MEMORANDUM OPINION
KAPLAN, District Judge.
In the late 1990s, Citibank, N.A. ("Citibank") agreed to make an entity controlled by Daniel Valente Dantas, a Brazilian banker, the sole general partner of an investment vehicle to which Citibank contributed the entire $728 million in capital. The vehicle now owns, through an elaborate holding company structure, a very substantial interest in Brasil Telecom S.A. ("Brasil Telecom"), a provider of fixed-line and...
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