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NOTICE TO CEASE-AND-DESIST
FROM:
Bob Brown (Aka Robert A. Brown)
Pan-African Roots
1016 W. Jackson Blvd. Suite 1056
Chicago, IL 60607
25 September 2024
Re: Cease-and-Desist Notice
Unlawful Use of Name, Photograph, Likeness, Speech, and Associated Documents
Defamation of Character and Association with and Service to various political parties, USA
Distributed via certified mail, return receipt requested, email, and other available means
CITED INDIVIDUALS:
Leila Wills, Executive Director
Historical Preservation Society of the Illinois Chapter of the Black Panther Party
1507 East 53rd Street, Suite 485
Chicago, IL 60615
Bobby Rush, Pastor
Beloved Community Christian Church
6430 South Harvard Ave.
Chicago, IL 60621
(Complete list to Follow)
BOB BROWN, [Aka Robert A. Brown], is a respected person in the national, Pan-African, and international community and one who has spent their entire life building a positive reputation and one who assiduously protects his name, integrity, biography, history, and image. Mr. Brown has spent 61 years as a political and social activist and organizer, engaged in the lifelong struggle to help liberate, unify and advance Africa, and the more than 1.5 billion African People, in the 125 countries in the 5 Regions in Africa, the 6th Region (African Diaspora), and all of Humanity. Mr. Brown has supported no effort to negatively affect those cited above.
Mr. Brown’s work, study and struggle, his personal and political associations, principled declarations and, clear direction of his goals and objectives are of fundamental value to his life, reputation, and wellbeing
Nevertheless, we have been informed that you have Unlawfully used Mr. Brown’s name, likeness, photograph, speech, associations and associated documents in inaccurate depictions and unfounded information that is damaging to his personal and professional character and without his permission.
Specifically, it appears that the above cited individuals and those acting in the name or serving as representatives of the cited organizations have repeatedly, consistently, and deliberately used Mr. Brown’s name, likeness, words, biography and history in connection with building and sustaining support for a collective effort to insert, enter and include the Illinois Chapter of the Black Panther Party into “The National Register of Historic Places.”
- See:
This misuse includes but is not limited to the above cited persons, and others, in connection with the establishment of a proposed project to Landmark the “Historical Preservation Society of the Illinois Chapter of the Black Panther Party.” See also:
- WTTW, A ‘Black Voices’ Community Conversation: Latest Efforts to Preserve Legacy of Illinois Black Panther Party, Acacia Hernandez | January 29, 2024
- Illinois Black Panther Party Honored In New Exhibit Ahead Of DNC, Leen Yassine, Block Club News in Chicago, 7 August 2024.
- “When the Democratic National Convention came to Chicago in 1968, the Illinois Black Panther Party was just beginning.
- That August 56 years ago, Bobby Rush, Bob Brown and Fred Hampton came together to found the party’s Chicago chapter
- Now --- ahead of another Democratic National Convention in the Windy City --- the Epiphany Center for the Arts and the Historical Preservation Society of the Illinois Chapter of the Black Panther Party are honoring the Illinois chapter’s history of Black political struggle in a new exhibit.”
Under common and State laws:
“Any person who knowingly uses another's name, voice, signature, photograph, or likeness, in any manner, on or in products, merchandise, or goods, or for purposes of advertising… without such person's prior consent” shall be liable for damages and attorney's fees (and potentially punitive damages). It is unlawful for an individual to make deliberate statements that intend to harm a person’s reputation without factual evidence or based on hearsay.
Defamation by association refers to written or spoken statements that are false, unprivileged, and harmful to someone's reputation. Defamation can occur in many places, including the workplace, media, school, home, or in a public forum.
Mr. Brown avers categorically that at no time did he, his family or assigns at any time offer, gift or provide any of the above cited individuals or representatives, his permission, right, or leave to use his name, likeness, photograph, biography and/or history for any purpose, at any time.
Further, Common laws and State Statutes set forth remedies and provides the right to “bring an action to enjoin such unauthorized publication, printing, display or any other public use and to recover damages for any loss or injury sustained by reason thereof…”
Aside from the flagrant violations against Mr. Brown as outlined above, the included individuals and representatives appear to have engaged in (or intended to engage in) in an intentional attempt to defame Mr. Brown by deliberately associating him with the National Democratic Party, and/or its Illinois, Cook County and and/or Chicago chapters, and/or its 1968 and 2024 National Conventions, an allegation of an association which is entirely false, and which may be detrimental to his reputation and standing in the local, national, Pan-African, and international communities with which he has engaged for his teenage and entire adult life.
If you do not cease and desist any and all related use of my name and likeness, etc. as cited above, a lawsuit may be commenced against you.
This shall serve as a formal demand letter demanding that you provide us written assurance within a reasonable time that you will cease and desist from the use of Mr. Bob Brown’s name, likeness, use, biographical information, history, etc., and publish retractions of any and all statements that presume a defamatory association with the organizations cited above, and/or similar organizations and situations.
If you do not comply with this cease-and-desist letter within the aforementioned reasonable time-period, then a lawsuit may be filed in the proper jurisdiction seeking monetary damages as well as pursuing all available legal remedies for your individual and/or organizational involvement.
Sincerely,
<<Bob Brown>>
Bob Brown
Director, Pan-African Roots
Organizer, All-African People’s Revolutionary Party (GC)
Founder, and former co-Organizer, Illinois Chapter of the Black Panther Party; and former Midwest Organizer, March 1968 to December 1968 [appointed by Kwame Ture]
Former Director of Chicago Office of SNCC, and former Midwest Organizer ((appointed by Joyce Brown)
Former Organizer, Chicago Chapter of CORE (under the leadership of Bob Lucas, Jorja English Palmer, Elmo Taylor, Ellis Wicks and Murton Shanklin)
[List of additional organizational affiliations, worldwide, historical and current, furnished upon request.]
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