7 0 5 0 W.

P a l m e t t o P a r k R o a d

BBennett
15-249

Boca Raton, FL 33433

■w w w . s e r v i n g t h e w o r l d . n e t ■ ■S E R V I N G THE WORLD. S IE R V I N G YOU. ■

February 7, 2022

V I A U S P S 2 - D AY T R A C K I N G N U M B E R S
MFI-MIAMINM, LLC MFl-MiamiNM, LLC
do Cindy's New Mexico, LLC 10401 Montogmeray Parkway NE
120 Medeira Drive NE Suite lA
Suite 219 Albuquerque, NM 87111
Albuquerque, NM 87108 Attn: Stephen Dibert
Attn: Stephen Dibert 9 4 0 5 5 11 6 9 9 0 0 0 9 9 8 1 3 0 3 2 4
9 4 0 5 5 11 6 9 9 0 0 0 9 9 8 1 3 5 9 8 5

Mr. Stephen Dibert

265 S. Federal Highway
Suite 279
Deer eld Beach FL 33441
9 4 0 5 5 11 6 9 9 0 0 0 9 9 8 1 3 7 2 4 8

e-mail as well to: steve@m -miami.com

Re: CEASE AND DESIST

Demand for Retraction from “MFI-Miami.com” (the “5/Ve”)

D e a r M r. D i b e r t ,

Please be advised this of ce represents Ryan Boylston (“Mr. Boylston") and Cassidee Boylston with respect to the publication
of adefamatory blog post on the site http:.'ymil-miami.com (the “Site") published by, Stephen Dibert (“You"), on February 1,
2022 entitled “Delray Beach Residents Accuse Ryan Boylston of Anti-Semitism" (the “Blog Post”) which contained untruthful
and unveri ed statements against Mr. Boylston. Cassidee Boylston and others. MFl-Miami NM, LLC and You are directed to
immediately Cease and Desist any further statements of any kind whatsoever pertaining to Mr. Boylston and Cassidee Boylston
and post an immediate retraction of the defamatory statements as outlined below.

Upon information and belief. You are the owner of MFI-Miami NM, LLC, an Arizona limited liability company. You are the
manager of similarly named organized entities within the state of Florida such as MFl-Miami, MFl-Miami Holdings, LLC.
According to the Site, MFl-Miami NM, LLC is the owner and is responsible for all content on the Site. Aside from MFl-
Miami NM, LLC admitting responsibility for the content of the Site, MFl-Miami NM, LLC is also liable as an online publisher
and not exempt by virtue of Section 230 to the Communications Decency Act (47 U.S.C. §230).

On February 1, 2022, You caused the Blog Post to be disseminated through the Site as well as the site medium.com and
Facebook. Your Blog Post is defamatory from start to nish. The entirety of Your Blog Post is false and maliciously untrue.
You disseminated the Blog post through MFl-Miami NM, LLC only to bring Mr. Boylston into ill repute and destroy the
con dence in Mr. Boylston’s integrity as apublic of cial. You published the Blog Post with actual malice and the simplest
rudimentary fact checking would have revealed how utterly phony and false Your Blog Post is. Speci cally, Your Blog Po,st
contains the following false statements:

1. 'Delray Beach Residents Accuse Ryan Boylston of Anti-Semitism". The tagline to the Blog Post in and of itself is
false and defamatory. Nothing within the content of the Blog Post references any accusation of any Delray Beach
residents (plural), by implication or otherwise, as to Mr. Boylston’s anti-Semitism.
2. “Delray Beach Residents Accuse Ryan Boylston And His Supporters of Using Cryptic Nazi Rhetoric in Attempt to
Derail Project". The headline to the Blog Post falsely accuses Mr. Boylston of using cryptic Nazi rhetoric. Nothing
within the context of the Blog Post mentions any Delray Beach residents (plural) who accused Mr. Boylston of using
Nazi rhetoric. In fact, the only person making such an accusation is You, Mr. Dibert, and the accusation is defamatory,
not true, and unsupported.

