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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
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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:
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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
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NYSCEF DOC. NO. 68
RECEIVED NYSCEF: 10/15/2026
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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
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NYSCEF DOC. NO. 68
RECEIVED NYSCEF: 10/15/2026
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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
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