IN THE HIGH COURT OF IKEJA

IN THE JUDICIAL DIVISION

HOLDEN AT IKEJA DISTRICT,LAGOS-NIGERIA

AFFIDAVIT OF CLAIM

I Barrister ALI LUKMAN. (Senior Advocate of Nigeria) male, Citizen of Nigeria full age and
capacity, a Solicitor and Advocate of the Supreme Court of Nigeria with office at Bourdillon Road S.W
Ikoyi Lagos , do hereby make affidavit of claim and swear as follows;

1) That my professional legal services was retained by MR. EDWARD BROWDER owner of
IONTRONICS LTD at 1300 N 4th St-Suite 5 Berthoud, Colorado 80513 USA residing in the
United States of America.

2) That Edward Browder is a bonafide Contractor to the Federal Ministry for

Environment/Ministry for Finance and executed a Contract Job with Number: FMEnv-DPR-
3401/PED/2001.

3) That Edward Browder is the right ownership rights holder of USD27.3m(Twenty Seven Million,
three Hundred Thousand United States Dollars Only) as under payment review by the Contract
Payment Review Board Commission of the Federal Ministry for Finance.

4) That Edward Browder has fulfilled all required Contract Payment requirements as under the the
provisions of the Federal Republic of Nigeria Contract Award Rights Act of 1997 as re-enacted
2003.

5) That Edward Browder recognizes solely Ali Lukman & Associates being his legal representative
to act under any capacity resulting in the release of the funds to Edward Browder.

6) That this Affidavits is official and for records purposes.

7) That where to I depose to this Affidavit sworn before the Commissioner of Oath consciously
believing the contents to be true and correct to the best of my knowledge and in accordance
with the Contract Payment Review Act of 1963 as re-amended 2005.

SWORN to at the Ikeja High Court Registry

Lagos this ....12........... day of...July............. 2006

Claimant:

KUMURA DITIA BEFORE ME: Efineat Huilt

COMMISSIONER FOR OATH