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CLAIMANT’S FACTUAL EXHIBITS

No. Exhibit Description Date
Claimant’s Factual Exhibits
1. C-1 Official website of the Eurasian Economic Commission, The Treaty on the Eurasian Economic Union entered into force 1 January 2015
2. C-2 Resolution No. 1 of the founder of Manolium-Processing 20 November 2000
3. C-3 Certificate of registration of Manolium-Processing and extract from the register of legal entities on Manolium-Engineering 24 July 2002
4. C-4 Charter of Manolium-Processing (4th edition) 5 March 2015
5. C-5 Certificate of state registration of Manolium-Engineering in the Unified State Register of Legal Entities and Individual Entrepreneurs 18 March 2004
6. C-6 Certificate of state registration of Manolium-Engineering in the Unified State Register of Legal Entities and Individual Entrepreneurs 16 April 2004
7. C-7 Charter of Manolium-Engineering 16 April 2004
8. C-8 Application of Manolium-Engineering to initiate the liquidation procedure 14 October 2016
9. C-9 Powers of attorney to represent Claimant 1 March 2017 and 13 November 2017
10. C-10 Statistics yearbook of the Republic of Belarus for 2015 2015
11. C-11 Doing Business in Belarus 2015 Report prepared by Ernst & Young 1 September 2015
12. C-12 Economic review of the Republic of Belarus prepared by the World Bank 28 April 2016
13. C-13 GDP of Belarus in 2015 // Business Gazette 29 January 2016
14. C-14 Navigant Expert report 24 April 2017

[Page 2]

No. Exhibit Description Date
Claimant’s Factual Exhibits
15. C-15 Credit rating of the Republic of Belarus, Trading Economics Portal 8 February 2017
16. C-16 Doing Business 2016 Report prepared by the World Bank 2016
17. C-17 V.N. Usosky, Impact of the financial and economic crisis of 2008-2011 on cyclical fluctuations of the Belarusian banking system and economy 15 March 2011
18. C-18 Official website of news portal of Belarus Naviny.By, Belarusian ruble is a global leader for devaluations 8 February 2017
19. C-19 Official website of news portal Rosbalt, Belarusian banks on the verge of collapse 8 November 2011
20. C-20 Official website of information and analytical portal BelGazeta, Is Belarus on the verge of a debt crisis? 25 April 2016
21. C-21 Official website of Belarusian news portal Belarus Digest, Belarus Sends Confusing Messages To Investors Accessed on 15 November 2017
22. C-22 World Bank's Report for 2016, Country Program Snapshot April 2016
23. C-23 Official website of news portal Nabiny.by, Belarus frightens investors 8 February 2017
24. C-24 UNCTAD data: Investment Policy Hub. List of effective bilateral and multilateral international investment treaties of the Republic of Belarus Accessed on 8 February 2017
25. C-25 Information about membership of the Republic of Belarus in international organizations Accessed on 17 April 2018
26. C-26 Official website of news portal of Belarus TUT.BY, Lukashenko recognized that Belarus would not recover its growth without the IMF and foreign investments 21 April 2016
27. C-27 Official website of news portal Business Gazette, Lukashenko invites investors to Belarus and issues guarantees to them 15 November 2012
28. C-28 Tender documents for the Tender 24 April 2003

[Page 3]

No. Exhibit Description Date
Claimant’s Factual Exhibits
29. C-29 Official website of news portal of Belarus TUT.BY, Two central prospekts of Minsk - Francisca Skorina and Masherova - renamed into Nezavisimosti and Pobediteley 8 May 2005
30. C-30 Claimant's bid to participate in the Tender 22 May 2003
31. C-31 Protocol 2 on the results of the Tender 30 May 2003
32. C-32 Letter from MCEC to Claimant 4 June 2003
33. C-33 Decision of MCEC on approving the results of the Tender 5 June 2003
34. C-34 Investment Contract 6 June 2003
35. C-35 Letter from MCEC to the President of the Republic of Belarus 26 May 2006
36. C-36 Photoreport: an abandoned trolleybus depot in the center of Minsk, 20 August 2014 20 August 2014
37. C-37 Belarusian business gazette, Russian investor will change the center of Minsk, 10 September 2014 10 September 2004
38. C-38 Map of microdistrict Uruchye-6 24 April 2017
39. C-39 Minutes of the meeting attended by MCEC, Minsktrans and Claimant 21 January 2004
40. C-40 Decision of MCEC 2 December 2004
41. C-41 Letter from the Main Office of Internal Affairs of the Republic of Belarus 3 August 2005
42. C-42 Official website Lenta.ru, Lukashenko instructed all Belarusians to pool some money for the National library 11 October 2002
43. C-43 Official website of Belarusian gazette Solidarnost, Constructors are still unpaid their fees for the National Library 18 October 2008
44. C-44 Letter from the State Control Committee of the Republic of Belarus to the President of the Republic of Belarus 31 July 2003

[Page 4]

