Case 1:19-cr-00373-PGG Document 267 Filed 02/19/20 Page 1 of 1

U.S. Department of Justice

United States Attorney

Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007

February 19, 2020

BY ECF

The Honorable Paul G. Gardephe

United States District Judge
Southern District of New York
40 Foley Square
New York, New York 10007

Re: United States v. Michael Avenatti,

S1 19 Cr. 373 (PGG)

Dear Judge Gardephe:

Pursuant to the Court’s direction on the record on February 12, 2020, the Government
submits the PowerPoint presentation used during its summation on February 11, 2020.

Respectfully submitted,

GEOFFREY S. BERMAN
United States Attorney

By: s/ Matthew D. Podolsky

Matthew D. Podolsky
Daniel C. Richenthal
Robert B. Sobelman
Assistant United States Attorneys
(212) 637-1947/2109/2616

Attachment

cc: (by ECF)

Counsel of Record
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 1 of 117

United States of America

v.

Michael Avenatti

S1 19 Cr. 373 (PGG)

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“Avenatti: Have you ever held the balls of the client in

your hand where you can take 5, 6 billion dollars in
market cap off of ‘em?”
(GX 2T: 23)
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“Avenatti: Have you ever held the balls of the client in

your hand where you can take 5, 6 billion dollars in
market cap off of ‘em?”
(GX 2T: 23)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 4 of 117

“Avenatti: I don’t think that it makes any sense for Nike to be

paying, um, an exorbitant sum of money to Mr. Franklin, in
light of his role in this.
Wilson: Okay
Avenatti: I mean, imagine that.”
(GX 2T: 19-20)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 5 of 117

“Avenatti: I don’t think that it makes any sense for Nike to be

paying, um, an exorbitant sum of money to Mr. Franklin, in
light of his role in this.
Wilson: Okay
Avenatti: I mean, imagine that.”
(GX 2T: 19-20)
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1. The defendant threatened to harm Nike if Nike did not hire him.

2. The defendant did not tell Gary Franklin what he was doing.
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 8 of 117
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Avenatti Threatened Nike

“Avenatti: I’m not fucking around with this, and I’m not continuing to
play games. And I don’t-you know, this isn’t complicated. You guys
know enough now to know you’ve got a serious problem. And it’s worth
more in exposure to me to just blow the lid on this thing. A few million
dollars doesn’t move the needle for me. I’m just being really frank with
you. So if that’s what, if that’s what is being contemplated, then let’s
just say it was good to meet you, and we’re done. And I’ll proceed with
my press conference tomorrow and I’ll hang up with you now and I’ll
call the New York Times, who are awaiting my call. I-I’m not fucking
around with this thing anymore.”
(GX 1T: 4-5)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 10 of 117

Avenatti Threatened Nike

“Avenatti: I’m not fucking around with this, and I’m not continuing to
play games. And I don’t-you know, this isn’t complicated. You guys
know enough now to know you’ve got a serious problem. And it’s worth
more in exposure to me to just blow the lid on this thing. A few million
dollars doesn’t move the needle for me. I’m just being really frank with
you. So if that’s what, if that’s what is being contemplated, then let’s
just say it was good to meet you, and we’re done. And I’ll proceed with
my press conference tomorrow and I’ll hang up with you now and I’ll
call the New York Times, who are awaiting my call. I-I’m not fucking
around with this thing anymore.”
(GX 1T: 4-5)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 11 of 117

Avenatti Threatened Nike

“Avenatti: And I’ll go and I’ll go take and I’ll go take
ten billion dollars off your client’s market cap. But I’m
not fucking around.”
(GX 1T: 5)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 12 of 117

Avenatti Threatened Nike

“Avenatti: And I’ll go and I’ll go take and I’ll go take
ten billion dollars off your client’s market cap. But I’m
not fucking around.”
(GX 1T: 5)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 13 of 117

