2 — LAB Reform’s answer to Greehan’s lawyer

Dear Mr. Greehan:

Subject: LAB Reform and Statements Regarding Michael F. Greehan

In response to your letter of December 2, 2005, which makes unspecified and unsubstantiated claims of “false, misleading, and injurious” statements on the LAB Reform website about Mr. Greehan, we, the undersigned, maintain that no such statements exist on our website.

It is true that the site contains statements that are critical of Mr. Greehan, but all the criticisms are factually accurate and can be documented; indeed, some documentation appears on the site.  We have been careful not to state our criticisms of Mr. Greehan, or the other LAB directors whom we have cited, in ways that a reasonable person might consider libelous or slanderous.

After receipt of your letter, we carefully examined the entire site, and we found nothing that a reasonable person could find slanderous or libelous, because our statements fall within the bounds of lawful free speech and are factually correct.

LAB directors serve in a quasi-public capacity, like directors of non-profit and publicly-owned corporations.  In that capacity, they may be subject to criticism by persons having a stake in the organization or corporation, such as members or stockholders.  Mr. Greehan recently became President of LAB, which legitimately exposes him to the possibility of public criticism to a greater degree than before.

Your letter insinuates that if content that you deem objectionable is not removed within fourteen days, “legal steps may be taken to protect his rights.”  We will vigorously contest any such actions, not only for the reasons stated above, but also because you have not identified any specific statements or materials on our website that meet your claim of “false, misleading, injurious, and defamatory.”  We doubt that any court will entertain a suit that does not clearly and specifically state the claims being made by the Plaintiff.

Should you decide to proceed with a suit against any or all of us, we will seek to have it dismissed as frivolous, and we will petition to have Mr. Greehan reimburse us for all expenses incurred in defending ourselves.

If Mr. Greehan would meet with us and, in concert with the LAB Board, address our grievances, we would be more favorably inclined to remove our criticisms of him, and them, from our website.  Now, as the President, he has the authority and the opportunity to do so.


William N. Hoffman, on behalf of John Schubert and Fred Oswald

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