RE: Pitney Hardin LLC

This page contains and includes our opinions:

Below is the "AUP" complaint sent to ServePath Hosting by Michael J. Dunne, "attorney" for HP Financial Services, employed by the "law firm" Pitney Hardin. This was the tactic used by HP to attempt to remove the website "" from public view. This "back-door" tactic was used by HP because HP had apparently exhausted all legal remedies, the aforementioned document being, of course, legal protected speech. The sleazy tactic shown below is often one of the ploys used by unscrupulous corporations, and even less scrupulous, dirty little law firms, to side-step that pesky thing called the 1st Amendment. Indeed, scum-bags everywhere live in fear of that small addition to the US Constitution. It allows light to be directed onto their scurrilous activities, and cockroaches always run from light. It appears that, in the document below, Mr. Dunne has further engaged in a classic instance of defamation against us. He has purposely, apparently maliciously, and with forethought, written and edited the letter to assert to our business associate, ServePath Hosting company, that, in FACT, we have committed one or more CRIMES by posting our review of HP's products and business practices (to wit: "ServePath has the right and, indeed, the obligation to remove such abusive and illegal content immediately"). This was written on behalf of and at the direction of HP, by one stupid son of a bitch: Michael J. Dunne "attorney" for Pitney Hardin. This issue has gone back to our attorneys for an assessment of the wisdom of filing suit against Pitney Hardin and HP for defamation. It seems Mr. Dunne feels perfectly comfortable asserting untruths about others, while screaming bloody murder regarding truths and opinions that may be voiced about his client, HP. Well, ain't that just lawyers for you. And they wonder why they're the butt of every other joke in America.

We believe ServePath was quite miffed when they discovered they'd been duped by HP's scurrilous, counter-productive attorneys (Pitney Hardin), and Servepath expressed a willingness to discuss the reposting of our legal HP document. We fired them anyway without discussion. ServePath is responsible for their decisions, and we submit that companies in need of a dedicated server look elsewhere for competent, professional, educated hosting.

So what has the brilliant legal mind, Michael J. Dunne, accomplished by writing and disseminating the document below? For his client, HP, he has delivered to us more material which must be appended to this case, as it is no longer just an argument over our product review, but a full-fledged 1st Amendment issue. He has caused us to seek total, comprehensive protection for this document by 1st Amendment attorneys we've used for many years, who've delivered perfect scores in every instance, in court and out. He has shown the world that he ain't the brightest bulb in the string himself. For his law firm, he has shown to what scummy depths they'll sink in the hope of landing a "really big" client (HP). He's shown the world the TRUE degree of their competence or lack thereof. He has bamboozled an entire major hosting company (ServePath) and almost certainly pissed them off to no end. And all for what? No one really knows. We know only that this is why the country hates attorneys. To be utterly devoid of moral fiber is bad enough -- attorneys are taught that in law school. To be incompetent and counter-productive (HP is worse off than before it hired these nitwits) is unconscionable. It's just ridiculous. And by the way, HP and Pitney Hardin, go fuck yourselves. You've caused enough trouble for us and for everyone involved with you in this case and in many others. Cease and desist.

For the record, we do ABSOLUTELY believe that some or many HP employees are dishonest.
For the record, we do ABSOLUTELY believe that some or many HP employees are underhanded.
For the record, we do ABSOLUTELY believe that some or many HP employees are insane.
For the record, we do ABSOLUTELY believe that some or many HP employees are intentionally attempting to defraud us. To form your own opinion, read the entire review here:



Pitney Hardin llp
P.O. BOX 1945

973-966-8138                                                                                                                   (DELIVERY TO)
E_MAiL                                                                                                                         200 CAMPUS DRIVE
MDUNNE@PITNEYHARDIN.COM                                                                    FLORHAM PARK, NEW JERSEY 07932-0950
(973) 966-6300
FACSIMILE (973) 966-1015

FACSIMILE (212) 916-2940

FACSIMILE 32-02-514-16-59

February 17,2006
Mr. John Keagy, CEO
ServePath LLC
360 Spear Street
Suite 200
San Francisco, CA 94105
Re:      Abuse Complaint

Dear Mr. Keagy:

As discussed with Mr. Kratt of your office, this firm represents Hewlett-Packard
Financial Services Company ("HPFSC").

On Friday, February 3, 2005,1 spoke with Mr. Kratt and called to his attention the web pages that are found at: []. As Mr. Kratt subsequently confirmed to me, and as indicated by our own research, ServePath owns the IP address for those web pages.

The content of the web pages contains "threatening, libelous, obscene, harassing or offensive" material that is specifically prohibited by ServePath's Acceptable Use Policy. The web pages at issue were posted by the author with the obvious intent to embarrass, harass, and intimidate HPFSC and the individuals who are named in those pages. For example, the web pages at issue contain the following obscene and threatening statements about HPFSC: "still you attempt to virtually extort funds from us . .."; "Please do not make us book a flight to visit you in your office. It will not be pretty or fun" ; "go fck yourselves"; "shove it up your collective asses." The web pages also accuse HPFSC employees of such things as being "dishonest,""underhanded," "insane," and "intentionally attempting to defraud us."

The posting, display, and publication of the foregoing content are actionable. It is equally clear that the content of those pages violates ServePath's Acceptable Use Policy and the 1389217A05021706

Pitney Hardin llp
Mr. John Keagy, CEO February 17, 2006 Page 2

Acceptable Use Policies of ServePath's upstream providers, and that ServePath has the right and, indeed, the obligation to remove such abusive and illegal content immediately.

HPFSC hereby confirms the demand we made to Mr. Kratt on Friday February 3, 2005, that ServePath immediately and permanently remove the pages containing the offending content that appear at the above referenced web address. At this time, HPFSC does not seek and has no interest in removing the entire [  ] web site, but only the pages that appear at the full extension as referenced above. However, HPFSC reserves all of its rights should the abusive and offensive postings continue.

HPFSC would prefer that this matter be resolved in an efficient business-like manner by ServePath's enforcing its rights and obligations to remove the above-referenced pages. Please confirm by February 22, 2006 that ServePath has permanently removed the above-referenced pages.

Please do not misinterpret HPFSC's forbearance to date or underestimate HPFSC's resolve to have the offending content removed.

Very truly yours,