20. JUL 200 17:39 In 7285 CHARLES RUSSELL P. 2/9 IN'THE HIGH COURT OF JUSTICE FAMILY DIVISION P DICIPAL REGISTRY Matter No. FD07D0213136 Dated 19e7JUNE 2007 B TWEEN: • -. Applicant-, a Sax M CHELL.E DANIQUE YOUNG d Respondent: .....:.......,:•:.,/ . ''',.\:.:: S OT GORDON YOUNG . .-- .- ..• ..: In Private -•-s.,., ‘.....° B tore Mr. Justice Moylan T':SCOT GORDON YOUNG of: (1 (2 (4) 3467 North Moorings Way,Coconut Grove, Miami,Florida 33133,USA do Mr GwIlym Davies, 82 TiddIngton Road, Stretford-upon-Avon, Warwickshire CV37 7E3A do Greenfield Horizon Ltd of3111 Floor, Nagico Building, Road Town, Tortola, British Virgin Islands c/o Mr GwIlyrn Davies, 82 TiddInglon Road, Stratford-upon-Avon, Warwickshire CV377BA do Condor Corporate Services Ltd of 15 Warwick Road, Stratford upon Avon, Warwickshire, 0V37 SYW, do Mr Gwilym Davies, 82 TicklIngton Road, Stratford-uponAvon,Warwickshire,CV377BA PENAL NOTICE IF OU SCOT GORDON YOUNG DISOBEY THIS ORDER YOU MAY BE HELD TO BE IN CO MPT OF COURT AND MAY BE IMPRISIONED, FINED OR HAVE YOUR ASSESTS D. AN OTHER PERSON WHO KNOWS OF THIS ORDER AND DOES ANYTHING WHICH HE PS OR PERMITS THE RESPONDENT TO BREACH 'THE TERMS OF THIS ORDER MAY AL 0 BE HELD TO BE IN CONTEMPT OF COURT AND MAY BE IMPRISIONED, FINED OR HA E THEIR ASSETS SEIZED. 110. 7285 CHARLES RUSSELL 20. JUN. 2007 17:39 P. 319 ORDER against SCOT GORDON YOUNG (the This Is a Worldwide Freezing injunction made an an the application of MICHELLE Moyi ce Justi Mr by Respondent') on 19 June 2007 Affidavits listed in Schedule A and the e read DANIOUE YOUNG Oho Applicant,. The Judg13 at the end of this Order. dule Sche In out accepted the undertaldngs set ondent. The Respondent has a right to This order was made without notice to the Resp graph 13 below. There will be a further para see it arge apply to the court to vary or disch 2007 tithe return date"). hearing in respect alIbis order at 10.30 am on 26 June F EEZING iNJUNCTIoN Respondent must not Until the return date or further order of the court,the s up to the value of £60 million; removefrom England and Wales any of his asset (1) value of his assets worldwide transfer or dispose of or deal with or diminish theof his nominee or Jointly with (2) whether held In his own name or In the name howsoever arising, up to the est another, nor any assets in which he has an inter . value same This prohibition includes in particular the following (but, limitation): for the avoidance of doubt without nt may have in any of the a. Any interest (howsoever held) that the Responde following properties: I. 1DG 29South Lodge,245 Knightsbridge,London,8W7 U. 39 Chester Terrace;London, NW1 4ND Ili. ch, High Dlone House, Oxford Road, Stokenchur 3S:ot HP1 , Buddrighemshire M London SW1 BOB Buckinghamshire Suite,26-27 Belgrave Square, v. 3647 North Moorings Way,Coconut Grove,Miami vi. e,0X20 1FA Wootton Place, Church Street, Wootton,Oxfordshir vii. 27 Eaton Square,London,SW1W 90F yid. 28 Eaton Square,London,SW1W 9DF ix. 29 Eaton Square,London,SW1W 9DF x. 23Wilton Crescent,London,SW1X xL Lincoln University Halls of residence. 2 Wycombe, 33133, Florida USA • NO. 7285 CHARLES RUSSELL .20. JUN. 2007 17:40 P. 4/9 b. In the event that any of the above properties have been sold, the Respondent's Interest in the net proceeds of sale thereof and/or any asset purchased wholly or in part with the net proceeds of sale; c. Any money standing to the credit of any bank account d. Any shareholding In Eseridex Limited(company number 04217280) e. Any loan notes Issued by Esendex Ltd f. Any interest In Boss Holdings Lid(company number 02838730)or its assets g. Any shareholding in Fosse Developments Ltd(company number04764639) h. Any interest in Star lane Estates Lid (company number 05506638)or its assets L My shareholding in Condor Corporate Services Ltd (company number 03713623) j. Any interest in Greenfield Horizon Ltd (a company registered in the British Virgin Isalnds with company number 1000867)or its assets k. Any shareholding in EPOSS Ltd(company number 03713623) I. Any shareholding In EPOSS plc m. My loan notes issued by EPOSS plc rt. Any shareholding in Honnington Investments Lid o. Any shareholding in Shipston Investments Ltd p. Any shareholding In Dominlon.Nomlnees Ltd q. Any shareholding in Parasol Participations Ltd r. Any shareholding in SMS Ltd (company number05716119) s. Any shareholding in NOG Ltd (company number 02584799) t. Any shareholding in iDlosks Lid u. Any shareholding In IDM Cityscape Ltd (company number 05611706) v. Any shareholding In !SENTRY Ltd (company number 05136224) w. Any shareholcUng In Allied Minds plc(company number 05361385) x. Any shareholding in Futuragene plc(company number 04001406) y. Any shareholding In Xenos Ltd (company number04069923) z. Any shareholding in Minster Ltd (company number 01759121) 3 1Œ285 CHARLES RUSSELL 20. JUN. 2007 17:40 P. 5/9 35) aa. Any shareholding In Mlivus Ventures Ltd (company number048231 bb. Any shareholding in Solar Breeze Ltd cc. Any shareholding In Canyonrose Ltd dd. My shareholding in Jaggersfield Ltd ce. Any shareholding in Readywood Ltd If. Any shareholding In Westcreek Holdings Ltd gg. Any sharehokfing in lake Golden Ltd t in any of the above, trie hh. In the event that the Respondent has sold any interesthereof andtor any asset sale of ds procee net the In t Interes Respondent's sale; of ds procee net the with purchased wholly or In part N. Any interest the Respondent may have in the fixtures and at)Wooton Place,Oxford; fittings at(or tonmerly B. The Respondent's Roger Dubs& wristwatch; kk. Any asset held in or by or Via the 10!mom Fouodation; Il. Any asset held In or by or via the Espino Foundation; mm. 5. 