{"@context":"https://schema.org","@type":"DigitalDocument","altText":"EXHIBIT(S)\r\n \u00a0- A\r\n \u00a0(Motion #002) Sealed","alternateName":"NYSCEF-Document-000068.pdf","caption":"NYSCEF document #68 | Filed: 2026-10-15 | Filed by: BHIMANI, ALISHAH Filed: Received: | Current docket status: Processed | Court: New York County Supreme Court","contentUrl":"https://lucycraig.blog/media/421/raw","datePublished":"2026-10-15T20:36:33+00:00","description":"NYSCEF document #68 | Filed: 2026-10-15 | Filed by: BHIMANI, ALISHAH Filed: Received: | Current docket status: Processed | Court: New York County Supreme Court","encodingFormat":"application/pdf","identifier":"421","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/421/index.json","markdown":"https://lucycraig.blog/media/421/index.md"},"name":"EXHIBIT(S)\r\n \u00a0- A\r\n \u00a0(Motion #002) Sealed","ocrStatus":"ready","ocrText":"--- Page 1 ---\nFrom:\nEthan Cohen\nTo:\nTeny Geragos; Thomas P. Giuffra; echohen@rheingoldlaw.com\nCc:\nJames C. Knox; Alishah E. Bhimani; ebernstein@nylegaljustice.com; tdavis@nmllplaw.com; nino@lamalaw.com;\nehallak@harrisbeachmurtha.com; asash@bushellsovak.com; sbernstein@nmllplaw.com;\nmcuccaro@shertremonte.com; rfriedman@shertremonte.com; rsweeney@mgmlaw.com\nSubject:\nRe: Demand for Immediate Retraction\nDate:\nThursday, October 15, 2026 10:38:50 AM\nAttachments:\nimage001.png\nimage002.png\nDear Ms. Geragos,\nMr. Giuffra is out of town and is currently unavailable. He will respond this evening.\nEthan J. Cohen\nAssociate\nRHEINGOLD GIUFFRA RUFFO\nPLOTKIN & HELLMAN, LLP\n551 5th Avenue, 29th Floor\nNew York, NY 10176 \ntel 1.212.684.1880 / fax 1.212.689.8156\necohen@rheingoldlaw.com\nFrom: Teny Geragos \nSent: Thursday, October 15, 2026 10:23 AM\nTo: Thomas P. Giuffra ; Ethan Cohen ;\nechohen@rheingoldlaw.com \nCc: jknox@hackermurphy.com ; abhimani@hackermurphy.com\n; ebernstein@nylegaljustice.com\n; tdavis@nmllplaw.com ;\nnino@lamalaw.com ; ehallak@harrisbeachmurtha.com\n; asash@bushellsovak.com ;\nsbernstein@nmllplaw.com ; mcuccaro@shertremonte.com\n; rfriedman@shertremonte.com ;\nrsweeney@mgmlaw.com \nSubject: Demand for Immediate Retraction\n \nDear Mr. Giuffra and Mr. Cohen:\nAlthough we have never met, you have apparently seen fit to make serious and wholly\nbaseless allegations impugning my professional integrity in a public court filing. Separate and\napart from the false allegations you and your client have made against my client, you have now\npersonally accused me of unethical conduct in which I have never engaged and would never\nengage.\nI have come to understand that some civil practitioners consider personal attacks and\nFILED: NEW YORK COUNTY CLERK 10/15/2026 04:18 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 68\nRECEIVED NYSCEF: 10/15/2026\n\n--- Page 2 ---\ninflammatory accusations acceptable litigation tactics. I do not. In my years of practicing\ncriminal law, I have never regarded baseless accusations against opposing counsel as a\nlegitimate substitute for advocacy. Your decision to publicly accuse me of professional\nmisconduct without any factual foundation is outrageous, offensive, and entirely\nunacceptable.\nWhat makes your conduct particularly indefensible is that, despite apparently monitoring my\nactivities and those of a member of my family, you never once contacted me to inquire about\nthe allegations you now purport to make. You made no effort to verify your accusations, seek\nan explanation, or afford me even the most basic professional courtesy before publishing\nallegations that directly attack my integrity and reputation. Your failure to do so speaks\nvolumes about the recklessness of your conduct.