B-201 8 ANTWERPEN
MECHELSESTEENWEG 210 A
TEL. (03) 237 21 00 - FAX (03) 237 60 17
JOS VAN GOETHEM|
IN»S DF VOS
To Mr PANOUSSIS Zenon|
Tweede Van Swindenstraat 188
BY NORMAL MAIL
Antwerp, 10 November 1999
CLONEN / SPAINK and PANOUSSIS
My client has just found out that you, because of the lawsuit that has earlier been brought against your friend Ms SPAINK Karin, have opened an entire website under the name www.Klotenknijper.com, that is completely dedicated to the proceedings to-be-started and where not only the integral text of the lawsuit (and the scanned version) are published, but also Ms SPAINK's letter to the Permanent Committee of Control of the Police Services, as well as the integral version of your declarations given in the frame of the investigative research.
In the introductory text my client is insulted anew and is described, among others, as "a shameless creep". These biased descriptions and the reproduction of your one-sided account is again a flagrant attack on the reputation of my client and constitutes moreover a serious breach of his privacy, which only serve to increase the damage already caused.
It should be emphasised in this context that the copies of the declarations given within the frame of an investigation procedure may only be used for legitimate purposes, but can under no circumstances be used for publication, a fortiore when the latter is done in order to cause damage to the parties involved or to third parties.
Due to the aforementioned facts, a new lawsuit will be filed presently.
Moreover, I hereby give notice to both you and Ms SPAINK to immediately remove the webpages in question upon reception of this letter and to abstain, directly as well as indirectly, from every further publication of court documents and insulting remarks and comments by any means of communication whatsoever, in order to - also in your own interest - avoid increasing the damage. In case no furtherance is given to this letter, my client reserves all rights to possibly force a court decision in summary proceedings.
In the hope that you will give the appropriate furtherance to this
P.S. A copy of this letter will also be sent directly
to Ms SPAINK for the record.