Cameron McKenna Attendance Note Client: Insurance Compmy Matter: Belle: Co - claims undu Solidtms' PI Insurance File Number. 121092/00010 Fee-Emu: NGRI of Attendance: Mceling at Mine Hans: Dm 20 June 2006 . Attending s: hen om jixehous: Capital 9 a CMS 6mm CMS Cameron McKan (3431265111) I Cameron McKenna Cameron McKenna following individuals were present at this meeting and daiined to be owcd the following approidniate mom's: 55in usseni 1 {sin {an ussernn ){on secured ?500,000 ?600,000 1! was not always absolutely clear whethet amounts referred to at this stag: were in sterling ot dollars] 5] explained that it had become apparent chat SY had been making promises without cash to back them up {er quite some dine uuw; approximately 5 or 6 yents. 5] said that, at this point his locus was to sort out Proycct Moscow. MEC commented that she found the structure of Project Moscow camemely confusing. replied that that was becaus: the deal was, in tact, confusing. 5) said. however, that he had it list of every participant in the ijecx, whieh he would be able to provide to MEC if 51:: wanted. 5] said that he believed in being open. In litigation, one has to be careful. but this was such a wmplu matter that he "thought that it was being completeiy uperont and honest" with MEC. said that in reviewing the project himself after the event he had "followed the money". He had wire nansfets back to find out wheie the money had gone. explained that he had liles af evidence of the money transfers, affidavits, surety documents, etc. In total, 8} thought that the sum involved in Project Moscow was approximately min, broken down ns follows: Jixehousc zabludnwiez (sin Stephen Kay/catnmse Berezovslti legal at Equitable seeun'ties US$3.75ni SY was fronting fox all of this, Fonniehev and Boris Bereaovsld go back a long way. Boris an nevet been seen to invest in Russia openly, however, for political reasons. Cameron McKenna (1411754 nn Cameron McKenna (um 7m 1m Cameron McKenna 5} said that jitthousc is in a diitetent situation, hecause theit undemhing was weied, to entotee heeause had been no eonsidet-ation", Jisehouse in the citonostanees is happy to waive any elaini it niay have we need to oousidet this hiethee). In eelation to Zahludowia, 3] said that the is that he has not made a claim in eelation to peojeet Moseow, only in telation to the ?21m, so this is one that they ate crying to do a "hack deal" on pattial eelease ofassets rot instance, shatea, to pay that off. 5] said that Bods Buczovski's elaiin would also "go" (?45m) in the deal he eonteniplated 5} said that Ian dealc of 75 had aheady xdused any intetest whatsoevet in telatioii to peojeet Masoow. 5} said that he could not eannot change the insutatiee position in tespeet of the Zuneh daitns, howeyet, as that had to do with 53's ne ee Legal at Equitable elaiin -- 5] said that this telated pittely to SB's negligence Bank of Scotland -- this dzim would be dischugad 100% uudcx line proposed Caineose thete would he a minox shonfall under the ptoieet Moseow settlement This could probably be negotiated away. lieehouse and Stteathets this would be dealt with 100% nodes Ptoieet Moscow. MEC queried what 5) meant when he xefened to 100%. 5] said that, to the extent that that is a tight ofindeniniaeation whete SB ean look to SY to pay the monies, each of those claims would "go away". said that he was saloilating what was on the tahle {oi the insuterst 51 said that he would ptoyide a spteadsheet with this information. He said that this would ptohahly he usslaao in total and, in deal was done with the Ttust, there would he an exoa hanging the total to ussisist said that if SB had been grossly negligent then he would not have my light to an indemnity fiom SY ptesuouably. He said that the law "got a hit sticky on this point following the unldatets tnseu in 2003, s; appeated to he suggesting that thete would only he a discount for SB it was done that SB has a right of indemnity ovee SY. SJ eonhenied that "in the fol in the sense that th would he wtapped up in Peojeet Moscow would he So fat as eoneetned those not "in the fold", 5] said that he thought that he could ptohahly deal with an of these on the seine basis (ie. dtaw up a settlement), S) appeated to be suggesting that the liability of SY to SE would have to he eleaily established were these niattets to he wrapped up in the Moscow deal. MEC said that we would need to think about the pnctiuliu'es. li 513 had to puasue elaitns against Sit in oidee to satisiy these claims then it would be {at El:va satisfactory horn out point oiyiew. 