NOTICE OF INTENT TO FILE CIVIL ACTION
TO: Patricia “Tish” Lee Reynolds
FROM: Ali Eslami
Date: October 10, 2025
PLEASE TAKE NOTICE that, pursuant to applicable Florida law and in conjunction with Plaintiff’s prior cease and desist demand, Plaintiff Ali Eslami intends to initiate a civil action in the Circuit Court for Duval County, Florida, against Defendant Patricia “Tish” Lee Reynolds. The contemplated causes of action include Battery, Defamation (Libel and Slander), Invasion of Privacy, and Intentional Infliction of Emotional Distress arising from events beginning in May 2024 and continuing thereafter.
This Notice is provided to afford you an opportunity to resolve the matter before suit is filed and to ensure preservation of all relevant evidence. Within ten (10) days of your receipt of this Notice, please confirm in writing that you will:
1. Cease and desist from all defamatory, harassing, or invasive publications concerningAli Eslami;
2. Remove and retract the online statements, posts, images, and videos previously published concerning Ali Eslami;
3. Preserve all evidence, including but not limited to social media posts, messages, emails, recordings, devices, and account credentials related to the subject matter of this dispute;
4. Engage in good faith discussions toward resolution.
If written confirmation is not received within the allotted time, Plaintiff will proceed to file suit without further notice, seeking injunctive relief, compensatory and punitive damages, costs, and any other relief the Court deems just and proper.
Nothing in this Notice shall be construed as a waiver of any rights or remedies available to the Plaintiff, all of which are expressly reserved.
Dated: October 10, 2025
Respectfully submitted,
Ali Eslami
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Notice of Intent to File
Civil Action was served by certified mail, return receipt requested, and/or by other verifiable delivery on the date set forth above to:
Patricia “Tish” Lee Reynolds
