>>5918150
KMT:MKP/TH/MJL 271 Cadman Plaza East F. #2017R01840 Brooklyn, New York 11201
March 1, 2019
By Hand and ECF
The Honorable Nicholas G. Garaufis United States District Judge United States District Court 225 Cadman Plaza East Brooklyn, New York 11201
Re: United States v. Keith Raniere, et al. Criminal Docket No. 18-204 (S-1) (NGG) (VMS)
Dear Judge Garaufis:
The government respectfully submits this letter to notify the Court regarding a potential conflict involving counsel for defendants Keith Raniere and Clare Bronfman. This potential conflict arises from the fact that an attorney for Raniere and an attorney for Bronfman are closely related to each other.
The government advises the Court of this information pursuant to its obligation under Second Circuit law so the Court may conduct the appropriate inquiry pursuant to United States v. Curcio, 680 F.2d 881, 888-90 (2d Cir. 1982). See, e.g., United States v. Stantini, 85 F.3d 9, 13 (2d Cir. 1996); United States v. Malpiedi, 62 F.3d 465, 467 (2d Cir. 1995).
The government notes the Court’s familiarity with the charges in this case and the prior Curcio hearing held for Raniere and does not reiterate that background here. Additionally, the government incorporates by reference the law set forth in its Curcio motion, dated November 30, 2019 (Dkt. No. 210).
I. Defendants’ Representation Before the Court
On April 13, 2018, Marc A. Agnifilo, Esq., Teny Rose Geragos, Esq., and Jacob Kaplan, Esq., attorneys with the law firm Brafman & Associates, P.C., filed notices of appearance on behalf of the defendant Keith Raniere. On April 10, 2018 and April 23, 2018, respectively, Paul DerOhanessian, Esq. and Danielle Renee Smith, Esq., attorneys from the law firm DerOhannesian & DerOhannesian, also filed notices of appearance on behalf of defendant Raniere.
Case 1:18-cr-00204-NGG-VMS Document 390 Filed 03/01/19 Page 1 of 4 PageID #: 3811
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On July 24, 2018, Susan R. Necheles, Esq., Kathleen Elizabeth Cassidy, Esq., and Gedalia Moshe Stern, Esq., attorneys with the law firm Hafetz & Neches LLP, filed notices of appearance on behalf of the defendant Clare Bronfman. On September 27, 2018, Alexandra A.E. Shapiro, Esq. and Fabien Manohar Thayamballi, Esq., attorneys with the law firm Shapiro Arato LLP, also filed notices of appearance on behalf of defendant Bronfman. On February 27, 2018, Mark J. Geragos, Esq. also filed a notice of appearance on behalf of Bronfman.
On March 1, 2019, Cassidy informed the that Mark Geragos was replacing Necheles as lead trial counsel for Bronfman. The government is unclear as to what, if any, role the attorneys from Hafetz & Necheles LLP will have on this case going forward.
Sauce
https://frankreport.com/wp-content/uploads/2019/03/Document-390-Letter-From-Prosecution-Regarding-Potential-Conflict-Of-Interest-Regarding-Mark-J.-Geragos-03.01.2019.pdf
(Pic unrelated)