Re: Clifford v. Trump, at. BM .1 -ov- 22W- -FFM Dear Mr. Avenatti: As you know from our meeting earlier this week, this law firm is litigation eounsel for Michael Cohen in the above-referenced matter. I am writing in eonneetion with the false and defamatory statements you and your elient, Stephanie Clifford a.k.a. Stormy Daniels, made on 60 Minutes this evening regarding Mr. Cohen, namely that he was responsible for an alleged thug who supposedly visited Ms. Clifford, while she was with her daughter, and made an alleged threat to Ms. Clifford. In truth, Mr. Cohen had absolutely nothing whatsoever to do with any such person or ineident, and does not even believe that any sueh person exists, or that sueh ineident ever oeeurred. You and your client?s false statements about Mr. Cohen aeeuse him oferiminal oonduet and eonstitute, among other elaims, libel SE and intentional infliction of emotional distress. It would also appear that your statements ofalleged oriminal oonduet are being made to obtain an advantage in a eivil dispute, which is also improper. I hereby demand that you and your elient cease and desist from making any ?lrther false and defamatory statements about my elient, that you immediately retraet and apologize to Mr. Cohen through the national media for your defamatory statements on 60 Minutes, and make elear that you have no faets or evidenee whatsoever to support your allegations that my elient had anything whatsoever to do with this alleged thug. Most ofwhat you have been stating to the press, partieularly these baseless allegations of oriminal oonduet, have absolutely nothing to do with the underlying eontraet dispute between Ms. Daniels and Essential Consultants LLC. Moving forward I would ask that you refrain from any further false aeeusations and litigate this ease in eourt on the aetual merits. This letter is not intended as a full or eomplete statement ofall relevant faets or applicable law, and nothing herein is intended as, nor should it be deemed to eonstitute, a waiver or relinquishment ofany of my client's rights, remedies, elaims or causes ofaetion, all ofwhieh are hereby espresst reserved. March 25, 2013 Page 2 Should you have any questions regarding the foregoing obligations, please do not hesitate to eontaet me. 3 ine erely, BRENT H. BLAKELY