LEVENTHAL, MULLANEY & BLINKOFF, LLP
ATTORNEYS AT LAW
15 REMSEN AVENUE
ROSLYN, NEW YORK 11576
TELEPHONE: (516) 484-5440
STEVEN G. LEVENTHAL MARTHA V. SMITH, RA
THOMAS J. MULLANEY CRISTINA GONCALVES, PA
JEFFREY L. BLINKOFF
October 19, 2023
Via USPO Overnight Mail, and email: [email protected]
Mr. Jude Seymour
Republican Commissioner
Jefferson County Board of Elections
175 Arsenal St., First Floor
Watertown, NY 13601
Re: NOTICE TO CEASE AND DESIST
Dear Mr. Seymour:
You maliciously published false and defamatory information about Mr. Simao by your
public statements indicating that he improperly made campaign expenditures that are subject to
reporting requirements pursuant to the New York Election Law.
As a Commissioner of Elections for the County of Jefferson with years of experience,
and as a frequent attendee of educational programs presented by the NYS Board of Elections and
the NYS Election Commissioners’ Association, you surely must know that your public
statements were false and misleading. New York is an “express advocacy” jurisdiction.
Expenditures related to a communication that does not expressly advocate a vote for or against a
particular candidate is not a reportable campaign related expenditure.
It is hereby demanded that you retract your false and misleading accusation in every
forum in which it was made. You are hereby placed on notice to cease and desist in these tortious
actions and to preserve all related records and other evidence, including but not limited to email
correspondence, text messages, Facebook pages and other statements posted to social media.
Furthermore, it appears that your statements were not made on behalf of the bipartisan Board of
Elections. Therefore, you likely acted in your individual capacity when you defamed Mr. Simao.
Please provide a copy this letter to your insurance carrier and your personal attorney.
Very truly yours,
Steven G. Leventhal