By Nerdy Addict NOTICE OF INTENT TO INITIATE LITIGATION
Pursuant to § 770.01, Florida Statutes
From:
Ali Eslami
To:
Briana Jade Firmin (aka Briana Jade Schexnaider, born Hawke)
Date: October 28, 2025 (SENT VIA CERTIFIED MAIL)
This letter serves as formal notice of intent to initiate civil proceedings against you for defamation (libel and slander), tortious interference with a contractual/business relationship, cyberstalking, and malicious false reporting, arising from your electronic and written communications directed to management of a Florida sober-living residence and subsequent public postings.
On October 22, 2025, you, using the email address [email protected], sent emails to the management of my sober-living home in Naples, Florida. In those emails, you made false and malicious claims accusing me of recording residents without consent, committing cybercrimes, and being violent with active restraining orders. Each statement is demonstrably false and intended to damage my reputation and jeopardize my housing.
You further claimed to have reported me to the FBI and encouraged others to “add to the report,” fabricating an IC3 reference to legitimize your claims. Detectives with the Collier County Sheriff’s Office are evaluating the incident documented under Report #2500408506 to determine whether the actions constitute harassment under Florida Statute §784.048(1)(d) or other applicable criminal statutes. The report contained sufficient evidence to warrant the opening of an official police case.
After learning law enforcement was involved, you published a public blog post on or about October 24, 2025, openly acknowledging your communications to the sober home and attempting to justify them. In that post, you referred to Florida’s Video Voyeurism law (§810.145) and federal statutes (18 U.S.C. §§2511 and 1801) to falsely imply criminal conduct on my part, stating that you were “within [your] legal parameters to report such crime.”
You repeatedly asserted falsehoods that I filmed residents without consent, posed a danger to vulnerable people, and was under investigation by law enforcement—all after becoming aware of the active police report. This constitutes retaliation and continuing defamation made with actual malice under §770.01, further violating §784.048 (Cyberstalking) and §837.05 (False Report to Law Enforcement). Your statements were intended to amplify harm through online publication and interstate communication originating from Baytown, Texas.
- Defamation / Libel (§§770.01 and 836.04, Fla. Stat.) – Publication of false statements that expose another to hatred, ridicule, or injury to reputation.
- Cyberstalking / Harassment (§784.048, Fla. Stat.) – Use of electronic communication to willfully and maliciously cause substantial emotional distress.
- False Report to Law Enforcement (§837.05, Fla. Stat.) – Knowingly providing false information concerning an alleged crime.
- Civil Remedies for Criminal Practices (§772.104, Fla. Stat.) – Allows treble damages for malicious criminal conduct causing injury.
- Tortious Interference (Common Law) – Intentional interference with an existing contractual or advantageous relationship.
Your false statements and blog publication have caused:
- Reputational harm within the sober-living community and online;
- Emotional distress and fear for personal safety;
- Threat to housing stability and employment opportunities;
- Law enforcement involvement and legal expenses.
Pursuant to §770.01, you are hereby required to:
- Issue a full written retraction within 10 days of receipt, distributed to every recipient of the original communications and to any public platform on which your statements were made; and
- Preserve all evidence, including emails, IC3 reports, screenshots, metadata, and social-media records to avoid spoliation penalties.
If you fail to comply within 10 days, I will file a civil complaint in the Fourth Judicial Circuit Court, Duval County, Florida, seeking compensatory and punitive damages, attorney’s fees, and all relief available under Florida law.
Sincerely,
Ali Eslami
nerdbirdmafia