No. Exhibit Description Date
Claimant’s Factual Exhibits
45. C-45 Resolution of the President of the Republic of Belarus to implementing the project under the Investment Contract 5 November 2003
46. C-46 Letter from the Council of Ministers of the Republic of Belarus to the President of the Republic of Belarus 30 October 2003
47. C-47 Additional Agreement No. 1 10 October 2003
48. C-48 Additional Agreement No. 2 22 October 2003
49. C-49 Additional Agreement No. 3 30 October 2003
50. C-50 Confirmation of the Library Payment 30 December 2003
51. C-51 Order of MCEC 29 September 2006
52. C-52 Letter from Manolium-Engineering to MCEC 19 May 2005
53. C-53 Decision of MCEC 15 July 2004
54. C-54 Letter from Manolium-Engineering to MCEC 19 January 2005
55. C-55 Letter from the Committee for Economy to MCEC 28 July 2004
56. C-56 Minutes of the meeting attended by MCEC, Minsktrans and Claimant 3 December 2003
57. C-57 Minutes of the meeting attended by MCEC, Minsktrans and Claimant 17 December 2003
58. C-58 Minutes of the meeting attended by MCEC, Minsktrans and Claimant 4 February 2004
59. C-59 Minutes of the meeting attended by MCEC, Minsktrans and Claimant 17 March 2004
60. C-60 Minutes of the meeting attended by MCEC, Minsktrans and Claimant 7 April 2004
61. C-61 Minutes of the meeting attended by MCEC, Minsktrans and Claimant 24 June 2004
62. C-62 Letter from Manolium-Engineering to MCEC 21 February 2005
63. C-63 Letter from Claimant to the Assistant to President of the Republic of Belarus 24 March 2006

[Page 5]

No. Exhibit Description Date
Claimant’s Factual Exhibits
64. C-64 Resolution of the President of the Republic of Belarus 11 July 2006
65. C-65 Letter from the Committee for Economy 17 January 2007
66. C-66 Additional Agreement No. 4 8 February 2007
67. C-67 Order of Manolium-Engineering No. 1-C 20 March 2007
68. C-68 Decision of MCEC 24 May 2007
69. C-69 Certificate of registration of the right of temporary use granted to Manolium-Engineering in respect of the land plots for construction of the Depot in Uruchye-6 29 June 2007
70. C-70 Construction permit issued by Gosstroy for constructing the Depot 15 October 2007
71. C-71 Letter from Manolium-Engineering to MCEC 11 September 2008
72. C-72 Additional Agreement No. 5 16 December 2008
73. C-73 Decision of MCEC 3 September 2009
74. C-74 Letter from Manolium-Engineering to MCEC 6 September 2010
75. C-75 Decision of MCEC 16 September 2010
76. C-76 Additional Agreement No. 6 20 April 2011
77. C-77 Letter from Manolium-Engineering to MCEC 29 June 2011
78. C-78 Letter from Minsktrans to Manolium-Engineering 22 July 2011
79. C-79 Letter from Manolium-Engineering to MCEC 7 September 2011
80. C-80 Letter from Manolium-Engineering to MCEC 12 October 2011
81. C-81 Letter from Minsktrans to Manolium-Engineering 27 October 2011
82. C-82 Depot Facilities Gratuitous Use Agreement 14 November 2011
83. C-83 Letter from Claimant to MCEC 19 March 2013
84. C-84 Agreement on terminating the Depot Facilities Gratuitous Use Agreement 30 December 2014

[Page 6]

No. Exhibit Description Date
Claimant’s Factual Exhibits
85. C-85 Order of Manolium-Engineering No. 1-C 20 March 2008
86. C-86 Decision of MCEC 2 May 2008
87. C-87 Construction permit issued by Gosstroy 29 May 2008
88. C-88 Certificate of registration of the right of temporary use granted to Manolium-Engineering in respect of the land plots for construction the Depot in Uruchye-6 20 August 2008
89. C-89 Decision of MCEC 22 January 2009
90. C-90 Certificate of state registration of the State Committee for Property No. 500/708-4289 11 October 2010
91. C-91 Order of Manolium-Engineering No. 1-C 1 July 2011
92. C-92 Letter from Minsktrans to Manolium-Engineering 13 December 2011
93. C-93 Letter from Claimant to MCEC 27 May 2013
94. C-94 Letter from Claimant to MCEC 27 June 2013
95. C-95 Letter from Claimant to MCEC 18 July 2014
96. C-96 Order of Manolium-Engineering No. 3-C 10 April 2008
97. C-97 Decision of MCEC 30 May 2008
98. C-98 Construction permit issued by Gosstroy for construction of the Pull Station 30 July 2010
99. C-99 Pull Station Gratuitous Use Agreement 6 July 2010
100. C-100 Acceptance Act in respect of the Pull Station 30 July 2010
101. C-101 Registration of the Pull Station as a permanent structure 1 October 2010
102. C-102 Letter from Manolium-Engineering to MCEC 11 October 2010
103. C-103 Letter from Manolium-Engineering to MCEC 21 October 2010
104. C-104 Letter from Minsktrans to Manolium-Engineering 17 November 2010
105. C-105 Letter from Minsktrans to Manolium-Engineering 19 September 2011

[Page 7]

