 Sutton was the principal surgeon at Lasik. operates 55 laser eye centers in North America, eight of which are in Canada. Defendants intended falsely to suggest, and have falsely suggested in a manner designedto mislead the public, that the services of Dr. Attached as Exhibit "A" to this my Affidavit is a true copy of Mr. The reference to "low-cost providers" in the Post Article referred to and was understood to refer to Lasik. In so doing, the defendants, were actuated by malice with the dominant motive of damaging Lasik and its business. Donnenfeld may have performed laser surgery on defendant GiuseppeDellorusso, a local pediatrician. In addition, I have reviewed the subsequentrecords of Cheryl Fiorelli from Richard Tipperman, M. Ralph in the CBC Broadcast are known to the defendants to be false. Jury Trial Plaintiff herein requests that the matters complained of herein be heard anddetermined by a Jury. The falsity of the statement was known, or ought to be known, to the defendants to be false, as Mr. Finally, in January of 1999, plaintiffsubmitted to a so-called "enhancement" surgery, which ultimatelyimproved her vision, except for the increased "floaters". Compelling defendants to recall from the trade and all distribution channels anyand all publicity, advertising and promotional materials bearing representationsthat Dr. |
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