Royal Dutch Shell Reserves Fraud Litigation

ROYAL DUTCH SHELL RESERVES FRAUD / SCANDAL

THOUSANDS OF PAGES FROM ROYAL DUTCH SHELL RESERVES COURT CASE DOCUMENTS, INCLUDING WITNESS STATEMENTS

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

ROYAL DUTCH/SHELL TRANSPORT SECURITIES LITIGATION

Civ.No. 04-374 (JAP)

PACER CODE: 3:2004-cv-00374

3:04-cv-00374-JAP-JJH BROCKAMP v. N.V. KONINKLIJKE NEDERLANDSCHE PETROLEUM MAATSCHAPPIJ et al Judge Joel A. Pisano, now presiding

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Click here to read the original Amended Complaint filed in Sept 2004

Motion filed by Lead Plaintiff 27 March 2006

Motion filed by Lead Plaintiff on 9 May 2007

Motion filed by Royal Dutch Shell 9 May 2007

Order Appointing Special Master filed 24 May 2007

Declaration by Special Master 24 May 2007

Shell discovery document added on 10 October 2007

Entire 333 page searchable deposition of Iain Percival (retired Shell Group Global Chief Petroleum Engineer) first posted online on 10 October 2007

Motion filed by Lead Plaintiff 11 October 2007 (includes REPORT & RECOMMENDATION OF SPECIAL MASTER NICHOLAS H. POLITAN

ROYAL DUTCH/SHELL TRANSPORT'S FACTUAL SUBMISSION TO SPECIAL MASTER RELATING TO EXTENT OF UNITED-STATES-BASED CONDUCT: DOC 340 FILED 10 Oct 2007 387 Searchable Pages

Motion filed on behalf of Shell 15 October 2007

Committee of Royal Dutch Shell Managing Directors (CMD) Confidential Document dated 15 Jan 2002 (filed with Court 15 October 2007)

Shell U.S. West Coast Investor Road Show: Confidential document (Filed with court 15 October 2007)

Christensen & Associates 5 part document RDS Management/Market Analysis and Perception Study - every page marked as being confidential (filed with court 15 October 2007)

Part 1 (16 pages)

Part 2 (15 pages)

Part 3 (19 pages)

Part 4 (14 pages)

Part 5 (16 pages)

SHELL EP Business Plan - Volume 2: Exploration and Production Committee: Marked "MOST CONFIDENTIAL": IN 2 PARTS

Part 1 (30 pages - now searchable)

Part 2 (29 pages now searchable)

Cover letter from Lead Plaintiff attorneys Bernstein Liebhard & Lifshitz LLP filed with the Court 16 October 2007

Part 1 of Transcript filed with Bernstein letter of 16 October 2007

Part 2 of Transcript filed with Bernstein letter of 16 October 2007

Corrections to transcript filed 16 October 2007

MARKED AS BEING "HIGHLY CONFIDENTIAL": REPORT OF DAVIS POLK & WARDWELL TO SHELL GROUP AUDIT COMMITTEE (Now searchable- 202 pages)

Shell discovery documents added on 30 October 2007

MAIN DOCUMENT: REVIEW OF GROUP END 2000 PROVED OIL AND GAS... (Searchable)

SHELL EP IMPROVING PERFORMANCE & MAXIMISING VALUE (PART 1 - Searchable)

MAIN DOCUMENT (PART 9)

PART 10

PART 11

PETROLEUM RESOURCE VOLUME GUIDELINES; RESOURCE CLASSIFICATION AND VALUE REALISATION (40 pages - Searchable)

PART 1 (31 PAGES)

PART 2 (39 PAGES)

Shell discovery documents added on 31 October 2007

Royal Dutch Shell/Group Presentation to the Financial Community 2002 (Searchable)

Opinion of Forrester Garb & Associates Inc (Searchable)

Shell discovery documents added on 1 November 2007

Shell Confidential: Guide for the Administration of proved Reserves and Production for External Disclosure

Email Correspondence on 22 Aug 2000 between Heinz Rothermund and Phil Watts

Confidential Minutes of EPA Region Reserves Challenge Session, 19 Nov 2003

MARKED CONFIDENTIAL: From Anton Barendregt, Group Reserves Auditor, circulated 6 Dec 2002 to Frank Coopman and other notables

MARKED CONFIDENTIAL: From Anton Barendregt, Group Reserves Auditor, circulated 31 May 2002 to various Shell Executives plus KPMG Accountants NV and PriceWaterhouseCoopers

EP EXCOM: Minutes of meeting held in The Hague 11 Nov 2002: every page marked "Confidential"

Deepwater Steering Council Meeting held on 5 Oct 2001: every page marked "Confidential"

Shell discovery documents added on 2 November 2007

January 2004 email correspondence between Anton Barendregt, Royal Dutch Shell Group Reserves Auditor and John Hoppe DPE-RES: Confidential

SEPTEMBER 2003: Petroleum Resources Volume Guidelines Resource Classification and Value Realisation: This document is confidential and restricted to Shell personnel only (48 pages)

October 2002 communication from Anton Barendregt, Royal Dutch Shell Group Reserves Auditor, to Shell senior managers plus KPMG Accountants NV and PriceWaterhouseCoopers: Confidential

January 2000 note from Frits Eulderink EPG to Heinz Rothermund EPC: Subject SPDC Onshore Reserves: Confidential

Shell discovery document added on 3 November 2007

Annual Report on Form 20F 2002 Royal Dutch Petroleum Company and The "Shell" Transport and Trading Company, Public Limited Company filed with the United States Securities & Exchange Commission: Filed in March 2003: Every page in discovery document marked "FOIA Confidential Treatment Requested": Believe to be request for exemption from U.S. Freedom of Information Act. Contained fraudulent declaration of oil and gas reserves signed by Jeroen van der Veer and countersigned by "Independent Accountants": filed 10 months before news of reserves scandal broke.

