| Mr. Dodd, My Thursday just evaporated. Have to be in court up until I leave for Italy. Will have to revisit this effort after Christmas. V/r, Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Dec 14, 2010, at 8:20 AM, Michael Dodd wrote: Neal, Thurs morning from 8:30am - 10am works for me, please advise if open for you. Best, Mike Mike Dodd <image001.jpg> One Source. Global Solutions. CEO 1185 Ave of the Americas, Suite 1750 New York, New York 10036 Toll free (866) 238-6761 ext 111 Direct Dial 212-205-6171 Fax 866-238-6761 International Cell 001-212-729-6959 This electronic message transmission contains information from 3D Global Solutions which may be confidential or privileged and is otherwise protected by law under the Electronic Communications Privacy Act [18 United States Code ÂÂ 2510-2711]. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by calling the sender at 866-238-6761 immediately, and delete or destroy all copies of this transmission. Alternatively, you may contact us by electronic mail at MIS@3Dglobalsolutions.net From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Monday, December 13, 2010 4:42 PM To: Michael Dodd Cc: Montalvo Eric Subject: Re: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Mr. Dodd, I would be happy to participate in the discussion you propose. Unfortunately, I don't believe that can happen until at least Thursday. I'm checking with Eric for his availability for that day, as he is out of town until Friday, as well. I'm available Thursday morning, but depart for Sicily on business early Thursday afternoon. I'm in trial all day tomorrow and Wednesday. Please let me know how Thursday looks for your schedule. V/r, Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Dec 12, 2010, at 11:47 AM, Michael Dodd wrote: Neal, I would sincerely appreciate the opportunity to review this with you and Erik this week. I believe Haytham has briefed you some of the scenario, and to be perfectly candid, I would appreciate a fresh perspective on the discussion points. I will forward the contracts and scope of service for your review for the discussion. One reason I believe the conversation must be this week; I received a very disturbing phone call from my Russian partner and his attorney, which I briefed Haytham on in detail, and I would ask you speak with him for details. And while Haytham and your firm have represented 3DGS and me as a client, I am not a litigious person. I sincerely am looking for "middle ground" if it exists between 3DGS and Arrow. Haytham speaks very highly of you and I sincerely would like a fresh opinion. If you would like, I can make available LtGen Frank Libutti (our President), Joe Grano (Board Member and former CEO UBS), Lew Merletti (Board Member and former Director of US Service) Many thanks for making yourself available soonest. All the best, Mike Mike Dodd <image001.jpg> One Source. Global Solutions. CEO 1185 Ave of the Americas, Suite 1750 New York, New York 10036 Toll free (866) 238-6761 ext 111 Direct Dial 212-205-6171 Fax 866-238-6761 International Cell 001-212-729-6959 This electronic message transmission contains information from 3D Global Solutions which may be confidential or privileged and is otherwise protected by law under the Electronic Communications Privacy Act [18 United States Code ÂÂ 2510-2711]. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by calling the sender at 866-238-6761 immediately, and delete or destroy all copies of this transmission. Alternatively, you may contact us by electronic mail at MIS@3Dglobalsolutions.net From: Eric S. Montalvo [mailto:eric@puckettfaraj.com] Sent: Thursday, December 09, 2010 11:52 AM To: Michael Dodd Cc: mustreport@googlemail.com; kenneth@puckettfaraj.com; Frank Libutti; neal@puckettfaraj.com Subject: RE: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Next week is not going to work for either of us given each of our court/commitment schedules. Tomorrow afternoon is a possibility. Eric S. Montalvo Attorney at Law 1800 Diagonal Road Suite 210 Alexandria, VA 22314 (703) 706-9566 Phone (540) 840-7717 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: Thursday, December 09, 2010 11:39 AM To: Eric S. Montalvo Cc: mustreport@googlemail.com; kenneth@puckettfaraj.com; Frank Libutti; neal@puckettfaraj.com Subject: RE: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Eric, Please