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Patrick.George@kennedyslaw.com
Rebekah.Giles@kennedyslaw.com
10 November 2016
Dear Mr Bartlett
1 As you are aware, this firm acts on behalf of the Unaoil Group, and its owners the
Ahsani family.
2 We refer to the March 2016 ‘World Exclusive’ series concerning our clients published
in Australia and elsewhere by Fairfax Media and the Huffington Post (the Articles).
The Articles referred to may be found at:
http://www.theage.com.au/interactive/2016/the-bribe-factory/day-1/the-
company-that-bribed-the-world.html
3 Our client is considering taking action against the source(s) of the documents
referred to in the Articles. As such, our client is currently taking steps to identify
the source(s) who supplied the documents purported in the Articles. In accordance
with the Uniform Civil Procedure Rules 2005 (NSW), Rule 5.2 our client must make
all reasonable enquiries to ascertain the identity of the source(s), prior to making
an application for preliminary discovery.
4 In the circumstances, we request that you please urgently provide our client with
all information in your client’s, or agents of your client’s possession or control
relating to the source(s) who supplied the documents purported in the Articles.
Kennedys offices, associations and cooperations: Auckland, Beijing, Belfast, Birmingham, Bogotá, Brussels, Buenos Aires, Cambridge,
Chelmsford, Copenhagen, Dubai, Dublin, Edinburgh, Glasgow, Hong Kong, Karachi, Lima, Lisbon, London, Madrid, Manchester, Mexico City,
Miami, Moscow, Mumbai, New Delhi, Oslo, Paris, Rio de Janeiro, Santiago, São Paulo, Shanghai, Sheffield, Singapore, Stockholm, Sydney,
Taunton and Warsaw
Legal_APAC\1714576.1
Mr Bartlett
Minter Ellison Lawyers
Yours faithfully
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