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S004040
VANCOUVER REGISTRY
BETWEEN:
PLAINTIFFS
AND:
TAKE NOTICE that the Plaintiffs demand you Honourable Mr. Muravei Radev in
your official capacity for Defendant Republic of Bulgaria make discovery of all
documents which are or have been in your possession or control relating to any matter in
question in this action within 21 days from delivery of this demand by providing a list in
Form 93.
Plaintiffs rely further on the provisions of Rule 26(8) of the Court that you produce or
make available for copying the following documents, inter alia, referred to in the
Pleadings:
1
present, including but not limited to, inter alia, typed or hand written notes, daily
diary entries, minutes of meetings, memorandums, directives, letters, agreements,
telephone logs, faxes, telexes, teletype, telephone recordings or as electronic data.
2. All original correspondence to you or from you to any other Defendant in this action
referring to the Plaintiffs personally or their assets, including, inter alia, typed or
hand written notes, daily diary entries, minutes of meetings, memorandums,
directives, letters, agreements, telephone logs, faxes, telexes, teletypes, telephone
recordings or as electronic data.
4. Any other document referred or alluded to in the pleadings setout in the amended
Statement of Claim.
________________________
On behalf of Plaintiffs