\nTo be clear, since you never asked: I have never leaked any information, and your suggestion\notherwise is categorically false. You had no legitimate basis to accuse me of doing so, much\nless to memorialize that accusation in a public judicial filing.\nI am demanding that you immediately correct the record by filing a written retraction expressly\nacknowledging that you have no factual basis to accuse me of leaking information or engaging\nin any other unethical conduct. That correction must be made publicly, in the same forum in\nwhich you chose to publish your accusations.\nIf you fail to file that correction by tomorrow, I intend to pursue all appropriate relief. I will not\npermit you to use a court filing as a vehicle to make unsupported allegations that damage my\nprofessional reputation without consequence.\nYou and your colleague are further directed to preserve all documents, communications,\nelectronic messages, research, notes, and other materials relating in any way to the\nallegations against me, including communications with your client, other counsel, third\nparties, or anyone involved in investigating, formulating, approving, or disseminating those\nallegations. This preservation demand includes electronically stored information and any\ncommunications concerning me or members of my family.\nI expressly reserve all rights and remedies. Confirm receipt.\n \nTeny Geragos\n \nTeny Geragos\nPartner, Agnifilo Intrater LLP\n140 Broadway, Ste. 4530 | New York, NY 10005\no: (646) 205-4351 | c: \nteny@agilawgroup.com\nwww.agilawgroup.com\n \nFILED: NEW YORK COUNTY CLERK 10/15/2026 04:18 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 68\nRECEIVED NYSCEF: 10/15/2026\n\n--- Page 3 ---\nThis message is a PRIVATE communication. This message and all attachments are a private\ncommunication sent by a law firm and may be confidential or protected by attorney-client\nprivilege or work product protection. If you are not the intended recipient, you are hereby\nnotified that any disclosure, copying, distribution or use of the information contained in or\nattached to this message is strictly prohibited. Please notify the sender of the delivery error by\nreplying to this message, and then delete it from your system. Thank you.\nFILED: NEW YORK COUNTY CLERK 10/15/2026 04:18 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 68\nRECEIVED NYSCEF: 10/15/2026","text":"--- Page 1 ---\nFrom:\nEthan Cohen\nTo:\nTeny Geragos; Thomas P. Giuffra; echohen@rheingoldlaw.com\nCc:\nJames C. Knox; Alishah E. Bhimani; ebernstein@nylegaljustice.com; tdavis@nmllplaw.com; nino@lamalaw.com;\nehallak@harrisbeachmurtha.com; asash@bushellsovak.com; sbernstein@nmllplaw.com;\nmcuccaro@shertremonte.com; rfriedman@shertremonte.com; rsweeney@mgmlaw.com\nSubject:\nRe: Demand for Immediate Retraction\nDate:\nThursday, October 15, 2026 10:38:50 AM\nAttachments:\nimage001.png\nimage002.png\nDear Ms. Geragos,\nMr. Giuffra is out of town and is currently unavailable. He will respond this evening.\nEthan J. Cohen\nAssociate\nRHEINGOLD GIUFFRA RUFFO\nPLOTKIN & HELLMAN, LLP\n551 5th Avenue, 29th Floor\nNew York, NY 10176 \ntel 1.212.684.1880 / fax 1.212.689.8156\necohen@rheingoldlaw.com\nFrom: Teny Geragos \nSent: Thursday, October 15, 2026 10:23 AM\nTo: Thomas P. Giuffra ; Ethan Cohen ;\nechohen@rheingoldlaw.com \nCc: jknox@hackermurphy.com ; abhimani@hackermurphy.com\n; ebernstein@nylegaljustice.com\n; tdavis@nmllplaw.com ;\nnino@lamalaw.com ; ehallak@harrisbeachmurtha.com\n; asash@bushellsovak.com ;\nsbernstein@nmllplaw.com ; mcuccaro@shertremonte.com\n; rfriedman@shertremonte.com ;\nrsweeney@mgmlaw.com \nSubject: Demand for Immediate Retraction\n \nDear Mr. Giuffra and Mr. Cohen:\nAlthough we have never met, you have apparently seen fit to make serious and wholly\nbaseless allegations impugning my professional integrity in a public court filing. Separate and\napart from the false allegations you and your client have made against my client, you have now\npersonally accused me of unethical conduct in which I have never engaged and would never\nengage.