FORMAL COMPLAINT AGAINST UAE IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY,

FLORIDA CASE NO. AMERICAN GULF INSURANCE. LLC and AZZAM RUSTOM, Plaintiffs, v. ABU DHABI, UNION NATIONAL BANK. EMIRATES BANK INTERNATIONAL MOHAMED BIN THAALOOB SALEM AL DAREI, AKRAM KANAKRIEH MOHAMED SAEED SULAIMAN MOHAMED AL MAZROUEI AND SAIF MIZROUEI, Defendants. VERIFIED COMPLAINT 1. This is an action for compensatory damages for conspiracy, fraud, theft, and terrorism. Pursuant to the Florida rules governing punitive damages, such damages will be sought upon a proper motion to Amend the Complaint. PARTIES 2. American Gulf Insurance, LLC (AGI) is a Delaware company with its principal of business in Broward County, Florida. AGI, through its United Arab Emirates (UAE) subsidiary, AGI was organized to establish a publicly held insurance company in the UAE to provide vehicle, property. fire, marine and personal accident insurance coverage throughout the United Arab Emirates. 3. Aziam Rustom (Rustom) is a citizen of Pain, Beach County, Florida. who is a member of Arnerica Gulf Management Co. LLC which is the Managing Member of AGI 4. Abu Dhabi is an Emirate in the UAE and through its representatives, encouraged and conspired with the individual defendants in the commercial venture and the acts described below. 5. His Highness Sheikh Hazza Bin Zayed Al Nahyan (Sheikh Haza) is a member of the Royal family of the Emirate of Abu Dhabi and the brother of the Crown Prince of Abu Dhabi i.e., Sheik Mohammed Bin Zayed Al Nahyan (Crown Prince). Sheikh Hazza is the National Security Advisor of the United Arab Emirates. He assumed the role of the Sponsor of AGI.

6. His Excellency Mohammed Bin Thaaloob Al Darei (Al Darei) is the Chief of Staff of Sheik Hazza as well as the Chairman of the Abu Dhabi Wrestling and Equestrian Federation. Al Darei was a Member of the Board of AGL He is a citizen of the United Arab Emirates (UAE). 7. Akram Kanakreih (Kanakreih) is the President of the Chairman's Office of the Crown Prince. He possesses a UAE Military Resident Identification Certificate as a member of the UAE Armed Forces. 8. Mohamed Saeed Sulaiman Mohamed Al Mazrouci (Al Mazrouei) is a UAE citizen who was appointed by Sheik Hazza to be the sponsor of AGI and, at Sheik Hazza's direction, to hefp establish the Gulf Platinum Group which was to be the local holding company for AGI. Mazrouei is related to the Royal Family of Abu Dhahi by reason of being a member of the family of the wife of His Highness Sheikh Khalifa bin Zayed Al Nahyan (Khalifa) the ruler of Ahu Dhabi and the President of the United Arab Emirates. Mazrouei is also a member of the Criminal Investigative Division (CID) of Abu Dhabi. 9. Saif Mizrouei, (S. Mazrouei) the brother of Mohamed Mizrouei, is a UAE. Citizen. Mazrouei is related to the Royal Family of Abu Dhabi by reason of being a member of the family of the wife of the Khalifa. 10. Union National Bank (UNB) is a registered Bank in the UAE and has affiliated banks in the United States of America. 11. Emirates Bank International (EBI) is a registered Bank in the UAE. 12. This Court has personal jurisdiction over the Defendants because they acted as coconspirators and, as alleged below, one of the conspirators had sufficient minimum contacts with Florida to allow him and his fellow co-conspirators, to be subject to the jurisdiction of this Court. FACTS 13. During the year 2007 the UAE, Abu Dhabi, and the emirate of Dubai embarked upon a major advertising and solicitation campaign in the United States. The campaign utilized such publications as the New York Times, Wall Street Journal and other major media outlets. The object of their campaign was to solicit and induce US investors and businesses into undertaking investment in Abu Dhabi, Dubai and the UAE. The campaign represented, inter alia, that the UAE was a safe haven for investors because of a stable government which enforces both its civil and criminal laws to protect any business or individuals who invest and conduct business the UAE. 14. In November 2007 the founding members of AGI traveled to Abu Dhabi to meet with various high level members affiliated with the Royal Family of Abu Dhabi as well as certain high level members of the Royal Families of two other countries that are a part of the Gulf Cooperative Council (GCC). Among those affiliated with the Royal Family

