ORIGINAL AL - fmc.gov motion to... · 50273 and Rule 12b2of the Federal Rules of Civil Procedure Respondent Impexia Inc Impexia petitions the Federal Maritime Commission to issue

DNB EXPORTS LLC andAFI ELEKTROMEKANIKANIK VE

ELEKTRONIK SAN TIC LTD STI

v Docket No 11 07

BARSAN GLOBAL LOJISTIKS VE GUMRUK

MUSAVIRLIGI A S BARSANINTERNATIONAL INC and IMPEXIA INC

BEFORE THE riFEDERAL MARITIME COMMISSION

Complainants

Respondents

RESPONDENT IMPEXIA INCS

MOTION TO DISMISS COMPLAINT FOR LACK OF JURISDICTION

Pursuant to Rule 50273 of the CommissionsRules of Practice and Procedure 46 CFR

50273 and Rule 12b2of the Federal Rules of Civil Procedure Respondent Impexia Inc

Impexia petitions the Federal Maritime Commission to issue an order dismissing this

proceeding as to Impexia with prejudice

Dated June 3 2011

1

Respectfully submitted

Os CicORIGINAL AL

CfrIGFncR

AShley WCraigDavid G Dickman

Lauren D Eade

Venable LLP

575 7th Street NWWashington DC 20004Telephone 202 344 4351Facsimile 202 3448300awcraig@venablecomdgdickma n venablecom

ldeade@venablecomCounselfor Respondent Impexia Inc



BEFORE THE

FEDERAL MARITIME COMMISSION


MUSAVIRLIGI A S BARSAN

INTERNATIONAL INC and IMPEXIA INC

Complainants

Respondents

2

v Docket No 11 07

RESPONDENT IMPEXIASMEMORANDUM IN SUPPORT OF

MOTION TO DISMISS FOR LACK OF JURISDICTION

Respondent Impexia Inc Impexia submits this memorandum in support of its motion

to dismiss the complaint of DNB Exports LLC and AFI Elektromekanikanik Ve Elektronik San

Tic Ltd Sti collectively Complainants for lack of personal jurisdiction Complainants have

improperly sought to recast a common law state tort claim as a violation of federal law and have

failed to carry their burden of making a primafacie showing that this claim falls within the

Federal Maritime CommissionsFMC or the Commission limited jurisdiction Good cause

exists to grant this Motion for the reasons set forth below

I INTRODUCTION

Complainants have brought their complaint the Complaint pursuant to Section

10b13of the Shipping Act of 1984 as amended by the Ocean Shipping Reform Act of

1998 the Shipping Act 46 USC 41103aand pursuant to the FMCsauthority

under Section 11a of the Shipping Act 46 USC 41301a Impexia is not a regulated

person or entity under the Shipping Act L it is not an ocean freight forwarder nonvessel

operating common carrier NVOCC ocean common carrier marine terminal operator did

not engage in conduct or behavior regulated by the Shipping Act or the FMC and has not held

itself out in any manner or capacity that would result in Commission oversight Accordingly the

FMC lacks personal jurisdiction over Impexia The Complaint should be dismissed with

prejudice as to Impexia

II FACTUAL BACKGROUND

On April 14 2011 Complainants filed the Complaint alleging Respondents violated

Section 10b13of the Shipping Act 46 USC 41103aby knowingly disclosing offering

soliciting and receiving information concerning the nature kind quantity destination shipper

consignee and routing of property tendered or delivered to Barsan Intl by DNB andor AFI by

without the consent of DNB andor AFI using that information to the detriment and

disadvantage of DNB andor AFT by unlawfully disclosing that information to Impeixa sic as

a competitor Complaint at 1125 The Complainants also allege that ajs a direct

consequence of the unlawful conduct engaged in by Respondents Complainants have suffered

loss of clients current and future revenues from those clients not only loss amounts represented

by shipments with Respondents but also with other forwarders and loss of reputation all of

which has caused and continues to cause Complainants monetary damages of at least 12

million and other significant amounts Complaint at 1134

The Complaint alleges that Impexia as BGLs and Barsan lntIs alter ego is a mere

corporate shell of BGL and Barsan Intl for the purpose of obtaining and utilizing BGLs andor

Barsan IntIscustomers commercial proprietary information which is routinely obtained for

3

performing Barsan NVOCCfreight forwardingNVOCC services with the purpose of engaging

in the same business as Barsan Intlscustomers and to solicit importexport trading business

from their customers clients Complaint 10 15 and 35 To support its position that

Impexia is a mere corporate shell and an alter ego the Complaint states thatupon

information and belief Respondent Impexia is a corporation incorporated on or about March

2010 and existing pursuant to the laws of the State ofNew Jersey with its principal place of

business the same location as Barsan Intlthat Impexia used to display its business address

in New Jersey as the same address as Barsan Intlsaddress in its website that Impexia

indicates on its website that it has three offices in New Jersey Florida and Texas which upon

information and belief are close to Barsan Intl or BGL offices in these three States that

Mr Jimmy Cuneyt Karadaglisfull name was also displayed in the Impexis sic webpage and

that Barsan Intlsofficers President Ugur Aksu Vice President Sevgi Cebe and Export

Manager Tugsan Uresin also maintain a close relationship with Impexia Complaint at 6 20

21 and 22

On May 23 2011 Respondents Barsan Global Lojisticks Ve Gumruk Musavirligi AS

and Barsan International Inc filed a Verified Answer Counterclaim and Crossclaims BGL

and Barsan Intl Answer in response to the Complaint

III ARGUMENT

a Standard of Review

Complainants bring this suit against Impexia pursuant to 46 USC 41103awhich

states that a common carrier marine terminal operator or ocean freight forwarder either alone

or in conjunction with any other person directly or indirectly may not knowingly disclose offer

solicit or receive any information concerning the nature kind quantity destination consignee

4

or routing of any property tendered or delivered to a common carrier without the consent of the

shipper or consignee if the information 1 may be used to the detriment or prejudice of the

shipper the consignee or any common carrier or 2 may improperly disclose its business

transaction to a competitor 46 USC 41103a

Impexia seeks dismissal with prejudice for lack of personal jurisdiction As no specific

FMC Rule provides for a motion to dismiss for lack of personal jurisdiction the Commission

should apply Rule 12b2of the Federal Rules of Civil Procedure See 46 CFR 50212

in proceedings under this part for situations which are not covered by a specific

Commission rule the Federal Rules of Civil Procedure will be followed to the extent that they

are consistent with sound administrative practice Rule 12b2allows for a defendant to

bring a motion to dismiss for lack of personal jurisdiction Every defense to a claim for relief

in any pleading must be asserted in the responsive pleading if one is required But a party may

assert the following defenses by motion 2 lack of personal jurisdiction

The Commission has clearly articulated in the past that before proceeding to the merits

of a case the FMC must determine whether it has jurisdiction over the parties See Kawasaki

Kisen Kaisha LTD v Intercontinental Exchange Inc 2000 WL 1285694 FMC it is

elementary law that a court or agency of limited jurisdiction such as the Federal Maritime

Commission should determine its jurisdiction before proceeding to decide the merits of a

controversy see also Government of the Territory ofGuam v SeaLand Service Inc 28

SRR 252 265 FMC 1998 The general rule is that an adjudicatory body must first find that

it has jurisdiction over the parties and the subject matter of the case before it reaches the

merits The case at bar presents this very issue as it pertains to Impexia and warrants the

Commissionsconsideration

5

b Limited Jurisdiction of the Federal Maritime Commission

The Commissionsjurisdiction over specific persons and entities involved in oceanborne

commerce is well established dating to the enactment of the Shipping Act 1916 and presently

derived from and circumscribed by the Shipping Act of 1984 as amended by the Ocean

Shipping Reform Act of 1998 the Foreign Shipping Practices Act of 1988 Section 19 of the

Merchant Marine Act 1920 and Public Law No 89777 46 USC 40101 41309

Pursuant to the Shipping Act the Commission has limited regulatory jurisdiction to oversee

defined activities of international shipping lines ocean common carriers marine terminal

operators and ocean transportation intermediaries OTIs that provide certain regulated

services in the United States foreign commerce In short the FMCsstated mission is to

foster a fair efficient and reliable international ocean transportation system and to protect the

public from unfair and deceptive practices See

httpwwwfmcgovaboutmissionandvisionstatementsaspx

The Shipping Act defines an ocean common carrier as a person holding itself out to

the general public to provide transportation by water of passengers or cargo between the United

States and a foreign country for compensation 46 USC 40102 6 A marine terminal

operator means a person engaged in the United States in the business of furnishing wharfage

dock warehouse or other terminal facilities in connection with a common carrier or in

connection with a common carrier and a water carrier 46 USC 40102 14 The Act

further defines an ocean transportation intermediary as an ocean freight forwarder or a non

vesseloperating common carrier 46 USC 40102 19 Specifically an ocean freight

forwarder is a person that a in the United States dispatches shipments from the United States

via a common carrier and books or otherwise arranges space for those shipments on behalf of

shippers and b processes the documentation or performs related activities incident to those

6

shipments 46 USC 40102 18a b A nonvessel operating common carrier or

NVOCC means a common carrier that does not operate the vessels by which the ocean

transportation is provided and is a shipper in its relationship with an ocean common carrier 46

USC 40102 16

The Commission has no statutory or regulatory authority to oversee a person or entity

that does not conduct activities that squarely fall under the Act The Commission has held that

the status of a person under the Act is not determined by his or her own declaration of what he

or she is but what he or she is in fact doing See eg Carolina Marine Handling Inc v South

Carolina State Ports Authority 2000 WL 722272 FMC citing Stark v Willard 321 US 288

309 1944 citing Marine Terminal Practices ofthe Port ofSeattle 18 SRR 141 156

ID 1978 adopted 18 SRR 1029 FMC 1978 Resolution of this question depends upon

consideration of the facts Id Therefore under its prior precedents in addition to considering

the representations of the parties the Commission should consider Impexiasactions in

determining whether its activities fall within the definition of a regulated entity under the

Shipping Act

c Impexia Is Not An Entity Subject to the Shipping Act of 1984

As set forth in the accompanying Declaration Impexia is not nor has it ever been

engaged in the business of providing ocean freight forwardingNVOCC services nor does it hold

itself out to the public as an ocean common carrier Consequently Impexia is not a person

subject to the Shipping Act and the Commission lacks personal jurisdiction over it Moreover

the mere fact that Impexia during the normal course of its business activities may come into

contact with entities that are engaged in regulated ocean transportation activities does not imbue

Impexia with the any of the characteristics sufficient to authorize the FMC to exercise

7

jurisdiction over it Section 41103aprohibits a common carrier marine terminal operator or

ocean freight forwarder from engaging in certain conduct Because Impexia is not a common

carrier marine terminal operator NVOCC or ocean freight forwarder nor has it ever acted as

one the Commission lacks jurisdiction over the company

Impexia is a corporation registered in the State of New Jersey with a registered office

located at 14 Hasbrouck Place Rutherford NJ 07070 Declaration of Cuneyt Karadagli

Decl at 2 a copy of which is attached hereto as Exhibit A Impexia has never had its

principal place of business or registered address located at 1709 Zink Place Unit 5 Fair Lawn NJ

07410 as Complainants alleged in the Complaint at 6 Decl at 2 In their submissions

BGL and Barsan Intl also both denied that Impexia ever had its principal place of business at

Barsan Intlsaddress See BGL and Barsan Intl Answer at 6

Impexia performs procurement management providing building materials and complete

industrial products Decl at If 1 see also Impexia Company Profile a copy of which is attached

as Exhibit B Impexia deals with US government agencies as well as private clients globally

Decl at If 1 Impexia has a clientcustomer relationship with Barsan Intl Decl at in 7 15

19 31 In fact Impexia has hired Barsan Intl at least five 5 times to provide multimodal

transport services Decl at 9111619 Impexia does not have nor has Impexia ever had any

type of corporate affiliation nor has Impexia existed or acted as a subsidiary of Barsan IntI

Decl at 32 Impexia is its own unique corporate entity independent of BGL and Barsan

Int1

As set forth in the Declaration there is a simple straightforward explanation for

Impexiasuse of Barsan IntIsaddress Impexia used Barsan Int1smailing address as a

temporary measure while Impexia was obtaining its own commercial address Since Ms Burcin

8

Karadaglia Mr Karadagliswife previously worked at this location it was practical for her to

receive express mailcourier deliveries for Impexia at this address Decl IN 22 28 29 In

addition in the past Mr Karadagli rented office space upstairs from Barsan Intlsspace and

hoped to be able to negotiate a new lease of the same space for Impexia Decl at 27 In sum

use of the Barsan Intl address by Impexia was a temporary measure Decl at 28

Based on the single fact that Impexia utilized Barsan Intlsmailing address

Complainants improperly assert that Impexia is a mere corporate shell ofBarsanBGL

Complaint at 10 and on this thin reed rests Complainants complicated conspiracy theory that

Impexiassole purpose is to use the proprietary business information of BGLs andor Barsan

Intlscustomers to compete with Barsan Intlscustomers and to solicit importexport trading

business from the clients of BGL and Barsan IntIscustomers Complaint at 1110

Complainants offer no proof whatsoever that Impexia was involved in such a scheme other than

their brief conclusory allegation In fact Impexia has no corporate affiliation whatsoever with

Barsan Intl or BGL and was simply albeit improperly using Barsansaddress for the sake of

convenience Decl at 22 28 31 32 BGL and Barsan Intl also deny that Impexia was a

corporate shell of BGL and Barsan Intl for any purpose BGL Barsan Intl Answer at 1115

When Impexia realized its mistake Impexia immediately ceased its use of the address and

apologized to Respondents Decl at 26 28

Simply put Impexia is not nor has it ever been engaged in the business of providing

ocean freight forwardingNVOCC services nor does it hold itself out to the public as an ocean

common carrier Decl at 4 15 23 And finally no scheme has ever existed between

Impexia and Respondents Decl at 33 Impexia obtained its clients by its own diligent efforts

Decl 3328

9

d Complainants Fail To Address Facts Affirmatively Showing that theCommission Has Personal Jurisdiction Over Impexia

Under Rule 12b2it is not sufficient for a plaintiff to establish personal jurisdiction

merely by asserting conclusory allegations

Where a district courts personal jurisdiction is contested plaintiffs ultimatelybear the burden of persuading the court that jurisdiction exists A district courtdeciding a motion to dismiss for want of personal jurisdiction should apply theprima facie standard under which the district court considers only whether theplaintiff has proffered evidence that if credited is enough to support findings ofall facts essential to personal jurisdiction However the prima facie showing ofpersonal jurisdiction must be based on evidence of specific facts set forth in therecord In other words the plaintiff must go beyond the pleadings and makeaffirmative proof

See Memorandum and Order on Respondents Motion for Reconsideration RO White

Company and Ceres Marine Terminals Inc v Port ofMiami Terminal Operating Company et

al Docket No 0611 2007 citing NegrOn Torres v Verizon Communications Inc 478 F3d

19 23 1st Cir 2007 citations and internal quotation marks omitted

Complainants fail to carry their burden of making a primafacie showing that the

Commission has personal jurisdiction over Impexia under the Shipping Act Complainants

assert thatduring the period commencing on or about January 2009 continuing through on or

about the middle of January 2011 Barsan IntI provided NVOCC services to DNB and AFI for

shipments originating at US Ports for delivery at Ports in Turkey and other ports and points

pursuant to a Contract Carrier Agreement executed on January 15 2009 Complaint at 11

emphasis added Complainants make no such allegation that Impexia was providing NVOCC

services ocean freight forwarding services or engaging in any other regulated activities under the

Shipping Act Instead without any factual support Complainants insert the terms corporate

shell and alter ego liberally in the Complaint in the hope that these accusations will blind the

Commission to Complainants failure to carry their burden and that the mere assertions will

10

create a sufficient legal nexus between Impexia and BGL and Barsan Intl whose activities are

regulated by the Shipping Act to provide jurisdiction over Impexia Complaint at 10 15 and

35 Whether or not the officers of Barsan Intl maintain a close relationship Complaint at

22 with Mr Cuneyt Karadagli the president of Impexia and whether or not they were

facebook friends these allegations are simply insufficient to establish that Impexia has a

corporate relationship with is affiliated with or is or ever has been under the influence direction

or control of Barsan Intl

To the contrary Ms Karadagli was an employee of Barsan Intl for six 6 years and

Mr Karadagli hired Barsan Int1 for its international transportation services on behalf of several

of Mr Karadaglisformer and present businesses including Impexia Decl at1117 8 9 10 12

13 15 1619 It is therefore not surprising that Mr Karadagli would have a working

relationship Impexia does not necessarily characterize that relationship as close with Barsan

Intl based on years of professional and personal interaction

IV CONCLUSION

The Complainants have failed to establish that the Commission has personal jurisdiction

over or authority to issue any orders binding Respondent Impexia Accordingly the

Commission should dismiss this proceeding against Impexia Inc

Considering that as of February 2010 over 400 million people use Facebook it is difficult tocontend that being Facebook friends necessarily implies a close relationship Seehttp wwwwebpronewscomhow over 400 millionpeopleuse facebook201002

11

Relief Requested

For the foregoing reasons Impexia hereby moves the Commission to dismiss the

Complaint as to Impexia with prejudice

Dated June 3 2011 Respectfully submitted

12

Ashley W CraigDavid G Dickman

Lauren D Eade

Venable LLP

575 7th Street NWWashington DC 20004Telephone 202 344 4351Facsimile 202 344 8300awcraig@venablecomdgdickman@venablecomIdeade@venablecomCounselfor Respondent Impexia Inc

CERTIFICATE OF SERVICE

I hereby certify that on this 3 day of June 2011 a true and complete copy of the

foregoing Motion to Dismiss Complaint was served on the following by first class mail postage

prepaid

Carlos RodriguezRodriguezODonnelGonzalez Williams PC1250 Connecticut AveNW Suite 200Washington DC 20036Counselfor Complainants

David P Street

GKG Law PC1054 ThirtyFirst Street NW

Suite 200

Washington DC 200074492Counselfor RespondentsBarsan Global Lojisticks Ve Gumruk MusavirligiASBarsan International Inc

LauWn D Eade

Counselfor Respondent Impexia Inc

13

EXHIBIT A



BEFORE THE

FEDERAL MARITIME COMMISSION

v Docket No 11 07


MUSAVIRLIGI A S BARSANINTERNATIONAL INC and IMPEXIA INC

Complainants

Respondents

DECLARATION OF CUNEYT KARADAGLI IN SUPPORT OF IMPEXIAS

MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION

I Cuneyt Karadagli also known as Jimmy Karadagli declare under penalty of perjury

that the following is true and correct

1 I am currently the President and Special Products Coordinator of Impexia Inc

Impexia a USbased procurement firm that specializes in providing overseas services to the

