Summary

GENERAL OBJECTIONS

The following General Objections apply to each of the Definitions, Instructions, and Questions and shall have the same force and effect as if set forth in full in response to each individually numbered Definition, Instruction, or Question. Certain General Objections may be specifically repeated in individual responses for the purpose of emphasis. Failure to make a specific reference to a General Objection is not a waiver of any General Objection.

In the event any information falling within one or more of these objections is disclosed in response to the Questions, the disclosure is inadvertent and is not a waiver of the objection.

The objections and responses herein are based on the Republic's present knowledge, information, and belief and on its document productions to date. Further investigation may reveal additional facts or documents that could result in additions to, changes in, and/or variations from, the responses herein. Without in any way obligating itself to do so, the Republic reserves the right to amend, revise, correct, supplement, and clarify any of the objections or responses herein. Regardless of whether the Republic provides a response to any Question in the Subpoena, the Republic reserves the right (but does not assume the obligation) to: (i) revise, correct, supplement, or clarify the content of these Responses and Objections in accordance with the CPLR and the Rules; (ii) provide additional responses in the future; (iii) object to further post- judgment discovery in the Actions; (iv) rely upon any documents produced in the Actions in any hearing, proceeding, or trial in the Actions; and (v) challenge the authenticity or admissibility in any proceeding, hearing, or trial of any documents.

1. The Republic objects to the Questions in their entirety to the extent that they impinge upon the Republic's sovereign dignity in violation of the "grace and comity" to which it is entitled as a sovereign state. Aurelius Capital Master, Ltd. v. Republic of Argentina, 589 F. App'x 16, 18 (2d Cir. 2014).

2. The Republic objects to the Questions as overbroad and not relevant to or reasonably calculated to assist in collecting on the judgment to the extent that they seek information and documents that are only relevant to assets that are immune from execution, including pursuant to the Foreign Sovereign Immunities Act ("FSIA"), see 28 U.S.C. § 1609. The Republic has not "waived its immunity from attachment in aid of execution or from execution either explicitly or by implication." 28 U.S.C. § 1610(a)(1). The Republic is a foreign sovereign with numerous assets that are exempt from attachment or execution under applicable Argentine, U.S., foreign, and/or international law--including, but not limited to, the FSIA, the Vienna Convention on Diplomatic Relations, the Vienna Convention on Consular Relations, other countries' laws relating to sovereign immunity, and/or another applicable protection for foreign state property. Such property includes, without limitation, diplomatic bank accounts, military bank accounts, diplomatic facilities, military facilities, and other government-owned facilities and assets used to provide essential services and perform core government functions.

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