Rule 26 Initial Disclosures - Chicago-Kent Blogs
Rule 26 Initial Disclosures
| |
|[p|UNITED STATES DISTRICT COURT |[p|
|ic|SOUTHERN DISTRICT OF NEW YORK |ic|
|] | |] |
| |______________________________ | |
| |NOREX PETROLEUM LIMITED No. 02 Civ. 1499 (LTS)(KNF) | |
| | | |
| |Plaintiff | |
| |v. | |
| |ACCESS INDUSTRIES, INC.; | |
| |Et. al. | |
| |Defendants. | |
| |______________________________ | |
| | | |
| |PLAINTIFF’S RULE 26(a)(1) INITIAL DISCLOSURES | |
| | | |
| |I. INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION | |
| |THAT MAY BE USED TO SUPPORT NOREX’S CLAIMS: | |
| | | |
| |Plaintiff’s initial disclosure is made without the benefit of any discovery and prior to Defendants’ answers. Plaintiff reserves the | |
| |right to amend its disclosures to add additional witnesses. | |
| | | |
| |A. Individuals Associated With Plaintiff | |
| | | |
| |1. Phillip Murray | |
| |Norex Petroleum Limited | |
| |#530 734 7th Avenue SW | |
| |Calgary, Alberta T2P P38 | |
| | | |
| | | |
| |Information includes: full knowledge of dispute | |
| | | |
| |2. Alex Rotzang | |
| |Norex Petroleum Limited | |
| |#530 734 7th Avenue SW | |
| |Calgary, Alberta T2P P38 | |
| | | |
| | | |
| |Information includes: full knowledge of dispute | |
| | | |
| |B. Individuals and Entities Affiliated with Defendants | |
| | | |
| |1. Joseph Bakaleynik | |
| |730 5th Avenue, 20th Floor | |
| |New York, NY 10019 | |
| | | |
| |Information includes: full knowledge of dispute and specific relevant conduct of OAO Tyumen Oil Company. | |
| | | |
| |2. Alan Bigman | |
| |730th Fifth Avenue, Suite 1906 | |
| |New York, NY, 10019 USA | |
| | | |
| |Information includes: full knowledge of dispute and specific relevant conduct of entities such as Novy Petroleum Finance Ltd and OAO | |
| |Tyumen Oil Company. | |
| | | |
| |3. Leonard Blavatnik | |
| |1009 Park Avenue, Apt 5A | |
| |New York, NY 10028 | |
| | | |
| |Information includes: full knowledge of dispute from 1997 to date | |
| | | |
| |4. Gillian Norah Caine | |
| |8th Prospect Hill, Douglas, | |
| |Isle of Man, IM1 1EJ | |
| | | |
| |Information includes: full knowledge of role of Slush Fund entities in dispute and money laundering activities of entities such as | |
| |Inverforth Properties Limited, Aston Trustees Limited (f/k/a Aston Corporate Management Limited), Aston Corporate Trustees Limited, | |
| |Banstead Enterprises Limited, Lamport Trading Limited, Redhill Properties Limited, Ringford Investments Limited, Ringford Shipping | |
| |Limited, Sandwell Enterprises Limited, Wasdale Limited and Watford Limited. | |
| | | |
| |5. Philip Mark Croshaw | |
| |The Avenue | |
| |Sark, | |
| |Channel Islands | |
| | | |
| |Information includes: full knowledge of role of Crown and Slush Fund entities in dispute and money laundering and tax evasion activities | |
| |of Crown Trade Limited, Inverforth Properties Limited, Lamport Trading Limited, Redhill Properties Limited, Sandwell Enterprises Limited,| |
| |Wasdale Limited and Watford Limited. | |
| | | |
| |6. Susan Christine Cubbon | |
| |8th Prospect Hill, Douglas, | |
| |Isle of Man, IM1 1EJ | |
| | | |
| | | |
| |Information includes: full knowledge of role of Crown and Slush Fund entities in dispute and money laundering activities of entities such| |
| |as Inverforth Properties Limited, Aston Trustees Limited (FKA Aston Corporate Management Limited), Aston Corporate Trustees Limited, | |
| |Banstead Enterprises Limited, Lamport Trading Limited, Redhill Properties Limited, Ringford Investments Limited, Ringford Shipping | |
| |Limited, Sandwell Enterprises Limited, Wasdale Limited and Watford Limited. | |
| | | |
| |7. Simon Peter Elmont | |
| |Le Fregondee, | |
| |Sark, Chanell Islands | |
| | | |
| | | |
