Document / Category of Documents. The documents related to or prepared in connection to the 2017 Amendments to the Oro Negro Contracts, including any internal or external government correspondence, memoranda, official resolutions, reports, or analyses regarding Pemex’s decision to impose the 2017 Amendments prepared between January 1, 2016 and December 31, 2017. See SOC ¶ 91; Gil Decl. ¶ 61.
Document / Category of Documents. Records of communications between Tele Fácil (or any person or entity acting on its behalf) and Telmex (or any person or entity acting on its behalf) between 1 August 2013 and 11 July 2014 regarding: a) interconnection with Telmex; b) the Telmex Offer or any other proposal on the terms for interconnection; c) the PEA Declaration and/or the PEA Rate Decision;
Document / Category of Documents. The Documents containing the data and information relied upon by Xx. Xxxxxx in his reply report for the purpose of determining Future Telecom’s traffic –i.e. in addition to the Memorandum of Understanding executed by Tele Fácil and Future Telecom.
Document / Category of Documents. All documents relied upon by Analysys Xxxxx in preparation of their expert report, in their native versions. In cases where there is an Excel version of the document, please provide the Excel version. These documents include, but are not limited to, the following information listed in Exhibit B of Analysys Mason’s report: 1. Anexo Analysys Xxxxx-021. (Anexo B) Análisis de datos de tráfico Free Conferencing Corporation, a partir del anexo 23. 2. Anexo Analysys Xxxxx-022. (Anexo B) Análisis de datos de tráfico SIP Meeting Conference, a partir del anexo 29. 3. Anexo Analysys Xxxxx-023. (Anexo B) Análisis de datos de tráfico SIP Meeting Chat, a partir del anexo 30. 4. Anexo Analysys Xxxxx-024. (Xxxxxx 4.3) Análisis de datos de tráfico No Cost Conference, a partir del anexo 31. 5. Anexo Analysys Xxxxx-025. (Anexo B) Análisis de datos de tráfico AudioNow, a partir del anexo 32. 6. Anexo Analysys Xxxxx-029. (see Anexo 22 in Anexo B) 7. Anexo Analysys Xxxxx-030. (see Anexo 23 in Anexo B) 8. Anexo Analysys Xxxxx-031. (see Anexo 24 in Anexo B) 9. Anexo Analysys Xxxxx-032. (see Anexo 25 in Anexo B)
Document / Category of Documents. All international interconnection agreements relied upon by Analysys Xxxxx in preparation of their expert report, contained in Exhibit A (Anexo A- Acuerdos de tarifas de terminación internacional). These documents include, but are not limited to, the following information listed in Exhibit A of Analysys Mason’s report: i. International Interconnection Agreement executed by and between TV Rey de Occidente, S.A. de C.v. and Comunicaciones Rey, LLC, authorized on February 25, 2016; ii. International Interconnection Agreement executed by and between Qualtel, S.A. de C.V. and Procom, Inc., authorized on October 13, 2016; iii. International Interconnection Agreement by and between Telefonos de Mexico, S.A.B. de C.V. and T-Mobile USA, Inc., authorized on September 1, 2016; and iv. International Interconnection Agreement by and between Telefonos de Mexico, S.A.B. DE CV and Instituto Costarricense de Electricidad; authorized on September 13, 2016.
