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S20 HAROOM HAIDER FILA GID fle Investigation Report of the Joint Investigation Team, Panama Case Volume V (Qatari Letters) Join Investigation Team Consttuted bythe ‘Implementation Beach of the Supreme Court of Pakistan Vide Order dated May 5, 2017 IRqyecno7no17 ISLAMABAD (Answers to Questions Raised by Honourable Supreme Court of Pakistan in is Order dated ‘5 May 2017 in case af C.MLA. No, 2939 of 2017 in Constitution Petition No. 29 of 2016 ete) aw [R. HAMAD BIN JASSIM BIN JAB! ‘The Honourable Bench, Supreme Court of Pakistan has directed the JIT 10 probe following question rated to leters of Qatari Prince; ’) Whether sulden appearance of his eters isa myth ora reality? PART 2: ground and Significance of Letters of Mr Hamad ALThanl 1. Pana Papers were released on 20" of April 2016 by ICU (Intemational Consortium of Investigative Jouraliss) Even before the release, the Sharif family through the interviews of Mr. Husssin Nawaz Sharif had accepted the ownership of the Avenfield apartments. Mr Hussain’ explanations were followed hy the addresses of Mian Muhammad Nawaz Shavif (ihe Prime Minister of Pakistan), which tried to explain the moans that were used to purchase these partments, Tn all the media interviews and addresses, thee was no mention ofan investment With the Royal family of Qatar after she claimed sul of GulStel Mills in 1980, As a matter of fact, the proceedings in Honourable Supreme Court of Pakistan hd been well under way and no ‘mention of this investment was made inthe concise statement of Respondent No I. It was on 5 of November 2016 thatthe council for Respondent No 6, 7 and 8 presented the first letter fiom Mr. Hamad A-Thani (copy attacked as Annexure ), followed by another leter on 22% of December 2016 (copy atsched as Annexure B). The letters ae important as they are the final ‘defence and explanation of Respondents of how these proceeds of Gulf tet, invested with the Royal family of Qatar in 1980, not only resulted in the Avenfield apartments becoming the ‘property of Sharif fiily, but practically all other businesses that were set up by the father oF sons ofthe Prime Minister Mian Muhammad Nawaz Sharif abroad, after two decades. SYZD HARON Investigation Methodology 2. Recording of the statements of the witnesses The JIT recorded statements of, i) Mian Muhammad Nava Sharif (Respondent No. 1, i) Mian Muhammad Skabibaz Shariff) Mr. Hussain Nasr Sharif (Respondent No.7) an, iv) Me. Hasan Nawaz Sharif (Respondent No. 8). [Excerpts of thor statements related fo two Quai letters are attached as Anmexure C. 3. Acauisiton of Documents/ Records by the Respondents. Despite prior notioes the Respondents (No.1, 6,7 & 8) fled to produce any document! record or evidence before the TT to corroborate contents of Qatar leters, which they were otherwise requited to produce before the JET in the light of Antisls 117, 119 & 129 of Qanoon-e-Shahadat 1984 and Section-B(aXS) (of National Accountability Ordinance 1999, 4, Request fo 7 JA) to Government of Emirates (UAE). ‘The JIT initiated request for Mutual Legal Assistance (MLA) to British Virgin Island (BVD, United Kingdom (UK), United Arab Emirates (UAE) and Switzerland to ‘oblain evidence to extabish the ownership of Nielson and Nescoll Offshore Companies (shareholders of Avenfield Apartments) and to collet evidence that could corroborate oF contradict the eters submited by Althani details are covered in Volume-9 of the J's Report. Hindings ofthe JIT 5, Infirmities! Contradiction n the to Qatari Letters, ‘The JIT analysed the to letters submitted by ARthani in the Honorable Supreme Cout of Pakistn, recorded and analysed the statements ofthe respondents, moved eters for mutual legal assistance to foreign jurisdiction, “These are discussed as hereunder SYZ0D HAROOWM AAIDBR GILA IT Saar Taeepi Hom Ovni ate “THF aa contradtons ‘Gea Ltr November 206) (EA 708, 4.15 aren 1980, Me Nias Mutaninad Shit ores hit deo invest een ont of ney in rel este bases of A+ Te fl in Qu Tera eghaton fa Bas ae ‘obo ined him aarp esto hat ine hat an arg sm of and 12 Millon Dis (AED 12, 00,00 ws cubated by Me, Mian Matuniod Shai, orisiting fom the Tear, “The popes iat 17, Flt #70 Flat 16, Pat # 16a ot Avenelé House, Pak ane, London wee sgl the omentip of two ofthe companies, eat sae cries of whisk wee pt daring ha imei Qtr. These wee prcased fom the proceeds of te real ae sine. On scout of lap ences he fimo, Me Minn Matra Shi ands oy ws te ope whet eae all expenses sng © he Proper, neta te ound et and service crn, ‘The sttemeat that the popes wee pctased fom he real ete bases conrad the positon sursueny ken when deulet venmast on inert aleited et Libor was. prsent fo ‘alesition ofp, "Te chim ht Ges dae? we hp a (Gerda ot provide he die tat who ‘waste csi ofthe sarer tat ne ee any reed provided © suport his hin, Sarasa = 1 can scl ht ring ie tne, Me Mian Maca Shc wish ht te ty hi vem a eta in tle int his Gens Mr nn Nava Sti, Teray, Doe ot provide wo provid is infrmatn sat sro cing eal. in contain so i mbes eer Irawced te “acenalh aod ater Aexthos sie over be Yeon of the SYBO HAL oow HAIDER GILAD SS WARE wae CNET BY inadicing band writen notes and a Wwodibes. Thetis ring oration a a the fa eter Mr, Haan Nae Sha ves suposed 0 be the sol ene oF the invest bat the “bons” made ‘lode payments mide to Haber Naver Stato ating up is snes wo yet ad 1 ete te a Towck ae | Queens Cour, Londen, Tie ies serous dubs abou the vera of te eae coum, ber) 36) Taraeraph fi 1 reponse to sh ques, I wish 1 rit a 190, Ma Mb ‘Sci (Mr Star, = longstanding and ‘tw bas perf my Sar, ade ‘nye, (he vesimen) of sppximatly tte mio AED ine real ett bsies fhe A-Thon fay, This loveseat was ade ty way of provision of cash, which was enon Prati in he elf rian at he ine of tie ivesnest and al, sven the longing ean. Beween ny fae Me Shai eatomay ay fe them to dobbs at Batwecs No deal oT long ang prop sade liber even exe aR a [AL the ead of 200, ar ening lt scr nd ot batons made ver the tem of teeta wae aro iat ae sour of apyoxiontely 5 $90,900 was dw Me: Sts. In loser Me, Husain Newz Shi was supposed 0 be te sole Deir ofthe nv bat the "Sarbons™ made Include payers mde 4 Hasan Nwaz Staci sting up his business elas SYED HAROOM HAID#R GILAD c!= cic wih MSF ws, ts [payee wd Yo ele ie a Tow sunt oe in wasted i 2006 by | ie Qucene Cour, Lonlon, Tis sous say ofthe delvery'© Mr Haman Nawaz | ieonsseney in the sace cast serious Shai? epee bearer stares of | dob about te versity of ee ete, ‘esc Lined and Nelan Enerpies mid, wie od een Hot dig hat ine in Gane 6. ‘The we of lack of documentation of investment It was claimed that no documentation was made for the sizable investment of AED 12 milion made by Mian Sharit withthe his father Mr, Febad Al-Than, Me, Husain Nawaz Shari tied to explain that neither his srandfather believed in documentation nor was it» norm at that time in the Gu fr such ocumenttion. This contention is, how . the Respondents in thet defence rated to establishment and sale of Gul Ses Mills, which is that proper documentation about sich in ‘arm, Keeping in view that Mian Sharif was the real owner of Gulf Stel Mills the contention that he was averse 1 any documentation also seems bascess. Regardless of what Mr Hussain ‘Nawaz. Shaft. lak of documentation for such a sizeable investment is implausible. 