| |Information includes: full knowledge of role of Slush Fund entities in dispute and money laundering activities of entities such as | |
| |Banstead Enterprises Limited, Crown Trade Limited, Inverforth Properties Limited, Lamport Trading Limited, Redhill Properties Limited, | |
| |Sandwell Enterprises Limited, Wasdale Limited and Watford Limited. | |
| | | |
| |8. Mikhail Fridman | |
| |Alfa Group | |
| |107078 Moscow, | |
| |Mashi Poryvaevoy Str., 9, “G”, Russia | |
| | | |
| |Information includes: full knowledge of dispute and relevant conduct of Alfa-related entities, including OAO Alfa-Bank; Alfa Finance | |
| |Holdings, SA; Alfa Group Consortium; and OAO Tyumen Oil Company. | |
| | | |
| |9. David Gould | |
| |400 Route d-Esch | |
| |L-1471 | |
| |Luxembourg | |
| | | |
| |Information includes: Facts pertaining to involvement of Alfa Finance Holdings, S.A. in money laundering and tax evasion activities. | |
| | | |
| |10. James William Grassik | |
| |La Closette, Sark, | |
| |Chanell Islands, | |
| |GY9 0SB | |
| | | |
| |Information includes: full knowledge of role of Slush Fund entities in dispute and money laundering activities of entities such as | |
| |Banstead Enterprises Limited, Crown Trade Limited, Inverforth Properties Limited, Lamport Trading Limited, Redhill Properties Limited, | |
| |Wasdale Limited and Watford Limited. | |
| | | |
| |11. David Kenneth Griffin | |
| |97 Cronk Liauyt, Tromode Park, Douglas, | |
| |Isle of Man, IM2 5LR | |
| | | |
| |Information includes: full knowledge of role of Slush Fund entities in dispute and money laundering activities of entities such as Aston | |
| |Trustees Limited (fka Aston Corporate Management Limited), Aston Corporate Trustees Limited, Banstead Enterprises Limited, Lamport | |
| |Trading Limited, Sandwell Enterprises Limited and Watford Limited. | |
| | | |
| |12. James Harmon | |
| |United States | |
| | | |
| |Information includes: History of TNK’s efforts to obtain loan guarantees from Ex-Im Bank, investigations of Chernogorneft bankruptcy in | |
| |connection with same and current use of proceeds guaranteed by Ex-Im Bank. | |
| | | |
| |13. Linda Jean Howe | |
| |179, Woodhouse Road, | |
| |London, | |
| |N12 9NN, United Kingdom | |
| | | |
| |Information includes: full knowledge of role of Crown entities in dispute and money laundering and tax evasion activities of Crown | |
| |Commodities Ltd. | |
| | | |
| |14. John Irving | |
| |United Kingdom | |
| | | |
| |Information includes: full knowledge of role of Crown and Slush Fund entities in dispute and money laundering and tax evasion activities | |
| |of Crown Commodities Ltd, Crown Resources, A.G. and Crown Trade and Finance Limited. | |
| | | |
| |15. German Khan | |
| |c/o OOO Alfa-Eco | |
| |21 Ul. Novy Arbat, | |
| |Moscow GSP-2 119992, Russia | |
| | | |
| |Information includes: full knowledge of dispute and relevant conduct of OOO Alfa-Eco and Tyumen Oil Company. | |
| | | |
| |16. Alexander Knaster | |
| |c/o Alfa Finance Holdings, S.A. | |
| |400 Route d-Esch | |
| |L-1471 | |
| |Luxembourg | |
| | | |
| |Information includes: full knowledge of facts pertaining to involvement of Alfa Finance Holdings, S.A. and various Alfa and Crown | |
| |companies in money laundering and tax evasion activities. | |
| | | |
| |17. Alfred Reingoldovich Kokh | |
| |Montes Auri | |
| |ul. Tverskaya 16/2, 6th Floor, | |
| |Moscow 10309, Russia | |
| | | |
| | | |
| |Information includes: full knowledge of dispute from 1997 to date including privatization of TNK and role of Novy Petroleum Finance Ltd. | |
| | | |
| |18. Simon Kukes | |
| |106 Central Park South, # 4A | |
| |New York, NY 10019 | |
| | | |
| | | |
| |Information includes: full knowledge of dispute from 1998 to date and specific relevant conduct of OAO Tyumen Oil Company; knowledge of | |
| |facts pertaining to relevant conduct of LT Enterprise, Inc. | |