United States Government and to global construction companies Impexia performs procurement

management providing building materials and complete industrial products Impexia deals with

US government agencies as well as private clients globally In addition Impexia offers a

unique service to companies where a single qualified source supplier is considered more

beneficial and cost effective than estimating sourcing and expediting all items on a project

Consequently Impexias responsibility is to fully manage and coordinate each of a projects

following phases takeoffsbills of material quotationproposal preparation submittals of

manufacturers technical data shop drawings approvals review production and fabrication

field coordination and shipments and logistics

2 Impexia was incorporated on March 11 2010 in the State of New Jersey In the

Articles of Incorporation I listed my home address of Hasbrouck PI Rutherford New Jersey

07070 as the registered office for Impexia See Certificate of Incorporation of Impexia Inc a

copy of which is attached to this declaration as Exhibit 1

3 I am currently the only member of Impexia When I first started Impexia I

intended for my cousin Mr Okan Eker to be my partner in the Company Accordingly Mr

Ekersname appears in ImpexiasCertificate of Incorporation Exhibit 1 Currently Mr Eker

lives in Turkey In April of 2011 Mr Eker and I decided to end our partnership in Impexia I

intend to file new documents on which Mr Ekers name will not appear as a partner in Impexia

4 Impexia is not and has never been an ocean common carrier a marine terminal

operator nor an ocean transportation intermediary Impexia does not and never has

participated in providing transport of any shipments by ocean as a carrier Impexia has always

hired a freight forwarder NVOCC or ocean common carrier to transport its products by ocean in

the US foreign commerce

5 Since 2005 I have incorporated and operated several companies including

Source Concept Inc dba Myra Home House of Water LLC House of Water Inc and Impexia

Inc Source Concept Inc dba Myra Home was incorporated on July 20 2005 and ceased

operations in April of 2009 House of Water Inc was incorporated in June 2009 and ceased

operations in December of 2009 I was president with a 33 share with two other partners In

January of 2010 which was previously House of Water Inc became House of Water LLC

House of Water LLC ceased operations in November of 2010

2

6 At the time Impexia was incorporated and while my other companies were in

operation my wife Burcin Karadagli was employed by Barsan International Inc Barsan

IntI as an Accounting Manager I was familiar with the company Barsan Int1 through my

wife because she worked there from October 2005 until April 2011

7 I chose to hire Barsan Int1 for my own companies transportation needs because

there are only a few ocean freight forwarders or NVOCCs that service the United StatesTurkey

trade Barsan IntI is unique because it has its headquarters in Turkey with branches in the

United States Based on this among other reasons I was familiar with the company and was

comfortable hiring them

8 In dealing with the sale of rugs Source Concept dba Myra Home hired Barsan

Int1 to transport by ocean two different containers of rugs from Turkey to the United States on

April 30 2008 and on May 9 2008 See Source Concept dba Myra HomeBarsan IntI Ocean

Freight Invoices copies of which are attached as Exhibit 2 From July of 2008 through April of

2009 I also used Barsan IntI warehouse services for storing Myra Home inventory See Source

Concept dba Myra HomeBarsan Intl Warehouse Freight Invoice a copy of which is attached

as Exhibit 3

9 When Myra Homesbiggest customer filed for bankruptcy in November of 2008

I had no choice but to stop operating Myra Home

10 In dealing with the sale of industrial products Source Concept dba Myra Home

hired Barsan IntI to transport shipments from the US to Turkey and Pakistan in the time period

spanning December 2008 through December 2009 See Source Concept dba Myra

HomeBarsan Intl Air and Ocean Freight Invoices copies of which are attached as Exhibit 4

3

11 In August of 2009 I began selling bottled water In September of 2009 along

with a partner I incorporated House of Water Inc House of Water I stored some of the

companysinventory in the Barsan Intl warehouse and paid for those services I was a regular

customer who often accessed properly and with authorization the Barsan Intl warehouse in

order to load water onto my truck House of Water paid for these services as would any other

customer See House of WaterBarsan Int1 Warehouse Invoices copies of which are attached as

Exhibit 5

12 On behalf of House of Water I also hired Barsan Intl to provide ocean freight

services between September 2009 and September 2010 House of Water paid for these services

as would any other customer See93010 House of WaterBarsan Intl Ocean Freight Invoice a

copy of which is attached as Exhibit 6

13 From July 2009 until September 2009 House of Water rented an office space

located at 1709 Zink Place Unit 3 Fair Lawn NJ 07410 upstairs from the Barsan Intl

warehouse located at 1709 Zink Place Unit 5 See Asik Warehousing Inc Invoices for Rental

of Office space copies of which are attached as Exhibit 7 After September of 2009 House of

Water had office space at another location including at my own residence at 14 Hasbrouck

Place Rutherford NJ 07070 I stopped operating House of Water by mid October of 2010

because I did not think that the company would succeed and I was not happy with my partner

14 In November 2010 I shifted my focus to Impexia which was selling certain

products to the Turkish and Pakistani militaries

15 Impexia often hired Barsan Intl a FMC licensed ocean freight forwarder and

NVOCC to provide ocean transportation services Impexia itself has never issued a bill of

4

lading and has never engaged in ocean transportation Impexia has always hired an ocean freight

forwarder NVOCC or ocean common carrier to handle Impexiasocean shipments

16 Specifically since March 2010 Impexia has hired Barsan IntI to transport by

ocean two shipments of certain nonmilitary items to Turkey See ImpexiaBarsan Intl Ocean

Freight Invoices copies of which are attached as Exhibit 8 and Exhibit 9

17 In AprilMay 2010 Barsan Intl transported by ocean a shipment for Impexia

from Barsan IntIswarehouse to Turkey See5410 Invoice Exhibit 8

18 In NovemberDecember 2010 Barsan Intl transported by ocean a shipment for

Impexia from Barsan IntIswarehouse to Turkey to the end user 77 Construction Company

See 12910 Invoice Exhibit 9

19 Since March 2010 I have hired Barsan Intl to make two air shipments of certain

non military items to Turkey for Impexia see ImpexiaBarsan Intl Air Freight Invoices copies

of which are attached as Exhibit 10 and one road shipment

20 I have never hired Barsan IntI to store Impexiasproducts in its warehouse

However it is possible that Impexia products were stored in the Barsan IntI warehouse while in

the care of Barsan IntI

21 Barsan Int1 has never shipped by air or by ocean any of Impexiaselectrical

products

22 From November 12 2010 until March 7 2011 I posted the address 1709 Zink

Place Unit 5 Fair Lawn New Jersey 07410 on Impexiaswebsitewwwimpexiausacomand

in the signature line of my Impexia business emails 1709 Zink Place Unit 5 Fair Lawn New

Jersey 07410 is also the address of Barsan Intl I used the Barsan Intl address as Impexias

mailing address out of convenience because my wife worked there and was easily able to bring

5

home mail addressed to Impexia At no time was the Fair Lawn address Impexiasregistered

address

23 Never during the time I was using the Barsan Intl address did Impexia hold itself

out as an ocean freight forwarder or an NVOCC

24 During the time Impexia was using the Barsan Intl address I wrote multiple

emails on behalf of Impexia seeking freight quotes from Barsan IntI employees including Isik

Onur Ugur Aksu Sevgi Cebe Tugsan Uresin The recipients of these emails surely saw that

Impexia listed the Barsan Intl address as Impexiasmailing address Barsan Intl was therefore

aware that Impexia was using the same address as early as November 2010 but Barsan Intl

made no objections until March of 2011 See 11301012811 and22811 Emails copies of

which are attached as Exhibit 11 Exhibit 12 and Exhibit 13

25 I declined to use Barsan IntIstransportation services during the time period I

was using the same address as Barsan Intl November 2010 through March 2011 because

Barsan IntIsquotes were higher than the ones I had received from other freight forwarders

26 On March 4 2011 I was confronted by Ugur Aksu President of Barsan Intl who

ordered me to cease using the Barsan Intl business address for Impexia I agreed to stop using

the address and by the next business day I had removed the Barsan Intl address from everything

associated with Impexia including the website and my business email signature

Pursuant to Rule 7 of the Rules of Practice and Procedure 1 have provided English translationsof emails that were originally in Turkish The English translation appears first and behind eachtranslation is the original Turkish version The translations have been prepared and notarized byLink Translations an independent company whom I have hired to perform this service eslihanTorgut of Link Translations has provided a verification of the accuracy of the translations whichis included with this Declaration

6

27 I was interested in continuing to rent the same office for Impexia as I had used for

House of Water I was in the process of negotiations with the landlord when Barsan Intl

approached me in early March 2011 and asked me to stop using Barsan Intlsaddress for

Impexiasmail

28 Impexia was using the Barsan Int1 address only as a temporary measure and only

until I was able to obtain office space for Impexia As I stated above I was in the process of

negotiating a business address for Impexia in March of 2011 when Barsan Intl requested that I

cease using its address I realize that it was improper for me to use the Barsan Int1 address and

I regret having done it As soon as I realized my mistake I took corrective action For example

on March 7 2011 I sent a letter to Barsan Intl apologizing for using the Barsan Intl address as

Impexiasmailing address See March 7 2011 Apology Letter a copy of which is attached as

Exhibit 14 Then I immediately ceased all use of the address

29 After Impexia stopped using Barsan Intlsaddress in March 2011 Impexia

opened virtual offices in New Jersey Florida and Texas through Reguscom Impexia used one

telephone number for all three locations due to the fact that there are no physical offices in

Florida or Texas M of the date of this declaration Impexia has a physical office through

Reguscom located in Saddlebrook New Jersey Impexia still maintains virtual offices in Florida

and Texas

30 As of March 4 2011 I had negotiated for Barsan IntI to handle the ocean

shipment of its first Impexia electrical product After Mr Aksu spoke to me Barsan Intl

withdrew its freight quote and 1 was told to remove the Impexia product from the Barsan Intl

warehouse which I did soon thereafter

7

31 No agreement between Barsan Int1 and Impexia has ever existed outside of a

normal ocean freight forwarderNVOCCcustomer relationship

32 Impexia does not have nor has Impexia ever had any type of corporate affiliation

or existed as or acted as a subsidiary of Barsan Intl

33 At no time has Impexia been involved in a scheme with Barsan Int1 to obtain and

utilize BGL or Barsan Intlscustomers commercial proprietary information with the purpose of

engaging in the same business as Barsan Intlscustomers and in order to solicit importexport

trading business from Barsan Intlscustomers clients Impexia has obtained its customers

through my own efforts to research and to market I frequently used wwwfbogovto find

government contractors as potential clients to whom I could send marketing materials In emails

that were sent on December 8 12 and 22 of 2010 and on January 18 2011 I wrote to the

following companies including but not limited to Emta Construction States Corps Asfa

International Construction Trading Co Artek Construction Lona Cec Fayz Contruction Chris

M Brown Road Roof Construction Company Hertz Construction Inc Afghanistan

Mutamadin Azad Construction Sigem Ltd DDFRB Inc Dorce Holding Treysan

Prefabricated Zafer Construction Epik Construction Kulak Construction Co Metag

Construction and OBD Construction I found these companies through my own research

34 For example when Impexia was engaged in selling products to the US Corps of

Engineers in Afghanistan as part of my normal business practices I performed internet research

on companies operating in Afghanistan and discovered Emta Construction located in Kandahar

Afghanistan I sent Impexiasmarketing materials to Gulsen Ozdemir of Emta Construction in

order to market to Emta Construction and possibly gain Emta Construction as a customer of

Impexia See December 8 2010 Email with Impexia Company profile a copy of which is

8

attached as Exhibit 15 Mrs Ozdemirshusband Galip Koper an employee of Ceytun

Construction Company Ceytun also located in Kandahar Afghanistan forwarded my email

to his supervisor at Ceytun On December 9 2010 Ceytun contacted me and expressed an

interest in doing business with Impexia See December 9 2010s Email from Ceytun to Impexia

copies of which are attached as Exhibit 16 At that point Impexiasbusiness relationship with

Ceytun commenced

35 Impexia did not knowingly receive any information about Ceytun through Barsan

Intl

36 As another example after conducting research on wwwfbogov I contacted

Metag Construction Metag by sending an email and attaching Impexiasmarketing materials

See January 18 2011 Email to Metag Construction a copy of which is attached as Exhibit 17 I

did not hear back from Metag However Impexia was introduced to Metag by representatives of

Ceytun via email on February 5 2011 not through Barsan Intl as alleged in the Complaint See

February 5 2011 Email from Niyazi Berberoglu of Ceytun Email to Jimmy Karadagli copying

Metag territory managers a copy of which is attached as Exhibit 18 On behalf of Impexia I

replied back to Metag on February 6 2011 See February 22 2011 February 6 2011 Emails a

copy of which is attached as Exhibit 19 At first Metag did not respond On February 22

2011 Metag requested Impexiasservices via two separate emails and was particularly

interested in Impexiaselectronic material Exhibit 19 See also February 22 2011 Email from

Oktay Kasimoglu to Jimmy Karadagli a copy of which is attached as Exhibit 20 At that point

Impexia began to sell electronic material to Metag and the ImpexiaMetag business relationship

commenced

9

37 in August of 2010 1 learned about 77 Construction Company 77 Construction

through its business development manager Omer Can Kayhan who is a longtime personal friend

of mine I sent Mr Kayhan a quote from lmpexia for an overhead door in which

Construction was interested Mr Kayhan accepted those rates on behalfof 77 Construction ano

the lmpexia77 Construction business relationship commenced at that point See November 18

2010 and November 29 20101mails a copy of which is attached hereto as Exhibit 21

38 Impexia Teamed of 77 Construction through my own prior personal relationship

with Mr Kayhan and not through Barsan IntI as alleged in the Complaint

I declare under penalty of perjury that the forego is true aryl correct

EXECUTED ON June 3 2011

uneyt Karadagli

10

VERIFICATION

1 Neslihan Torgut of Links Translations declare and state that the translations

Link Translations provided of the mails attached as exhibits to the Declaration of

Cuncyt FCaradagli are true and correct to the best of my knowledge and belief

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

Executed on June 3 2011

Ms N ihanforgut Project ManagerLink Translations

EXHIBIT 1

Mar 12 2010g 12BPMENBE Fax6099846851 Mar 12 2010 1325 No 0174 02 P 1No 0154 P 2

Mar 11 200 22F1

centfGcaeeofIncorporatunOf

IMflXIA INC

The endorsgno0 of tiro ago of eighben yearn or older forme purpose of fmmMg a corporation puneoe e meprovisions ofTills I4A Corporations General Alba New Jersey Statutes does hereby ox cute IhoF 1L E Dfollowing ccrniteatcofincorporation

I The name of the corporation is 1MPEXIA INC

2 The purpose for which the corporation is formed is

To do any act or activity far which corporations may be organized pursuant to the provisions ofTitlet4A Copotation General of the New Jersey Statutes provided that the corporatioi shall not engagein any act or activity for which the consent or approval ofany slate office agency board departmentoffice or any other body ofthe State ofNew Jersey without first obtaining such consent or approval3 The aggregate number of shares that the corporation shall be aulhotized to issue is 2500 with no

per value

4 The address of the coporalionSinitial registered office and the name of the c p r cons agenttherein is

Cuneyt Karadagii 14 Hasbrouck Place Rutherford NJ 07070

5 The names and addicssos of the initial board of directors to salve until the That annual meetingof shareholders or until the successorsarc elected aid qualify are as follows

Cuneyl Ksradagll 14 Hasbrouck Place Rutherford NJ 07070

piton Eker 14 Hasbrouck Place Rutherford NJ 07070

6 The number of directors constituting the initial Board of Directors is Two

7 The name and address ofthcincopotatoris

Sean Burgess I9 W 34 Street Suite 1018 New York NY 10001

8 No diteeter of this corporation shall be personally liable to the corporation or its shareholders fordamages for any breach of duty in such capacity provided that this provision shall not limit theliability of any director if a judgement or other final adjudication advet sc to hire establishes thathis act or omiSSiens were in bad faith or involved Intentional misconduct or a knowing violationof law or that he personally gained lit fact a financial profit or other advantage in which he wasnot legally entitled

The initial ByLaws of the corporation shall be adopted by the undersigned incorporationThereafter the Board of Directors to the extent petmissrble by the New Jersey Business CorporationAct may adopt amend andor repeal said ByLaws

In Witness Whereof I hereto sign this Cm tificatc of Incorporation this t1 day of March 2010

Sean Burgess

Incorporator S 2C c f

MAR 11 2010

STATE TREASURER

EXHIBIT 2

Fee Description Amount

Ocean Freight 199500

AMS 3000

Documentation 5000

Total S207500

Invoice 11495

Invoice Date 4302008

Terms Net 30

Due Date 5302008

BARSAN INTERNATIONAL INCCLIFTON COMMERCE CENTER 3

700 ROUTE 46 WEST

CLIFTON NJ 07013

PH 973 253 2121 FX973253 2122

Bill To

SOURCE CONCEPT DBA MYRA HOME

14 HASBROUCK PLACE

RUTHERFORD NJ 07013

BGL Ref No BGLIO22108

ORGDST MERSNYC

PCSWGT

Ship Date

4302008

YUK

ETD ETS 041508

ETA 042808

OTI 4656NF

Invoice

HBUHAWB

CNT

MBLMAWB


Ocean Freight 199500

AMS 3000

Documents and Handling Fee 5000

Inland Fee 32500

EXAM FEE 34000

TERMINAL FEE IN TURKEY 2500

Total 5276500

Invoice 11519

Invoice Date 592008

Terms Net 30

Due Date 682008


700 ROUTE 46 WEST

CLIFTON NJ 07013

PH 973253 2121 FX973253 2122

Bill To


14 HASBROUCK PLACE

RUTHERFORD NJ 07013


ORGDST MERSNYC

PCSWGT

Ship Date

592008

YUK

ETD ETS 04172008

ETA 050908

OTI 4656NF

Invoice

HBUHAWB MENY08097546

CNT TOLU 1621299

MBLMAWB APLU800901856

EXHIBIT 3


Warehouse Rent of July 2008 50000

Terms

Total 50000

Invoice 11708

Invoice Date 712008

Terms Net 30

Due Date 7312008


700 ROUTE 46 WEST

CLIFTON NJ 07013

P1 973 253 2121 FX973253 2122

Bill To


14 HASBROUCK PLACE

RUTHERFORD NJ 07013


ORGDST MERSNYC

PCSWGT

Ship Date

712008

YUK

ETD ETS 04172008

ETA 050908

OTI 4656NF

Invoice

HBLJHAWB MENY08097546

CN

MBLMAWB APLU800901856

EXHIBIT 4

Date Invoice

1282008 1907200911

PO Number Terms Expires Rep Ship Via CIF Project

VFFIO PrePaid 182009 JB 12102008 Air Istanbul

Quantity Item Code Description UM Price Each USD Amount

550 VFFI 0 DUPONT VITON FREE FLOW 10 PELLETS 22 Kg 4000 2200000

25 kg packages

I Inland Freight Inland Freight Delivery Fee 38000 38000

1 Export Preparat Export Preparation Fee AES Filing Fee ea 50 00 5000

I ForwardersFee Freight ForwardersFee ca 50 00 5000

I Air Freight Air Freight Fee ea 222000 222000

CIF Total in USD 2470000

Source Concept Inc

14 Hasbrouck Place

Rutherford NJ 07070United States of America

T 201 7291581

Bill To

Bati Savunma SanayiOsman Durmaz

100 Yil Bulvari 41 A Sokak No 10

Ankara Ostim TurkeyTel 90 312 3863062

Commercial Invoice

Ship To

Bati Savunma SanayiOsman Durmaz

Istanbul Airport TurkeyTel 90 312 3863062

Date Invoice

512009 20091978

SOURCECONCEPT14 Hasbrouck 11ce Rutherford NJ 070702016362802T 800882A8TF 2016562803Finfoasotirceconceptriet Wwwsciurcecon