7. Theisiue of Cash payment and transfer, ‘The statement of Mr. Tarig Shati and his Affidavits eters ofthe Me. Al-Thani; and th Sale Agreement of Gulf Steel Mil (proved to be fake in response of MLA roquot) produced by the Respondents are inconsistent with each other. ‘the documentary and citumstanial evidence, when examined with provided record evidence, «donot indicate any cash payment to Me, Tarig Shafi by Mr. Alt on account of sale of remaining 25% shares of Gulf Stel Mills n 1980 forthe following reasons; 4, Inhis sutement before the JIT, Me Tasig Shafi conceded that he neither had met “Me. Fad Bin Joss Bin Jaber Al Thai, expecially during that period (1980) nor hd ever made any direct payment to Al Thani, He stated that he used to eocive SYED HAROON WAID#R GIL ASI Hos instructions fom Mian Sharif to deliver installments to different representatives ‘ofAI Thani, whom he neither knew nor had seen earlier His claim inthe afidavit of handing over the cash payments to Mr Fahad Athan is totally contradicted by his statement. He filed to produce any record receipt showing transfer of money fromm Mr. Ali to him or from him to AV Th (Mr, Tati Sha himself admited that he was authorized to handle oly small amounts of payments, largest being AED 60,000 that he ever handled in the period between 1974 to 1980, It would be therefore very unlikely that he was ‘asked to handle 2 million in cash all of sudden and to handle AED 12 milion in cash over a 6 mouth period. I also became clear thatthe reference made inthe affidavit about the general practice of dealing in eas in the Gulf in those times i ‘not consistent with his own assertion in the statement that he used to issue ‘cheques fr larger amounts. Ms. Tariq Shafi's claim of canying and handing over cash of AED million without any receipt or written acknowledgement isnot plausible as it has ‘been clearly mentioned inthe sale agreement of 1980 that bank guarantees wore kept for payment from Mr. AKI t him. This also belies his claim that all ‘payments were made on verbal instructions and tus Against AED 12 million received on account of sale of rem Gulf Steet Mills (if any), there were ibis tothe tune of AED 14 milion; ence, iis not plausible tha this sum was tanaerred to Mr, Tha in Real Estate, for investment Conclusion: The inconsistencies in statements of witnesses when reviewed ‘against available documentary evidence submitted by the respondents in the Honorable Supreme Court af Pakistan, definitively indicates that Mr, Tariq Shai ether received AED 12 millon from Mr. Abdullah Kayed Abi as sale proceeds of remaining 259% shares of Ali Stel Mills (erstwhile Gulf Stel Mill) aor did SY2O HAROOM Ihe hand over this claimed amount fo Mr. Al-Thani during 1980, Moreover the documentary evidence procured asa result of MLA response by UAE government described Inter in this setion conclusively rejects the possibilty of any cash transfer. Mr, Hssnin N vith AL-Thanl family during Mr. Hussain Nawaz Sharif was asked by the JET why, despite the fae that head been askee about the sources of income that helped establish the factory in Jesh, be had not mentioned inthe interview that the major share came fom pat ofthe prof onthe investment of AED [2 million; the le proceeds of Gulf Stel Mills, which was placed with Mr. Al-Thani by his grandfather in 1980? Also he ‘vas cteyorially asked sbout any asistance that he received from any person(s) belonging » Qatar would not have “This explaation, however, isnot convincing at all because the stating of tah upfront would infact resulted in staying away from the contoverses that were faced by the Sharif family because of late introduction of this evidence. As a rater of fit, the Qatari connection found no mention in all subsequent media talks by Me, Hussain Nawaz Sharif and the addresses ofthe Prime Minister. was the te source of purchase of the Avenfield Aparments and forien ‘ncomprehnsible consistencies in Statements of Respondents 4 Material difference between the submissions of Respondent No. 7 and [Respondent No.1 in Honourable Supreme Court of Pakistan. This important question was answered by Mr. Hussain Nawaz Sharif in an unconvincing manner The text of questions and answers relating to the contradiction between the stances of Mf. Husssin Nawaz Sharif and hs father are reproduced below as they < not need mh comment ‘Question: Did your father know when the settlement was made with Mr, Al Answer: Answer: “Thani io 2006 regarding the investment made by your grandfather and that asa result the Mayfair Apartments have been adjusted agains the residual amount and ownership bas been transfered in your name? He had the knowledge ofthe settlement as these things are discussed inthe family. [n't think that he knew the details like the amounts of disbursement made, ow do you then scsount forthe fact that he has made no mention in his submission before the Supreme Court of Pakistan during the proceedings of the Panama Case of the investment made by your randfither with Mt, Al-Thani and the settement resling in the ‘ownership ofthe Mayfair Apartments? He had a diferent Counsel, [think that he under the advice of his ‘Course uid st easider it appropiate to mention these fis inthe submissions made before the Supreme Court of Pakistan, Concusion that q ‘one of the Respondents andthe whole tuth wos not put before the. Honorable Supreme Court Shifting Stance of Mian Muhammad Nawaz Sharif (Respondent No. 1) before the JT. Although Mian Nawaz Sharif confirmed, in his statement before the JIT, that he had the knowledge ofthe investment made by Mian Sharif with the royal fenily of Qatar but he hardly seemed fo remember any details (1) Although saying that the sale proceeds of Gulf steel were used forthe businesses setup by his sons he did not remember the details. He did not remerber having sen the worksheet submited by his sons withthe CMA, ‘but in the end said hat he stood by all the submissions made by his sons ‘and daughters inthe Supreme Court, (@) He remained completely non-commital about the evo letes submited by ‘Me, Hamm Bin Jossim Bin Al-Thani in Honourable Supreme Court of Pakstan for defence of Respondents Nos. 6, 7 and 8. He initially declined to have rea the under reference tw letters but later stated that he might have seen theso. He also endorsed the corecness of these two letters bofve the JT, without being sure about she contents (8) Conclusion. His statment contradictad his stance taken in his submissions before the Honorable Supreme Cout of Pakistan and seemed cot to substantiate the stance taken by Mr. Hussain NawarStarif and othe rspnndont a8 the evidence (Qatar letters) his shihng of stance further weakened it. Ilan stnge Teen af lenting any cede tn 0 © Implausible Stance of Mr, Muhammad Shahbaz Shari: (1) Inti statement before the JT, he stated that he neither knew, nor cou he confirm, when, by what means and how much money, did Mr. Tariq ‘haf give to Mr. AL-Thani ater the sle of Gulf Stel Mills. However, his fuer, Mian Sharif and Mr. Tariq Shafi did make mention about some investment in the °805, (@)—Purhermore, he stated that he does not know whether proceeds fiom investment with Qatari Prince were used by Mr. Hassan Nawaz Sharif for stsblishment of his businesses in UK, Conclusion: The reluctance of key witnesses to discuss the details ofthis ‘evidence scoms to be a conscious effort to ster away ffom it to avoid furtter contradictions. This lack of knowledge about the investment with the Qatari family, by a witness so closely involved in the affairs ofthe {amily and the company. 