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IN BUSINESS REQUEST SEEKS EXTENSIVE DOCUMENTATION OF SANDS BUSINESS JACOBS, FROM PAGE 8 ordering Gonzalez to take another look at the issue. The state Supreme Court decision put Jacobs' main lawsuit allegation on hold — and last week he and his new legal team filed an extensive discovery request with Gonzalez in hopes of nailing down details about Sands China's activities in Nevada. The request — which Sands China and Las Vegas Sands are sure to argue would violate Macau's privacy laws — asks Gonzalez to require that Las Vegas Sands or Sands China produce: n Executives for depositions, including Adelson, Sands President and Chief Operating Officer Michael Leven, Sands Chief Financial Officer Kenneth Kay and Sands President of Global Gaming Operations Robert Goldstein. n Telephone records for calls Adelson, Leven and Goldstein had over several years involving Sands China. n All documents reflecting the flow of money from Macau to Las Vegas Sands, including those about the alleged physical couriering of money from Macau to Las Vegas and about a system for moving money called "Affiliate Transfer Advice.'' n All documents reflecting the company's global gaming and/or player development efforts. n The dates and times of all Sands China board meetings and the locations of each participant for each meeting. n Documents reflecting travel to and from Macau and Hong Kong by Adelson and other executives. n The calendars of Adelson and other executives who had meetings related to Sands China or traveled to China for Sands China business. n Documents about Leven's service as CEO of Sands China and as the executive director of the Sands China board of directors. n Documents about negotiations and execution of agreements for the funding of Sands China that occurred in whole or in part in Nevada. n Contracts and agreements Sands China entered into with entities based in or doing business in Nevada. n Agreements for all shared services between Las Vegas Sands and Sands China. n Documents including emails reflecting services performed by Las Vegas Sands for Macau development projects, recruitment and interviewing of potential Sands China executives, negotiations about a possible joint venture between Sands China | 3 OCTOBER 2011 | and Caesars Entertainment Corp., negotiations about the sale of Sands China's interest in sites to Macau competitor Stanley Ho and deals with show operator Cirque du Soleil. n Documents used to Sands executives for such work. n All documents Sands China has provided to Nevada gaming regulators. Records about money transfers are calculate management fees for services provided by Las Vegas Sands to Sands China, and any reimbursements to Las Vegas also likely to be of particular interest to Jacobs, as Sands China already has accused him of lying in asserting there had been improper transfers by courier. And while Las Vegas Sands and Sands China will likely ask Gonzalez to sharply limit the allowed discovery, Jacobs' attorneys wrote in their request: "The law affords Jacobs the right to conduct jurisdictional discovery in order to meet his burden of establishing Sands China's systematic and pervasive contacts with the state of Nevada.'' " City National guided us from the start." When we started our business over 30 years ago, we needed guidance. We've always partnered with the very best people we can fi nd, and that's why we chose City National. Th ey've been with us since the beginning and it's been absolutely fantastic. Th ey've done everything they can to educate me and help me run a more successful business. City National is Th e way up® for me and my business. Terry Vance President, Vance & Hines Racing Hear Terry's complete story at cnb.com/thewayup. Experience the Diff erence. Call (702) 425-6559 or visit cnb.com to fi nd a business banker near you. City National Business Banking Member FDIC 9 ©2011 City National Bank