From:   "Mike Regas" [email protected]
To:   [email protected], [email protected]  
Subject:   Scentura Creations  
Date:   Mon, 26 Aug 2002 16:50:48 -0400  

VIA CERTIFIED AND REGULAR EMAIL 
[email protected] 
[email protected] 

Re: Scentura Creations, Inc. 

Dear Mr. Dombrowsky: 
  
This firm represents Scentura Creations, Inc. (�Scentura�).  We have been 
asked to contact you regarding your website located at 
www.csh.rit.edu/~davek/scentura.html and certain defamatory statement made 
against Scentura contained therein.  Please be advised the factual information 
contained in your website is, per se, inaccurate, misleading and defamatory 
and in violation of Federal Trade and common law.

First, please be advised that Scentura is not a fictitious name for local 
distribution offices.  Scentura is located only in Atlanta, Georgia and is in 
the business of bottling its line of perfume which is sold to distributors 
around the world.  The list of businesses you identified are not related to 
Scentura and Scentura has no way of controlling their method of selling 
perfume or hiring its employees.  Scentura simply sells its products to those 
groups for resale/distribution to the public.   If, in fact, their hiring and 
employment practices are offensive or even illegal, Scentura has no knowledge 
of same.  Certainly, Scentura does not condone illegal activity.  However, 
Scentura does not have any control over these alleged practices by entities or 
persons unrelated to Scentura.  

Second, statements on your website such as: 

�These people lie for a living. What they do is at best unethical, and at 
worst illegal. Much like scams such as Amway or CutCo, Scentura is constantly 
being investigated by the IRS for fraud and illegal business practices. The 
Federal Trade Commission has been alerted of this company and others like it, 
but strong legislation does not exist in this area, and little can legally be 
done to stop them.�

and 

�This is a pyramid scheme and it is illegal� are the real lies.  You simply 
are wrong and your website is hurting Scentura�s business.  It must stop.

Demand is hereby made that you immediately cease and desist all defamatory 
statements made against Scentura and that all reference to them be removed 
from your website.  Scentura has already been materially damaged by your 
actions and intends to hold you responsible for all damages which have been 
incurred to date and which are hereafter incurred.  If you do not immediate 
cease and desist, Scentura will take such action as may be necessary to 
protect its interest including filing of a lawsuit against you, personally, as 
well as any other person or entity responsible for publication of the website 
including Rochester Institute of Technology.  If your website is not removed 
within 20 days of this date of this letter, we will send a copy of this letter 
to Dr. Fred W. Smith, Albert J. Simone and Michael Cooney, Esq.  Further, if 
suit is filed, Scentura will seek injunctive relief prohibiting further 
violation of the Agreement as well as all available damages for your actions 
including damages, costs of litigation, attorney�s fees and punitive damages.

This firm is not attempting to provide you with legal advise.  In that regard, 
we urge you to consult with independent counsel to discuss the very serious 
nature of the matters contained herein.  Govern yourself accordingly.  

If you have any questions, please contact the undersigned. 

Sincerely, 

Michael G. Regas II 

MGR/ 

cc:     Mr. Lawrence Hahn, Mr. Robert Hasty 



Michael G. Regas II 
Scherffius, Ballard, Still & Ayres, LLP 
1201 Peachtree Street, NE 
400 Colony Square, Suite 1018 
Atlanta, Georgia 30361 
(404) 873-1220 
(404) 876-4951 Computer Fax 
[email protected]