Re: Foreign Corrupt Practices Act Due Diligence Questionnaire

Mike,

Here is where we are at.

Billing:

1) October 12 will be the pay through date for 3D which extends and accounts for the last tender submission.

2) I have reviewed the documents 3D sent to Arrow and they are not acceptable to Arrow.Â 3D cannot have open access to Arrowâs financials.Â This is exactly the position 3D has taken with regard to the documents sent to Luk Oil so this should not be a surprise and I find it an âodd requirementâ or an unacceptable provision contained in no other KYCâs that Iâve seen.Â In addition, these are 3D KYCâs not Luk Oils.ÂÂ In fact, I have seen no communication from Luk oil which describes or indicates they even know they are doing business with Arrow.Â I know they are doing business with 3D as is evident from your e-mails.Â I am directing Arrow not to compensate 3D for the Russian portion of the trip at this point because none of what was promised from that trip was delivered.Â Indeed, the Russian component of the trip seems to have diverted resources away from the Paki submission which was more time critical and based on all the exchanges prior to the trip including our phone discussion prior to you getting on the plane as to whether the trip was still necessary there was a promise that you were bringing back documentation from Russian and that simply did not happen.Â It was clearly discussed in Dubai that Arrow has no issue with 3D doing its business but it will not pay 3D to do it.Â This KYC issue has not been addressed properly at all.Â I will await one last time to hear what you have to say on this but telling me you are waiting on the KYC for Luk from me is not good to go.Â I went back and reviewed the entire exchange re Russia and that wasnât part of the discussion and the time critical need for the trip had no tie in with the impending proposals.Â In other words we could have waited on that trip if it was even needed (for Arrowâs business).Â If you want to forward the e-mails discussing Arrow with Luk Oil then that will be considered.Â All exchanges should be provided and sent to both myself and H within the next business day.

3) Tracy -Â he is being well overpaid and producing little if anything.Â While there is no dispute regarding his technical competencies his absence of work product for 20K needs to be resolved immediately.Â ÂIf he is unable or unwilling to produce work product then he will be terminated.Â Arrow will not continue to pay him to sit in his hotel roomâthis is simply malingering.Â He is being paid a CEO level salary and is absent.Â

Arrow and 3D

1) ÂIf the contracts are awarded then we will address the way ahead and draft a new agreement accordingly as was previously contemplated.

2) Arrow is not interested in reentering another contract like the one that was previously entered into on the first solicitation.Â 20k for Tracy to basically write the 9 pages is not a fiscally prudent option for Arrow.Â If 3D is interested in bringing additional contracts to the table and undergoing any bid solicitation then it will need to significantly alter its fee requirements and provide full disclosure as to who will be working on the proposal.Â

3) None of the things discussed in Dubai have been addressed.Â Arrow will compensate for this leg of travel and for that time so Mr. H expects responses to the issues he addressed in that meeting.

Items owed:

1) Dubai tasker update.

2) Russian trip substantiating material to include how Arrow qualifies to important given that they seemingly âviolateâ the military delivery proscription within Luk Oil KYC.

3) Tracy job status

4) New work proposal by 3Dâif no intention to submit this is contemplated then please advise by COB Friday so we can seek out viable alternatives.

5) Luk Oil e-mails.

Eric

-
Eric S. Montalvo
Attorney at Law
1800 Diagonal Road

Suite 210

Alexandria, VA 22314

eric@puckettfaraj.com

(703) 706-9566Â Phone

(540) 840-7717Â Cell
(202) 318-7652 Fax

DC × CA × MI × VA
www.PuckettFaraj.com

Practice is limited to matters and proceedings before special courts - federal courts - agencies. Confidentiality / Privilege Notice: This transmission, including attachments, is intended solely for the use of the designated recipient(s). This transmission may contain information that is confidential and/or privileged or otherwise protected from disclosure. The use or disclosure of the information contained in this transmission for any purpose other than that intended by its transmittal is strictly prohibited. If you are not an intended recipient of this transmission, please immediately destroy all copies received and notify the sender.

From: Michael Dodd [mailto:mike.dodd@3dglobalsolutions.net]
Sent: Monday, October 25, 2010 10:28 AM
To: eric@puckettfaraj.com; Ryan Shane; Tracy Clark; Mohammad Fahim
Subject: RE: Foreign Corrupt Practices Act Due Diligence Questionnaire

Eric,

are you still on point on this? Would be great to have soonest, as Luk is looking to offer Arrow some cargoes and begin transacting.

From: eric@puckettfaraj.com [mailto:eric@puckettfaraj.com]
Sent: Monday, October 18, 2010 10:03 PM
To: Ryan Shane; Tracy Clark; Mohammad Fahim; Michael Dodd
Subject: Re: Foreign Corrupt Practices Act Due Diligence Questionnaire

Ryan

Told mike I would address this on tues

R
E

Sent via BlackBerry by AT&T

From: Ryan Shane <ryan.shane@3dglobalsolutions.net>

Date: Mon, 18 Oct 2010 19:57:47 -0400

To: 'eric@puckettfaraj.com'<eric@puckettfaraj.com>

Subject: Fw: Foreign Corrupt Practices Act Due Diligence Questionnaire

Eric,

Hi again. Following up on this as well and I have asked Tracy to try and link up with H and his folks to help them fill this doc out as well.

Regards,

Ryan

From: Ryan Shane
Sent: Friday, October 08, 2010 04:16 PM
To: 'Eric Montalvo' <eric@puckettfaraj.com>
Cc: 'me me' <mustreport@googlemail.com>
Subject: Foreign Corrupt Practices Act Due Diligence Questionnaire

Eric,

Attached for Arrow to fill out and sign is a Foreign Corrupt Practices Act Due Diligence Questionnaire.

Thanks!

Ryan

Ryan Shane

Program Manager

1185 Ave of the Americas Suite 1750
New York, NY 10036
ryan.shane@3dglobalsolutions.net

www.3dglobalsolutions.net

Direct Dial 732.584.0609

Fax 866.238.6761

Cell 973.610.6797

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