Total Budget	€ 57.500,00
THEME	DESCRIPTION	INVESTIGATIVE STEPS	STAFF	Budget (EUR)	PRIORITY	DEADLINE
Litigation in countries other than Brazil	Greece: allegations that bribes were paid to the company by Greek telecoms operator OTE to stay out of bid for mobile telephony licences in Bulgaria are currently being investigated by Greek courts	Information still very sparse and media coverage negligible. Assign sources on the ground to obtain further information on court proceedings	Marianna Vintiadis		HIGH	25/6/2004
	Venezuela: litigation currently under way due to accusations of accounting fraud and conflict of interest on behalf of Digitel TIM's minority shareholders.	We need the full list of cases and documentation on the proceedings (their nature and any decisions). Also need to establish whether the cases deal with the alleged JP Morgan issue or whether that warrants a separate investigation.	Marianna Vintiadis		HIGH	25/6/2004
	Bolivia: Controversy with government as Entel is accused of failing to meet contractual comitments. Also part of the money that has not been invested may be in an escrow account.	Miami to send in preliminary information for us to decide on strategy	Marianna Vintiadis		HIGH	25/6/2004
	Spain: investigation on JV and relation with RC ongoing	Awaiting final reports to decide on further steps.
	Mexico Charlie could you fill in please?
	SEC: Could there be an issue of failure to report litigation	Attempt to establish legal requirements on litigation reporting and then check to see if these have been fulfilled.			HIGH	25/6/2004
Press Campaign	Corporate Governance: make the case in a press style article that there are serious CG problems with TI, listing instances	Identify appropriate journalists	Omer Erginsoy / Marianna Vintiadis
	Accounting practices: press style article on CRT	Identify appropriate journalists	Omer Erginsoy / Marianna Vintiadis
Exhibits	Assemble all available documentary evidence that can be used by lawyers in support of ongoing or proposed litigation		Marianna Vintiadis		HIGH
Manipulation of case distribution in Rio State Court	Get further information on the case	Continue oblique dialogue with various court officials to obtain source intelligence and further leads.	BG and Confidential source		HIGH
	Judge Carlos Alberto Ayube is reported to have made two complaints in late 2003/early 2004 regarding the manipulation of distribution to the Vice President of the Court. No action appears to have been taken in these cases.	Contact Judge Carlos Alberto Ayube.	BG and Confidential source	€ 10.000,00
	Inquiries have uncovered anecdotal evidence of three specific examples of manipulation of the court system, not included in the investigative Committee's report. A document has been obtained which shows that shows a distribution one day prior to its allocation.	Continue to develop initial dialogue with Barros Snr and Jnr. Provide Copy of document.	BG and Confidential source
	The underlying (but not exclusive) system of manipulation is through in-built corruption of the security software provided by a Rio based computer services company called Modulo Security Solutions Ltda.
	Modulo is variously said to be controlled by relatives of Fichtner's partner, Dr Mannheimer, or by relatives of Superior Judges Pestana (current TJ President) and Ventura. Public records confirm that the company is 8.2% owned by Bank Santander and 91.8% owned by a Cayman Islands entity called Modulo Security Systems SA.	Research Modulo Security Systems SA in the Cayman Islands.	Kroll Italy / CAC
	Fichtner is said to benefit from this system, in conjunction with Nelson Tanure.	Further source intelligence regarding the relationship between Fichtner and Tanure and Manes is being sought.	BG and Confidential source
	Judge Humberto Manes, a member of the TJ Investigative Committee, is reported to be a close friend of Fichtner, who represented Manes as his lawyer in the past.
	MP Prosecutor Dora Beatriz Wilson da Costa interviewed Marcio Barros, and his father, Luis Carlos Barros. Another functionary called Maria Jesus has not appeared for Interview.	Maintain oblique dialogue with Wilson da Costa and Markus Druker (in charge of the Civil Police investigation) to feed findings re. Modulo.	Confidential source
	Luis Carlos Barros and Judge Pestana worked together for many years and may have jointly invested in some (unspecified) business. Barros is said by other sources to also have a close relationship with Fichtner.	Develop intelligence regarding Luis Carlos Barros' alleged relationship with Pestana and Fichtner.	BG and Confidential source
	Wilson da Costa is known to be a friend of Judge Manes, a member of the TJ Investigative Committee who is said to have personally benefited from the software system in the past. It is not thought that this relationship is conspiratorial however, it does raise the possibility of Wilson da Costa being 'guided' by Manes.
