LEVY


,5 BURRELL


 

December 4, 2017

VIA EMAIL AND FIRST CLASS MAIL

Patricia Glaser

Glaser Weil

10250 Constellation 
19th Floor

Los Angeles, CA 90067

Re: Matt Dababneh

Dear Ms. Glaser,

Mr. Dababneh?s threat to sue Ms. Lopez for damage to his reputation is the kind of intimidation that
keeps many sexual harassment victims silent. Ms. Lopez has bravely spoken out and she will not be

sHenced.

First, truth is an absolute defense to any claim of defamation. Ms. Lopez will vigorously assert this
defense.

Second, bringing forward allegations of sexual assault against a sitting Member ofthe Legislature serves
the public?s interest in having a governing body of elected officials who do not abuse the power vested
in them. The public?s interest in this issue is evident from the fact that the Assembly has held hearings
on this issue, has called for victims to step forward, and has promised they will be protected from
retaliation. Ms. Lopez? communications to the Assembly and the public'regarding Mr. Dababneh further
the common interest Ms. Lopez shares with the Assembly and the public in ending sexual harassment

and assault by public servants.

Finally, defamation lawsuits compensate for damage to reputation. Were Mr. Dababneh to proceed with
such a claim, he would be placing directly at issue the question of his reputation in the Capitol. ln
defending a defamation lawsuit, Ms. Lopez would necessarily conduct discovery into the nature of Mr.
Dababneh?s existing reputation. Indeed, as the California Supreme Court ruled more than fifty years ago,
discovery into the reputation ofan individual alleging defamation is relevant. Chronic/e Pub. Co. v.
Superior Court, 54 Cal.2d 548, 559?61 (1960). While we understand that many lawmakers and others
who work in the Capitol might not volunteer their opinions regarding your client, we are confident that

they would testify truthfully under oath if questioned about this subject.

Sexual abuse thrives in silence. Perpetrators count on shame and fear of reprisal to stop their victims
from talking about what happened. Ms. Lopez has chosen to break her silence and speak out. Our firm
stands with her and any lawsuit Mr. Dababneh launches will be met with a vigorous defense of truth.

Sincerely, a.
VA

\Leslie F. Levy 7

I

 

180 Grand Avenue, Suite 1300
Oakland, CA 94612

p. 510.318.7700 f. 510.318.7701
levyvinickcom

.7. .71.. 

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