Bill To

Faith Arab General Trading LLCJabeen YagoopPO Box No 92380Dubai United Arab Emirates

Tel 971 4 2728611

Page 1

Commercial Invoice

Ship To

Faith Arab General Trading LLCJabeen YagoopDubai United Arab Emirates

Tel 971 4 2728611

PO No Terms Expires Rep Ship Via CFR

FANT5153 Cash in Advance 612009 IB 552009 Air Dubai UAE


1 DORIC LENSE Bare Fiber Adapter Kit Six SMA Connectors Ieach 100 um 200300400 600 1000 um And aconnect and release adapter to Fasten the SMAsonto bare optical fiber

ea 61380 61380

1 DORICLENSE Termination Kit SMA Connector SMA ea 92400 92400

Connectors 4 each 50 100 200 400 600 1000um 1 Polishing Puck 2 15 cm x 15 cm glasspolishing plate 36 Polishing papers 12 each of11 cm x 10 cm 12 um 3 um and 1 um lappingfilm 1 Inspection scope 2 Hour cure epoxyoptical wipes and instructions

1 DORIC LENSE 10 premium SMA Connector for 100um And 100urn 50 um fiber

ea 29370 29370

1 DORICLENSE 10 premium SMA connector for 200um fiber ea 29370 29370200um

1 DORIC LENSE 10 premium SMA connector for 300um fiber ea 29370 29370300um

1 DORIC LENSE 10 premium SMA connector for 400um fiber ea 29370 29370400um

1 DORICLENSE 10 premium SMA connector for 600ym fiber ea 29370 29370600um

1 DORIC LENS 10 premium SMA connector for I000um fiber ea 29370 29370I000um

ORIGINAL

CFR Total in USD

SOURCECONCEPT14 Hasbrouck 11ce Rutherford NJ 070702016362802T 800882A8TF 2016562803Finfoasotirceconceptriet Wwwsciurcecon

Bill To

Faith Arab General Trading LLCJabeen YagoopPO Box No 92380Dubai United Arab Emirates

Tel 971 4 2728611

Page 1

Commercial Invoice

Ship To

Faith Arab General Trading LLCJabeen YagoopDubai United Arab Emirates

Tel 971 4 2728611

Date Invoice

512009 20091978

PO No Terms Expires Rep Ship Via CFR

FANT5153 Cash in Advance 612009 JB 552009 Air Dubai UAE


1 35462E1FM VERB Optical Breadboards are 18 thk ea 135630 135630Ferromagnetic steel skins laminated to anonmetallic honeycomb core with greater than 50direct core to metal skin lamination Providing astrong bond and static rigidity the core has 38honeycomb cells with Internet broadband energyabsorption eliminating the need for additionalinternal dampers to suppress the found in metalcores The breadboard is coated in an anti reflective

black polyurethane finish 36 x 48 x 23 Grid ofv 20 holes

1 FL2 14S3MC FL2 14S3MC 1392x1032 Monochrome CCD ea 109500 109500

Camera 139461 M12t4MP 12mm Fl 4 Lens wlocking Iris Focus MegaPixcl ea 12430 12430

2 ST0530IOAT46 1 FNPT HAYWARD DUPLEX STRAINER ea 67100 134200CONSTRUCTED

OF CAST IRON WITH BUNA ELASTOMERS

1 SHEARPLATE Shear Plate Collimation Tester Aperture Sizel0mm

ea 43450 43450

500 03937 03937 Nickel A200 CFW Material 100140Annealed Temper Spooled Round Bare wire

Mt 09845 49225

I Air Freight Air Freight Door to Dubai Port ea 250000 250000

Total iPallet

Gross wweight 15100 Kg 0 R 1 GINA

CFR Total in USD1064435

SOURCEONCEPT

14 Hasbrouck Place Rutherford NJ 070702016362802T 80088208991F 201436803 Finfo@sourceconceptnet wwwsotirceconceptnet

Bill To

Faith Arab General Trading LLCJabeen YagoopPO Box No 92380

Dubai United Arab Emirates

Tel 971 4 2728611

Page 2

Commercial Invoice

Ship To

Faith Arab General Trading LLCJabeen YaqoopDubai United Arab Emirates

Tel 971 4 2728611

Our Ref EA15009

Your RefInvoice No 12523


Invoice Due Date 06052009

Invoice To

SOURCE CONCEPT DBA

14 HASBROUCK PLACE

RUTHERFORD NJ 07013

USA

Loading John F Kennedy Intl Discharge Dubai

Descriptions157 6434 3521

ETS ETA

Item Description Of ChargesAir Feight

Shipment Nr 91008 Quantity 1

Barsan International IncInternational Freight Forwarder NVOCCA division of Barsan Global Lojistik AS

1709 Zink Place Suite5 Fair Lawn NJ 07410Ph 201 773 0730 ext 204 Fax 201 773 0731

Item Description

EA15009

Gross Weight 15100

Total Invoice Amount

PLEASE MAKE CHECKS PAYABLETOBARSAN INTERNATIONAL INC

Total

60000

60000

Item Description Of Charges

Ocean Freight




Our Ref E016309




Invoice To

SOURCE CONCEPT DBA

14 HASBROUCK PLACE

RUTHERFORD NJ 07013

USA

Loading NEWYORK Discharge DUBAI

DescriptionsCRSU 9145510

ETS ETA

Item Description

E016309

Gross Weight 11800



Total

40000

40000

Item Description Of ChargesAir Feight




Our Ref EA25009




Invoice To

SOURCE CONCEPT DBA

14 HASBROUCK PLACE

Loading

RUTHERFORD NJ 07013

USA

Discharge

DescriptionsLAXHKGDXB1 BOX17 LBS

ETS ETA

Item Description

EA25009

Gross Weight 800


PLEASE MAKE CHECKS PAYABLE TO BARSAN INTERNATIONAL INC

Total

35000

35000

EXHIBIT 5


Storage Fee SAKA 15 PALLET STORAGE 2 CONTAINER10052009 11052009

12000

ORGDST

Total 12000

BGL Ref No 1077909 YUK 189314

ORGDST

Due en receipt

ETD ETS

109

PCSIWGT ETA

Invoice 13208


Terms Due en receipt

Due Date 109

BARSAN INTERNATIONAL INC17 09 ZINK PLACE STEt5

FAIR LAWN NJ 07410PH 201 773 0730 FX201 773 0731

Bill To

I10USE OF WATER

1709 ZINK PLACE UNIT If 3

FAIR LAWN NJ 07410

PaymentsCredits

Ship Date

1092009

80 00

OTI 4656NF

Invoice

HBLHAWB

CNT

MBLMAWB

Balance Due 5120 00


Storage Fee 3 container hayat bl 528885734

yts k4

139314

16000

Fr0

u

MAr

ETD ETS

10912009

Total 516000

BGL Ref No I077909 YUK 139314

ORGDST

Due on receipt

ETD ETS

10912009

PCSWGT ETA

Invoice 13206


Terms Due on receipt

Due Date 10912009

BARSAN INTERNATIONAL INC1709 ZINK PLACE STEWS

FAIR LAWN Ni 07410PH 201 773 0730 FX201 773 0731

Bill To

HOUSE OF WATER

1709 ZINK PLACE UNIT W 3

FAIR LAWN NJ 07410

PaymentsCredits

Ship Date

1092009

50

OTI 4656NF

Invoice

HBLHAWB

CNT

MBLMAWB

Balance Due 16000


Storage Fee saka inout bl ist2090231

r car

rJ

lw

17600

ORGDST

Total 17600

BGL Ref No I077909 YUK 189314

ORGDST

Due on receipt

ETD ETS

10812009

PCSWGT ETA

Invoice 13205


Terms Due on receipt

Due Date 10812009

BARSAN INTERNATIONAL INC1709 ZINK PLACE STE5

FAIR LAWN NJ 07410PH 201 773 0730 FX201 773 0731

Bill To

HOUSE OF WATER

1709 ZINK PLACE UNIT it 3

FAIR LAWN NJ 07410

PaymentsCredits

Ship Date

1082009

50 00

t111162DTI 4656NF

Invoice

HBLHAWB

CNT

MBLMAWB

Balance Due S17600

Our RefInvoice No 14389

Invdit el ate 0531 s 1 0invoice et d site 05f1 i 0Your Ref

Invoice To

HOUSE OF WATER

1709 ZINK PLACEUNIT 3

FAIRLAWNNJ 07410

Descriptio4MAY STORAGE FEE

IETA 1Loading NEWYORK Discharge NEW JERSEY EIS

Ocean Storage FeeShipment Nr 13579Ocean Storage Fee

enhipment Nr 13579

item Description Of Charges

Quantity 1

Quantity 1

Barsan Inter 1 ationaInternational Freight Forwarder NVOCA division of BarsanlGlobal Lojistik AS

1709 Zink Place Suite5 Fair Lawn NJ 0Ph 201 773 0730 ext2O4 Fax 201 773

Item DescriptionMAY STORAGE FEE 365 PALLETS

Gross Weight11 CONTAINERS 242 P

Gross Weight

100

LLETS IN OUT EE

100

Tote Invoice Arnoun

BARSAN I09 A STE

INC3

FAIR LAWN NJ 07410

Go

PLEASE MAKE CHECKS PAYABLE TO BARSAN NTERNATIONAL 1 4C

V

Tot

313

i2

6

Our RefInvoice No 15231


Your Ref Invoice Due Date 09302010

Invoice To

HOUSE OF WATER

14 HASBROUCK PLACE

RUTHERFORD NJ 07070

DescriptionsSEPTEMBER STORAGE FEEAPHU6384960 22 PALLET RECEIVED

TRLU5235751 22 PALLET RECEIVEDGATU8477391 22 PALLET RECEIVED

Loading NEWYORK Discharge NEWYORK ETS ETA


Ocean Storage Fee

Shipment Nr 40155

Ocean Storage FeeShipment Nr 40155



Item Description164 PALLETS STORAGE FEE

Quantity 1 Gross Weight 1003 CONTAINERS 66 PALLET IN OUT FEE

Quantity 1 Gross Weight 100



Total

164000

66000

230000

EXHIBIT 6

Our Ref

Your Ret

Invoice To

HOUSE OF WATER

1709 ZINK PLACE

UNIT 3

FAIRLAWN NJ

Loading MERSIN

7 Item Description Of CharOcean Pre gnt

Shipment Nr 273299Ocean MIS

Shipment Nr 273299Ocear 1Cstcms C1nargcs

Shiprnent Nr 273296Ocean Uuy

Shipment Nr 273299Ocean Olhe Expenses

Shipment Nr 273299Ocean Customs Pee

Shipment NrOccan Csonts

Shiprnent Nr 27129E

Shipment NrAam

Shipment Nr

ges

07410

Quantity 62

Quantity 162

Quantity 62

Quantity 62

Quantity 62

Quantity 62

Quantity 5

Quantity

Quantity

International Frenghl Forwamer NVOCCA civsior of Baysan Gloow LopstIc A

1709Z PlaceSterth Fair Lawn NJ C1Pr 20 773 0730 exl 204 Fax 201 773 0

Invoice Date 9

Invoice Due Date 39302010Invoice No

Gross Weight

Gross Weight

Descriptions

APHU6384960TRLU5235

Discharge NEWYORK ETS 26 08 2010 ETA 22 09 2010

10 989 0

Gross Weight 76 320 30r

Gross Weight 6FDA ZEE

Gross Weight9 10

Gross Weight C

13 3r C

Gross Weight

Gross Weight 76 L

id C

Gross Weight E 1z

S4 650 00

524 00

35060

335 72

585 64

30

01

Total Invoice Amount 5784056

EXHIBIT 7

Asik Warehousing Inc1709 Zink Place Unit 3Fair Lawn NJ 07410

Bill To

House of Water Inc1709 Zink Place Unit it 3

Fair Lawn NJ 07410

Date

Invoice

Invoice

772009 1 3

Due Date Terms

772009

Description Rate Amount

Office Rent for month of July 09 50000 50000

Total 50000Fax 201 773 0988


Bill To

House of Water Inc1709 Zink Place Unit it 3

Fair Lawn NJ 07410

Date

Invoice

Invoice

772009 1 3


Bill To

House of Water Inc1709 Zink Place Unit 3

Pair Lawn NJ 07410

Invoice

Date

812009

Invoice

25

Due Date Terms

812009 Due on receipt

Description Quantity Rate Amount

Office Rent for month of August 09 1 50000 50000

Total 5000CFax 201 773 0988


Bill To

House of Water Inc1709 Zink Place Unit 3

Pair Lawn NJ 07410

Invoice

Date

812009

Invoice

25


Bill To

House of Water Inc

1709 Zink Place Unit 3

Fair Lawn NJ 07410

Invoice

Date

9112009

Invoice

56

Due Date Terms

9I2009 Due on receipt

Description Quantity Rate Amount

Office Rent for month of SetoCMiier oq 1 50000 50000

Total 55000CFax 201 0988


Bill To

House of Water Inc

1709 Zink Place Unit 3

Fair Lawn NJ 07410

Invoice

Date

9112009

Invoice

56

EXHIBIT 8

Our Ref

Your Ref

Invoice To

IMPEXIA INC

14 HASBROUCK PLACE

RUTHERFORD NJ 07070

Loading NEWYORK Discharge AMBARLI

Item Description Of ChargesOcean FreightShipment Nr 138016 Quantity 7

Barsan International IncInternational Freight Forwarder NVOCCA division of Barsan Global Loiistik AS


Invoice No 14234

Descriptions

Item DescriptionEO1770410

Gross Weight 574000




ETS 542010 ETA 5262010

Total

1200 00

120000

EXHIBIT 9

Our Ref FO 364 10

Your Ref

Invoice To

IMPEXIA INC

14 HASBROUCK PLACE

Barsan International Inc

r

RUTHERFORD NJ 07070

International Freight Forwarder NVOCCA division of Barsan Global Lojistik AS


Invoice No 15731

DescriptionsCAXU7371706



Loading NEWYORK Discharge MI RSIN ETS ETA

Item Description Of Charges Item Description Total

Ocean Freight 33 096 00

Shipment Nr 404714 Quantity 23 Gross Weight 4 990 00

Total Invoice Amount 309600

EXHIBIT 10




Invoice To

IMPFXIA INC

4 KASBROUCK PLACE

RUTHERFORD NJ 07070

Loading John F Kennedy Intl Discharge Ataturk

Descriptions756 1176 7582

ETS ETA

Our Ref EA14010


Air Feigh

Shipmem Nr 114348 Quantity 3Air insune

Shipmer J r 114348 Quantity 3



Item Description

EA14010

Gross Weight 246000

Gross Weight 246000


Total

595000

12000

607000

Our Ref EA18310Invoice No 14744


Your Ref 445146 Invoice Due Date 07272010

Invoice To

IMPEXIA INC

14 HASBROUCK PLACE

RUTHERFORD NJ 07070

Descriptions7561176 7674

Loading John F Kennedy Intl Discharge Ataturk ETS ETA




Air Feight

Shipment Nr 238546

Air Inland Haulge

Shipment Nr 238546Air Transfer Fee

Shipment Nr 238546

Air Forwarding Fee

Shipment Nr 238546

Quantity 4

Quantity 4

Quantity 4

Quantity 4

Item Description

Gross Weight 300000

Gross Weight 300000

Gross Weight 300000

Gross Weight 300000



Total

635700

46000

29300

3500

714500

Our Ref EA18310Invoice No 14766


Your Ref 445146 Invoice Due Date 07292010

Invoice To

IMPEXIA INC

14 HASBROUCK PLACE

RUTHERFORD NJ 07070

Descriptions

WEIGHT DIFFRENCE

Loading John F Kennedy Intl Discharge Ataturk ETS ETA


Air Feight




Item Description

Gross Weight 360000



Total

5655

5655

EXHIBIT 11

I Foi d jno Sieet Surto 1406 Now York NY 10017

1 888 577 INK 154051 ininffiIoklurslclron Qom

TO WHOM THIS MAY CONCERN

STATEMENT CERTIFYING PROFESSIONAL TRANSLATION

Link ransiations provides professional translation services We have translated the attached clocumentstitled

Email Coorespondents

Prom TUKTSN

into S5H

en I0 I ItO a tha 111 1 tii Ufe55101 and es pet tented translatorswho have a Idler It knowledge of both languages

d the tr tvd text 101 income accuracy and c ons is tenc y with t he original source text and we proof Feddi a Fans aFd teat for spelling ord gr am ma oral accuracy

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SWORN TO BEFORE ME THIS

3x day of Juce 20I

Jimmy KaradagliFrom Jimmy Karadagli ijkaradagli impexiausacomSent Tuesday November 30 2010 456 PMTo Isik Onur

Cc Tugsan Uresin Sevgi Cebe Ugur AksuSubject RE SHIPMENT TO CAMP BASTION

Isik let it be Mersin Is this the best rate for ocean freight I had told the customer 2750 without taking intoaccount the inland Could you review it and see what you can do for this time There is a confusion which Icouldntunderstand either 111 send the details of the delivery to the warehouse for tomorrow On Thursdayand Monday two separate materials metal door and metal shutterSee if you can find Mersin Bastion inland rate As I told you they have 10k rate at hand