| | | |
| |19. Alexey Kuzmichev | |
| |14 Little Adelphi, | |
| |John Adam Street, | |
| |London, SW2 | |
| | | |
| |Information includes: full knowledge of dispute and relevant conduct of Crown and Slush Fund entities, including money laundering and tax| |
| |evasion activities from 1994 to the present, and conduct of Alfa Finance Holdings, SA, Crown Resources A.G., Crown Trade and Finance | |
| |Limited (director), Eastmount Properties Ltd, Lamport Trading Limited and Futura. | |
| | | |
| |20. Joseph Louis Daniel Moss | |
| |17 Lime Tree Lodge | |
| |Montagu Gardens, Gibraltar | |
| | | |
| | | |
| |Information includes: full knowledge of role of Slush Fund entities and various Crown companies in dispute and money laundering | |
| |activities of Banstead Enterprises Limited, Beechville Trading Limited, Crown Group Investments SA, Crown Lux Holdings, Crown Trade and | |
| |Finance Limited, CTF Holdings Ltd., Fairfax Services Limited, Inverforth Properties Limited, Redhill Properties Limited and Wasdale | |
| |Limited. | |
| | | |
| |21. Oleg Nam | |
| |Nizhnevartovsk, Russia | |
| | | |
| |Information includes: Full knowledge of dispute, including witness intimidation, corruption of Russian court proceedings and illegal | |
| |takeover of Yugraneft. | |
| | | |
| |22. Pavel Nazarian | |
| |1203 Eurotowers, | |
| |Gibraltar | |
| | | |
| |Information includes: full knowledge of role of Slush Fund entities in dispute and money laundering activities of entities such as | |
| |Banstead Enterprises Limited, Inverforth Properties Limited, Redhill Properties Limited and Wasdale Limited. | |
| | | |
| |23. Peter Nesti | |
| |Seefeldstrasse 75, 8008, | |
| |Zurich, Switzerland | |
| | | |
| |Information includes: full knowledge of role of Crown entities in dispute and money laundering and tax evasion activities of Crown | |
| |Resources, A.G. | |
| | | |
| |24. Dmitry Plouzhnikov | |
| |Timberscombe, 8 Linersh Wood, Bramley, | |
| |25 Surrey, GU5 OEE, UK | |
| | | |
| |Information includes: full knowledge of role of Crown and Slush Fund entities in dispute and money laundering and tax evasion activities | |
| |of Crown Commodities Ltd., CTF Holdings Limited, Novy Petroleum Finance Limited, Redhill Properties Limited and Watford Limited. | |
| | | |
| |25. Vladimir Plouzhnikov | |
| |c/o Crown Resources AG | |
| |33 Cavendish Square | |
| |London | |
| |W1M 9HF | |
| |United Kingdom | |
| | | |
| |Information includes: Full knowledge of role of Crown entities in dispute and money laundering and tax evasion activities of Crown Trade | |
| |and Finance Limited, CTF Holdings Limited, Lamport Trading Limited and Eastmount Properties Limited. | |
| | | |
| |26. Bogdanus Bonus Prana | |
| |LT Enterprise, Inc. | |
| |250 Saffrey Square | |
| |Nassau | |
| |Bahamas | |
| | | |
| |Information includes: Knowledge of facts pertaining to relevant conduct of LT Enterprise, Inc. | |
| | | |
| |27. Paul Rodzianko | |
| |Access Industries, Inc. | |
| |730 5th Avenue, 20th Floor | |
| |New York, NY 10019 | |
| | | |
| |Information includes: Knowledge of facts pertaining to relevant conduct of Access Industries, Inc. | |
| | | |
| |28. Christian Rosenow | |
| |Eigenheimstr. 29, 8700 Kusnacht | |
| |Liechtenstein | |
| | | |
| |Information includes: Knowledge of facts pertaining to role of Crown Finance Foundation and other Crown entities in entities and money | |
| |laundering and tax evasion activities. | |
| | | |
| |29. Cristopher Andrew Sayer | |
| |c/o Crown Resources AG | |
| |33 Cavendish Square | |
| |London | |
| |W1M 9HF | |
| |United Kingdom | |
| | | |
| |Information include: full knowledge of role of various Crown companies in dispute and money laundering activities of Crown Commodities | |
| |Limited | |
| | | |
