217 Problems

Here is the second part of the “legal” Google template notice.

FORMAL LEGAL NOTICE AND DEMAND LETTER

RE: Criminal Defamation, Cyberstalking, and Harassment – The 217 Group Administrators and Moderators

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VIA EMAIL AND CERTIFIED MAIL – RETURN RECEIPT REQUESTED

[Current Date]

TO: The Administrators and Moderators of "The 217 Group" (Facebook)
c/o Facebook, Inc.
1 Hacker Way
Menlo Park, CA 94025

FROM: Matthew Fricke
[Your Full Address]
[Your Phone Number]
[Your Email]

RE: FORMAL LEGAL NOTICE – CRIMINAL DEFAMATION, CYBERSTALKING, HARASSMENT THROUGH ELECTRONIC COMMUNICATIONS, AND HATE CRIME – DEMAND FOR REMOVAL AND PRESERVATION OF EVIDENCE

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I. INTRODUCTION

This letter serves as formal legal notice to the Administrators and Moderators of "The 217 Group" (the "Group"), a Facebook-based community group. The purpose of this notice is to inform you of ongoing criminal conduct occurring within your Group, to demand the immediate removal of all defamatory and harassing content, and to place you on notice of your potential civil and criminal liability for allowing such content to remain.

I am the target of a coordinated campaign of defamation, harassment, and cyberstalking that has occurred within your Group. Multiple individuals—including Serina Garcia-Heintzelman, Stephanie Renee, Rylee Gibson, and others—have posted or reposted false, defamatory, and harassing statements about me. These posts have been viewed more than 121,000 times across multiple platforms, including your Group.

This letter is not a threat—it is a legal notice. You are now on formal notice of the unlawful conduct occurring within your Group. Your failure to act may expose you to civil and criminal liability.

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II. THE UNLAWFUL CONDUCT

A. The Defamatory Statements

Multiple individuals have posted or reposted statements containing the following false and defamatory assertions:

· That I "strangled" my ex-wife.
· That I "nearly killed" my ex-wife.
· That I am a "pe*****le."
· That I am a "piece of s**t."
· That I am a "drunk."
· That I am "insanely mentally ill."

These statements are false. They are not opinions—they are false assertions of fact that impute the commission of serious criminal offenses. Under Illinois law, such statements constitute defamation per se—the damage to my reputation is presumed.

B. The Coordinated Harassment and Cyberstalking Campaign

The posts and comments directed at me constitute a course of conduct using electronic communication directed at a specific person, which has caused me severe emotional distress. I have been formally diagnosed with Complex Post-Traumatic Stress Disorder (CPTSD) and Persistent Depressive Disorder (PDD) —conditions that have been directly exacerbated by this coordinated attack.

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III. CRIMINAL STATUTES VIOLATED

A. Cyberstalking – 720 ILCS 5/12-7.5

Under 720 ILCS 5/12-7.5(a) , a person commits cyberstalking when he or she engages in a "course of conduct using electronic communication directed at a specific person," and knows or should know that it would cause a reasonable person to "(1) fear for his or her safety" or "(2) suffer other emotional distress".

A person also commits cyberstalking when, "knowingly and without lawful justification, on at least 2 separate occasions, harasses another person through the use of electronic communication" and transmits a threat or places the person in reasonable apprehension of harm.

Application to Your Group: The multiple posts and comments—from Serina Garcia-Heintzelman, Stephanie Renee, Rylee Gibson, and others—constitute a "course of conduct" on at least two separate occasions. The false accusations and threats of harm constitute harassment.

Penalty: Cyberstalking is a Class 4 felony for a first offense. A second or subsequent conviction is a Class 3 felony.

B. Harassment Through Electronic Communications – 720 ILCS 5/26.5-3

Under 720 ILCS 5/26.5-3(a) , a person commits harassment through electronic communications when he or she uses electronic communication for any of the following purposes:

1. "Making any comment, request, suggestion or proposal which is obscene with an intent to offend";
2. "Interrupting, with the intent to harass";
3. "Threatening injury to the person or to the property of the person to whom an electronic communication is directed or to any of his or her family or household members"; or
4. "Knowingly permitting any electronic communications device to be used for any of the purposes mentioned in this subsection (a)".

Application to Your Group: The posts and comments falsely accusing me of being a "wife strangler," "pe*****le," and "piece of s**t" are obscene comments made with intent to offend. The coordinated attack constitutes harassment. Additionally, any administrator or moderator who knowingly permits such content to remain may be liable for "knowingly permitting" an electronic communications device to be used for harassment.

C. Criminal Defamation – 720 ILCS 5/27-1

Under 720 ILCS 5/27-1(a) , a person commits criminal defamation when, "with intent to defame another, living or dead, he communicates by any means to any person matter which tends to provoke a breach of the peace".

Application to Your Group: The false accusations that I am a "wife strangler," "pe*****le," and "piece of s**t" are matters that tend to provoke a breach of the peace. The Illinois Supreme Court has upheld the constitutionality of this statute.

