested in my letter, I'll certainly consider
>> your position. If I have mis-stated anything in your opinion, I
>> would
>> welcome your clarification. Again, this matter has gotten to this
>> point for reasons that are not abundantly clear to me, but I think it
>> certainly in everyone's interest to simply bring the matter to
>> closure, have my client pay your bill, and for the parties to part
>> ways with the very reasonable mutual assurance to one another that
>> this matter has indeed been put to rest.
>> Are we not all on the same page in that regard?
>> Sincerely,
>> Reese Boyd
>> Begin forwarded message:
>>>> From:

>>>> Date: November 20, 2009 1:43:52 PM EST
>>>> To:

>>>> Cc:
, "Lynne " >,

>>>> Subject: Re: DSL Marketing, Inc.
>>>> I am being advised to respond to your document as follows:
>>>> Nothing we have done is outside the law, and it is our intention to
>>>> keep
>>>> our actions within a justifiable legal framework. It is clear from
>>>> this
>>>> document that there is a complete lack of understanding of the
>>>> issues at
>>>> hand, although it suggests unlawful behavior. We consider any such
>>>> suggestion to be libelous.
>>>> By the close of business today, the deadline for payment will have
>>>> passed.
>>>> Bob Sakayama
>>>> TNG/Earthling, Inc.
>>>> 110 West 86th Street
>>>> NYC 10024 USA
>>>> 212 799-4181
>>>> ---------------------------- Original Message
>>>> ----------------------------
>>>> Subject: DSL Marketing, Inc.
>>>> From: "Patti Wolfe" >
>>>> Date: Fri, November 20, 2009 9:43 am
>>>> To:

>>>> --------------------------------------------------------------------------
>>>> Mr. Sakayama:
>>>> Please see attached correspondence from Reese Boyd III, attorney
>>>> for
>>>> DSL Marketing, Inc.
>>>> The attached is a convenience copy; the original letter is being
>>>> forwarded to you via U.S. Mail.

>>>> Should you have any questions, please do not hesitate to contact
>>>> us.
>>>> Sincerely,
>>>> Patti Wolfe
>>>> _____________________________
>>>> Patti Wolfe
>>>> Executive Assistant
>>>> Boyd Law Firm LLC
>>>> (843) 238-1978

>>> _____________________________
>>> Patti Wolfe
>>> Executive Assistant
>>> Boyd Law Firm LLC
>>> (843) 238-1978

>> ________________________________
>> Reese Boyd III
>> Boyd Law Firm LLC
>> P. O. Box 15358
>> Myrtle Beach, SC 29587
>> (843) 238-1978
>> (843) 455-9889 (Mobile)
>> (843) 238-2112 (Fax)

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