| |30. Dr. Norbert Seeger | |
| |Rechtsanwalt, Vaduz | |
| |Liechtenstein | |
| | | |
| |Information includes: Knowledge of facts pertaining to role of Crown Finance Foundation and other Crown entities in money laundering and | |
| |tax evasion activities. | |
| | | |
| |31. Elliot Spitz | |
| |14 Green Lane | |
| |London, NW4 2NN, UK | |
| | | |
| |Information includes: full knowledge of role of Crown and Slush Fund entities in dispute and money laundering and tax evasion activities | |
| |of Crown Commodities Ltd, Crown Resources, A.G. and Crown Trade and Finance Limited. | |
| | | |
| |32. Alexander Tolchinsky | |
| |c/o Alfa Finance Holdings, S.A. | |
| |400 Route d-Esch | |
| |L-1471 | |
| |Luxembourg | |
| | | |
| |Information includes: Facts pertaining to involvement of Alfa Finance Holdings, S.A. in money laundering and tax evasion activities. | |
| | | |
| |33. Victor Vekselberg | |
| |111 West 67th Street, Apt 30A | |
| |New York, NY 10023 | |
| | | |
| |Information includes: full knowledge of dispute and relevant conduct of AS Naftaco Industrial Partners Limited, Renova Inc., ZAO Renova | |
| |and OAO Tyumen Oil Company. | |
| | | |
| |34. John Whitehead | |
| |United Kingdom | |
| | | |
| |Information includes: full knowledge of role of Crown and Slush Fund entities in dispute and money laundering and tax evasion activities | |
| |of Crown Commodities Ltd, Crown Resources, A.G. and Crown Trade and Finance Limited. | |
| | | |
| |35. Paul Joseph Williams | |
| |La Colombier, Sark, Channel Islands, | |
| |UK, GY 9 OSF | |
| | | |
| |Information includes: knowledge of dispute and relevant conduct of Alfa Finance Holdings, SA from at least 1999 to date. | |
| | | |
| |36. Franz Wolf | |
| |211, Portland House, | |
| |Glacis Road, Gibraltar | |
| | | |
| |Information includes: full knowledge of role of Crown entities in dispute and money laundering and tax evasion activities of CTF Holdings| |
| |Ltd. | |
| |C. Third-Party Witnesses | |
| | | |
| |1. Dr. Samuel M. Bennett | |
| |BP p.l.c. | |
| |1 St James's Square | |
| |London | |
| |SW1Y 4PD | |
| | | |
| |Information includes: Full knowledge of manner in which TNK and other Alfa-related entities illegally acquired an interest in various | |
| |subsidiaries of Sidanko and harmed American and other Western investors thereby. | |
| | | |
| |2. David Chalmers | |
| |Custodian of Records | |
| |Bayoil (USA), Inc. | |
| |909 Texas St., Ste. 202 | |
| |Houston, TX 77002 | |
| | | |
| |Information includes: Knowledge of facts and documents pertaining to the international tax evasion and money laundering schemes. | |
| | | |
| |3. Howard Chase | |
| |BP Amoco | |
| |Washington, DC | |
| | | |
| |Information includes: Full knowledge of manner in which TNK and other Alfa-related entities illegally acquired an interest in various | |
| |subsidiaries of Sidanko and harmed American and other Western investors thereby. | |
| | | |
| |4. Alistair Graham | |
| |BP p.l.c. | |
| |1 St James's Square | |
| |London | |
| |SW1Y 4PD | |
| | | |
| |Information includes: Full knowledge of manner in which TNK and other Alfa-related entities illegally acquired an interest in various | |
| |subsidiaries of Sidanko and harmed American and other Western investors thereby. | |
| | | |
| |5. Nikolay Gulidov | |
| |Arbat, 35, office 627 | |
| |Moscow 121835 | |
| | | |
| |Information includes: full knowledge of facts pertaining to forgery of corporate documents. | |
| | | |
| |6. Jim Housman | |
| |Larnaca, Cyprus | |
| | | |
| |Information includes: Knowledge of facts pertaining to armed takeover of Yugraneft Base in the Malo-Chernogor Oil Field. | |
| | | |
| |7. Lyudmilla Kondrashina | |
| |Arbat, 35, office 627 | |
| |Moscow 121835 | |
| | | |
| |Information includes: full knowledge of dispute | |
| | | |
| |8. Vladimir Mekler | |
