5 — A Second Greehan Letter

Our reply to Greehan and our message sent to the entire board was “answered” by the following letter. Attorney Greehan apparently realized that his claims have no merit, thus he is trying another tactic. This is not an acceptable reply from Greehan. It will not resolve the crisis.

We have again added notes in red text below to highlight false accusations or to provide background information.

Re: LAB Reform & Statements Regarding Michael F. Greehan

Dear Messrs. Hoffman, Oswald and Schubert:

I am in receipt of Mr. Hoffman’s letter dated December 15, 2005. I have also reviewed a copy of Mr. Oswald’s “news release” of December 17, 2005. While Mr. Hoffman’s letter to me does not mention a date by which you wanted Mike Greehan to respond, I wanted to get back to you before the December 31 date referenced in Mr. Oswald’s release.

First, contrary to your contentions, my December 2, 2005, letter was not on behalf of the League of American Bicyclists (“the League”), only Mike Greehan privately. Trying to draw the League into this matter is unwarranted. Further attempts will only support the position that you are using this private dispute to try and improperly promote your group’s personal agendas. Again, this is a private matter between you and my client.

Note: We fully understand that the threatening letter of Dec. 2 was sent at the instigation of Mike Greehan. Greehan’s actions were performed as a director of LAB, and that brings LAB into this unfortunate situation. Now that he is LAB president, his rash actions may cause even more harm to the League. The other directors should be ashamed of this conduct.

Our “personal agenda” is simply to return control of the League to the League members.

Second, contrary to your contentions, the December 2, 2005, letter requested that any false or misleading statements about Mr. Greehan be removed from your website and any other publications over which you had control. It was an attempt to resolve these matters amicably so that further action would not even be a consideration. Mr. Greehan believes that you have been asked nicely on several occasions has asked you nicely on several occasions to do so and was the under the impression that he had been given your word that these materials would be removed from your website and emails. However, not only had they not been removed, more inflammatory statements appear to have been added.

Note: One does not use certified letters sent by an attorney to “resolve these matters amicably”. Mr. Greehan made a vague complaint about our material just once (at the March 2005 board meeting). However, he has never pointed out any statements that are “false or misleading”, nor can we find any such statements.

Third, while Mr. Greehan believes in Free Speech and the First Amendment, such rights do not extend to false expressions of opinion that are stated as or published as fact. I would ask that you again look through your website and emails to see if the line has been crossed on some occasions.

Note: We have again searched our site and find no such “false expressions of opinion that are stated as or published as fact.”

This letter is not intended to address all of the matters in Mr. Hoffman’s December 15, 2005, letter or Mr. Oswald’s December 17 “news release.” I am in the process of preparing a more comprehensive response, but wanted to get this out to you in the meantime. Again, I hope that these matters between you and my client can be resolved on friendly terms.

Note: We have our own suggestion for resolving this on friendly terms: In addition to retracting his legal threat and reimbursing us for the expenses he has caused, Mr. Greehan should promptly resign from the board of the League of American Bicyclists without causing further harm to the League or its members. Once he does this, there will be no further need for material about him on labreform.org. Once the League is returned to the control of its members, there will be no further need for LAB Reform itself.

Randall T. Greehan

cc: Michael F. Greehan

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