UPDATE: Speedy Delivery - Cease and Desist
Date: September 23, 2025
On September 23, 2025, Plaintiff issued formal cease-and-desist notices to attorneys Kyle T. Manderfeld and Bradley A. Kletscher after discovering that Defendant Madeline Lee had submitted a false abuse report to domain registrar Porkbun.
The report falsely portrayed the HRO as a gag order that prohibited Plaintiff from maintaining her websites-including her ADA archive, OSINT investigations, and the public record documenting the case. This was not only untrue, but the exact opposite of the HRO's scope. The false report triggered improper “prove your innocence” demands from Porkbun and forced Plaintiff to intervene before the situation escalated further.
Why the Cease-and-Desist Was Necessary
Plaintiff's cease-and-desist letters were issued on the basis that:
- Both attorneys were already on notice of ongoing litigation involving their client;
- Lee's false representations had already been debunked through court findings and federal filings;
- Her repeated misuse of third-party reporting systems created material risk of unlawful interference with Plaintiff's websites and ADA accommodations;
- The attorneys failed to prevent or correct their client's actions despite knowledge of ongoing harassment.
Each letter instructed counsel to prevent further abuse reports, stalking behavior, and misuse of intermediary systems carried out in Lee's name-a professional responsibility requirement they had already been warned about.
Porkbun's Role in the Escalation
The cease-and-desist was issued immediately after Porkbun began forwarding Lee's false claims back to Plaintiff and demanding additional documentation, despite:
- Existing litigation holds in place;
- Prior correspondence explaining the nature of the case;
- Porkbun's own acknowledgment that Plaintiff's domains were fully compliant.
Plaintiff made it clear that she would not continue performing unpaid investigative labor to rebut spammed, duplicative, and disproven complaints originating from Lee.
The Attorneys' Responsibilities
By September 23, both Manderfeld and Kletscher were deeply involved in related litigation:
- Manderfeld had already filed multiple defective and misleading submissions across state and federal dockets;
- Kletscher had recently blown a federal deadline, triggering Plaintiff's motion for default;
- Both had knowledge of documented false statements made by their client.
The cease-and-desist put counsel on explicit notice that they were responsible for ensuring Lee ceased her interference with Plaintiff's domain infrastructure and digital archives—conduct directly tied to Plaintiff's ADA accommodation and First Amendment rights.
Immediate Aftermath
Delivery of both letters was confirmed by signature. Within days:
- Porkbun acknowledged Plaintiff's litigation hold and withdrew its request for additional proof;
- No further abuse reports were forwarded to Plaintiff by the registrar;
- Lee’s pattern of third-party misuse was formally logged as evidence across the federal case, HRO appeal, and civil harassment suit.
Though the cease-and-desist did not end the broader litigation, it marked a critical step in halting off-the-record interference and protecting the integrity of Plaintiff's online evidentiary archive.