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Joanie Scott McDonough, GA 30253 George T. Brown Brown & Brown Attorney at Law 108 South Main St.

. Jonesboro, GA 30237 ***Sent Via Email *** July 17, 2012 Dear Mr. Brown, I am in receipt of your amended letter to me dated July 16, 2012 in which you state you represent Dale Rutledge. After consulting with legal counsel, please consider this my response to said letter. You falsely state in your letter that I allege your client violated Georgia Workers Compensation Laws. That is a false statement and I deny making such a claim. My allegation is that the Georgia State Workers Compensation Board holds no records of Rover, Inc. carrying the insurance prior to 2004 and that there are laws against not having workers compensation insurance. Those are both true statements. You also falsely claim that I alleged Dales brother was injured while working for his brothers company. That is also a false statement and I deny making that claim, too. What I did claim is that Dales sister alleged the injury to the brother in a legal affidavit and that, if that were the case, the law would require the injury to be reported. Those are both true statements.

As to your own claim that Dales sister provided information to me, that is also false. That information was obtained from court documents which I located at Henry County Superior Court where they are public record. I have never made any contact with Dale Rutledges sister or any member of his family. And, as an attorney, it seems that you should already be aware that the Probate documents to which you suggest I examine, a civil competency case, are not available to the public. It also seems to me, Sir, that as an attorney, you should already be aware that by declaring himself as a candidate for election to public office, Dale Rutledge has made himself a public figure. Even if my allegations against Dale Rutledge were false, which they are not, under the First Amendment of the United States Constitution, as set forth by the U.S. Supreme Court in the 1964 Case, New York Times v Sullivan, where a public figure attempts to bring an action for defamation, the public figure must prove an additional element: That the statement was made with "actual malice". There is simply no way which Mr. Rutledge can make that case in this instance because it is not true. As well, in any libel claim Dale would make against me would require he also show actual damages. Since Rover, Inc. no longer exists, that would be impossible. Lastly, since my statements about Mr. Rutledge are in fact true, Im sure you also aware that truth is an absolute defense as are the case in this matter.

Mr. Brown, you should know that I have been made aware of a failed attempt by Dales campaign manager, Charles Mobley, to have fictitious or false documents delivered to me, with the expectation that I would publish said fictitious or false information on my website, for the specific intent of bringing litigation against me. Mr. Mobley is unable to refute claims I make in my blog so it seems he would rather try and intimidate me into shutting up by setting me up to be sued. If your client, Mr. Rutledge, and his associate, Mr. Mobley, are conspiring to intimidate me from further writing about his candidacy, those actions would be, as Im sure you are aware, a violation of 18 USC 241 which prohibits intimidation against Americans for exercising free speech rights. The statute says: If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised the same; They shall be fined under this title or imprisoned not more than ten years, or both. Vetting of candidates is essential to the democratic process of our elections and Mr. Rutledges threat of legal action against me is a threat to my First Amendment right to free speech which I take very seriously. As such, your demands for cease and desist, removal/retraction of, or apologies for my writings about Mr. Rutledge are baseless and have no warrant. In fact, these baseless claims have caused me great distress since first receiving your first letter on Friday, July 12th and any further stress caused to me by your client threatening frivolous law suits against me may result in my choosing to take legal action against your client.


Joanie Scott