8] suggested that we might get the hw Society involved and that pethaps we should considet euly detenninatioti as a means of settling the issue SJ said that, in any even; some of tbs: people weie sufficiently dose to SY that the Ptojeet Moscow settlement would deal with it Howeyet, iithete ate othet people left out of the settlement, then SB would still he open to daimsi 1n the alteanatiye, suggested that thete might have to he some kind of contaihution on behalf of SB. (343126631) (Cg. Cameron McKenna said that Zuneh was alieady "in the fold" in some tespects. was not suae what they omently have nvet them 5] said that he tnight he able to hn'ng Zunch into the fold in inspect of the claim in telation to the seetanties that'was supposed to he being held hy Mt Benet and wete not as well 5] said that zutich cannot haiug a claim against SY, hetause he has cut a dealwith thehanltia eelatioa to the sale of Dione House, due to the chatge ova: the ptopetty. Taming to Mt Founicbcv, 51 said that that will also "go" (only ?270,000); 5] is doing a deal 5] that although the undettalsing was ou'gimfly lot [In] pans of the balance has aheady heen repaid and it is only [270,000 which is outstanding. Legal Equitahle secunties (Guy Davis) [8111. (I pointed out that this sum was entitely unpaeticulaiised). 5} said that we tould deduct {tom that sum the amount that rcodv: in telation tn ptoject Moscow That would still leave the claim in telation to the hast change which had not been duly tegstened ovet as chestet Tenaee and the allegations in telation to the Minstet shines. in telation to each of these claims, thete wete ot house also atguments as to whethea theae had heen any loss sutteted. Wilshaw and legal at Equitablc Secun'ties ?4m in tespeet of Ptoject Moscow. confusing because initially weae contacted sepatately hy Legal at Equitable and hy-- Hatvey Lawtence woalted rot SB,>>who intaoduced SY. Bemavski -- have him and his wife Elena Betezoysltaya in relation to 26/27 Belgeave Squat: ?4.15m. SJ confinned that you could negatd Betezovski and his wife as one and the same. Ben Andetson undettaldng for [5111, SJ said he was a wealthy blue chip uadeai Ben Andetson was owed ?511: hy 5'1, but this has not appeaaed on credimx's schedule. 5] did not lsnow whethet Ben Anderson had agteed with SB that he would not ptess it, which may be why it hasuit appeaeed s] was confident that Ben Andetson would (alas: deht ifwe asked him. . The deal would not he sttuctuted 'as an IVA, heeause it would not seave any put-pose othet than to fuethet delay mattets, hut the settlemnit would tepaesent 95% ot the debts Ifw: an-auged the settlement as an IVA, it would have an advantage of binding the Inland Revenue, hut then we would also have to talte insolvency pncfidouas onhoatd, which would diereaent consideiations into the equation. has been seeing SY's post as the tinghaadet of SY's cteditots. sv does not want the stigma of bankruptcy, this is something that he is despmtely crying to avoid Cuuendy haired-I7 an issue of oi at least as {at as we ate aware No one petson is taking anything Jixehouse is planning to have a genetal telaase and postponement of claims documents ie. full diselosnee, Going down this mute mitigates a substantial amount of the claim, which 5} felt that would he heuetin'al to the instuets. The claims odginally looked like it was going to he atound the ?35m math, but we got mote pteo'se this figure none down. 513 has actually made money with sy as well as having developed a petsonal relationship and :hechote he has a talqu (a belicv: him. There ate a lot of personal relationships It stake in this. (3431266111) Cameron McKenna 5] will ask as fol telease of the 21929 Eaton Square property which Lissa have already released In addition the Elect: investment shates A EPOS, MJG, SMS. In exehaoge, will start to sort out the insuretside of things. said that the asset schedule fax the Emezing iniunetion was wrong and asked if SY had informed us of the changes that needed to he made MEC eonhnned that SY had sent a declaration to that effeeh MEC explained to that following yestelday's reruns date heating we had put an additional ph in the older in order to make it clear that we were not seeking to attend the scope of the 01'ch when SY was not the beneficial owner of die assetsr However. whex: other puka claim to awn the assets, we would still xequile to see the documentary evidence in support of eiainr befox: we would xelmse chose assets. mac explained that she was seeing the insuters on Fn'day and will explain all ofthis to then They need to he kept in the loop as this will move quite quickly when it gets going. 5] asked MEC whether there was anything specific that he could assist mac with in the meantime mac xequested that he call off (at at least fax the time being), He was veey tenacious. asked whether mac would still like him to attend the meeting on Thursday. that it would still be helpful if eouldattend the nieenngwidi_, as she felt that it would help to use the situation. 5} eoniioned he would attend. 51 eeniniaited that on and off, he has had quit: a lot of dealings with_who,had aiways been very Edendly. s; has told sv to keep the hank on ride . . In relation to-, commented that his hark was worse than his hite He used to he partners with Philip Green, before they fell out, 5} said that he was definitely a threatening individual, hot that deep down he was quite a loveahle chap. In any event, he was definitely onnide s] asked what the Law Society was going to do. MEC said that the Law Society had intervnied into the practice. As it was the sole praen'ee and the poenee had ptaetieally disappeared after sv had gone off, it was now really in a run off. She did not know what they were planning to do in the iong run. Nam (343125401)