From: "Webb, Dan K."
Date: September 6, 2011 6:43:13 AM PDT
To: "
[email protected]
Subject: Jonah Shacknai
Dear Ms. Bremner,
I am an attorney for Jonah Shacknai, retained by him to address false public statements you have made, which have the effect of severely damaging Mr. Shacknai's personal and business reputations. Over the past several days, you have made a series of inaccurate and utterly unsupported statements about the facts surrounding the tragic deaths of Max Shacknai and Rebecca Zahau. However, what is most concerning are recent false public statements you have made that Mr. Shacknai, because of his business success, has somehow improperly influenced the investigations and conclusions of four different, and, independent California law enforcement agencies. You have further made public comments that these agencies have applied a different standard in conducting their investigations because of Mr. Shacknai's wealth. You have absolutely no facts to support these false and irresponsible statements, and you are fully aware that such facts do not exist. Please know that your false public statements constitute defamation, per se, and under law, entitle Mr. Shacknai to recover from you, and your law firm, substantial damages.
Moreover, your statements and actions are highly insensitive on a human level. Mr. Shacknai and his family have suffered two tragic losses under the harsh and unkind glare of a national media frenzy you have now helped sustain. It is ironic that Mr. Shacknai went through the entire law enforcement investigation, at all times cooperating completely with several police authorities, and never once considered retaining an attorney. It is only now, after authorities have announced the conclusions of their comprehensive investigations, that Mr. Shacknai finds it necessary to consult with me because of the false and irresponsible public statements you are making, harming his personal and business reputations. Importantly, throughout the investigation, Mr. Shacknai was not advancing any particular outcome regarding Rebecca Zahau's cause of death, because he had absolutely no knowledge of what happened the night she died.
It is not, in any way, the intent of this communication to advocate that your clients accept the results of the investigation. They are, of course, entitled to their point of view regarding this matter. Nevertheless, you must cease and desist from making any further false public statements about Mr. Shacknai. I appreciate your immediate attention to the seriousness of this matter.
Dan K. Webb
Chairman
Winston & Strawn LLP
35 W. Wacker Drive
Chicago, IL 60601-9703