No. Exhibit Description Date
Claimant’s Factual Exhibits
106. C-106 Letter from Manolium-Engineering to MCEC 11 August 2011
107. C-107 Letter from Manolium-Engineering to MCEC 11 October 2011
108. C-108 Letter from Manolium-Engineering to the State Control Committee of the Republic of Belarus 21 October 2011
109. C-109 Letter from Minsktrans to Manolium-Engineering 31 October 2011
110. C-110 Composition and the key technical and economic indexes for the Investment Object 25 February 2005
111. C-111 Letter from the Committee for Architecture to the Committee for Economy 9 June 2005
112. C-112 Letter from Minsktrans to Manolium-Engineering 16 March 2006
113. C-113 Schedule of design and construction of the Investment Object 28 December 2007
114. C-114 Letter from Manolium-Engineering to MCEC 5 November 2007
115. C-115 Letter from Manolium-Engineering to MCEC 27 May 2008
116. C-116 Investment Object Location Selection Act 25 March 2009
117. C-117 Letter from Manolium-Engineering to MCEC 17 May 2010
118. C-118 Letter from Manolium-Engineering 9 September 2010
119. C-119 Letter from Manolium-Engineering 28 October 2010
120. C-120 Schedule of Manolium-Engineering in respect of designing and constructing the Investment Object April 2011
121. C-121 Letter from the Committee for Architecture to Manolium-Engineering 26 April 2011
122. C-122 Letter from Manolium-Engineering to MCEC 24 November 2011
123. C-123 Letter from Minsktrans to Manolium-Engineering 6 December 2011
124. C-124 Letter from MCEC 5 January 2012
125. C-125 Minutes of the meeting attended by MCEC, Minsktrans and Claimant 9 January 2012

[Page 8]

No. Exhibit Description Date
Claimant’s Factual Exhibits
126. C-126 Letter from MCEC to Claimant 18 June 2012
127. C-127 Letter from Gosstroy to Manolium-Engineering 21 April 2012
128. C-128 Letter from Minsktrans to Manolium-Engineering 28 August 2012
129. C-129 Letter from Manolium-Engineering to MCEC 20 September 2012
130. C-130 Letter from MCEC to Manolium-Engineering 3 October 2012
131. C-131 Paritet-Standart Report 5 November 2012
132. C-132 Letter from MCEC to Claimant 10 December 2012
133. C-133 Letter from Manolium-Engineering to MCEC 18 December 2012
134. C-134 Letter from MCEC to Manolium-Engineering 18 January 2013
135. C-135 Letter from MCEC to Claimant 4 February 2013
136. C-136 Letter from Claimant to MCEC 4 March 2013
137. C-137 Letter from MCEC to Claimant 11 March 2013
138. C-138 Decision of MCEC 14 March 2013
139. C-139 Letter from MCEC to Claimant 19 September 2013
140. C-140 Statement of claim to terminate the Investment Contract 14 October 2013
141. C-141 Letter from Manolium-Engineering to MCEC 18 July 2014
142. C-142 Decision of MCEC 15 August 2014
143. C-143 Letter from Minsktrans to Manolium-Engineering 19 September 2014
144. C-144 Official website of State Production Association Minskstroy, About Association Accessed on 8 February 2017
145. C-145 Ruling of the Economic Court of Minsk on scheduling a forensic expertise and suspending court proceedings 30 July 2014
146. C-146 Ruling of the Economic Court of Minsk on resuming court proceedings 1 September 2014

[Page 9]

No. Exhibit Description Date
Claimant’s Factual Exhibits
147. C-147 Judgment of the Economic Court of Minsk 9 September 2014
148. C-148 Official website of information and analytical weekly publication BelGazeta, Watered irrigators 23 May 2016
149. C-149 Appeal of Manolium-Engineering 9 October 2014
150. C-150 Ruling of the instance of appeal of the Commercial court of Minsk 29 October 2014
151. C-151 Cassation appeal of Manolium-Engineering 29 November 2014
152. C-152 Decision of the Supreme Court of the Republic of Belarus 27 January 2015
153. C-153 Minutes of the meeting attended by MCEC, Minsktrans and Claimant 4 February 2015
154. C-154 Registration and Cadastre Agency Report (as submitted to the Tribunal on 18 April 2019, extended translation) 16 June 2015
155. C-155 Letter from Manolium-Engineering to MCEC 17 June 2015
156. C-156 Letter from MCEC to Manolium-Engineering 7 August 2015
157. C-157 Letter from Manolium-Engineering to MCEC 20 August 2015
158. C-158 Letter from MCEC to Manolium-Engineering 4 September 2015
159. C-159 Order of the Ministry of Finance 3 February 2016
160. C-160 CAO of the Ministry of Finance Report (as submitted to the Tribunal on 18 April 2019, extended translation) 22 February 2016
161. C-161 Letter from Claimant to MCEC 21 April 2016
162. C-162 Decision of the Economic Court of Minsk 13 May 2016
163. C-163 Decision of the Economic Court of Minsk 14 June 2016
164. C-164 First Tax Audit Report 17 May 2016
165. C-165 Letter from the Tax Inspectorate to Manolium-Engineering 21 June 2016

[Page 10]

