SUMMARY OF ALBERTA CLAIM

(a) Placement of Insurance Coverage

1. Chubb Insurance Company of Canada ("Chubb") issued a policy of insurance for the policy period from November 14, 2000 to November 1, 2001 identified as Policy No. 3710 9631 (the "Chubb Policy") in favour of Norex Petroleum Limited ("Norex") and its affiliates and subsidiaries, including ZAO Yugraneft Corporation ("Yugraneft").

2. Chubb required the first loss property coverage to be written by a Russian insurance company and negotiated with Ingosstrakh Insurance Company Ltd. ("Ingosstrakh") for the placement of such coverage (the "Ingosstrakh Coverage"). The Ingosstrakh Coverage consisted of a binder and a policy. The binder was for the policy period from November 15, 2000 to November 1, 2001 and is identified as Binder No. 2000202688-0 in favour of Norex and its affiliates and subsidiaries, including Yugraneft.

3. Ingosstrakh never stamped, sealed and returned the binder and Norex never received a formal executed insurance policy with substantially the same terms as the binder. In or about September of 2002, Ingosstrakh provided Norex with a copy of an Ingosstrakh Policy for property damage insurance identified as Policy No. 41-000903101 in favour of Yugraneft alone (the "Ingosstrakh Policy"), together with General Conditions purportedly incorporated therein. Norex strongly disputes the authenticity of the Ingosstrakh Policy.

4. The Ingosstrakh Coverage and the Chubb Policy were effected within a framework of a joint insurance program which provided for Norex to have direct recourse to the Chubb Policy on the basis of Differences in Conditions and Differences in Limits in the event that the Ingosstrakh Coverage did not initially respond to a claim.

5. The Ingosstrakh Coverage and the Chubb Policy insured certain specialized oilfield equipment (the "Oilfield Equipment") having a value of U.S. $11,764,900, which was used by Yugraneft to enhance production from its oil properties in Nizhnevartovsk, Russia. Norex provided two shareholder loans to Yugraneft to facilitate this acquisition.

6. At the time the Ingosstrakh Coverage and the Chubb Policy were put into place, Norex held 97.3% of the shares of Yugraneft and exercised effective control and management of Yugraneft from its operational office in Calgary, Alberta.

(b) Facts Underlying Norex's Claims

7. On or about June 29, 2001, Norex was the victim of a fraudulent and illegal scheme of corruption and conspiracy designed to enable Tyumen Oil Company ("TNK") and its subsidiaries and affiliates to acquire control of Yugraneft and take over Yugraneft's property and assets, including the Oilfield Equipment.

8. In brief, TNK implemented the fraudulent and illegal scheme by claiming to have relied upon the legal authority of a purported shareholders' meeting of Yugraneft on or about June 28, 2001, at which Alexander Berman, an officer of a TNK affiliate, was allegedly elected as general director of Yugraneft. In fact, no such meeting took place.

9. On or about June 29, 2001, Mr. Berman, accompanied by at least 16 thugs wearing military style fatigues and armed with machine guns, invaded Yugraneft's offices in Nizhnevartovsk. On or about July 6, 2001, TNK security guards armed with pistols and machine guns took over Yugraneft's oilfields and field offices and cut off Yugraneft's telephone and internet services.

10. Commencing from June 29, 2001, TNK stripped Yugraneft of its assets, including Yugraneft's oil and gas properties, its inventories, its accounts receivable, its Oilfield Equipment, and its bank deposits amounting to over USD $50 million, which consisted of approximately USD $24 million in dollar denominated accounts and the remainder in Russian rubles.

11. Since June 29, 2001, Yugraneft has operated as a business unit of TNK. Since that time, Norex has been deprived of any access to the records or assets of Yugraneft. In addition, Norex has had no effective access to the courts or government of the Nizhnevartovsk region as TNK and its principals, subsidiaries, and affiliates effectively control the courts and the government of the Nizhnevartovsk region by the exercise of corruption and bribery.

(c) Claims and Legal Action

12. Norex provided both Chubb and Ingosstrakh with written notice and sworn proofs of loss regarding claims under the Chubb Policy and Ingosstrakh Coverage arising out of the loss of the Oilfield Equipment as a result of the forcible takeover of Yugraneft as outlined above. Those claims were denied by both Chubb and Ingosstrakh.

13. Chubb's response to the armed takeover of Yugraneft was to cancel the Chubb Policy and all other coverage which it had written in favour of Yugraneft and its affiliated companies, including Norex.

14. On June 28, 2002 Norex filed its Statement of Claim in Alberta. On July 15, 2002 Norex obtained an Order allowing it to serve the Statement of Claim upon Ingosstrakh in Russia.

15. On August 12, 2002 Ingosstrakh filed a Statement of Defence. On June 28, 2004 - almost two years later - Ingosstrakh brought an application for an order staying or striking out Norex's action on the basis that Alberta is forum non conveniens. That application is presently scheduled to be heard on February 21-23, 2007.

16. On September 13, 2002 Chubb filed a Statement of Defence. On November 4, 2002 Chubb filed an Amended Statement of Defence. Further filing on the forum non Conveniens motion.

17. On or about May 26, 2006 - nearly five years after the events giving rise to Norex's claim and four years after Norex commenced its action - Chubb sent Yugraneft a letter purporting to void the Chubb Policy from the commencement of the policy term.

18. On July 10, 2006 Norex filed an Amended Statement of Claim amplifying its claims of bad faith against Chubb and objecting to Chubb's purported voidance of coverage on the basis that it was a malicious, oppressive and high-handed litigation tactic.

19. Chubb subsequently filed an Amended Amended Statement of Defence and brought an application for an order bifurcating the bad faith claims and the coverage issues. This application was heard on November 14, 2006 and the court's decision was reserved.