To: Professor Tatiana Servin

From: Bob Burruss

Public Relations Specialist
Piney Woods Lumber Company
Date: February 10, 2015
Subject: Matt Martinez Lawsuit
Recently, Matt Martinez filed a lawsuit against Piney Woods Lumber
Company along with myself as well as personnel director Jim Haskins. The
circumstances for his lawsuit are currently unclear but it is most likely a
case of libel and publication of private facts.
The law states that the publication of private facts involves the disclosure
of information that is not newsworthy or part of any public record. It also
states that libel is considered injury to reputation and that a message is
only considered libel if it is defaming, published, identifying, negligent, and
damaging.
I believe Martinez is claiming that we did not tell him prior to receiving his
written permission statement that we would be telling his whole life stories
including the mistakes he made while under the influence of alcohol most
of which were obtained in an confidential interview and that we were
publishing a libelous message about his life.
In previous profiles we have done regarding our employees we have
discussed their hobbies and interests; this was the first time we told
someones life story. I understand where there could have been confusion
however; we received written permission to publish a story on Mr. Martinez
and therefore followed through with it.
I believe the argument he can make for this lawsuit is that his private
information that was published was not newsworthy. We published the
story several decades after his charges making them irrelevant to publish
now however they were used in content to our story and our end goal of
having other employees enter rehab. When speaking with Mr. Haskins, Mr.
Martinez told him he had never told another one of his co-workers his life
story because he was ashamed of his youthful past. Despite this, he does
not have a case when it comes to publishing information regarding his
conviction for manslaughter, DUI, child and divorce because those facts
are public record, which can help our defense case.
In regards to the libel accusation the story about his life could be perceived
as having 4 out of the 5 qualities that are need for a message to be

classified as libel. The story was published and identified Mr. Martinez and
told a story that could be defaming or considered as damaging to his
reputation. However, the message lacks negligence and we can use that in
our defense. We did not act out of malice or published anything that is
false or inaccurate. All facts were received from public record or during the
personal interview with Mr. Martinez that Mr. Haskin conducted.
Due to the fact that we did not act out of malice or publish information that
was not public record I do not believe that Mr. Martinez has a just cause to
create a lawsuit.
Perhaps Mr. Haskin and myself could have taken precautionary actions to
avoid legal trouble with Mr. Martinez. We should have been clearer on
what the profile was regarding as well as our intentions to make an
example out of him in front of his peers and then asked for permission to
disclose facts that were given to Mr. Haskin in their interview. If we would
have had him sign a contract stating he understood what we were planning
on doing with his profile and story we could have avoided legal and ethical
negative outcomes.
Please let me know if you need any more information about this case or
the interview conducted with Mr. Martinez.