7/31/2019 Response to Rutledge

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颼葟葟

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 Dale’s 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 Dale’s 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 Dale’s sister provided information to me, that is also false. That informationwas 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 Rutledge’s 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, I’m sure you also aware that truth is an

absolute defense as are the case in this matter.

7/31/2019 Response to Rutledge

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Mr. Brown, you should know that I have been made aware of a failed attempt by Dale’s 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 I’m 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. Rutledge’s 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 mywritings 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.

Sincerely,

Joanie Scott