| |World Trade Center, entrance 3 (Mercury), room 1805 | |
| |Krasnopresnenskaya nab., 12 | |
| |123610, Moscow, Russia | |
| | | |
| |Information includes: Knowledge of facts pertaining to the June 28, 2001 Yugraneft shareholder meeting. | |
| | | |
| |9. Lyle Nelson | |
| |Halliburton Energy Services | |
| |10200 Bellaire Blvd | |
| |Houston, TX 77072 | |
| | | |
| |Information includes: Knowledge of facts pertaining to armed takeover of Yugraneft’s Malo Chernogor base and efforts to force Yugraneft | |
| |employees to enter employment contracts with TNK. | |
| | | |
| |10. Zinaida Pushkarenko | |
| |Nizhnevstovsk | |
| |Tyumen Region, Russia | |
| | | |
| |Information includes: Knowledge of facts pertaining to attempted bribery, threats of violence against her person and orchestration of | |
| |criminal charges against Kondrashina. | |
| | | |
| |11. Alexander Radov | |
| |Yugraneft Corporation | |
| |Arbat, 35, office 627 | |
| |Moscow 121835 | |
| | | |
| |Information includes: Knowledge facts pertaining to witness tampering and intimidation. | |
| | | |
| |12. Phil Rogers | |
| |Canada | |
| | | |
| |Information includes: Knowledge of facts pertaining to armed takeover of Yugraneft’s Malo Chernogor base and efforts to force Yugraneft | |
| |employees to enter employment contracts with TNK. | |
| | | |
| |13. Robert Shepard | |
| |BP Amoco | |
| |535 Madison Avenue | |
| |New York, NY 10022 | |
| | | |
| |Information includes: Full knowledge of manner in which TNK and other Alfa-related entities illegally acquired an interest in various | |
| |subsidiaries of Sidanko and harmed American and other Western investors thereby. | |
| | | |
| |14. Byron Sprawls | |
| |Halliburton Energy Services | |
| |10200 Bellaire Blvd | |
| |Houston, TX 77072 | |
| | | |
| |Information includes: Knowledge of facts pertaining to armed takeover of Yugraneft’s Malo Chernogor base and efforts to force Yugraneft | |
| |employees to enter employment contracts with TNK. | |
| |15. Lory Sultanov | |
| |Canada | |
| | | |
| |Information includes: Knowledge of facts pertaining to armed takeover of Yugraneft’s corporate office in Nizhnevartovsk on June 29, 2002,| |
| |including acts of intimidation, destruction of evidence and cutting off of all means of communication. | |
| |16. Alexey Timoshkin | |
| |Law Firm Mir, Moscow | |
| | | |
| |Information includes: Knowledge of facts pertaining to witness tampering and intimidation. | |
| | | |
| |17. Custodian of Records | |
| |ABN Amro Bank, New York (an affiliate of ABN Amro North America, Inc.) | |
| |500 Park Avenue | |
| |New York, NY 10022 | |
| | | |
| |Information includes: Transactions and money laundering activities of Slush Fund entities and specific involving LT Enterprise Limited, | |
| |Crown Trade and Finance Ltd. and Flora-Moskva Bank. | |
| | | |
| |18. Custodian of Records | |
| |Bank of New York | |
| |1 Wall Street | |
| |New York, NY 10286 | |
| | | |
| |Information includes: Records pertaining to damage to use holders of ADRs of Chernogorneft as a result of the corrupt bankruptcy and | |
| |subsequent stripping of assets of Chernogorneft. | |
| | | |
| |19. Custodian of Records | |
| |Chase Manhattan | |
| |One Pennsylvania Plaza | |
| |New York, NY 10001 | |
| | | |
| |Information includes: Knowledge of documents pertaining to TNK’s use of Ex-Im Bank loans and objections to same by U.S. State Department | |
| | | |
| |20. Custodian of Records | |
| |Commerzbank, AG | |
| |2 World Financial Center, Fl 33 | |
| |New York, NY 10281-1008 | |
| | | |
| |Information includes: Knowledge of documents pertaining to TNK’s use of Ex-Im Bank loans and objections to same by U.S. State Department | |
| | | |
| |21. General Counsel | |
| |Depository Trust & Clearing Corporation | |
| |55 Water Street | |
