throbber
Case 1:13-cv-06326-TPG Document 420 Filed 11/18/15 Page 1 of 3
`Case 1:13—cv—O6326—TPG Document 420 Filed 11/18/15 Page 1 of 3
`
`UNITED STATES DISTRICT COURT
`
`SOUTHERN DISTRICT OF NEW YORK
`
`UNITED STATES OF AMERICA
`
`V.
`
`Plaintiff,
`
`PREVEZON HOLDINGS LTD., et al.
`
`Case No. l:13—cV—06326 (TPG)
`
`ECF CASE
`
`Defendants,
`
`DECLARATION OF NATALYA
`VESELNITSKAYA
`
`ALL RIGHT, TITLE AND INTEREST IN THE
`REAL PROPERTY AND APPURTENANCES
`
`KNOW AS THE 20 PINE STREET
`
`CONDOMINIUM, 20 PINE STREET, NEW
`YORK, NEW YORK 10005, UNIT 1816 (“20
`PINE STREET, UNIT 1816”), et al.,
`
`Defendants in Rem.
`
`Natalya Veselnitskaya hereby declares as follows:
`
`1.
`
`I am an attorney admitted to practice in the Russian Federation. I have been
`
`practicing law since 1998.
`
`I am the founder and managing partner of the law offices of
`
`Karnerton Consulting. I have been retained by Denis Katsyv and the Defendants in this action to
`
`assist their attorneys in the United States, Baker & Hostetler LLP (“Baker Hostetler”) and Baker
`
`Botts LLP (“Baker Botts”), in preparing their defense.
`
`2.
`
`In 1998, I graduated with distinction from the Moscow State Legal Academy with
`
`a degree in jurisprudence. Upon graduation from the Academy, I started working at the
`
`Prosecutor’s Office where I worked for three years, overseeing the legality of statues that were
`
`adopted by legislators of Moscow Oblast. After that I moved into private business.
`
`In 2003, I
`
`formed a private legal firm, Kamerton Consulting, which later grew to 30 employees, including
`
`five attorneys. My firm and I specialize in corporate and property disputes in courts. Among
`
`

`
`Case 1:13-cv-06326-TPG Document 420 Filed 11/18/15 Page 2 of 3
`Case 1:13—cv—O6326—TPG Document 420 Filed 11/18/15 Page 2 of 3
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`my clients are large State owned and private corporations, such as main Moscow international
`
`airport Sheremetyevo, and other clients from real estate and banking sectors. I have argued and
`
`won more than 300 cases on corporate, tax, and property law.
`
`3.
`
`I was informed by Defendants’ U.S. attorneys that the United States Attorney’s
`
`Office (“USAO”) for the Southern District of New York improperly and illegally issued a
`
`request under a criminal Mutual Legal Assistance Treaty (“MLAT”) between the United States
`
`and the Russian Federation seeking documents in connection with this action, which is purely
`
`civil in nature and not criminal. Baker Hostetler made repeated requests that the USAO disclose
`
`to Defendants a copy of the criminal MLAT request and the Russian Federation’s response. The
`
`USAO refused to turn over its improper MLAT request or the Russian Federation’s response.
`
`4.
`
`When the U.S. Government withheld the diplomatic exchange from Defendants, I
`
`filed a request with the Prosecutors Office of the Russian Federation which was denied. The
`
`Russian prosecutors attempted to withhold the correspondence on the grounds that the United
`
`States had represented that this case was criminal (a false representation) and asked them to keep
`
`their information secret. I have considered that action illegal, and challenged this action in court.
`
`The Russian court determined that the case is civil and ordered the prosecutor to release the
`
`correspondence, which confirms that the USAO misrepresented to the Russian Federation that
`
`this civil action is criminal. See Exhibit 1 hereto (June 22, 2015, Russian Court Decision); see
`
`Exhibit 2 hereto (June 22, 2015, Hearing Transcript); Exhibit 3 hereto (Russian Prosecutor’s
`
`Compliance With Court Order).
`
`5.
`
`The Russian response to the United States request stated that the Russian crime
`
`alleged in the United States’ complaint did not occur and that the story in the complaint was an
`
`attempt by Browder to “discredit the law enforcement and judicial authorities of Russia
`
`

`
`Case 1:13-cv-06326-TPG Document 420 Filed 11/18/15 Page 3 of 3
`Case 1:13—cv—O6326—TPG Document 420 Filed 11/18/15 Page 3 of 3
`
`investigating his criminal activities.” See Exhibit 4 hereto (March 21, 2014, U.S. Govemment’s
`
`MLAT Request To The Russian Federation); see Exhibit 5 hereto (August 12, 2014, Response of
`
`The Russian Federation To MLAT Request); see Exhibit 6 hereto (The Government’s Production
`
`of The Response of The Russian Federation To MLAT Request). Even after receiving this
`
`diplomatic note, the Government continued to allege the same discredited facts. Only when
`
`Defendants conducted the investigation that the Government should have has the truth come out.
`
`6.
`
`In the beginning of October 2013, Mr. Mark Feigin, and attorney, got in touch
`
`with me. He introduced himself as an attorney of Mr. Browder. At his initiative, Faigin and I
`
`had several meetings and in the course of these meetings Faigin asked me, in the interests of
`
`Browder and Firestone, to help them obtain compromising materials to incriminate former
`
`investigator of the Ministry of Interior of the Russian Federation, Mr. Pavel Karpov. Mr. Karpov
`
`constituted a reputation threat to Mr. Browder and Firestone, due to the defamation case filed
`
`against them in the High Court of London. Mr. Faign’s proposal was substantiated by his
`
`assurance that if I help his clients win the case in London, Mr. Browder would close the case in
`
`the United States.
`
`I refused to cooperate in the corrupt action, however, I told Mr. Feigin to
`
`persuade his clients to give truthful testimony in the U.S. court.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated: November 17, 2015
`
`New York, New York

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