PDF · PUBLIC LIBRARY #421

EXHIBIT(S) - A  (Motion #002) 10.15.26 Email from Teny Geragos

NYSCEF document #68 | Filed: 2026-10-15 | Filed by: BHIMANI, ALISHAH Filed: Received: | Docket status: Processed Confirmation Notice | Source: NYSCEF, New York County Supreme Court | SHA-256: 7673367e28ec9f0828d648da83f011e46aa4577b06ec64ce280ee29e3a4dcaa0

File: NYSCEF-Document-000068.pdf · 0.19 MB
SHA-256: 7673367e28ec9f0828d648da83f011e46aa4577b06ec64ce280ee29e3a4dcaa0
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--- Page 1 --- From: Ethan Cohen To: Teny Geragos; Thomas P. Giuffra; [email protected] Cc: James C. Knox; Alishah E. Bhimani; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Re: Demand for Immediate Retraction Date: Thursday, October 15, 2026 10:38:50 AM Attachments: image001.png image002.png Dear Ms. Geragos, Mr. Giuffra is out of town and is currently unavailable. He will respond this evening. Ethan J. Cohen Associate RHEINGOLD GIUFFRA RUFFO PLOTKIN & HELLMAN, LLP 551 5th Avenue, 29th Floor New York, NY 10176 tel 1.212.684.1880 / fax 1.212.689.8156 [email protected] From: Teny Geragos <[email protected]> Sent: Thursday, October 15, 2026 10:23 AM To: Thomas P. Giuffra <[email protected]>; Ethan Cohen <[email protected]>; [email protected] <[email protected]> Cc: [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]> Subject: Demand for Immediate Retraction Dear Mr. Giuffra and Mr. Cohen: Although we have never met, you have apparently seen fit to make serious and wholly baseless allegations impugning my professional integrity in a public court filing. Separate and apart from the false allegations you and your client have made against my client, you have now personally accused me of unethical conduct in which I have never engaged and would never engage. I have come to understand that some civil practitioners consider personal attacks and FILED: NEW YORK COUNTY CLERK 10/15/2026 04:18 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 10/15/2026 --- Page 2 --- inflammatory accusations acceptable litigation tactics. I do not. In my years of practicing criminal law, I have never regarded baseless accusations against opposing counsel as a legitimate substitute for advocacy. Your decision to publicly accuse me of professional misconduct without any factual foundation is outrageous, offensive, and entirely unacceptable. What makes your conduct particularly indefensible is that, despite apparently monitoring my activities and those of a member of my family, you never once contacted me to inquire about the allegations you now purport to make. You made no effort to verify your accusations, seek an explanation, or afford me even the most basic professional courtesy before publishing allegations that directly attack my integrity and reputation. Your failure to do so speaks volumes about the recklessness of your conduct. To be clear, since you never asked: I have never leaked any information, and your suggestion otherwise is categorically false. You had no legitimate basis to accuse me of doing so, much less to memorialize that accusation in a public judicial filing. I am demanding that you immediately correct the record by filing a written retraction expressly acknowledging that you have no factual basis to accuse me of leaking information or engaging in any other unethical conduct. That correction must be made publicly, in the same forum in which you chose to publish your accusations. If you fail to file that correction by tomorrow, I intend to pursue all appropriate relief. I will not permit you to use a court filing as a vehicle to make unsupported allegations that damage my professional reputation without consequence. You and your colleague are further directed to preserve all documents, communications, electronic messages, research, notes, and other materials relating in any way to the allegations against me, including communications with your client, other counsel, third parties, or anyone involved in investigating, formulating, approving, or disseminating those allegations. This preservation demand includes electronically stored information and any communications concerning me or members of my family. I expressly reserve all rights and remedies. Confirm receipt. Teny Geragos Teny Geragos Partner, Agnifilo Intrater LLP 140 Broadway, Ste. 4530 | New York, NY 10005 o: (646) 205-4351 | c: [email protected] www.agilawgroup.com FILED: NEW YORK COUNTY CLERK 10/15/2026 04:18 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 10/15/2026 --- Page 3 --- This message is a PRIVATE communication. This message and all attachments are a private communication sent by a law firm and may be confidential or protected by attorney-client privilege or work product protection. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of the information contained in or attached to this message is strictly prohibited. Please notify the sender of the delivery error by replying to this message, and then delete it from your system. Thank you. FILED: NEW YORK COUNTY CLERK 10/15/2026 04:18 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 10/15/2026
PUBLIC DISCUSSION

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Anonymous
Defense attorney sends cease and desist email to Lucy Criags lolwyer. This is getting heated!