Free Declaration - District Court of Delaware - Delaware

Case 1 :04-cv-00834-SLR Document 15 Filed 05/18/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
POR. THE DISTRICT OP DELAWARE
I
In re; ) Chapter ll
I
STONE & WEBSTER, INCORPORATED 1) Case No. 00-OZI42 (PJW)
et al., ) Jointly Administered
I Adv. No. 0l·7'/66 (PIW)
Debtors )
.... .,...”......E -m.,-."-.-. I
I
SAUDI AMERICAN BANK, )
Plaintiff )
I
v. )
)
THE SHAW GROUP INC., SWINC )
ACQUISTION THREE, INC., and )
STONE 8; IMEBSTER. ENGINEERING )
CORPORATION, et alt, I
Defendants )
________...........,_____,___._,.,s....s............».->
DECLARATION OF ARIF USMANI IN SUPPORT OF
PLAINTIFPS MOTION FOR ASSESSMENT OF DAMAGES
I, Arif Usmani, do hereby depose and state:
I. I am the Chief Risk Officer for Samba Financial Group (fomierl y Saudi American
Bank), resident in Riyadh, Saudi Arabia which is the head oftice ofthe Samba Financial Group.
This affidavit is made in support of PIaintiiI"s Motion for Assessment ot`Damages and
Memorandum in support thereof, which are being tiled herewith.
2. I am familiar with the facts surrounding this case, and have supervised or been a
member ofthe group responsible for supervising I<&LNG’s litigation and monitoring of the
bankruptcy cases since the outset ofI<.&LNG’s retention.
3. I have reviewed SAMBA”s documentation concerning its travel expenses.
rz<>s~s4as¤s tz ·>sr»sse<»~r»~>r>r

Case 1:04-cv-00834-SLR Document 15 Filed 05/18/2005 Page 2 of 2
4. Each item that is included in the documents attached hereto as ExhibitA is a
reasonable and necessary expense incurred by SAMBA in connection with SAMBA enforcing its
rights under the SWEC Guaranty. ExhibitA attached hereto and incorporated herein are
documents which detail the travel expenses incurred by SAMBA employees in connection with
this litigation. These travel expenses total $36,931.
5. There are no additional unpaid travel expenses.
6. As Chief Risk Officer I am fully familiar with the method and manner that
SAMBA uses and has used to calculate the interest under the credit agreement that Bugshan
Stone & Webster had with SAMBA. Under the credit agreement, interest has accrued and
continues to accrue on the outstanding principal at the rate of 7375% compounded monthly The
interest accrued under the credit agreement constitutes part of the obligations covered by the
SWEC Guaranty.
I declare under penalty ofperjury under the laws of the United States ofiAmerica that the
foregoing is true and correct Executed on May @. 2005. L
f l ,1 je
· <#=i · _
Arif Usrnanil I A H
- 2 ,