Form 20F Return in 5 Parts

Part 1 (31 pages)

Part 2 (31 Pages)

Part 3 (41 Pages)

Part 4( 41 Pages)

Part 5 (39 Pages)

Shell discovery documents added on 6 November 2007

Shell Confidential Economics, Planning and Portfolio Analysis (EPPA) Review - SNEP Co: Nov 2000 (32 pages)

Note From: A A Barendregt Group Reserves Auditor to A J Parsley, Director, SEPIV BV 8 February 1999: Confidential (13 Pages)

Shell Confidential: Petrol Resource Volume Guidelines Resource Classification and Value Realisation: SIEP EPB-P SEPTEMBER 2001 (49 pages)

2002 SEC RESERVES AUDIT BRUNEI - Conclusions: Every page marked "Confidential" (8 pages)

NOTE 31 MAY 2002: From: Anton A Barendregt Group Reserves Auditor, SIEP-EPB - GRA: Long circulation list including Chris Finlayson: Document marked "Confidential" (5 pages)

Every page marked "Confidential": PDO 2003 SHELL Resource Volume Submission Proved Developed and Undeveloped Reserves (5 pages)

Shell discovery documents added on 7 November 2007

Confidential EP Presentation to Financial Analysts by Tim Warren in New York and Rijswijk, April 8-9, 1999 (20 pages)

Angola Block 18 Development Project Shell Management of bp Operations 9-13 October 2000: Every page marked "CONFIDENTIAL" (11 pages)

September 2000 Shell internal email correspondence involving Robert Inglis and G Parry EPC Study to Support Reserves Booking: "The Group has been doing very badly at replacing reserves and everyone needs to pull out all the stops": Every page marked "CONFIDENTIAL" (6 pages)

March 2001 Shell internal email correspondence involving Robert Inglis and others: Every page marked "CONFIDENTIAL" (7 pages)

March 2000 Shell internal email correspondence involving Ian Hines, Robert Inglis and others: "Apologies for my tardiness and any misrepresentation...": Every page marked "CONFIDENTIAL" (6 pages)

September 2000 Shell internal email correspondence involving Heinz Rothermund, G Parry, Lovelock, Minderhoud, Peter Osborne and many others: Every page marked "CONFIDENTIAL" (8 pages)

2002 STEP - Individual Performance and Development Self Appraisal for Shell employee Christopher J. (Chris) Varley, Bonga Team Leader: Every page marked "CONFIDENTIAL" (9 pages)

December 2002 Shell internal email correspondence about Angola involving Luuk Karsten, Chris Duhon circulated to many others Shell employees: Every page marked "CONFIDENTIAL" (3 pages)

September 2000 Shell internal email correspondence about Angola - Brazil Reserves Note, involving Ian Hines, Derek Newberry, Robert Inglis, Peter Osborne and many others: Every page marked "CONFIDENTIAL" (5 pages)

September 2000 Shell internal email correspondence regarding Angola reserves involving Ian Hines, Derek Newberry and many others: Every page marked "CONFIDENTIAL" (10 pages)

Shell discovery documents added on 8 November 2007

Shell EP November 2000 Internal email correspondence involving Matthias Bichsel, Martijn Minderhoud, Heinz Rothermund and many others: Subject: West Africa Reserves 2000: Every page marked "CONFIDENTIAL": (5 pages - now searchable)

Shell SIEP Internal email correspondence Jan 2001 involving Aidan McKay, John Bell, Mark Leonard, Remco Aalbers and others: Subject: Reserve audit - use of contractors: Every page marked "CONFIDENTIAL": (5 pages- now searchable )

Shell SIEP Internal email correspondence Sept 2000 involving Ian Hines, Richard Sears, Chandler Wilhelm, Gordon Parry and others: Subject: Reserves: Every page marked "CONFIDENTIAL": (7 pages- now searchable )

Shell SIEP Internal email correspondence Jan 2002 involving Robert Inglis, Ian Hines, Luuk Karsten, Wouter Smits and others: Subject: Reserves Bookings: Every page marked "CONFIDENTIAL": Extract: "I still cannot understand how the case for reserves booking falls apart on the day we have to make the submission... The news went down like a lead balloon and clearly will impact all our performance assessments for 2001..." (4 pages - now searchable )

EP/GP Investor Relations Presentation 12/13 April 2000 involving Phil Watts, Dominique Gardy, Din Megat, Linda Cook, Tim Warren and Walter van de Vijver: Every page marked "CONFIDENTIAL" (49 pages - now searchable)

