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  • Jorge Muniz Eiches

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    RafaelOlaechea
    45 tayangan3 halaman
    The document is an affidavit filed in support of Doe Run Peru's motion to compel production of documents from Trafigura A.G. in a criminal defamation case in Peru. It summarizes testimony from employees of Consorcio Minero S.A. who stated that their legal department and external counsel orchestrated the conduct and statements at issue in the case. Based on this testimony, Doe Run Peru requested that Consorcio Minero's in-house counsel and external counsel provide testimony in the criminal case regarding their communications on the subject matter. The affidavit asserts that the attorneys may not prevent disclosure of written or oral communications regarding the subject of the libel action based on privilege.

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    The document is an affidavit filed in support of Doe Run Peru's motion to compel production of documents from Trafigura A.G. in a criminal defamation case in Peru. It summarizes testimony from employees of Consorcio Minero S.A. who stated that their legal department and external counsel orchestrated the conduct and statements at issue in the case. Based on this testimony, Doe Run Peru requested that Consorcio Minero's in-house counsel and external counsel provide testimony in the criminal case regarding their communications on the subject matter. The affidavit asserts that the attorneys may not prevent disclosure of written or oral communications regarding the subject of the libel action based on privilege.

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    Attribution Non-Commercial (BY-NC)
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    45 tayangan3 halaman

    Jorge Muniz Eiches

    Diunggah oleh

    RafaelOlaechea
    The document is an affidavit filed in support of Doe Run Peru's motion to compel production of documents from Trafigura A.G. in a criminal defamation case in Peru. It summarizes testimony from employees of Consorcio Minero S.A. who stated that their legal department and external counsel orchestrated the conduct and statements at issue in the case. Based on this testimony, Doe Run Peru requested that Consorcio Minero's in-house counsel and external counsel provide testimony in the criminal case regarding their communications on the subject matter. The affidavit asserts that the attorneys may not prevent disclosure of written or oral communications regarding the subject of the libel action based on privilege.

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    Attribution Non-Commercial (BY-NC)
    Unduh sebagai PDF, TXT atau baca online dari Scribd
    Tandai sebagai konten tidak pantas
    dari 3

    Case 3:11-mc-00077-SRU Document 25-34

    Filed 06/30/11 Page 1 of 3

    UND STATES DISTRCT COURT


    DISTRICT OF CONNECTICUT
    DOE RUN PERU S.R.L.,

    ......--~...--._---------------.--------------_.)(
    Applicat.
    AFFrOAVlT

    ZICBES
    v.

    OF JORGE MUz

    TRFIGUR A.G.,

    ......___.._...___.______.____..__..x
    JORGE Mtz ZlCBES, being duly sworn: deposes and says:
    I. .r am member of the law finn Muiz,. Ramirez, Prez- Taiman & Olaya in Peru. I have

    Respondent.

    been admittd to the practice of law in Peru since 1976. 1 repreent Doe Run Peru S.R.L.
    in the criminal defamaton action that it institute agaist Consorcio Minero S.A.

    (UCormin") and Trafgura Group ("Trafigura'1 in the 20th Criminal Court in and for

    Lima, Per (the "Libel Action"). 1 subnut this afdavit in support of Doe Run Peru's
    Motion to Compel Production ofDocuinents.
    2. During their recent depositions before the Peruvian criminal judge, Connfn

    employees testified that their attorneys ai:e the ones who orchestrated the conduct and made the
    sttements that are the subject of

    the Libel Action.

    3. Mr.. G0117..lo Miguel Andrade Nicoli testfied before the Criminal Court in and for

    Lima. Peru on June 22, i 0 i i, and he stated: "The controversy with Doe Run Peru is being
    handled by our legal departent and our external counsel, and T undersand that (the April 8,
    2011 Cormn press release) was drafted in reponse to an initial pres.

    releae n-om Doe Run

    dated April 2, i 0 i 1."

    GOO~

    ZIN.fl OIlI.rJ.S3

    000Ltt9 YVd OS:~t tt06/66/90

    Case 3:11-mc-00077-SRU Document 25-34

    Filed 06/30/11 Page 2 of 3

    4. Mr. Ricardo Juan Trovarell Vecchio testifed before the Crminal Cour in and

    for Lima, Peru on June 24. 201 I, and he stated: t'Cormn's legal deparment, advised by our
    external advisors, saw the need to resond to this press releae, a decision which 1 considered

    correct, thus I authorzed the Legal Manager to respond to the false statements made by Doe Run
    Peru. i did not parcipate in the draftng of the only communiqu issued by Connfn on April 8,

    2011, in response to the statements made by Doe run Peru in their press releaes dated April 2
    and April 6, and 1 also did not order its publicaon" which was done by Cormfn's Legal
    Manager, Dr. Alfredo Polo Glvez. ......

    5. Juan Wilians Negnn CrispilJ, Vivian Marlene Cortvitae Acevedo, Fernando


    Enrique Parodi GaUino, Jessica Elizabeth Portoy Canazs and Alejandro Jose Almenara
    Roullon provided similar testimony.

    6. Based on this sworn testimony by these Connn employees, DRP fied a reuest

    before the Judge in the Libel Acton to call for the testfmonial declaration of i) Cormin's inhouse counsel, Alfrdo Polo Glvez (who was mentioned by Jessica Portoy, Alejandro

    Alenara, Fernando Parodi, Miguel Andrade, Viviana Cortvitae and Juan Trovarel1 as the
    legal m~ager of the company who made the decision to publsh the libelous press releases) and,
    (ii) the legal representative ofEstudio Rodrigo, Elas & Medrano (mentioned by Miguel Andrade

    and Juan Trovarell as the external counsel tht advised Connin with repect to these matters).

    COOfE

    ZI~ OHI!I.S3

    OOOLlT9 XVd oS:CT tlOZ/6Z/90

    Case 3:11-mc-00077-SRU Document 25-34

    Filed 06/30/11 Page 3 of 3

    7. Under these circuinstces, the atorneys involved in the conduct at issue in the
    Libel Action are obligated to give evidence tn the Criminal Court in Peru. In other words,
    Corm

    in and its lawyer n1ay not prevent disclosure of their wrttn or ora communications
    the Libel Aotion on the basis of an~ type of

    regading the subject inater of

    'ches

    Dated: June 29, 201 i

    l'OO~

    Z i ij 0 I anis a:

    OOOL TTa YV OS: CT tT06/6Z 190

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