D. Hate Crime – 720 ILCS 5/12-7.1

Under 720 ILCS 5/12-7.1, a person commits a hate crime when, "by reason of the actual or perceived ... physical or mental disability" of another person, they commit specified offenses.

Application to Your Group: I have been formally diagnosed with CPTSD and Persistent Depressive Disorder—both recognized mental disabilities under Illinois law. The posts attacking my mental health ("insanely mentally ill") and the coordinated harassment targeted at a person with documented disabilities may constitute a hate crime.

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IV. LIABILITY OF GROUP ADMINISTRATORS AND MODERATORS

You are not merely passive hosts of this content. As administrators and moderators of "The 217 Group," you exercise editorial control over the content posted in your Group. This control creates potential liability.

A. Defamation – Publication and Republication

Under Illinois law, "publication occurs when the defendant communicates the defamatory statement to someone other than the person being defamed." Administrators and moderators who knowingly allow defamatory content to remain on their pages may be considered "publishers" or "republishers" of that content.

In a recent Illinois case, the court held that both the poster and the page administrator could be held liable for defamation. The court sent the case back to trial court to award compensatory damages against both defendants. This precedent establishes that page administrators can be held liable for defamatory content posted on their pages.

B. Harassment Through Electronic Communications – Permitting Use

Under 720 ILCS 5/26.5-3(a)(6) , a person commits harassment through electronic communications when he or she "knowingly permits any electronic communications device to be used for any of the purposes mentioned in this subsection (a)".

If you are aware of the defamatory and harassing content on your Group and fail to remove it, you may be knowingly permitting your Group to be used for harassment.

C. Civil Conspiracy

The coordinated nature of the attack—Serina's original post, Stephanie's republication, and multiple commenters piling on—supports a claim for civil conspiracy. Under Illinois law, civil conspiracy requires: (1) a combination of two or more persons, (2) for the purpose of accomplishing by some unlawful means, (3) in the furtherance of which one of the conspirators committed an overt tortious or unlawful act. If you are aware of this conduct and do nothing to stop it, you may be considered part of the conspiracy.

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V. YOUR EXPOSURE

Offense Statute Penalty
Cyberstalking 720 ILCS 5/12-7.5 Class 4 felony (1-3 years)
Harassment Through Electronic Communications 720 ILCS 5/26.5-3 Class B misdemeanor / Class 4 felony
Criminal Defamation 720 ILCS 5/27-1 Class B misdemeanor
Hate Crime Enhancement 720 ILCS 5/12-7.1 Enhanced penalties
Civil Defamation Common law Compensatory and punitive damages
Civil Conspiracy Common law Joint and several liability

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VI. DEMANDS

You are hereby formally demanded to take the following actions:

A. Immediate Removal of All Defamatory Content

Remove all posts, comments, and content that:

1. Accuse me of strangulation or attempted murder;
2. Accuse me of being a "pe*****le";
3. Accuse me of being a "piece of s**t";
4. Accuse me of being a "drunk";
5. Accuse me of being "insanely mentally ill"; or
6. Otherwise defame, harass, or attack my character.

B. Preservation of All Evidence

Preserve all records related to the defamatory and harassing posts, including:

1. The original posts and comments (including all metadata);
2. All engagement data (likes, shares, comments);
3. All IP addresses and account information;
4. All moderation logs and actions.

C. Identification of Anonymous Posters

Provide identifying information for any anonymous or pseudonymous posters who participated in the defamatory and harassing conduct. Your failure to do so may result in a subpoena to Facebook/Meta for such information.

D. Response to This Notice

Provide a written response within seven (7) days confirming that:

1. You have removed the defamatory content;
2. You have preserved all evidence;
3. You will cooperate with any future legal proceedings.

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VII. DEADLINE FOR COMPLIANCE

You are hereby given seven (7) days from receipt of this letter to comply with the demands set forth above. Failure to comply may result in:

1. Criminal complaints being filed against you and the Group;
2. A civil lawsuit being filed against you personally and the Group;
3. A subpoena to Facebook/Meta for identifying information;
4. A request for sanctions and attorney's fees.

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VIII. NOTICE OF PRESERVATION OBLIGATION

This letter constitutes formal notice of your obligation to preserve all evidence related to the defamatory and harassing content on your Group. Any destruction, alteration, or concealment of evidence may result in spoliation sanctions, including but not limited to:

· An adverse inference instruction at trial;
· Monetary sanctions;
· Dismissal of defenses;
· Contempt of court.

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IX. CONCLUSION

You are now on formal notice of the unlawful conduct occurring within your Group. Ignorance of the law is no defense, and your failure to act may expose you to both civil and criminal liability. The law is clear: page administrators can be held liable for defamatory content posted on their pages. You have the power to stop this harassment. The question is whether you will use it.

I look forward to your prompt compliance with the demands set forth above.

Respectfully,

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Matthew Fricke

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CERTIFICATE OF SERVICE

I, Matthew Fricke, certify that I served a copy of this Formal Legal Notice and Demand Letter on the Administrators and Moderators of " 217 Problems" via:

· Message to the Group's administrators
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Dated: 07/19/2026

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Matthew Fricke

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