EFTA01079171.pdf

EXHIBIT B EFTA01079171  Case 1:16-cv-00214 Document 6-2 Filed 01/12/16 Page 2 of 3 Patterson Belknap Webb & Tyler LIP 1133 Avenue of the Americas New York. NY October 19, 2015 Erik Haas By Hand Mr. Larry Gagosian Gagosian Gallery, Inc. Re: Notice of Priority Claim: Pablo Picasso Sculpture, Bust of a Woman (Marie Therese) Dear Mr. Gagosian: We are counsel to Pelham Europe, Ltd. ("Pelham"), an art advisory firm based in London, United Kingdom. We write in reference to the Pablo Picasso sculpture, Bust of a Woman (Marie-Therese), or, Buste de femme (Marie-Therese), Boisgeloup, 1931, original plaster, (the "Sculpture") currently on display at the Museum of Modem Art ("MoMA"). The MoMA exhibition materials state that the Sculpture is on loan "Courtesy Gagosian Gallery." Pelham has a claim to the transfer and delivery of the Sculpture by virtue of a sale agreement dated November 13, 2014 entered into between Pelham and Connery Pissaro Seydoux SA ("CPS") (the "Sale Agreement"). CPS executed the Sale Agreement as the agent of the owner of the Sculpture, Maya Widmaier-Picasso. Pelham intends to transfer the Sculpture to Sheikh Jassim bin Abdul Aziz Al-Thani of Qatar with whose knowledge and support this letter is written. In May 2015, following a belated attempt to repudiate the contract by Widmaier- Picasso, Pelham commenced litigation in Switzerland to enforce its claim to the Sculpture (the "Swiss Litigation"). On May 13, 2015, the High Court ofParis entered a writ of seizure (the "Writ of Seizure") in aid of the Swiss Litigation prohibiting, under penalty of criminal sanctions, the alienation or transfer of the Sculpture from France while the Swiss proceedings are pending. An English translation of the Writ of Seizure is attached hereto. In apparent violation of the Writ of Seizure, the Sculpture has been moved from France to New York, where it currently is on display at MoMA. Pelham has commenced contempt proceedings in the High Court of Paris to address that illicit transfer (the "Contempt Proceedings"). By this letter we are providing you with formal notice of the Swiss Litigation, the Writ of Seizure, and the Contempt Proceedings, to the extent you were not previously aware thereof. We demand that you not transfer, sell or otherwise deal with the Sculpture pending the resolution of the Swiss Litigation or in contravention of the Writ of Seizure. We further demand EFTA01079172  Case 1:16-cv-00214 Document 6-2 Filed 01/12/16 Page 3 of 3 Mr. Larry Gagosian October 19, 2015 Page 2 that you disclose to any party inquiring regarding the ownership, title or purchase of the Sculpture that Pelham has a claim to transfer and delivery of the Sculpture, and the existence of the Swiss Litigation, Writ of Seizure, and Contempt Proceedings. Pelham reserves all its rights, remedies and recourse in the event you fail to comply with this demand. Please contact me if you have any questions. Very truly yours, 7 Erik Haas Enclosure Cc: Patty Lipshutz, Esq. General Counsel Museum of Modem Art EFTA01079173