From a 36-page letter filed yesterday in Brooklyn, N.Y., by John Lauro, attorney for disgraced NBA referee Tim Donaghy:

Tim attended Cardinal O'Hara High School in Pennsylvania with Thomas Martino and James Battista, who have also been indicted in this case as a result of Tim's cooperation. Tim and Martino socialized occasionally while Tim attended Villanova and later when he became a referee. Tim was never close with Battista, who had become a professional gambler and bookmaker, with professed ties to organized crime.

In 1994, Battista telephoned Tim during his first year as an NBA referee. Battista asked Tim whether he was going to be "up and up," which Tim understood to mean whether he would use his position to help Battista gamble. Tim told Battista to never call again. When Tim spoke next to Martino, he told Martino that if Battista ever called again, he would report Battista to the authorities.

However, years later, Battista learned (probably through [Peter] Ruggieri) that Tim and [Jack] Concannon had been betting on sports events. We believe Battista (once again through Ruggieri) may have been secretly betting on the selections Tim made with Concannon. At one point, Tim and Concannon stopped betting on sports, and Battista apparently became angry. Battista then used Martino to contact Tim. On December 12, 2006, Tim was in Philadelphia to officiate a game between Boston and Philadelphia. Tim planned to meet Martino for dinner in Philadelphia. When Martino picked Tim up at the airport, Battista was in the car.

Martino and Battista drove Tim back to the hotel. During the car ride, Battista said that he knew Tim bet on NBA games with Concannon. Battista wanted Tim to help him select bets. Battista told Tim he would report Tim's gambling activities to the NBA if Tim didn't provide selections. Later at the hotel restaurant, Battista told Tim to call Martino in order to relay selections. In return, Battista agreed to pay Tim $2,000 for each correct selection. If Tim's selection did not win, he would receive nothing. Battista also threatened Tim's family, stating that Tim would not want people from New York (Mafia figures) visiting his wife and kids.

Battista, Martino and Tim participated in these actions for approximately four months, and bet on 30 games. We believe Battista profited by possibly more than hundreds of thousands of dollars in winnings. Tim obtained a net gain of about $25,000 from Battista for his participation in those activities.