ENABLE 600 MASSACHUSETTS AVE.. NW WASHINGTON, DC 20001
LLP A T202.344.4000 F202.344.8300 

Geoffrey Garinther
(202) 344-4919
(202) 344-8300
grgarinther@venable.com

 

October 30, 2017
VIA E-MAIL To CHARLES co UGER

Tucker Carlson

Fox News Channel

1211 Avenue of the Americas, 2nd Floor
New York, NY 10036

T: (212) 301-3000

Re: Mr. Podesta and the Podesta Group

Dear Mr. Carlson:

This law ?rm represents Anthony Podesta, Chairman of the Podesta Group. On behalf of
Mr. Podesta, I write to demand that you and Fox News Channel immediately cease and desist
disseminating false and misleading reports about Mr. Podesta and the Podesta Group. In
particular, your statements about Mr. Podesta and Podesta Group made during Tucker Carlson
Tonight on October 24 and 25, 2017 are provably false and misleading and are defamatory.

The European Centre for a Modern Ukraine a non?pro?t organization,
retained the Podesta Group to advocate for Ukraine?s turn to the West and to enter into an
Association Agreement with the EU. The ECFMU provided the Podesta Group with a formal
certi?cation that it was neither funded by nor directed by a foreign government or political party.
Based on the certi?cation and advice of in-house and outside counsel, the Podesta Group fully
disclosed its representation of the ECFMU, and complied with Foreign Agents Registration Act
by ?ling under the Lobbying Disclosure Act. This representation was further disclosed in eight
subsequent public ?lings. Paul Manafort did not work with the Podesta Group in its
representation of the ECFMU. Further, Mr. Manafort did not regularly attend meetings at the
Podesta Group. The Podesta Group has fully cooperated with the Special Counsel?s office and
taken every possible step to provide documentation that con?rms compliance with the law.

You and Fox News Channel have disseminated false and misleading reports about Mr.
Podesta and the Podesta Group. Your report propagated falsehoods, such as: (1) Mr. Manafort
was seen in the Podesta Group?s of?ces ?once a month? (2) Mr. Manafort and the Podesta Group
worked for the Russian Government through Podesta Group?s representation?of the European
Centre for a Modern Ukraine (ECFMU), and (3) the Podesta Group?s client, the ECFMU, was a
?sham? organization. Your statements are fabricated and demonstrate a callous disregard for the
truth.

VENABLEL.

Tucker Carlson
October 30, 2017
Page 2

 

Your false and defamatory statements have caused damage and injury to the reputation of
Mr. Podesta and the Podesta Group. Many" of the false statements are so obviously false or so
easily subject to investigation that it is apparent that you and Fox News Channel disseminated
the false and defamatory statements either knowingly or with reckless disregard for whether the
statements were true or not. You and Fox News Channel have an independent and non-delegable
duty to conduct a reasonable investigation of the information you publish and disseminate and
the failure to do so is a violation of law and the rights of those targeted by such unfounded
allegations. You and Fox News Channel are not shielded from liability by conveniently
disseminating the story as the account of an undisclosed third party. The obligation to
investigate is indeed non-delegable and independent, and should be held inviolate by any
credible news organization.

Venable LLP, on behalf of Mr. Podesta, demands that you and Fox News Channel: 
immediately issue a retraction that is of equal prominence to the reports by no later than Friday,
November 3, 2017, (ii) remove the story from all media sources, and cease and desist from
disseminating false and misleading statements about Mr. Podesta and the Podesta Group. Please
con?rm in writing within three business days of receipt of this letter that you will immediately
take these steps. If you do not supply such written con?rmation, Mr. Podesta may pursue legal
action, including for damages, in order to fully protect his rights.

This letter does not constitute a complete or exhaustive statement of all of Mr. Podesta?s
rights, claims, contentions or legal theories. Nothing stated herein is intended to nor should-be
deemed to constitute a waiver or relinquishment of any of Mr. Podesta?s rights or remedies,
whether legal or equitable, all of which are hereby expressly reserved.

This is a confidential legal notice and is not for publication. Any publication,
dissemination or broadcast of any portion of this letter will constitute a breach of con?dence and
a violation of Copyright Act. You are not authorized to publish this letter in whole or in part
absent our express written authorization.

Sincerely yours,

aim Mm

Geoffrey Garinther

cc: Anthony Podesta