Free Appendix - District Court of Delaware - Delaware

Case 1 :04-cv-01482-GIVIS Document 54-4 Filed 03/31 /2005 Page 1 of 4
COUNT IV
Violation of RICO § 1962(d) for Conspiracy to Violate §l962(a) I
Norex v. All Defendants Except Astons
421. The allegations of the above paragraphs are incorporated herein as if set
out in full. V
422. Pursuant to the Illegal Scheme, the above Defendants conspired among
themselves, and with others, to violate section §l962(a).
423. The above Defendants knowingly agreed among themselves to commit or
participate in at least two Predicate Acts in furtherance of the Conspiracy.
424. Given the complexity and far·reaching nature of the Conspiracy, coupled
with the number of instances in which the above Defendants engaged in the Predicate
Acts alleged herein, the Predicate Acts committed by the above Defendants could not
have been committed without coordination and agreement among the above Defendants
to knowingly panicipate in the Conspiracy.
425. As a direct and proximate cause of the above conspiracy, Norex suffered
damages in an amount in excess of $500 million. -
69
A - 603

Case 1 :04-cv—01482-GIVIS Document 54-4 Filed 03/31 /2005 Page 2 of 4
COUNT V
Violation of RICO § 1962(d) for Conspiracy to Violate §1962(b) I
Norex v. All Defendants Except Astons
426. The allegations _0f the above paragraphs are incorporated herein as if set
out in full.
427. Pursuant to the Illegal Scheme, the above Defendants conspired among
themselves, and with others, to violate sections §l962(b).
428. The above Defendants knowingly agreed to commit or participate in at
" least two Predicate Acts in furtherance of the Conspiracy.
429. Given the complexity and far-reaching nature of the Conspiracy, coupled
with the number of instances in which the above Defendants engaged in the Predicate
Acts alleged herein, the Predicate Acts committed by the above Defendants could not
have been committed without coordination and agreement among the above Defendants
to knowingly participate in the Conspiracy.
430. As a direct and proximate cause of the above conspiracy, Norex suffered
damages in an amount in excess of $500 million. —
70 ' "
A - 604

Case 1 :04-cv-01482-GMS Document 54-4 · Filed 03/31 /2005 Page 3 of 4
i COUNT VI
Violation of RICO § 1962(d) for Conspiracy to Violate §196Z(c)
Norex v. All Defendants
431. The allegations of the above paragraphs are incorporated herein as if set
out in full.
432. Pursuant to the Illegal Scheme, all Defendants conspired among _
themselves, and with others, to violate section §l962(c).
433. The above Defendants knowingly agreed to commit or participate in at
least two Predicate Acts in furtherance of the Conspiracy.
434. Given the complexity and far-reaching nature of the Conspiracy, coupled
with the number of instances in which the Defendants engaged in the Predicate Acts
alleged herein, the Predicate Acts committed by the Defendants could not have been
committed without coordination and agreement among the Defendants to knowingly
participate in the Conspiracy. ’
435. As a direct and proximate cause of the above conspiracy, Norex su&"ered
damages in an amount in excess of $500 million.
71
A - 605

Case 1 :04-cv-01482-GMS Document 54-4 Filed 03/31 /2005 Page 4 of 4 ·
WHEREFORE, Norex demands judgment against Defendants, as follows: i
1. Compensatory damages in excess of $500 million;
2. Treble damages RICO in excess ofS 1.5 billion;
4. Costs and attorney fees under RICO;
5. Such other relief u is just and proper.
M & SOKOLOV, LLC
By: .»
ce S. Marks,
Marks & Sokolov, LLC
1835 Market Street, 28"` Floor
Philadelphia, PA 19103
215-569-8901 (telephone)
215-569-8912 (telefax)
Attomeys for Plaintiff Norex Petroleum Limited
BLANK ROME TENZER GREENBLATT LLP
aze é i
Harris N. Cogan
Blank Rome Tenzer Greenblatt LLP -
The Chrysler Building
405 Lexington Avenue
New York, New York 10174
(212) 885-5000
Attomeys for Plaintiff Norex Petroleum Limited
Dated: /2}:/14.% .26, J vo 9.
A - 606