Kind regards

Jimmy KaradagliSpecial Projects Products Coordinator1709 Zink Place Unit5

Fair Lawn NJ 074102016362802 T201 636 2803 F

msn aol gmall Ikaradagll Skype jimmy karadaglijkaradagli@impexiausacomwww Impexiausa com

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email m error and that any use dissemination forwarding printing or copying of this email s strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments ifany

From Isik OnurmailtoisikonurbarsancomSent Tuesday November 30 2010 435 PMTo Jimmy KaradagliCc Tugsan Uresin Sevgi Cebe Ugur AksuSubject RE SHIPMENT TO CAMP BASTION

Cuneyt

If it is more convenient for the client we can unload at Istanbul too But Im not sure if we can catch the

USD10000 freightI also asked from the IST office an AFG rate with IST exit

We can unload either in Mersin or Istanbul depending on the clients choiceWill the materials enter to our warehouse on Monday How many pieces will there beAlso attached you can find the SLI document Could you complete it accordingly and send it to me togetherwith the commercial invoice

Thanks and good day

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL CS

wwwbarsancom

Logistics @ Speed of ThoughtOwn Orruss t ogMcsCarr rt 7 URKE V USA tt RMANY UK FRANCE n AI Y SPAN HUNGARY POt AND U8FKISrAN H PUSHONG KONG

From Jimmy Karadagli mailtojkaradagli@impexiausacomSent Tuesday November 30 2010 200 PMTo Isik Onur

Cc Tugsan Uresin Sevgi Cebe Ugur AksuSubject Re SHIPMENT TO CAMP BASTION

Ok ocean freight will be NYMersin III will tell the inland rate to the clientCan you forward to me 40 containers to be loaded on Monday

Kind RegardsJimmy KaradagliSpecial Projects Products CoordinatorImpexia1709 Zink Place Unit5

Fair Lawn NJ 07410201 6362802 T201 6362803 Fjaradagli Frimpexiausacomwwwimpcxiausacom

On Nov 30 2010 at 133 PM Isik Onur isikonurabarsancom wrote

Hi Cuneyt

They said that if it will exit from the Turkish office by air and Istanbul arrival will be by land then Mersin arrivalwould be better

For Istanbul arrival you may consider the Turkon rates below For ISTAFG Ill inquire the IST office again togive me a rate for IST exit

Thank you and good day

From NJ 07410

To MERSIN 1X40 DC

VIA TURKON

INLAND 275 USD

0F 2821 USD

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL L OGISTICS

201 77iiirax 201 77 Owwwbarsancom

Logistics @ Speed of ThoughtOwn Offices Logistics Cerners m TURKEY USA GERMANY UK FRANCE ITALY SPAIN HUNGARY POLAND UZBEKISTAN CHNAHONG KONG

From Jimmy Karadagli mailtojkaradagli@impexiausacomSent Monday November 29 2010 538 PMTo Isik Onur

Cc Tugsan Uresin Sevgi Cebe Ugur AksuSubject Re SHIPMENT TO CAMP BASTION

Isik hi

It needs to be Istanbul It cant be Mersin because material shipments to Afghanistan from Turkeymust be made via Istanbul Now there is a route between Istanbul and Afghanistan For yourinformation

The inland freight forward rate that the client has at hand is 10000 But 1 want it to be Barsan sothat 1 can both provide doortodoor service for the client and work with you because suchAfghanistan freights could become monthly via Istanbul and there can even be more demand

Kind RegardsJimmy KaradagliSpecial Projects Products CoordinatorImpexia1709 Zink Place Unit5

Fair Lawn NJ 07410

201 6362802 T201 6362803 F

jkaradaglicimpexiausacomwwwimpexiausacom

On Nov 29 2010 at 613 PM Isik Onur isikonuribarsancomwrote

Hello Cuneyt

The price offer for the said freight is below Please review it and let me knowWhen will the materials arrive at the warehouse How do you want us to organize


From NJ 07410

TO MERSIN

1X40 DC

VIA TURKON

INLAND 275 USD

0F 2921 USD

TR LOCAL PRICES

Free Out USD165

ISPS USD11

Ordino USD65

Mersin Afghanistan delivery freight USD14500Store house total cost USD600From NJ 07410TO KARACHI PORT QUISIM

1X40 DCVIA SAFMARINE

INLAND USD300OF USD2220

Mersin Afghanistan delivery freight USD14500Store house total cost USD600

Karachi to Camp LeatherneckTransportation US 1020040COCType CommercialWeight 1015 MT including tare weightRouting Karachi Quetta Chaman Kandhar Camp BastionCamp Leatherneck

MsIsik Onur

Export Traffic ManagerBARSAN GLOBAL 1 OGISTCS

wwwbarsancom

Logistics @ Speed of Thought

HONG KONS

From Jimmy Karadagli mailto jkaradagli@impexiausacomSent Saturday November 27 2010 807 AMTo Isik Onur

Cc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Isik have you received the rate

Kind regards

Jimmy KaradagliSpecial Projects Products Coordinator

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responsibility to scan attachments Of any

From Isik Onur mailtoisikonur@barsancomSent Tuesday November 23 2010 146 PMTo Jimmy KaradagliCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Hello Cuneyt

Will the materials be delivered to a military or civil organization Please let me know We need it for truckpricing

Thanks and good day

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL 1 OGISIICS

wwwbarsancom


From Isik Onur

Sent Tuesday November 23 2010 930 AMTo Jimmy KaradagliCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

HI Cuneyt

Thanks and good day

rr n i 1 I

TR office said they will let me know about the TR costs if shipment will be via Turkey For Pakistan Karachiroute Im still waiting for the agency to give me the rates

I sent a reminder Ill let you know as soon as I receive a reply

Mslsik Onus

Export Traffic Manager

BARSAN GLOBAL 1 OGlSTICSI 09 Plea Unrtr

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1i tI JU 20139ax 1 CC 77 41wwwbarsancom

Logistics @ Speed of ThoughtOwn Offices ik LousUcs Centers n TURKEY USA GERM UK FRANCE ITALY SPAIN HUNGARY POLANDUZBEKI STAN CHINA HONG KONG

From Isik Onur

Sent Monday November 22 2010 1056 AMTo Jimmy KaradagliCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Hi CuneytI havent received the price yet Turkonsfirst vessel information is as follows

Erkan k 2381008e

From ny 1201Cutoff 1130Eta Mersin 1221

Eta ist 1225

Thanks good day

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL LOGS17CS

wwwbarsancom

Logistics @ Speed of ThoughtO1C L 102 CS r1QYf L 1r

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From Jimmy Karadagli mailto jkaradagli @impexiausacomSent Monday November 22 2010 1002 AMTo Isik Onur


Have you received the inland transportation price yet Also it would be great if you NY departure dates ofTurcon

Kind regards


16 R rKEL At PA11 G f2Y 14 ANDJ

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jkaradagli@impexiausa comwww impexiausa comDisclaimer This email and any files transmitted with it are confidential and intended for the use of theindividual or entity to whom they are addressed This communication may contain information whichmay be privileged If you are not the intended recipient you are advised that you have received thisemail in error and that any use dissemination forwarding printing or copying of this email is strictlyprohibited If you received this email in error please contact the sender and in any event delete thematerial from your system immediately Email may be susceptible to data corruption interception andunauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is yourresponsibility to scan attachments if any

From Isik OnurmailtoisikonurbarsancomSent Monday November 22 2010 1058 AMTo Jimmy KaradagliCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Hi Cuneyt

Im waiting for transport rates both for Pakistan and for Turkey leg For today I cannot receive anything fromPakistan but I believe they will send it tomorrow Then I can inform you tooIm waiting for transfer and freight information Ill let you know as soon as I receive it

Thanks good day

MsIsik Onur

Export Traffic ManagerBARSAN GLOBAL I OGIS TICS

wwwbarsancom

Logistics @ Speed of Thought0 k L C kKr iA IE Vr K r t R

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From Jimmy Karadagli mailtojkaradagli@impexiausacomSent Monday November 22 2010 954 AMTo Isik Onur


Isik

It is very important that we should receive information today Also ISTANBUL CAMPLEATHERNECKBASTION inland transport rate

Kind regards


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Karadagli@impexiausacomwwwimpexiausa comDisclaimer This email and any files transmitted with it are confidential and intended for the use of theindividual or entity to whom they are addressed This communication may contain information whichmay be privileged If you are not the intended recipient you are advised that you have received thisemail in error and that any use dissemination forwarding printing or copying of this email is strictlyprohibited If you received this email in error please contact the sender and in any event delete thematerial from your system immediately Email may be susceptible to data corruption interception andunauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses It Is yourresponsibility to scan attachments if any

From Isik OnurmailtoisikonurbarsancomSent Monday November 22 2010 1052 AMTo Jimmy KaradagliCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Thank you 1 let you know

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL C3ICS

wwwbarsancom

Logistics @ Speed of Thoughtoffes9Lot Ct NRKC Ed4i9 Y SPAIN 18n di AND

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From Jimmy Karadagli mailtojkaradagli@impexiausacomSent Monday November 22 2010 933 AMTo Isik Onur

Subject RE SHIPMENT TO CAMP BASTION

Overhead doors Dims 23 ft x 25 ft x 25 ft each Weight 900 Ibs each 10 PiecesMetal Doors 37795 inches x 81102 inches each door size Weight 500 Ibs each 4 pieces

Kind regards


image00l jpg

1709 Zink Place Unit3

Fair Lawn NJ 07410201 6362802 T

201 6362803 F9179726562 C

tkaradagli @impexiausa cornwwwimpexiausa com

Disclaimer This email and any files transmitted with it are confidential and intended for the use of theindividual or entity to whom they are addressed This communication may contain information whichmay be privileged If you are not the intended recipient you are advised that you have received thisemail in error and that any use dissemination forwarding printing or copying of this email is strictlyprohibited If you received this email in error please contact the sender and in any event delete thematerial from your system immediately Email may be susceptible to data corruption interception andunauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is yourresponsibility to scan attachments Of any

From Isik Onur mailtoisikonur@barsancomSent Monday November 22 2010 933 AMTo jkaradagli @impexiausacomCc Sevgi Cebe Tugsan UresinSubject SHIPMENT TO CAMP BASTION

Hello Cuneyt

Im making a price inquiry for the freight Ill learn the prices for transfers via both Turkey and KarachiBut I need the average weight for transport Please advise me about this matter


Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL 1 0113T

wwwbarsancom

Logistics f Speed of Thought

UfPi

The information contained in this email including anyattachments is confidential Tt must not be disclosed to anyperson without our authority If you are not the intendedrecipient please delete it from your system immediately BarsanGlobal Lojistik AS makes no warranty as to the accuracy orcompleteness of any information contained in this message andhereby excludes any liability of any kind for the informationcontained therein or for the information transmission recepta onstorage or use of such in any way whatsoever Any opinionsexpressed in this message are those of the author and may notnecessarily reflect the opinions of Barsan Global Lojistik AS

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From Jimmy Karadagli jkaradagli impexiausacomSent Tuesday November 30 2010 456 PMTo Onur

Cc Tugsan Uresin Sevgi Cebe Ugur AksuSubject RE SHIPMENT TO CAMP BASTION

Isik Mersin olsun ocean freight icin en iyi rate bumu ben musteriye inland hesap etmeden 2750 demisim bir gozdengecirirsen bu seferlik ne yapabilirsin bir bak benimde bilmedigim bir karisiklik oldu Ben sana yarin delivery nasil yapilacaksizin depoya bilgi geciyorum Thursday ve Monday iki ayri malzeme metal kapi ve metal kepenkler gelicek

Bulabiliyorsan mesin bastion inland rate bakabilirsin dedigim gibi 10k rate var ellerinde

Kind regards

Jimmy KaradagliSpecial Protects Products Coordinator

mpe1709 Zink Place Unit5

Fair Lawn NJ 074102016362802 T

2016362803 F

msn aol gmail Ikaradagli Skype jimmykaradagliIkarad an likaimpexlausa comwww impexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments ifany

From Islk Onur mailtoisikonur@barsancomSent Tuesday November 30 2010 435 PMTo Jimmy KaradagliCc Tugsan Uresin Sevgi Cebe Ugur AksuSubject RE SHIPMENT TO CAMP BASTION

Cuneyt agbi eger Musteri icin Istanbul uygun olacak ise Istanbula da cikartabiliriz ancak belirttigi 10000 usd navlunuyakalayabilirmiyiz bilmiyorum IST ofisime IST cikisli olacak AFG fiyati da talep ettim

Hangisi uygun olacak is eve musterinin talebine gore Istanbul veya Mersine cikartabiliriz

Malzemeler bizim depoya pazartesimi girecek toplam kac adet olacak

Ayrlca ekte SLI evragini da iletiyorum buna gore doldurup commercial invoice ile beraber iletebilirmisin

Tsk iyi calismalar

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL LOGISICS

1

wwwbarsanwm

logistics 9 Speed of Thought04ra ces LUc c5 CA i i KEY USA LERtvN K FRAtit I ALY SWN HUNGARY 1OAU UIGF Ci rt h tair t KcAG

From Jimmy KaradaglimailtojkaradagliimpexiausacomSent Tuesday November 30 2010 200 PMTo Isik OnurCc Tu6san Uresin Sevgi Cebe Ugur AksuSubject Re SHIPMENT TO CAMP BASTION

Ok ocean freight NYMersin olsun Karayi bildiricem musteriye

Pazartesi yukleme yapilacak sekilde 40lik Konteyner getirtebilirsin bana

Kind Regards

Jimmy KaradagliSpecial Projects Products CoordinatorImpexia1709 Zink Place Unit5

Fair Lawn NJ 07410201 6362802 T201 6362803 Fiaradagl iaimpexiausacomwwwimpexiausacom

On Nov 30 2010 at 133 PM lsik Onurisikonuribarsancomwrote

Cuneyt agbi merhaba

Acikcasi Turkiye ofisden hava cikisi olacak ise Istanbul varisi kara cikisi olacak ise Mersin varisinin dahauygun olacagini belirttiler

Istanbul varis olarak asagidaki Turkon fiyatlarini dikkate alabilirsinISTAFG icin ise tekrar 1ST ofisdensorguluyorum 1ST ciksli fiyat vermeleri icin

Tsk iyi calismalar

From NJ 07410

TO MERSIN

1X40 DC

VIA TURKON

INLAND 275 USD

OF 2821 USD

Msfsik Onur

Export Traffic ManagerBARSAN GLOBAL LOGSTCS

2

wwwbarsancorn

Logistics Cw Speed of ThoughtOvr Offices I N el cs Centers r RKFY USA CR RMANY UK FRANCF TAI Y SPAIN HUNGARY KN AND U79EKISTAN CHNA

HONG KONG

From Jimmy Karadagli mailto jkaradagli@impexiausacomSent Monday November 29 2010 538 PMTo Isrk OnurCc Tugsan resin Sevgi Cebe Ugur AksuSubject Re SHIPMENT TO CAMP BASTION

Isik selam

Istanbul olmasi gerekiyor Mersin degil cunku AfganistanaTurkiyeden malzeme sevkiyatlariIstanbul uzerinden oluyormus haliyle IstAfgan yolu olusmus bilgine

Gerci su anda musterinin elinde 10000 kara tasima fiyati varmis fakat ben Barsanlaolsunistiyorumki musteriye hem door to door servis sunayim hemde sizle calismis olayim Cunku butarz Afgan tasimalari her ay Istanbul uzerinden olabilir hatta dahada yogunlasabilir

Kind Regards


Impexia1709 Zink Place Unit5

Fair Lawn NJ 07410

201 6362802 T201 6362803 Fjkaradagliimpexiausacomwwwimpexiausacom

On Nov 29 2010 at 613 PM Isik Onur isikonurubarsancom wrote

Cuneyt agbi merhaba

Ilgili yukleme icin fiyat teklifi asagidaki gibi degerlendirip bilgi vermeni rrcaediyorummalzemeler ne zaman depoya varis yapacak ve nasil organize etmemiziistiyorsun

Tsk iyi calismalar

From NJ 07410

TO MERSIN

1X40 DC

3

VIA TURKONINLAND 275 USD

OF 2921 USD

TR LOCAL FIYATLARIFree Out usd 165

ISPS usd 11

Ordino usd 65

Mersin Afganistan teslim navlun usd 14500Ardiye toplam masraf usd 600

From NJ 07410

TO KARACHI PORT QUISIM

1X40 DCVIA SAFMARINE

INLAND 300 USD

OF 2220 USD

Mersin Afganistan teslim navlun usd 14500Ardiye toplam masraf usd 600Karachi to Camp LeatherneckTransportation US 1020040 COCType Commercial

Weight 1015 MT including tare weightRouting Karachi Quetta Chaman Kandhar Camp BastionCamp Leatherneck

Mstsik Onur

Export Traffic ManagerBARSAN GLOBAL L OGIS HOS

wwwbarsancom

Logistics Speed of Thought

From Jimmy Karadagli mailto jkaradagli@impexiausacomSent Saturday November 27 2010 807 AMTo Isik OnurCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Isik fiyat geldimi

Kind regards


image00 1 jpg1709 Zink Place UmH63

Fair Lawn NJ 074102016362802 T

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9179726562 C

4

jkaradaoli2dimoexiausacomwwwimoexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of theindividual or entity to whom they are addressed This communication may contain information whichmay be privileged If you are not the intended recipient you are advised that you have received thisemail In error and that any use dissemination forwarding printing or copying of this email is strictlyprohibited If you received this email in error please contact the sender and in any event delete thematerial from your system immediately Email may be susceptible to data corruption interception andunauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is yourresponsibility to scan attachments if any

From Isik Onur mailtoisikonurbarsancomSent Tuesday November 23 2010 146 PMTo Jimmy KaradagliCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Cuneyt agbi merhaba

Malzeme Afganistanda askeriye mi yoksa sivil bir kurulusami Bu konuda bilgiverebilirmisin Kamyon fiyatlandirmasi acisindan gerekmekte

Tsk iyi calismalar

Mssik Onur

Export Traffic ManagerBARSAN GLOBAL L OGIS UICS

www r anQm

togfstics G9 Speed of Thought

From Isik OnurSent Tuesday November 23 2010 930 AMTo Jimmy KaradagliCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Cuneyt agbi merhaba

Turkiye den aktarilacak sekilde Tr de olusacak masrafalri TR ofisimiz yarin iletebilceginibelirtti Pakistan Karachi aktarmali olacak sekilde ise acentadan fiyatlari bekliyorumhatirlatma gectim kendilerine gelir gelmez bilgi verecegim

