Accordingly, we demand that you (1) rectify the false accusations that you have made towards Mr. Alasow (2) immediately cease and desist your unlawful defamation of Mr. Alasow and (3) provide us with prompt written assurance within 30 days that you will cease and desist from any further defamation of Mr. Alasow's character and reputation.
August 24, 2016
Federal Republic of Somalia
Ministry of Internal Security
Attn: Mr. H.E. Abdirizak Omar Mohamed
Maka-Al-Mukarama Main Road, Shangani District
Tel: +252 61 6462606 or + 252 699 777 024
Subject: cease and desist order
Dear Mr. Abdirizak Omar Mohamed,
Mr. D. Alasow, the owner "Waagacusub Media”, and of the company named "Onderzoek Journalist Alasow”, has authorized me, Mrs. S. Roblè-van Deursen, Attorney at Law, to represent him and to act in all matters on behalf of himself and "Waagacusub Media” and "Onderzoek Journalist Alasow”.
If you are represented by legal counsel, please direct this letter to your attorney immediately and have your attorney notify us of such representation.
You are hereby directed to:
CEASE AND DESIST ALL DEFAMATION OF MR. DAHIR ALASOW’S CHARACTER AND REPUTATION.
On October 28, 2015, you sent a letter with the following content:
<Beginning of content>
This is to conform that Dahabshiil is a legally registered Remittance Company that operates throughout the globe.
It has been brought to my attention that Mr. Alasow’s website publication alleges that Dahabshiil supports terrorism, there is no evidence that supports Dahabshiil is involved in any criminal activity. Furthermore, then are no evidence that suggests of any involvement of dahabshiil is weapons trafficking as claimed by Mr. Hassan in a publication on Mr. Alasow website.
The author & publisher of the said publications (Aka) Dahir Alasow is a known Fraudster & extortionist who spreads defamatory & false information with the intent of blackmailing prominent & high level government officials including the president in order to extort money from them.
<End of content>
Mr. Alasow is an outstanding and distinguished journalist. His career in journalism spans years. He covered a broad array of stories with insight and aplomb during his career, from war to politics to sensitive portraits of artists. He has spent years serving the Somali community in his profession and building a positive reputation.
Mr. Alasow has learn through the above quoted letter, that you have engaged in spreading false, destructive, and defamatory accusations about him. My client did not publish any defamatory nor false information in any way whatsoever. All of his facts and publications were rock solid.
Under the international law, it is unlawful to engage in defamation of another character and reputation. Defamation consists of:
(1) a statement that tends to injure reputation;
(2) communicated to another; and
(3) that the writer knew or should have known was false.
Your defamatory statements involved the above mentioned letter of October 28, 2015. In this letter you characterized Mr. Alasow as "a known fraudster & extortionist who spreads defamatory & false information with the intent of blackmailing prominent & high level government officials including the president in order to extort money from them”.
Accordingly, we demand that you (1) rectify the false accusations that you have made towards Mr. Alasow (2) immediately cease and desist your unlawful defamation of Mr. Alasow and (3) provide us with prompt written assurance within 30 days that you will cease and desist from any further defamation of Mr. Alasow’s character and reputation.
If you do not comply with these cease and desist demand within this time period, Mr. Alasow is entitled to seek monetary damages and equitable relief for your defamation. In the event you fail to meet these demands, please be advised that Mr. Alasow has asked us to communicate to you that he will pursue all available legal remedies, including seeking monetary damages, injunctive relief, and an order that you pay court costs and attorney’s fees. Your liability and exposure under such legal action could be considerable.
Before taking these steps, however, my client wishes to give you one opportunity to discontinue your unlawful conduct by complying with this demand within 30 days.
If you or your attorney have any questions, please contact me directly. I can be reached on either my telephone number (31) 070-392 53 67 or fax (31) 070-392 53 68 or
by e-mail (email@example.com).
Mrs. S. Roblé-van Deursen LL.M.
Attorney at Law
Enclosure: letter of October 28, 2015