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Weil, Gotshal & Manges 110 Fetter Lane London EC4A 1AY +44 20 7903 1000 tel +44 20 7903 0990 fax

BY EMAIL AND POST

Our Ref: HF -L/VB/99985.0070 28 March 2013

Victoria Bu rt on +44 (20) 79031271 victoria.burton@weil.com

Ms Copleston-Warren cc. Mr Warren 4 Kendrick Mews London SW7 3HG Dear Ms Copleston-Warren We act for the owners of Yeotown Limited ("Yeotown"). We have been instructed in connection with recent behaviour exhibited by you concerning Yeotown and our clients.

Defamatory postings made on yoga-related websites We wish to address certain postings that have been made on various yoga-related websites using a selection of user pseudonyms since June 2012 as detailed below. On www.wahanda.com: •

a post concerning an alleged visit to Yeotown in April 2012 from "LadyIsabella";

posts concerning alleged visits to Yeotown in July 2012 from "SophiaTP" and "Calming";

a post concerning an alleged visit to Yeotown in October 2012 from "Creativity";

a post concerning an alleged visit to Yeotown in December 2012 from "Dspence"; and

a post concerning an alleged visit to Yeotown in February 2013 from "MHonor".

It is also understood that similar reviews have been written on the TripAdvisor and Queen of Retreats websites, also purportedly posted by Lady Isabella Hervey. Screen shots of these postings are reproduced in the annex to this letter. The statements made about Yeotown and our clients in these postings are defamatory. The postings are negative, personal and repetitive. The comments are also unsupportable as they describe a series of entirely fictitious visits to Yeotown (by way of illustration, Yeotown did not host any detox retreats in July 2012 and Lady Isabella Hervey has never visited Yeotown or been taught yoga by our client, Ms Mercedes Ngoh).

Weil, Gotshal & Manges is a partnership of solicitors, exempt European lawyers and registered foreign lawyers. A list of the partners is open to inspection at the above address. Authorised and regulated by the Solicitors Regulation Authority with registration number 192479. EUW ACTIVE:\38370173\5\99985.0070


Ms Copleston-Warren 28 March 2013 Page 2

Weil, Gotshal &

Manges

It is clear that, by these comments, the author sought to portray Yeotown, which is a retreat that places great emphasis on the health and wellbeing of its guests (and therefore markets itself accordingly), as a place where their needs would be ignored. The intention was to damage our clients' professional reputations, thereby discouraging others from visiting Yeotown and causing damage to our clients' business. It is evident from the content of the postings made on the website that they have been made by you. Specifically, the postings written by "Calming" and "LadyIsabella" display knowledge of a previous dispute before the Employment T ribunal between yourself and a now dissolved company connected to our clients (Beyond the Mat Ltd); clearly no third party would be privy to, or indeed inclined to, post following the outcome of the dispute. Yeotown was unconnected to that dispute and there is therefore no basis for your recent negative comments about Yeotown. Accordingly, it is clear that you seek to defame our clients and damage their reputation and that of their business. The websites in question, having independently investigated these postings and concluded that they were not genuine, have removed them. Our clients have been informed by these websites that the majority of the postings originated from the same IP address in South Kensington, indicating that one author was using multiple email addresses and user pseudonyms. They have been supplied with the IP address in question and have lodged a formal complaint with BT in respect of that IP address. Our clients believe that this is the IP address of your home address in South Kensington. It is clear that an email sent to Yeotown, purportedly from Lady Isabella Hervey, which is also annexed to this letter, is not genuine. Given that the author makes reference to issues that have been the subject of a previous dispute between you and our clients historically, it appears highly likely that this correspondence was sent by you. Lady Isabella Hervey has been supplied with the postings and direct emails sent to our clients in her name should she wish to take any legal action against you in relation to this impersonation of her. Harassment campaign against Ms Mercedes Ngoh It has also been brought to our attention that you have embarked on a destructive campaign against Ms Ngoh and her reputation. We understand that you contacted companies associated with Ms Ngoh in an attempt to discredit her. Specifically: •

you and an individual named Ms Lauren Prakke approached the clothing company, Lululemon, in December 2012 to request that it no longer sponsor Ms Ngoh's yoga business activities;

•

in January 2013 you contacted the Managing Director of Triyoga, Mr Jonathan Sattin, to ask that Ms Ngoh be removed from her position there as a yoga teacher (also informing him that you and Ms Prakke wished to meet with him in person to discuss Ms Ngoh); and

•

in January 2013 (and previously) you contacted Adrian Kowal of Evolve Wellness Centre to discuss Ms Ngoh.