Tsk iyi calismalar

Mslsik Onur


5

BARSAN GLOBAL LOGISTICS

wwwbarsenmm

Logistics @ Speed of ThoughtOwn O cc G cgs cs Cane r TURKGP USA Gf f4MANY JK FRANCI Irk p SPA L JNGAPY POI ANDU78EKTAN CHINA NONC KONG

From Iglk OnurSent Monday November 22 2010 1056 AMTo Jimmy KaradagliCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Cuneyt agbi merhaba

Maalesef henuz fiyat ulasmadi Turkonun ilk gemi bilgisi asagidaki gibi

Erkan k 2381008e

From ny 1201Cutoff 1130Eta Mersin 1221

Eta ist 1225

Tsk iyi calismalar

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL LOGISTICS

wwwbarsancom


From Jimmy Karadagli mailto jkaradagli impexiausacomSent Monday November 22 2010 1002 AMTo Isik OnurCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Kara nakliye fiyati geldimi trden Birde turconun nyden kalkis tarihlerini bildirirsensevinirim

Kind regards


6

image001jpg17 09 Zink Place Unit3

Fair Lawn NJ 074102016362802 T2016362803 F

9179726562 C

jkaradaoliGDimpexiausa comwwwimoexiausa com

Disclaimer This email and any files transmitted with it are confidential and intended for the use of theindividual or entity to whom they are addressed This communication may contain information whichmay be privileged If you are not the intended recipient you are advised that you have received thisemail in error and that any use dissemination forwarding printing or copying of this email is strictlyprohibited If you received this email in error please contact the sender and in any event delete thematerial from your system immediately Email may be susceptible to data corruption interception andunauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is yourresponsibility to scan attachments if any

From Isik Onur mailtoisikonur@barsancomSent Monday November 22 2010 1058 AMTo Jimmy KaradagliCc Tugsan resin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Cuneyt agbi merhaba

Hem Pakistan ayagi hem de Turkiye ayagi icin aktarma ile ilgil ifiyat bekliyorum Bugunitibari ile Pakistanda bilgi alamam ancak yarina fiyatlari gecmis olurlar heralde o zamaniletebilirim

Turkiye ayagi Iclnde aktarma ve navlun icin bilgi bekliyorum onlaradan da bilgi gelirgelmez iletecegim

Tsk iyi calismalar

Msisik Onur

Export Traffic ManagerBARSAN GLOBAL L OGISTICS

wwwbarsancom

Logistics C Speed of Thought

From Jimmy Karadagli mailtojkaradagli @impexiausacomSent Monday November 22 2010 954 AMTo Isik OnurCc Tugsan resin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

ISIK COK ONEMLI BUGUN BILGI GELIRMI BIRDE ISTANBUL CAMPLEATHERNECKBASTION KARA NAKLIYE FIYATI

Kind regards

7


image001jpg1709 Zink Place Unit13Fair Lawn NJ 074102016362802 T

201636 2803 F9179726562 C

jkaradagliTimpeziausa comwwwimpexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of theindividual or entity to whom they are addressed This communication may contain information whichmay be privileged If you are not the intended recipient you are advised that you have received thisemail in error and that any use dissemination forwarding printing or copying of this email is strictlyprohibited If you received this email in error please contact the sender and in any event delete thematerial from your system immediately Email may be susceptible to data corruption interception andunauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is yourresponsibility to scan attachments Of any

From I5ik Onur mailtoisikonur@barsancomSent Monday November 22 2010 1052 AMTo Jimmy KaradagliCc Tugsan Uresin Sevgi CebeSubject RE SHIPMENT TO CAMP BASTION

Tsk bllgi verecegim

Ms Isik Onur


Ittorn


From Jimmy Karadagli mailto jkaradagli @impexlausacomSent Monday November 22 2010 933 AMTo Iik OnurSubject RE SHIPMENT TO CAMP BASTION

Overhead doors Dims 23 ft x 25 ft x 25 ft each Weight 900 Ibs each 10 Pieces

Metal Doors 37795 inches x 81 102 inches each door size Weight 500 Ibs each 4pieces

Kind regards


image001jpg8

1709 Zink Place Unit3Fair Lawn NJ 07410201636 2802 T2016362803 F917972 6562 C

jkaradagliaimpexiausa cornwwwimpexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of theindividual or entity to whom they are addressed This communication may contain information whichmay be privileged If you are not the intended recipient you are advised that you have received thisemail in error and that any use dissemination forwarding printing or copying of this email is strictlyprohibited If you received this email in error please contact the sender and in any event delete thematerial from your system immediately Email may be susceptible to data corruption interception andunauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is yourresponsibility to scan attachments if any

From Iglk Onur mailtoisikonur@barsancomSent Monday November 22 2010 933 AMTo ikaradaali @imoexiausacom

Cc Sevgi Cebe Tugsan UresinSubject SHIPMENT TO CAMP BASTION

Cuneyt agbi merhaba

Ilgili yukleme icin fiyat calismasi yapiyorum hem Karachi hem Turkiye aktarmali olarakfiyatlari toparlayip iletecegim

Ancak aktarma icin ortalama kilo bilgisi gerekmekte bu konu da bilgi iletebilirsensevinirim

Tsk iyi calismalar

Mslsik Onur


BARSAN GLOBAL OCSiiCS

www barsancom

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The information contained in this email including anyattachments is confidential It must not be disclosed to anyperson without our authority If you are not the intendedrecipient please delete it from your system immediately BarsanGlobal Lojistik AS makes no warranty as to the accuracy orcompleteness of any information contained in this message andhereby excludes any liability of any kind for the informationcontained therein or for the information transmission receptionstorage or use of such in any way whatsoever Any opinionsexpressed in this message are those of the author and may notnecessarily reflect the opinions of Barsan Global Lojistik AS

Bu epostanin icerdigt bilgiler ekleri dahil olmak Uzeregiztidlr Onayimiz olmaksizin ncuncu kisilere aciklanamaz Bumesajin genderilmek istendigi kisi degilsenlz utfen mesajisistominizden derhai sil iniz Barsan Global Lojistik AS bumesajin iccrdig bllgillcrin dogrulugu veya eksiksin oidugukonusunda bir garanti vermemektedir Bu nedenie biigilerin nesekilde olursa oisniergnden iletilmesinden alnmasirdansaklanmasnian scrzriu 7rri u mesa in erg yazarina aitolup Barsar Gleba iojASrn g5rUser gerncyobiir

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The information contained in this e mail including anyattachments is confidential It mast not be disciosed to anyperson without our authority If you are not the intendedrecipient please delete it from your system immediately BarsanGlobal Lojistik AS makes no warranty as to the accuracy orcompleteness of any information contained in this message andhereby excludes any liability of any kind for the informationcontained therein or for the information transmission receptionstorage or use of such in any way whatsoever Any opinionsexpressed in this message are those of the author and may notnecessarily reflect the opinions of Barsan Global Lojistik AS

Bu epostantn igerdig bilgiler ekleri dahil olmak azuregtzlidir Onayimiz olmaksiLzin upuncii kisilere asiklanamaz Bumesajin genderiirek istendigi kisi degilseniz 1Ufen mesajisisteminizden derhai siinis Barsan Global ojisck AS bumesair icerdig ogi1in dogrulugu voya eksiksiz odUgukonusurda bi ran ononektadir Fa euolc bYg erin no

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EXHIBIT 12



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State of New York

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tiny Public

Jimmy KaradagliFrom Jimmy Karadagli jjkaradagli@impexiausacomSent Friday January 28 2011 519 PMTo Islk OnurCc Ugur AksuSubject RE Panleboards to Afghanistan Kandahar

Isik

Putting it sideways will not be a problem

They will all be in separate wood boxes But can you find me the people who could do the wood boxingand even get a quote from them From there it can directly go to warehouse of the company that will dothe airfreight in JFK

By the way the full dimensions and weight are as below

4 Boxes HCP Panelboards Each 281 kgs Each 68 H x 42 W x 95 D9 Boxes HCRU Panelboards Each 330kgs Each 86 H x 44 W x 9 5 D

Kind regards

Jimmy KaradagliSpecial Projects Products Coordinator1709 Zink Place Unit5Fair Lawn NJ 074102016362802 T2016362803 F

msn aol gmail jkaradagli Skype pmmykaradaglijkaradagli @impexiausa cornwww impexiausa com

Disclaimer This email and any files transmitted with a are confidential and intended for the use of the individual or entityto whom they are addressed This communication may contain information which may be privileged If you are not theintended recipient you are advised that you have received this email in error and that any use dissemination forwardingprinting or copying of this email is strictly prohibited If you received this email in error please contact the sender and inany event delete the material from your system immediately Email may be susceptible to data corruption interceptionand unauthorized amendment and no liability is accepted for any such corruption interception or amendment or theconsequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments ifany

From Isik Onur mailtoisikonur@barsancomSent Friday January 28 2011 504 PMTo Jimmy KaradagliCc Ugur AksuSubject RE Panleboards to Afghanistan Kandahar

Cuneyt agbi TranslatorsNote Agbi is a term of endearment widely used that means big brother hello

We do not do wood boxing in our warehouse that is why there are companies around JFK that do this work and they shoulddo it will the 13 panelboards each be wood boxed separately Also you mention the height as 88 can we put thatsideways as it is quite high

Thanks and best

Ms srk Omit


BARSANGLOBAL LOGISTICS17 S4 2 nc Pafi mt 3 S

Fan lawn 07110 NOW lrsey1T 1 1 20 7E1 0730l01 7n 0731

wwwbarsancom

Logistics @ Speed of ThoughtOwn offices i ngistics Centers tURKCY USA GERMANY UK PRANCE ITALY SPAIN HUNGARY PO AND U7REKIS1AN CHINA

HONG KONG

From Jimmy Karadagli mailtojkaradagli @impexiausacomSent Friday January 28 2011 217 PMTo Iglk OnurCc Ugur AksuSubject Panleboards to Afghanistan Kandahar

Isik hi

The material below are being manufactures right now and I will receive them on February 15 could beFair Lawn NJ Can you obtain a price for airfreight Also the panelboards will be wood boxing exportpacking if there is a person who can come to your warehouse to take care of this please let me know Ifnot it would be logical to first ship it to the place that would get the wood boxing done and then have itpicked up for air freight

You have not done it for me but Impexia is a Known shipper by TSA for your information O

13 Panelboards Each Box 88H x 46W x 115D Each Box 300kgsMaterial Electrical Panelboards and going to KandaharAfghanistan

Jimmy KaradagliSpecial Projects Products Coordinator17 09 Zink Place Unit5Fair Lawn NJ 07410

2016362802 T2016362803 F

msn aol gmail jkaradagli Skype jimmy karadaglijkaradagli@impexiausacomwww impexiausacomDisclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entityto whom they are addressed This communication may contain information which may be privileged If you are not theintended recipient you are advised that you have received this email in error and that any use dissemination forwardingprinting or copying of this email is strictly prohibited If you received this email in error please contact the sender and inany event delete the material from your system immediately Email may be susceptible to data corruption interceptionand unauthorized amendment and no liability is accepted for any such corruption interception or amendment or theconsequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments ifany

The information contained in this e mail including any attachments isconfidential

Tt must not be disclosed to any person without our authority If you are notthe intended recipient please delete it from your system immediately BarsanGlobal Lojistik AS makes no warranty as to the accuracy or completeness ofany information contained Ln this message and hereby excludes any liabilityof any kind for the information contained therein or for the information

transmission reception storage or use of such in any way whatsoever Anyopinions expressed in this message are those of the author and may notnecessarily reflect the opinions of Barsan Global Lojistik AS

Jimmy Karadagli

From Jimmy Karadaglj ukaradagli@impexiausacomSent Friday January 28 2011 519 PMTo Icik OnurCc Ugur AksuSubject RE Panleboards to Afghanistan Kandahar

Isik

Yan yatirmak sorun olmaz

Hepsi ayri ayri wood boxing olacak Peki sen bana wood boxing yapacak yeri bulabilirmisin vede hatta quotealabilirmisin oradanda airfreight yapacak sirketin depoya gider JFKde direk

Bu arada tam dims ve agiriik asagidaki gibi

4 Boxes HCP Panelboards Each 281 kgs Each 68 H x 42 W x 95 D9 Boxes HCRU Panelboards Each 330kgs Each 86 H x 44 W x 95 D

Kind regards

Jimmy KaradagliVenial Projects Products Coordinator

mpreia17 09 Zink Place Unit5Fair Lawn NJ 07410201 6362802 T

201636 2803 F

msn aol gmail jkaradagli Skype jimmy karadaglijkaradaoli@impexiausacomwwwimpexiausacom


From Islk Onur mailtoisikonur@barsancomSent Friday January 28 2011 504 PMTo Jimmy KaradagliCc Ugur AksuSubject RE Panleboards to Afghanistan Kandahar

Cuneyt agbi merhaba

Wood boxing yapmiyoruz depoda bu nedenle JFK yakinlarinda wood boxing yapan firmalar var onlara onlara yaptililmasilazim

13 panelboradin hepsi ayri ayri mi boxing yaptirilacak bir de 88 H demissin bunu yan yatirabilme sansi varmi yoksaoldukca yuksek

Tsk iyi calismalar

1

Mstsik Onur


IPOAKF t NI 77www barsancom

Logistics 6 Speed of ThoughtOran Ot cues Loat cs Ce NI TiiRKfY USA GERMANY UK FRANCK TTAI Y SPAIN HUNGARY PO A D t7i3FdISTiN HINA HONG KONG

From Jimmy Karadagli mailto jkaradagli impexiausacomSent Friday January 28 2011 217 PMTo Isik OnurCc Ugur AksuSubject Panleboards to Afghanistan Kandahar

Isik selam

Asagidaki malzemelerin uretimi yapiliyor suanda Subat 15de elimde Fair Lawn NJ olabilir olacak Airfreight icin fiyatalabilirmisin Birde panelboardlar wood boxing export packing olacak eger sizin depoya gelip bu isi halledebilecek birivarsa bildirirsin bana yoksa ilk once wood boxing yapacak yere ship ettirip sonra airfreight icin pickup daha mantikli olur

Sen beni yapmadin ama Impexia Known shipper TSA tarafindan bilgine O

13 Panelboards Each Box 88H x 46W x 115D Each Box 300kgsMaterial Electrical Panelboards and going to KandaharAfghanistan

Kind regards

Jimmy Karadagli

Venial Projects Products Coordinatoros

impexua1709 Zink Place Unit5Fair Lawn NJ 074102016362802 T2016362803 F

msn aol gmail jkaradagli Skype jimmy karadaglijkarad aeliImpexiausa comwwwimpexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system Immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments ifany

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The information contained in this e mail including any attachments is confidentialIt must not be disclosed to any person without our authority If you are not the intendedrecipient please delete it from your system immediately Barsan Global Lojistik ASmakes no warranty as to the accuracy or completeness of any information contained in thismessage and hereby excludes any liability of any kind for the information containedtherein or for the information transmission reception storage or use of such in any waywhatsoever Any opinions expressed in this message are those of the author and may notnecessarily reflect the opinions of Barsan Global Lojistik AS

3

EXHIBIT 13

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uiovino a tear n CA professional and expeIenced tIa nslatoisarho have a fluent knowledge of both a nyuages

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State of New York

County of New York

SWORN TO BEFORE MF THIS

3d day of Jane 2011

Jimmy KaradagliFrom Isik Onur isikonur@barsancomSent Monday February 28 2011 411 PMTo Jimmy KaradagliCc Tugsan Uresin Ugur Aksu Sevgi CebeSubject RE Transformer to Istanbul

Hello Cuneyt

The gross weight of the freight will be 1302 kg and it will be transported by air according to thedetails below

Delivery of the freight from our warehouse to Fifo USD300Aes USD30

For 1000 kg by LHFsc ssc 120usdkgs 15624 usd

Air freight by LH airlines 195 usd kgs 25389usdTransfer fee from Fifo to Airline 010 usd kgs min 40 usdForwarding fee 35 usdValid for non hazardous substances and tr locals are not included

The insuranece as I told before will be around USD6065

Mslsik Onur

Export Traffic ManagerBARSAN GLOBALIOGS7 S

wwwbarsancom

Logistics Speed of ThoughtOwn Ot co St I lcs ILRKFYUSA UK FRANCL TALYSPAIN nUrtRULLKISIAN 0 IINA HONG KONG

From Jimmy Karadagli mailtoikaradagli @impexiausacomSent Monday February 28 2011 1052 AMTo Isik Onur

Cc Tugsan UresinSubject RE Transformer to Istanbul

Isik

The delivery of this freight to you will be two days The client also wants to learn the Istanbulprice Can you advise me about it

Kind regards


2

17 09 Zink Place Unit5

Fair Lawn NJ 074102016362802 T

2016362803 F

msn aol gmail karadagli Skype jimmy karadaglijkaradagll@impexiausacomwwwlmpexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the Individual or entity to whom they areaddressed This communication may contain Information which may be privileged If you are not the Intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email Is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability Is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility Is accepted for viruses It Is your responsibility to scan attachments Ifany

From Isik Onur mailtoisikonur@barsancomSent Thursday February 17 2011 1218 PMTo Jimmy KaradagliCc Tugsan UresinSubject RE Transformer to Istanbul

Cuneyt

WiII the below freight will arrive at the warehouse May I learn about the sender details Do youknow when it will reach the warehouse

Thanks good day

Mstsik Onur

Export Traffic ManagerBARSAN GLOBAL L OGIs ICS

wwwbarsancom


i lq ri

From Isik Onur

Sent Monday February 14 2011 425 PMTo Jimmy KaradagliSubject RE Transformer to Istanbul

Eta 0320

MsIsik Onur

Export Traffic ManagerBARSAN GLOBAL GS1CS

3

wwwbarsancom

Logistics @ Speed of ThoughtOwn Offices loglsbcs Centers m TURKEY USA GEUZBEKISTAN CHINA HONG KONG

From Jimmy Karadagli mailtojkaradagii@impexiausacomSent Monday February 14 2011 330 PMTo Isik Onur

Subject RE Transformer to Istanbul

0225 vessel is Eta number

Kind regards


Fair Lawn NJ 074102016362802 T2016362803 F

msn aol gmail jkaradagli Skype jimmy karadaglljkaradag li Impexlausacomwwwimpexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email i5 strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption Interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments Ofany

From Isik Onur mailtoisikonur@barsancomSent Monday February 14 2011 420 PMTo Jimmy KaradagliCc Ugur Aksu Tugsan UresinSubject RE Transformer to Istanbul

The first vessel is on 0225 cut off is on 0224 It would be great if it arrives at the warehouse thisweek

I can followup if you send me the documents I need from you merchandise invoice SLI and therouting details

