His lawyers suggested that he petition for parole.

When asked this month in Germany about the possibility that our client’s situation might be alleviated, the Russian President Dmitry Medvedev stressed the priority of judicial procedures over measures that form part of his exclusive competence as head of state.

On Mr Khodorkovsky’s instructions we have thoroughly analysed various courses of action aimed at his rapid release. It is our view that an effective way of defending his lawful rights and interests might be to petition the courts for him to be released on parole from the sentence imposed by the Meshchansky district court in Moscow. Further hopes for a positive outcome are instilled in us by President Medvedev’s repeated declarations that legality must be strengthened in Russia, by expanding the role of the courts and ensuring the genuine independence of the judiciary. Accordingly, we have prepared and submitted for Mr Khodorkovsky’s consideration the corresponding recommendations and a draft text of the petition.

Naturally, the submission of a petition of this kind would not halt the other activities of the defence team. These aim to repudiate, in accordance with established legal procedures, all false and groundless accusations against Mr Khodorkovsky in the first and second case, and to secure his complete rehabilitation.

The defence team of M.B. Khodorkovsky