Subject: Your threat to sue everyone on Twitter posting negative comments about

you

Mr. Avenatti,

You are a public figure who has extensively used Twitter, on which platform you
have a large following, to court public controversies. You have also made scores
of recent appearances on CNN, MSNBC and other cable news networks to
discuss the various public controversies in which you have involved yourself. In
the past month you submitted to an interview with Vanity Fair.

You have been indicted by three separate grand juries in the SDNY and the SDCA
for over 40 alleged felony crimes, which include, without limitation, extortion,
identity theft, tax evasion, wire fraud, embezzlement from 4-clients, theft of
$300,000 from a 5th client, perjury, bankruptcy fraud, bank fraud and failing to
file personal income tax returns for years in which you deposited $18M in your
personal accounts and had six-figure expenses paid by your law firms (on whose
behalf you are the designated tax partner) and on whose behalf you also allegedly
failed to file tax returns during high-income years.

Given your high-profile legal career (you have described yourself as "the most
famous lawyer in America" and recently as a candidate for president of the
United States and have recently sued the president of the United States in
two headline producing lawsuits), your federal criminal indictments have
created even more controversy about you in the news media and on Twitter. You
have fanned these flames by blaming your indictments (for some conduct, BTW,
that predates the Trump Presidency by years) by suggesting that your
prosecution is pay-back for suing the president.

Exacerbating this publicity frenzy, the State Bar of California has filed a petition
to place you on inactive involuntary enrollment for alleged client theft and a host
of other related, alleged charges - which 570 page petition is supported by
declarations (including by the alleged victim) as well as attorney client trust
account records and other documents that on their face appear to support the
charges.

You have also been sued by a disabled, wheelchair bound client claiming a multi-
million dollar theft of settlement funds, whose attorney has ripped a page from
your playbook by announcing the suit at a nationally reported press conference
last week. You, in turn, using Twitter as platform, which tweets were
republished in the general media, have accused said attorney of misconduct and
the client of being "delusional". This has created yet more controversy on Twitter
and in the general news media.

Last, you have been challenging many public figures to "debate the issues" at
least once a week on Twitter calling them cowards and have just last week been
very critical of a well-known actress on Twitter, creating even more notoriety,

file:///C|/...ments/Your%20threat%20to%20sue%20everyone%20on%20Twitter%20posting%20negative%20comments%20about%20you.txt[6/19/2019 3:22:14 PM]

 publicity and controversy.

Since you have thrust yourself in the limelight and fanned the flames
surrounding your several felony indictments and petition to effectively suspend
you from the practice of law with daily Tweets and by claiming an over-arching
conspiracy against you by litigation foes, and by your own comments on social
media to your 800,000 followers, you are hardly in a position to cry
"harassment" or "stalking" by 40 or 50 random Twitter users with a handful of
followers, whom you have blocked on Twitter, but nevertheless appear to
studiously monitor.

Don't you have more important matters to occupy your time right now that
obsessing about what everyone in the world, no matter how obscure, says about
you on Twitter?

For instance, you have a verified answer due in the pending Cal Bar matter
within 48 hours that may determine your ability to practice law for the next few
months or years.

In five short months your alleged extortion trial begins in the SDNY.

In any event, I am aware of no one who has done anything in any way actionable
on any Twitter thread commenting on the public controversies relating to
@MichaelAvenatti.

A guy with 800,000 Twitter followers threatening to sue folks with 40 or 50

followers is perceived by some as bullying behavior.

file:///C|/...ments/Your%20threat%20to%20sue%20everyone%20on%20Twitter%20posting%20negative%20comments%20about%20you.txt[6/19/2019 3:22:14 PM]