Shell discovery documents added on 9 November 2007

Exhibit 112: December 2000 Shell SIEP Development Angola: Note for information: Block 18 Reserves SDAN: From Grigore Simon and Robert Inglis update to Gordan Parry and Peter Osborne: Every page marked "CONFIDENTIAL" (4 pages - now searchable)

Exhibit 113: October 2000 Shell SIEP internal email involving Grigore Simon, Robert Inglis, Susan Lovelock, Heinz Rothermund and others: "Bichsel under pressure": Every page marked "CONFIDENTIAL" : (3 pages- now searchable )

Exhibit 114: October 2000 Shell SIEP internal email involving Ian Hines, Robert Inglis, Grigore Simon and others: Subject: Angola Reserves: "Rob, We really need to discuss this very urgently - this note suggest a continued disconnect and paints a very optimistic picture on volumes which is unlikely that we will be able to support": Every page marked "CONFIDENTIAL" (4 pages- now searchable )

Exhibit 115: Shell SIEP November 2001 internal email involving Grigore Simon, Ian Hines, Wouter Smits and others: Subject: Urgent Action Plan: Every page marked "CONFIDENTIAL": (6 pages - now searchable)

Exhibit 116:Shell SIEP January 2001 internal email involving Chandler Wilhelm, Ian Hines, Barry Knight and Richard Sears: Subject: RESERVE BOOKING FOR BLOCK 18: Every page marked "CONFIDENTIAL" (3 pages- now searchable )

Shell discovery document added on Saturday 10 November 2007

Searchable Transcript of Financial Services Authority Interview with Sir Philip Watts: 24 June 2004: 75 pages - every page marked "CONFIDENTIAL" (Searchable)

EXTRACT: Samantha Griffin for the FSA to Sir Philip: "You are not under arrest and are free to leave any time. The interview is being conducted under caution. That is to say you do not have to say anything but it may harm your defence if you do not mention when questioned something you later rely on in Court. Anything you say may be given in evidence. Do you understand?"

Shell discovery document added on Sunday 11 November 2007

The Minutes of the Royal Dutch Shell Committee of Group Managing Directors (CMD) meeting in September 2001: Every page classified as "MOST CONFIDENTIAL"

Shell discovery document added on Monday 12 November 2007

The Minutes of the Royal Dutch Shell Committee of Group Managing Directors (CMD) meeting on 23 July 2002 (Now Searchable)

Shell discovery document added on Tuesday 13 November 2007

(SEARCHABLE PDF FILE)

SHELL COMMITTEE OF MANAGING DIRECTORS - MINUTES OF THE MEETING HELD ON 9 DECEMBER 2003, JUST WEEKS BEFORE NEWS BROKE ABOUT THE RESERVES FRAUD

Shell discovery documents added on Wednesday 14 November 2007

ENTIRE SEARCHABLE DEPOSITION OF ROYAL DUTCH SHELL GROUP RESERVES AUDITOR, ANTON BARENDREGT - 32mb pdf FILE, 965 PAGES SO WILL TAKE SOME TIME TO LOAD, PARTICULARLY IF YOU DON'T HAVE BROADBAND

OR SPLIT BELOW INTO NON SEARCHABLE FILES

EXHIBIT 19: VIDEOTAPED DEPOSITION UPON ORAL EXAMINATION OF ANTON BARENDREGT: VOLUME 1 taken on Monday 19 February, 2007 at The Hague Zurich Tower (325 searchable pages)

Shell discovery documents added on Thursday 15 November 2007

Exhibit 20: Part 2 of Anton Barendregt deposition (75 pages)

Exhibit 21: Part 3 of Anton Barendregt deposition (50 pages)

Exhibit 22: Part 4 of Anton Barendregt deposition (50 pages)

Exhibit 23: Part 5 of Anton Barendregt deposition (25 pages)

Exhibit 24: Part 6 "Main Document" of Anton Barendregt deposition (50 pages)

Exhibit 25: Part 7 of Anton Barendregt deposition (50 pages)

Exhibit 26: Part 8 of Anton Barendregt deposition (50 pages)

Exhibit 27: Part 9 of Anton Barendregt deposition (50 pages)

Exhibit 28: Part 10 of Anton Barendregt deposition (50 pages)

Exhibit 29: Part11 of Anton Barendregt deposition (50 pages)

Exhibit 30: Part 12 of Anton Barendregt deposition (50 pages)

Exhibit 31: Part 13 of Anton Barendregt deposition (50 pages)

Exhibit 32: Part 14 of Anton Barendregt deposition (50 pages)

Exhibit 33: Anton Barendregt Declaration (15 pages)

Shell discovery documents added on Friday 16 November 2007

Entire 850 page searchable legal document containing the testimony of Walter van de Vijver and related exhibits.

