Carmelo Furci

Objective: Background intelligence & leverage.

• TV commencing review of all press and litigation records relating to CF in order to identify previous associates, counterparties, litigants, informed journalists etc.

• Double check with FP re Source A's findings regarding CF's status with agency on Banestado and any other. EBS can we use source???

• Check with FP re current status of Banestado investigation in general (why CF does not appear). Also note news report says 'going to be indicted'. EBS can we use source???

Gianni Grisendi

Objective: Background intelligence & leverage.

• TV commencing review of all press and litigation records relating to GG in order to identify previous associates, counterparties, litigants, informed journalists etc. Expected TV when???

• KSP identifying former senior employees of Tecnosistemi who have suffered from the company's bankruptcy and who may be in a position to assist . Expected 30/01-03/02

• KSP making similar searches for former employees of GG's three personal companies. Expected 30/01-03/02

• Public record on GG's three personal companies in Brazil. Expected 26/01

• KSP obtaining filings on GG's two Uruguayan Co's. Expected 27/01-30/02

• KSP obtaining Tecnosistemi bankruptcy files. Expected TV today???

• KSP and TV collate Tecnosistemi files to date and report. Expected TV when???

• Tecnosistemi Bankruptcy files. Pursue financial details through Ministerio Publico and bankruptcy administrator.

• See other evidence of Tecnosistemi fraud in CRT deal.

• Build dialogue with Source G - head of FP investigation into Parmalat-Zirconia (false tax returns) re current status of Parmalat case and links between Parmalat, GG and TI. EBS can we do this???

• Build dialogue with Julia Cunha source at Cirio. EBS can we do this???

• Source M under development re GG background . Ongoing.

Naji Nahas

Objective: Background intelligence & leverage.

• TV reviewing all press and litigation records relating to NN in order to identify previous associates, counterparties, litigants, informed journalists etc. Expected TV when???

• Oblique approach to the former head of the SP stock Exchange, who was involved in highly personal dispute with NN.

• Check with FP re any information held on NN. EBS can we use source???

• Source M under development as possible source of NN background. Ongoing.

• Tribunal Superior do Justicia files indicate foreign interest in Nahas OE explain???

• Chase

Objective: Investigate whether Chase engineered the Globo.com acquisition (improper conduct, conflict of interest), particularly in a way which would expose Chase/TI to scrutiny under US laws (fraud) or securities regulations. To do this:

Trace TI's payment to Globo and check whether it was used to preferentially repay Chase credit facilities. (This could be in the form of a reduction of Globo debt or a reduction of RBS debt -Globo acquired Net Sul from RBS at the same time as the Globo.com transaction).

• Source A accessing Central Bank for transaction details. Expected 26/01

• Also develop alternative to Source A - FP or other. EBS can we use source???

TV Other Alternatives???

• Approach ex-Globo executive (Molchansky) Too dangerous.

• Also, was the transaction linked to corruption surrounding FIFA broadcasting rights in Brazil? Wild card. Bear in mind, not worth pursuing.

• Approach Giovanni Stella and/or Claudio Varoli. TI employee being pursued by Milan.

• Globo.com Acquisition

Link controversy surrounding the Globo.com acquisition to BrT's claims against TI. This would include:

• Collect additional evidence to show that TI actively worked against BrT in the broad-based proposals they made to Globo (breach of trust vis-à-vis BrT's prior proposals to Globo on issues such as cable, the VICOM license. OE ? BG discuss???

• Links to the CRT acquisition (possibly involves RBS; or may involve Moreira who was both the CFO of Globo and the negotiator of a Brazilian pension fund). OE should we do something on Moreira.

• CRT Acquisition

• Investigate possible corruption of Government officials by Telefonica, through personalities such as Andrea Matarazzo, Pimenta de Veiga and Gregorio Marin Presioto. OE/BG discuss???

• Establish the role played by Tecnosistemi; find hard evidence of fraud. See above.

• Frank or Charles ??? to try and obtain details of the current Brazil Prosecutor's investigation into CRT.

• Options Issue

Search of CVM Files re Globo Cabo options with TI, TI sub or Chase unfruitful. TV currently pursuing non-public disclosure at CVM through TV family link. TV initiate???

Option found in Monopolies Commission files being translated. TV when???

Globo.Rede co filings being translated. TV when???

• Other

Obtain current information on TI's strategy in as much as it may relate to the Brazilian dispute:

• Why did Globo drop its anti-BrT position after Tronchetti took over? OE?BG discuss

• What is Tronchetti's media strategy and is his link with Murdoch relevant to the issues surrounding Globo or Net? OE - Anything to do in Brazil???

• Is there evidence to suggest TI may be looking for a settlement? FT opinion that Troncetti attitude toward the dispute is more hard than previously thought. What is current thinking of IT senior management? OE discuss

Source M under development as possible source for the above and other questions.