January 23, 2015 Petition from Savaro Limited’s Lawyer

Joseph Kareh and Associates

For Law and Legal Consultations

[Redacted]

Beirut, on 23/1/2015

Honorable Judge of Urgent Matters in Beirut,

Petitioner: Savaro Limited

Represented by: Lawyer Joseph Kareh

Attached is an image of the power of attorney (Document 1)

Subject: Request to appoint an expert

Whereas the petitioning company that owns merchandise in hangar no. 12 in Beirut Port, notably bags containing Ammonium Nitrate, as per a shipping policy and sales contract, attached hereto (Documents 2 and 3);

Whereas the policy indicates that the company which owns the merchandise is Rustavi Azot and the sales contract was concluded from Rustavi Azot to Savaro Limited;

And, whereas the petitioning company requests to know the status of this merchandise present in the port to take the adequate decision in that regard, notably since the incurred damage is huge and since the company pays daily storage fees at the port,

Therefore, we ask your esteemed judgeship to appoint an expert to inspect the merchandise, determine their condition and quantity, and specify whether they are fit for use.

Respectfully yours,

By virtue of the Power of Attorney,

Joseph Emile Kareh

Appeals Lawyer

Translated by Human Rights Watch