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Third, the damages Claimant seeks are depending on an Investigation at odds with the statements in Claimant’s Reply that Yukos' tax assessments were not them selves expropriatory actions. Because the supplemental expert report of Professor James Dow demonstrates, LECG’s calculation of damages, on which Claimant depends, is based on the identica

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The Respondent’s arguments to the contrary rely on legal authorities from the sphere of diplomatic defense, not bilateral expense treaties. [ ] established that Rosneft, as being the successor in curiosity to YNG, had breached its obligation to repay particular bank loan agreements amongst YNG and also the offshore Yukos entity. The Russian court

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