Cohen & Silver, llc

227 Pine Street Philadelphia, PA 19106

www.cohenandsilver.com
Eric J. Cohen direct dial: 215-413-3686 Michael Silver direct dial: 215-500-0840

eric@cohenandsilver.com

michael@cohenandsilver.com

November 8, 2012 Douglas T. Muth Webmaster and Board Member The Save Ardmore Coalition P.O. Box 453Ardmore, PA 19003 Initially via email to doug.muth@gmail.com and webmaster@saveardmorecoalition.org Copy may follow by certified mail RE: Take Down Notice for Libelous and Defamatory Content about Susan Rose ----------------------------------------------------------------------------------------------------------Dear Mr. Muth: I represent Susan Rose. Be advised that there are a series of completely false, libelous and defamatory statements about Ms. Rose posted on the website http://www.saveardmorecoalition.org, for which you serve as the webmaster. It is also my understanding that you serve as a board member of the non-profit entity that publishes the website. I am sending this letter as a courtesy seeking your good faith cooperation to immediately take down these false, libelous and defamatory statements regarding Ms. Rose. Please refer to the following specific content posted on your website, all of which contains false information about Ms. Rose, and all of which is accessible via this URL: http://www.saveardmorecoalition.org/node/5505/breaking-liz-rogan-refuses-change-meeting-datelower-merion 1. 2. 3. 4. 5. Post #5 dated Wed, 2011-02-02 13:20; Post #6 dated Wed, 2011-02-02 14:42; Post #7 dated Thu, 2011-02-03 00:47; Post #8 dated Thu, 2011-02-03 11:41; and Post #9 dated Wed, 2011-02-02 16:00.

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Douglas T. Muth

November 8, 2012

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I also direct your attention to the following specific statement contained in Post #6 that reads: There is a teacher at Penn Valley ES named Susan Rose. She lives in Penn Valley, I think not far from the school. What's odd is I think her kids go to Merion ES instead of PVES. Not sure why. She did come to one of the public meetings on Plan 3 (not 3R) and speak in favor of it. She was also known to have made some pretty not-nice comments to the kids in school about Ardmore and redistrciting. She is not loved by the African-American parents in Ardmore In addition to being completely false, the above statement in particular, by its very nature, is absolutely libelous and defamatory. Ms. Rose is a caring and dedicated senior teacher and a highly trained, sensitive and compassionate educational professional. To falsely state that she is known to have made some pretty not-nice comments to the kids in school about Ardmore and redistricting and that She is not loved by the African-American parents in Ardmore is simply outrageous. Your actions in allowing the above referenced content to appear on your website have cast Ms. Rose in a false light, invaded her privacy, defamed her personally, defamed her professional reputation, and caused her significant and irreparable damage. You need to take the following actions immediately: 1. Remove and take down all of the above referenced content from your website. 2. Take all appropriate actions to insure and continually monitor that no further false content about Ms. Rose will be posted to your website. 3. Issue a formal letter of apology to Ms. Rose on behalf of your website and The Save Ardmore Coalition. I am writing in the hope of being able to resolve this matter amicably, but your failure to immediately take the above actions will result in legal action, both against you personally and the Save Ardmore Coalition. Moreover, my client reserves all of her rights and remedies arising out of your unlawful conduct to date. This is a very serious matter, and I look forward to your immediate cooperation. Sincerely,

Eric J. Cohen cc: Susan Rose

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