Anatol To Mr. Lewis - 031601

SUGDEN, McFEE & ROOS Barristers and Solicitors 200 –375 Water Street Vancouver, BC V6B 5C6 For the attention of Mr. PATRICK LEWIS Tel: Fax:

604-687-7700 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 Respondent Ministry of Justice S 1, Slavianska St. 1040, Sofia Bulgaria

Chief Judge Provincial Court of British Columbia Suite 501 – 700 West Georgia Street Vancouver, British Columbia 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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