Avenatti Threatened Nike

“Avenatti: No, this is not me pounding my chest, or any of that shit. I’m just gonna,
this is, I’m just gonna have a very real discussion with you, that this is what happens
every time, okay? As soon as this becomes public, I’m gonna receive calls from all
over the country, from parents, and coaches, and friends, and all kinds of people,
because this is always what happens - and they’re all going to say, “I’ve got an
email, or text message or – now. 90% of that is gonna be bullshit. Cause it’s always
bullshit 90% of the time. Always. Whether it’s R. Kelly, or Trump, or the list goes
on and on. But 10% of it is actually going to be true. And then what’s gonna happen
is, this will snowball. And then it will be 5 players, and then it will be 9, and then it
will be 15, and then it will be 25, and it's gonna snowball - and every time we get
more information, that’s gonna be The Washington Post, The New York Times,
ESPN, a press conference – and the company will die, not die, but they’re going to
incur, cut after cut after cut after cut, and that’s what’s gonna happen. As soon as this
thing becomes public. So, it is in the company’s best interest to avoid this becoming
public…”
(GX 2T: 26-27)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 14 of 117

Avenatti Threatened Nike

“Avenatti: No, this is not me pounding my chest, or any of that shit. I’m just gonna,
this is, I’m just gonna have a very real discussion with you, that this is what happens
every time, okay? As soon as this becomes public, I’m gonna receive calls from all
over the country, from parents, and coaches, and friends, and all kinds of people,
because this is always what happens - and they’re all going to say, “I’ve got an
email, or text message or – now. 90% of that is gonna be bullshit. Cause it’s always
bullshit 90% of the time. Always. Whether it’s R. Kelly, or Trump, or the list goes
on and on. But 10% of it is actually going to be true. And then what’s gonna happen
is, this will snowball. And then it will be 5 players, and then it will be 9, and then it
will be 15, and then it will be 25, and it's gonna snowball - and every time we get
more information, that’s gonna be The Washington Post, The New York Times,
ESPN, a press conference – and the company will die, not die, but they’re going to
incur, cut after cut after cut after cut, and that’s what’s gonna happen. As soon as this
thing becomes public. So, it is in the company’s best interest to avoid this becoming
public…”
(GX 2T: 26-27)
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Avenatti Demanded to Be Hired and Paid

“Avenatti: Well Scott, I mean look, I I just, I mean
we’re gonna get a million five for our guy, and we’re
gonna be hired to handle the internal investigation, and
if you don’t wanna do that, we’re done.”
(GX 1T: 4)
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Avenatti Demanded to Be Hired and Paid

“Avenatti: Well Scott, I mean look, I I just, I mean
we’re gonna get a million five for our guy, and we’re
gonna be hired to handle the internal investigation, and
if you don’t wanna do that, we’re done.”
(GX 1T: 4)
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Avenatti Demanded to Be Hired and Paid

“Avenatti: …12 million dollar retainer upon signing
Evergreen. Um, that’s gonna be deemed earned when
paid, we’ll cap it at 25 million dollars, minimum of 15
million dollars, unless the scope changes.”
(GX 2T: 14)
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Avenatti Demanded to Be Hired and Paid

“Avenatti: …12 million dollar retainer upon signing
Evergreen. Um, that’s gonna be deemed earned when
paid, we’ll cap it at 25 million dollars, minimum of 15
million dollars, unless the scope changes.”
(GX 2T: 14)
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 Three Simple Reasons You Know the
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 20 of 117

Defendant Is Guilty
1. The Defendant’s Own Words
2. Gary Franklin’s Testimony
3. Common Sense
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 21 of 117

Avenatti’s Own Words

“Avenatti: I’m not fucking around with this, and I’m not
continuing to play games. And I don’t-you know, this isn’t
complicated. You guys know enough now to know you’ve got
a serious problem. And it’s worth more in exposure to me to
just blow the lid on this thing. A few million dollars doesn’t
move the needle for me. I’m just being really frank with you.”
(GX 1T: 14)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 22 of 117

Avenatti’s Own Words

“Avenatti: I’m not fucking around with this, and I’m not
continuing to play games. And I don’t-you know, this isn’t
complicated. You guys know enough now to know you’ve got
a serious problem. And it’s worth more in exposure to me to
just blow the lid on this thing. A few million dollars doesn’t
move the needle for me. I’m just being really frank with you.”
(GX 1T: 14)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 23 of 117

Avenatti’s Own Words

“Avenatti: So if you guys think that you know, we’re
gonna negotiate a million five, and we’re gonna, you’re
gonna hire us to do an internal investigation, but it’s
gonna be capped at 3 or 5 or 7 million dollars, like let’s
just be done.”
(GX 1T: 5)
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Avenatti’s Own Words

“Avenatti: So if you guys think that you know, we’re
gonna negotiate a million five, and we’re gonna, you’re
gonna hire us to do an internal investigation, but it’s
gonna be capped at 3 or 5 or 7 million dollars, like let’s
just be done.”
(GX 1T: 5)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 25 of 117

Avenatti’s Own Words

“Avenatti: I don’t think that it makes any sense for Nike to be
paying, um, an exorbitant sum of money to Mr. Franklin, in
light of his role in this.
Wilson: Okay
Avenatti: I mean, imagine that.”
(GX 2T: 19-20)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 26 of 117

Avenatti’s Own Words

“Avenatti: I don’t think that it makes any sense for Nike to be
paying, um, an exorbitant sum of money to Mr. Franklin, in
light of his role in this.
Wilson: Okay
Avenatti: I mean, imagine that.”
(GX 2T: 19-20)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 27 of 117

Avenatti’s Own Words

“Avenatti: Have you ever held the balls of the client in
your hand where you can take 5, 6 billion dollars in
market cap off of ‘em?”
(GX 2T: 23)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 28 of 117

Avenatti’s Own Words

“Avenatti: Have you ever held the balls of the client in
your hand where you can take 5, 6 billion dollars in
market cap off of ‘em?”
(GX 2T: 23)
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 29 of 117

Avenatti’s Own Words

Scott Wilson, Tr. 257

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 30 of 117

Avenatti’s Own Words

Robert Leinwand, Tr. 1166

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 31 of 117

Avenatti’s Own Words

Benjamin Homes, Tr. 1422

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 32 of 117

Avenatti’s Own Words

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 33 of 117
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 34 of 117

Avenatti’s Own Words

Scott Wilson, Tr. 501

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 35 of 117

Avenatti’s Own Words

Robert Leinwand, Tr. 1170

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 36 of 117

Avenatti’s Own Words

Benjamin Homes, Tr. 1506

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 37 of 117

Avenatti’s Own Words

Gary Franklin, Tr. 1537

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 38 of 117

Avenatti’s Own Words

“Avenatti: I don’t wanna hear about somebody on a
bike trip, I don’t wanna hear that somebody has,
somebody’s grandmother passed away or something, I
don't- look - the dog ate my homework, I don’t wanna
hear, none of it is gonna go anywhere unless somebody
was killed in a plane crash. It’s going to go zero, no
place with me.”
(GX 2T: 29)
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Avenatti’s Own Words

“Avenatti: I don’t wanna hear about somebody on a
bike trip, I don’t wanna hear that somebody has,
somebody’s grandmother passed away or something, I
don't- look - the dog ate my homework, I don’t wanna
hear, none of it is gonna go anywhere unless somebody
was killed in a plane crash. It’s going to go zero, no
place with me.”
(GX 2T: 29)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 40 of 117

What Avenatti Did Not Say

• Complaint

• Lawsuit
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 41 of 117

Avenatti Did Not Threaten a Lawsuit

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 42 of 117
 Three Simple Reasons You Know the
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 43 of 117

Defendant Is Guilty
1. The Defendant’s Own Words
2. Gary Franklin’s Testimony
3. Common Sense
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 44 of 117

Franklin Wanted Avenatti to Help Him

Gary Franklin, Tr. 1536

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 45 of 117

Franklin Wanted Avenatti to Help Him

Gary Franklin, Tr. 1541

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 46 of 117

Franklin Wanted Avenatti to Help Him

Gary Franklin, Tr. 1542

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 47 of 117

Avenatti Did Not Tell Franklin About His

Scheme

Gary Franklin, Tr. 1553

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Avenatti Did Not Tell Franklin About His

Scheme

Gary Franklin,
Tr. 1560-1561
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Avenatti Did Not Tell Franklin About His

Scheme
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 52 of 117

Avenatti Did Not Tell Franklin About His

Scheme

Gary Franklin, Tr. 1567

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Avenatti Did Not Tell Franklin About His

Scheme

Gary Franklin, Tr. 1568

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Avenatti Did Not Tell Franklin About His

Scheme
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 56 of 117

Avenatti Did Not Tell Franklin About His

Scheme
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 57 of 117

Avenatti Did Not Tell Franklin About His

Scheme

Gary Franklin,
Tr. 1569-1570
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Avenatti Did Not Tell Franklin About His

Scheme
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Avenatti Did Not Tell Franklin About His

Scheme

Gary Franklin,
Tr. 1577-1578
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Franklin Did Not Want a Press Conference

Gary Franklin, Tr. 1542

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Franklin Did Not Want a Press Conference

Gary Franklin, Tr. 1547

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Avenatti Was Going to Hold a Press

Conference If His Scheme Failed
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 64 of 117

Avenatti Did Not Tell Franklin About His

Scheme
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 65 of 117

Avenatti Was Going to Hold a Press

Conference If His Scheme Failed
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 66 of 117

Avenatti Was Going to Hold a Press

Conference If His Scheme Failed
“Avenatti: I’m not fucking around with this, and I’m not
continuing to play games. And I don’t-you know, this isn’t
complicated. You guys know enough now to know you’ve got
a serious problem. And it’s worth more in exposure to me to
just blow the lid on this thing. A few million dollars doesn’t
move the needle for me. I’m just being really frank with you.”
(GX 1T: 14)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 67 of 117

Avenatti Was Going to Hold a Press

Conference If His Scheme Failed
“Avenatti: I’m not fucking around with this, and I’m not
continuing to play games. And I don’t-you know, this isn’t
complicated. You guys know enough now to know you’ve got
a serious problem. And it’s worth more in exposure to me to
just blow the lid on this thing. A few million dollars doesn’t
move the needle for me. I’m just being really frank with you.”
(GX 1T: 14)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 68 of 117

Avenatti Was Going to Hold a Press

Conference If His Scheme Failed

Gary Franklin,
Tr. 1579-1580
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Avenatti Was Going to Hold a Press

Conference If His Scheme Failed
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 70 of 117

Avenatti Was Going to Hold a Press

Conference If His Scheme Failed
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 71 of 117

Avenatti Was Going to Hold a Press

Conference If His Scheme Failed
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 72 of 117
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What the Defense Told You

Howard Srebnick, Tr. 176

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 Three Simple Reasons You Know the
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 75 of 117

Defendant Is Guilty
1. The Defendant’s Own Words
2. Gary Franklin’s Testimony
3. Common Sense
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Avenatti Had a Conflict of Interest

Scott Wilson, Tr. 312

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 77 of 117

Avenatti Had a Conflict of Interest

Robert Leinwand, Tr. 1156

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 78 of 117
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 79 of 117

Avenatti Had a Conflict of Interest

Jeffrey Auerbach, Tr. 747

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 80 of 117

Avenatti Had a Conflict of Interest

Gary Franklin, Tr. 1572

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 81 of 117

Avenatti Had a Conflict of Interest

 Three Simple Reasons You Know the
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 82 of 117

Defendant Is Guilty
1. The Defendant’s Own Words
2. Gary Franklin’s Testimony
3. Common Sense
 Three Simple Reasons You Know the
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 83 of 117

Defendant Is Guilty
1. The Defendant’s Own Words
2. Gary Franklin’s Testimony
3. Common Sense
Bonus: Crushing Debt
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Avenatti Had Crushing Debt

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 85 of 117
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Avenatti Had Crushing Debt

Judy Regnier,
Tr. 1569-1570
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Avenatti Had Crushing Debt

Judy Regnier, Tr. 1406

 Three Simple Reasons You Know the
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 88 of 117

Defendant Is Guilty
1. The Defendant’s Own Words
2. Gary Franklin’s Testimony
3. Common Sense
Bonus: Crushing Debt
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 89 of 117

Defense Arguments
1. The Nike Did Bad Things Defense
2. The Three Questions Defense
3. The Text Message Defense
4. The Scott Wilson Came Up With It Defense
5. The Blame the Victim Defense
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 90 of 117

Defense Arguments
1. The Nike Did Bad Things Defense
2. The Three Questions Defense
3. The Text Message Defense
4. The Scott Wilson Came Up With It Defense
5. The Blame the Victim Defense
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 91 of 117

Defense Arguments
1. The Nike Did Bad Things Defense
2. The Three Questions Defense
3. The Text Message Defense
4. The Scott Wilson Came Up With It Defense
5. The Blame the Victim Defense
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The Three Questions Defense

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 93 of 117

Defense Arguments
1. The Nike Did Bad Things Defense
2. The Three Questions Defense
3. The Text Message Defense
4. The Scott Wilson Came Up With It Defense
5. The Blame the Victim Defense
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 94 of 117

The Text Message Defense

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 95 of 117

Defense Arguments
1. The Nike Did Bad Things Defense
2. The Three Questions Defense
3. The Text Message Defense
4. The Scott Wilson Came Up With It Defense
5. The Blame the Victim Defense
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 96 of 117

The Scott Wilson Defense

Benjamin Homes, Tr. 1426

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 97 of 117

The Scott Wilson Defense

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 98 of 117
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 99 of 117

The Scott Wilson Defense

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 100 of 117

Defense Arguments
1. The Nike Did Bad Things Defense
2. The Three Questions Defense
3. The Text Message Defense
4. The Scott Wilson Came Up With It Defense
5. The Blame the Victim Defense
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 101 of 117

The Blame the Victim Defense

Robert Leinwand,
Tr. 1239-1240
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 102 of 117

The Blame the Victim Defense

Gary Franklin, Tr. 1773

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 103 of 117

Avenatti Committed Honest Services Fraud

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 104 of 117

Avenatti Committed Honest Services Fraud

1. The Defendant Owed Gary Franklin Duties of Loyalty,
Confidentiality, and Reasonable Communication
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 105 of 117

Avenatti Committed Honest Services Fraud

1. The Defendant Owed Gary Franklin Duties of Loyalty,
Confidentiality, and Reasonable Communication
2. The Defendant Solicited Quid Pro Quo Payments
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 106 of 117

Avenatti Solicited Quid Pro Quo Payments

“Avenatti: I’m not fucking around with this, and I’m not continuing to
play games. And I don’t-you know, this isn’t complicated. You guys
know enough now to know you’ve got a serious problem. And it’s worth
more in exposure to me to just blow the lid on this thing. A few million
dollars doesn’t move the needle for me. I’m just being really frank with
you. So if that’s what, if that’s what is being contemplated, then let’s
just say it was good to meet you, and we’re done. And I’ll proceed with
my press conference tomorrow and I’ll hang up with you now and I’ll
call the New York Times, who are awaiting my call. I-I’m not fucking
around with this thing anymore.”
(GX 1T: 4-5)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 107 of 117

Avenatti Solicited Quid Pro Quo Payments

“Avenatti: I’m not fucking around with this, and I’m not continuing to
play games. And I don’t-you know, this isn’t complicated. You guys
know enough now to know you’ve got a serious problem. And it’s worth
more in exposure to me to just blow the lid on this thing. A few million
dollars doesn’t move the needle for me. I’m just being really frank with
you. So if that’s what, if that’s what is being contemplated, then let’s
just say it was good to meet you, and we’re done. And I’ll proceed with
my press conference tomorrow and I’ll hang up with you now and I’ll
call the New York Times, who are awaiting my call. I-I’m not fucking
around with this thing anymore.”
(GX 1T: 4-5)
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 108 of 117

The Charges
Count One: Transmission of Interstate Communications
with Intent to Extort
Count Two: Attempted Extortion
Count Three: Honest Services Wire Fraud
Venue
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 109 of 117

The Charges
Count One: Transmission of Interstate Communications
with Intent to Extort
Count Two: Attempted Extortion
Count Three: Honest Services Wire Fraud
Venue
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 110 of 117

Count One: Interstate Communication

 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 111 of 117

Count One: Interstate Communication

Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 112 of 117
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 113 of 117

The Charges
Count One: Transmission of Interstate Communications
with Intent to Extort
Count Two: Attempted Extortion
Count Three: Honest Services Wire Fraud
Venue
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 114 of 117

The Charges
Count One: Transmission of Interstate Communications
with Intent to Extort
Count Two: Attempted Extortion
Count Three: Honest Services Wire Fraud
Venue
 Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 115 of 117

The Charges
Count One: Transmission of Interstate Communications
with Intent to Extort
Count Two: Attempted Extortion
Count Three: Honest Services Wire Fraud
Venue
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 116 of 117
Case 1:19-cr-00373-PGG Document 267-1 Filed 02/19/20 Page 117 of 117

United States of America

v.

Michael Avenatti

S1 19 Cr. 373 (PGG)