WANO·M o u • PR T LC

August 2,2010

VIA US MAIL: CERTIFIED

Ms. Marni Zollinger

Troutdale, OR 97060

Re: Demand for Cease and Desist

.
Dear Ms. Zollinger,

As you might know, j alTI Matthew Wand's law pa,~ner, and I represent him in
connection with an ethics complaint you made, or caused to be made, against him with
the Oregon Attorney General's office. It has come to my attention that you are
republishing that ethics complaint to others, despite the fact that the complaint was
summarily dismissed by the Oregon Attorney General's office because the accusations
were blatantly and intentionally false. Your personal vendetta is obviously being
pursued with malice, and it is clear that you either know that the accusations are false,
or you are making them with reckless disregard for their falsity.

I demand that you immediately cease and desist making any further false
allegations against Matthew Wand, and refrain from republishing them in any form in the
future. Should you continue making such allegations against Mr. Wand, I am prepared
to file suit against you for damages arising from abuse of civil process and defamation.
Should it become necessary to file such an action, please be advised that we may
recover Mr. Wand's attorney fees pursuant to Oregon Revised Statutes § 20.080.

Ms. ZoHinger, this is a formal demand, and I trust that your compliance in this
regard will make further legal proceedings unnecessary.

Regards,
....

Z:IWorkIWand, Malthewl001 Zoll!nger.docx

236 NE Roberts Avenue. Gresham, Oregon 97030

lei' (503) 666-7114 • fax: (503) 512-8112 • kevin@wa',dmaddou •. com
WAND· MADDOUX· PRESTON lLC
ATTORNEYS

13£1 N[ r~()uerrs Avenue' Gresham, Oregon 97030

Ms. Marnie Zollinger

Troutdale, OR 97060

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