FILED TODAY (Nov. 15)
The Honorable Vernon S. Broderick
United States District Court
Southern District of New York
Dear Judge Broderick:
I write on behalf of our client Huntington Ingalls Incorporated (“Ingalls”). The purpose of this
letter is to inform the Court that Ingalls, a claimant to the funds in the Bolivarian Republic of
Venezuela’s Trust Account No. XXXX4314 (the “Account”) at The Bank of New York Mellon
(“BNYM”), does not intend to appear in this turnover proceeding filed by Crystallex
International Corporation (“Crystallex”), and indeed supports Crystallex’s request for an order to
BNYM to turn over to Crystallex the funds in the Account in partial satisfaction of Crystallex’s
$1.4 billion judgment against the Bolivarian Republic of Venezuela (the “Republic”).