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
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`UNITED STATES DISTRICT COURT
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`SOUTHERN DISTRICT OF NEW YORK
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`UNITED STATES OF AMERICA
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`V.
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`Plaintiff,
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`PREVEZON HOLDINGS LTD., et al.
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`Case No. l:13—cV—06326 (TPG)
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`ECF CASE
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`Defendants,
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`DECLARATION OF NATALYA
`VESELNITSKAYA
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`ALL RIGHT, TITLE AND INTEREST IN THE
`REAL PROPERTY AND APPURTENANCES
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`KNOW AS THE 20 PINE STREET
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`CONDOMINIUM, 20 PINE STREET, NEW
`YORK, NEW YORK 10005, UNIT 1816 (“20
`PINE STREET, UNIT 1816”), et al.,
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`Defendants in Rem.
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`Natalya Veselnitskaya hereby declares as follows:
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`1.
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`I am an attorney admitted to practice in the Russian Federation. I have been
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`practicing law since 1998.
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`I am the founder and managing partner of the law offices of
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`Karnerton Consulting. I have been retained by Denis Katsyv and the Defendants in this action to
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`assist their attorneys in the United States, Baker & Hostetler LLP (“Baker Hostetler”) and Baker
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`Botts LLP (“Baker Botts”), in preparing their defense.
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`2.
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`In 1998, I graduated with distinction from the Moscow State Legal Academy with
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`a degree in jurisprudence. Upon graduation from the Academy, I started working at the
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`Prosecutor’s Office where I worked for three years, overseeing the legality of statues that were
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`adopted by legislators of Moscow Oblast. After that I moved into private business.
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`In 2003, I
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`formed a private legal firm, Kamerton Consulting, which later grew to 30 employees, including
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`five attorneys. My firm and I specialize in corporate and property disputes in courts. Among
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`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
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`airport Sheremetyevo, and other clients from real estate and banking sectors. I have argued and
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`won more than 300 cases on corporate, tax, and property law.
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`3.
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`I was informed by Defendants’ U.S. attorneys that the United States Attorney’s
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`Office (“USAO”) for the Southern District of New York improperly and illegally issued a
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`request under a criminal Mutual Legal Assistance Treaty (“MLAT”) between the United States
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`and the Russian Federation seeking documents in connection with this action, which is purely
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`civil in nature and not criminal. Baker Hostetler made repeated requests that the USAO disclose
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`to Defendants a copy of the criminal MLAT request and the Russian Federation’s response. The
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`USAO refused to turn over its improper MLAT request or the Russian Federation’s response.
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`4.
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`When the U.S. Government withheld the diplomatic exchange from Defendants, I
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`filed a request with the Prosecutors Office of the Russian Federation which was denied. The
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`Russian prosecutors attempted to withhold the correspondence on the grounds that the United
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`States had represented that this case was criminal (a false representation) and asked them to keep
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`their information secret. I have considered that action illegal, and challenged this action in court.
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`The Russian court determined that the case is civil and ordered the prosecutor to release the
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`correspondence, which confirms that the USAO misrepresented to the Russian Federation that
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`this civil action is criminal. See Exhibit 1 hereto (June 22, 2015, Russian Court Decision); see
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`Exhibit 2 hereto (June 22, 2015, Hearing Transcript); Exhibit 3 hereto (Russian Prosecutor’s
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`Compliance With Court Order).
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`5.
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`The Russian response to the United States request stated that the Russian crime
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`alleged in the United States’ complaint did not occur and that the story in the complaint was an
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`attempt by Browder to “discredit the law enforcement and judicial authorities of Russia
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`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
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`investigating his criminal activities.” See Exhibit 4 hereto (March 21, 2014, U.S. Govemment’s
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`MLAT Request To The Russian Federation); see Exhibit 5 hereto (August 12, 2014, Response of
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`The Russian Federation To MLAT Request); see Exhibit 6 hereto (The Government’s Production
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`of The Response of The Russian Federation To MLAT Request). Even after receiving this
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`diplomatic note, the Government continued to allege the same discredited facts. Only when
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`Defendants conducted the investigation that the Government should have has the truth come out.
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`6.
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`In the beginning of October 2013, Mr. Mark Feigin, and attorney, got in touch
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`with me. He introduced himself as an attorney of Mr. Browder. At his initiative, Faigin and I
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`had several meetings and in the course of these meetings Faigin asked me, in the interests of
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`Browder and Firestone, to help them obtain compromising materials to incriminate former
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`investigator of the Ministry of Interior of the Russian Federation, Mr. Pavel Karpov. Mr. Karpov
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`constituted a reputation threat to Mr. Browder and Firestone, due to the defamation case filed
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`against them in the High Court of London. Mr. Faign’s proposal was substantiated by his
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`assurance that if I help his clients win the case in London, Mr. Browder would close the case in
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`the United States.
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`I refused to cooperate in the corrupt action, however, I told Mr. Feigin to
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`persuade his clients to give truthful testimony in the U.S. court.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Dated: November 17, 2015
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`New York, New York