members that participated in the meetings were Saline, an individual who is a citizen of the UAE, Sheikh Faisal Al Hamoud Al Malik Al-Sabah, a member of the ruling Royal Family of Kuwait, and who was then the Kuwaiti Ambassador to Oman and is currently the Kuwaiti Ambassador to Jordan. Sheikh Saline represented that the company would eventually enter into an IPO for multiple hundreds of million of dollars. 15. In January 2008, three of the founding members of AGI and employees of AGI moved to the UAE for the purpose of establishing an insurance company. The AGI founders and managers were inroduced to the Chief of Staff of Sheik Hazza's office, Al Darei, and ultimately were informed that Sheikh Hazza had decided that he would be the Sponsor for AGI for purposes of obtaining all appropriate licenses to conduct its insurance business in the UAE. 16. On February 6, 2008, Al Darei forwarded a communication to AGI which stated: .....IIH Sheikh Hazza Bin Zayed Al Nihon has accepted to be apart of this great company.....We appoint Mr. Akram Kanakrieh Passport No. 4819227, a member of the UAE Armed forces to be the lead Agent/Pro from this day forward to handle all of American Gulf insurance matters. All Legal Accounting, Banking and day to day openitions until IPO finalized. .....Regards, H.E. Mohammed Bin Thaloob Al Darei. Sheikh Hazza also appointed Al Mazrouie to be the lead individual along with Kanakrih to coordinate all efforts with AGI. 17. Thereafter, Al Darei, on behalf Sheikh Hazza and their appointees engaged the internationally renowned accounting firm of KPMG, the investment banking firm of CAP M and various corporate attorneys to obtain all appropriate licenses, for both a Commercial Brokerage license and an Underwriting Insurance company license, as well as to oversee the Initial Public Offering of AGI on the Abu Dhabi Stock exchange. 18. Messrs. Kanakreih and Al Darei also assembled a prominent Board of Directors for AGI, which, in addition to the Founders, Azzam Rustom, Amer Rustom and Michael Weinberg, was comprised of the following persons: H.E. Mohamed Bin Thaaloob Salem Al Darei H.E. Jawaan Awaidah Al Khaili H.E. Saif Mohamed Al Hajeri H.E. Mr. Hamed Mubarek Salem Raghash Al Shamsi Mr. Khalid Mohammad Kadfoor Al Mehaira H.E. Mohamed Abdul Majid Abdulla Al Mehairi H.E. Dr. Mohamed Al Khamis Al Hosni H.E. Ahmed Darwish Daghar Darwish Al Marar

H.E. Awadh Tareef Mohammed Al Kuthbi 19. In January 2009 Al Darei thru Mazrouei instructed AGI to transfer approximately 9.5 million dollars into EBI from its account that was maintained at HSBC. Mazrouei presented signature cards to Rustom and Michael Weinberg and provided documents demonstrating that the account was an escrow account to which they were the signatories. He also at that time presented signature cards to UNB bank and represented that they were the signatories to the account. 20. On May 12, 2009, the UAE Insurance Authority formally approved the application of AGI in a document containing Reference No. A-T/240/2009, and on the same day in May, initial approval was given by the UAE. Department of Planning and Economy along with a trade name registration for AGI. The approval number was 1164453. 21. In June 2009, Al Darei's office provided to AGI the UAE Executive Council Approval of the Company to obtain an Insurance license in Resolution 24. 22. Kanakreih and Al Darei assured AGI's Managers that the Initial Public Offering paperwork was in order and complete, and ready for final approval. In order to submit the paperwork for final approval, AGI was informed by Al Darei that the Founders' minimum capital account must show a total of Emirati Dirham (AED) 67,500,000 ($18 million U.S. dollars). During September 2009 9 million USD were deposited to EBI. On or about September 13, 2009, Mazrouei reported that the monies necessary to meet all requirements to complete the IPO were wired to UNB. UNB provided an official stamped receipt showing a total of Emirati Dirham (AED) 67,500,000 i.e. 18 million in the AGI account. 23. In a series of 2009 e-mails to Michael Weinberg in Florida, Kanakreih assured AGI that the monies were safe: "Hopefully by tomorrow or after tomorrow we will have the new account number in Union National Bank under American Gulf Insurance Formation Company . . ." and: "We have processed the documents to open Bank Accounts and the Bank requested the Articles for the Association for the AGI Formation Company as their procedure, therefore I am working on it today and soon will be sent to you for the signature by your good self and Mr. Amer and Azzam." And again: "Hopefully by tomorrow or after tomorrow we will have the new account number in Union National Bank under American Gulf Insurance Formation Company, consequently I can provide you the complete documents." 24. On September 14, 2009. the AGI Founders received this letter from Al Darei: Dear Sirs September 14, 2009 Michael Weinberg, Azzam Rustom, Amer Rustom On behalf of Sheikh Hazza Bin Zayed Al Nihon, we say to you congratulations. Today we have submitted the Completed file for AIG (PJSC) to the Insurance authority for final approval to get the license and process the IPO. As planned we will have the final approval between the 1st - 15th of October