No. Exhibit Description Date
Claimant’s Factual Exhibits
166. C-166 Amendments and supplements to the First Tax Audit Report 21 June 2016
167. C-167 Order of the Tax Inspectorate for arrest of the land plots 5 July 2016
168. C-168 Decision of the Tax Inspectorate 19 July 2016
169. C-169 Application of the Tax Inspectorate 20 July 2016
170. C-170 Judgment of the Economic Court of Minsk 18 August 2016
171. C-171 Extract from the records of the Ministry of Taxes in respect of the indebtedness of Manolium-Engineering as 10 November 2016
172. C-172 Letter from the Department of Humanitarian Activities of the Administrative Office of the President of the Republic of Belarus 18 November 2016
173. C-173 Decision of MCEC 1 December 2016
174. C-174 Official website of MCEC, On the enterprise Accessed on 29 May 2018
175. C-175 Official website of Minsktrans, General information Accessed on 29 May 2018
176. C-176 Official website of the Organization for Economic Cooperation and Development Accessed on 15 November 2017
177. C-177 Public Sector Transparency and the International Investor, Organization for Economic Co-operation and Development 2003
178. C-178 Policy Framework for Investment, version of 2015, Organization for Economic Co-operation and Development, OECD publishing house, Paris 2015
179. C-179 Official portal of the system of common courts of the Republic of Belarus, Information on cases in connection with economic insolvency (bankruptcy) for the period from 1 February 2017 through 28 February 2017 Accessed on 15 November 2017

[Page 11]

No. Exhibit Description Date
Claimant’s Factual Exhibits
180. C-180 Official portal of the system of courts of general jurisdiction of the Republic of Belarus, The Supreme Court issued a judgment in the criminal case involving Grushetsky, Melnikova, Vintskevich, Khaletskaya, Rikun and Gretskaya Accessed on 15 November 2017
181. C-181 Official website of Belarusian telegraph agency Novosti Belarusi, Judges of the Economic Court of Minsk were sentenced to 11 and years in prison 4 July 2016
182. C-182 Resolution of the court of the Pervomaysky district of Minsk (operative part and statement of reasons) 17 May 2016
183. C-183 Complaint of Manolium-Engineering to the resolution of the court of the Pervomaysky district of Minsk 9 June 2016
184. C-184 Resolution of the Minsk City Court 3 August 2016
185. C-185 Official website of news portal of Belarus TUT.BY, Almost fivefold of the initial price. A-100 acquired the section of the trolleybus depot in the center of Minsk 12 September 2017
186. C-186 Amendments to the Second Tax Audit Report 18 May 2017
187. C-187 Second Tax Audit Report 24 March 2017
188. C-188 Decision of the Tax Inspectorate in respect of the Second Tax Audit Report and amendments to the Second Tax Audit Report 13 June 2017
189. C-189 Letter from the Tax Inspectorate to Manolium-Engineering 22 September 2017
190. C-190 Pre-Arbitration Notice of Claimant (without attachments) 25 April 2017
191. C-191 Letter from the Ministry of Economy of the Republic of Belarus to Claimant 24 October 2017
192. C-192 Letter from Claimant to the Ministry of Economy of the Republic of Belarus 27 October 2017
193. C-193 Letter from the Ministry of Economy of the Republic of Belarus to Claimant 30 October 2017

[Page 12]

No. Exhibit Description Date
Claimant’s Factual Exhibits
194. C-194 Letter from Claimant to the Ministry of Economy of the Republic of Belarus 1 November 2017
195. C-195 Letter from the Ministry of Economy of the Republic of Belarus to Claimant 14 November 2017
196. C-196 About Commonwealth of Independent States Accessed on 10 May 2018
197. C-197 Eurasian Economic Community, About EurAsEC Accessed on 10 May 2018
198. C-198 Eurasian Economic Union, About the Union Accessed on 10 May 2018
199. C-199 [Redacted] [Redacted]
200. C-200 [Redacted] [Redacted]
201. C-201 Respondent's letter to Claimant 22 June 2018
202. C-202 Claimant's letter to Respondent 27 June 2018
203. C-203 Respondent's letter to Claimant 27 June 2018
204. C-204 Claimant's letter to the Arbitral Tribunal 29 June 2018
205. C-205 Human Rights Watch World Report 2014: Belarus. Events of 2013. Accessed on 27 July 2018
206. C-206 Human Rights Watch World Report 2018: Belarus. Events of 2017 Accessed on 27 July 2018
207. C-207 US Department of State, Country Reports on Human Rights Practices for 2017: Belarus 2017
208. C-208 Charter-97 website, How Many Investors To Be Imprisoned In Belarus? Accessed on 27 July 2018
209. C-209 Reuters website, From potash powerbroker to Minsk prison, the cost of crossing Belarus 8 September 2013

[Page 13]