0. Detneen first Ontari sited by the same respondent, a mesk apart 8. The first later of Mr. Hamad Al-Thani was submited inthe Hononible Supreme ‘Court of Pakistan on $ November 2016 by the Council epreseting Me, Hussain [Nawaz Shaif and other respondenss, however, the fist Affidavit of Me. Tarig ‘Safi, sgain submited on behalf of Mr, Hussain Nawaz Sharif dated (2/05/2017 Aid ot find any mention of the Qatr investenen. b. This despite the fact that Mr Tariq Shafi and Mr. Husssin Nawaz Sharif, sccording thei statements, were together in Dubai soon afer he release of ICU u. u Panama Papers, to get the documents of sale of gulf steel mill, Thus, they had plenty of tine for consultation and preparation ofthe contents ofthe Affidavit, ‘© Gometusion, This omission in she afidait of Me, Tara Shaft. tebe to he supreme Court of Pakistan therfore, Physical Transfer of the Bearer Shaves of Nielson and Nescoll Offshore Companies. Contradictory stance of Mr Hussain Nawaz, Me, Hussain Nawaz Sharif inthe CMA and his fst statement before the JIT had asserted that the bearer shares had been exchanged in early 2006 between Me [Nasir Khamis, the representative of Mr, ALThani and Me, Wagar Alumed, the Dasiness manager of Hassan’s frm without any receipt, He was also unable to larly explain as fo how the shares were sent to Minerva, whieh was the holding ‘compaay af Nescoll and Nielson. He also asserted tht as far asthe necessity of instructions to Minerva from Mr. Al-Thani regarding the transfer of bearer shares ‘of Nescll and Nielson are concerned, he didnot think they were required 3s it was the possession of bearer catifcatss that matters. Asked whether the ‘possession of bearer shares by anyone like Wagar make him the owner Me sean did not have any response ‘c.-Mr Mussas, however, in his statement dated 03 June 2017, changed his stance now insistng that on his instructions Me. Wagar Ahmed recsived the bearer shares by courier and send them by mailto Minerva 4d, Heconfimed, when repeatedly asked, that neither he nor Me, Wagar Ahmed ever saw the Beaer Shares themselves, e. _ Inthe statement Ms Maryam Nawaz also denied to have ever seen or possessed the bearer cetfcates, As por one of the clauses of the Trust Deed signed 2 between Me Hussain Nawaz Shaef and Ms, Maryam Safar) produced by him, tho “Truske (Ms, Maryam Safa)” was roquired to “hold” Bearer Shares on behalf of Mr. Hussain Nawaz Sharif Inthe event, whon both of them have never ‘even seen fese Bearer Shares, a6 per her statement, the autheniityfegaity of the document (Trust Deed) becomes doubtful The expet opinion filed on behalf of the pettioners of Gilead Cooper QC dated 13-2-17, fled throvgh CMA to Honourable Supreme Court of Pakistan also substantiate this legal contention {copy ofthe document is attached a8 Anmesure D. ‘Conclusions o ® @ Repeated change in stance of Mr. Hussain Nawaz Sharif before the JIT and even departure fom the reply submited in Honourable Supreme Cour of Pakistan indicates posibie efforts to conceal he ft. If Ms Maryam Safar did not soe, let alone, hold the bearer certificates scm that the se didnot full the requirement of being @ ust, ‘The stances of both these winesses clearly show that they could not satisfactorily explain how the bearer certificates were supposed to have ‘bee transfered from Althan o them. The fact that this whole episode is ‘ken out of the equation because of the response received from BVI ‘stolishing Ms Maryam asthe beneficial owner ofthe two eompanics, as detailed in volume 4 ofthis report, futher reinforces JT's coneusion that the sory ofbeaor certificate being handed over from Althan to Shari is totaly false and cooked up. The atemptt0 use faliied documents (0 Ihooswink the Apex Court of the land, as estblthed by the expert's reps also inthe Volume-IV, als establishes that the Qatari eter and the issus of bearer certificate is nothing more than an attempt to coverup the fet. 1B 12. Aud f sheet Attached with the Secon dated 22 December 2016, Mr, ALThini, tough this spreadsheet, bas tied to own! justify various investments made by sons of Respondent No. | in their businesses and properties from 2000 to 2006 (a under). However, nether he himself nor the Respondents could provide even ‘one corroboriing document! record to prove any banking transaction or connect the missing links, Findings of the JIT ith reference to various entries in attached spreadsheet are as under a. Admissibility as Evidence, The document cannot be acepied as evidence for ‘ot fulfiling Qanoon-e-Shabadat 1984. The IT's observations ae as under; thes ial document i is submit leserhead, date, signatures. or certification ete. (2) Theretuns in Rel Estate business are not linear. Contra, the pattern of the rate of annus intrest shown in the spreadsheet i consistent and linear, hence seems atta 7 ‘Inconsistencies in Statements of Sharif Family. The two key witnesses, Mc ‘Mussin Nawaz Shusif and Mr Hassan Naway Sharif gave conflicting statements wth gan to heir knowleda about entrigscontents of the spreadsheet (Excel shoe) attached wit the eters of Me Al-Thani which essentially was used top ‘the gaps identified inthe money tail o ® ® Mr, Hassan Nawac Sharif (Respondent No, 8) is on record stating that he either saw nor is aware about the existence of the said spresdshect, et alone its contents (On the other hand, Mr. Hussain Nawaz Shasif (Respondent No, 7) stated that it was in late 2005, that he eame to know about the detils of the transactions made previously on te instructions of Mian Muhammad Sharif during the process of so calld setlement with Me. AL-Thani However, according to him, he had no mean to check autbentiety of this document neither representative of Mr. Al-Thani showed him any ledgers cor rcord to comborate the entries inthe spreadsheet, ‘This makes the transactions given in the spreadsheet seriously ‘questionable, which could have only been explained by ALThani himself ‘Transactions shown for the Busineses! Accounts of Me, Hassan Nawaz Shari (US 3.72 Mion o @ (One ofthe expenditures tat have been shown in the spreadshest isthe provision of acy W Mb, Hass Naw Slat he yes whe ie was setting up bis business in UK inthe year 2000 to 2004, [Mr Hassan Nase, in is statement before the JIT, expined that Me. -Hussia Nawaz Sharif had sent him abou 2.4 milion GBP to help him set, up bis business without disclosing the source where the money was o ® o © Is coming fiom. He also confirmed tha he did not receive any money from anyone ese ‘Mr. Hussain Nawaz Shasif, onthe ter hand in his statement, said that ate discussion, ofthe expenditures already made, with Me, Nsir Khamis (Ghe representative of Mr. ALThani), he had sent a fax ofthe spreadsheet {0 Me Hassan Nawaz Shasit‘o confirm this transaction. (Mr. Hassan Nawaz Sharif, in his statement however, assuredly stated that he never remained involved, saw or possessed any documents! record, ‘his related to Qatar Prince or Mayfair properties. ‘The conflicting accounts of Mr, Hassan Nawaz. Sharif and Mr. Hussain [Nawaz Sharif clearly show thatthe investment with Me. Al-Thani and its istuesement to Me Hassan Nawae Sharif for setting up business in UK natfictally comest Conclusion: Jn_view of the non-production of any documents to somoborste the slams. made in the leer. the HIT believes that the aration ofthe eters submited by Mr Al-Than is not base on fics. ‘Settlement of AL Towfoek Case (US $ 8 Million o @ ‘The spreadsheet also shows payment made for settlement of Al Towfeek Case filed in Queens Bench Division (QBD), London. Mi Hussain Nawaz Shari was asked whether he verified from someone in the family that his cexpandinure had been made, He stat that thie verifetion could have beer done by his uncle Mian Muhammed Shahbaz Sharif but such verification was not