Common use of Reply Clause in Contracts

Reply. Claimants refer to and incorporate by reference as if fully set forth herein their responses to Respondent’s General Objections Nos. 1-3 and their response to Request No. 1 above. In addition, Respondent’s objections are without merit and should be overruled for the following reasons: First, Xxxxxxxxx’ request is relevant to this case as documents and communications relating to Judge Xxxxxxx’x promotion are directly related to Claimants’ claim that he was promoted for his role in Pemex’s collusion with the Bondholders to take over the Rigs, through the issuance of orders permitting the seizure of Oro Negro’s assets and the takeover of the Rigs. See SOC ¶¶ 247-57, 265. Respondent’s assertion that Judge Xxxxxxx is impartial and independent judge is self-serving. Claimants have provided strong reasons to believe that Judge Xxxxxxx was rewarded for issuing the Seizure and Take-Over rights contracts. Moreover, Respondent’s relevance objection is undetailed and fails to identify the basis for such assertion. Second, Xxxxxxxxx’ request is reasonable and specific, and certainly not a fishing expedition, because it asks for documents and communications relating to a specific incident—the promotion of Judge Xxxxxxx. See SOC ¶ 265. Moreover, Respondent’s objections as to burden and lack of specificity are undetailed and fail to identify the bases for such assertions. On these grounds, Claimants respectfully request that the Tribunal order Respondent to produce the requested documents.

Reply. Claimants refer to and incorporate by reference as if fully set forth herein their responses to Respondent’s General Objections Nos. 1-3 and their response to Request No. 1 above. In addition, Respondent’s objections are without merit and should be overruled for the following reasons: First, Xxxxxxxxx’ request is relevant to this case as documents and communications relating to Judge Xxxxxxx’x promotion are directly related to Claimants’ claim that he was promoted for his role in Pemex’s collusion with the Bondholders to take over the Rigs, through the issuance of orders permitting the seizure of Oro Negro’s assets and the takeover of the Rigs. See SOC ¶¶ 247-57, 265. Respondent’s assertion that Judge Xxxxxxx is impartial and independent judge is self-serving. Claimants have provided strong reasons to believe that Judge Xxxxxxx was rewarded for issuing the Seizure and Take-Over rights contracts. Moreover, Respondent’s relevance objection is undetailed and fails to identify the basis for such assertion. Second, Xxxxxxxxx’ request is reasonable and specific, and certainly not a fishing expedition, because it asks for documents and communications relating to a specific incident—the promotion of Judge Xxxxxxx. See SOC ¶ 265¶265. Moreover, Respondent’s objections as to burden and lack of specificity are undetailed and fail to identify the bases for such assertions. On these grounds, Claimants respectfully request that the Tribunal order Respondent to produce the requested documents.

Reply. Claimants refer to and incorporate by reference as if fully set forth herein their responses to Respondent’s General Objections Nos. 1-3 and their response to Request No. 1 above. In addition, Respondent’s objections are without merit and should be overruled for the following reasons: First, Xxxxxxxxx’ request is relevant to this case case, as documents and communications relating to Judge Xxxxxxx’x promotion are it is directly related to Claimants’ claim that he was promoted for his role in Pemex’s collusion Respondent colluded with the Bondholders to take over drive Oro Negro out of business by suddenly refusing to execute the Rigs, through the issuance of orders permitting the seizure of 2017 Amendments and forcing Oro Negro’s assets and the takeover of the RigsNegro into bankruptcy. See SOC ¶¶ 247-57, 265. Respondent’s assertion that Judge Xxxxxxx is impartial and independent judge is self-serving. Claimants have provided strong reasons to believe that Judge Xxxxxxx was rewarded for issuing the Seizure and Take-Over rights contracts¶ 93. Moreover, Respondent’s relevance objection is undetailed and fails to identify the basis for such assertion. Second, Xxxxxxxxx’ request is reasonable and specific, and certainly not a fishing expedition, because as it asks for documents and communications relating to a specific incident—decision made by Pemex in August 2017 not to execute the promotion of Judge Xxxxxxx2017 Amendments. See SOC ¶ 265. id. Moreover, Respondent’s objections as to burden and lack of specificity are undetailed and fail to identify the bases basis for such assertions.Third, Respondent’s allegation that Pemex officials signed the 2017 Amendments but that they were not formalized for reasons attributable to Oro Negro is disputed and besides the point, as the Claimants are seeking documents relating to the decision by Pemex to not go forward with the Amendments, regardless of who Pemex believes was at fault for it. Moreover, this objection is not appropriate as a response to a document request, and should instead be limited to Respondent’s Statement of Defense and related pleadings to the Tribunal. On these grounds, Claimants respectfully request that the Tribunal order Respondent to produce the requested documents.

Reply. Claimants refer to and incorporate by reference as if fully set forth herein their responses to Respondent’s General Objections Nos. 1-3 and their response to Request No. 1 above. In addition, Respondent’s objections are without merit and should be overruled for the following reasons: First, Xxxxxxxxx’ request is relevant to this case case, as documents and communications relating to Judge Xxxxxxx’x promotion are it is directly related to Claimants’ claim that he was promoted for his role in Pemex’s collusion Respondent colluded with the Bondholders to take over drive Oro Negro out of business by suddenly refusing to execute the Rigs, through the issuance of orders permitting the seizure of 2017 Amendments and forcing Oro Negro’s assets and the takeover of the RigsNegro into bankruptcy. See SOC ¶¶ 247-57, 265. Respondent’s assertion that Judge Xxxxxxx is impartial and independent judge is self-serving. Claimants have provided strong reasons to believe that Judge Xxxxxxx was rewarded for issuing the Seizure and Take-Over rights contracts¶ 93. Moreover, Respondent’s relevance objection is undetailed and fails to identify the basis for such assertion. Second, Xxxxxxxxx’ request is reasonable and specific, and certainly not a fishing expedition, because as it asks for documents and communications relating to a specific incident—decision made by Pemex in August 2017 not to execute the promotion of Judge Xxxxxxx2017 Amendments. See SOC ¶ 265. id. Moreover, Respondent’s objections as to burden and lack of specificity are undetailed and fail to identify the bases basis for such assertions. Third, Respondent’s allegation that Pemex officials signed the 2017 Amendments but that they were not formalized for reasons attributable to Oro Negro is disputed and besides the point, as the Claimants are seeking documents relating to the decision by Pemex to not go forward with the Amendments, regardless of who Pemex believes was at fault for it. Moreover, this objection is not appropriate as a response to a document request, and should instead be limited to Respondent’s Statement of Defense and related pleadings to the Tribunal. On these grounds, Claimants respectfully request that the Tribunal order Respondent to produce the requested documents.