d. List the victims and state how each victim was injured.

Plaintiff is not aware of all persons who are the victims of the Illegal Scheme to takeover a substantial portion of the Russian oil industry, absent discovery. Plaintiff will list those entities which are known to it and were the victims of companies related to Plaintiff’s interests.

1. Appalachia Investments Ltd. (“Appalachia”)

Appalachia is a holding company organized under the laws of the State of California. It owns Norex. It has lost the value of its investment in Norex because of Norex’s loss of its investment in Yugraneft.

2. Norex Petroleum Limited (“Norex”)
Norex is a holding company organized under the laws of Cyprus. It owned 97% of Yugraneft. It lost the value of its investment in Yugraneft when Yugraneft was illegally seized and stripped of its assets.

3. ZAO Yugraneft Corporation (“Yugraneft”)
Yugraneft is a company organized under the laws of the Russian Federation, which was illegally seized as part of the Illegal Scheme. It lost the value of its assets, which were stripped from it.

4. OAO Siberian Far Eastern Oil Co. (“Sidanco”)
Sidanco is a company organized under the laws of the Russian Federation, which owned the majority interests of its subsidiaries, Kondpetroleum and Chernogorneft, and was harmed by the corrupt bankruptcies of these subsidiaries thereby loosing the value of its equity in these companies. As a result of the harm to Sidanco, its shareholders suffered harm as well.

5. OAO Kondpetroleum (“Kondpetroleum”)
Kondpetroleum is a company organized under the laws of the Russian Federation, which was stripped of its assets as the result of a corrupt bankruptcy proceeding, which was part of the Illegal Scheme. As a result of the harm to Kondpetroleum, its shareholders and creditors suffered harm as well.

6. OAO Chernogorneft (“Chernogorneft”)
Chernogorneft is a company organized under the laws of the Russian Federation, which was stripped of its assets, including its shares in Yugraneft, as the result of a corrupt bankruptcy proceeding, which was part of the Illegal Scheme. As a result of the harm to Chernogorneft, its shareholders and creditors suffered harm as well.

7. OAO Nizhnevartovsk Nefte Gaz (“NNG”)
NNG is a company organized under the laws of the Russian Federation, of which 38% was owned by TNK, and over which TNK obtained full control through corrupt proceedings. As a result of the harm to NNG, its shareholders and creditors suffered harm as well.

8. BP, PLC formerly known as BP-Amoco (“BP-Amoco”)
BP-Amoco is a company with various subsidiaries and many shareholders in the United States. BP-Amoco was a shareholder of Sidanco at all relevant times. BP-Amoco was harmed by the false bankruptcies of Kondpetroleum and Chernogorneft by which the assets of these companies were stripped as part of the Illegal Scheme, destroying the value of Sidanco’s interests therein.

9. The Harvard University Endowment Fund (“Harvard”)
Harvard is an unincorporated fund owned by Harvard University. Harvard was a shareholder in Kantupan Holdings Co. Ltd. (“Kantupan”), an investment vehicle which, directly or indirectly, owned 40% of Sidanco, at all relevant times. Harvard was harmed by the false bankruptcies of Kondpetroleum and Chernogorneft by which the assets of these companies were stripped as part of the Illegal Scheme, destroying the value of Sidanco’s interests therein.

10. The Governments of the United States, United Kingdom and Russia
The Governments of the United States, United Kingdom and Russia were harmed by the Massive Tax Fraud. In addition, the government of Russia was harmed by the Corrupt 1997 and 1999 Privatizations.

11. John and Jane Does 1-100
Upon information and belief, citizens of the United States were shareholders of American Depository Receipts (“ADR’s”) of Chernogorneft (collectively, the “Chernogorneft American Investors”), which were managed by the Bank of New York in New York City. The Chernogorneft American Investors were harmed by the corrupt Chernogorneft bankruptcy, the illegal diversion of profits from Chernogorneft to TNK and Crown Group and the Slush Fund Companies as part of the Illegal Scheme.

12. John and Jane Does 101-200
Upon information and belief, citizens of the United States were shareholders of TNK subsidiaries (collectively, the “TNK American Investors”). The TNK American Investors were harmed by the illegal diversion of profits from TNK to the Crown Group and then to the Slush Fund Companies as part of the Illegal Scheme.