Rottenberg Lipman Rich, P.C.

 
230 Park Avenue eighteenth floor new york, new york 10169 telephone (212) 661-3080 
telecopier (212) 867-1914 
new jersey office park 80 west, plaza one 
250 pehle avenue, suite 101 saddle brook, new jersey 
07663 telephone (201) 490-2022 telecopier (201) 490-2040 

www.rlrpclaw.com 
bertrand c. sellier member bsellier@rlrpclaw.com 

June __, 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 con- 
cerning certain false and defamatory 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 appar- 
ent, 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 defamato- 
ry 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 dis- 
tress on our clients, particularly Mrs. Litvinenko. She struggled for ten years to have her hus- 
band'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. 
 
Rottenberg Lipman Rich, P.C. 
Ms. Margarita Simonyan June 12, 2018 Page 2 
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 clear- 
ly 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 murder- 
ing his wife, and that she in fact has died of cancer. 
Please  confirm  in  writing  within  forty-eight  (48)  hours  of  your  receipt of this let- 
ter  that  the  foregoing  requests  will  be  complied  with promptly. In the absence of such confirma- 
tion 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, 
Bertrand C. Sellier