James Imbriaco
Times Mirror
Two Park Avenue
New York, NY 10016
Dear Mr. Imbriaco:
"(L)et me assure you the SUN was not required to pay you money or obtain your written consent to publish photographs of you and others acting in concert with you in connection with events described in news stories published in the SUN, as you appear to suggest in your letter of September 8, 1999 to Robin Milligan of SunSource. The First Amendment simply would not tolerate it."
"Our web site is a compilation of personal photographs and related news articles about First Amendment activities outside the White House. We have personally witnessed or been the subject of all of the stories. We include articles by reporters from the Baltimore Sun because we were specifically named or involved in the events described. We have never asked for or been offered any money for providing an archive of this little-explored, but historically significant, subject." First letter to Robin L. Milligan.
"(O)ur web site is intended as a vehicle of criticism, comment, news reporting, teaching, scholarship, and research concerning the history of Lafayette Park, and the changing legal perimeters of freedom of expression in the nation's preeminent public forum; as such, the two articles to which you refer are merely footnotes to the substance of our web site..." Second letter to Robin L. Milligan.
THIS LETTER IS NOT INTENDED TO BE, NOR SHOULD IT BE CONSTRUED AS A COMPLETE STATEMENT OF THE FACTS AND CLAIMS RELEVANT TO THE MATTERS SET FORTH HEREIN, OR OF MY POSITION WITH RESPECT TO SUCH MATTERS.
Very truly yours,
W. Thomas