Justin Bennett Helen Bennett

Direct Dial: 954-261-2266 Direct Dial: 561-350-6467

E-Mail: jbennett@servingtheworld.net E-Mail: hbennett@servingtheworld.net

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 3. Mr. Boylston “k contributing to the cryptic Nazi rhetoric and hysteria by feeding these crazies misinformation and
encouraging them to build anonymous websitesN Yet another conclusory statement lacking both truth and factual
support. The Blog Post fails to disclose the identity of “these crazies”, the type, character, content, or date of any
“misinformation” and what “anonymous websites” Mr. Boylston has encouraged people to build. The reason for such
ambiguity within the Blog Post is the simple truth that Your statement is false and only seeks to injure Mr. Boylston.
4. Mr. Boylston ""and his wife promote the old-school Florida cracker attitude with their ‘True Floridan ’brand apparel
husinessF The term ‘cracker’ in and of itself is aracial slur. To categorize Mr. Boylston’s True Floridian brand in
such away is not only defamatory but interferes and damages the goodwill ofTrue Floridian. In addition, the statement
defames Mr. Boylston’s wife, Cassidee, who as aprivate citizen, holding no public of ce, enjoys substantial rights
afforded her to be free from such libel.
5. Mr. Boylston '"began telling residents that he and his supporters, ‘don’t want this type of business in OUR town! ”’.
There is no substance to when or where Ryan Boylston made this quoted statement because he never made this
statement. You knowingly made up this quote to destroy Ryan Boylston’s reputation by painting him as an anti-
Semite.
6. Mr. Boylston ""also began complaining about ‘New Yorkers’ and using the same Mein Kampf-style rhetoric ....’’
Like Your prior false and defamatory statements, this never happened. You then go on to imply that when Ryan
Boylston refers to 'New Yorkers’, he intends the words in an anti-Semitic context. This is adisgustingly and
maliciously false narrative originated only by You.
7. The picture of Mr. Boylston with the caption “sporting his new Proud Boys hair style” is equally defamatory and
implies Mr. Boylston’s hair associates Mr. Boylston with aneo-fascist political group. It is quite defamatory to askew
aphoto and caption it in such aderogatory and utterly unrelated and accusatory libelous manner.

Each of the above statements are patently false, libelous, and defamatoiy. These statements are vile, disgusting, foster
divisiveness and constitute impermissible hate speech.

Given the outrageous and nauseating content in the Blog Post, You could have easily con rmed the accuracy of these statements
and detailed Your con rming sources within the Blog Post. You did not because You are well aware each of the aforementioned
statements are completely made up. This is the very character of actual malice and ample evidence to suggest that You
entertained serious doubts as to the truth of Your own Blog Post. Your Blog Post calls into question the ethics and integrity of
Mr. Boylston and Cassidee Boylston in such avile and disrespectful way as to clearly constitute defamation per se. The
defamator>' Blog Post maliciously impacts his career, livelihood, reputation and destroys the reputation of his wife, Cassidee,
who is not apublic gure.

Therefore, and on behalf of Mr. Boylston and Cassidee Boylston, You are to immediately cease and desist from the
dissemination of any such further defamatory remarks against Mr. Boylston, his wife, or the True Floridian brand. We
also demand You immediately, and without delay, issue aretraction of each false statement contained in the Blog Post.
Your retraction must be made to m -miami.com, issued on medium.com as well as posted on all social media pages and
mediums that have posted and shared/re-shared Your publication.

In addition, Bennett Law, P.A. hereby noti es MFI-Miami NM, LLC and Stephen Dibert to preserve all electronically stored
infonnation, copies and backup as de ned under Rule 34 to the Federal Rules of Civil Procedure, along with any paper that
MFI-Miami NM, LLC and/or Stephen Dibert maintains relevant to the Blog Post. Mr. Boylston and Cassidee Boylston shall
seek discovery of electronic data in MFI-Miami NM, LLC and Stephen Dibert’s custody and control that is relevant to this
action, including without limitation emails and other information contained on any computer systems, servers or cloud storage
systems owned by or licensed to MFI-Miami NM, LLC and/or Stephen Dibert. Mr. Boylston places MFI-Miami NM, LLC
and Stephen Dibert on notice not to allow the deletion of any electronic communications such as e-mails, social media posts,
SMS. iMessages, Facebook Messages or such similar communications related to the Blog Post. 1am con dent that MFI-Miami
NM, LLC and Stephen Dibert have already taken af rmative steps to preserve these items in anticipation of litigation and we
direct that MFI-Miami NM, LLC and Stephen Dibert continue to preserve all electronic data throughout any future litigation.

G O V E R N Y O U R S E L F A C C O R D I N G LY

Sincerely,

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