| |New York, New York 10041 | |
| | | |
| |Information includes: Records pertaining to damage to use holders of ADRs of Chernogorneft as a result of the corrupt bankruptcy and | |
| |subsequent stripping of assets of Chernogorneft. | |
| | | |
| |22. Custodian of Records | |
| |Deutsche Bank AG (fka Bankers Trust of New York ) | |
| |31 West 52nd Street | |
| |29th Floor | |
| |New York, NY 10019-6160 | |
| | | |
| |Information includes: Transactions and money laundering activities of Slush Fund entities and specific transactions involving LT | |
| |Enterprise Limited, Crown Trade and Finance Ltd. and foreign correspondent banks, such as Lateko Bank and Flora-Moskva Bank. | |
| | | |
| |23. Custodian of Records | |
| |National Westminster Bank (aka “NatWest”) | |
| |101 Park Avenue | |
| |New York, NY 10178 | |
| | | |
| |Information includes: Financial Transactions and money laundering activities of Sandwell Enterprises and Eastmount Properties Limited. | |
| | | |
| |24. Custodian of Records, Responsible Auditors | |
| |Pricewaterhouse Coopers, LLC | |
| |1301 Avenue Of The Americas | |
| |New York, NY 10019 | |
| | | |
| |Information includes: Knowledge of accounting treatment of transactions related to case and relationships among Slush Fund entities and | |
| |Alfa Group Consortium, including treatment of LT Enterprises as a “related party” for financial reporting purposes. | |
| | | |
| |25. Custodian of Records, Director | |
| |Simpson, Spence & Young | |
| |46 Southfield Avenue | |
| |Three Stamford Landing | |
| |Suite 100 | |
| |Stamford, CT 06902 | |
| | | |
| |Information includes: Knowledge of facts and documents pertaining to fraudulent payment of “address commissions” to Slush Fund companies.| |
| | | |
| | | |
| |26. Custodiam of Records | |
| |TotalFinaElf Services, Inc. | |
| |444 Madison avenue - 42nd floor | |
| |New York - NY 10022 | |
| | | |
| |Information includes: Knowledge of documents pertaining to TNK’s use of Ex-Im Bank loans and objections to same by U.S. State Department;| |
| |knowledge of facts and documents pertaining to the international tax evasion and money laundering schemes. | |
| | | |
| |27. Directors and Custodian of Records | |
| |TPT Ltd. | |
| |Cayman Islands | |
| | | |
| |Information includes: Full knowledge of manner in which TNK and other Alfa-related entities illegally acquired an interest in various | |
| |subsidiaries of Sidanko and harmed American and other Western investors thereby. | |
| | | |
| | | |
| |II. CATEGORIES AND LOCATION OF DOCUMENTS: | |
| | | |
| |1. Documents related to formation of Yugraneft, including, but not limited to, copies of agreements, corporate documents, correspondence | |
| |and facsimiles. | |
| | | |
| |2. Documents related to corrupt TNK privatization, including, but not limited to, copies of agreements, government decrees, court | |
| |pleadings and decisions, correspondence, reports, and facsimiles. < | |
| | | |
| |3. Documents related to corrupt Russian bankruptcies including, but not limited to, copies of agreements, court pleadings and decisions, | |
| |correspondence, and facsimiles. | |
| | | |
| |4. Documents related to Blocking of the Ex-Im Loan Guarantees to TNK, including, but not limited to, copies of correspondence, | |
| |agreements, facsimiles and e-mails. | |
| | | |
| |5. Documents related to the disputes over oil owed to Yugraneft, including, but not limited to, copies of agreements, court pleadings and| |
| |decisions, correspondence and facsimiles. | |
| | | |
| |6. Documents related to takeover of Yugraneft by TNK and/or its affiliates, including, but not limited to, corporate documents, court | |
| |pleadings and decisions, correspondence and facsimiles. | |
| | | |
| |7. Documents related to stripping of Yugraneft assets, including, but not limited to, bank account documents, promissory notes, | |