possible ashe was notin Kingdom of Saudi Arabia at ‘hatte. This explanation also isnot convincing In eudited accounts of Hudsbiva Paper Mill Ltd for the year ended June 30, 2000, it was observed that an outstnding amount of Rs, 310.23 Millon on June 30, 1999, on account of Liabilities Against Assets Subjest to Finance Lease Payable to Al Towfeek for Investment Funds, Bahrain and was setled and converted into 2 Long Term Loan of Rs.494.960 nil ion during the yest according to the audited accounts ofthe company. @ 6 As per accounts of the company filed with the SECP, the aforesaid liabilities against assets subject to finance lease of Al-Towfeck were sted for US $ 8,000,000 on January 5, 2000. The settlement amount of USS 8 million was converted in to PKR @ Rs. 53.80US Dollar prevailing ‘on he date of settlement. The long term loan of R5.494.960 million was ‘bocked against the setlement of litilis against assets subject to finance lease. The audited accounts do not disclose the idenity ofthe lender who provided this long term lan to the company for adjustment of settlement amount to Al-Towfck, The status of this loan remained unchanged ill he lastaccounts were filed with SECP peraning othe period ended June 30, 2005, The shave disclosures are at variance from the stated positions taken by Respondent No. 6, 7 and 8 in their CMAs. According to Respondent No.7, he was informed bya representative of Al Tani fay of Qatar that US 8 Million were paid by thet family to AL Toweek Company in Janney 2000, in connection with the Decree issued by the ‘igh Court of Justice: Queen's Bench and the setement agreement ‘between the partes, Respondent No, 7 futher stated that he was informed bythe representative of Al Thai farsily tha the payment was made on the instructions of Mian Sharif out ofthe funds placed by him with them. Cogetusion: If the above stance taken by the Respondents is corect, than in that case, the setlement of Al Towieck Company was mad out ‘ofthe proceeds received ftom Althans onthe instructions of Mian Sharif, ‘thea in that ease, under the norms of accountng disclosures, it shoud have bow reflected in the accounts of Hudabiya Paper Mills id. as a Loan fiom Directors, as Mian Sharif was a Director ofthe company a the date of subsiion, instead of a Long Term Loan payable to an undisclosed lender, ‘The legal aspects of Al twfeck case are discussed in he Volume 4 of this report. 0 13, Response of UAE Government to MLA regarding Gulf steel, The whole defence of Respondents hinged on irvestment of AED 12 milion, from sale proceeds of 25 9 shares of exsowhile Golf Steel Mi fn 1980, with Me, Fahad Bin Jassm Bin Jaber Al Thani by Mian Sharif. A copy ofthe sale deed dated 14 April 1980 which was claimed to have been notorsed by notary public of Dubsi courts on 30 May 2016 was submitted in the Honorable Supreme Court of Pakistan by the respondents 6, 7,8. This stated position of Respondents has been found without any substance due to the following fact:- ‘a. In response to the Mutual Legal Assistance (MLA) request by the JIT, the Ministry of Justice, Government oF UAE, through a letter (Aamexure B) hasafer having vtifed the record of of competent authorities of UAE, namely the Dubai Cours systam certified that, © ® @ o Paragraph 1: That shar slo 25% agreement of 1980 of Ahli Steet Mill (erstwhile Gulf steel Mils) dted on 14/4/80 according to your (IT) request doesnot exist “That no transaction worth AED 12,000,000 (twelve million ditham) as sale proceeds of 25% shares of Ali Steel Mills (erstwhile Gulf Steet ill) ever tok place in name of Mr. Muhammad Tariq Sha Paragraph 3: “That no record could be found which indicate that oturization ofthis document was done by Notary Public of Dubai Courts 00 30/5/2016." ‘Coneluston: The document dat the rexpondents subi bexe the Howorable Supreme Court of Pakistan as sale document of 25% shares of, Eswhile Gulf steel mil and its ntorsaion having been proven by the response of UAE government isnot tue and is an ate to present false ‘evidence. The attempt to present such false evidence is matched by 8 prosenting leters which are based on hearsay and not supported by any : documentation, In any ease the purported source of money’ for investing vid the Qatar family docs not have any document, gsnvine ot ss. to 1 t_All subsequent wen “ tausnesses and ownership of Avenficld Apartments of the Sharif fils Hse do not have any baste 14, Specific Answer of the Question Raised by Honourable Bench based on JIT's 8. Question: Whether sudden appearance ofhis letter isa myth ora reality? b. Answer: ‘The facts that there were material contaditons in the statements of Respondents the hearsay nature ofthe lees with 20 documents to suppor the contention, thatthe affidavits of Tariq Shafi were found totally wanting as evidence were in themselves quite sufficient to state that the letters seemed a rayth rater than a reality. However the facts ar that (1) the response hy UAB: authorities to the MLA sent by TT establishes thatthe gulf steel agreement isa false docunent , which has been submitted inthe Apex Court by respondent 6,7 4 8 (2) he response to the MLA by the Financial Investigation Agency, BVI ‘stablishing that the panama leak document released by ICIS showing Ms | Maryam Safdar a the beneficial vmer ofthe companies i genuine (discussed in ‘etal in Volume-1V of this report) end lastly as per report ofthe document expert (ako diseussed in detail in volume 4 of the report) establishes that falsiied document of the two trusts have been prepared by respondent no 6, 7 ‘and 9 and submited in the Apex court mislead it to believe that the tusts documents were signed in 2006. On the streagth of the overwhelming ‘documentary evidence it is concluded thatthe appearance of eters of Qatar prince arotntally a myth 15, Conelusive Findings by the JIT. In view ofthe above, conclusive findings ofthe JIT 8, that eviderce gathered establishes that even the question of Mr. Tarig Shaft handing over AED 12 Million to Me. Fahad ALThan in 1980 does no arise b, that the spreadsheet is not an official document; i i submited without any Teerhead, date, signatures or certification ete, Thie_spronishect_has been constructed” os an afterthought to artificial teal ©. That after saving investigated the casein detail, examination of other witnesses and roccin of irefitable evidence ftom foreign jurisdiction, recording of the f sia 4. That the appearance of the two Its from Mr. Al-Than inthe Hanoursle Supreme Cour of Pakistan is totlly “Myth and not a elit, Part 16, Efforts to Record Statement of Me. ALThani for Verification of Qatari Letters The JIT analyzed the two leters of Mr. ALThani minutely in Tight of the documents avilable to it and the satements ofthe witnesses. It was flt essential that Me, Al-Thani be interviewed to ascertain the veracity of the contents of the laters subritted by him and sequire supporting documents! record 20 ‘Special arngements were made to ensure timely delivery of summons to Mr. AI ‘Thani, Comaily, the response ftom Me. AL-Thani remsinod wanting and lacked “urgeney. He wes given adequate time and muliple opportunites to appear before LIT (even a: Qaia), but to no aval, [Brief detaits along with of summons (copies atached as Annexure F) issued to ‘Mr. ALThani by the JIT and his responses (copies atached as Annexure G@) ‘hereto ae under: Received:19-6-17 Ser Date ‘Aetvities (| Isuei35-2017 [First Summon issued by JIT! Asked to appear before JIT on 24-5.2017 at Federal Judicial eceived:175-17 | Aetdems, slamabad @) | EmueDESZOIT | Second