2009. We have received from you the final $3 million USD to bring your UNB AGl trust account balance to the 67,500,000 AED (Up to date proof of funds included) needed to cover the 45% of the IPO as per Law. HH Hazza Bin Zayed Al Nihon looks forward on celebrating with you at the Abu Dhabi Fl Race on November 1st 2009. Please be Ready. Best Regards, H.E. Mohamed Bin Thaaloob Al Darci WITH COMPLIMENTS 25. In late September 2009, information was brought to the attention of Rustom that there was a problem with the UNB AGI bank account. Kanakreih repeatedly assured AGI that any "problem. . . will be solved." When attempts were made by the three founders to ascertain the status of their account UNB would not provide any information claiming that the three founders had no rights to any information about the account. 26. There was a problem. It was not solved. The Plaintiffs have recently learned, and allege here based upon the information received, that the UNB statement was a forgery and that the monies which were supposed to be in UNB had been, over time. either not transferred from EBI , or alternatively transferred back and forth from EBI to UNB and then back to EBI. where the sole signatory was ultimately, Al Mazrouei, who had withdrawn the funds deposited by AGI. The signatures of the founders were forged at both banks. 27. In July, 2009 two of the Founders' signatures were forged and notarized by a military notary public from the Crown Prince's Office and submitted to the Insurance Department to change the ownership of the Plaintiffs' holding company to Mazrouei. 28. Subsequent, to receiving that information the Plaintiffs engaged in extensive efforts both in the UAE and USA, in both a diplomatic and investigatory manner, to determine the whereabouts of the money and to prosecute those responsible for its loss. 29. The founders met in Abu Dhabi with the United States of America's Ambassador to the UAE, Richard Olsen, accompanied by former United States Senator and Ambassador, Wyche Fowler, who is a consultant to AGI. Despite his best efforts to assist us citizens, Ambassador Olsen was limited by the jurisdiction and parameters of his office. 30. The Plaintiffs communicated with several members of the United States House of Representatives most of whom had USA constituents who are investors in AGI. In this regard three Congressmen communicated with the UAE Ambassador to the United States, Yousef Al Otaiba. In fact the Chairman of the Subcommittee of the Middle East and Asia of the House of Representatives, Congressman Gary Ackerman, actually scheduled a meeting with the Ambassador to address this issue, which meeting the Ambassador abruptly canceled the day prior to the meeting. Ambassador Otaiba stated to one of the Congressman that his position was that this was a "civil" matter. He took this position notwithstanding the fact that he had been advised that an American citizen had been kidnapped in Abu Dhabi and a substantial group of citizens of the USA who had