| |correspondence and facsimiles. | |
| | | |
| |8. Documents related to criminal proceedings brought in Russia against Kondrashina, Norex, and its executives. | |
| | | |
| |9. Documents relating to the existence and operations of various Slush Fund companies, including, but not limited to, corporate | |
| |documents, invoices, correspondence, facsimiles and e-mails. | |
| | | |
| |10. Documents relating to the money laundering and tax evasion activities of the defendants (including existence and operation of various| |
| |Slush Fund companies), including, but not limited to, corporate documents, invoices, correspondence, and various e-mails. | |
| | | |
| |11. Documents related to the action brought by Yugraneft in Russia after commencement of this action against Norex including court | |
| |pleadings and decisions. | |
| | | |
| |All of the aforesaid documents are located at the Norex Petroleum Limited document repositories at the following addresses: | |
| | | |
| |#530 734 7th Avenue SW | |
| |Calgary, Alberta, T2P 3P6 | |
| | | |
| |Nicolaou Pentadromos Centre | |
| |Office 908, Block A | |
| |P.O. Box 123 | |
| |Limassol, Cyprus | |
| | | |
| |Arbat, 35 Office 627 | |
| |Moscow 121835 | |
| | | |
| | | |
| |III. COMPUTATION OF DAMAGES | |
| | | |
| |Norex has suffered damages, as follows: | |
| | | |
| |(1) The value of its shares in Yugraneft, which would be equal to 97% the value of the assets (i.e. physical plant, offices, equipment, | |
| |oil reserves, accounts receivable) less liabilities of Yugraneft. The approximate value of the major assets of Yugraneft were the | |
| |following: | |
| | | |
| |· Cash & Investments $40.4 million | |
| |· Malo-Chernogorneft Oil field $85.3 million | |
| |· Eastern oil field $76 million | |
| | | |
| |· Chernogorneft Oil Debt | |
| |Principal $11.2 million | |
| |Interest $170.6 million to $1,457 million | |
| | | |
| |· NNG Oil Debt | |
| |Principal $16.3 million | |
| |Interest $12.4 million to $18.6 million | |
| | | |
| |· Drilling service business $22.2 million | |
| |· ESP Supply business $ 5.2 million | |
| |· Oil Field Service business $ 38.4 million | |
| | | |
| |Total: $478 million to $1,770.6 million | |
| | | |
| |Note: Interest on the oil debt is calculated at the applicable Russian statutory interest rate compounded annually (minimum) and monthly | |
| |(maximum) | |
| | | |
| |(2) Approximately $18.7 million in accounts receivable and lost profits related to the management and supply contract between Norex and | |
| |Yugraneft which was breached when Defendants took control of Yugraneft. | |
| | | |
| |(3) Approximately $3.3 million in legal fees incurred in attempting to preserve Norex’s interest in Yugraneft through prosecution or | |
| |defense of actions in various courts. | |
| | | |
| |Total damages: $500 million to $1,792.6 million | |
| | | |
| | | |
| |IV. INSURANCE | |
| | | |
| |Plaintiff, at this time, is not aware of any insurance agreement under which any persons carrying on an insurance business may be liable | |
| |to satisfy all or part of a judgment which may be entered in favor of Plaintiff or to indemnify or reimburse Defendants for payments to | |
| |satisfy the judgment. | |
| | | |
| | | |
| | | |
| |Dated: October 14, 2002 By:________________________________ | |
| |Bruce S. Marks | |
| |David A. Niles | |
| |MARKS & SOKOLOV, LLC | |
| |1835 Market Street, 28th Floor | |
| |Philadelphia, PA 19103 | |
| |(215) 569-8901 | |
| | | |
| | | |
| |Harris N. Cogan | |
| |BLANK ROME TENZER GREENBLATT | |
| |405 Lexington Avenue | |
| |New York, NY 10174 | |
| |(212) 885-5000 | |
| | | |
| |ATTORNEYS FOR PLAINTIFF | |
| |NOREX PETROLEUM LIMITED | |
| | | |
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