\nI have come to understand that some civil practitioners consider personal attacks and\nFILED: NEW YORK COUNTY CLERK 10/15/2026 04:18 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 68\nRECEIVED NYSCEF: 10/15/2026\n\n--- Page 2 ---\ninflammatory accusations acceptable litigation tactics. I do not. In my years of practicing\ncriminal law, I have never regarded baseless accusations against opposing counsel as a\nlegitimate substitute for advocacy. Your decision to publicly accuse me of professional\nmisconduct without any factual foundation is outrageous, offensive, and entirely\nunacceptable.\nWhat makes your conduct particularly indefensible is that, despite apparently monitoring my\nactivities and those of a member of my family, you never once contacted me to inquire about\nthe allegations you now purport to make. You made no effort to verify your accusations, seek\nan explanation, or afford me even the most basic professional courtesy before publishing\nallegations that directly attack my integrity and reputation. Your failure to do so speaks\nvolumes about the recklessness of your conduct.\nTo be clear, since you never asked: I have never leaked any information, and your suggestion\notherwise is categorically false. You had no legitimate basis to accuse me of doing so, much\nless to memorialize that accusation in a public judicial filing.\nI am demanding that you immediately correct the record by filing a written retraction expressly\nacknowledging that you have no factual basis to accuse me of leaking information or engaging\nin any other unethical conduct. That correction must be made publicly, in the same forum in\nwhich you chose to publish your accusations.\nIf you fail to file that correction by tomorrow, I intend to pursue all appropriate relief. I will not\npermit you to use a court filing as a vehicle to make unsupported allegations that damage my\nprofessional reputation without consequence.\nYou and your colleague are further directed to preserve all documents, communications,\nelectronic messages, research, notes, and other materials relating in any way to the\nallegations against me, including communications with your client, other counsel, third\nparties, or anyone involved in investigating, formulating, approving, or disseminating those\nallegations. This preservation demand includes electronically stored information and any\ncommunications concerning me or members of my family.\nI expressly reserve all rights and remedies. Confirm receipt.\n \nTeny Geragos\n \nTeny Geragos\nPartner, Agnifilo Intrater LLP\n140 Broadway, Ste. 4530 | New York, NY 10005\no: (646) 205-4351 | c: \nteny@agilawgroup.com\nwww.agilawgroup.com\n \nFILED: NEW YORK COUNTY CLERK 10/15/2026 04:18 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 68\nRECEIVED NYSCEF: 10/15/2026\n\n--- Page 3 ---\nThis message is a PRIVATE communication. This message and all attachments are a private\ncommunication sent by a law firm and may be confidential or protected by attorney-client\nprivilege or work product protection. If you are not the intended recipient, you are hereby\nnotified that any disclosure, copying, distribution or use of the information contained in or\nattached to this message is strictly prohibited. Please notify the sender of the delivery error by\nreplying to this message, and then delete it from your system. Thank you.\nFILED: NEW YORK COUNTY CLERK 10/15/2026 04:18 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 68\nRECEIVED NYSCEF: 10/15/2026","thumbnailUrl":"https://lucycraig.blog/media/421/thumb.webp","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/421"}