SETTLED ISSUES FOR HEARING

FERDINAND SAMUEL

International Arbitrators Inc.

C/O Sonnenalp Resort

20 Vail Road

Abuja, Nigeria

Our Ref: NIG/ 09/2015 Your Ref…………………………………………

19th July 2015.

To:

• Norman Adebayo Tunde SAN, Dike & Atere,

Abuja, Nigeria

(Counsel for Owari Unlimited)

• Bill Troutman, Esq., Fenwick, Sage & Hardy, P.C., U.S.A.

(Counsel for Great North Leathers Ltd.)

Dear Sirs,

IN THE MATTER OF THE ARBITRATION CONCILIATION RULES and

IN THE MATTER OF AN ARBITRATION BETWEEN

OWARI UNLIMITED (CLAIMANT)

– and -

GREAT NORTH LEATHERS LTD (RESPONDENT)

Flowing from the pleadings of the Claimant deduced from its Notice of Arbitration and the Defence and Counterclaim filed by the Respondent, the following issues are hereby settled for hearing:

• A determination whether or not this Arbitrator has jurisdiction over this Arbitration considering the Arbitration Agreement
• Whether or not the Arbitration Agreement is no longer in force
• Whether or not Arbitration Clause is void for any reason whatsoever
• Whether or not the Respondent owes Claimant for any of the garments shipped to Respondent from August 2015 through November 2015?
• Whether the garments shipped during the period stated above were made of Gnu hides, as ordered and required under the contract,
• Whether or not the Claimant is required under the contract to notify and obtain the approval of Respondent prior to substituting garments made of animal hides.
• Whether or not the Claimant did notify or obtain the approval of Respondent prior to substituting garments made of Hartebeest hides for Respondents' order of garments made of Gnu hides
• Whether or not the Claimant breaches a material term of Arbitration of 5 October 2011, as a result of the above considerations
• Whether or not the Respondent was justified in terminating said Agreement; and

10.If the above is proved, whether or not the Respondent was not required to provide Claimant time to cure Claimant's breach under the terms of the Agreement.

Parties would be expected to furnish the following documents as necessary evidence in resolving the issues: