JM
Jordan Morrison
Nov 11, 2025
Attorney Lewinski:
I am in receipt of your correspondence dated June 27, 2025, regarding the above-referenced property. After reviewing your letter, I am compelled to respond due to the numerous false statements, factual inaccuracies, and unsupported allegations it contains.
Let me be clear at the outset: every claim asserted in your letter is demonstrably false, and I possess documentary evidence, written communications, photographs, and third-party records that directly contradict each assertion made on behalf of your clients.
Your letter reflects a complete failure to investigate, a disregard for facts that were previously provided to you, and a reliance on unverified statements that any reasonable attorney should have examined before issuing accusations of “illegal,” “unethical,” or retaliatory conduct. Your threats of litigation and your clients’ demand for $20,000, free occupancy, and waived rent are entirely baseless, unsupported by law, and grossly disproportionate to the fabricated allegations contained in your letter.
Given the gravity of the false claims presented, I am addressing several key points below:
1. Misrepresentations and False Statements of Fact
Your letter asserts, as fact, multiple events that never occurred. The statements in paragraphs 1–7 of your letter are wholly inaccurate. You were provided with contradictory evidence, including messages, timestamps, photographs, and records from the relevant agencies and myself, yet you elected to ignore these materials and repeat your clients’ falsehoods as though they were verified facts.
Your presentation of these falsehoods as established fact raises serious concerns under New York Rules of Professional Conduct 4.1 and 8.4(c), which prohibit knowingly making false statements and acting with deceit or misrepresentation.
2. Failure to Investigate & Reliance on Fabricated Allegations
You state legal conclusions that have no basis in law, no factual support, and no connection to the events as they actually occurred. Your characterization of ordinary events as “illegal” or “retaliatory” is not only inaccurate but reckless.
Your use of your clients’ unverified statements, despite having been provided evidence disproving them, appears to be a violation of Rule 3.1 (Non-Meritorious Claims) and Rule 1.1 (Competence).
3. Improper and Exaggerated Monetary Demand
Your clients’ request that I:
waive all rent owed, allow rent-free occupancy through October 31, 2025, and
pay $20,000 in addition, is not grounded in any legal right or factual circumstance. Given that the underlying allegations are false, the monetary demand reads as coercive and retaliatory, rather than a legitimate settlement offer.
To the extent this demand attempts to extract money based on factual misrepresentations, it approaches conduct prohibited under Rule 8.4 (Misconduct) and may raise issues under New York Penal Law §155.05 (Extortion) if pursued further.
4. Retraction and Clarification Required
Given the clear factual inaccuracies and unsupported accusations in your letter, I formally demand that you:
1. Issue a written retraction of all false statements.
2. Confirm in writing that you have reviewed the evidence previously provided.
3. Cease making false claims on behalf of your clients.
4. Refrain from any further threats of litigation based on knowingly inaccurate facts.
If you intend to continue this matter, you will be expected to provide documentation supporting every factual assertion made in your June 27, 2025 letter. Unsupported conclusions, speculation, and accusations will not be entertained.
5. Notice of Reservation of Rights
Please be advised that I reserve all rights and remedies available under New York law, including but not limited to:
Filing a grievance with the Attorney Grievance Committee, seeking sanctions for frivolous or bad-faith litigation threats, and pursuing any other relief warranted by your conduct and your clients’ knowingly false statements.
Nothing in this response should be construed as a waiver of any rights, claims, or defenses.