Summon Kswed by JIT” Asked to appear before JIT on 1-6-2017 at Federal Judicial eceived26.s17 | Aetdems, Islamabad @ | sue 2ES2017 | Response of Mr ATThand to First Summon he id not appear stating that “I hereby confirm and Received:t-617. | Veil thatthe two letters dated November 5, 2016 ‘and December 22,2016 respetively..vere signed ‘by me and Iam pleased to reconfirm the contents thereof i ight of the above confirmation, there is no requirement for my attendance “in the proceedings of th JT." IsueiT -62017 | Response of Me. ALThant to Second Summon | he didnot appear stating that “Unfortunatly itis rot possible for me to visit due to unavoidable citeumstances.....4 suggest that the members of SIT may visit me in Doha at a mutually agreeable | a eae™ @ |o- Taue2D6R07 Received 23-617 Tue 2662017] Received28.6-17 Third Summon isued by I The HiT deco that due tote importance of this piece of evidence {or the respondents it would travel to Qatar, despite the major contradictions, inconsistencies and legal infimities that ad come to light ducing the investigation. Despite the time constraints, it offer to record the statement of the Prince in Qaiaron one ofthe two days ie 28 oF 29 of June 2017 in the Pakistan High Commission in Dots, tar. | Response of Mr. AEThani to Third Sammon: In his reply instead of confirming the dates for interview, he stated that “I wish to obtain an acknowledgement from you that Lam not subject to the jurisdiction and the laws of Pakistan and that you confirm that Tam not subjet of any investigation o required wo appear before any court ‘of law of tribunal for any purpose whatsoever. However Ihave expressed my willingness to mest ‘your team in Doba in order to allow you verify in person the contents of both my letters submitted to the JIT” @ Tue PR0IT ReceivedS-7.17 Fourth Sammon sued by JIT! A detail response was sen to him explaining the legal issues ‘The JIT asked him to respond in timely manger as the report has 19 be submitted in the Honomble Supreme Court of Pakistan in ine. @ sues 72017 Received:7-7-17 Response of Mr, AThani to Fourth Summon: In his reply he stated “I reiterate that I do not recognize, and am not subjeet to Jurisdiction of Pakistani laws and Pakistani courts in any manner ‘whatsoever. Your statement that {have accepted and submited to the jurisdiction of Pakistan laws 2 ‘and cours i inappropriate and factually inoorect. “He again however asked the team to come and meet im ‘Legal Postion on Response of Mr. ALThani to Fourth Summon:(dnmesire H o ® ° ® © Mr. Thani, as adopted an evasive and evidently disingenuous stance with respect (© his willingness to coopes Iitoly, less than 72 hours before the final report ofthe IT te His last letter was received, Besides employing dilatory tactics, Mr. Thani has also categorically ‘efised to recognize tobe subject othe “jurisdiction of Pakistani laws and Pakistani courts in any manner whatsoever” (Ms. Thani has to-date also filed to formally confirm his aceptance of the proposed process and terms for he recording of his statement as se out in the mr. In his leter dated 26-6:2017 (which reached the JIT on 3-7-2017) in whic, for the frat time, he raised a number of conditions, compliance With which was beyond the powers and remit ofthe JIT and which even ‘otherwise wore in coafict with and inimical to the proposed process and tems fo the recording oF his statement as stout inthe JT's letter of 22- 6.2017. Sigsficantly, Mr. Thani as never indicated that he has or will be proving any documentation to substantiate the contents of the Thani TLetors. Instead, a5 is evident from the correspondence with him summarized above, he has simply “offered to verify in person that he di © o ® o 2 sign the sui fetes and that he stands by their content bet without any farter elaboration a al ‘The legal stats and utility of interviewing an individual in such ‘ircumstances, who had prior thereto, categorically refused to recognize, sccat or submit t the cours end laws of Pakistan oF “to appear before ‘ay court or tibunsl for any purpose whatsoever, in the JIT's bumble ssssment also seemed inappropriate and, potenti fast as refusal to appear ina Cour o Tribunal would have defeated the ‘very underying objective for which the JT itended and needed to record his statement, ‘Ms Thoni despite th best efforts ofthe JTT, as are clear ffom the above pars, chose to delay his responses or sideline the issue of recording of atiment, by fist refusing t give a statement , then accepting and asking for a dat, thea easing the legal isues of jurisdiction of Pakistan courts and finally sending his response at the last moment without seceding tothe jurisdiction of Pakistani law and courts, that too, when the IT had already started preparing its final report. This whole episode of avoidance to record his statement and delay i to the extent that the time tiven by the Honorable Supreme Cour of Pakistan practically expires can ‘only be seen as a tactical move to Keep the defence of the respondents alive “The JT in its investigations has collected sufficient evidence as det ‘hisseotion and elsewhere inthis report to conede that the appearance or ‘orappearance of Mr Than isnot as significant ws was asested earlier Ir tas beon proved through the acquired authentic documentary evidence and inconsistencies in the statement of witnesses that Mr. Tariq Shaft a never banded over AED 12 milion to father of Hamad Al-Thani Henee, no question of any investment in Qatari business and proceeds thereto, — ae fw Ace WAM 214) PSP, Head of TT (AMER AZIZ) (A (BRIGADIER KAMRAN KHURSHID) NSU) SAEED i \ I en “if in sin Bn Jaber dT November 2018 the undersigned, do nereby state the folowing: 4. My father had longstanding ‘business rotations with Mr. Mian Muhammad Shari, which were coordinated through my eldest. brother. Our Families enjoyed and continue to enjoy personal relations, E62. | was informed that during the yesr 1980, Mr. Mian Muhammad Shasif expressed his desir to invest a certain amount of money in real estate business of Al Than! family in Qatar. 3, | understood atthat time, that an aggregate sum of around 12 Millon Dithams (AED 12,000,000) was contributed by Mtr. Mian Muhammad Shae, originating from the sale ofbusinesé In Dubal, UAE, ‘The propertios Flat # 17, Flat # 17a, Flat # 16, Fat # 18a at Avenfold House, Park Lane, Landon were registered in thé, ownershln. of two offshore ‘companies, bearer share certificates of which were kept during that time in Catar. These wers purchased from the proceeds of the real estate business. (On account of relationship between th families, Mr. Man Muhammad Shai and his famly used tho Properties whist bearing all expenses relating to the Properties, including the ground rent and service charges. can recall that during his Ife ima, Mr, Mian Muhdmmad Sharif wished that the beneficiary of his Investment and returns in the cea estate business ish Grandson, Wr. Hussain Nawaz Shari {EAD i latement is phate and conden cannot be wed o ecose ory party thou ny prior writen consort, excepto the bens of the cuts and equates ot Stuy tce, of HE Shade in Jessie boom ober ‘ey atenton that certain queries have bgen raload wih respect tomy : % tw such gisrios, wich to cary that in 1900, Mr. Mian Mohammad: 5 sharif, longstanding and trusted buslnass pariner of my father, made 5 eee seea Tt ssa) ot procreation AED: ha el PPousiness of the AlThanl tarly. This- investment was made by wy of Fees ot gan cmon poten te Ou gin atte hina of en ae sgn aint between, ater an han yor erases ab bebe emiones. et fw of 