NOTICE OF ATTILA DOGAN CONSTRUCTION AND INSTALLATION CO. TO THE SULTANATE OF OMAN

22 March 2013

This letter constitutes formal notice, under Article 9 of the Agreement between the Government of the Republic of Turkey and The Government of the Sultanate of Oman Concerning the Reciprocal Promotion and Protection ofInvestments (hereinafter the "BIT"), that a Dispute exists between the qualifying BIT Investor, Attila Dogan Construction and Installation Co. Inc. ("AD") and the Sultanate of Oman ("Oman"). AD is an Investor within the definitions contained in Article 1 of the BIT, thereby qualifying for protections afforded under Article 9 of the same. Please note that this Dispute arises out of and relates to the treatment accorded to AD by Oman in breach of its treaty obligations under the BIT as well as Oman's derogation from customary international law, which treatment has caused AD to sufler harm and damages.

I. Statement of Relevant Facts

For the reasons, and as detailed below, AD notifies Oman of harm and damages amounting to not less than USD $182,763 ,000.00 exclusive of interest, consequential losses, moral damages and legal fees and costs, as a consequence of Oman's breach of the BIT and customary international law. As explained further herein, Oman, acting via and through a number of its agencies, sought systematically to deprive, and ultimately did take and deprive AD of its Investment comprising the Off Plot Delivery Contract C3l1162 North as well as all receivables related to the work arising out of that contract.