Little Falls, New Jersey 07424

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LAWRENCE G. TOSI Telephone: (973)256-8555

. . . Fax: (973)256-8556

DWAYNE WARREN E-Mail:wtslawfirm@aol.com

. . .

MARK J. SEMARAO

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Personal & Confidential

July 12, 2001

Dear Mr. and Mrs. Bicharo (sic) and Sergio Bichao

RE: Slander and Libel

Please refer to your legal counsel. Please be advised that this office represents the Township of Hillside including the council and the mayor in response to the attached libelous letter and article written by you or your representative. The statements that you or your representative made were not true. Further, you repeated the same allegations on the internet. Your comments were intentionally made to damage the fine reputation of the Township and the members of the Council. At this time our clients are contemplating legal actions against you.

You are fully aware that your assertions are not protected speech and you can be held personally responsible for such damage for slander and libel. Unless you make a full retraction of the letter to all individuals to whom you forwarded this letter, we will have no other alternative but to seek redress in the Courts. Since this was done by you with the purpose of injuring our clients’ reputation, we will seek punitive damages.

I must demand retraction of you lies and a public apology printed in the Star Ledger newspaper and the internet in three (3) days of this letter.

You r lack of investigation concerning the remarks and your rush to judgment regarding the Council’s hiring practices are especially disturbing coming from a supposed journalist. Finally, you misrepresented your association with Hillside High School. Our clients may seek damages for that conduct as well.

The reference to a public entity in order to legitimate your article to advance slanderous statements is not permitted. It appears that you may have violated multiple statutes. Please be advised that we fully intend to report your conduct to the appropriate State and Federal authorities.

In the interim, we demand a full retraction of your devastating and reckless lies and immediate response to the demands of this letter.

Very truly yours,

Dwayne D. Warren [signed]

DDW/kn

Cc:

Hillside Board of Education

President John O’Shea, Board President

Peter Corvelli, Council President

John Kulish, Council Vice President

Joe Pinckney, Councilman

Leonard Gilbert, Councilman

Jorge Baptista (sic), Councilman

Gerald Freedman, Councilman

Sam McGhee, Councilman

Karen Mc Coy (sic), Mayor