Kenneth J. Joyce

e-mail: kenneth.joyce@brinkleymorgan.com

 

September 6, 2006

 

 

VIA CERTIFIED MAIL – RETURN RECEIPT REQUESTED

 

Platinum Gold Entertainment, Inc.

Attention: Glenn M. Goldklank

3650 Coral Ridge Dr, Suite 102
Coral Springs FL 33065

            Re:       BarMitzvahs.com Inc.

 

Dear Mr. Goldklank:

 

            This law firm represents BarMitzvahs.com Inc. d/b/a/ M&M Entertainment (“M&M Entertainment”).

 

            M&M Entertainment has received specific information that Platinum Gold Entertainment’s Senior Event Coordinator Phil Rose has misrepresented to several of M&M Entertainment’s clients and prospective clients that M&M Entertainment has declared bankruptcy. This is unequivocally false. These statements were made by Mr. Rose with actual knowledge that the representations were false or without undertaking any investigation whatsoever to determine the veracity of said statements. The above-referenced misrepresentations were made by Mr. Rose during the course of his employment with your company and said statements were made for the direct benefit of Platinum Gold and with the aim of procuring a business advantage.

 

            The actions undertaken by your employee are willful and malicious, constitute slander and tortious interference with an advantageous business relationship, and have caused M&M Entertainment to sustain damages. M&M Entertainment will take all necessary action to protect the strength of its business reputation, particularly in regards to competitors who attempt to influence clients and potential clients by making material misrepresentations. The law allows M&M Entertainment to be compensated for the damage that Mr. Rose and Platinum Gold have caused, or will cause in the future.

 

            M&M Entertainment hereby demands that you immediately cease and desist your illicit activities. This is your one notice and only opportunity to correct your conduct. M&M Entertainment demands that you respond in writing within five (5) days of the date of this correspondence advising that you and your employees have ceased making any misrepresentations regarding M&M Entertainment. Further, Platinum Gold and Mr. Rose are obligated to issue a contraction of this false information and advise that the false statements were made without basis. Should you refuse, or otherwise make any future misrepresentations, we have been instructed to proceed immediately to file suit to address your wrongful actions and prevent further wrongful conduct. We will further seek all attorney’s fees and costs in the action.

 

            Please direct all further communication regarding this matter to my office. Please also contact us in writing to advise us that you have ceased forever the above-referenced actions. If we do not have a response within five (5) days from the date of this letter, we will assume have chosen to ignore this notice and will proceed accordingly.

 

            Govern your actions accordingly.

 

                                                                        Very truly yours,

 

                                                                        Kenneth J. Joyce

 

KJJ:vf