8 7. 8. 9. Any asset held on the Respondent's behalf by GwiMm Davis. which he has the For the purpose of this order the Respondent's assets Include any asset The Respondent own. his were if it as with deal or e of dispos power,directly or Indirectly, to s the asset in control or Is to be regarded as having such power If a third party holds tions. t accordance with his direct orindirec Instruc aph 4 above are For the avoidance of doubt, the particular assets referred to attoparagr that they are extent the and If only above 3 aph' In paragr subject to the freezing Injunction . above) 5 aph assets of the Respondent(as the term is explained In parage cumbered value') of the If the total value free of charges and other securities ('unen the Respondent may million, £60 s exceed Wales and d Englan in assets dent's Respon or deal will them so of e dispos may or Wales and d Englan remove any of those assets from England and Wales In still long as the total unencumbered value of the Respondent's assets remains above 260 million. d and Wales does not from England and assets those of any exceed £50 million, the Respondent must not remove has other assets dent Respon the If them. of any with or deal ot e dispos Wales or must not outside England assets those With or deal of outside England and Wales,he may dispose r In or outside whethe assets his all of value mbered total unencu the as and Wales so long England and Wales remains above MO million. • on the Respondent The Applicant is at liberty to spree the application and this order as. overse U the total unencumbered value of the Respondent's assets in Englan 4 411 20. JUL 2007 17:40 CHARLES RUSSELL H0.1285 P. 6/9 P OVISION OF INFORMATION The Respondent must Within 72 hours of service of this order and to the best of his ability (1) inform the (1) Applicant in writing of all ids assets with an individual or collective value In excess of £.60,030 held worldwide whether la his own name or not and whether solely or jointly owned, giving the value, location and details of all such assets and PO set out the up to date position in respect of the proceedings that were Issued against him In the Queens Bench Division under claim no 11006X00957 and claim no H006=1635 and In the Chancery Division under claim number HCO6C01198. The Respondent may be entitled to refuse to provide some or all of this information on the grounds that he may incriminate him. (2) Within 4 days after being served with this order swear an affidavit confirming the above information which must be served on the Applicant's legal representatives. EX OPTIONS TO THIS ORDER 11. (1) This order does not prohibit the Respondent from spending E8,000 a week towards his ordinary living expenses, including by providing for the Applicant and the parties' children, and also a reasonable sum on legal advice and representation, provided that in each case he shall inform the Applicant's legal representatives of the bank account(s) or source of funds withdrawn and provide documentary evidence of the same. (2) This order does not prohibit the Respondent from dealing with or disposing of any of his assets in the ordinwy and proper course of business. (3) The Respondent may agree with the Applicant's legal representatives that the above spending limits should be increased or that this order should be varied in any other respect, but any agreement must be In writing. (4) This order does prevent the Respondent from complying with any obligations Imposed upon him by any orders that have,been made to date in the proceedings Issued in the Queen's Bench Division under claim no14Q08X00957 and daim no H006X01635 and in the Chancery Division under daim number H006001196. However. before complying with any such obligation he shall give the Applicant's legal representah'ves 24 hours notice in writing of (I) the obligation in question and (1i) the manner in which he intends to comply with the same and (Hi) provide documentwy evidence of the same. COST 12. e costs of this application are reserved to the Judge hearing the application on the return . d le. rA 20. JUN. 2007 17:41 NO. 7285 CHARLES RUSSELL P. 1/9 TION OR DISCHARGE OF THIS ORDER Anyone sewed with or notiSed of this order may apply to the court at any time during normal court hours to vary or discharge this order(orso much of it as affects that person), but they must first Inform the Applicant's legal representatives of their Intention to do so. If any evidence is to be relied upon In support of the application, the substance of It must be communicated In writing to the Applicants legal representatives in advance. RETATION OP THIS ORDER 14 A Respondent who is an Individual who is ordered not to do something must not do It himself or in any other way. He must not do It through others acting on his behalf or on his Instructions or with his encouragement. 