Richard Horowitz & Associates

Attorneys at Law 450 Seventh Avenue, 9th Floor New York, NY 10123 rhorowitz@rhesq.com
Telephone: (212) 829-8196 Facsimile: (212) 813-3214 Admitted in New York and the District of Columbia www.rhesq.com www.InternationalSecurityResources.com

November 3, 2011 Kataryna Lyson, Esq. Assistant General Counsel Broadcasting Board of Governors 330 Independence Ave., S.W. Washington, D.C. 20237 Dear Ms. Lyson, I am in receipt of your letter to me dated October 28, 2011. The two points in your letter, that my clients were contractors and not employees, and that Mr. Fakhravar has no relationship with BBG and you are therefore unable to comment, are not responsive to the concerns in my prior two letters. I trust you recognize it is of no consequence if the VOA terminated the employment of an employee or did not renew the contract of a contractor if the VOA did so for improper reasons. It strains the imagination that Mr. Batebi completed his contract-for assignment as you wrote at 10:47 P.M. on Saturday, October 8, the time and date when he received an e-mail notice from VOAs Persian News Network, effective October 9. Your assertion that you cannot comment on Mr. Fakhravar because he has no relationship with the BBG is unresponsive because I did not ask you to comment on Mr. Fakhravar but rather brought to your attention facts that relevant to legal matter at hand, for which the BBG is responsible. As the court said in Melodi Navab-Safavi, v. Glassman, et. al., 637 F.3d 311, (App. D.C. 2011): The BBG is a federal agency charged with overseeing all U.S. government and government-sponsored, non-military, international broadcasting services. The BBG oversees Voice of America (VOA), which in turn oversees the Persian News Network (PNN), formerly called the Persian Service. And, if as you wrote, you are responding on behalf of the management of the Voice of America it is similarly of no consequence that Mr. Fakhravar has no relationship with the BBG. We seek an explanation as to why the VOA terminated my clients working relationship. As I have written, Mr. Fakhravar publicly stated that Mr. Batebi is under FBI investigation (see my October 19 letter, page 1), published that the VOA would terminate my clients before they were notified of this decision, and was seen having dinner with Mr. Asgard the night of Mr. Sehhatis last day with the VOA. He similarly published that the VOA would terminate the employment of Rudi Bakhtiar which has indeed recently happened (see my letter dated October 12, page 2). We are also aware that the VOA has hired several new people, including Mahtab Farid, an associate of Mr Fakhravar. See the attached page from Ms. Farids blog were she refers to herself as a VOA PNN correspondent on October 9, the date you claim Mr. Batebi completed his contract-for assignment. We have additional information which leads us to believe that Mr. Fakhravar played some role in this matter as well.

Kataryna Lyson, Esq. November 3, 2011 Page Two

I have provided the BBG with ample evidence to indicate that an inquiry into the VOAs decision and Mr. Fakhravars influence is warranted. I submit that it behooves you to provide an appropriate response. My clients are dismayed by the behavior of an agency of a government that granted them political asylum. Please note that we are aware that Mr. Fakhravar has brought this matter to the attention of several members of Congress.

Sincerely,

S/Richard Horowitz

cc: Patricia Hargrave, Esq. David Ensor Steven Redisch Ramin Asgard Ahmad Batebi Kourosh Sehhati