invested in the UAE, based upon promises that civil and criminal laws would be honored and enforced, had been victimized by having been defrauded and victimized by the theft of the 18 million dollars. 31. Those efforts at resolution, prosecution and restitution were unavailing, but they did result in acts of intimidation and terrorism being perpetrated against Rustom by members of the Abu Dhabi government. 32. On January 19, 2010, Saif Mazrouei under the instructions of his brother Al Mazrouei, visited Rustom's apartment with seven policemen and members of the Criminal Intelligence Division. 33. They proceeded to interrogate him about the complaints that had been made concerning the missing eighteen million dollars made by AGI, and ordered him to be prepared the next morning to provide the keys to his (Rustom's) automobile. 34. The following morning, Saif, accompanied by members of the Criminal Intelligence Division, took the keys to Rustom's automobile, ordered him into an automobile which they drove around Abu Dhabi for 12 hours, refusing his repeated requests to leave the automobile. When Rustom told them that he had to use lavatory facilities, they laughed at him and told him to use his pants. They stated that "you need to forget about this situation," and if you don't you will find yourself in the desert with your head out off and in our country no one will ever find you." They further stated "if you tell anyone about today, we will find out and we will come and get you." Saif then ordered one of his minions to drive Rustom back to his apartment. Nearly 12 hours had passed between the time Rustom was forcibly taken from his apartment and his return. Rustom's automobile, was never returned. Subsequent to this act Rustom was called on his cell phone and told that he and his "Jew Investors" should forget about their money because they will never see it again. 35. A week prior to this act of terrorism, false imprisonment and theft of his car, Rustom had been stopped by a stranger tapping on the window of his car, who said: "You go America or Bin Thaaloob [Al Darei] . . . ." and then gestured with a hand slicing across his throat. 36. Subsequently Rustom's cell phone service was mysteriously terminated. When this occurred inquiries were made and it was determined that this was done by the "government." 37. The three Founders filed police reports with the Dubai Police Department and the Abu Dhabi police department. Neither law enforcement agency took any action to either investigate or apprehend the perpetrators. 38. The three Founders were successful in obtaining a meeting with the Chief of Staff of the Khalifa. In this meeting he advised them that he was outraged and that this matter

would be remedied in "two to three days." He stated that he would arrange a meeting with the SID which is the highest law enforcement branch of the UAE. 39. In fact this meeting occurred the next day and was attended by the Founders and four members of the SID, the highest ranking of which was a Brigadier General. The Plaintiffs were advised that this matter would be solved to their satisfaction within two days. 40. One week elapsed and when the Brigadier was called he stated that he had been "instructed" that this matter would by handled by the Abu Dhabi Police Department. 41. Upon information and belief at each step along the way Al Darei utilized his position as Chief of Staff of the National Security Advisor, Sheikh Hazza, to squelch all efforts of the Plaintiffs to resolve this matter and recover their money. All law enforcement authorities stonewalled the Plaintiffs' efforts to secure compliance with the laws of the UAE and Abu Dhabi, contrary to the representations made by both Governments that their laws would be enforced on behalf of the investors. 42. The Founders, including Plaintiff Azzam Rustom, fearful for their lives and well being left the UAE and returned to Florida. AGI'S FIRST CLAIM FOR RELIEF FOR CONSPIRACY TO COMMIT CIVIL FRAUD 43. Plaintiff AGI repeats and re-alleges paragraphs 1 - 42 set forth above. 44. The acts and promises set forth above in which Defendants Kanakreih, Al Darei and Al Mazrouei stated that the application of AGI had been approved and that the necessary funds were in place for the issuance of the approval of the Initial Public Offering were false statements of fact, intentionally made with the knowledge that the representations were false with the intention that AGI rely on the intentional misrepresentations, causing the consequent injury of substantial economic losses to AGI as a result of monies expended to pursue the formation of, and operation of, the insurance company that had been endorsed by Sheik Al Nahyan. 45. The individual, Governmental, and Bank Defendants agreed, conspired, combined and confederated to perpetrate and cover-up the fraud set forth above, and the actions set forth above were the product of an agreement between all the Defendants to do an unlawful act or a lawful act by unlawful means. 46. As a result of the conspiracy to commit civil fraud, AGI seeks damages in excess of thirty million dollars for the expense attendant to its efforts to incorporate and operate in the United Arab Emirates. AGI'S SECOND CLAIM FOR CONSPIRACY TO COMMIT OBTAINING PROPERTY BY FALSE PRETENSE

