A. INTRODUCTION

1. I am Anton Vladimirovich Asoskov, doctor of law, Professor of the International Private Law Department at the Russian School of Private Law and Assistant Professor of the Civil Law Department at M.V. Lomonosov Moscow State University. The areas of my academic interests are Russian civil law and international private law. I am a member of the working group organized under the auspices of the President’s Council on Codification of Civil Legislation and participated in drafting the Development Concept for Civil Legislation of the Russian Federation and the preparation of draft amendments to the Civil Code of the Russian Federation (Section VI “International Private Law”). I am an Arbitrator of the International Commercial Arbitration Court at the Chamber of Commerce and Industry of the Russian Federation, and I also have experience as an arbitrator in proceedings under the Arbitration Rules of the International Chamber of Commerce (ICC) and the UNCITRAL Arbitration Rules. My concise curriculum vitae is attached as Appendix 1 to this report (the “Report”).

2. I have been asked by the law firm Cleary Gottlieb Steen & Hamilton LLP to prepare an expert opinion on certain issues of Russian law in connection with proceedings to set aside the arbitral awards issued in PCA Case Nos. AA226, AA227 and AA228, brought under the Energy Charter Treaty (the “ECT”). In particular, I have been asked to examine the following question under Russian law as of December 17, 1994, and its further development up to the date of this Report:

Does Russian law authorize or permit the arbitration of disputes concerning

(i) taxation measures; (ii) enforcement measures related to tax assessments; and

(iii) bankruptcy matters?

3. Section B sets forth my analysis of the question that I have been asked to address, followed by my conclusions in Section C.