EXHIBIT B

Case: 2:17-cv-00720-EAS-EPD Doc #: 1-2 Filed: 08/16/17 Page: 1 of 3 PAGEID #: 51
Abtd R. Quraahi 

Direct Dial: 202.637.2240 

E-Mail abid.quraahiCiw.com 

LATHAM&WATKI NS tLP 

June 15,2017 

VIA EMAIL & US. MAIL 

Andrew Anglin 

The Daily Stonner 

P.O. Box 208 

Worthington, Ohio 43085 

555 Eleventh Stn!et, N W., Su~e 1000 

Washington, D.C. 20004-1304 

Tel: +1 .202.637.2200 Fax: +1.202.837.2201 

www.lw.com 

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Milan 

Re: Retraction of Defamatory Daily Stonner Article Regarding Dean Obeidallah 

Dear Mr. Anglin: 

Latham & Watkins LLP and Muslim Advocates represent Mr. Dean Obeidallah in 

connection with the June 1, 2017 article you wrote and published on the Daily Stonner internet 

website entitled "Dean Obeidallah, Mastermind Behind Manchester Bombing, Calls on Trump to 

Declare Whites the Real Terrorists" (the "Article"). The Article is false and defamatory, and has 

caused significant harm to Mr. Obeidallah's name and reputation. The Article also jeopardizes 

his safety by encouraging readers to "confront" Mr. Obeidallah. We demand that you 

immediately take corrective action by retracting the Article, publishing an apology, and deleting 

comments threatening violence against him. 

While Mr. Obeidallah champions freedom of expression and supports diversity of 

opinions, your publication of untrue and damaging statements-made without any factual 

basis-is not entitled to legal protection. The Article contains numerous false, misleading, and 

inaccurate statements regarding Mr. Obeidallah. For example, the title of the Article falsely 

states that Mr. Obeidallah is the "mastermind" of a horrific criminal act. The Article falsely 

portrays him as a member of a terrorist organization who is wanted by international lawenforcement authorities. The Article falsely states that Mr. Obeidallah is planning terrorist acts. 

In addition, the Article fabricates tweets purportedly made by Mr. Obeidallah, attributing to him 

responsibility for criminal actions committed by others. All of the inaccurate and disparaging 

statements in the Article were apparently made without any regard for the truth. 

The false and misleading statements in the Article have damaged Mr. Obeidallah's 

reputation, coopted his name and likeness, and prompted threats against his life and physical 

Case: 2:17-cv-00720-EAS-EPD Doc #: 1-2 Filed: 08/16/17 Page: 2 of 3 PAGEID #: 52
June 15, 2017 

Page2 

LATHAMe.WATKINS UJ 

safety. Accordingly, we demand that you remove the Article, publish a retraction and apology, 

and take all necessary steps to delete comments threatening his security. We also demand that 

you preserve and maintain all records, documents, electronically stored infonnation, and any 

other materials related in any way to the Article, including any factual diligence you performed 

prior to publishing the statements regarding Mr. Obeidallah. If you have any questions about 

your preservation obligations or the elements of a defamation action, we strongly suggest you 

consult an attorney. 

If you fail to comply with the demands in this correspondence by June 22, 2017, Mr. 

Obeidallah intends to take all appropriate and necessary steps to protect his reputation and 

redress the injuries you have caused. Please know that Mr. Obeidallah expressly reserves all 

rights and remedies. 

Sincerely, 

Abid R. ureshi 

LATHAM & WATKINS LLP MUSLIM ADVOCATES 

Case: 2:17-cv-00720-EAS-EPD Doc #: 1-2 Filed: 08/16/17 Page: 3 of 3 PAGEID #: 53