Case 1:05-md-01720-MKB-JO Document 6406 Filed 02/06/15 Page 1 of 2 PageID #: 76728

WILLKIE FARR & GALLAGHERLLP

STEPHEN

W. GREINER

2127288224
sgreiner@willkie.com
787 Seventh Avenue
New York, NY 100 19-6099
Tel:

212 728 8000

Fac: 2127288111

February 6, 2015

VIA ECF
Honorable Margo K. Brodie
United States District Judge
United States District Court
Eastern District of New York
225 Cadman Plaza East
Brooklyn, NY 11201
Re: MDL 1720 Class Action Litigation (05-MD-1720) (MJB) (JO)
Dear Judge Brodie,
We write with respect to the above-referenced matter to request that Your Honor convene a
conference as described below.
On December 22, 2014, Keila Ravelo, a former partner at this Firm, was arrested on a criminal
complaint filed in the United States District Court for the District of New Jersey, charging her
with, inter alia, participation in a wire fraud scheme whose object is alleged to have been to
defraud two law firms and a client of $5 million. The complaint currently remains pending.
MasterCard International Incorporated is the alleged client, and our Firm, Willkie Farr &
Gallagher LLP (Willkie Farr), is one of the alleged law firms, referenced in the complaint.
The law firm of Hunton & Williams, LLP (Hunto7 & Williams) is the other alleged law firm.
Ms. Ravelo resigned from Willkie Farr on November 14, 2014, after the Firm became aware that
she was under investigation by the United States Attorneys Office for the District of New Jersey
(the USAO). Prior to her resignation, Ms. Ravelo had represented MasterCard in this
litigation, originally as a partner at Hunton & Williams, and later as a partner at Willkie Farr.
After the contact with the USAO, our Firm commenced a review. The review has identified
certain documents which we believe raise questions that appropriately should be discussed with
the Court concerning communications in which Ms. Ravelo was involved relating to this
litigation and other matters.

NEW YORK

WASHINGTON

PARIS

LONDON

MILAN

ROME

FRANKFURT

in alliance with Dickson Minto W.S., London and Edinburgh

BRUSSELS

Case 1:05-md-01720-MKB-JO Document 6406 Filed 02/06/15 Page 2 of 2 PageID #: 76729

Hon. Margo K. Brodie
February 6, 2015
Page 2

We respectfully request that Your Honor convene a conference at your earliest convenience at
which we will seek the Courts guidance as to how to proceed. The defendants agree that our
request for a prompt conference is appropriate.
It may be necessary to request that portions of the conference be conducted in camera and we
reserve the right to request to be heard in camera.
Respectfully submitted,

stephen Greiner
Willkie Farr & Gallagher LLP
787 Seventh Avenue
New York, NY 10019

ccs.

Hon. James Orenstein, USMJ (Via ECF)

All Counsel (Via ECF)