2095, afer rovandling gir settle, and Sher detipuions made over oi eit alee ail ay og! = aera Se en acim Ges wets be ane Ufone sattes 2008 $/-way oP Geivey to Me Hussain Nowae Shere Le eet cul en er ease Les, Se eae! imo el + islemort is vale ay pot wrt consent, exept to Tre benef ofthe gq and eg ee PEF Signed JAG. Sherk Jaber AIThani Pewee Bin Tassie Te angen (tA a (nan AE a “praca cron Fx ra e108, OBE 44: Deta Oar 27 ‘Excerpts of Statement of Mian Nawaz Sharif so Min Muhammad Sharif (Recorded on 15 June 2017) Tiel S2OSOCOONIOOOIOIN 15, As foraseltionship between my father and the Al Than family of Qatar is concerned, it dates back long time, Sheikh Hamad was the frst person who ad met me a custody ae the 1999 Coup, do not want to dizuss the details ofthe sale proceeds of Gulf Stel as they were Dest known to my father. All Tknow is that they wero used forthe businesses set up outside Pakistan later. As far as the leer of Prince Hamad AI Thani submitted ia the Supreme Cou is ‘concemed I do remember that tad seen them but dot remember the details, Thave been read ‘ut the lator of Prince Hamad Bin Jasin Al Thani dated 5 Novetnber 2016 aad I confi tat Ihad the knowledge that beneficiary of the investment was to be Hussain Nawaz. I cannot however say when was the sie proceed of Gulf Stel handed overt Al Thani fay, whether immediatly after the sale or later on. Ido no remember the details ofthe second letter of Prince Hamad dated 22 December 2016. As far asthe worksbect, submitted in the Supreme Court of Pakistan, submitted by my sons, is concemed I do not recall having seen it or know of its contents. Ican however say that his investment was the hase of subsequent businesses setup by “Hasan and Hussain. I stand by sl the submissions made by my sons and daughter before the ‘Supreme Court of Pakistan during the proceeding ofthis case, 16t0 17, 2QQQ00G000RKXX000000X0X 18. As far as my not refering to the investment besween the Qatasi family and my srandfter inthe speeches is corcered, Thad at that time said hat I would tell de details when the time comes, With regard to the international meaia interviews about the Avenfield partments in the 1990s where se didnot mention the Qetari investment in our sponses all 28 can say is that there is a sary behind ow that interview that you are refering to happened and I ‘who sponsored it 1 do not want to dscass the details. In relation tothe news report of the ‘guardian which quoted my wife as saying thatthe Avenfield apartments were purchased for “Hasan and Hissin in 2000 while they were studying in London; my eesponse is that sometimes ‘hese things are sid ocaseoflack of knowledge. 191020, sgQgENEEETONEEOGNGEDN 29 Recorded 17 107. XXXXRAKINAANNA AARON 8, The Gulf Stel Mills was the only factory or business inthe Middle Bast setup by my fier before 1980 In fac the ony other factory that he setup inthe Mile Kast wns the Azizia factory that was established when we were forced to ive in exile in Sendi Arabia The only other Snvestment inthe Middle East by my father, which I can think of, isthe investment of the sale proceeds of Gulf Stel Mill in 1980 with the Qatari Royal fanily. My Eaer had told me about this investment at that ime bu it was nota detailed discussion, Trig Shafi had also mentioned ofthis investment atthe tne. As far asthe question of my Tater investing the sle proceeds of ‘Gulf Stel Mills with the Quasi Royal family, instead of clearing the lailities, i concemed, 1 ‘do agree that itis totally out of character for him, He would slays clear his liabilities ase was very strict on these issues. Bven ifthere were any liabilities, Mr. Tariq Shai being the owner and ‘beneficiary of Gulf Stel Mills, was responsible for clearing the Liailities. However, this is @ ‘more legal interpretation. 9, Tam not aware of th diss ofthe investment that was made withthe Qatari. The only time I rocall it ing discusad was atthe time of seting up of Azixa Stee! Mills. Ido not know in what form the sale procseds of Gulf Stel Mills were handed over to the Qaars, I do not know of any other investmnt made by my father or family prior to this investment with the Qutris. oF later, Ae fara my own rlasions with the Qatari Prince Hamed bin Jim is concerned 1 met him forthe ist ie i 2010, 10, XQOORRODECOONROCRRRAN 11, As regards the cation placed on these apartments by the Queen's Court in the al “Towfeoq case agains Hucbiya, I rofuse t answer any questions relaled to Hudabiya asthe investigation by FIA and NAB hve been quashed by the High Court and therefore ae closed and shut cases. Although Iam made aware ofthe directions contained in para 3 ofthe Supreme ‘Coutts order dated 20 Apr] 2017 regarding the FIA and NAB investigations my position is that | would not discus it as the JIT is not authorized to probe itn any case I was incarcerated in 2000 and not aware whether the Qataris had played a role inthe settlement or otherwise, 12, The seiting up of Azizin Stel Mills was the result ofthe forced exile of our family t0 Saudi Arabia in Inte 2000, After the Coup of 1999, Mian Nawaz Shaif, Abbas Sharif, Mian Sharif, Hussuin Nowse enc I were all incarcerated our businesses in Pakistan ‘were non-functional excep: Chaudary Sugar Mills which my son Hamza Shabbaz was looking er, Iwas suffering from cancer 2001-2 at the time, Thowever do know that here were three shareholders; Hussain Navaz Sharif, my daughter Rabi and my brother Abbss. It was an investment whete all tree brothers were represented. The equity ftom the share holders was fiom the Qatari investnet, The Mill was not making profit and in 2004 there was some discussions that it should be sold. My father had indicated that in case the MGll was sold all sale ‘proceeds would goto Hussain think at that time I was inthe United States for treatment, As t0 the question that Hussain Nawaz Sharif ison recordin w TV interview that he was notin fivor of selling Aziza but was ouumbered by othor shaccoldors { can only say tht T was under treatment a that ime and donot know the details. As tothe question that ifthe sale proceeds of Azioia were tobe given to Hussain only; who did not want itt be sold thea why would other uareholdert including my daughter Rabin insist on its sale and to what end, T offer no our exile 1, XXXXXKAXIADORNOOCKNOOK 31 erpts f of Hussain Nawaz: war Shar) (Recorded on 30 May 2017, 01 June 2017 and 03 June 2017) 1 to 6, XXNNRRARK AIO AKA 7. As far as the source of purchase of these apartments is coneemed they came in our ‘ownership os a result of stlement of money that was placed by my grandfather with Sheikh Jasim Athan who was the uler of Qutar a hat ime. No paperwork or any kind of agreement ‘was signed and it was a tally verbal arrangement, My grandfather was a man of action nd vere to documentation. Hist leamt about this arrangement from my grandfather, somewhere after the year 2000, witen we were living in exile in Saudi Arabia, He told me that afer deducting the amount of money tken back from the Sheikh for meeting essential requirements, 1 would be entitled fo whatever is the residual amount He did not mention about when this ‘rangement was to end an sttement to be made. As to the question why he chose me over ‘others to be the sole beneficiary of Aziia steel and the residual amount, it must be understood that, out of respect, noone in the family asked any question about his decisions. 