Untitled

Legal Complaint

Curtis N. Ofori (“Requestor”), by way of counsel, seeks  
to have Google, Inc. (“Google”) remove unlawful material contained on  
www.publicintegrity.org/.../Russell_civil_suit_AmendedMotion.pdf  
(“Website”).  In support of this request, Requestor asserts that the  
Website owned and operated by the Center for Public Integrity (“Company”)  
is in violation of the following state laws and applicable terms of first.   
Company a U.S. organization is domiciled and doing business in the District  
of Columbia and thus is subject to its laws.    The exact content on the  
Website that is unlawful in the United States falls under the District of  
Columbia Code (“D.C. Code”) and Google’s Search Terms of Use.

In this case, the Company published a false document on its Website styled  
as a civil legal complaint and linked it as a pdf document.  The person who  
made false allegations against Requestor never actually pursued a civil  
claim against the Requestor.  A search of the Virginia Civil Court records  
will show that Case No. 06-39, Russell v. Ofori was never filed by the  
purported author, attorney Steven D. Rosenfield.   In fact, this false  
document was actually used as extortion tool by the attorney and  
extortionist for $1.5 million dollars.  After the Requestor rebuffed the  
tactic, the parties went about slandering and defaming the Requestor in  
hopes of a settlement.  Accordingly, because the true facts are in direct  
conflict with the material provided on the site, this letter proves that  
Website is in violation of the D.C. Code and Google’s Search Terms of Use  
and thus should be taken down from Google searches.

The Website is in violation of:
(1) District of Columbia Code § 31-2231.05. Defamation;
(2) District of Columbia Code § 31-5605.04. Misleading filings and District  
of Columbia Code §§ 22-5101 to 22-5106. Libel;
  (3) Google’s Search Terms of Use, Paragraph 4.2, Section (3), Subsection  
(b) and (e).
	
(1) 	Under D.C. Code § 31-2231.05, defamation, no person shall make,  
publish, disseminate, or circulate, directly or indirectly, or aid, abet,  
or encourage the making, publishing, disseminating or circulating, of an  
oral or written statement or a pamphlet, circular, article, or literature,  
which is false with respect to, maliciously critical of, or derogatory to,  
the financial condition of an insurer and which is calculated to injure the  
insurer.  In this case, the Company published the statement and distributed  
it to more than one person through its website.  Because it was published  
on the internet, this requirement has been met.   Second, the statement is  
about the Requestor.  The statement directly names the Requestor with  
enough identifying information that those who know the person will  
recognize the statement as being about him.  Third, the statement has  
harmed the Requestor’s reputation.  The false document published by the  
Company is a defamatory statement because the false statement of fact has  
exposed the Requestor to hatred, ridicule and contempt.  It also has  
lowered his esteem, caused him to be shunned and injured him in his  
business.  Fourth, the statement was published with some level of fault.   
The Company is at fault because the defendant should not have published a  
document it knew to be false.  The Company acted negligently in not  
checking the civil records to ensure that it was an actual legal document.

(2) 	Under District of Columbia Code § 31-5605.04, misleading  
communications and D.C. Code §§ 22-5101 to 22-5106, libel, a person shall  
not make, or cause to be made, in a document which is, at the time and in  
the light of the circumstances under which it is made, false or misleading  
in any material respect.  Similarly, a person shall not make false charges,  
blackmail; intent to commit extortion by communication of illegal threats  
and demands.  In this case, there was a public disclosure of a false  
statement (stating that Requestor engaged in an assault), about the  
Requestor which was highly offensive to a reasonable person (being accused  
of sexual assault is highly offensive to any reasonable person).   Finally,  
Requestor can show that the Provider is at fault based on the readily  
available website.  The website does not hide the identity and parties  
publicize their involvement.  The Provider acted with willful and wanton  
malice and Google should remove the site from its indexes.

(3)	Under Google’s Search Terms of Use, Paragraph 4.2, Section (3),  
Subsection (b) and (e), each website warrants that it will not provide  
content that (b) constitutes defamation, libel or obscenity or violates any  
applicable law, statute, ordinance, or regulations.  Here, the Website as  
discussed above is in violation of Subsection (b) and (e) by defaming the  
Requestor with remarks that he assaulted anyone.  Accordingly, because the  
Website avails itself to Google’s search functions, as such it must comply  
with Google’s Terms of Use and its failure to do is grounds for removal.   
Finally, the Website is violating applicable D.C. law and regulations.

	In light of these facts, Requestor asks that Google remove  
www.publicintegrity.org/.../Russell_civil_suit_AmendedMotion.pdf from its  
search indexes based on its violation of (1) District of Columbia Code §  
31-2231.05. Defamation; (2) District of Columbia Code § 31-5605.04.  
Misleading filings; District of Columbia Code §§ 22-5101 to 22-5106. Libel;  
and  (3) Google’s Search Terms of Use, Paragraph 4.2, Section (3),  
Subsection (b) and (e).

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