Thanks and good day

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL CGS7 ri a

wwwbarsancom

Logistics @ Speed of Thought0 ces S l ces

LVEMKISTAN KON0

ANY UK FRANC PAIN HUNGARY POLAND

4

ITALY

CT r a1N GLRv POLAND

From Jimmy Karadagli mailtojkaradagli impexiausacomSent Monday February 14 2011 306 PMTo Isik Onur

Cc Ugur Aksu Tugsan UresinSubject RE Transformer to Istanbul

Lets have it insured then Is there a container leaving on Friday We can catch that one I guess

Kind regards

Jimmy KaradagliSpecial Projects S Products Coordinator1709 Zink Place Unit5

Fair Lawn NJ 074102016362802 T

2016362803 F

msn aol gmail jkaradagli Skype jimmykaradaglljkaradagli@impexiausacomwwwimpexiausa com

Disclaimer This email and any files transmitted with it are confidential and Intended for the use of the individual or entity to whom they areaddressed This communication may contain Information which may be privileged If you are not the intended recipient you are advised thatyou have received this email In error and that any use dissemination forwarding printing or copying of this email is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption Interception and unauthorized amendment and no liability a accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it w your responsibility to scan attachments ifany

From Isik Onur mailtoisikonurbarsancomSent Monday February 14 2011 357 PMTo Jimmy KaradagliCc Ugur Aksu Tugsan UresinSubject RE Transformer to Istanbul

In general insurance is estimated as merchandise value freight 10 CIF cost and chargeUSD035 for each USD100 Please send me the supplier and delivery information so that I caninform the warehouse

Thanks and good clay

Mslsik Onur


www barsan com


1 KV AS N

5

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From Jimmy Karadagli mailtojkaradagliimpexiausacomSent Monday February 14 2011 250 PMTo Isik Onur

Cc Ugur Aksu Tugsan UresinSubject RE Transformer to Istanbul

Merchandise value is total US15000 how much would insurance costThe supplier delivers to the warehouse We dont need inland transport then

Kind regards

Jimmy KaradagliSpecial Projects Products Coordinator17 09 Zink Place Unit5

Fair Lawn NJ 07410201 6362802 T

2016362803 F

msn aol gmail jkaradagli Skype jimmykaradaglijkaraclagli@impexiausacomwwwimpexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email In error and that any use dissemination forwarding printing or copying of this email is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility i5 accepted for viruses it is your responsibility to scan attachments Ofany

From Isik Onur mailtoisikonur@barsancomSent Monday February 14 2011 328 PMTo Jimmy KaradagliCc Ugur Aksu Tugsan UresinSubject RE Transformer to Istanbul

CuneytWill it be delivered here or will we go and take it If we will transfer it inland should be added tothe price below Since it is delivery at port Im only sending you the OF cost

of 75 usd cbm

aes 30 usd

According to the dimensions you gave me Two times 51x42x26 it makes 1 82 cbmYou also asked for merchandise value will it be insured

Thanks good day

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL 1 OGIS1CS

6

wwwbarsancom

Logistics 10 Speed of ThoughtOwn Offices Locntc5 Centers n TURKEY USA GERMANY UK FRANCt ITALY SPAIN HUNGARY POLAND

UL6LKISAN CHINA HONG KONG

From Jimmy Karadagli mailto jkaradagli@impexiausacomSent Monday February 14 2011 1001 AMTo Isik Onur

Subject Transformer to Istanbul

Hi IsikI need to send two units of DryType Distribution Transformer to Turkey Delivery to Istanbul potyOcean partial freightDimensions Each H 51 x W 42 x D 26

Weight Each 1436 Ibs

We cant put them on top of one another non hazmat commercial value 15000 It will be onpalettes but from small onesIve attached a picture of the freight

Kind regards


Fair Lawn NJ 07410201 636 2802 T

2016362803 F

msn aol gmail jkaradagli Skype jimmy karadaglljkaradagli@impexiausacomwwwimpexiausa com

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability s accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments ifany

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The information contained in this e mail including any attachments is confidentialIt must not be disclosed to any person without our authority If you are not the intendedrecipient please delete it from your system immediately Barsan Global Lojistik ASmakes no warranty as to the accuracy or completeness of any information contained in thismessage and hereby excludes any liability of any kind for the information containedtherein or for the information transmission reception storage or use of such in any waywhatsoever Any opinions expressed in this message are those of the author and may notnecessarily reflect the opinions of Barsan Global Lojistik AS

The information contained in this e mail including any attachments Ls confidentialIt must not he disclosed to any person without our authority If you are not the intendedrecipient please delete it from your system immediately Barsan Global Lojistik ASmakes no warranty as to the accuracy or completeness of any information contained in thismessage and hereby excludes any liability of any kind for the information containedtherein or for the information transm rsstun reception storage or use of such in any waywhatsoever Any opinions expressed in this message are those of the author and may notnecessarily reflect the opinions of Barsan Global Lojistik AS

Jimmy Karadagli

From Islk Onur islkonur@barsancomSent Monday February 28 2011 411 PMTo Jimmy KaradagliCc Tugsan Uresin Ugur Aksu Sevgi CabeSubject RE Transformer to Istanbul

Cuneyt agbi merhaba

Asagidaki detaylara gore malzeme

Gross kg uzerinden ucus yapacak 1302 kg

Malzemelerin bizim depodan Fifoya birakilmasi 300 usdAes 30 usd

1000 kg icin LH ileFsc ssc 120usd kgs 15624 usd

LH gava yollari ile Hava navlun 195 usd kgs 25389 usdTransfer fee from Fifo to Airline 010 usd kgs min 40 usdForwarding fee 35 usdTehlikeli olmayan malzemeleri icin gecerlidir tr localler dahil degildirSigorta daha once belirttigim gibi 6065 usd arasinda tutacaktir

Mslsik Onur

Export Traffic ManagerBARSAN GLOBAL i OG S TI S

wwwbarsanmm

Logistics P Speed of Thought

From Jimmy Karadagli mailtojkaradagli@impexiausacomSent Monday February 28 2011 1052 AMTo Isik OnurCc Tuosan UresinSubject RE Transformer to Istanbul

Islk

Bu tasimanin deliverysi iki gune sana ulasir

Musters hava Istanbul fiyatinida gormek istiyor Onun icinde bir fiyat gecebilirmisin

Kind regards


17 09 Zink Place Uni5

Fair Lawn NJ 074102016362802 T201636 2803 F

msn aol gmail jkaradagli Skype jimmykaradaglijkarad agMimpexiausa comwww imoexiausacom


From Islk Onur mailtoisikonur@barsancomSent Thursday February 17 2011 1218 PMTo Jimmy KaradagliCc Tugsan UresinSubject RE Transformer to Istanbul

Cuneyt agbi

Asagldaki yuk gelecekmi depoya gonderici detaylarini alabilirmiyim ne zaman depoda olacaginin bilgisi varmi

Tsk iyi calismalar

MsLsik Onur

Export Traffic ManagerBARSAN GLOBAL LOGS

wwwbarsanmm

Logistics c Speed of Thought

From Islk OnurSent Monday February 14 2011 425 PMTo Jimmy KaradagliSubject RE Transformer to Istanbul

Eta 0320

MsLskOnur

Export Traffic ManagerBARSAN GLOBAL LOGS i ICS

2

wwwbarsanm

Logistics e Speed of ThoughtOwn 01 cur I o lcs Certtrs n i aKi Y U A GFRNANY UK i RANCI it AL Y FAN tIiPJiARY POLAND UM ISTAN CHNA HONG KONG

From Jimmy Karadagli mailtojkaradagli@impexiausacomSent Monday February 14 2011 330 PMTo Iglk OnurSubject RE Transformer to Istanbul

Eta ne 0225 gemisinin

Kind regards

Jimmy Karadagli

Special Projects Products Coordinatora

111 a1709 Zink Place Unit5

Fair Lawn NJ 074102016362802 T2016362803 F

msn aol gmail jaradagli Skype jimmykaradaglijkaradagllTimpexiausa comwwwimbexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email Is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments ifany

From Isuk Onur mailtoisikonurbarsancomSent Monday February 14 2011 420 PMTo Jimmy KaradagliCc Ugur Aksu Tugsan UresinSubject RE Transformer to Istanbul

Ilk gemi 0225 de cut off 0224 bu haftac depoda olursa lyi olur

Senden ihityiacim olacak evraklar mal faturasi ve SLI malzemeler nereden gelecegi bilgisini iletebillrsen ben de takipederim

Tsk lyi calismalar

Mssik Onur

Export Traffic ManagerBARSAN GLOBAL CGS11C S

wwwbarsan com

Logistics e Speed of ThoughtcmIJfes C 1 cc ca QSrcrs G TIRKFY USA GEkhLAUY IK t RANCL ITN Y SPAIN HUNGARY P ANJ 176FRTAN OIDJA HONG KONG

3

From Jimmy Karadagli mailtojkaradagli@impexiausacomSent Monday February 14 2011 306 PMTo Isk OnurCc Ugur Aksu Tugsan resinSubject RE Transformer to Istanbul

Sigorta yaptiralim o zaman Bu Cuma varmi konteyner cikacak ona yetisir buyuk ihtimal

Kind regards

Jimmy Karadagli

facial Projects Products Coordinator

impexiaa17 09 Zink Place Unitt5

Fair Lawn NJ 074102016362802 T201636 2803 F

msn aol gmail Karadagli Skype jimmykaradaglijkaradaoliQi mpexiausacomwwwimpexiausacom


From Iflk Onur mailtoisikonur@barsancomjSent Monday February 14 2011 357 PMTo Jimmy KaradagliCc Ugur Aksu Tugsan UresinSubject RE Transformer to Istanbul

Genelde sigorta icin mal bedeli navlun 10 CIF bedeli uzerinden hesaplanip her 100 usd icin 035 usd charge edilir

Yani ortlama olarak senin malzemen icinde 6065 usd tutacaktir supplier ve ne zaman depoya ulssacak bilgileri deiletebilirsen

Ben de depodakilere bilgi verebilirim

Tsk iyi calismalar

Msfsik Onur

Export Traffic ManagerBARSAN GLOBAL L OC i5 tS

wwwparsan com


4

From Jimmy Karadagli mailto jkaradagli@impexiausacomSent Monday February 14 2011 250 PMTo Isik OnurCc Ugur Aksu Tugsan UresinSubject RE Transformer to Istanbul

Mal bedeli toplam 15000 sigorta ne kadar tutar

Depoya teslimat yapiyor supplier o yuzden inlanda gerek yok

Kind regards

Jimmy Karadagll

Stacie Projects Products CoordinatoriM a

s

1709 Zink Place Unil5

Fair Lawn NJ 07410201636 2802 T2016362803 F

msn aol gmail jkaradagli Skype jimmykaradaglijkaradagliGDimpexiausacomwwwimpexiausa com


From Iflk Onur mailtoisikonur@barsancomSent Monday February 14 2011 328 PMTo Jimmy KaradagliCc Ugur Aksu Tugsan UresinSubject RE Transformer to Istanbul

Cuneyt agbi burayami teslim edilecek yoksa biz mi aldiracagiz

Biz aldiracaksak inland eklenecek asagidaki fiyata liman teslim oldugu icin sana sadece of masrafini iletiyorum

of 75 usd cbm

aes 30 usd

verdigin olculere gore iki adet 51x42x26 den 182 cbm yapar

Bir de mal bedeli de belirtmisssin sigortada olacakmi

tsk iyi calismalar

Mstsik Onur


5

wwwbarsanrom

Logistics Speed of ThoughtOtroti OT cos Lugs s Certors o H i7RKFY USA GERMANY LK FRANCE I IALY SPAIN HLNCOARY PCMD UZBEKISTAN CHINA HONG KONG

From Jimmy Karadagli mailtojkaradagli impexiausacomSent Monday February 14 2011 1001 AMTo Isik OnurSubject Transformer to Istanbul

Isik selam

Iki adet DryType Distribution Transformer gondermem gerek Turkiyeye Istanbul liman teslim ocean parsiyel tasima

Dimensions Each H 51 x W 42 x D 26

Weight Each 1436 Ibs

Ust uste koyamiyoruz non hazmat commercial value 15000 Palet uzerinde olacak fakat ufak paletler varya onlardanekte resmini gorebilirsin malzemenin

Kind regards

Jimmy Karadagli

Special Projects Products Coordinator

impexia1709 Zink Place Unitt5

Fair Lawn NJ 074102016362802 T201636 2803 F

msn aol gmail jkaradagli Skype jimmykaradaglilkaradagleimpexiausa comwww Impexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility Is accepted for viruses it Is your responsibility to scan attachments ifany

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The information contained in this e mail including any attachments is confidential11 must not be disclosed to any person wJthout our authority if you are not the intendedrecipient please delete it from your system immediately Barsan Global Lojistik ASmakes no warranty as to the accuracy or completeness of any information contained in thismessage and hereby excludes any liability of any kind for the information containedtherein or for the information transmission reception storage or use of such in any waywhatsoever Any opinions expressed in this message are those of the author and may notnecessarily reflect the opinions of Barsan Global Lojistik AS

Au epostanin icerdigi bilgiler ekleri dahil olmak Uzere gizidir Onayimizolmaksizin tiquncu kisilere apiklanamaz Au mesajin gonderilmek istendigi kiss degilsenizlutfen mesaji sisteminizden derhal siliniz Barsan Global Lojistik AS bu mesajini cerdigi oilyLlerin dogrulugu veya eks iksiz oldugu konusunda bie garan Li vermemektedir

Bu nedenle biigilerin ne sekilde olursa olsun igeriginden iletilmesinden alinmasindansaklanmasindan sorumlu degildir Bu mesajin igerigi yazarina ait olup Barsan GlobalLojistik ASnin gbrusLerzni ieermeyehilir

The information contained in this e 14L including any uti aohrnenus s confidentialit must not be disclosed to any person ur uthc r cy ou are not the intended

recipient please delete it r rmeolately n ooa Lc j txk ASmakes no warranty as Lo ihe ao cy iteLeas f ahy a contained in this

message and hereby iz des any i for ccntalncad

therein or for the irf rirdtirrsssc r cene s use or sch r aty waywhatsoever Any opinions xrresseo it tnis issaoe are Lrc of tne author ane Hay notnecessarily reflect the opinions of garsan ba st

aab ma sBu epostanin iceaig ie re Oantzoimaksiz in ucencu kis cikaa ualn eodnek isoeo ki deglseniziutfen mesaji sister dera s cba AS bu resaii

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whatsoever Any opinions expressed in this message are those of the author and may notnecessarily refect the opinions of Barsan Global Lojistik AS

8

EXHIBIT 14



Leter With Business Card

Hem TURKISH

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t ink Translations provides professional translation services We have translated the attached documenttst titled

employing a team of pi ofessional and expel fenced translators who have a fluent knowledge of both languages

AS t Ci tvC the iinstated text for meaning accuracy and consistency with the angina wutce rink end vr proof woot ensIn ci test fo spelhnJand gianiniaticav accnac y

i radii sato s 11t 0 the best of our k riu edge ute 1ransla uon that ne hwe provded It on acc wait e and fart hto

icaigauun of the original text provides to us

State of New York

County of New York


ltd day of Tune 2011

impexia14 Hasbrouck Place

Rutherford NJ 07070 USA2016362802 T

2016362803 F

Dear Mr Aksu

Jimmy KaradaglispoaalPelacls 8Products Coordnalor

14 Hasbmua PI

Rutherford NJ 07010wwwmpexiausacwa

impexiaENEROY

Cell 1817 972 6682

Tel1201832802

Fax120116362602

Emel lkaradegb@lmpexlausa com

We have been using the warehouse of Barsan International at 1709 Zink Place FairLawn NJ 07410 as our logistic warehouse for the last one and a half month

We did not make an application to Barsan International to use this address and wesincerely apologize for this

Impexia Inc is not affiliated with Barsan International except for receiving warehouseservices The address of our headquarters on our website is updated as 14 HasbrouckPI Rutherford NJ 07070

I kindly request your attention for this matter

Cuneyt KaradagliPresident

SIGNATURE

Page 1

14 Hasbrouck PlaceRutherford NJ 07070 USA201 6362802 T

2016362803 F

Sayin Aksu

Barsan Internationail adresi 1709 Zink Place Fair Lawn NJ 07410 adresini lojistik depo amacli son bir bucuk aydirkullanmaktayiz Adresi kullanim icin Barsan Internationalsbasvurmadik ve bundan dolayi sizlerden ozur dileriz

lmpexia Incin Barsan International ile hic bir ilgisi ve alakasi yoktur depo hizmeti almanin disinda

Websitemizdeki adres degisikligi merkez ofrsimiz 14 Hasbrouck PI Rutherford NJ 07070 olarak guncellenmistir

Saygilariniza arzederim

Cuneyt KaradagliPresident

Page 1

Jimmy KaradagliSpcIa Ptgatls RPctlxis Coordinator

14 Hasbrouck PI

RuIwlad NJ 07070

mwrxnpmleuse pm

impexiaENERGY ENGINEERING FROJECIS

CWI 1 91107285621 2016384802

Fax12016362803

Em lmada0ImPodausa oam

EXHIBIT 15



Lck I nshltionspiovides professional translation services We have translated the attached clocumentstitled

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51 E ost 4 ra Seat Smte 1406 New York NY 1001

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www brit061slui


rd day of re 20

State of New York

County of New York

Jimmy Karadagli

From Jimmy Karadagli jkaradagli@impexiausacomSent Wednesday December 08 2010 1140 AMTo gulsenozdemir@emtainscomSubject Procurement from USA to Afghanistan Iraq Pakistan and TurkeyAttachments lmpexia Company Profiledocx

Dear Ms Gulsen

I saw your name on a website that followsup US federal bureaucratic procedures and wanted to write to youAs far as 1 understand previously you participated in a project in Afghanistan Impexia is a material supplier forconstruction companies that contracts with the US Department of Defense and the British Department ofDefense in construction projects in Afghanistan Iraq Pakistan and Turkey We supply materials from the USAas well as from the other parts of the world30 km close to New York ports we have a closed warehouse that extends to8000 m2 We store our

customers merchandises here and provide them with advantageous logistics and transportation price quotesfor destinations they needFor air transportations we work with DHL Global Forwarding and National Air Cargo while for ocean andinland freights we have advantageous contracts for regions we operate inAttached you may find our company profileYou can be assured that youll be provided most advantageous services if you give us the opportunity

Kind regards

Jimmy Cuneyt KaradagliSpecial Projects Products Coordinator1709 Zink Place Unitt5

