Rule 26 Initial Disclosures

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

______________________________

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