OR SPLIT INTO SEGMENTS BELOW

Exhibit 289: Videotaped Deposition of former Royal Dutch Shell Group MD and Chief Executive of Shell Exploration & Production - Mr Walter van de Vijver, in Washington, D.C. 16 Wednesday, January 31st, 2007: 17 9:39 a.m. (first 390 pages)

Exhibit 290: Walter van de Vijver Deposition (70 pages)

Exhibit 291: Walter van de Vijver Deposition (65 pages)

Exhibit 292: Walter van de Vijver Deposition (60 pages)

Exhibit 293: Walter van de Vijver Deposition (65 pages)

Exhibit 294: Walter van de Vijver Deposition (61 pages)

Shell discovery documents added on Saturday 17 November 2007

Exhibit 319: Walter van de Vijver Deposition (16 pages)

Exhibit 320: Walter van de Vijver Deposition (21 pages)

Exhibit 321: Walter van de Vijver Deposition (36 pages)

Exhibit 322: Walter van de Vijver Deposition (37 pages)

Exhibit 323: Walter van de Vijver Deposition (14 pages)

Exhibit 324: Walter van de Vijver Deposition (15 pages)

ENTIRE SEARCHABLE DEPOSITION OF ROYAL DUTCH SHELL GROUP RESERVES AUDITOR, ANTON BARENDREGT - 32mb pdf FILE, 965 PAGES SO WILL TAKE SOME TIME TO LOAD, PARTICULARLY IF YOU DON'T HAVE BROADBAND

Exhibit 302: Videotaped deposition of BRIAN J. WARD, a former Managing Director of Shell, taken by the Lead Plaintiff and the Class, at the offices of LeBoeuf, Lamb, Greene & MacRae LLP, 1 Minster Court, London, England, before Gail F. Schorr, a Certified Shorthand Reporter, Certified Realtime Reporter and Notary Public within and for the State of New York. January 10, 2007: 10:07 a.m. (198 pages)

Shell discovery documents added on Sunday 18 November 2007

Entire searchable videotaped deposition of Tim Warren, retired Country Chairman, Shell Australia, deposed in Washington, D.C. Tuesday, January 30, 2007: 10:25 a.m. Formally Shell EP Technology director, Shell International Exploration & Production B.V.: 16.62mb pdf file containing 518 pages, so will take some time to load, particularly if you don't have broadband

Shell U.S. and Dutch Court documents added on 19/20 November 2007

U.S. Court Decision to allow European Settlement to proceed: UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY: IN RE ROYAL DUTCH/SHELL : Civ. No. 04-374 (JAP) TRANSPORT SECURITIES : (Consolidated Cases) LITIGATION : OPINION: Joel A. Pisano: United States District Judge: Dated: November 13, 2007: 20 Pages

Petition to Amsterdam Court of Appeal April 2007

Proposed European Settlement April 2007

Letter to U.S. Court from Shell Attorney Jeffrey Cohen: November 16, 2007

Letter to U.S. Court from Shell Attorney Ralph C. Ferrara: November 16, 2007

Proposed Order for issue by U.S. District Court Judge Joel A. Pisano: Filed November 16,2007

Certificate of Service filed with U.S. District Court on November 16, 2007

Shell discovery documents added on Wednesday 21 November 2007

Videotaped deposition of Dr Roelof Platenkamp, Shell Corporate Vice President of Petroleum Engineering and Development: taken in New York, New York November 14, 2006: 10:06 a.m.

Main Platenkamp Deposition, 200 pages

Platenkamp Exhibit 253

Platenkamp Exhibit 254

Platenkamp Exhibit 265

Platenkamp Exhibit 256

Platenkamp Exhibit 257

Platenkamp Exhibit 258

Platenkamp Exhibit 259

Platenkamp Exhibit 260

Platenkamp Exhibit 261

IN RE ROYAL DUTCH/SHELL TRANSPORT SECURITIES LITIGATION: Appealable Judgment by U.S. District Court Judge Joel A. Pisano: Ordered that the Clerk is directed to enter a final judgment in this matter directing that Peter M. Wood's and the other Non-U.S. Purchasers' claims are dismissed for lack of subject-matter jurisdiction: 16 November 2007

Shell discovery document added on Thursday 22 November 2007

ROYAL DUTCH/SHELL GROUP OF COMPANIES: Investor Relations Presentation by Philip Watts, Jeroen van der Veer,Judy Boynton, Walter van de Vijver, Harry Roels and Paul Skinner: Tuesday, December 18, 2001, New York City. (60 pages every paged marked "Confidential"

Shell discovery documents added on Friday 23 November 2007

Videotaped deposition of REMCO AALBERS, formerly Shell Group Reserves Coordinator

Exhibit 14 (400 pages)

Exhibit 15 (50 pages)

Exhibit 16 (50 pages)

Exhibit 17 (69 pages)

Exhibit 285 (54 pages)

Exhibit 18 (7 page Declaration June 2007)

Shell reserves fraud discovery documents added on Saturday 24 November 2007

The email correspondence which proves that Walter van de Vijver, Chief Executive of Shell EP, warned Philip Watts about "aggressive" reserves bookings and other matters in August 2002:

Walter van de Vijver to Phil Watts:

"I feel strongly that we should stop talking to analysts about things we have not delivered yet...": "With aggressive historical proved reserves booking, massive investment in Nigeria with increasing risks, few material discoveries, ROACE pressures, we just need to be very careful."

Exhibit 185: August 2002 Shell internal email correspondence between Walter van de Vijver and Philip Watts (2 pages)

Shell reserves fraud discovery documents published on Sunday 25 November 2007

The first item, Exhibit 186, is email correspondence on 3 January 2004 from Frank Coopman, Chief Financial Officer, Shell Exploration and Production B.V. to Curtis Frasier of Shell International, which was copied to John Darley, SIEP-EPT. This was sent 6 days before the Shell reserves fraud was announced to a stunned world. Frank Coopman made it plain that the "independent" Group reserves auditor, Anton Barendregt (a retired former Shell employee who acted as the Group reserves Auditor on a part-time basis) was in fact "not completely independent".

