Letter From Attorney Bevan On Behalf of His Client Joe Migliorini Received 10-1-2015

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occ" BEVAN & ASSOCIATES LPA, INC. “Attomeys-at-Law (6555 Dean Memorial Parkway Boston Heights, Ohio 44236 ‘THOMAS W. BEVAN PATRICK M. WALSH. DWIGHT. MoTscO Phone (330) 650.0088 (CHRISTOPHER J. STEFANCIK DAVIDS. BATES CINDY L. KOBAL Fax: (330) 467-4493 ANGELA M, HARDWAY ESSICA M. BACON JOSHUA GRUNDA Website: wa bevanlaw com ANIALLA. MEHTA, ERIN M, SCHMIDT Seat KEITH D. DEVAN DALES. BCONOMUS* (Use ia PAK OF} September 30, 2015 Sylvia J. Hanneken 1033 Hampton Drive Macedonia, Ohio 44056 Dear Ms. Hanneken: Please be advised that I represent Joseph Migliorini. It has been brought to Mr. Migliorini’s attention that you have made numerous defamatory statements about him over the past several weeks. For example, on or about September 24", you accuse Mr. Migliorini of resigning under a “corruption investigation”. You also accuse Mr. Migliorini of living in Florida “half the year”. These statements are false and should be promptly removed from any campaign material or Facebook content. As I am sure you know, the Ohio Secretary of State has, dismissed these frivolous residency claims and Mr. Migliorini resigned as Macedonia Mayor to become the Summit County Director of Development, a position that he held for over four years. We believe that these false statements were made with actual malice. Making such allegations with knowledge of their falsity or with a reckless disregard of the truth constitutes grounds for a defamation action. ‘This is to advise you that further faise statements regarding my client, Joseph Migliorini, will not be tolerated. If you do not immediately stop making such false statements, we intend to file a defamation action against you in the Summit County Court of Common Pleas. Sincerely, Thomas W. Bevan

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