set up a call where you and I and Neal can chat about the open issues. I think a fresh set of eyes would be helpful. and in no way threatening anyone's position at DLA. However if Arrow and 3DGS are no longer a team the contracting officer would need to be notified that the proposal naming them as partners was void and perhaps addendum proposal submitted. I sincerely hope for an award in the next week, so it puts us all to work and reconciliation invoices a heck of a lot easier. Let me know what works for you all. Monday afternoon is best for myself and LtGen Libutti. Mike Dodd <image001.jpg> One Source. Global Solutions. CEO 1185 Ave of the Americas, Suite 1750 New York, New York 10036 Toll free (866) 238-6761 ext 111 Direct Dial 212-205-6171 Fax 866-238-6761 International Cell 001-212-729-6959 This electronic message transmission contains information from 3D Global Solutions which may be confidential or privileged and is otherwise protected by law under the Electronic Communications Privacy Act [18 United States Code ÂÂ 2510-2711]. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by calling the sender at 866-238-6761 immediately, and delete or destroy all copies of this transmission. Alternatively, you may contact us by electronic mail at MIS@3Dglobalsolutions.net From: Eric S. Montalvo [mailto:eric@puckettfaraj.com] Sent: Wednesday, December 08, 2010 12:39 PM To: Michael Dodd Cc: mustreport@googlemail.com; kenneth@puckettfaraj.com; Frank Libutti; neal@puckettfaraj.com Subject: RE: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Mike, I am really unclear what needs to be discussed but I will answer this e-mail in this way. 1) You will receive a letter that memorializes through the U.S. post office everything you have already been provided. 2) I will present this letter to Neal for his review. If you wish to still have the conversation after reviewing indicate as much. I will scan you a copy. 3) I have responded to Ryan's request for invoicing reconciliation and no response to the issues raised in that have been addressed. 4) The KYC point of contact for Lukoil is once again requested. 5) Trip report is once again requested. 6) I would recommend caution with regard to threatening Arrow's position with DLA. A 3D employee is fired and you need to disclosure information that you were paid to acquire. Eric S. Montalvo Attorney at Law 1800 Diagonal Road Suite 210 Alexandria, VA 22314 (703) 706-9566 Phone (540) 840-7717 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: Wednesday, December 08, 2010 6:55 AM To: 'eric@puckettfaraj.com' Cc: 'mustreport@googlemail.com'; 'kenneth@puckettfaraj.com'; Frank Libutti; 'neal@puckettfaraj.com' Subject: Re: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Hashimi met with Tracy Dec 2nd and told him that we would be receiving his termination letter providing 2 weeks notice. Hashimy in that meeting did not identify any performance issues with Tracy. In fact telling him he has done a fine job. We have yet to receive this termination letter for Tracy. Eric I think it would be invaluable to have Haytham and or Neal on a call to review the issues. I think some new, smart guys listening in would help. I am certainly open to it from a perspective of discussions, no binding discussions if we leave there disagreeing and have to involve 3DGS General Counsel. The call must be scheduled soonest, so please advise your availability. If we cannot speak by Dec 14th we will notify the KO of our non participation in any proposals they have and we would also cancel the supply commitments in our name. Please let me know your availability to discuss. I also take your comment that Arrow will not submit required KYC information to Lukoil to establish themselves as an authorized trade partner as your final determination and Arrow has no interest in establishing a trade relationship with Lukoil / LITASCO and their affiliates. Please advise if different. Mike Dodd CEO 3D Global Solutions 212-729-6959 Sent from my Blackberry From: Eric S. Montalvo [mailto:eric@puckettfaraj.com] Sent: Tuesday, December 07, 2010 06:45 PM To: Michael Dodd; Ryan Shane Cc: mustreport@googlemail.com <mustreport@googlemail.com>; kenneth@puckettfaraj.com <kenneth@puckettfaraj.com>; Melissa Katz; Frank Libutti; 'Puckett Neal' <neal@puckettfaraj.com> Subject: RE: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Mike, The intention had been to hash this out in the meeting today which Ryan cancelled this morning. In sum, the questions still have not been answered by 3D. My task today was to discuss the way forward and identify that Arrow is interested in the program management piece if an award were to be granted. I have been directed to inform you that Arrow still desires to maintain open communication and a working relationship. As their attorneyâthis is my piece: I will send a very detailed letter out tomorrow detailing when he was taken off of Arrow's books for failure to perform in addition to the many other concerns regarding that contract that is causing Arrow to lose money on a daily basis to include withholding information and tortuous interference with contract. Date of termination is not changing so that is for 3D to decide how to proceed. You have been provided a month's notice of intent which you have acknowledged and the expressed concerns and took no action. As far as the information provided by Ryan I will address that in a letter as well. This is what was provided: Knaub Andrey Tomskiy Refinery & Euro-Link Holding International Limited Chairman of the Board of Directors Andrej Skrobot LUKOIL Elena Nazarova LUKOIL Aleksandr Ovanesov LUKOIL Dmitriy Popov LUKOIL Oleg Chernokalov LUKOIL Jeffrey R. Fearnside LUKOIL Pan Americas, LLC Clean Products Trader Cesar Figueroa LUKOIL Pan Americas, LLC Ian Eftaxes LUKOIL Pan Americas, LLC Jens Hoffmann LUKOIL Pan Americas, LLC Joseph Colella LUKOIL Pan Americas, LLC Nikita Pozhidaev URALSIB Corporate Finance VP Anikina Svetlana NHKO Commercial Director Trades Marzoev Tamerlan Euro-Link Holding International Limited Fuad Mekhti Uralsib Financial Corporation Investment Banking, Corp Finance Tomskiy What is this? I am sure you don't walk into Mr. Libutti's office and tell him you won't provide any information to him until your next paycheck and then when you do provide information it is useless. I have stated in the past and will state it againâonce the basic questions have been answered ( sorry I have to put satisfactorily) and to define that it means usable information the trip is still an open issue. For exampleâwhich of these person works for LITASCO? Arrow has an absolute right to know who, what, where, when as it relates to this trip as you purportedly went there as their agent. You have still withheld that information which has created an unnecessary impasse and is directly interfering with Arrow's business. End this, answer the questions, and letâs move onto the next objective. It is your ball and has been for a while. You have unexplained expenses, undocumented expenses, unbudgeted expenses, unresponsive answers to contact information, and making believe you don't know that an employee who is not performing their job for 20,000 a month is still an employee over a month after the fact. Where are the daily reports, where is the revised work performance? I will close by sayingâfor some reason Arrow wants to continue this relationshipâI do not subscribe to the position any longer. I will do what I am told to do by Arrow but if and when asked I will not advise them to pay for work that has not been performed. Way forward is for 3D to provide the information that has been requested on numerous occasions and I will focus my efforts on making sure the books are closed on this. All of the requested information is contained in previous e-mails. I have cc'd my boss Neal Puckett for his visibility on this matter. R/ Eric S. Montalvo Attorney at Law 1800 Diagonal Road Suite 210 Alexandria, VA 22314 (703) 706-9566 Phone (540) 840-7717 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: Tuesday, December 07, 2010 5:09 PM To: 'eric@puckettfaraj.com'; Ryan Shane Cc: 'mustreport@googlemail.com'; 'kenneth@puckettfaraj.com'; Melissa Katz; Frank Libutti Subject: Re: Expense Receipts for Mike Dodd's trip to Moscow on behalf ofArrow General Supplies Company Eric, Called and got vm. Pls advise when we can chat to reconcile open invoices. Are you sending termination letter re; Tracy so we have his official end date and can prepare final invoice? Mike Dodd CEO 3D Global Solutions 212-729-6959 Sent from my Blackberry From: eric@puckettfaraj.com [mailto:eric@puckettfaraj.com] Sent: Tuesday, December 07, 2010 01:24 PM To: Michael Dodd; Ryan Shane Cc: 'mustreport@googlemail.com' <mustreport@googlemail.com>; Kenneth Nicholson <kenneth@puckettfaraj.com>; Melissa Katz Subject: Re: Expense Receipts for Mike Dodd's trip to Moscow on behalf ofArrow General Supplies Company Gtg Sent via BlackBerry by AT&T Date: Tue, 7 Dec 2010 13:15:34 -0500 Subject: Re: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Hi Eric, I have a 230, is 4pm+ ok? Pls advise Thank you Mike Dodd CEO 3D Global Solutions 212-729-6959 Sent from my Blackberry From: Eric S. Montalvo [mailto:eric@puckettfaraj.com] Sent: Tuesday, December 07, 2010 12:38 PM To: Michael Dodd; Ryan Shane Cc: 'me me' <mustreport@googlemail.com>; 'Kenneth F. Nicholson' <kenneth@puckettfaraj.com> Subject: RE: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Mikeâneed to slide this to 1430âplease confirm we are still good. V/r E Eric S. Montalvo Attorney at Law 1800 Diagonal Road Suite 210 Alexandria, VA 22314 (703) 706-9566 Phone (540) 840-7717 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: Tuesday, December 07, 2010 9:21 AM To: Eric S. Montalvo; Ryan Shane Cc: 'me me'; 'Kenneth F. Nicholson' Subject: RE: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Importance: High Eric, unfortunately Ryan is out of the office today and unable to get to DC. I would like to do a conf call with you at 2pm and discuss the agenda items previously sent. Mike Dodd <image001.jpg> One Source. Global Solutions. CEO 1185 Ave of the Americas, Suite 1750 New York, New York 10036 Toll free (866) 238-6761 ext 111 Direct Dial 212-205-6171 Fax 866-238-6761 International Cell 001-212-729-6959 This electronic message transmission contains information from 3D Global Solutions which may be confidential or privileged and is otherwise protected by law under the Electronic Communications Privacy Act [18 United States Code ÂÂ 2510-2711]. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by calling the sender at 866-238-6761 immediately, and delete or destroy all copies of this transmission. Alternatively, you may contact us by electronic mail at MIS@3Dglobalsolutions.net From: Eric S. Montalvo [mailto:eric@puckettfaraj.com] Sent: Thursday, December 02, 2010 1:26 PM To: Ryan Shane Cc: 'me me'; Michael Dodd; 'Kenneth F. Nicholson' Subject: RE: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company I am available Tuesday. Prior to any meeting I request a proposed agenda. R/s Eric S. Montalvo Attorney at Law 1800 Diagonal Road Suite 210 Alexandria, VA 22314 (703) 706-9566 Phone (540) 840-7717 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: Ryan Shane [mailto:ryan.shane@3dglobalsolutions.net] Sent: Wednesday, December 01, 2010 2:24 PM To: 'eric@puckettfaraj.com' Cc: 'me me'; Michael Dodd Subject: FW: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Eric, In addition to the receipts I sent this morning, below is the list of people Mike met with in Moscow on behalf of Arrow. I would like to schedule a face to face meeting with you to discuss all outstanding issues. Please revert soonest with your availability. Regards, Ryan Knaub Andrey Tomskiy Refinery & Euro-Link Holding International Limited Chairman of the Board of Directors Andrej Skrobot LUKOIL Elena Nazarova LUKOIL Aleksandr Ovanesov LUKOIL Dmitriy Popov LUKOIL Oleg Chernokalov LUKOIL Jeffrey R. Fearnside LUKOIL Pan Americas, LLC Clean Products Trader Cesar Figueroa LUKOIL Pan Americas, LLC Ian Eftaxes LUKOIL Pan Americas, LLC Jens Hoffmann LUKOIL Pan Americas, LLC Joseph Colella LUKOIL Pan Americas, LLC Nikita Pozhidaev URALSIB Corporate Finance VP Anikina Svetlana NHKO Commercial Director Trades Marzoev Tamerlan Euro-Link Holding International Limited Fuad Mekhti Uralsib Financial Corporation Investment Banking, Corp Finance Tomskiy From: Ryan Shane Sent: Wednesday, December 01, 2010 9:30 AM To: 'z.sahibzada@arrowgsc.com' Cc: 'eric@puckettfaraj.com'; 'me me' Subject: Expense Receipts for Mike Dodd's trip to Moscow on behalf of Arrow General Supplies Company Zakariya, Incidental costs for transportation in Dubai, cost for mailing the visa and some phone usage from the trip to Russia do not have receipts. Everything else is on the attachement Thanks, Ryan Ryan Shane <image001.jpg> One Source. Global Solutions. 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