The following day, Anton Barendregt sent an email to Frank Coopman copied to John Pay, John Darley and John Bell admitting that with hindsight he should have been more "forceful" in respect of a correct formulation of Group guidelines in relation to avoiding conflict with SEC rules. He stated in his penultimate paragraph: "I realise that Curtis may not like my references to the guidelines. I seem to remember him saying that we should not say externally that our internal guidelines were different from the SEC's. I do not see how we can maintain that pose in ernest. It would imply saying that either our guidelines were SEC compliant (which would be easily refutable lie) or that we had no guidelines at all, which would be unbelievable and also clearly not true."

Exhibit 186: Confidential January 2004 Shell internal email correspondence involving Anton Barendregt, Frank Coopman, Chief Financial Officer, Shell International Exploration and Production B.V. plus Curtis Frasier and John Darley (3 pages)

Exhibit 187: January 2002 Confidential Shell internal email correspondence involving Jan-Willem Roosch, Rod Sidle, Manager, Oil and Gas Reserves/Value Assurance Houston and others (5 pages)

Exhibit 188: March 2002 Confidential Shell internal email correspondence involving Jan-Willem Roosch, Rod Sidle, Jonathan Holroyd and others (3 pages)

Exhibit 189: March 2002 confidential Shell internal email correspondence involving Jan-Willem Roosch, John Pay and Rod Sidle (3 pages)

Exhibit 190: September 2002 Confidential Shell internal email correspondence involving Rod Sidle and others (23pages)

Exhibit 191: July 2003 Confidential Shell internal email correspondence involving Frank Coopman, Bob Deer, Tim Morrison, John Pay, Van Poppel and others (4 pages)

Exhib 192: 19 April 2004 Shell News & Media Releases (7 pages)

Exhibit 193: March 20002 confidential Shell internal email correspondence involving Jan-Willem Roosch, Van Driel, Craig Myers, Peter Van Driel and Mark Wharton (3 pages)

Shell reserves fraud discovery document published on 26 November 2007

Exhibit 129: January 2003 email correspondence involving Stuart Evans DPVM, Paulo Bizarro ONP32F, Niels van Dijk Shell International Petroleum - EPGO-RTL-R, Abdulla Lamki DMD, Saif Hinai OND, Jeroen Peters OSD, Abia Riyami OSP, Frode Linge ONP, Rob Willis SIEP-EPT-AGI, Bart Wassing OSP3H, Chris Mijnssen ONP3, Stuart Evans DPVM, Stuart Clayton DTEM, Said Harthy UPG2G, Kathleen Heller UPP: Subject Updated Reserves Picture and initial water flood plans: Extract: "Following on from the SSG, a meeting was reviewed to revisit options to make up the reserves shortfall."

Shell reserves fraud discovery document published on 27 November 2007

Exhibit 131: Walter van de Vijver Exhibit: appears to be record of his visit to Oman in May 2002. Contains blunt assessment of senior PDO management. Every page marked Confidential: (6 pages)

Shell confidential reserves fraud discovery documents published on 28 November 2007

Exhibit 132: SPDC Restatement 1998-2002: Confidential (9 pages)

Exhibit 133: Note for Discussion: Group Investor Relations: Strategy and Plan to 2004: Every page marked "Confidential" (20 pages)

Exhibit 134: 2002 Executive Summary: Most Confidential: Signed by Walter van de Vivjer (12 pages)

Shell confidential reserves fraud discovery document published on 29 November 2007

Exhibit 64: January 2002 Confidential Investor Relations Plan signed by Philip Watts (15 pages)

Shell confidential reserves fraud discovery document published on Friday 30 November 2007

ROYAL DUTCH/SHELL GROUP OF COMPANIES: 2001 Confidential "Management/Market Analysis and Perception Study"

Some extracts:

"I like Phil Watts. He is an 'upstreamer' and has a good understanding of the business and is looking to grow it profitably."

"RD/Shell's management comes across as honest and credible."

"Management's weakness is that they got ahead of themselves in their promises."

"They give us all these colorful slides, but when they are compared to reality, they always fall short."

Part 1 (16 pages)

Part 2 (15 pages)

Part 3 (19 pages)

Part 4 (14 pages)

Part 5 (16 pages)

Shell confidential reserves fraud discovery document published on 3 December 2007

CONFIDENTIAL: Shell note 30 Jan 2001 from Anton Barendregt, Group Reserves Auditor, to Lorin Brass Shell EP Director), Phil Watts (EP Chief Exec) , Dominique Gardy (CFO SIEP), John Bell, Remco Aalbers SIEP plus Egbert Eeftink (Partner, KPMG Accountants) and Stephen L. Johnson of PriceWaterhouseCoopers: REVIEW OF GROUP END-2000 PROVED OIL AND GAS RESERVES SUMMARY PREPARATION

Shell confidential reserves fraud discovery documents published on 4 December 2007

CONFIDENTIAL (Doc 423) : 27 January 2000 Note for Information from Frits Euiderink Shell EPG to Remco Aalbers, Group Reserves Coordinator: Subject: SPDC Onshore Oil Reserves (6 pages)

