Dear Attorney Velella:
Perhaps I have not made myself clear to you:
You raised the issue of the video and you and your client will live by it or die by it.
Also, you lied in your letter, counselor. The police were called well before my clients reached the doorway. Your clients called the police just after my clients presented a printout on wrongful dishonor of a check at the cashier's window. And Mr. King did not use any foul language at that point, he did not do so until he left the building, wherupon he will freely admit that he called Carlo Caramanna a "Motherfucker." Of course all of that will be clear on the videos that you so proudly trumpeted in your letter. Let me quote you again so there's no mistake counselor:
"Please be advised that we do have video from the South End Branch from March 24 that captures interaction between staff and your clients and have also taken statements from the affected employees."
Sir, I couldn't care less about the self-serving employee statements. The proof is in the video from that day and all other days that you have maintained and that the court will compel you and your client to produce.
Meanwhile regarding Mr. Gillenwater's claims, I am hereby alerting attorney Michael Cunningham that he too, will be a named Defendant given the allegations you made at page three of the attached letter "Citibank Response 1," in which you claim that he would not grant authorization for the bank to cash the check, given that's not what Attorney Cunningham represented to Mr. Gillenwater.
Lastly, you may want to seriously consider your ethical obligations regarding the statement you wrote to me about the nature, timing and sequence of the call to the police. You have an ethical responsibility not to mis-report known facts to the tribunal and to your brethren. You also have an ethical responsibility not to threaten actions of harassment for my clients' exercise of their First Amendment Rights on any blog, website or in person near your bank branches unless you intend to seek redress for such activity. In the event that you do, you will be met with substantial resistence and the underlying facts of all of this case will emerge.
But of course you're not concerned about that. Because you have everything on video.
Now I have made myself clear and we will see you in court.
Sincerely,
John N. Moore, Esq.
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