Fair Lawn NJ 07410201 636 2802 T

201 636 2803 F

msn aol gmail jkaradagli Skype jimmy karadaglijkaradagli @impexiausa cornwww impexiausacom

nsclaimer This ema l and any files transmitted with it are confidential andintended for the use of the individual or entity to whom they areaddressed This communication may contain Information with may be privileged If you are not the Intended recipient you are advised thatyou have received this email In error and that any use dissemination forwarding printing or copying of this email Is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system Immediately Email may besusceptible to data corruption Interception and unauthorized amendment and no IIablltty is accepted for any such corruption Interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses It Is your responsibility to scan attachments ifany

Jimmy Karadagli

From Jimmy Karadagli jkaradagli@impexiausacomSent Wednesday December 08 2010 1140 AMTo gulsenozdemir@emtainscomSubject Procurement from USA to Afghanistan Irag Pakistan and TurkeyAttachments Impexia Company Profiledocx

Merhaba Gulsen Hanim

Isminizi US Federal islerin takibini yapan bir internet istesinde gorunce yazmak istedim Sanirim daha evvelAfghanistandabir projeye katkida bulunmussunuz

Impexia olarak Afganistan Irak Pakistan Turkiye bolgelerinde US Department of Defense ve British Department ofDefenseeis yapan ve kontratlarini alan insaat firmalarina ABDden ve dunyanin diger bolgelerinden her turlu malzemetedarigi yapiyoruz Bu bolgedeki musterilerimize is ve kontrat alabilmeleri icin oldukca rekabetci fiyatlar sunuyoruz NewYork limanlarina 30 kilometre yakinlikta 8000 metre karelik kapali depomuz var burada musterilerimizin malzemelerinidepolayabiliyoruz ve ihtiyac duyduklarinda ihtiyaci plan bolgelere cok avantajli lojistik ve nakliye fiyatlari veriyoruz Havenakliyede DHL Global Forwarding ve National Air Cargo deniz ve kara nakliyede de Barsan Global Logistik ile calistigimizbolgelere yonelik fiyat avantajli kontratlarimiz var

Ekte firmamizin profilini bulabilirsiniz

Bizlere firsat verirseniz sizlere ne kadar avantajli oldugumuzu gosterecegimizden kuskunuz olmasin

Kind regards

Jimmy Cuneyt Karadagli

Veda Projects Products Coordinator

impexia1709 Zink Place Unit5

Fair Lawn NJ 07410201 636 2802 T

201 636 2803 F

msn aol gmail jkaradagli Skype jimmy karadaglLkaradaolialmpexiausa cornwww impexiausa corn

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it Is your responsibility to scan attachments Ofany

EXHIBIT 16

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Link Translations provides professional translation services We have translated the attached dacumentstitled


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file od tec se tnmatocl text tw meaning accuracy and consistency with the original source text and we proofreadthe Iran aed text or spelling and grammatical accuracy

eehy er Illy that to me best of our knovclge the translation that we have provided is an accurate and faithfulrnvatoe Of tit Of Cjinal trxt provided o ors

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3 rd day of Jcce 011

Pu

SQUARED Panel TYPE QuantityQ0342MQ225RB 14

HCM 400A MCBTYPE4 3

HCR U 800A MCB TYPE 4 STAINLESSS 4


Jimmy Karadagli

From Niyazi BERBEROGLUnberberoglu@ceytuncomSent Thursday December 09 2010 706 AMTo jkaradagli@impexiausacomCc Galip Koper hasan kind sevket tuncSubject SQUARE D Electricity Equipment

Dear Mr CuneytWe received the introductionemail of your company and we would be pleased to work with you We are inthe urgent need of the SQUARED brand panels listed belowIll be waiting for the price quote and delivery time for this order

Thank you

Kind regards

Niyazi BerberogluCountry General ManagerCeytun Construction

Ctnnah Caddesi Kuskondu SokakANKARA TURKEY

Phone 90 312 438 14 14

Fax 90 312 438 13 14

Nlobilc 90 532 45616501r a 93 0 65 99 88 fyi 93 799 84 84 2 fgrau cn tun cum

Please consider the environment before printing thisemail

1

SQUARE0 Panel TYPE Quantity

Q0342MQ225RB 14

HCM 400A MCB TYPE4 3



Jimmy Karadagli

From Niyazi BERBEROGLUnberberoglu @ceytuncomSent Thursday December 09 2010 706 AMTo jkaradagli@impexiausacomCc Galip Koper hasan tune sevket tuncSubject SQUARE D Elektrik malzemeleri

Cuneyt bey

Sirketinizi tanitici mailinizi aldik ve sizinle calismak isteriz Bize Acil olarak asagida listesi olan SQUARED markalipanellerden lazimBu konudaki fiyat ve temin suresi teklifinizi bekliyoruzTesekkurler

Saygilar

Niyazi BerberogluCountry General Nl anagerCeytun ConstructionCinnah Caddesi Fuskondu SokakANKARA TURKEYPhone 90 312 138 14 14

Fax 90 312 438 13 14

Mobile 90 532 4561650 r 93 707 65 99 88 Afg 93 799 84 84 r Afwwo cc run corn

APlease consider the environment before printing thisemail

1



Linkrrafslations provides professional translation services We have translated the attached dacumentstitled


gSr

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ntltlo irrq a tva In tt notesSmal and expe Ienced ti nslaTOIsvho have a Omen knowledge of both la nyuages

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State of New York

County of New York


d day of June 2011

Jimmy Karadagl

From Niyazi BERBEROGLUnberberogluceytuncomSent Wednesday June 01 2011 1117 AMTo Jimmy KaradagliSubject FW Procurement from USA to Afghanistan Iraq Pakistan and TurkeyAttachments lmpexia Company Profiledocx

From Galip koper mailtogalipkoper@ceytuncomSent Thursday December 09 2010 220 PMTo Niyazi BERBEROGLU sevket tunc hasan tuncCc bulentturkyilmaz@ceytuncom fmucahid@ceytuncomSubject FW Procurement from USA to Afghanistan Iraq Pakistan and Turkey

I kindly request your attention for this matter

RegardsGalip Koper

CEYTUN INSOTONAKSAN VE TICLTDTICinnah Cad Kukondu sok No74 tiankaya Ankara TURKEYTel 0090312 4381414 Fax0090312 4381314 email galipkoper@ceytuncom

Impexia is a material supplier for construction companies that contracts with the US Department of Defenseand the 8h6sh Department of Defense in construction projects in Afghanistan Iraq Pakistan and Turkey Wesupply materials from the USA as well as from the other parts of the world

30 km close to New York pros we have a closed warehouse that extends to 8000 m2 We store ourcustomers merchandises here and provide them with advantageous logistics and transportation price quotesfor destinations they need

For air transportations we work with DHL Global Forwarding and National Air Cargo while for ocean andinland freights we have advantageous contracts for regions we operate in

1

Attached you may find our company profileYou can be assured that youll be provided most advantageous services if you give us the opportunity

Kind regards

Jimmy Cuneyt KaradagliSpecial Projects Products Coordinator1709 Zink Place Unit5

Fair Lawn NJ 07410201 636 2802 T

201 6362803 F

msn aol gmall jkaradagli Skype jemmy karadagliJkaradagli@lmpexiausa comwww impexiausa com

Disclaimer This email and any film transmitted with it are confidential and intended for the use of the mdiwdual or entity to whom they arc addressed Ibis communication maycontain information which may be pnvded Ifyou are not the intended recipient you arc advised Na you have received M1sninail In error and that any use dissemination

forwarding priming or copying of this email is stnctly probibitod Ifyou received this email in error pleas contact dm sender and in any event delete the material from yourvstem immediately Email may be susceptible to data corruption mtercoptren and unaudionaed amendment and no liability rs accepted for any such corruption interception or

amendment or the consequences thenof No liability or responsibility is accepted for vrrusa i is car responsibility to scan attachments d any

2

Jimmy Karadagli

From Niyazi BERBEROGLUnberberoglu@ceytuncomSent Wednesday June 01 2011 1117 AMTo Jimmy KaradagliSubject FW Procurement from USA to Afghanistan Irag Pakistan and TurkeyAttachments Impexia Company Profiledocx

From Galip koperfmailtogaliokoper@cevtuncomlSent Thursday December 09 2010 220 PMTo Niyazi BERBEROGLU sevket tunry hasan tuncCc bulentturkyilmaz@ceytuncomfmucahidceytuncomSubject FW Procurement from USA to Afghanistan Irag Pakistan and Turkey

Bilgilerinize sunarim

Saygilar Regards

Galip Koper

CEYTUN INSOTONAKSAN VETICLTDTI

Cinnah Cad Kuskondu sok No74 cankaya Ankara TURKEY

Tel 0090312 4381414 Fax0090312 4381314 email galipkoperPceytuncom

Impexia olarak Afganistan Irak Pakistan Turki e bolgelerinde US Department ofDefense ve British Department of Defense e isyapan ve koniratlarint alan insaat firmalanna IBDden re dunyanin digerbogelerinden her milli maeme tedarigi yapiyorur Bubolgedeki musterilerimire is ve kontrat alabilmeleri tcn oldukca rekabetcifiyadar sumyoru Aew fork limanlarina 30 kilometreyakinlikta 8000 metre karelik kapali depomu rar burada musterilerimicin maLemelerini depolayabiliyortr veiuiyac duyduklarindaihtiyaci olan bolgelere cok arantajli lojistik ve nakliye fiyadari reriyorir Hara nakliyede DHL Global Forwarding ve National AirCargo Beni ve kara nakliyede de Barsan Global Logistik ilecnlistigimir bolgelere yonelik ftyat avantajli kontratlarimir var

1

Ekte firmamizin profilini bulabilirsiniz

Bizlere firsat verirseniz sizlere ne kadar avantajli oldugumuzu gosterecegimizden kuskunuz olmasin

Kind regards

Jimmy Cuneyt Karadagli

Special Projects Products Coordinator

17 09 Zink Place Umt5

Fair Lawn NJ 07410

201 636 2802 1

201 636 2803 F

msn aol gmail Jkaradagli Skype Jimmy karadagli

karadaplikdimoexiausa com

www imneeiausa com

Disclaimer This email and any tiles transmitted eNt it are confidential and intended for the use ofthe individual or entity to whom they are addressed This communication maycontain information which may be pm deged I Cy ou are not the intended recipient you are advised that you have received this ennui in error and that any use disseminationfonvaiduig printing or copying Thhu email is sincih prohibited Ifyou recen ed this entail in error please contact the sender and in any ekenl delete the material from yoursystem munediately Email may be susceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No habil its or responsibility is accepted fort cruses n is your responsibility to scan attachments Of any

2

EXHIBIT 17

Jimmy Karadagli

From Jimmy Karadagli jjkaradagli@impexiausacomjSent Tuesday January 18 2011 247 PMTo metag@metagtrcomSubject Procurement and Logistic from USA to Afghanistan Iraq Pakistan and TurkeyAttachments Impexia Company Profiledocx

Merhabalar

Im one of the managing partners of Impexia We found your name on a website that provides the name of the companieshave done jobs for the US DoD

As Impexia we have been procuring to US federal state and local government agencies We also procure mainly fromUSA and as well as around the worldcustomer specific materials for our construction engineering food logistics servicecompanies that work with US Department of Defense and British Department of Defense in Afghanistan Iraq Pakistanand Turkey We give very aggressive and advantageous prices to our customers in those regions so that they can submitcompetitive prices for contracts and bids

We know how difficult to move something from one place to another so haventsaid that you dont have to worry onforwarding your materials all around We store our customers materials in our warehouse located to eastern ports of theUS so that whenever they need something its ready in our warehouse We ship it for them with very aggressive freightcosts logistic wiseshipping wise Since we have contracts with DHL Global Forwarding Express National Air CargoDSV Forwarding to those geographies were able to quote very aggressively time wisefinancial wise

Attached you can see our company profile

We will look forward to seeing an opportunity so that we can prove our self being of service to you

Kind regards

Jimmy Cuneyt KaradagliSpecial Projects Products Coordinator

Impexia1709 Zink Place Unit5

Fair Lawn NJ 07410

201 636 2802 T

201 636 2803 F

msn aol gmait Jkaradagli Skype Jimmy KaradagliJkaradaglic impexiausa comwww impexiausa com


1

EXHIBIT 18

TO WHOM THIS MAY CONCERNSTATEMENT CERTIFYING PROFESSIONAL TRANSLATION

VnkTranslati provides professional translation services We have translated the attached documentstitled

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Nuuiy Publ c

Jimmy KaradagliFrom Niyazi Berberoglu mailtoniyaziberberoglu @ceytuncomSent Saturday February 05 2011 1112 PMTo Jimmy KaradagliCc turgaygokdas@metagcomtrTayfun KayasSubject Introduction email for Metag company representatives

JimmyI CC this mail also to Tayfun Kayas METAG Company Regional General Manager and Turgay Gokdas head ofElectricity Department in order to introduce them to you They will correspond with you upon my advice inrelation to the procurement from the United States Im sure you will show the required assistance on thismatter

Thank you very much in advance

Kind Regards

Niyazi BerberogluCountry General ManagerCeytun ConstructionCinnah Caddcsi Kuskondu SokakANKARA TURKEY

Phone 90 312 438 14 14

Fax 90 312 438 13 14

Mobile 90 532 45616501r93 707 65 99 88 fP 93 799 84 84 27 fIJ

IailScanner Ibis detected a possible fraud anemia from w nwepilcomlrclaiming to be wwcc tun coin


Jimmy Karadagl

From Niyazi Berberoglu niyaziberberoglu@ceytuncomSent Saturday February 05 2011 1112 PMTo Jimmy KaradagliCc turgaygokdas@metagcomtrTayfun KayasSubject Metag Sirketi yetkilileri ile tanistirma

Jimmy

Sizinle tanistirmak amaci ile METAG sirketi Bolge Genel Muduru Tayfun Kayas ve Elektrik islerinden sorumlu TurgayGokdas bu mailimde CC deter ve Amerikadan malzeme alimlarinda benim taysiyem ile sizinle yazisacaklar gerekenyardimi yapacagindan eminimSimdiden tesekkurler

Saygilar

Niyazi BerberogluCountry General ManagerCeytuu ConstructionCinnah Caddesi Kuskondu SokakANKARA TURKEYPhone 90 312 438 14 14Fax 90 312 438 13 14

Mobile 90 532 4561650Tr 93 707 65 99 88 Afg 9399 84 84 27 AfgVWW cemin com

APlease consider the environment before printing thise

1

EXHIBIT 19

Air S ear 5no 1406 New Yuck NY 100

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TO WHOM THIS MAY CONCERNSTATEMENT CERTIFYING PROFESSIONAL TRANSLATION

ink translations provides professional translation services We havetranslated the attached documentstitled

TURKISH

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MARY L31 IC STALL 0 N4v YORK

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State of New York

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3 rd day of Jne 2011

Notary Public

Jimmy KaradagliFrom Guney GUNER guneyguner@metagcomtrSent Tuesday February 22 2011 521 AMTo jaradagli@impexiausacomCc tayfunkayas@metagcomtrturgaySubject About Camp Dwyer Flood light Price quoteAttachments Flood Light Camp Dwyerjpg

Dear Mr Jimmy Karadagli

I got your contact information from our General Manager As you may know METAG AS is a prime contractorthat undertakes particularly Afghanistan USACE projects

We wish to cooperate with you in our operations The products that you may see in the attachment are GEbrand How can we organize the procurement of these products from the US in fast and economic mannerAfter the procurement we are able to transfer the merchandise directly to Kandahar by DHL

Ill be waiting for your price quote and delivery time in relation to these products Thank you for yourcooperation

Kind Regards

Guney GunerCivil Engineer

From Tayfun Kayas mailto tayfunkayas@metagcomtrSent Sunday February 06 2011 636 PMTo Guney GONERSubject FW Attention RE Introduction email for Metag company representatives

From Jimmy Karadagli mailto Iaradagli @impexiausacomSent Sunday 06 February 2011 1536To Niyazi BerberogluCc turgaygokdas@metagcomtrTayfun KayasSubject Attention RE Introduction email for Metag company representatives

Dear Mr Niyazi

Of course we are ready to do whatever we can You know our working standards and the services weprovide We are confident that we will work effectively with Mr Tayfun and Mr Turgay too

Mr Tayfun and Mr TurgayAttached you may also find our company profile It would be great if you take a look when you have timeThere you may find a detailed explanation of the services that we can provide for you

No matter whether it is a minor or major request you can always contact us for your needs We are lookingforward to hearing from you

Kind regardsJimmy KaradagliSpecial Projects Products Coordinator

1709 Zink Place Unit5Fair Lawn NJ 074102016362802 T201 636 2803 F

msn aol gmall jkaradagli Skype jimmy karadaglijkaradagli@impexiausacomwwwlmpexiausacom

Disclaimer This email and any files transmitted with It are confidential and Intended for the use of the Individual or entity to whom they areaddressed This communication may contain Information which may be privileged If you are not the intended redolent you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email is stnctly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system Immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it Is your responsibility to scan attachments ifany

From Niyazi Berberoglu mailtoniyaziberberoglu @ceytuncomSent Saturday February 05 2011 1112 PMTo Jimmy KaradagliCc turgaygokdas@metagcomtrTayfun KayasSubject Introduction email for Metag company representatives

JimmyI CC this mail also to Tayfun Kayas METAG Company Regional General Manager and Turgay Gokdas head ofElectricity Department in order to introduce them to you They will correspond with you upon my advice inrelation to the procurement from the United States Im sure you will show the required assistance on thismatter

Thank you very much in advance

Kind Regards

Niyazi BerberogluCounty General Managere tun ConstructionClnnah Caddcsi Kuskondu SokakANKARA TURKEY

Phone 90 312 438 14 14

Fax 90 312 438 13 14

Mobile 90 532 4561650fir 93 0 65 99 88 f 93 99 84 84 2T f

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Jimmy Karadagli

From Guney GONER guneyguner@metagcomtrSent Tuesday February 22 2011 521 AMTo jkaradagli@impexiausacomCc tayfunkayas@metagcomtrturgaySubject Camp Dwyer Flood light Fiyat Talebi HkAttachments Flood Light Camp Dwyerjpg

Sayln Jimmy Karadagli

Iletisim bilgilerinizi Gene Mudurumuzden aldim Bildiginiz gibi METAG AS olarak Afganistan USACE agirllkll projelerdeana muteahhit olarak faaliyetteyiz

Bu kapsamda sizinde desteginizi alarak yolumuza devam etmek arzusundayiz

Ekte gbreceginiz Dronler GE marka Bunlan Amerikadan hilzi ve uygun fiyatll bir sekilde nasll organize ederiz Tedariksurecinden sonra DHL ile direkt Kandaharasevkiyat yapabiliyoruz

