SUGDEN, McFEE & ROOS

Barristers and Solicitors

200 –375 Water Street
Vancouver, BC
V6B 5C6

For the attention of Mr. PATRICK LEWIS

Tel: 604-687-7700
Fax: 604-687-5596

March 15th, 2001

Civil Action: Kapoustin v. Republic of Bulgaria et al

In the Supreme Court of British Columbia,
Vancouver Registry Case No. S004040
And

Civil Action: LifeChoice et al v. Republic of Bulgaria et al

In the Supreme Court of British Columbia
Vancouver Registry Case No. S005440
Class Action Certification Pending

Ref: Service, Notice of Motion

Rule 65

Dear Mr. Lewis,

Be advised that I am attorney for the Plaintiffs in the Republic of Bulgaria and will be filing on
behalf of my clients an affidavit. As well I will be seeking one time admission to your Law Society
and the Court to appear, together with a colleague from Canada, in the above captioned civil cases
as an expert on Bulgarian law.

Your consent to the extension of time requested by my clients would considered a profession
courtesy and will give an opportunity to my client Michael Kapoustin prepare his materials,
because the conditions in Sofia Central Prison do nor allow him work in the way he might do it in
case he was free. His access to documents is limited an there are restrictions in his time for contacts
with his lawyers as well.

Because of the distance between me and my other clients living abroad time is also necessary to
maintain contacts between ourselves.

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I consider that the Plaintiffs who are Bulgarian residents experience difficulties because of the
distance, lack of knowledge of the English language and of your legal system. Therefore they need
more time to react.

Furthermore you should take into consideration the circumstance that the Bulgarian Plaintiffs and
my client Michael Kapoustin have financial difficulties because throughout all this period of
detention of my client Michael Kapoustin company LifeChoice International - AD, with which the
Bulgarian Plaintiffs have made their investments, in practice does not have any activities and does
not bring any proceeds to its owners and investors. This also is an obstacle for their ability to react
in due time.

Yours truly,

Anatol - Vesel Lukanov

Attorney at Law

Cc: Defendant Republic of Bulgaria Chief Judge

Respondent Ministry of Justice S Provincial Court of British Columbia
1, Slavianska St. Suite 501 – 700 West Georgia Street
1040, Sofia Vancouver, British Columbia
Bulgaria Canada

Mr. Gar Pardy Other Parties of Record

Director General
JPD Consular Affairs Bureau
Department of Foreign Affairs and International Trade
Lester B. Pearson Building
Tower B3
125 Sussex Drive
Ottawa, Ontario K1A 0G2
Canada

For the veracity of translation:

Marianna Radoulova
Sworn translator

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