8 Ido not remember the exact date but sometime around March 2005 Nasir Khamees (8 representative of Mr, Hasna Bin Jisia Bin AL-Thani) met me in Saudi Arabia along wih some ‘other persons in his team te discus he terms of setlement ofthe money that had been placed by my grandfather. Iwas the oly one who was representing cur family. Nasi told me that the Prince Hamad bin Jasim Alas, wanted to reach aseftlement on the aangemeat of investment ‘that had boos made Between my’ grandfather and his ther Ho Aid not provide any details ofthe ‘amount that had been already used and the residual amount. Inthe next 6 months @ couple of meetings were held and details were discussed, I think that it was in October 2005 tht in = ncetng the details of expenses were worked out between our teams, As far as the involvement ofthe Prince Hamad bin Jisim Althan i the negotiation process is concerned think during the 32 time this negotiation was king place, we met on some social event but this matter was never Aisussed with him, 9, Although I tre to ask forthe details ofthe investment portfolio, but Nase and his team politely prosnted the sumnary. I must emphasise that we were totally dependent on whatever calculations were made by Nasir and {was nt ina position to challenge any ofthe calculations 5 thore was no written ajgeement between my grandfather and Sheikh Jasim Althani, In any case if you consider the awironment of Mile Kast, were the investors do not have much protection and rishts, the setlement offer was very noble iiiatve by the Qatar Prince, which can only be ataibuted tothe sense of religious obligation to sete this longstanding investment sail. 10. In the end we prepared the sammary of investment made the profit the amount already returned from time to tima, and the residual amount, This was a hand writen document that formed the basis ofthe Excel woskshoet Ido not remember when this work sheet which was presented in the Supreme Court was prepared, Itmust be understood, and Thave already sated it, that there existed no writen agreement for the investments made by my grandfather with the (Qatari Ruler and therefore we practically had to agree whatever was being offered. 1 think the ‘reason for not inking an ageement was to avoid fare tigation by any pay. Ite3l,EECADONGGAOCONOGROOAK 33 [Excerpts of Siatsment of Husain Nawaz Sharifsio Mian Nawaz Sharif (Recorded on 09 June 2017) Ties, S2dcKXXXIONHETANIENOTAG 6. As faras the handing over f the bearer shares is concerned I donot remember the exact dates but somewhere aroun! en of 2005 or early 2006 I alld Wagar Ahmed, who works inthe ‘office of Hassan and tld him thst Mr, Nas Kame, the representative of Prince Hamad Al- “Thani would be sending ke bearer shares though a courier sevice and instructed him to send ‘them to Minerva by post, think that Wagar confirmed that hed received the envelope fiom ‘Nasir od had set it to Mizerva. Ido not think hat be had opened the envelope. Lam not aware if thee was anything else that was sent by Nasir 1 thik that T received phone call from Minerva confining that ey had recsived the share. Iam not sure whether they Id sent sny email or write communistion to confirm receipt. we, Ges, xconECONUTCERDOGNOONN aren. 34 Excerpts of Sta waz Sha jan Nawaz Shavit Recorded on 2 June, 2017 108, SQOOCONIOOCIRITINOGO 9. As far as my knowlege about she sotlament barweon Husshin and Prince Hamad bin ‘asin Albani, in 2005-06, is conceened I was not involved in the process and did not know any ofthe details but knew of she bigger picture that Hussain is going tobe the beneficial owner of those apartments, Although I had previously known of the close relations between our family nd Althani family of Qus, I became aware about the arangement of investment between my grandfather and Althani family at the time of final settlement, Previously I had not come across ‘ny event that would have made me aware of Althan investment. Tam not aware thatthe bearer shares of Neilson and Nesol ever have been handed over to Wager, who works as my assistant low 14, sg9QENGENTONGENECONS 35 ‘poston 1, Lam nett os bea faa Abed Khan Wnt vise wth geo ‘austin of Brysh aor BV awa has ae i he contest of is lignin the Pakistan Super Cour aguas Mian Naw Shai waz Sa he cure Prine Minster of Passa {have Yee provided wit» mma of tho boners in th case, bt ont ned set the oa at they somo materia th mazow oon which my aie ough 12, understand ht tl Opieoe may be provided othe oar ar expe evidence che es wih which das. My profane questions ae povided Ing septs document, “The gut on which am ake eave “The quinn ei th etc onerp of he sues in no BVL compass, Nien Exes Lite CMe) nd Nell Lid (Nese: peel, ete sae oad bene by Husa Neva ‘Shui (Hain, he sn of a Sar or by Naim Setar (Nari, ‘he dangerofNawez Shc 4, Bat Nelen and Novo te apes pupae oils nt pt ld te ag tiesto two ve Lacon ropes (ompelig our prea) known ss Noe. 16,16 17 and 1-4 Avni Hoare, 18127 Pt Lane ered to more simply a "No 16° sd N17 Aven Hous repecve 0 togetes "bo Prope, No 16h by Nic and No 17 by Nes. 136 Chronatgy of events 4 or the pups of thls Opin F have Been provided witha number of oct wish wif have asad the it tobe coda | stn hoe doen evap where tie lea at Lam merely eording ‘noses yon fevers Wore Ive au it to bt te at be int ta hey ae ceed orate by ele Yoh pres ser sng the fetal amumpsos T ave made fr the poses of cos he relevant egal pipes. 6.1 fake the following ehooloy of the elvat evens peor from ocr elite “Pure Stet oo Bela f Respedent No and 8° (te Sutemene, which fas teen submited inte cour proceetings co ‘hf Hunn sd bis roth, ss Nox Sht have als inlet Information wag some pinay Zcuments of which opis have been ‘provided 10 me, sn & sent served inte rocendngs om teal of Mai date 24 Jnnay 2017 (Matas Staten Newall wae fovea fhe BVI on 27 Jnuay 193, and is arog itl ses by a sng eer saris on 29 Apsl1993, ‘Nickens corte fa the BVT on 4 Angst 1994, and is torsoling aly eerie by a sel ee shred e022 November 194 ‘Tammy, ep nde ctg a a he ‘soe ofeach 37 By alee dated 3 Deventer 205, Sta Flan Serve Limited (Samba) wrote toa Janey company, Miner Fiona Service ime ora” eying that Maran? was wel known tent soe of ceva outnesnse 002 Tho lee est ith eo prod the request f Maa, “wiout any reson” om he ptf Samba, The ren forthe Heer, acading tthe Sttnest, was tp provide fafamaon to Minera at pt of an sermgeentbtoen Hin nd Maria hat Maia sos ct “aoe sgntnyowesenav” in mats pening 1 te Inasageret of he companies, The Statnet farther exis tat tec been desided (iis stele by om) to api Mera Trt nd Comore Seis Lime, Minera Nm Lime, Minera Serves Linted and Miners Ofser Li a “the sevice _provke” wth apt Nien ant Nest, 4 Janay 2006, th beer sacs were pyle ded to x Wonar Abe CM Als) fn London. Me Amol sal 0 have se “appointed to tke ppl utr on Behalf” Hana. ake ato mean hat Me Abed ed he hres a nomines for Hn 2 The Satret then debs meting Ia London Soar 2006 ‘een Hunn and Minera “in eo Fal the appointment Mina Nest the Statement sys tat Hsin equ Novia tact a Bt thera lng ont opameniee efectos to Miner 1 nt expaied why tis ous ft fo be convenient, gen tht remanent aterm tr ene 3 38 Matin wo seta Sault Arba, wil Husa was esd Landon Gin tet copying one of the Propet). Accorting to Masia’ Steet, Huei “wate autre bef lato to these poperioe so Bat ix cate of Bs denise [as} could ears tbo he ropentiea per Shri a Yeeen hs pl ie” soe point fetwan Jomney 2006 and Fehr 2006 Hwa bind pyc possesion of the tare Shaes. The Staement oes sot sey the exact dts, bu have een proved wih a coy o Desrton of Tat (the Dsnaton of Tea" sgn by Maan om 2 ebramy end by Hsin on Febuary 2006, wih ets tat sain the “bene over and bole of te bearer sae, so odes ht Min lol hes on ts rhe sole nd abt beet and on etal of