Exhibit 163: CONFIDENTIAL: February 2004 Angola Country Analysis Brief (13 pages)

Exhibit 164: CONFIDENTIAL: 24 August 2000 Shell internal email from Heinz Rothermund SEPI-EPG to Phil Watts SI-MGDPW: Subject Angola - Block 18 Well: Accuses BP of being "over-optimistic" with its plans: (3 pages)

Exhibit 165: CONFIDENTIAL: Minutes of EPA Region Reserves Challenge Session. 19 November 2003 (7 pages): Participants included: John Pay (Group Reserves Coordinator), Lim Min Teong (Group RE Discipline Head), Brian Straub (EP Technical Director), John Sutherland (SM-EP), Tho Hui Tsin (SM-EP), Tan Teck Choon, Martin Ijpelaar, Paul Vledder (Sarawak Reserves Coordinator), Stanley Kuch, Heng Hiok Boon, Bart van de Leemput (Shell EPA), Lai Vui Leong, Dan van Nispen, Anco Maan, Kenneth Newn, Louis Huizenga, Sara Bell, Steven Pannett, Roland Stoltz, Dave Hawton, Ante Frens, Frans Deckers and Oliver Lepine (7 pages)

Exhibit 166: CONFIDENTIAL: NOTE - 6 December 2002: From Anton Barendregt Shell Group Reserves Auditor to Frank Coopman (Shell EP CHIEF FINANCIAL OFFICER) Lorin Brass, Director Shell International EP- EPB and Luuk Karsten, General Manager, Shell Development Angola. Copied to Rob Inglis, Patrick Whittome, Woulter Smits, Liz Sturman, Barry Knight, Ian Hines, Derek Newberry Rahim Khan, Malcolm Harper, Jaep Nauta, John Pay, Chris Duhon, Han van Deidan (KPMG Accountants NV) and Brian Puffer of PriceWaterhouseCoopers: Subject:SEC PROVED RESERVES AUDIT - SHELL DEVELOPMENT ANGOLA, 25-26 Nov 2002 (11 pages)

Shell confidential reserves fraud discovery documents published on 5 December 2007

Exhibit 167: CONFIDENTIAL: NOTE - 31 May 2002: From Anton Barendregt to Lorin Brass and Chris Finlayson (Managing Director, BSP) copied to Brian Straub, Rosmawatty Abd-Mumin, Salieh-Bostaman Zainal-Abidin, Martin Graham, Thomas Prudence, Peter Worby, Ben van den Bergh, Chris Kennett, Dominique Gardy, Rahim Khan, Malcolm Harper, Jaap Nauts, John Pay, Paul Tauecchio, Han van Delden (KPMG Accountants NV) and Stephen Johnson (PriceWaterhouseCoopers): Subject: SEC PROVED RESERVES AUDIT - BRUNEI SHELL PETROLEUM SDN BHD, 29 April - 3 May 2002 (17 pages)

Exhibit 168: Shell Confidential EP 2003: Subject: Guide for the Administration of Proved Reserves and Production for External Disclosure: This document is confidential. Distribution is restricted to the named individuals and organisations contained in the distribution list maintained by the copyright owners. Further distribution may only be made with the consent of the copyright owners and must be logged and recorded in the distribution list for this document, Neither the whole nor any part of this document may be disclosed to any third party without the prior written consent of the copyright owners. Copyright 2003 SIEP B.V. SHELL INTERNATIONAL EXPLORATION AND PRODUCTION B.V., RIJSWIJK (25 pages)

Exhibit 169: Confidential EP EXCOM Minutes of meeting in The Hague: EP Excom Members Present: Walter van de Vijver, Matthias Bichsel, Lorin Brass, Linda Cook, Frank Coopman, John Darley, Carol Dubnicki, Dominique Gardy, Din Megat, Bob Sprague and Brian Ward. Curtis Frasier attended as Secretary. Wide ranging discussion on 11 November 2002 covering Nigeria and many other EP matters. (9 pages)

Exhibit 170: 5 October 2001: Confidential "Deepwater Steering Council Meeting" held 8-9 Houston Time/3-4 Hague Time: Attendees: The Hague: Lorin Brass, Heinz Rothermund and John Darley: Houston: Matthias Bichsel, Lori Priess: Fran Lohr via telephone (11 pages)

Shell confidential reserves fraud discovery document published on 6 December 2007

Videotaped Deposition of JOHN MALCOLM taken in Washington, D.C. on Friday, October 20th, 2006: John Malcolm, Managing Director of Petroleum Development Oman

Videotaped Deposition of DAVID ANDREW SEXTON taken in Washington, D.C. 16 Wednesday, September 13th, 2006: David A Sexton, President of Shell Oil Products U.S.