47. Plaintiff AGI repeats and re-alleges paragraphs 1 - 42 set forth above. 48. The acts and promises set forth above in which Defendants Kanakreih, Al Darel and Al Mazrouci stated that the application of AGI had been approved and that the necessary funds were in place for the issuance of the approval of the Initial Public Offering Were knowing false representations of existing facts, made with the intent to defraud for the purpose of causing AGI to rely on those misstatements (which they did) and to cause AGI to surrender eighteen million dollars as a direct consequence of the fal se representations. 49. The individual, Governmental and Bank Defendants agreed, conspired, combined and confederated to perpetrate and cover up the false representations to obtain AGI property and the actions set forth above were the product of an agreement between all the Defendants to commit the unlawful act of obtaining property by false pretenses. 50. As a result, AGI was damaged by the loss of the eighteen million dollars it has deposited pursuant to the instructions and directions of the co-conspirators. AGI'S THIRD CLAIM FOR RELIEF FOR CONSPIRACY TO COMMIT THEFT AND CIVIL THEFT 51. Plaintiff AGI repeats and re-alleges the facts set forth in paragraphs 1-42. 52. The acts of all the Defendants set forth above constitute the obtaining of eighteen million dollars, the property of AGI, with the intent to deprive AGI of those funds and to appropriate those funds to their own use. 53. The Defendants agreed, conspired, combined and confederated to illegally obtain AGI's eighteen million dollars and appropriate those monies to their own use. 54. As a result AGI was damaged by the loss of the eighteen million dollars it had deposited pursuant to the instructions and directions of the co-conspirators. AZZAM RUSTOM'S CONSPIRACY CLAIM FOR TERRORISM AND FALSE IMPRISONMENT AGAINST MOHAMED AL MAZROUEI AND SAIF AL MAZROUEI AND THE OTHER DEFENDANTS 55. Azam Rustorn repeats and re-alleges paragraphs 1-42 set forth above. 56. The acts specifically set forth above in paragraph 33 above constitute the unlawful detention and deprivation of liberty of Rustom against his will, without legal authority and was unreasonable and unwarrinted under the circumstances. 57. Defendants Saif Mizrouei and Mohamed Mizrouei agreed, conspired, confined and confederated with Al Darei and Kanakreih to falsely imprison Rustom by virtue of their unlawful detention to him, for the purpose of inhibiting any investigation of their illegal

activities. Abu Dhabi, acting through its officials, condoned and conspired to deprive Rustom of his liberty during the duration of his false imprisonment and the terroristic threats made to him. AZZAM RUSTOM'S CONSPIRACY CLAIM FOR THEFT OF HIS MOTOR VEHICLE 58. Azam Rustom repeats and re-alleges paragraphs 1 -42 set forth above. 59. The acts specifically set forth in paragraph 33 above, constitutes Saif Mizrouei's knowing obtaining of the property of Rustom with the purpose to deprive him of his property and to appropriate that property to his own use or to the use of another person not entitled thereto as part of the conspiracy to prevent Rustom from continuing to secure relief for theft, misrepresentation and fraud of the co-conspirators. 60. The property that was taken had a value in excess of $50,000. RELIEF REQUESTED 61. Based upon the above stated facts and claims for relief, the Plaintiffs request the following relief. As to the claim for conspiracy to commit fraud, AGI requests joint and several damages in excess of thirty million dollars; As to the claim for conspiracy to commit obtaining property by false pretense, AGI requests joint and several damages of eighteen million dollars plus interest; As to the claim for conspiracy to commit theft and civil theft, AGI several damages of eighteen million dollars, plus interest, trebled pursuant to Florida Statute 772.11, plus attorneys fees; As to Azzam Rustom's claim for conspiracy to commit false imprisonment, Rustom seeks joint and several damages in excess of $50,000; As to Azzarn Rustom's claim for conspiracy and theft of his automobile, Rustom seeks joint and several damages in excess of $50,000. DEMAND FOR JURY TRIAL Plaintiffs demand ajury trial on all claims. Respectfully submitted, BRUCE S. ROGOW Florida Bar No. 067999 CYNTHIA E. GUNTHER Florida Bar No. 0554812 BRUCE S. ROGOW, P.A. Broward Financial Centre, Suite 1930 500 East Broward Blvd.

Fort Lauderdale, FL 33394 Ph: (954) 767-8909 Fax: (954) 764-1530 [email protected] and BRADFORD M. COHEN Florida Bar No. 118176 BRADFORD COHEN LAW 1132 SE 3rd Avenue Fort Lauderdale, FL 33316 Ph: (954) 523-7774 Fax: (954) 523-2656