UgaldevsAlyssa

FORMAL DEMAND TO CEASE AND DESIST

MS. ALYSSA CAY UGALDE PASCUA
also known/using the name “Alyssa Cay Ugalde” on Facebook

Dear Ms. Ugalde:

We represent MR. ALEX A. UGALDE regarding your repeated Facebook posts, Stories, and other social-media publications concerning him, his businesses, professional activities, former employees, relatives, and persons assisting him.

Our client has preserved electronic and documentary evidence of these publications.

The documented publications include accusations concerning our client's honesty and professional conduct, allegations regarding the quality and safety of construction projects associated with him, statements threatening interference with or closure of his business activities, and repeated derogatory statements concerning him and persons associated with him.

Accordingly, FORMAL DEMAND IS HEREBY MADE that you:

IMMEDIATELY CEASE AND DESIST from publishing, reposting, sharing, or causing the publication of false, defamatory, malicious, threatening, or otherwise unlawful statements concerning Mr. Alex A. Ugalde, his businesses, projects, or professional activities;

IMMEDIATELY CEASE making threats or statements intended to interfere with, damage, or cause the closure of his lawful businesses or projects; and

CEASE further harassment, intimidation, or retaliation against our client through attacks involving his relatives, employees, former employees, associates, or persons assisting him.

TAKE NOTICE that relevant social-media publications are being documented and preserved. Any further similar conduct after receipt of this demand may be used as additional evidence in appropriate legal proceedings.

Should you fail to heed this demand, our client reserves the right to pursue ALL APPROPRIATE CIVIL, CRIMINAL, AND OTHER LEGAL REMEDIES WITHOUT FURTHER NOTICE OR DEMAND.

Nothing herein constitutes forgiveness, condonation, reconciliation, compromise, waiver, or abandonment of any right or remedy available to our client.

GOVERN YOURSELF ACCORDINGLY.

ATTY. ______________________________
Counsel for MR. ALEX A. UGALDE