Free Exhibit to a Document - District Court of Delaware - Delaware

Case 1:04-cv-01482-GMS

Document 85-2

Filed 05/31/2005

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF DELAWARE ------------------------------------------------Davis International, LLC et al. Plaintiffs, -againstNew Start Group Corp, et al. Defendants. ------------------------------------------------DECLARATION OF BRUCE S. MARKS I, Bruce S, Marks, declare pursuant to the provisions of 28 U.S.C. §1746, as follows: 1. I am a member of the Bars of the State of Pennsylvania and New Jersey and of the law firm Marks & Sokolov, LLC, counsel for Plaintiffs Davis International, LLC, Holdex, LLC, Foston Management, LTD, and Omni Trusthouse, LTD. I submit this declaration in support of Plaintiff's Opposition to Defendants' Motion to Dismiss the Complaint Pursuant to the Doctrine of Direct Estoppel and to Enjoin Plaintiffs From ReFiling This Action. 2. During a legal conference in Budapest in May, 2004, I met with Sergey Gladyshev, with whom I had been previously acquainted. He has a very fine reputation in Moscow as a tax attorney and represents many Western clients in tax litigation. 3. He informed me that he had done a legal expert report in the London case on extradition of two former Yukos employees against whom the Russian Federation brought charges within its case against Yukos and that the report concluded that the Moscow Arbitrazh court proceedings involving Yukos had been influenced. He informed me that there was no other reasonable explanation for many of the decisions by the Court. No. 44-1482-GMS

Case 1:04-cv-01482-GMS

Document 85-2

Filed 05/31/2005

Page 2 of 2