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~ ~ Summit Crest's Threatening Letter ~ ~
The following is the text of the letter being sent to Karen & Mike from Summit Crest's Lawyers. Letterhead was reproduced but not totally accurate. The remainder of the letter has been reproduced here without change.

Grammatical errors and spelling errors were not corrected.


DENVER OFFICE:
303 E. 17TH AVE SUITE 700
DENVER, COLORADO 80203
TELEPHONE: (303) 860-1888
Purvis, Gray & Gordon, LLP
ATTORNEYS AT LAW

SUITE 501
BOULDER, COLORADO, 803302-5144
TELEPHONE (303) 440-3366
FAX (303) 440-3688
e-mail: info@pgglaw.com
PLEASE REPLY TO BOULDER OFFICE

October 12, 2001

BETH KLEIN, PC
SPECIAL COUNSEL
Tony Johnson, Esq.
Retherford Mullen Johnson & Bruce, LLC
415 S. Sahwatch Street
Colorado Springs, Colorado 80903

            Re: Michael Meadors and Karen Dudnikov

 

            I am advised that you represent Michael Meadors and Karen Dudnikov in matters related to a Summit Crest home that they purchased from NorthStar Builders in Florissant, Colorado. I represent Summit Crest Homes.

            Summit Crest Homes has delt with your clients fairly and in accordance with its legal obligations. In this particular case, your clients mailed a request for service work to Summit Crest dated January 17, 2001. This letter was received by the company on January 19, 2001. Summit Crest acknowledged this letter, and the company commenced repairs within one week. The work was promptly completed to your client's satisfaction. Indeed, Karen Dudnikov personalli signed an acknowledgement that she accepted and was satisfied with the work performed by Summit Crest. Every repair issue was addressed, and your clients were treated with the utmost courtesy. Summit Crest received no further notification of problems until your clients recently sent the General Manager a letter outlining a limited number of repair issues and making unwarranted threats against the company.

            As it has done in the past Summit Crest will continue to honor its legal obligations and will conduct itself with professionalism in dealing with your clients, and this process has already begun. Summit crest has already spoken to Karen Dudnikov concerning further claims for warranty work. During this conversation Ms. Dudnikov was very complimentary of the efforts of Summit Crest and in particular, John Kowalczyk. She also relayed that Ann Hart is also very appreciative of the work of Summit Crest.

            Given the background, my client was very surprised to receive threats from your clients and to view the defamatory statements made against Summit Crest on a website located at www.NorthStar-sucks.com. that is published by your clients. The web site falsely states that my client enables criminal conduct and refers to my client's product as "crap". This web site publishes perverse ad hominem attacks - many of which are sexually oriented and slanderous per se. Your clients have already been sued in Park County by others who have been attacked on this web site for defamation and outrageous behavior.

            Your clients have threatened to harm my client further by publishing an additional website: www.SummitCrestHomesSucks.com. We can inly assume that the content will be similar in nature, and this outrageous conduct will not be tolerated.

            Summit Crest has three request. First, your clients must delete all reference to it on any website that they publish. Second, your clients must agree to refrain from any action that would defame Summit Crest in the future. Third, your clients must agree to write a letter or toher appropriate communication retracting defamatory statements that they have already made against Summit Crest.

            We have the opportunity to resolve this dispute quickly and fairly. We look forward to your prompt response.

Sincerely,

signature

Beth Morrison Klein, Esq.

Cc: clients

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