16. A Respondent which is not an indhriduarwhich Is ordered not to do something must not do it Itself or by its directors, officers, partners,employees or agents or In any other way. P ES OTHER THAN THE APPLICANT AND RESPONDENT (1) Effect ofthis order 16. tt Is a contempt of court for any person notified of this order knowingly to assist in or permit a breach of this order. Any person doing so may be imprisoned, fined or have their assets seized. (2) Set off by banks 17: Is injunction does not prevent any bank from exercising any right of set off It may have in act of any facility which it gave to the respondent before it was notified of this order. (3) Withdrawals by the Responaent 18. • o bank need enquire as to the application or proposed application of any money withdrawn' y the Respondent If the withdrawal appears to be permitted by this order. (4) Persons outside England and Wales 19. (1) Except as provided In subparagraph (2) below, the terms of this order do not act or concern anyone outside the jurisdiction of this coud. The terms of this order will affect the following persons in a country or state (2) outside the jurisdiction of this court(a) the Respondent or his officer or agent appointed by power of attorney; (b) any person who. (I) Is subject to the jurisdiction of this coud; 8 20. JUN. 2007 11:41 HO. 7205 CHARLES RUSSELL P. 019 (1) has been given written notice of this order at his residence or place of business wIthin the jurisdiction of this court and (Ili) is able to prevent acts or omissions outside the jurisdiction of this court which constitute or assist in a breach of the terms of this order; and (c) any other person,only to the extent that this order is declared enforceable by or Is enforced by a court In that country or state. Assets located outside England and Wales 20 Nothing in this order shall, in respect of aesets located outside England and Wales, prevent any third party from complying withwhat it reasonably believes to be its obligations, contractual or otherwise, under (1) the laws and obligations of the country or state in which those assets are situated or under the proper law of any contract between itself and the Respondent;and (2) any orders of the courts of that country or state, provided that reasonable notice of any application for such an order is given to the Applicant's solicitors_ CO MUNICATIONS urtm THE COURT 21. All communications to the court about this order should be sent toThe Royal Courts of Justice,Strand, London WC2A 211, quoting the names of the parties and the Matter number given above_ The offices are open between 10 asn. and 4.30 p.m. Monday to Friday. SCHEDULE A AFFI AVITS The pplicant relied on the following affidavits1. First Affidavit of Michelle Danique Young sworn on 19 June 2007 together with its Inhibit. 1111104 SCHEDULE B UND AKINGS GIVEN TO THE COURT BY THE APPLICANT 1 if the court later finds that this order has caused loss to the Respondent or a third party, and decides that they should be compensated for that loss, the Applicant will comply with any order the court may make. 2 The Applicant will serve upon the Respondent together with this order practicable: as S0011 as copies oi the affidavits and exhibits containing the evidence relied upon by the Applicant, and any other documents provided to the court on the making of the application; 7 JUN. 2007 17:41 . /0 . CHARLES RUSSELL OD the Notice of Application; PR the Petition and the Applicant's Form A. 110. 7285—iP. 9/9 Anyone notified of this order will be given a copy of It by the Appricanfs legal representatives. The Applicant will pay the reasonable costs of anyone other than the Respondent which have been Incurred as a result of this order including the costs of finding out whether that person holds any of the Respondent's assets and If the court taterfinds that this order has caused such person loss, and decides that such person should be compensated for that loss,the Applicant will comply with any orderthe court may make. If this order ceases to have effect the Applicant will immediately take all reasonable steps to inform in writing anyone to whom he has given notice of this order. or who he has reasonable grounds for supposing may act upon this order, that it has ceased to have effect. NA E AND ADDRESS OF APPLICANT'S LEGAL REPRESENTATIVES The pplicant's legal representatives areCh - es Russell LLP 8— 0 New Fetter Lane, London EC4A 1RS Ref: AIGW/089635 Tel; 7203S000 Fa,c.d 2030200 Em - Miranda,f[sherechadesrussell.co.uk Oat 3 19 June 2007 •