No. Exhibit Description Date
Claimant’s Factual Exhibits
210. C-210 RadioFreeEurope RadioLiberty website, Russia Puts Uralkali Chief Under House Arrest December 2013
211. C-211 ICSID website, GRAND EXPRESS Non-Public Joint Stock Company v. Republic of Belarus, ICSID Case No. ARB(AF)/18/1, Case Details Accessed on 4 October 2018
212. C-212 Decision of Court of Appeal of Athens, Greece 14 September 2018
213. C-213 News Tut.by website, European Parliament Members has condemned harassment and detention of journalists in Belarus 4 October 2018
214. C-214 Reuters website, From potash powerbroker to Minsk prison, the cost of crossing Belarus 8 September 2013
215. C-215 Loans provided to Manolium-Engineering (excel file) 2004-2013
216. C-216 Loan agreements and confirmations of loan transfers from Bradley Enterprises Ltd. to Manolium-Engineering
217. C-217 Loan agreements and confirmations of loan transfers from Lascker Ltd. to Manolium-Engineering
218. C-218 Loan agreements and confirmations of loan transfers from Nomal Oil Ltd. to Manolium-Engineering
219. C-219 Loan agreements and confirmations of loan transfers from Manolium Trading Ltd. to Manolium-Engineering
220. C-220 Loan agreements and confirmations of loan transfers from Foreign LLC Manolium Processing to Manolium-Engineering
221. C-221 Letter from Minsk City Executive Committee to Claimant (with draft Addendum to the Investment Contract) 5 January 2006
222. C-222 Architectural design, Organization of construction of the Trolleybus Depot, Volume 2, Unitary Enterprise Avtorempromproekt at the Ministry of Industry of the Republic of Belarus 2005

[Page 14]

No. Exhibit Description Date
Claimant’s Factual Exhibits
223. C-223 Report of Republican Unitary Enterprise Belgosekspertiza [Belarusian state expert review] of the Ministry of Construction and Architecture of the Republic of Belarus 17 September 2005
224. C-224 Letter from Minsk City Executive Committee to Claimant 19 November 2003
225. C-225 Contract for conditions of design and construction of Communal Facilities between Minsktrans and Claimant 9 December 2003
226. C-226 Minsktrans letter to Minsk City Executive Committee 13 January 2005
227. C-227 Letter from Manolium-Engineering to Minsk City Executive Committee 4 May 2007
228. C-228 Letter from Minsk Land Management and Geodetic Service to Manolium-Engineering 7 May 2007
229. C-229 Architectural Planning task for the Road 14 June 2007
230. C-230 Letter from Manolium-Engineering to Minsk City Executive Committee 15 December 2009
231. C-231 General view of land plots for the New Communal Facilities before deforestation (Google Earth shot) 3 April 2004
232. C-232 Opinion of Minsk Architecture and City Planning Committee of Minsk City Executive Committee 4 February 2008
233. C-233 Letter from Manolium-Engineering to Minsk District Executive Committee 13 March 2008
234. C-234 Decision of Minsk District Executive Committee 9 April 2008
235. C-235 Letter from Manolium-Engineering to Minsk Forest Household 11 April 2008
236. C-236 Forest felling license 2 May 2008
237. C-237 General view of land plots for the New Communal Facilities after deforestation (Google Earth shot) 13 July 2008
238. C-238 Technical specification of Minsktrans for design and construction of the Trolleybus Depot 24 November 2003

[Page 15]

No. Exhibit Description Date
Claimant’s Factual Exhibits
239. C-239 Letter from Manolium-Engineering to Unitary Enterprise Autorempromproject 4 September 2007
240. C-240 Letter from Manolium-Engineering to Unitary Enterprise MinskIngProject 24 September 2008
241. C-241 Letter from Manolium-Engineering to Unitary Enterprise MinskIngProject 13 July 2009
242. C-242 Letter from Manolium-Engineering to Unitary Enterprise Autorempromproject 17 May 2010
243. C-243 Letter from CJSC Trest Bel PSP-stroy to Manolium-Engineering 1 March 2011
244. C-244 Letter from Manolium-Engineering to Unitary Enterprise Autorempromproject 3 August 2007
245. C-245 Letter from Manolium-Engineering to Unitary Enterprise Autorempromproject 15 April 2008
246. C-246 Letter from Manolium-Engineering to Unitary Enterprise Autorempromproject 12 June 2008
247. C-247 Letter from Manolium-Engineering to Unitary Enterprise Autorempromproject 13 June 2008
248. C-248 Letter from Manolium-Engineering to Unitary Enterprise Autorempromproject 21 August 2008
249. C-249 Letter of Manolium-Engineering to Unitary Enterprise Autorempromproject 5 May 2009
250. C-250 Letter of Manolium-Engineering to Unitary Enterprise Autorempromproject 8 June 2010
251. C-251 Letter from Manolium-Engineering to Unitary Enterprise Autorempromproject 26 August 2010
252. C-252 Letter from Manolium-Engineering to Minsk City Executive Committee 5 March 2008
253. C-253 Letter from Manolium-Engineering to Minsk City Executive Committee 13 September 2007
254. C-254 Letter from Manolium-Engineering to OJSC Stroytrest 28 March 2008

[Page 16]

