AFFIDAVIT OF DAVID HEILBRONER REGARDING
HIS DISCUSSION WITH MYRON BELDOCK.
1)My name is David Heilbroner
2)I am a graduate of Harvard College and Northeastern Law School (1984)
3)I clerked for the Hon. Walter Jay Skinner in the United States District Court, District of Massachusetts from 1984-1985.
4)From 1985 to 1988, I served as Assistant District Attorney for the New York Supreme Court
5)I am the author of the book “Rough Justice” about my experiences in the Criminal Justice System.
6)During the past fifteen years, I have authored numerous articles and directed documentary films about the justice system.
7)I have known William Galison and considered him a friend for approximately 35 years.
8)In the course of this time, I have never heard of any incident in which Mr. Galison was violent, harassing, abusive to any person in any way.
9)In fact, I consider Mr. Galison to be a particularly decent, considerate and gentle person.
10)In my opinion, Mr. Galison is also an exceptional musician and the album he made with Ms. Peyroux is a superb musical work.
11)Coincidently, I have also known and worked occasionally with Myron Beldock overethe past ten years on a pro bono matter not connected with Mr. Galison in any manner whatsoever.
12)Mr. Galison first told me about the situation regarding his CD with Ms. Peyroux in or around January, 2004.
13)When I told Mr. Galison that I knew Mr. Beldock personally, Mr. Galison asked if I would speak to Mr. Beldock about having a meeting in the hopes of settling this matter amicably.
14)Mr. Galison asserted to me that he earnestly wanted to avoid having to take legal action against Mr. Beldock’s firm and especially against Ms. Peyroux, but would do so if his entreaties were not taken seriously.
15)Mr. Galison asked me if I could use my personal relationship with Mr. Beldock to alert Mr. Beldock to the fact the Mr. Greenberg had made false statements of fact regarding his ownership of and rights to the CD.
16)Mr. Galison also asked me to alert Mr. Beldock to the fact that Mr. Greenberg had made false statements regarding “physical abuse” of Ms Peyroux by Mr. Galison.
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17)Mr. Galison told me that Mr. Greenberg had ignored his repeated requests for a recantation of the false statements made in his letter of 12/17/03
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18)Mr. Galison told me that his lawyer had already sent copies to the three principals of Beldock, Levine and Hoffman, with a request for a recantation, and that none of the three had responded
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19)Mr. Galison informed me that he wanted Mr. Beldock’s firm to recant the false statements that had been made in his December 17th letter that had been forwarded to Rounder Records and Cynthia Herbst, so as to make litigation unnecessary.
20))Mr. Galison also told me that he wanted Mr. Beldock’s firm to withdraw his threats of copyright infringement charges against a distributor with whom Mr. Galison was working.
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21)To the best of my recollection, in or around February 2004 I called Myron Beldock to arrange a meeting regarding this matter
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22)Despite my statements to him about Mr. Galison's good character and desire to resolve his legal issues, Mr. Beldock categorically refused to discuss the situation regarding Mr. Galison with me.
23I am willing to appear in court to testify about these matters.
Signed,
David Heilbroner
Sworn before me this ____ day of _______