Main Deposition (85 pages)

Exhibit 277 (20 pages)

Exhibit 278 (35 pages)

Exhibit 279 (75 pages)

Exhibit 280 (115 pages)

Exhibit 281 (65 pages)

Exhibit 282 (42 pages)

Exhibit 283 (10 page Declaration)

Shell confidential reserves fraud discovery documents published on 8 December 2007

Videotaped Deposition of RODNEY SIDLE, held at the offices of LeBoeuf Lamb Greene & MacRae LLP, 125 West 55th Street, New York, New York. October 30, 2006 10:00 a.m. Rodney Sidle, Senior Reserves Consultant for Shell International Exploration & Production Inc. Includes confidential Shell internal correspondence and documents

Exhibit 284 (295 pages)

Exhibit 285 (35 pages)

Exhibit 286 (44 pages)

Exhibit 287 (11 page Declaration)

Exhibit 311 Sidle Deposition continues on Oct 31, 2006 (16 Pages)

Exhibit 312 Sidle Deposition Continues (19 pages)

Exhibit 313 Sidle Deposition Continues Sidle (21 pages)

Exhibit 314 Sidle Deposition Continues (21 pages)

Exhibit 315 Sidle Deposition Continues (22 pages)

Exhibit 316 Sidle Deposition Continues (27 pages)

Exhibit 317 Sidle Deposition Continues (32 pages)

Exhibit 692 Rebuttal of Rodney Sidle (3 Pages)

Shell confidential reserves fraud discovery documents published on 11 December 2007

Videotaped deposition of JOHN C. DARLEY, Director E&P Technology, Shell International E&P, taken by the Lead Plaintiff in New York, New York: November 16, 2006: Includes "MOST CONFIDENTIAL" Shell documents, internal and external confidential correspondence and Shell plans and strategy - 2000/2001/2002/2004, involving senior managers and group managing directors including: Walter van de Vijver, Malcolm Brinded, Linda Cook, David Greer, Brian Ward, John Haney, Fran Lohr, Anton Barendregt, Lorin Brass, Frank Coopman and many others.

Exhibit 69 JOHN C. DARLEY Deposition (275 pages)

Exhibit 70 JOHN C. DARLEY Deposition (25 pages)

Exhibit 71 JOHN C. DARLEY Deposition (24 pages)

Main Document 346 (42 pages)

Exhibit 73 JOHN C. DARLEY Deposition (13 pages)

Exhibit 74 JOHN C. DARLEY Deposition (12 pages)

Exhibit 75 JOHN C. DARLEY Deposition (13 pages)

Exhibit 76 JOHN C. DARLEY Deposition (12 pages)

Exhibit 77 JOHN C. DARLEY Deposition (13 pages)

Exhibit 78 JOHN C. DARLEY Deposition (50 pages)

Exhibit 79 JOHN C. DARLEY Deposition (50 pages)

Exhibit 80 JOHN C. DARLEY Deposition (50 pages)

Exhibit 81 JOHN C. DARLEY Deposition (50 pages)

Exhibit 82 JOHN C. DARLEY Deposition (50 pages)

Errata 83 JOHN C. DARLEY Deposition (35 pages)

Supplemental Declaration of JOHN C. DARLEY June 6, 2005 (4 pages)

Shell confidential reserves fraud documents published on 12 December 2007

Expert Opinion of Professor Gregg A. Jarrell, expert on artificial inflation of Equity Securities caused by misstatement and omissions: Signed on November 3, 2006

Exhibit 385: Part One of Jarrell Report for Plaintiffs

Exhibit 386: Part 2 of Jarrell Report for Plaintiffs

Exhibit 387: Jarrell Rebuttal of expert opinions of Daniel R. Fischel and Dr Hans-Jurgen Peterson

Shell confidential reserves fraud documents published on 13 December 2007

Transcript of Videotaped Deposition of Simon Henry, Executive Vice President Finance Shell Exploration and Production: taken Monday October 16, 2006 in Washington D.C.

Pages 1 to 49 Simon Henry Deposition

Page 50 onwards of Simon Henry Deposition

Page 100 onwards of Simon Henry Deposition

Page 150 onwards of Simon Henry Deposition

Page 200 onwards of Simon Henry Deposition

Word Index for Simon Henry Deposition

Shell confidential reserves fraud documents published on 14 December 2007

Declaration of Sarah Bell, Sakhalin Energy Investment Company Limited, formally reservoir Engineer at Shell Development Australia (Five pages)

Transcript of Videotaped Deposition of MATTHIAS BICHSEL, Executive Vice President Technical, Shell Exploration and Production B.V.: taken in New York, New York October 31, 2006

Exhibit 49 (200 pages) Bichsel Deposition

Exhibit 50 below is of particular interest. In addition to the Deposition of Bichsel, it also contains his CV, confidential email correspondence and PERSON OVERVIEW documents for Bishsel and other senior Shell Executives, as follows: -

Brian Ward, Director, Technical and Operational Excellence: RBD Europe and Africa; Shell International Exploration and Production: Extract: "Brian needs to take care against slipping back in his natural Shell "operations management" role thereby diluting his all-round abilities as "role model EP leader".

Zaharuddin (Din) Megat, Regional Business Director, Central and South Asia and Russia, Shell International Exploration and Production:

Extract: "Din's portfolio was reduced on April 1, 2002 to better align scope and capabilities."

Extract: "Din does not always choose his words carefully when communicating with staff which has resulted in misunderstandings, anger and frustration for several of them this past year. He needs to work on his ability to build effective working relationships with, and more effectively motivate, those reporting to him."

Tim Warren, former Chairman Shell Australia: Extract: "Tim's long hours are a legend at Shell. Given our current struggles with work-life balance, he would be well served to lead by example in managing his own work hours and ensuring those he leads focus on the most critical strategic initiatives/issues."

