The comments were made in Avenatti's presence in Manhattan federal court, as part of a case currently sorting out which materials seized from Cohen in FBI raids last month are protected by attorney-client privilege.
The judge in that case, Kimba Wood, adjourned the Wednesday hearing after setting a June 15 deadline for Cohen's team of lawyers to complete their review of the seized materials. If the lawyers miss that deadline, Wood said a separate group of government lawyers, known as a "taint team," will take over to review the remainder.
Lawyers for Cohen said that about 3.7 million files in total needed to be evaluated for privilege status, and that they had thus far reviewed about 1.3 million of them.
Avenatti, a California-based lawyer, is attempting to represent Daniels in the New York case involving Cohen. Lawyers for Cohen have argued that Wood should not permit Avenatti to intervene in this instance. Ryan, in opposing Avenatti's request for admission, noted the lawyer has made 170 media appearances in recent months.
Cohen appeared in court Wednesday, though he said nothing during the proceeding aside from inaudible whispers to his lawyers.
Earlier in May, Avenatti published a report alleging payments made to Cohen's company, Essential Consultants, from large corporations including telecommunications giant AT&T and drug company Novartis, among others. Those companies both said in subsequent statements that they paid Cohen's company.
Lawyers for Cohen had questioned in a previous court filing how Avenatti could have obtained the information, which appeared to be drawn from bank records known as "suspicious activity reports."
"Mr. Avenatti has published some information that appears to be from Mr. Cohen's actual bank records, and Mr. Cohen has no reason to believe that Mr. Avenatti is in lawful possession of these records," the filing said.
Ryan, in court on Wednesday, called Avenatti's conduct reckless, intentional and malicious.
"I've never seen an attorney conduct himself the way Mr. Avenatti conducted himself," Ryan said. "What Mr. Avenatti did in releasing those records was entirely improper," he added.