	Wilson da Costa has now opened the case to the Civil Police. Most recently, the State Prosecutor's office has made a formal application to obtain banking and telephone records for several Judges and court functionaries, including the Barros' and Marcus Tullius Alves.
	Source intelligence maintains that Fichtner and Tanure are directly involved in manipulation of distribution of cases in the TJRJ and that Tanure has benefited from this system in his own legal actions in the Court.	Obtain and analyse NT cases in the TJRJ.	Confidential source and para legal	€ 1.500,00
	N.B. The possibility of developing the findings of this investigation in conjunction with Veja magazine exists.	Discuss with Client
Tecnosistemi	Former CEO of Tecnosistemi Brasil Claudio Rafaelli has been recruited as source and has given detailed insight of money laundering and bribes paid to local officials - mainly PT - through TsB.	Continue CR debrief. Obtain documentation.	BG	€ 3.000,00
	Research has been undertaken into press reports regarding PT corruption in Riberao Preto & Santandrea. Although there are many allegations of corruption, no links with TsB /TIM have been identified to date.	Contact members of TsB's competition in order to obtain general intelligence.	JC/VV	€ 1.000,00
	TSB maintained a presence in other Latin American countries. It may have followed the same pattern as TIM investments in Latin America - Venezuela, Peru, Chile, Bolivia. Also Spain & Turkey.	Undertake public record research into relevant jurisdictions.	Kroll Italy
	TsB contractors - Iniassi Insurance, Sathis Factoring and Carueme Caminhoes - appear to be covertly controlled by either Mutti, Grisendi and Monteiro. They were used for parallel invoicing and possible money laundering.	Continue to develop background reports on these companies - seek banking details.	JC/VV	€ 3.000,00
	A travel agency and advertising agency said to belong to GG, were utilised exclusively by TIM during his tenure.	Continue to develop full public records, plus past tax returns and other records.	JC/VV	€ 3.000,00
	An informed source has identified offshore companies Roscomon and Telldor as being ultimately controlled by Mutti and Grisendi.	Develop public record and other details of these companies awaited.	Kroll Italy
	Research indicates that Aquasparta SA (Uruguay) has played an important role in moving TsB assets and possibly cash.	Develop public record and other details of these companies awaited	Kroll Italy
	Research into Mauro Marques, who co-ordinated TsB's bribes indicates that as well as being a Vice President of the Sao Paulo Football Federation, he has also served as the Administrative and Financial Director of Codesp (the Port of Santos). Reports indicate that MM is very close to the President of the PT in Sao Paulo, Paulo Frateschi. He is also said to be close to Palocci and to have played a transitional role between Cardoso and Lula	Further public record research continues. MM is also the subject of inquiries amongst political sources in Sao Paulo (see above).	JC/BG/Confidential souce	€ 1.000,00
	Joao Murra, a former TsB accountant and M. Candido, the former TsB security manager, have been recruited as sources.	Continue dialogue with JM to obtain TsB documents. Continue to run findings past both sources.	BG
Nelson Tanure	NT exerts a direct influence in the paper's daily editorial line and directly authorises reports against Opportunity. The reporter responsible for these articles is Gilberto Menezes Cortes. He broke the story on the fraud on TJRJ and was fed this information by NT, to damage Opportunity. NT has often announced in JB´s newsroom that he is very influential and can control the decision of the Judiciary in Rio de Janeiro.	Continue dialogue with JB sources.	VV/JC
	Research continues into assessing possible payments by TI to NT through advertising revenues in JB, GM and associated companies.	Continue source inquiries within the commercial department and amongst senior editorial staff.	VV/JC
