Due directly to the acts of Defendant Hanson, the nonprofit patient advocacy that has been my employer for nearly ten years is unable to pay me a salary. I have not been paid since March 2008. Also because of the acts of Defendant Hanson, my ability to find work in the industry in which I have expertise has been critically limited. On 21 January 2010 I was determined in forma pauperis by this Court. It would be extremely difficult, if not impossible, for me to incur the costs of travel and lodging in addition to the cost for a deposition of Defendant Hanson, thus if the instant motion is denied I may not be able to depose this Defendant.

re: Demand for Immediate Removal and Cessation of Statement Plaintiff Glenn Hagele is Broke

Mr. Donahue,

It has come to my attention that in addition to publishing a publicly accessible statement that I am insolvent, your client has, under the alias of “Cataract Scam Watch”, published an inference that I am “broke” at Internet Unique Resource Locator (URL) http://www.lasik-flap.com/forum/viewtopic.php?t=2794, with hyperlinks to a statement that I am “insolvent” at URL http://www.scribd.com/doc/25868998/Glen ... -Insolvent
The URL containing the statement Glenn-Hagele-Makes-a-Declaration-in-Court-Claiming-to-be-Insolvent is itself defamation per se.
Demand is herewith made that Mr. Hanson immediately stop publishing the false statement that I am broke and he take prompt corrective action, absent which I shall have no choice but to seek appropriate redress with the Court.

Mr. Hanson has made a written statement of fact, rather than opinion, that violates my constitutional rights, places me in a false light, tends to injure and in fact does cause injury to my occupation and character, and/or exposes me to hatred, contempt, ridicule or shame. Moreover, Mr. Hanson’s written statement constitutes defamation per se, which causes me substantial injury and interferes with my ability to conduct my business.

I herewith demand of your client the following:

1. Immediately remove or cause to be removed those portions of all publicly accessible Internet web pages he controls that include any statements stating or inferring that I am broke, including, but not limited to the statement published at URL http://www.lasik-flap.com/forum/viewtopic.php?t=2794.

2. Immediately remove or cause to be removed any inference or statement that I am insolvent from the URL http://www.scribd.com/doc/25868998/Glen ... -Insolvent (i.e. the portion of the URL “Glenn-Hagele-Makes-a-Declaration-in-Court-Claiming-to-be-Insolvent”.

3. Immediately remove or cause to be removed all publicly accessible newsgroup, bulletin board, or chat room statements stating or inferring that I am broke.

4. Immediately privately retract all inferences or statements that I am broke that were distributed via email, conventional mail, or any other private means.

5. Refrain from publishing, republishing, or communicating in any manner to any third-party the inference or statement that I am broke.

If I do not receive by 5:00pm Friday 29 January 2010 a confirmation from you that Mr. Hanson’s statement has been removed as defined above, I will seek injunctive relief from the Court that Mr. Hanson refrain from making this defamatory statement.

I can assure you that if this nonsense is not off the Internet by end of day Friday, your client will be explaining his actions to the Court.