Hain, Tee Declaration of ‘rt i etal tthe gto with whi is Opinion scons, sa wi rt tn more dail er. 1 have abo een spied witha document whew anny I teed hm be Stem be tong one 1s dtd 7 February 2006, and oppor to be, sgned by Mavi, The ocenent is sted 10 be “tve es at 13 May 2004, 1 a Insc ht hs th dosent fered ola pra I of he Siento "as-aled deshton of neil tre at in he ‘ett of meaty Til ert itn te Febuary Resin” On foe ee Foley Bean pons end 9 eon by Neal sosepting and approving the rapelaneat of LZ Nomioes nite come distr ofthe crmany, "ud ie bay soit 39 tnd approved by he Company a he sole shrchaler of the pen." Unt sft, Maca Is desea oe (re) Seale (5). ‘July 2016 Hin proce th cancelation of the Rare share, snd the ie f Catan Share Cates, which were eit the name of Miner? Asn the erst dle aot speci inthe Sntement bat have ae ifm nls ofthe Shae Cen iat rere provid with ny lasrstins ‘the nex docuent onlay dad 14 Otoer 211 ne & enol Informa Form beaded Misave Foun Series “Limite, appears ob «document complet sp of Miners ‘rcnow Yoor Cie” sequemats, and contaas basic information config th deny of Mean. In Min Sate ti ded hat he sigs theca i ao comet pined ou tat he ‘be athe hed fe frm mento ever fet eepre o persons fir om the fem Is Intended, tncalng anise slg ‘the next relevnt event assed an 12 Sune 2012, when the BYE InvetgstonAgsoey wrote to Mosc, Fonseca & Co(BYD Limited (/Mossck ones sting for dosent nd infrnation etn to ‘Neo and Nl. tn ponte Mosse Fone cri out sme Intent eosing, and ale conted Mla! Rosie, tbe Tras ‘oon of Minera Trust & Comonte Seviet Lined CM 40 1 an ell dated 22 Jane 2012, Mr Ronterintorned Mosse Fons hat Nir an Nel ar ned by the sane beet oes Masi Soe ao Itc her KYC dail” In a erate revo day 21 Sie 202, Me Roster sta tha “hee 0 st contol” I ltt te fo semen ken togeter at neni tat Miner lh gl ie te aes be ter foe Mai: in ete word Mira was at ewae of ny ermal, ot Maca ws thst eel ove, ‘fo erated 72 Joe 2012, Mosc Foes thn eps bck ete BVT Frac resign Agony, rong the informin tha had een eouetes, Tit included the state hat “the ena Orne ofthe caspany IeMarlam Sattar. ‘sho lo tou that ve been povided with short stutemect ty Maram, dod and uaine, wich unlesond to bein vee foe the coun whch Masi sy “Tam ot nd ae ever bean te bef omer of th 4 Laon at nd ave sever ervey nce opt Kaa beef rom tose ts The Sil event inthe onlogy sural en 9 Jane 2014, when th Minerva Shite Cefionss were caotlleé, sd fresh Censts ‘sual Inthe name of Tre Secs Comperstion TSC), whose sist gen in Landon. Acer tthe Steen, hs wa agin Ao on ination of smn alhegh no ean gen forthe ‘oor manent fine te og ol eld pe nia. ‘fanaa moth nnn so al ‘The Delain of Test 11 The Declaton of Trt fs mde ty Milam, who is éesiad a the trae" and Hus, who i dense a “be Benen” Hoa ined ty Maxam in sh on 2 Feb 2006 aby Hussin to dys ns, in London, & As Tbe aleaty enone, th eine he Desarain ta the ‘Benelary”~ notte Tren — Ia he beatae and ai f the ears, This ie oanitent withthe accu given in the Steen, seceding to wish he re wer nd thi Fit in ne Lode, 9 ower th delat of tin late of th boy ofthe Detaton saa y the Troe, Maran. Ava mtr of lish aw en wi desk Inter wi wheter Engh ew apie) the ae to mos by which rot ye tito 9 ter may decent be & na of opr elgg hin or stormy rane property 0 8 re, wh seco he eat [ttn teste of eae shares te lp ies vse in whoever hs phy essen ofthe sar eit a in ner fr the tat to Be fall cota, te cents mute phyly aed to he wets, Tee i ‘0 meon ofthe beter ahs in hice ever ating Been handel over Mat, Ith i ot ke pas, ere wos no was, and cones 2 they veya late 1 doe tht iam il old he shares“ to Fiasco GO) 17 itn, bt x 42 sole an abst best don bef Hsin. Clase 3 provides tht the Propet hl ain ihe excise we ne osuson of Hsin fr so Jong ae he egies, Cas oven ut inh eet Fs eth aca a ering Peper nd yng ofan ts ete th pte ints wih isn ofS Sl aw ang tone alpina H's Chas 5 vie at te den igs of Mi Be "ih cere hi Tra” sh eve sit And yc 6 tos Man arnt = fon Ardy tomas Be conpis 12. okt deine he wit ote Des of Tr cena dd he yin of er wih ht enon Be tno Asin tel het aba sone te he VL hei of nln and Was. aig a bcomatn eve lei ome el wich ooo ens sl er (nome; ra pp te tn anemia ics ey hav fg Wak a he wf he BV a8 th plese iy fet] Interpretation an Rectifetion 13. Delta of Trt ont 0 ere evi the proper aw of the tut Tht is atin se reamabl altough ene woul have apt a rofedona tte detain eae slums three gin some ‘ong the what was intended to ry 43 14. However st wall a the documents elag othe Propet, Ibe ase en provided witha seo Deaton of Tras in viral elena, ts ewcute in Sali Aria on 2 Pray 2006 by Mariam and on 4 ‘etry 2006 In Landon ty Husa, which does corn an exe sverige cs (plying Engl ie. This ocuent eal wih snes na iret company, Coomber Group Ine 1s, oth deinen mre tmp and sed by th same London slr, emg reemas of Frean Box Hi dl oink of any reson wy the ttn woud ie ited ch cae fe cs deol bt ot the ies, Oo posi casantn i simple vet, Mariam’: Statement ons tht, “The enon fr exon of ett ded etn io Conmer Group nc ws thoes fr er sb fhe Compan wig fe Lanon Tats 16. The aks of comtston wold potaly nat emit efirece to ane af the ees sdf contin he th, atiagh cannot eet ed ‘out Inder Sade Facil Group whichis iscued lower in this Opinio, tee wore sven trimers wafer casigeato, fou af wih laced express col of hw slaues. The eft nse onside ‘ha ne wre “tons pou for veluing ht these ev plied te ote tansonsby plain” The Court of Appeal id not comment on tissproh* 1. tf oon dos moti ania he sence of ny Th evens a ‘pplcson fr reetifeaton on he pounds of mistake cut hve #06 ipaacican aha ene a we bart svat aot ti otras apt aa a-ha however, aol dally In oder fr the Pgh cout tare Jiisicon to gat te remaly of siento, it mast eply gl ew ‘A A has already died tat Bglih Iw applies, eestifton i nese iflthas oto dese tent grantee making apch lew patie 19, my sve pos ep from apa pss. The tw ost pune cones fr the apie aw ars wil exp below) ‘Bahan Wolo he BV. fhe BVI cout were dee hat od Susi it ier the deo wo sutint the Iw of Baga ed Wale “The Recogsiton of Trans Ast 987 (te 1987 Ae”) 20.4 spt of elf tering which iw should ply i eng the sly of tut whe dtr juisition ao invave is conned in the Hague Convetion on th Law Aplcabet That nd ont Recor (the Hague Contention”. 21,The 1507 Aste effectin England nd Wales the Hage Cenvestion with fc om 1 Angus 19077 22.The Ress of Tuts Act 1987 (Ovens Tents) Onder 1989, snily plied th Hague Coneaton to a umber of Tent, which Incl he BVE Haplles wi etrom |Fne 1989, slighly madi reorrding of the raleve povsons of he Hague 45, Convention, hi any rater french prpses tte ites onsieed inthis Opinio, te oral wording of ie Hague Canveton ‘wold rea vag been incorporated ito BVI aw by an On in Come sate tn dora oa BVT Ose 24, The rel tha i 6 mater came befire fe cours er in Engin or fa the BV, the ating pot fr determing oe poper Iw ofthe st would beth Hage Coneston 25. Anil ofthe Hague Convention sen erat bt stl proviso. "The Conention does mt apt opinion issraing tthe ally of wis or of tor wot by views of which are ae tener oth ute” 1 ll oie vison later inthis pinion 26 Arce balay sang hat ‘rte tsp by Ate 6 7 sl govem te ily of te tris omtraton a ft and te aati of ets.” 27, Ac provides (oti pst) at — Att al be ever by he a chosen bythe set The ce use expe be plied int em othe asbunet rating ‘he wag evening the ts Intec, faces, inte haf she creme ofthe sas” (tie tht een hat sve det sons paragzpbs above coneing expe ce ofa clase)

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