EUW ACTIVE:\38370173\5\99985.0070


Ms Copleston-Warren 28 March 2013 Page 3

Weil, Gotshal & Manges

We are advised by Ms Ngoh that she has since filed a harassment complaint with the Metropolitan Police in respect of your conduct in this regard and that you have been advised by the Police that you may face criminal prosecution should you approach any further businesses or individuals affiliated with Yeotown or Ms Ngoh. For the avoidance of doubt, if you and Ms Prakke do not immediately desist from such activities (and any other related actions), our clients will revert to the Police without further notice and encourage prosecution. Both Lululemon and Mr Sattin have relevant email correspondence which they are prepared to provide to the Police if necessary. Further, you are advised that the comments contained therein may also amount to defamation against Ms Ngoh; if you continue to harass Ms Ngoh in the manner described above, a defamation action may also be brought against you respect of this. To be clear, so far as Ms Ngoh is presently aware, none of your comments have been afforded any merit whatsoever by her business associates. However, should your actions and words disturb any of Ms Ngoh's commercial relationships, you may be liable for procuring a breach of contract and, if so, our clients would also bring a civil action against you in that regard. Our clients have asked their associates, colleagues and partners in the yoga, budokon, fitness and wellbeing communities to notify them of any further behaviour amounting to harassment or any defamatory comments made about Ms Ngoh or Yeotown that their associates, colleagues and partners become aware of. Legal actions by our clients

The dispute you had with our clients in 2012 concerning your non-attendance on a yoga teacher training programme is now concluded. Your latest behaviour is highly inappropriate and must cease. If you do continue either to make defamatory comments about Yeotown or our clients online or in any public forum, or to target or contact Ms Ngoh, we are instructed to escalate this matter, the first step being to send you a formal Letter of Claim. Your actions have caused considerable distress to our clients and, if legal action becomes necessary, they will be seeking substantial damages from you. Should your actions result in a successful civil action, the damages that could be awarded to our clients may be significant. This letter is copied to Mr Warren in the event that he is responsible for maintaining the internet account at your home address. We are instructed (i) that BT has informed our clients that the responsibility for an internet account and its use lies with the account holder and (ii) that BT has reviewed the defamatory postings that have been made from the singular IP address referred to above, and has agreed to release the name of the account holder should legal action become necessary or a prosecution ensue. If Mr Warren is the account holder it is our clients' intention to join him to any claim for defamation filed should legal action become necessary.

EUW ACTIVE:\3837017315\99985.0070


Ms Copleston-Warren 28 March 2013

Weil, Gotshal & Manges

Page 4

Our clients are determined to protect the estimable reputation that they have built up and that your actions seek to threaten. We suggest that you and Mr Warren immediately seek legal counsel to advise you on your position and the severity of this matter. All of our clients' rights are hereby fully reserved. Yours sincerely

(,,oeil

,

Citsko L

Weil, Gotshal & Manges

EUW ACTIVE:\38370173\5\99985.0070


ANNEX

Visited Apr 2012 Yeordy,,, n was an awful experience, over priced and run by an egocentric, self obsessed couple. Both liars. as we saw and now i believe has been proved in court a couple of times! Mercedes should not be considered a yoga teache:riprofessional, s- he does not have a spiritual bone in her body. She has been slandering a poorlady left right and centre whom wanted to go on - a yoga teacher training With her and Mercedes would not let her fully qualified service dog on the course with her and then told her she was not .311owed to go as the lady would not sign the illegal disclaimer. tvlerceees went on to call this person a looser in the streets because she went to the equalities human rights team to try and mediate with Mercedes a.s she justwa.ntedto go on the course. Her assistance dog went to 90% of her -ĂŻoga, gym an d martial arts. classes, Mercedes however still refused and slandered the lady left right: and centre. she even Wrote lies on.her news letters and websites about her loosing the case in tribunal which:is totally not tru e as it was settled in mediation atthe Trio u nal... Furthermore friends of mine were - at the case management session ant the lag,r never claimed Mercedes was a.n employment service provider : she claimed Mercedes taught a vocational course - a yoga teachertraining, which Merce.-ies tried to deny.. She said her teachers-at Yeolovmnid not need =_lalifications - NO R insurance - so be careful. ao not do yoga nor any lltness as you could get injured.and Mercedes and her evil other half will not help you out Stay away from this .place th e owners are untrustworthy and entirely selfish. Treatrne.nt scores

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Visited Jul 2012

The yoga was r rCjE1 laoriqg and it seemed the teacher, Mercedes was sadly for own praci-ca n rather than making st!i'e V''E were Mt more inte:-e:;te (.1 in cne m.A.ced nurieieue reee spmewhat unsui's. he corrn: O. The food iei workotr,vhi:e plowed truc.licIrl ta ei-:. of food ail lecli e, flavour or taste. dairy., me clients and hung groudw Hsas.an eeth weekend incrediblyw . and it made . tlm to it. loaking.torward as t was quote nothing to show for it. Sorry to say Venue scores

