20 Madison Avenue
Now York, NY 10016
J 212. 867. 4466
BBWG Belkin Burden Wenig & Goldman, LLP x 212, 297. 1859
= Ag ATTORNEYS A T LAW 495 Post Rond East
: Wessport, CT 06880
Tel 203.227.1534
Fre 203, 727.6044
evacibwp.com
CEASE & DESIST DEMAND
February 16, 2016
BY FEDERAL EXPRESS AND EMAIL
‘Ted Cruz
Cruz for President
24 Greenway Plaza, Suite 725
Houston, TX 77046
Chad C. Sweet
Chairman, Cruz for President
c/o The Chertoff Group
1399 New York Avenue, NW, Suite 900
Washington, DC 20005
Jeff Roe
Campaign Manager, Cruz for President
clo Axiom Strategies
1251 NW Briarcliff Pkwy, Suite 85
Kansas City, MO 64116
Re: Your Defamatory Attack Ad
Dear Sit
1am counsel to Donald J. Trump for President, Inc. We recently had the opportunity to
view your television commercial entitled “Supreme Trust” together with your accompanying
statements in the media concerning my client's views (collectively, your “Attack Ad”) and, quite
frankly, are dismayed by the depths the Cruz for President campaign will go to in an attempt to
materially mislead the public.
Simply stated, your Attack Ad is not only completely disingenuous, but replete with
outright lies, false, defamatory and destructive statements and downright fabrications which you
fully know to be untrue, thereby exposing you and the Cruz for President campaign to liability
for damages and other tortious harm. For example, while your Attack Ad blatantly misrepresents
to the public that Mr. Trump is “pro-choice”, nothing could be further from the truth.Belkin Burden Wenig & Goldman, LLP
February 16, 2016
Page 2
Not surprisingly, a closer look at your Attack Ad reveals that the entire basis for your
argument that Mr. Trump is “pro-choice” is based on an interview from Meet the Press that took
place nearly two decades ago. That’s it. While a reputable organization would have at least had
the deceney to use current information to suppor its vitriolic attack ad, you conveniently chose
to leave out Mr. Trump's repeated “pro-life” position in a deliberate attempt to mislead the
public into believing that it is reflective of Mr. Trump's current position — when, unquestionably,
itis not. In other words, you lied. Mr. Trump is not “pro-choice”. This is the very definition of
libel.
Rest assured, however, we will not sit idly by and allow you or the Cruz Campaign to
defame Mr. Trump by intentionally disseminating libelous statements you fully know to be
untrue and, even worse, continue to purposely mislead the American people, Toward that end,
unless we receive your prompt written assurances that you have stopped running the Attack Ad,
‘we will seek immediate legal action to prevent the continued broadcast of the Attack Ad and
hold you jointly and severally liable to the fullest extent of the law for any damages resulting
therefrom ... and will look forward to doing it.
Please be guided accordingly.
Very truly yours,
Jeffrey L. Goldman