Legal Doc: Reply Affidavit
Filed May 9, 2002
UNITED STATES OF AMERICA
JONATHAN J. POLLARD,
Criminal No. 86-0207 (NHJ)
STATE OF NEW YORK
COUNTY OF NEW YORK
REPLY AFFIDAVIT IN SUPPORT OF MOTION FOR MODIFICATION
JACQUES SEMMELMAN, being duly sworn, deposes and says:
- I am a member of Curtis, Mallet-Prevost, Colt & Mosle LLP. My partner Eliot Lauer and I represent Jonathan J. Pollard. I am admitted in this case pro hac vice.
- I submit this reply affidavit in further support of the Defendant's Motion for Modification of the Court's January 12, 2001 Memorandum Order Based Upon the Government's August 3, 2001 Letter (the "Motion for Modification").
- Annexed hereto as Exhibit F is a copy of a letter dated September 10, 2001 from Assistant Attorney General Daniel J. Bryant to Congressman Anthony D. Weiner (the "Bryant Letter").
- The Bryant Letter was the result of a series of letters between Congressman Weiner and the Department of Justice. Prior correspondence has been attached as Exhibits A through E to my affidavit sworn to August 15, 2001, submitted in support of the Motion for Modification.
- In response to the Bryant Letter, Congressman Weiner wrote to Attorney General John Ashcroft and to Secretary of Defense Donald H. Rumsfeld. Copies of those letters are attached as Exhibits G and H, respectively.
- Attached hereto are copies of the following news articles, retrieved from Nexis:
- Exhibit I is a copy of a November 11, 1993 article from the Jerusalem Post.
- Exhibit J is a copy of a November 13, 1993 article from the New York Times.
- Exhibit K is a copy of a November 18, 1993 transcript of a weekly press conference given by Attorney General Janet Reno.
Sworn to before me this
8th day of May, 2002.
CERTIFICATE OF SERVICE
BAIRBRE KENNEDY certifies as follows under penalty of perjury:
On May 9, 2002, I caused to be served by hand delivery a true copy of the foregoing Reply Affidavit of Jacques Semmelman in Support of Motion for Modification, with exhibits, on:
Steven Pelak, Esq.
Office of the United States Attorney
555 Fourth Street, N.W.
Washington, D.C. 20001
Exhibit D: Attorney's Letter to Macisso and Gunning - May 15, 2001
Exhibit E: Congressman Weiner's Letter - June 11, 2001
- Sept. 20, 2001
- - Jan. 7, 2002
- Jan. 7, 2002
Exhibit I: Clinton Asks Review of Pollard Case - Jerusalem Post, Nov. 11, 1993
- New York Times, Nov. 13, 1993
Exhibit K: November 18, 1993 Press Conference of Attorney General Reno