No. Exhibit Description Date
Claimant’s Factual Exhibits
255. C-255 Official website of the Republic of Belarus, Press-release Belarus President's Team Outplays Hockey Legends of the USSR in Friendly 20 May 2014
256. C-256 Letter from Manolium-Engineering to Minsk City Executive Committee 6 September 2010
257. C-257 Letter from Manolium-Engineering to Gosstroy 18 July 2011
258. C-258 Letter from Manolium-Engineering to Minsk City Executive Committee 24 August 2011
259. C-259 Letter from Manolium-Engineering to Minsk City Executive Committee 5 September 2011
260. C-260 Letter from Minsktrans to contractor 6 October 2011
261. C-261 Letter from Manolium-Engineering to Gosstroy 30 January 2008
262. C-262 Construction permit issued by Gosstroy for constructing the Depot 7 February 2008
263. C-263 Decision of Minsk City Executive Committee 3 September 2009
264. C-264 Letter from Manolium-Engineering to Gosstroy 24 December 2009
265. C-265 Construction permit issued by Gosstroy for constructing the Depot 25 January 2010
266. C-266 Construction permit issued by Gosstroy for constructing the Depot 21 April 2010
267. C-267 Decision of Minsk City Executive Committee 16 September 2010
268. C-268 Letter from Manolium-Engineering to Gosstroy 29 October 2010
269. C-269 Construction permit issued by Gosstroy for constructing the Depot 20 December 2010
270. C-270 Letter from Manolium-Engineering to Gosstroy 19 January 2011
271. C-271 Construction permit issued by Gosstroy for constructing the Depot 27 January 2011
272. C-272 Letter from Manolium-Engineering to Gosstroy 22 May 2008

[Page 17]

No. Exhibit Description Date
Claimant’s Factual Exhibits
273. C-273 Scheme of affiliation in the Claimant's group of companies
274. C-274 Website of news portal Politics of Orenburg, Orenburg Businessmen Joined the Ranks of Beneficiaries of Russol 16 January 2017
275. C-275 Website of newspaper Kommersant, New Candidate for Salavatnefteorgsintez, Enterprise Could Be Received By Rosneft 14 November 2006
276. C-276 Website of news portal Russian Business Consulting, Owners of Russol Broke through Offshores, the Major Russian Producer of Salt Disclosed All Beneficiaries 13 January 2017
277. C-277 Article of incorporation of Tekstur 25 August 2006
278. C-278 Protocol No. 2 of extraordinary meeting of participants of Tekstur 1 December 2014
279. C-279 Extract from Protocol No. 14 of meeting of administration of Central district of Minsk 23 April 2003
280. C-280 Extract from Protocol No. 15 of meeting of administration of Central district of Minsk 22 July 2003
281. C-281 Decision of Minsk City Executive Committee 7 August 2003
282. C-282 Contract-obligation between Minsk City Executive Committee and Tekstur on reconstruction of the Revolutionary Building 28 November 2003
283. C-283 Addendum No. 1 to Contract-obligation between Minsk City Executive Committee and Tekstur on reconstruction of the Revolutionary Building 26 April 2005
284. C-284 Act of acceptance of technical passports and documents of entitlement to apartments for resettle inhabitants of Revolutionary Building 8 December 2005
285. C-285 List of cost of apartments purchased by Tekstur in accordance with Contract-obligation between Minsk City Executive Committee and Tekstur on reconstruction of the Revolutionary Building as of the transfer date of apartments 28 November 2003

[Page 18]

No. Exhibit Description Date
Claimant’s Factual Exhibits
286. C-286 Letter from Tekstur to Minsk City Executive Committee 9 December 2005
287. C-287 Letter from Tekstur to Minsk City Territory Fund of State Property 9 December 2005
288. C-288 Letter from Tekstur to Minsk City Executive Committee 12 December 2006
289. C-289 Letter from Communal Unitary Enterprise Minskaya Spadchina to Tekstur 26 September 2005
290. C-290 Resolution of President of the Republic of Belarus on transfer of the Revolutionary Building to Tekstur 24 February 2010
291. C-291 Decision of Minsk City Executive Committee 25 February 2010
292. C-292 Letter from Minsk City Executive Committee to Tekstur 16 January 2007
293. C-293 Internal briefing paper of Minsk City Executive Committee, On Application of Tekstur LLC 26 January 2007
294. C-294 Evaluation report of Unitary Enterprise Proektrestavratsiya 13 February 2008
295. C-295 Extract from Protocol No. 44 of meeting of Commission of Minsk City Executive Committee 6 March 2008
296. C-296 Letter from Communal Unitary Enterprise Minskaya Spadchina to Tekstur 14 March 2008
297. C-297 Extract from Protocol No. 45 of meeting of Commission of Minsk City Executive Committee 21 March 2008
298. C-298 Letter from Tekstur to Minsk City Executive Committee 9 June 2008
299. C-299 Letter from Minsk City Executive Committee to Tekstur 2 September 2008
300. C-300 Sale Contract of Revolutionary Building between Communal Unitary Enterprise Minskaya Spadchina and Tekstur 3 June 2010
301. C-301 Martin Ebon, KGB: Death and Rebirth, Greenwood Publishing Group, (extracts) 1994

[Page 19]