Document / Category of Documents. All international interconnection agreements relied upon by Xxxxxxxx Xxxx Xxxxxxxx in preparation of his witness statement. These documents include, but are not limited to, the following information listed in Exhibit 2 of Xx. Xxxx’x witness statement: i. International Interconnection Agreement executed by and between TV Rey de Occidente, S.A. de C.v. and Comunicaciones Rey, LLC, authorized on February 25, 2016; ii. International Interconnection Agreement executed by and between Radiomovil DIPSA, S.A. de C.V. and Vodafone Limited, authorized on August 17, 2015; iii. International Interconnection Agreement executed by and between Radiomovil DIPSA, S.A. de C.V. and Xxxxxxx Trade, S.A., authorized on September 13, 2016; iv. International Interconnection Agreement executed by and between Qualtel, S.A. de C.V. and Procom, Inc., authorized on October 13, 2016; v. International Interconnection Agreement by and between Telefonos de Mexico, S.A.B. de C.V. and T-Mobile USA, Inc., authorized on September 1, 2016; and vi. International Interconnection Agreement by and between Telefonos de Mexico, S.A.B. DE CV and Instituto Costarricense de Electricidad; authorized on Septmeber 13, 2016. vii. International Interconnection agreement executed by and between Servnet Mexico, S.A. de C.V. and Procom, Inc., authorized on February 9, 2016; viii. International interconnection agreement executed by and between UC Telecomunicaciones, S.A.P.I. de C.V. and Empresa de Telecomunicaciones de Cuba, S.A.P.I. de C.V., authorized on March 15, 2017; and ix. International interconnection agreement executed by and between Pegaso PCS, S.A. de C.V. and CAN Communication Services, LLC., authorized on September 29, 2017.
Document / Category of Documents. The communications between Pemex officials or their agents and the Bondholders or their agents regarding the meetings to discuss the 2015 Amendments, 2016 Amendments, 2017 Amendments, and the Oro Negro Contract terminations, including emails and messages sent via Whatsapp, text message, iMessage, WeChat, Signal Messenger, Telegram, or any other cloud-based messaging service, regarding these meetings between June 1, 2014 to December 31, 2017. See SOC ¶ 125.
Document / Category of Documents. Internal documents* containing an assessment, analysis, opinion or discussion of the regulatory framework governing the Claimants’ investment in Mexico, including any such documents addressing the following: a) the FTL (the former Telecommunications Law); b) the Constitutional Reform of 2013; c) the PEA Declaration; d) the FTBL (the current Telecommunications Law); e) the mechanism for the resolution of interconnection disputes. * Please note, for this and other requests, that “Internal documents” is a defined term. Please refer to the glossary for the definition.
Document / Category of Documents. Internal documents containing any of the following analysis prepared in connection with the original business plan and /or the decision to invest in México: a) financial projections (in excel if available); Procedural Order No. 5 b) economic viability analysis (e.g., net present value) (in excel if available); b) market/industry analysis; c) risk analysis; d) competition analysis; e) any other supporting documents for the original business plan Justifications: The Claimant relies on its original business plan to argue, inter alia, that “Tele Fácil’s business plan permitted it to thrive at whatever price Telmex offered” and that “part of Tele Fácil’s plan involved establishing a platform for offering innovative telecom services such as free conferencing”. (SoC, ¶ 10) This original business plan was allegedly prepared by Xx. Xxxxxx in February 2010 shortly after the company was incorporated and was submitted as Exhibit C-015. However, the document does not include many of the typical components of a business plan, such as: financial projections, economic viability analysis, market/industry analysis, risk analysis, among others. The requested documents are relevant to the case and material to its outcome. They are needed to evaluate and corroborate the claim for damages (such as the planned capital and operating expenditures) and to corroborate / dispute assertions about the original scope of the intended operations in the Mexico in Xx. Xxxxxx’x witness statement. They are also needed to determine and assess the validity of the Claimants’ expectations regarding, inter alia, the intended scope of operations / business opportunities, the expected amount of the investment, required funding and the expected return on the investment. Finally, they are needed to dispute the assertion that the alleged wrongdoing prevented Tele Fácil from launching services in Mexico (see ¶ 11 of Xx. Xxxxxx’x expert report.) The requested documents are not in the possession, custody or control of the Respondent. The Respondent reasonably believes that the documents exist and are in the possession, custody or control of the Claimants because they would have been necessary to make an informed decision on whether to invest in the intended project in Mexico.
Document / Category of Documents. Minutes of the Board of Directors discussing any change to the original business plan and/or any the 4 projects identified in section II.E (
