| Total Budget | 0,00 | ||||||
| THEME | DESCRIPTION | INVESTIGATIVE STEPS | STAFF | Budget (HRS) | PRIORITY | DEADLINE | |
| CORRUPTION IN BRAZIL | MODULO: Who is Modulo owned by? | Establish beneficial ownership of Modulo. Research Modulo Security Systems SA in the Cayman Islands. | Kroll Italy / CAC | HIGH | 15/7/2004 | ||
| MODULO: Link Modulo to Fichtner, Manheimer and Tanure | Pending ownership details | BG and Confidential source | |||||
| TECNOSISTEMI: Evidence of bribes | Profile § Firpo § Brunero § Lugaro § Pataro |
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| TECNOSISTEMI: Research into Mauro Marques, who co-ordinated TsB's bribes | Further public record research continues. MM is also the subject of inquiries amongst political sources in Sao Paulo (see above). | JC/BG/Confidential souce | |||||
| NT: Payments by TI to NR | Source enquiries in commercial department | VV/JC | |||||
| NT and CADE : Evidence of bribes? | Develop further evidence of these activities from confidential source in Brasilia. | BG | |||||
| NT and Tullius Alves | Continue dialogue with source within the TJRJ who claims knowledge of the Boavista judgement. Obtain legal extracts from this case and analyse for possible manipulation and other details of modus operandi. Conduct background research in Judge Alves. Assess relevant Alves judgements in the TJRJ. Conduct background press and public records research into Banco Nacional to establish background and identify sources. Contact possible sources. |
BG/JC confidential source and paralegal | |||||
| BOAVISTA | Provoke media coverage of the affair to draw attention to manipulation in cases against OPP that are pending | CAC | |||||
| NT and GUSHEKIN: Docas controlled Webnursery SA in turn is linked to Prosisa Informática Ltda and its subsidiary E:Safe Transfer, which produces all of the smart cards used by the banking sector in Brazil and is involved in developing security software for institutions. | § Analyse and report on articles of incorporation for Webnursury, Prosisa Informática and E:Safe Transfer. § Conduct further public record research into the Monadjems. Develop further source intelligence regarding the activities and links of these companies. . |
BG/JC | |||||
| LRD and GUSHEKIN: LRD is fronting a web-site venture on behalf of Gushekin. This venture is incorporated in Portal da Previdencia Ltda, held through Portal da Previdencia Participações Ltda, both created in Santana de Parnaíba, SP. | Further research into these companies - in particular their shareholding structure - continues. | ||||||
| NN : Role for TI in Brazil | Obtain in-depth source intelligence on true scope and nature of Nahas' relationship with TI. | CAC | |||||
| NN and LUIS FAVRE: What is the story behind the refuse collection contracts? | General source inquiries amongst relevant sources in Sao Paulo, which also takes into account AC and CCL (see below). | BG / Confidential source | |||||
| NN and LOCAL POLITICIANS | Develop intelligence on Nahas corruption in São Paolo municipality and links to local politicians. | BG/JC | |||||
| NN and GARNERO/MUSSASSI | Understand role of Garnero and/or Mussassi. | CAC/BG | |||||
| BRIBES | Profile § Andre Calabi § Cassio Casseb Lima § Carmelo Furci § Mario Garnero § Lulli Mussassi |
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| CORRUPTION | Focus on exposing past and current TI-related § corruption, improper links to politicians, § bureaucrats, § regulators, etc. |
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| CORRUPTION - TECNOSISTEMI | § Revisit Tecnosistemi sources to obtain further evidence of TI bribery § Investigations into Firpo, Pataro, Brunero, Lugaro |
BJ/JC | |||||
| CORRUPTION - TANURE | Develop Brasilia source to uncover Tanure attempts to corrupt regulators | BG | |||||
| CORRUPTION - TANURE II | Develop further intelligence on TI/TIM support of Tanure media | BJ/JC | |||||
| CORRUPTION - TANURE/DEMARCO | Investigate Tanure/Demarco links to Gushiken. | BG/JC | |||||
| CORRUPTION - VEIGA | Revisit sources to obtain further leads on role of de Veiga in the CRT affair | BG | |||||
| CORRUPTION-CCL | Complete investigation into CCL/AC links to TI; focus on possibility of actual payments made. | BG/JC | |||||
| CORRUPTION-FURCI | Investigate Furci's current role and other activities. | BG/JC | |||||
| TIM BRASIL | STRATEGY AND FINANCE | § Focus on TIM Brasil financial situation, § TI strategy for Brazil. |
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| FURTHER ANALYSIS | § Further analysis of TIM Brasil situation § review of recent presentations § identification of key areas to attack. |
OE | |||||
| TIM SUL/NORDESTE MERGER | § Analyse the TIM Sul / TIM Nordeste merger § contact institutional investors in Brazil and elsewhere to draw attention to the dilution impact on minority shareholders and corporate governance in general. |
OE | |||||
| LITIGATION | GREECE: Did OTE bribe TI to stay out of the Bulgarian bid for telecom licenses and, if so, why? Proceedings are ongoing, how is TI reacting? | § Speak to Alex § Speak to newspaper source § Contact Panos Polyzoidis |
MV | HIGH | 15/7/2004 | ||
| BOLIVIA: Did Entel fail in its contractual commitments? Why? Is the money that was not invested sitting in an escrow account in the US | Miami to appoint local source | MV | MEDIUM | 15/7/2004 | |||
| VENEZUELA: How and why did the settlement happen? How did TI handle the dspute? | Miami to appoint local source | MV | MEDIUM | 15/7/2004 | |||
| SPAIN: Can tangible evidence of a tradeoff between JV and RC be obtained? | Awaiting final reports to decide on further steps. | CC | LOW | 15/7/2004 | |||
| ITALY-GLOBAL | TI CONTROL STRUCTURE | § Focus on TI control structure; § Arab connection |
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| OLIMPIA- SOURCES OF FUNDING | Investigate sources of funding for Olimpia. | CAC, MV | |||||
| HOPA | Gnutti's game plan | MV | |||||
| SB | What is SB's true position? | CAC | |||||
| CORPORATE GOVERNANCE: Focus on exposing corporate governance issueS | Analyse TI/TIM controversies relating to corporate governance issues; write a memo to serve as a brief for PR campaign. | OE/MV | |||||
| PRESS/PR CAMPAIGN | Prepare Memo on TIM Sul Dilution | OE | HIGH | 15/7/2004 | |||
| Prepare Memo on Corporate Governance | OE/MV | HIGH | 15/7/2004 | ||||
| EXHIBITS | Assemble all available documentary evidence that can be used by lawyers in support of ongoing or proposed litigation | MV / Marcella Binda | HIGH | 31/7/2004 | |||