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Old 04-26-2007, 03:08 PM
Dr. Jarret Morrow Dr. Jarret Morrow is offline
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Join Date: Apr 2007
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Default University Lab Technologies

April 25, 2007 Federal Express

Cesar Correia
INFOLINK TECHNOLOGIES
662 King Street West, Suite 205
Toronto, ON M5V 1M7


Re: False and Defamatory Statements regarding
University Lab Technologies, Inc., George
Theodore and Dr. Jarret D. Morrow

Dear Mr. Correia:

This office represents University Lab Technologies, Inc. (“ULT”), George Theodore and Dr. Jarret D. Morrow in regard to the above referenced matter. It has come to my clients’ attention that you have made, and are continuing to publish false, defamatory and misleading statements in connection with the business of my clients. You did so using the false name “Bryan Swan.” Pursuant to F.S. § 770.01, this letter shall serve as statutory notice of such false statements and condition precedent to an action for libel or slander. The specific false statements and responses are set forth below:

1. “[ULT’s] products are not FDA approved (contrary to website claims)” – This statement is false because the website does not and never did make such a claim.

2. “[ULT’s] president lives in Canada and does not operate the company.” – This statement is false because ULT’s president, Dr. Jarret D. Morrow currently resides in Florida and does, in fact, operate the company in conjunction with the company’s CEO George Theodore.

3. “George Theodore is a Torontonian, trying to sell stock from the Florida office and enjoying the Florida homestead law to protect his assets in case he gets sued.” – This statement is false in that: (a) George Theodore does not sell stock, but rather has a substantial investment in ULT’s operations in Florida; and (b) George Theodore did not move to Florida to protect his assets from legal actions.

4. “Theodore fled to Florida to avoid his debts in Toronto, Canada.” – This statement is false because Mr. Theodore did not “flee” to Florida, but rather moved his family to Florida to enjoy the benefits of living in the United States and to manage and operate U.S. and Canadian based business interests with offices in Florida.

5. “Main ULT Florida office belongs to, and is paid for, by Activecore, not ULT.” – This statement is false because while the main ULT office is leased by Activecore, ULT subleases some of the space and at no time did Activecore pay the rent to ULT.

6. “The other [ULT] Florida office happens to be George Theodore’s house or basement.” – This statement is false because the ULT has three offices, none of which are in George Theodore’s house or basement. In addition to the executive office in Boca Raton, Florida, ULT has recently obtained another office in Boca Raton consisting of 2400 square feet and has an existing 2400 square foot office in Margate, Florida.

7. “ULT was created, produced, setup and funded by Activecore.” - This statement is false because no funds whatsoever were paid by Activecore to create, produce, setup or fund ULT or for any other ULT purpose. ULT was created, produced and setup by George Theodore, CEO and Dr. Jarret D. Morrow, President. ULT was initially funded by George Theodore and a private investor.

8. “This is called misdirecting funds from a public company to a private company and to the personal benefit of George Theodore.” - This is false because as stated above, no funds were paid to ULT by Activecore and consequently there could not have been any personal benefit to George Theodore.

9. “Hence your ULT investment may have some ownership difficulties.” This statement is false because as set forth above, there has been no funding by Activecore and accordingly no ownership difficulties.

10. “Currently, the Royal Bank of Canada is pursuing George Theodore for a $1,000,000.00 line of credit that has been exhausted and remains unpaid.” - This statement is false because the Royal Bank of Canada is not pursuing George Theodore.

11. “[ULT’s] assets consist of a website and several bottles of vitamin samples.” - This statement is false in that ULT has filed for patents for two of its products, one of the products is currently being mass produced and ULT has invested in an intensive marketing plan, including television commercials, call center, and will be presenting its products at the largest nutraceutical trade show taking place in Las Vegas, Nevada where Dr. Morrow will be a lecturer. The claim that ULT has only several bottles of vitamin samples is a completely malicious claim, particularly since you, Ceasar Correia, have no idea whatsoever about the advancements made by ULT.

12. “[ULT’s] does not own an office, or have office space lease in its name.” - This statement is false because while ULT does not “own” an office, it is currently leasing and/or subleasing three offices.

13. “[ULT] shares its office inside Activecore Florida office, paid for by Activecore.” - This statement is false in that while ULT subleases space from Activecore, ULT pays its sublease obligations.

14. “[ULT] has no foundation, or commitment to anyone.” - This Statement is not only false, but farcical. The principals and employees of ULT have dedicated countless hours, every single day, to ensure that ULT and its products are competing with the best selling products available.

15. “….in that Based on this evidence and Mr. George Theodore’s past, your investment will not be safe.” - This statement is false because you have not demonstrated any evidence or facts, only malicious fabrications. Nor have you demonstrated any facts or evidence of Mr. Theodore’s past; you have only created malevolent lies.

16. “They can close down next week, with little repercussion and your investment is gone, while George is protected by any lawsuit, with the use of the Florida Home Stead Law.” - This statement again is unworthy of a response, because anyone who visits ULT will see for themselves the amount of time and energy ULT principals and employees have put into developing a dramatic product. Indeed, you are clearly unfamiliar with Florida’s Homestead Law, which does not make a Florida resident immune from lawsuits.