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Visit d Jul 2012

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to yeotown, it is over priced. The owners do not believe that they need

insurance for their teachers, or needto look after their clients properly. Just look at theirwebsite it shows clear discrimination. They say no medical detection dogs before allowed on teacher trainings... These dogs go on gymnastics courses, martial arts, boxing, much more dynamic and intense activities other than yoga the owners do not speak the truth when they say they have spoken to the

equalities human rights team as they deny speaking to Yeotown, furthermore the head of Assistance dogs UK say what they nave written Is discriminatory. The owners are selfish, self centred and egotistical, they only have themselves in mind. Do yourself a favour go to another location for a retreat have a look at wellbeingescapes.co.uk they will be able to give a great choice of htir revview, ed and constantly checked retreats to ensure your health and well being. Venue scores

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Therapeutic Massage Stretching Hypnotherapy Stress Management Vinyasa Yoga Yoga


Creativity's profile None oksear Gem rt

Male

Location:

Not provided

Reputation Points Weltanda level: Newbie Tout Points:. 110 O First Reviews I Review 0 Ratings Received 0 Ratings Liven Il Wisltlist Items 0 Favourites 0 Questions Answered 0 Questions asked 0 Articles Cent-lent M.re

No description provided

Activity

Member since: 29-Dec-2012

Reviews

Questions

Scrapbook.

Yeotown

vistted Oct 2012 I went to get ow deserved break from work. The setting is very pretty, however t was disappointed. It felt Itke nany of the staff were not interested in the-clients. I Wan most disappointed by the vinyassa yoga classes, there was one teacher Mercedes whom did not seem to took at any offhe students, she did not scorn to care if we niece following of hot, my rite.nd and I felt we mold have stayed at nonte and welched a OM They bad very nice herbal teas, *Mon mere a life safer as we were constancy tutrigry,1 word lo toose weight and relax and did not loose any weight unfortunately.

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Showing ati reviews

Sort by: Most recent

Visited Dec 2012

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Mercedes Ngoh From: Sent: To: Subject:

Mercedes Ngoh 18 January 2013 12:56 FW: Press features & Yeotown

A new comment on the post "It's not too late to escape for Xmas & New Year" is waiting for your approval http://queenofretreats.com/christmas-new-year-healthy-holidays/ Author : Isabell (IP: 86.144.118.6 , host86-144-118-6.range86-144.btcentralplus.com ) E-mail : ladyisabella@gmail.com URL : http://yeotown.com Whois : http://whois.arin.net/rest/ip/86.144.118.6 Comment: DO NOT GO to yeotown, it is over priced. The owners do not believe that they need insurance for their teachers, or need to look after their clients properly. Just look at their website it shows clear discrimination. They say no medical detection dogs before allowed on teacher trainings... These dogs go on gymnastics courses, martial arts, boxing, much more dynamic and intense activities other than yoga - the owners do not speak the truth when they say they have spoken to the equalities human rights team as they deny speaking to Yeotown, furthermore the head of Assistance dogs UK say what they have written is discriminatory. The owners are selfish, self centred and egotistical, they only have themselves in mind. Do yourself a favour go to another location for a retreat have a look at www.wellbeingescapes.co.uk they will be able to give a great choice of reviewed and constantly checked retreats to ensure your health and well being. Approve it: http://queenofretreats.com/wp-admin/comment.php?action=approve&c=515 Trash it: http://queenofretreats.com/wp-admin/comment.php?action=trash&c=515 Spam it: http://queenofretreats.cam/wp-admin/comment.php?action=spam&c=515 Currently 336 comments are waiting for approval. Please visit the moderation panel: http://queenofretreats.com/wp-admin/edit-comments.php?comment status=moderated

1


Mercedes Ngoh From: Sent: To: Subject:

Yeotown <welcome@yeotown.com > 02 November 2012 15:45 welcome@yeotown.com Enquiry from Website

Name

Isabella Hervey

E Mail

ladyisabella123@ gmail.com

Message

hi i wanted to know if what you had written on your website under teacher training was true. It is written in a very unyogic way. I have seen these medical dogs, they amazing. They go to gymnastics classes and places i would consider far more vigorous than Mercedes yoga (she has taught me...) I think this should be passed on to the assistance dogs UK people as i am sure they would take proper action against this discrimination. Best Wishes

-

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Legal Letter served on Philippa Copleston Warren Defamation Warning & Harassment Complaint filed