Mr. Maciej Gąsiorowski, Publisher at o2.pl
Wirtualna Polska Media S.A.
with its registered office in Warsaw at 16 Żwirki i Wigury Street,
02-092 Warsaw | [email protected]
PRE-LITIGATION DEMAND FOR CURE OF DEFAMATORY AND OTHER UNLAWFUL CONDUCT
Specifically, the wrongful conduct includes, but is not limited to, the following:
- Your use of a clickbait and sensationalist headline that misleads readers by distorting the nature of Marzena Słupkowska’s involvement on the set of the film Odkrywanie Ameryki (“Discovering America”), a production concerning gold prospecting in the Sierra Nevada mountains. Through the phrasing of this headline, you falsely insinuated an intimate context with respect to the accompanying photographs—such context being entirely absent from the actual film production;
- The publication and dissemination of false and misleading statements regarding the professional career of my Principal;
- The misrepresentation and distortion of facts concerning my Principal’s media activities and his collaboration with Marzena Słupkowska and other entities;
- The publication and dissemination of false information concerning my Principal’s public activities, including, without limitation, his participation in presidential elections in Poland;
- Referring to my Principal as a “former reporter,” which is factually incorrect and disparages and harms his current professional reputation.
The foregoing list is illustrative only and does not constitute an exhaustive enumeration of all unlawful statements and actions.
DEMAND FOR RELIEF
You are hereby demanded to:
- Pay to Mariusz Max Kolonko the sum of PLN 200,000 (in words: two hundred thousand Polish zlotys) as monetary compensation for the harm suffered, within seven (7) days of your receipt of this demand, to my Principal’s PayPal account: https: [complete account details to be provided].
Please be advised that your failure to fully comply with the above demand within the specified time period will be deemed a final refusal to resolve this matter amicably and will result in the immediate commencement of legal proceedings against you, including, without limitation, claims for monetary damages, injunctive relief, publication of a formal apology, statutory interest for delay, and recovery of all attorneys’ fees and costs as permitted by law.
