This HTML version is machine-generated. Always consult the original document.

[Page 1]

UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA

------------------------------------------------------------------ x

------------------------------------------------------------------ x

DECLARATION OF MARCUS J. GREEN IN SUPPORT OF
PETITION TO CONFIRM ARBITRATION AWARD

In support of the Petition to Confirm Arbitration Award filed by Process and Industrial
Developments Limited, I, Marcus J. Green, do hereby declare and state as follows:

1. I am an attorney at the law firm Kobre & Kim LLP and am licensed to practice
law in the District of Columbia.

2. On February 5, 2018, I caused a paralegal at my firm to obtain, through a
document-retrieval service known as Thomson Reuters Court Express, photocopies of certain
court filings in an action captioned Malabu Oil & Gas Limited v. Federal Republic of Nigeria, et
al., 02-cv-6162, before the United States District Court for the Southern District of New York.
Hereinafter I refer to that action as the Malabu Action.

3. Attached as Exhibit 1 hereto is what I understand to be a true and correct copy of
a Notice of Motion filed on April 15, 2003, by Defendants Federal Republic of Nigeria and
Nigerian Ministry of Petroleum Resources (Dkt. No. 10) in the Malabu Action. The Notice of

[Page 2]

Motion is attached hereto in the form in which I understand it was filed in that action, with
several “annexed” documents combined into a single filing. Those “annexed” documents
include an April 10, 2003 Declaration of Idenyehim Stella Omiyi, which can be found on the
fourth and fifth pages of the full document.

4. Attached as Exhibit 2 hereto is what I understand to be a true and correct copy of
a Memorandum of Law in Support of Motion to Dismiss filed on April 15, 2003, by Defendants
Federal Republic of Nigeria and Nigerian Ministry of Petroleum Resources (Dkt. No. 11) in the
Malabu Action.

5. I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 16th day of March, 2018.

/s/ Marcus J. Green

Marcus J. Green
(D.C. Bar. No. 999223)