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CONTI FENN & LAWRENCE PLLC

36 SOUT H C H ARLES STREET , SUI T E 2 5 01


BALT IMORE, M AR Y LAND 21 2 01
PHONE (41 0 ) 837-6999
FACSIMILE (4 10 ) 5 10-1647

April 12, 2017

URGENT - FOR IMMEDIATE REVIEW

VIA FEDERAL EXPRESS/ OVERNIGHT MAIL - SIGNATURE REQUIRED


AND FACSIMILE (1-240-387-6225)

Glen Helman
11314 Hunt Fann Lane
Oakton, Virginia 22124

Re: Demand to Cease and Desist Defamation of Daniel Boice and Trustify

Dear Mr. Helman:

I am writing on behalf of my client, Daniel Boice, to demand that you immediately cease
and desist from continuing to publish false and intentionally disparaging statements about Mr.
Boice and his company Trustify. Although you have published false and defamatory statements
concerning Mr. Boice through comments on various media sites, you have written several
defamatory articles published to a blog that you maintain at www.drivenforward.com. My client
demands that you immediately and fully retract all of the defamatory statements you have
published about him and Trustify, and where appropriate, publish corrections.

In a March 9, 2017 article on your blog at drivenforward.com, you published the


following statement: "According to Danny, he's a Harvard man without quote marks, but
Harvard would say different." In another article that you published on your blog on July 2, 2015,
you wrote that Mr. Boice "pretends his not-for-credit, anyone with a credit card allowed, online
Harvard class made him a Harvard alum." These statement can be understood only as an
assertion that Mr. Boice has intentionally misrepresented his credentials, particularly with regard
to his attendance at Harvard University. To the contrary, Mr. Boice did in fact attend Harvard
University, taking courses in a Bachelor' s Degree program at the University' s Division of
Continuing Education. Although Mr. Boice has not received a degree from Harvard University,
he has never represented that he did, and has been completely open and honest regarding this
fact. For instance, beneath "Harvard University" in the Education section of Mr. Boice' s public
Linkedin profile, the page states, "Bachelor' s Degree candidate (did not graduate) .... " Your
statement that Mr. Boice intentionally misrepresented his credentials, particularly those relating
to Harvard University, is false, and you would have discovered this had you performed even a
cursory level of research on this issue.
In a July 2, 2015 article that you published to your blog, you asserted unfounded claims
of Mr. Boice's "ability to con people into hiring him before they fire him and investing in him ...
" In a post you published on your Twitter account on July 12, 2015, you advised readers to
"Hire a PI to investigate mgmt.." In a March 9, 2017 blog post, you repeatedly refer to Mr.
Boice as a "Flim Flam man" and ultimately call him a "crook." Your statements about Mr.
Boice, particularly given they relate to his profession, lack any factual support and constitute
defamation per se. Mr. Boice operates a legitimate business that has no doubt been vetted by the
hundreds of private investigators who affiliate with Trustify. Mr. Boice has been granted a
security clearance by the United States government and has been subjected to countless
background checks by investors. Mr. Boice and his company Trustify have never been found to
have engaged in acts of deception or fraud and your repeated assertions that he is a con man or
running a flim flam operation is not supported by any facts.

In a March 9, 2017 blog post, you re-publish an anonymous post to support your claim
that Mr. Boice is a fraud. One anonymous post that you re-publish in its entirety is entitled with
highlights "RED FLAG FEMALE INVESTORS! Sexually abusive Atmosphere Where Male
Employees to Prey on Women In The Workplace." The republished post asserts that Mr. Boice
and Trustify "have fired more than 3 women who have reported sexual harassment charges .... "
Trustify has not fired three women who have reported sexual harassment charges. In fact,
Trustify has never had a single reported instance of sexual harassment to its human resources
department. Your blog includes a false statement of fact, and you appear to have done nothing to
investigate or verify the facts you are publishing.

Trustify takes pride in maintaining a diverse workforce and supporting its women
employees. Trustify's staff is over 60% female, and its executive leadership team is 50% female.
Mr. Boice and his management team at Trustuify do not discriminate against any employees
based on gender, ethnicity, religion or otherwise. To the contrary, they actively recruit and hire
all gender, ethnic and religious minorities. Trustify and Mr. Boice have been recognized for
their achievements with awards for diversity and the fair treatment of employees by the District's
Mayor, Women in Tech, and other organizations focused on diversity in the workplace. In
addition, Trustify regularly handles pro bona cases protecting and supporting victims of sexual
assault, domestic violence, and other exploited or vulnerable populations. Your publication of
anonymous, unsupported allegations was done without any basis in fact and was particularly
damaging given my client's core mission of equitable access to investigative resources.

Your March 9, 2017 blog post also re-publishes an anonymous post containing further
false and defamatory statements concerning Mr. Boice, his company, and his spouse, including:
"The disgusting behavior of the CEO, Danny Boice and his wife/trophy 'President,' Jennifer
Mellon. Horrible human beings, thieves who deceit [sic] their investors, employees .... " These
statements falsely assert that Ms. Mellon is unqualified to be the President of Trustify and that
she obtained her position at the company only because of her relationship to Mr. Boice. Nothing
could be further from the truth. Had you conducted even basic research, you would have
discovered that Ms. Mellon graduated from Bucknell University magna cum laude, and was
personally involved in creating Trustify. Any inquiry into Ms. Mellon's background would have
revealed that she has served in several positions at the Joint Council on International Children's

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Services, the oldest and largest affiliation of licensed, non-profit international adoption
organizations in the world, including serving as the youngest Executive Director in the Council' s
history at that time. You publication ignores the myriad of awards that Ms. Mellon has received
for her charitable and business accomplishments. Ms. Mellon is fully qualified for her position
at Trustify. Moreover, there are no facts or evidence to support the statements that you have
published that accuse Ms. Mellon of being a thief or having deceived anyone.