	NT almost never goes to the paper, preferring to exert is influence through the executive-editor of the paper, Marcos Barros Pinto. However NT has appeared recently shouting at editors that sales are down. This has led to a bitter ongoing dispute with senior editorial staff. Cristina Conder, former director for Jornal do Brasil for over 10 years, has just been fired for not agreeing with the new editorial line.	Assess possible approach to Ms Conder.	VV/JC/BG
	JB journalists are still being forced to constitute a company (with CNPJ) in order to receive their monthly wages. This policy would appear to infringe Brazilian labour laws.	Develop details of NT's legal vulnerability to a possible audit by authorities.	VV/JC
	The GM is also said to be losing money, circulation and advertising revenues. GM still hasn't settled liabilities with former journalists from the paper. Its Rio office has all but closed with staff cut from 30 to 4. Here too morale is said to be very low.	Contact relevant sources at JB and GM in order to understand the size of JB and GM´s liability and offer litigants against NT informal assistance, such as the identification of a fixed asset that could be attached.	VV/JC	€ 4.000,00
	Efforts to confirm source intelligence that NT is trying to broker - and possibly participate in the acquisition of Correio Braziliense (part of the Diários Associados Group) have to date found no such evidence. Directors from the Jornal do Commercio (JC) - part of the group - have no knowledge of such an initiative.	Confirm original source intelligence from Brasilia.	BG
	NT is reported to be directly involved in lobbying activities inside CADE in Brasilia. These activities are said to include the payment of bribes.	Develop further evidence of these activities from confidential source in Brasilia.	BG	€ 4.000,00
	NT is reported to be lobbying on his own account within the BNDES (Brazilian Development Bank).	Develop further evidence of these activities from confidential source in Brasilia.	BG
	Informed sources have indicated that NT controls a number of investments in the computer software and related sectors. 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.	JC	€ 1.500,00
	The CEO of E:Safe Transfer is Neissan Monadjem. His brother, Shapoor Monadjem, is a former president of Sade-Vigesa S/A, another company held by NT. On February 22, 2001 Monadjem attended a lunch with Gushiken and LRD.	Conduct further public record research into the Monadjems. Develop further source intelligence regarding the activities and links of these companies. .	BG/JC	€ 1.500,00
	NT is reported to be involved in efforts to repeat the deal which he pulled off with Banco Boavista (which netted him a settlement of $150mn) with Banco Nacional. Discreet inquiries in the TJRJ indicate that the judge who awarded NT the judgement in the Boavista affair was Tullius Alves (see above).	Continue dialogue with source within the TJRJ who claims knowledge of the Boavista judgement. Obtain legal extracts from this case and analyse for possible manipulation and other details of modus operandi. Conduct background research in Judge Alves. Assess relevant Alves judgements in the TJRJ. Conduct background press and public records research into Banco Nacional to establish background and identify sources. Contact possible sources. .	BG/JC confidential source and paralegal	€ 7.000,00
	Tanure is said to have used Superior judge Amrion (ph) in this process	Research Superior Judge Amrion - said to be play a crucial role in a court decision in NT's favour	JC/BG	€ 2.000,00
LRD	LRD is fronting a web-site venture on behalf of Gushekin. This venture is incorporated in Portal da Previdencia Ltda, held through Portal da Previdencia Participações Ltda, both created in Santana de Parnaíba, SP.	Further research into these companies - in particular their shareholding structure - continues.		€ 2.000,00
	Further analysis of LRD's e-mails continues. New subjects, companies and individuals are being cross-searched against these communications.	Ongoing and occasional task.
	International phone calls made by LRD are being identified.	Reverse calls.
	Several offshore companies used by LRD have been identified: HIE Brazil Inc (Cayman Islands), Incubator Investment Co (Cayman Islands), CH Investment Co (Cayman Islands) and Long Pacific SA (Uruguay).	Obtain local public records.