No. Exhibit Description Date
Claimant’s Factual Exhibits
302. C-302 Website of newsportal UDF.BY, Why Belarus KGB Detained the Country's Former Top Businessman 18 March 2016
303. C-303 Website of news portal TUT.BY, KGB: Chyzh Confessed and Refunded the Losses 16 September 2016
304. C-304 Website of news portal TUT.BY, Chronicles of Business Clearing: Top-10 Stories 15 November 2016
305. C-305 Resolution of the European Parliament on the situation in Belarus 20 January 2011
306. C-306 Website of newsportal CBC, Belarus Election Ends with Violent Protests 19 December 2010
307. C-307 Website of Voice of America, Break Up of the Opposition's Rally in Minsk: What I Saw 19 December 2010
308. C-308 Website of news portal TUT.BY, Square, 19 December 2010, How It Was 20 December 2010
309. C-309 Website of Pulitzer Center, Dark Days in Belarus, Virginia Quarterly Review 11 December 2010
310. C-310 Website of BelarusFeed, The Last Large Protest: 19 Dec Marks Six Years Since Belarus 2010 Election Riot
311. C-311 Website of news portal VIASNA, Police and KGB Raid Apartments and Offices. Tatsiana Reviaka's flat NOT raided 25 December 2010
312. C-312 Website of news portal RadioFreeEurope/RadioLiberty, KGB Raid on Belarusian Activist's Home Captured in 45-Minute Recording 12 January 2011
313. C-313 Website of news portal CHESNOK, Committee Almighty: What is beyond KGB Arrests 26 July 2018
314. C-314 Act of Acceptance 5 September 2011
315. C-315 Act of Acceptance 14 October 2011
316. C-316 Letter from Manolium-Engineering to Minsk City Executive Committee 20 February 2014

[Page 20]

No. Exhibit Description Date
Claimant’s Factual Exhibits
317. C-317 Order of Manolium-Engineering No. 1-C 1 September 2011
318. C-318 Test protocol of State Enterprise Department of road-bridges construction and municipal improvement of the Minsk City Executive Committee on pavement of the Road 22 August 2012
319. C-319 Letter from Manolium-Engineering to Minsk City Executive Committee 28 October 2013
320. C-320 Protocol of meeting between Minsktrans and Manolium-Engineering 18 January 2012
321. C-321 Letter from Minsktrans to Manolium-Engineering 26 January 2012
322. C-322 Protocol of meeting between Minsktrans and Manolium-Engineering 23 March 2012
323. C-323 Website of news portal Blizko, Construction of Trolleybus Depot in Uryuch'e Was Resumed - Its Construction Was Frozen 14 December 2018
324. C-324 Minutes of the meeting attended by Minsk City Executive Committee, Minsktrans and Manolium-Engineering of 9 August 2012
325. C-325 Photographs of the land plot within streets Kiseleva-Krasnaya- Masherova intended for the construction of Investment Object, currently occupied by old Trolleybus Depot No. 1 (not in use) 20 September 2018
326. C-326 Letter from Minsktrans to Manolium-Engineering 14 September 2012
327. C-327 Letter from Minsktrans to Minsk City Executive Committee 8 November 2010
328. C-328 Letter from Minsktrans to Manolium-Engineering 14 October 2010
329. C-329 Act of technical investigation of accident on Pull Station 29 November 2010
330. C-330 Letter from Minsktrans to Manolium-Engineering 27 March 2012
331. C-331 General view of land plots for the New Communal Facilities (Google Earth shot) 29 May 2011

[Page 21]

No. Exhibit Description Date
Claimant’s Factual Exhibits
332. C-332 General view of land plots for the New Communal Facilities (Google Earth shot) 30 July 2012
333. C-333 Video of the Road in Minsk 20 February 2019
334. C-334 General view of land plots for the New Communal Facilities (Google Earth shot) 18 September 2014
335. C-335 Photographs of New Communal Facilities 20 September 2018 and 20 February 2019
336. C-336 Letter from Manolium-Engineering to Minsk City Executive Committee 11 June 2012
337. C-337 Letter from Minsk Land Planning Service to Manolium-Engineering 17 July 2012
338. C-338 Letter from Minsktrans to Manolium-Engineering 26 March 2013
339. C-339 Letter from Minsk City Executive Committee to Manolium-Engineering 28 March 2013
340. C-340 Letter from Manolium-Engineering to Minsk City Executive Committee 19 September 2016
341. C-341 Letter from Minsk City Executive Committee to Manolium-Engineering 29 September 2016
342. C-342 Claimant's decision 12 June 2013
343. C-343 Protocol of Minsk Land Planning Service of Minsk City Executive Committee on administrative offence No. 17 18 March 2016
344. C-344 Protocol of Minsk Land Planning Service of Minsk City Executive Committee on administrative offence No. 20 18 March 2016
345. C-345 Protocol of Minsk Land Planning Service of Minsk City Executive Committee on administrative offence No. 21 18 March 2016
346. C-346 Resolution of Pervomayskiy district court of Minsk 23 July 2012
347. C-347 Website of Washington Post, Why Europe's Last Dictatorship Keeps Surprising Everyone 25 March 2017

[Page 22]