In addition, you have published numerous false statements regarding the financial
condition of Trustify, apparently without having conducted any research or review of the
company's actual financial data, customer or vendor interviews, or any other form of due
diligence. Specifically, in an article to your blog that you posted on March 7, 2017, you refer to
Trustify as "one of DCs best known dumpster fires." You follow up on this article on March 9,
2017, with an article where you repeatedly republish false and unsupported anonymous posts
about the financial condition of Trustify and Mr. Boice that you later endorse. Your March 9
blog includes statements such as, "developers are not paid, Pis are not paid, contractors are paid
three months later," "They're dying. Flee," "The instability," and "CEO may be a sociopath."
Once again, these statements are not supported by any actual facts, and it appears as though you
have made no effort to verify these facts before publishing and endorsing them as true.

Had you made any effort to verify the statements you published as facts, you would have
confirmed that all of these statements of fact were false and that Trustify is categorically not a
"dumpster fire." In its two years of operation, Trustify has raised funding well over
$10,000,000.00 and generated over $8,000,000.00 in annual revenue. Trustify is currently cash-
flow positive and has over $5,000,000.00, which represents several years of operating runway.
Trustify makes a robust data and diligence room available to all of its investors, which contains
detailed financials, bank statements, and transaction data. Some of the most successful and
largest venture capital firms have referred to Trustify as the most transparent and mature startup
regarding data sharing that they have seen.

As to its accounts payables, Trustify maintains current accounts with all vendors,
contractors and employees. Trustify processes its payroll on a recurring schedule using a third-
party payroll company and has never been late in paying any employees. Trustify's private
investigators are paid on a monthly schedule using a third-party company that has never been
late in making payments due. All of Trustify's vendors and contractors are paid in a timely
manner and according to the terms of their individual contracts with Trustify.

Far from being a dying enterprise or an unstable company, Trustify has tapped into a
substantial business need and has received favorable reviews for the services that it provides.
Trustify's customers have provided overwhelmingly positive public reviews and testimonials
through an independent, third party that aggregates these reviews fairly. The reviews are
publicly available at www.trustpilot.com/review/trustify.info Had you investigated the
company, you would have discovered that it has an average positive review 8.4 out of 10 for the
quality of service that Trustify provides its customers.

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Finally, your repeated characterization of Mr. Boice as a con man, and Trustify as a flim
flam operation or as "Dis-Trustify" is egregious given the legitimacy of the business. Trustify' s
private investigators are all licensed through each jurisdiction where they perform work. In fact,
most of the private investigators are former police · officers, military veterans, or former
employees of federal agencies such as the FBI, DHS or the Secret Service. Trustify uses highly
regarded law firms such as King & Spalding for their regulatory compliance and DLA Piper to
ensure that its corporate governance and structure and operations comply with all applicable laws
and regulations. Attempting to characterize Mr. Boice and Trustify as being engaged in
fraudulent activity can only be viewed as a deliberate attempt to inflict harm.

These statements are only a few examples of the numerous false and defamatory
statements you have published concerning Mr. Boice and his company over the past two years.
All of these statements are false, and they threaten to severely damage the reputation and
business of Mr. Boice and Trustify. The statements demonstrate no due diligence and an
extreme recklessness for the truth. As a journalist, you are not insulated from liability when you
republish a statement of fact that has no attribution or actual facts to support the claim. As a
journalist, you are required to conduct due diligence before publishing such defamatory
statements that can be read as causing intentional harm to the reputation of Mr. Boice and
Trustify. You cannot escape liability by relying on unsubstantiated, anonymous posts on a
website. You chose to republish these statements to support the conclusions that you have drawn
about Mr. Boice and Trustify. Furthermore, you are personally liable for the false statements
contained in the anonymous blog posts you chose to republish because you endorsed the
accuracy of the posts in the conclusion of your March 9, 2017 article, when you asserted that you
were "positive" that the anonymous reviews would stand up to scrutiny.

Mr. Boice demands that you provide any and all evidence to support the statements you
have published about him, as well as the statements about Trustify and any of its officers or
employees. If you are unable to provide any supporting evidence, Mr. Boice demands that you
fully retract all of the false and defamatory statements you have published about him and
Trustify and that you publish a correction of all of these false and defamatory statements in the
same manner and in the same media that you published the false and defamatory statements. Mr.
Boice also demands that you immediately cease and desist publishing any further false and
defamatory statements regarding him and Trustify. Please provide my office with any
supporting evidence you have for your published statements concerning Mr. Boice and/or
Trustify, or retract and publish the appropriate corrections on or before 5:00 p.m. EST on April
21, 2017.

Please direct all communications regarding this matter to my attention. If you are
represented in this matter by an attorney, please forward this correspondence to your attorney.

Thank you for your immediate attention to this matter.

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Very Truly Yours,

Anthony M. Conti

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