Konu ile ilgili teslim saresinide belirten fiyat teklifinizi bekler yardimlariniz i9in simdiden tesekk0r ederim

Saygilarimia

Guney Guner

Insaat Mohendisi

From Tayfun Kayas mailto tayfunkayas@metagcomtrSent Sunday February 06 2011 636 PMTo Guney GONERSubject FW Dikkat RE Metag Sirketi yetkilileri ile tanistirma

From Jimmy Karadagli mailto jkaradagli@impexiausacomSent Sunday 06 February 2011 1536To Niyazi BerberogluCc turgaygokdas@metagcomtrTayfun KayasSubject Dikkat RE Metag Sirketi yetkilileri ile tanistirma

Niyazi Bey merhaba

Tabiiki elimizden ne geliyorsa yapmaya haziriz Siz bizim calisma standardimizi ve yapabilecegimiz servis olanaklarinibiliyorsunuz Eminim Tayfun Bey ve Turgay Beylede iyi calismalar yapacagimizdan eminiz

Tayfun Bey Turgay Bey

Ekte sirket profilimizide bulabilirsiniz firsatiniz oldugunda inceleyebilirseniz buradan size sunabilecegimiz servisin genisaciklamasini yapmakta

Buyuk kucuk fark etmez her turlu ihtiyacinizda bizlere basvurabilirsiniz Haberlerinizi bekliyoruz

Kind regards


1

impexia1709 Zink Place Unit5

Fair Lawn NJ 07410201 6362802 T

2016362803 F

msn aol gmail jkaradagli Skype jimmykaradaglijkaradaaliWimpexiausa comwwwlmpexiausacom


From Niyazi Berberoglu mailtoniyaziberberoglu @ceytuncomSent Saturday February 05 2011 1112 PMTo Jimmy KaradagliCc turgaygokdas@metagcomtrTayfun KayasSubject Metag Sirketi yetkilileri ile tanistirma

Jimmy

Sizinle tanistirmak amaci ile METAG sirketi Bolge Genel Muduru Tayfun Kayas ve Elektrik islerinden sorumlu TurgayGokdas bu mailimde CC deler ve Amerikadan malzeme alimlarinda benim taysiyem ile sizinle yazisacaklar gerekenyardimi yapacagindan eminimSimdiden tesekkurler

Saygilar

Niyazi BerberogluCountry General ManagerCevtnn ConstructionCinnnh Caddesi Kuskundu SukakANKARA TURKEYPhone 90 312 438 14 11

Fax 90 312 438 13 14

Mobile 90 532 4561650Tr 93 70 65 99 88 Afg 93 99 84 84 27 Afg111Sguer hq dctettesi 1 isi Jdr 11lud snrrljv tram taco lJjikCynl trI Turning L lic vw Learn corn

APlease consider the environment before printing thisemail

Bu mesas err cklenlun LeeNlgi Mi Anne ocl se gvl idly Bu bi ederi al kaged den ahn degdsenu bu bdgileri okammnali kuliaimamal1 4m 1 dagmnamalunnz tigerbu 1 esai ve a eklen anhshkla elms e gccnu be Int fen hemen unila edinv e 911 12 I 7731 tunalal Idlelonu araarak brie haber s erIn1 6ondencl bu ra veyaeklel lode elektronik puua aktariini IIasema inesdana erica hata se ekIkllklerc s e ciektionik poste aktan role gu mhgone dart hlcbu sot umluluk kabul eilnemekiedirGondrier bu leis se eklenndetsmn11s 0labdcce virus ses a beaten Tarah kodlaadair hicbir sorumiuluk kabul etmcincktedir1 he infounatron 111 this email is confidential and meant Mr the use oldie Intended recipients only 1 fy on are not the Intended recipient you oust not read use of disseminate thatInformation If sou lase leeched this entail in el rob please noun us at 31 42 731 and destroy it Immediately the sender does not accept hairdos for an errors oromissions that may hae occurred during the transmission of this email and to anachinent or the securav of such transmission 1 he sender accepts no 1 ahlllts 101 any viruses andother harmful code that leas he transmmcd bs this email

1311 mesas l eya eklei inln icerdIJ 111 gI di 1 i i oM e Cizln Bu brig heel Amato katedilen al ICI degllse z bu 1 1g1Itn oklnnalnall kul1annuatnal seya dagitma1nal 1511117 Egerbi mesas C35 ek lee ant nl i Ala eluvc ecnP1 1d tune remelt India ed nv se 91 312 112 31 numaral1 telefonu aras aiuk brie babel crinv londen el bu mesa veyaeklennde elekr onik pasta nkml 11111 esnaslnda lees dana gel en Irma se ekakl1s1cie se a clek110111k pasta aktanmino Uheslgule dun hicbir sorinnluiuk kabul etmenlektedirUondericl bu mesa e eklcrunlc to mmn orabdere Iris s esa benzei raised kudlara dair Iueblr soruulhduk kabul elnienleklee rfltc information in this email is confidential and meant for the se or the intended Ice0lenls onis if you are not the intended tecipicm you must not lead use or dusemmate that

Information Ifyou have recehdd this snail in error please notify us at 90 312 472 7731 and destroy it immediately The sender does not accept liability for any errors oromissions that may have occurred during the liasrnssion of this email and its attachments or the security ofsuch transmission The sender accepts no liability for any viruses andother harmful code that may be transmitted by this email

2

EXHIBIT 20

04800208KV 100KVA STEP DOWN TRANSFORMER EA

04800208KV 160KVA STEP DOWN TRANSFORMER EA

1000KVA 13804kV PAD MOUNTED TRANSFORMER EA

800KVA 13804kV PAD MOUNTED TRANSFORMER EA

Jimmy Karadagli

From Oktay Kasimoglu oktaykasimoglumetagcomtrSent Tuesday February 22 2011 750 AMTo Jimmy KaradagliAttachments E05pdf

Dear Mr KaradagliI get your email address from Mr Guney Hopefully you are fineFor our new project in Bagram Afghanistan see attached dwg the quantities and the specifications are blow

And 4 piece ring main unit which was shown in the drawingWould you please give your offer in a very short timeBest regards

Oktay Kasimoglu

1

EXHIBIT 21

fur TURKISH

nt ENGLISH

COO sperdencs

57 fora 49rd Sneer Suto 146 Nu York NY tOJ1

188657 tIMK 154051 i Tattlrirvarsiai ails u



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cnrHOY inq s team or professional and experienced translator s who have a fluen knowledge of both languages

Vr 4e 4vd text lr meaning accuracy and consistency with the ongrna i 50 urc e text and we proofread

P franated text ror spelling and grammaticid acrurdry

chy ertdj In ta tile 1C1 Of our know edne the transdUOn that we have prey rded is an accurate and fe t hfulrraarr of the original text provided to u

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IAAAN Al KAN

NOTrR1 U BUC STATE Of NEW YORK

OUAL FIEUill OfWrYORKCOUNTY

IC 70116217991

COMM1SSICiORES02222014

State of New York

County of New York

SWORN TO BEFORE NW THS

3rd dayof cr

otary Publkt

Jimmy KaradagliFrom Omercan Kayhan okayhan@77constructioncomSent Thursday November 18 2010 1151 PMTo Jimmy KaradagliSubject RE URGENT RE RFQ W5K9FH11 T0040

Brother

Lets give order for 6 units Other 4 units will become certain on Nov 23

Omercan KAYHAN

Business Development ManagerLeatherneckBastion AFGHANISTAN

Phone 0093703578053

www77constructioncom

integrity is what we do what we say and what we say we do

From Jimmy Karadagli mailto jkaradagli impexiausacomSent Friday November 19 2010 130 AMTo Omercan KayhanSubject URGENT RE RFQ W5K9FH 11T0040

Hi Omer

The Kalkavans have one ship tomorrow but it is impossible to catch it because we cant get finished untilthen Next week they skip because of the Thanksgiving So the first departure is on Dec 1

They said the production of the overhead doors would take 23 weeks But I begged them and made themconfirm that they will deliver the goods to the warehouse until Nov 30 But I have to send the deposittomorrow to have the production started If you confirm I can send them some money on your behalf Thuswe will be able to catch the Kalkavans fast ship 3 weeks departing on December 1

The production of custom made metal personnel doors takes 710 days So these will also be delivered tothe warehouse until November 30 and will be loaded

Ill send the proposals to you in another mail But you should confirm the order tomorrow in order to start theproduction of overhead doors as they have the longest production time

Kind regardsJimmy KaradagliSpecial Projects 8 Products Coordinator

1

1709 Zink Place Unit

Fair Lawn NJ 074102016362802 T

201636 2803 F9179726562 C

jkaradagli@impexiausa cornwwwimpexlausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be pmIleged If you are not the intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email is strictly prohibited If youreceived this email in error please contact the sender and in any event delete the material from your system Immediately Email may besusceptible to data corruption interception and unauthonzed amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments Ofany

From Omercan Kayhan mailto okayhan@77constructioncomSent Thursday November 18 2010 1036 AMTo jkaradagli @impexiausacomSubject FW RFQ W5K9FH 11T0040

Omercan KAYHAN

Business Development ManagerLeatherneckBastion AFGHANISTAN

Phone 00 93 703 578053


Integritjt is It hat vi do Shat str Nay and 11 hat 11e a1 Rc du

From Walden Maj Kenneth R RCSW RCC Contracting Officer mailtokennethwalden@afgusmcmilSent Thursday November 18 2010 733 PMTo Walden Maj Kenneth R RCSW RCC Contracting OfficerSubject RFQ W5K9FH 11T0040

This email is a Request for Quotation RFQ submitted to multiple vendors Please reference the attachedRFQ for details All quotes should be submitted via email by 1600 local time 21 November 2010 tokennethwalden@afgusmcmil

RS

Major Kenneth Walden

United States Marine Corps

2

Contingency Contracting OfficerRegional Contracting Center Leatherneck AfghanistanFPO AE 09372

DSN 3183576749

Cell93703742319

kennethwalden@afgusmcmilThis is my rifle There are many like it but this one is MINE My rifle is my best friend It is my life I must master it as 1 must master my life

3

Jimmy Karadagli

From Omercan Kayhan okayhan77constructioncomSent Thursday November 18 2010 1151 PMTo Jimmy KaradagliSubject RE ACIL ACIL RE RFQ W5K9FH11 T0040

Kardes6 adet icin dugmeye basalim 4 adet icinde 23 Kasinda netlesecek

Omercan KAYHAN

Business Development Manager

LeatherneckBastion AFGHANISTAN

Phone 0093703578053

77 CONSTRUCTIONContracting Trading Co


Integrity is what we do what we say and what we say we do

From Jimmy Karadagli fmailtoikaradaoliimpexiausacomSent Friday November 19 2010 130 AMTo Omercan KayhanSubject ACIL ACIL RE RFQ W5K9FH11T0040

Omer selam

Kalkavanlarin gems yarin bir tane var fakat imkansiz yetistirmemiz Haftaya skip yapiyor thanksgivingden dolayi busebepten ilk cikis 1 Aralik

Overhead doorlar icin uretimi 23 hafta diyorlar fakat adamlara yakardim yakardim 30 Kasimakadar benimdepoya sokacaklarina dair teyid aldim tabi yarin deposit gonderip uretime baslatirsam sart sen onay verirsenberm bir kisim gonderme imkanim olur adamlara Boylelikle 1 Araliktaki Kalkavanlarin hizli giden 3 haftagemiyi yakalayabilecegiz

Custom made metal personnel doorlar icin uretim 710 gun arasi bunlarda 30 Kasimda depoya giris yapipkonteynera yuklenebilecek

Bu konuda teklifleri gecicem biraz sonra sana ama muhakkak yarin teyid gec banaki overhead doorlarin uretiminegecilsin cunku en uzun uretim onlarda

Kind regards


1

a

17 09 Zink Place Unitf3

Fair Lawn NJ 074102016362802 T2016362803 F

9179726562 C

jkaradaglicimoexiausacomwwwinmexiausacom

Disclaimer This email and any files transmitted with it are confidential and intended for the use of the individual or entity to whom they areaddressed This communication may contain information which may be privileged If you are not the intended recipient you are advised thatyou have received this email in error and that any use dissemination forwarding printing or copying of this email is strictly prohibited If youreceived this email In error please contact the sender and in any event delete the material from your system immediately Email may besusceptible to data corruption interception and unauthorized amendment and no liability is accepted for any such corruption interception oramendment or the consequences thereof No liability or responsibility is accepted for viruses it is your responsibility to scan attachments ifany

From Omercan Kayhan Jmailtookavhan77constructioncomlSent Thursday November 18 2010 1036 AMTo ikaradacilifimpexiausacom

Subject FW RFQ W5K9FH11T0040

Omercan KAYHAN

Business Development Manager

LeatherneckBastion AFGHANISTAN

Phone 0093703578053

77 CONSTRUCTIONContracting Trading Co


Integrity is what we do what we say and what we say we do

From Walden Maj Kenneth R RCSW RCC Contracting Officer fmailtokennethwaldenafqusmcmillSent Thursday November 18 2010 733 PMTo Walden Maj Kenneth R RCSW RCC Contracting OfficerSubject RFQ W5K9FH 11T0040

This email is a Request for Quotation RFQ submitted to multiple vendors Please reference the attached RFQ fordetails All quotes should be submitted via email by 1600 local time 21 November 2010 tokennethwalden@afeusmcmil

RS

Major Kenneth WaldenUnited States Marine Corps

2

Contingency Contracting Officer

Regional Contracting Center Leatherneck AfghanistanFPO AE 09372

DSN3183576749

Cell93703742319

kennethwaldenlEafgusmcmilThis is my rifle There are many like it but this one is MINE My rifle is my best friend It is my life I must master it as I must master my life

EXHIBIT B

IMPEXIA COMPANY PROFILE

Impela14 Hasbrouck Place Rutherford NJ 07070Tel 201 6362802 Fax 201 6362803www impexiausa corn

We feel great pleasure in introducing ourselves as one of the leading indenting house in the US We arebuyer and seller of complete industrial products including ferrous and non ferrous metals in all shapesand sizes earth moving workshop machinery machine tools pumps compressors generatorsturbines boilers soot blowers bumers IT Communication food and food related products militarysupplies living essentials and spare parts for any application

Overview

Begun on the proverbial back of the napkin Impexia has now spread its wings over many nationsbalancing itself on the cutting edge of change while embracing the traditional approach of integrity andtrust

The burning torch of humanity combined with good business sense is the vessel that has broughtImpexia to even supply the needs of high risk prone war zones such as Iraq and Afghanistan At everystep of the way towards success the essence has always been a service satisfied and a smilingcustomer as our backing

Our primary focus area

Procurement

Engineering Products Building Materials Military Supplies Metals Commodities Life EssentialsMedical Supplies Food Food Products Computer Hardware Clenzoil Field and Range

Our Mission

Our mission is to be your service provider of choice Our core values Quality Integrity Trust gohand with our passionate zeal to be your final answer to dependable quality

Imagination that captures the world is not just a fancy tag line It is the way we think the way we act theway we live for ourselves for our customers and for the world at large

New challenges New opportunities New initiatives In todayseconomic environment More and morepeople are finding themselves in the position of planning their own financial futures

Modern products need to be structured to satisfy these individual needs Businesses are becoming moreadept at seizing new opportunities driven by technological innovation

As we face competing in an ever tougher arena our desire to be a leader in the procurement sector canonly be achieved by continuing to meet complex challenges Delivering strong performance for ourclients Attracting the best talents Behaving responsibly towards the environment and the community inwhich we operate Constantly investing in core businesses and technology to achieve greaterperformance Maintaining strategic momentum and our track record

Our Vision

There is a renewed sense of excitement across Impexia as we reflect upon our past and look expectantlytowards our future We have come a long way from our startup days but we continue to be nimble andresponsive We aim to continue our rapid growth and are within striking distance of the megasized visionwe had set for ourselves As we move surefooted towards becoming a truly Global Trading Co we smellthe compelling call of success

Couple of years ago we dared to dream of an lmpexia that would become a versatile companyEmboldened by success and seasoned by our journey from the developing markets to an internationalarena we are setting the score for our next symphony We believe that by the end of this decade we willtake our place as one of the reputable procurement company in our market Proprietary products andservices will give momentum to future growth while our core business will keep the rhythm

Even as we savor the performance of the present excitement and anticipation punctuate our preparationfor the future Identifying new competencies to build and gaps to bridge we will ensure another winningscore

PROCUREMENT

Overview

Founded as a trading company and honing the skill for a half decade were improving the way companiesdo business across borders

If you can name it we can get it for you Our buyers have tentacles that reach around the world and intoalmost every class of goods products and supplies We build lasting relationships with our suppliers andvendors so you benefit on every purchase Specializing in Living Essentials we pride ourselves in thebroad capacity that is able to turn a desert land into a fully functional campsite in 30 days We haveperfected the art of sourcing the best and in the most efficient manner This is a boast borne out of nearlya half decade of dealing with the most demanding of environments

The goal is to make it easier for customers to transact business and manage their global supply chains

Products

Construction

Building Materials

Steel

Hardware Tools

Plumbing Fixtures

Hardware Electrical Equipment

Earthmoving Machinery wheel loaders bulldozers dump trucks

Armored Vehicles

Electric ApplianceGoodsEquipment

Filters Oil FiltersAir Filters etc Gaskets

Hydraulic Hose Fittings

Fuel Tankers Water Tankers

Military Supplies

ClenzoilGun Lubrication and Protection

Tents

Vests

Sleeping Bags

Combat Boots

Commando Knives

Thermal Wear Fleece Jackets Socks

Disaster Relief

Tents Blankets

Water Cans

Mattresses

Bunk Beds

IT Communication Equipments

Computer Supplies Accessories

Mobile Phones Satellite Phones with Prepaid Cards and Lines

Cable CoaxialSplicing

Electronic Spare parts

Living Essentials

PreFabricated ModularHousingOffice Units

Air Conditioning Equipment

Office Furniture

Tower Lights

Desalination Plantsfor both brackish water and sea water

Diesel Generators all sizes

StandAlone FreezersReefer Units 40ft for Lease Sale

Lumber Plywood Cut Pieces

Kitchen Equipments Supplies

Cleaning Materials Janitorial Services

Food and Food Associated Products

Food Beverage

Fresh Frozen Dry Chilled Food Supplies from Approved Sources

Bottled Drinking Water Mineral Packaged

Disposables Plastic Paper

Industries

Power Generation Industry

Food Industry

Military Industry

Petrochemical Industry

Mining Exploration Industry

Iron Steel Industry

Heavy Construction Industry