250 pene AVENUE, SumTE 101 TELECOPIER (201) 490-2040 ROTTENBERG LIPMAN RICH, P.C 230 PARK AVENUE EIGHTEENTH FLOOR NEW YORK, NEW YORK 10169 TELEPHONE (2 | 2) 661-3080 yeLecopien (212) 867-1914 WwW, RLRPCLAW.COM aseiuer@niarciaw.com June 18, 2018 VIA E-MAIL AND FAX ‘Ms. Margarita Simonyan Editor-in-Chief, RT ANO-Novosti Borovaya St. 3, Bldg 1 Moscow 111020 Russia Re: Demand for Retraction Dear Ms. Simonyan: We represent Mrs. Marina Litvinenko and Mr.Alex Goldfarb. I am writing concerning certain false and detamatory statements in your recent program accusing Mr. Goldfarb of committing serious crimes. You broadcasted allegations that Mr. Goldfarb murdered Alexander Litvinenko on behalf of the CIA, and was complicit in the murder of his own wife. The program in question, “Worlds Apart”, was broadcast on 1 April 2018. Your broadcast was reckless, defamatory and constitutes libel per se. It is apparent, among other things, from the fact that you ignored the findings of Litvinenko Public Inquiry, which established and named the true murderers of Mr. Litvinenko. The linkage of the defamatory statements to the recent poisoning of Sergei and Yulia Skripal indicates that the statements are nothing more than a politically-motivated effort to deflect the blame from the true perpetrators of both poisonings. ‘Your actions also constitute intentional and negligent infliction of emotional distress on our clients, particularly Mrs. Litvinenko. She struggled for ten years to have her husband's murderers named in a court of law. Undermining the court’s finding with a fake narrative before tens of millions of viewers adds insult to injury. We hereby demand that you issue a full and immediate retraction and apology ‘with equal reach and prominence as the broadcast itself. Specifically, the retraction should clearly state that Mr. Goldfarb had nothing to do with the murder of Mr. Litvinenko and that the claim of Mr. Goldfarb's association with the CIA was totally baseless. The retraction should clearly state that an impartial and open judicial inquiry has established beyond reasonable doubt on clear and open evidence that Mr. Litvinenko was murdered by Andrey Lugovoy and Dmitry Kovrtun. The retraction should also state that there are no grounds of suspecting Mr. Goldfarb of murdering his wife, and that she in fact has died of cancer.ROTTENBERG LIPMAN RICH, P.C Ms. Margarita Simonyan June 18, 2018 Page 2 Please confirm in writing within forty-eight (48) hours of your receipt of this letter that the foregoing requests will be complied with promptly. In the absence of such confirmation our clients will pursue all available actions and remedies. This letter is not intended and shall not be construed as a complete expression of our clients’ factual or legal positions with respect to this matter. Nothing contained in or omitted from this letter is intended and should not be construed, as a waiver, relinquishment, release or other limitation upon any legal or equitable claims, causes of action, rights and/or remedies available to my clients, all of which are hereby expressly reserved. Sincerely, ee C. Sellier Ce: Brian Dickerson, Esq. (by fax)