Claimants request that Respondent produce the documents or categories of documents identified below. For the avoidance of doubt, each of these requests relates to specific documents or specific categories of documents that are reasonably believed to exist and to be in the possession, custody, or control of Respondent. 

The following defined terms are used in connection with these requests: 

“Respondent” or “Argentina” means the Argentine Republic, including its ministries, departments, and agencies, as well as their representatives, officers and employees. 

“Document” means all writings of any kind, whether recorded on paper, electronic means, audio or visual recordings, or any other mechanical or electronic means of storing or recording information, including but not limited to all communications (including reports, memoranda, presentations, letters, and e-mail and facsimile correspondence), notes, meeting minutes, transcripts, talking points, pitch books, speeches, financial statements, and proposals.