1.

Blavatnik is one of the worlds wealthiest men with a fortune estimated at

$19.6 billion by Forbes. He emigrated from Russia to the US as an adult. He

amassed this fortune primarily in the rigged privatizations of Russian natural

resource companies in the 1990s. In order to gain control of formerly state owned

assets worth well over $10 billion for very minimal investment, Blavatnik

maintained deep ties to the Russian government, including Russian intelligence

agencies such as the FSB; such ties included bribery of Russian government

officials in charge of privatization. For example, according to private investigators

hired by British Petroleum (BP), German Khan [Blavatniks fellow board member

at TNK] continues to take care of Vladimir Rushailo [former Russian Minister of

Interior] and Victor Kalyuzhny [former Russian Minister of Fuel and Energy].

Khan is alleged to have been paying each $30-50,000 per month. Khan keeps a

separate cell phone with a decoder that is used exclusively for communication with

Kalyuzhny.A Furthermore, Blavatnik has orchestrated violence and murder in

order to gain control of such assets and also bribed and intimidated judges in order

to vastly expand his empire.

2. In addition, he has extensive ties to individuals (akin to mafia associates)

who are significant shareholders and board members in all of his main investments

(including TNK and RUSAL) and who have been widely and publicly reported to

have orchestrated violence, murder, illegal arms shipments and coercion of the

Russian judiciary in order to expand their empires.

3. Blavatnik has continued to maintain his strong ties to the Russian

government in order to protect his fortune. This is evidenced by the fact that his

vast fortune has been totally untouched by the Putin government. This is in stark

contrast to the adverse actions taken by Putin towards many other Russian

oligarchs.

4. Public evidence of Blavatniks extralegal use of force has been widely

reported and has been alleged in numerous US court filings. For example, Fatigue-

wearing militiamen armed with AK-47 assault rifles stormed Yugranefts [an oil

company] corporate offices in June 2001, acting on the orders of Blavatnik,

Vekselberg and others and took control of the company according to BloombergB.

5. In a lawsuit related to the above, the complaint stated: Defendants

[including Blavatnik] accomplished their illegal takeoverby sending armed

private militiamen carrying AK-47 machine guns to storm Yugranefts corporate

offices and oil fieldC Further in the complaint, an associate of Blavatniks (German

Khan, who like Blavatnik was a board member and significant shareholder in

TNK), threateningly stated, we eliminate those who go against us.D

6. A court affidavit filed in the above situation by an expert on Russia stated,

Blavatnik, Victor Vekselberg, German Khan and Mikhail Fridman [the four main

shareholders of TNK]are among the most wealthy and powerful Russian

oligarchs. TNK is notorious for its aggressive (even by Russian standards!)

takeover tactics. It is understood to largely control the government and courts in

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the Tyumen oblast and the Khanty-Mansiysk region. A source of partiality is

threats against judges or their families, if they render unsatisfactory decisions.

These threats can involve both physical harm and criminal charges brought by

compliant prosecutors based on manufactured evidence.E

7. In a similar situation where Blavatnik and TNK orchestrated the bankruptcy

and takeover of an oilfield controlled by BP, armed guards prevented the delivery

of a court order to delay it [the fraudulent bankruptcy]. It seemed unreal. John

Browne [CEO of BP] wrote in a 2010 memoir. We were a nave foreign investor

caught out by a rigged legal system.F An internal BP email related to the incident

stated we regard the entire bankruptcy process as invalidwe understand the fun

went right to the end [and we] were prevented by armed guards from entering the

Chernogorneft [BPs oil field] officesjust another day in Russia!G

8. In another chilling episode Blavatnik and his associates attempted to poison

the BP-appointed CEO of TNK, Robert Dudley, in order to intimidate him.H

9. According to The Economist, even Blavatniks fellow Russian oligarchs are

intimidated by his actions, If they just stuck to bribing judges, we could play that

game too, says one of TNKs may rivalsdisgusted by [TNKs] alleged resort to

the wicked stick of intimidation, rather than the harmless carrot of bribery.I

10. German Khan, a fellow board member and significant shareholder in TNK,

referred to The Godfather as a manual for life.J In reference to Khans habit of

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openly bringing guns to meetings, a Western diplomat stated, Our companies

dont like people who bring guns to meetingsK

11. Oleg Deripaska is the largest shareholder in RUSAL (Blavatnik is the second

largest). Deripaska has a long history of using violent tactics to assemble RUSAL,

the worlds largest aluminum company. For example, in a complaint filed in the

Southern District of New York, he was accused of, directly or indirectly

[committing] criminal acts including murder, extortion, mail and wire fraud and

money laundering. Further, These acts include the attempted murder and murder

of American Felix Lvov.L Indeed, Deripaska was deemed so dangerous that he

was denied a visa to enter the US due to ties to organized crime.M

12. Leonid Lebedev is a Russian oil trader who provided Blavatnik with the

seed capital that allowed Blavatnik to participate in the privatization of TNK in

the mid-1990s. Similar to many of Blavatniks other associates, Lebedev is a

dangerous individual. For example, he is accused in an Italian criminal court of

shipping 30,000 AK47 Kalashnikov rifles, 400 guided missiles, 10,000 anti-tank

missiles and 32 million rounds of ammunition which were seized on a ship, the

Jadran Express, in Venice. In this venture, Lebedev was collaborating with

Russian and Ukrainian mafia, former KGB agents, politicians and a shadowy

syndicate.N The payments for this large arsenal were routed through Sintez,

Lebedevs company and the very entity which provided Blavatnik with the seed

money for the TNK privatization.

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A
Exhibit A BP & Trident Memo on TNK, page 24.
B
Exhibit B Bloomberg Article (Blavatnik & Norex), page 2.
C
Exhibit C Norex Complaint, page 2.
D
Exhibit C Norex Complaint, page 9.
E
Exhibit D Norex Complaint (Black Affidavit), pages 4 & 5.
F
Exhibit E New Yorker Article (The Billionaires Playlist), page 12.
G
Exhibit F BP Email on Chernogorneft Seizure.
H
Exhibit E New Yorker Article (The Billionaires Playlist), page 19.
I
Exhibit G Economist Article (The Rules of War), page 2.
J
Exhibit E New Yorker Article (The Billionaires Playlist), page 10.
K
Exhibit G - Economist Article (The Rules of War), page 1.
L
Exhibit H Deripaska Complaint, page 2.
M
Exhibit I WSJ Article (Deripaska Denied Visa).
N
Exhibit J The Guardian Article (UK Bankers Link to Arms Plot)