17. “They will proceed to open a new company, new website, change label on their vitamin samples, and start again.” - This statement is false in that countless weeks and months have gone into creating a name and reputation for ULT, and my clients will not stand for any malicious, spiteful and false statements published by you.

18. “Their frenzy of press releases is meant to legitimize their cause.” - This statement is false because ULT does not need to legitimize its cause. The press releases are for the purpose of notifying the public, potential business partners and consumers of ULT’s products.

19. “One such press release makes claim to two of their patents. Both patents have been researched in the US Patent & Trademark Office. Patents do not exist, therefore their press release is false, and the patent is also false. The particular patents in question are Arthroleve, and Zenstral, these are false.” - All of these statements are false. The US Patent & Trademark Office does not permit the public to view patent applications submitted by anyone, including ULT. ULT has made claims only that it has submitted patent applications, not that their products are currently patented. Our patent attorneys will verify that these patent applications have indeed been submitted to the U.S. Patent and Trademark Office.

20. “The press release claims of a production run for May 1/2007 is false.” - This statement is false. Our production facility has indeed begun production of our products for availability in May of 2007.

21. “There are no customers, there is no distribution for the product, and there are no sales.” - This statement is true. ULT does not yet have customers for its products as they have not been completed on the assembly line. However, this statement is false in that ULT has developed a magnificent distribution arena for its products.

22. “Therefore, a production run to complete by May 1/2007 is also false, as no company would manufacture large quantities without distribution in place, since these products have a limited shelf life, and would spoil.” - This statement is false in that our products are indeed being manufactured, in large quantities, by our facility partner which is one of the few nutritional supplement manufacturers to receive the Natural Products Association’s (formerly the National Nutritional Foods Association) GMP Seal of Approval.

23. Four reasons they give, for you to buy stock;

a. The press release is listed on Forbes.com, therefore it must be legitimate. (REBUTTLE; Forbes does not check for validity of press releases, anyone that can pay will be listed)”

b. They have a well respected bunch of medical advisors. (REBUTTLE; These doctors are friends of the young doctor J. Morrow, a recent graduate from medical school, and they don’t realize their credentials are being used for a stock scam)

c. Other competitors in the same industry have successfully gone public, with stock valued at $3 per share. (REBUTTLE; Other company’s successful management team, is not proof UNIVERSITY LAB TECHNOLOGIES will be successful. This is perceived value, there have been no sales, as yet, to indicate value of this company)

d. They claim to have reached 8 of 10 steps to list the company on American stock exchange. This 8-th step is a patent-pending for 2 products. (REBUTTLE; They do not list the first 7 steps, and there is NO patent-pending). - ULT, like many companies, would like to trade on a national exchange. Much work is to be done in this regard, and, while no assurances can be given, ULT is committed to doing its best to make this happen.

24. “George Theodore is a Professional Con Artist, according to my research.” - This statement is false, libelous, malicious, disrespectful and completely unfounded (particularly in light of absolutely no competent evidence stated by you, only your fanatical claims).
You also state that Dr. Morrow’s license may be held ransom by the College of Physicians and Surgeons of Alberta “until he provides restitution to those people who have been scammed.” Once again, you have made malicious and defamatory statements that ULT investors have been scammed. All of your alleged evidence is conjured in your head and the actual facts demonstrate that this statement is utterly false.
You state that Dr. Morrow and George Theodore are “very timid and scared.” This is a false statement in that they are far from timid and scared. In fact, they are angry as opposed to scared and are taking legal action as opposed to being timid. Dr. Morrow and George Theodore welcome any investor to the executive office to show how your outrageous claims are completely foolish and designed to harm them in their business because of a prior issue between your and Mr. Theodore which resulted in an embarrassment to you.

Each of your false statements was published in the following websites: biospace.com, 419legal.org, scamfraudalert.com, antiscam.net, friends in business.com and readablog.com. The publication of these statements was malicious and without any basis. The publication of these false statements to any other persons or business relations of my client constitutes defamation, trade libel and interference with business relationships. Your statements have resulted and are continuing to result in damage to my clients’ good name and reputation within the community, and within the industry. Furthermore, these statements represent unjustifiable interference with ULT’s business and contractual relationship with its shareholders and others.

Accordingly, we hereby demand that you (1) immediately cease and desist from publishing these false, defamatory and misleading statements; (2) publish a retraction of these statements within five (5) days of date of this letter; (3) remove all original statements including retractions from these websites or any others to which they were posted within five (5) days of publishing the retraction: and (4) pay each of my clients the sum of $1,000,000.00 in damages within five (5) days of the date of this letter. If these demands are not met in a timely fashion, be advised that my clients will not hesitate to pursue every legal and equitable remedy under the law. This includes applying to the Court for a temporary and permanent injunction and pursuing claims for damages. I trust my clients’ position is clear.

Govern Yourself Accordingly.

Sincerely,


Blaine H. Hibberd
For the Firm

cc: University Lab Technologies, Inc.
George Theodore
Dr. Jarret D. Morrow

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