UNITED STATES OF AMERICA V. REZA ZARRAB

The Court held a conference on April 4, 2017, after receiving a letter from the

Government, dated March 27, 2017, requesting a (second) Curcio hearing in this case. According

to the Government, a Curcio hearing is needed to examine whether there are conflicts of interest

related to the addition to the defense team of former New York City Mayor Rudolph Giuliani

(also former United States Attorney for the Southern District of New York), and former United

States Attorney General Michael B. Mukasey (also former Chief Judge of the District Court for

the Southern District of New York). The conflicts which the Government wishes to have the

Court explore relate to the work of their law firms, J.e., the alleged legal representations by the

law firms Greenberg Traurig (in the case of Mr. Giuliani) and Debevoise & Plimpton (in the case

of Mr. Mukasey) of certain banks whose interests are or may be adverse to the interests of

Defendant Reza Zarrab. The banks in question are Deutsche Bank, Bank of America, JP Morgan

Chase, Citibank, HSBC, Standard Chartered, UBS, and Wells Fargo.

The Government also seeks to have explored at the Curcio hearing, Greenberg Traurig s

status of "agent" to the Republic of Turkey.

' As discussed below (p. 9 infra), the defense agrees (consents) that a Curcio hearing is warranted. (See Defendant's Letter to Court, filed Mar. 31, 2017, at 2 ("[C]ounsel is prepared to

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The defense letter response stated:

The parties shall meet and confer in good faith to develop a joint list of Curcio

questions to be posed by the Court at the Curcio hearing. The list shall be submitted to the Court on or before April 18, 2017 (noon). If the parties do not agree on the questions to be posed, they may submit questions separately.