	An article in O Globo indicates that the judge that absolved NN is being investigated.	Contact Journalist, establish actual name of Judge. Conduct background research.	JC
	NN has been linked to a failed R$ 290 mn transaction on the Sao Paolo Stock Exchange (Bovespa) on 25th May 2004. Stockbrokers Master Corretora and Bonus Banval CCTVM Ltda, negotiated five thousand contracts on the Bovespa futures index on behalf of Nahas. Both companies collapsed after Nahas failed to pay the bill. This deal is known to currently be the subject of an in-depth investigation by Reuters.	Undertake public record research to identify sources. Continue informal dialogue regarding these deals with Reuters.	JC/VV	€ 2.500,00
	Links between NN and Luis Favre, the husband of Sao Paolo's current PT Mayor Martha Suplicy are being researched. Nahas and Favre are reported to have acted together in obtaining the garbage collection contract for Sao Paulo on behalf of a company Vega Engenharia Ambiental, and in that company's subsequent sale to the French group (Lyonnaise des Eaux).	General source inquiries amongst relevant sources in Sao Paulo, which also takes into account AC and CCL (see below).	BG / Confidential source	€ 3.000,00
	Research has identified Quirkline Investments Inc (BVI), an offshore vehicle currently used by NN.	Undertake public records and other research in BVI.	Kroll Italy
Andre Calabi	Previ was a shareholder in Inepar since 1996. In 2001 Inepar agreed with Previ to conduct a restructuring plan for the company to be headed by Procópio Lima Netto together with Cassio Casseb and Andrea Calabi.	Attempt to obtain a copy of this report. Also efforts to identify possible sources amongst former Inepar employees.	JC	€ 2.000,00
	This contract is confirmed in a Previ report dated September 2001 (not yet obtained).	Debrief Freitag (Previ Source).	BG
	Public records reveal no direct company links between AC and CCL outside Traliz and AACC. AC is reported to be a partner in a consulting company named Consemp. Initial research indicates that this company is also located at the same address of AACC and Traliz.	Check CCL partnership in this company and its activities, plus previous shareholders.	JC	€ 1.000,00
	Inquiries have established that whilst at BNDES, AC was centrally involved in controversial deals, including funding the acquisition of Opene, assisting Orsa in obtaining the rights to buy the Projeto Jari pulp mill for R$ 1,00 and discussions with NN and Jorge Serpa, regarding the construction of a petroleum refinery in Ceara.	Continue general background press and public record research into these deals. Attempt to identify sources	JC/VV	€ 1.000,00
	After BNDES, and prior to TI, AC was indicated to assume the presidency of Elcelsa. AC was hired by TI in late 2000 / early 2001.	Consult relevant sources regarding Calabi's recruitment to TI.	BG and others	€ 500,00
Cassio Casseb Lima	Research into the possibility that CCL has passed commercial interests into the hands of his family are underway. An individual called Eduardo Casseb - only four years younger then CCL and thought to be his brother - was identified as having links to a series of companies.	Confirm the relevance of this individual..	JC	€ 500,00
	Discreet inquiries are underway amongst sources linked to Sao Paulo municipal and state politics in order to establish possibly corrupt links between CCL, AC and Previ through links in the PT in Sao Paulo. These inquiries also include Traliz, AACC and the possible relationship with Inepar.	Continue inquiries.	JC
Carmelo Furci	TIM sources report CF recently had a heart attack and underwent an emergency operation in Rio. Since then he is reported to be based in the Copacabana Palace Hotel.		BG/JC
	A recent article reported that CF is in Rio de Janeiro to take care of ALL, a company which has just floated on BOVESPA. ALL America Latina Logistica is the biggest logistics operator at South America.	Continue inquiries.	JC	€ 500,00
Mario Garnero	Research into possible links between Mario Garnero and TI are underway and reveal one link to date. Press research confirms Garnero's role as a prominent investor, controlling Brasilinvest fund, which controls international investments of around US$ 3bn. The fund includes amongst its directors, George Bush, David Tang (China), Prince Andrew, Margareth Thatcher, Nathanael Rothschild (Atticus Fund), Marc Pietri, Carlo De Benedetti, Salman Bin-Khalifa Al Khalifa (VP of the state-owned oil company of Bahrein, also friend of NN), Youssef Hamada Al-Ibrahim (ex-Kuwaiti minister of finance), Oleg Deripaska (Russia), Armen Sarkissian (Armenia), Aécio Neves (Governor of Minas Gerais), Nicolas Berggruen (Alpha Investments), Nemir Kirdar and Turki Al Faisal.	Continue press research	JC	€ 1.000,00
	Carlo De Benedetti is the CEO of TIM. No further links with TI have been established to date.
Lulli Mussassi	No apparently relevant public records found.	Confirmation of correct spelling awaited from Kroll Italy	Kroll Italy / CAC	€ 1.000,00