No. Exhibit Description Date
Claimant’s Factual Exhibits
348. C-348 Website of Minsktrans, History of the Enterprise and of Transport in the City of Minsk
349. C-349 Interfax.by website, The City Transport Tariffs in Minsk Will Increase by 38.7% up to 1.3 BYR"
350. C-350 Opinion from the Minsk Architecture and City Planning Committee 30 May 2006
351. C-351 Letter from Manolium-Engineering to Minsktrans 7 October 2011
352. C-352 General view of land plots for the New Communal Facilities (Google Earth shot) 24 September 2010
353. C-353 Internal Memorandum of Deputy Chair of Administration of President of the Republic of Belarus 13 January 2009
354. C-354 Certificate of the Minsk Agency for State Registration and Land Cadastre on evaluation of Revolutionary Project building 1 January 2006
355. C-355 Letter from Tekstur to Chair of Commission on determining conditions of sale of transferred real estate objects of Minsk communal ownership 12 March 2008
356. C-356 Evaluation report of Unitary Enterprise Proektrestavratsiya 10 November 2009
357. C-357 Letter from Tekstur to Minsk City Executive Committee 4 December 2009
358. C-358 Notice of refusal in state registration of Minsk Agency for State Registration and Land Cadastre 15 July 2010
359. C-359 Letter from Tekstur to Minsk City Executive Committee 23 August 2010
360. C-360 Letter from Minsk City Executive Committee to Tekstur 13 September 2010
361. C-361 Decision of Economic Court of the city Minsk 27 December 2010
362. C-362 Architecture design of the Revolutionary Project 2012

[Page 23]

No. Exhibit Description Date
Claimant’s Factual Exhibits
363. C-363 Website of news portal TUT.BY, Lukashenko Instructed to Revise the Investment Project on the Construction of Multifunctional Center of Squares of Horizon in Minsk 4 August 2014
364. C-364 Website of news portal TUT.BY, Depot on the Horizon or How the Authorities Are Planning to Use Two Dainty Land Plots in the Center of Minsk? 10 March 2017
365. C-365 Letter from Minsk City Executive Committee to the Claimant 11 December 2014
366. C-366 Letter of Manolium-Engineering to President of the Republic of Belarus 12 October 2015
367. C-367 Share Certificate № 1 and Instrument of Transfer for Lascker Ltd 6 December 1997
368. C-368 Share Certificate № 5 and Declaration of Trust for Manolium Trading Ltd 22 November 1999
369. C-369 Share Certificate № 6 and Declaration of Trust for Manolium Trading Ltd 22 November 1999
370. C-370 Minutes of meeting of Manolium Trading Ltd 8 November 2000
371. C-371 Declaration of Trust for Bradley Enterprises Ltd 3 December 2001
372. C-372 Declaration of Trust and Share Certificate № 3 for Contresas Ltd 23 March 2007
373. C-373 Declaration of Trust for Bradley Enterprises Ltd 11 October 2007
374. C-374 Minutes of meeting of Contresas Ltd 15 October 2007
375. C-375 Share Certificate № 7 and Declaration of Trust for Manolium Trading Ltd 17 July 2008
376. C-376 Share Certificate № 8 and Declaration of Trust for Manolium Trading Ltd 17 July 2008
377. C-377 Minutes of meeting of Manolium Trading Ltd 17 July 2008
378. C-378 Declaration of Trust for Manolium Trading Ltd (1 – 125 000 shares) 1 January 2009

[Page 24]

No. Exhibit Description Date
Claimant’s Factual Exhibits
379. C-379 Declaration of Trust for Manolium Trading Ltd (125 001 – 250 000 shares) 1 January 2009
380. C-380 Minutes of meeting of Manolium Trading Ltd 1 January 2009
381. C-381 Share Certificate № 4 and Declaration of Trust for Lascker Ltd 14 January 2009
382. C-382 Minutes of meeting of Lascker Ltd 14 January 2009
383. C-383 Resolution of Claimant 29 March 2011
384. C-384 Annual Report of Nomal Oil Ltd 23 September 2011
385. C-385 Annual Report of Nomal Oil Ltd 23 September 2012
386. C-386 Resolution of Bradley Enterprises Ltd 19 February 2015
387. C-387 Instrument of Cancellation 19 February 2015
388. C-388 Extract from Register of Companies for Claimant 27 March 2019
389. C-389 Financial Statement (Balance Sheet) of Manolium-Engineering for 2012 29 March 2013
390. C-390 Letter of Stateco (Nominees) Limited, Declaration of Trust, Instrument of Transfer and Share Certificate No. 11 for Manolium-Trading Ltd (1 - 125 000 shares) 19 December 2014
391. C-391 Letter of Stateco (Nominees) Limited, Declaration of Trust, Instrument of Transfer and Share Certificate No. 12 for Manolium-Trading Ltd (125 001 - 250 000 shares) 19 December 2014
392. C-392 Instrument of Transfer for Manolium-Trading Ltd (1 - 125 000 shares) 25 January 2015
393. C-393 Instrument of Transfer for Manolium-Trading Ltd (125 001 - 250 000 shares) 25 January 2015
394. C-394 Extract from the Belarusian Registry of Legal Entities for Manolium-Processing Foreign LLC 16 September 2019
395. C-395 Extended Graphic of the Flow of Capital and Financing of the Claimant's Group of Companies