John Darley, Director Shell Technology Exploration and Production; SIEP

Bob Sprague, Regional Business Director Shell International Exploration and Production: Extract: "He is direct in his communications with others, sometimes uncomfortably so when stating his concerns or objections (particularly through e-mail!). He displays... intolerance for decisions/ recommendations where staff work has not been thorough or the thinking well organised. His lack of natural engagement skills and absence of pro-active behaviour towards changing performance or business climates can "downgrade" his overall excellence in-depth expertise and perspectives."

Bichsel Matthias, Exploration Director, Shell International Exploration and Production

Lorin Brass, Director, Business Development Support, Shell International Exploration and Production: Extract: "Lorin needs to work at more forceful, persuasive presentation of his position."

Dominique Gardy, Chief Financial Officer, Shell International Exploration and Production Company: Extract: "...Dominique at times has appeared to be spread a bit thin and needed to consider more effective delegation, time management and perhaps more effective use of resources."

Carol Dubnicki, HR Director, Exploration and Production, Shell International Exploration and Production.

Exhibit 50 (75 pages)

Exhibit 51 Confidential Production forecasts for Shell, ExxonMobil, TotalFinaElf, Chevron and Texaco (47 pages)

Exhibit 52 Declaration of Bichsel Matthias (13 pages)

Shell confidential reserves fraud documents published on weekend of 15/16 December 2007

Transcript of Deposition of Videotaped Deposition of Lorin Brass, Director Shell International Exploration and Production, taken in Washington D.C. on November 8, 2006

Exhibit 53: Start of Lorin Brass Deposition (240 pages)

Exhibit 54: Lorin Brass Deposition plus Shell internal email correspondence involving Phil Watts; plus EP ExCom Minutes of meeting held 31 January 2000; 23 February 2000 Shell letter to PriceWaterhouseCoopers; Shell letter to KPMG Accountants N.V.; Committee of Manager Directors Note dated 11 February 2002: ALL CONFIDENTIAL ITEMS (60 pages)

Exhibit 55: Shell internal documents plus Shell internal email involving Lorin Brass, Walter van de Vijver, John Pay, Marian van der Laan, Malcolm Harper, Ceri Powell, Debbie Gibbs and Jaap Nauta; plus CMD Note of 18 July 2002 signed by Walter van de Vijver (50 Pages)

Exhibit 56: CMD note continues, plus more Shell internal email involving Lorin Brass, Shirley Holm, Walter van de Vijver, Max Brouwers, Jaap Nauta, John Pay and Malcolm Harper; plus Walter van de Vijver July 2002 Most Confidential Reserves Outlook presentation to Committee of Managing Directors; plus CMD Minutes of Meeting - every page marked MOST CONFIDENTIAL (50 pages)

Exhibit 57: CMD minutes continue; more Shell internal email involving Lorin Brass and Walter van de Vijver, John Pay; plus confidential Note for Discussion entitled "EP PROVED RESERVES MANAGEMENT" (50 pages)

Exhibit 58: Declaration of Lorin Brass (9 pages)

Exhibit 286: Lorin Brass Deposition, Volume 2, on 9 November, 2006 page 195 onwards (65 pages)

Exhibit 287: Lorin Brass Deposition page 295 onwards (62 pages)

Exhibit 288: Lorin Brass Deposition page 320 onwards (72 pages)

Exhibit 289: Lorin Brass Deposition page 391 onwards plus Word Index (total of 44 pages)

Shell confidential reserves fraud documents published 17 December 2007

Transcript of Videotaped Deposition of GORDON PARRY, Regional Business Advisor South Asia for Shell Exploration and Production and General Manager of Shell Pakistan (Mr Parry is now retired); taken Washington D.C. on September 12, 2006.

Gordon Parry Deposition plus Shell internal email (175 pages)

Exhibit 229: more confidential Shell internal email correspondence relating to Gordon Parry Deposition: involving Philip Watts, Ian Hines, Richard Sears, Chandler Wilhelm, Barry Knight, Derek Newberry, Robert Inglis, Grigmore Simon, Remco Aalbers, Peter Osborne, Maarten Wink, Heinz Rothermund, Susan Lovelock, Martijn Minderhoud, Anton Barendregt, Bea Jespers, Hans van Nues, Keith Lewis, Tim Warren and Matthias Bichsel. (27 pages)

Extract from Gordon Parry email to Robert Inglis and Grimore Simon (circulated to several other Shell colleagues) 6 Sept 2000:

Gents, I attach the final version of the note requested by Heinz at the last EPG meeting regarding reserves booking in Angola and Brazil.

This note was forwarded to Phil Watts who remarked, quote

"It is critical that the Angola reserves are booked this year or our EP scorecard will be shot" unquote:

"Herewith Phil's reactions. We must pull this off aggressively! And we need on well, at least, as appraisal, whatever the purists say!"

Let's be guided accordingly!

Gordon

CONFIDENTIAL

Shell confidential reserves fraud court documents published 18 December 2007

Transcript of Videotaped Deposition of John Pay, Royal Dutch Shell Group Hydrocarbon Resource Coordinator, also known as Group Reserves Coordinator ("GRC") for Shell Exploration and Production: taken in Washington D.C. on January 22, 2007

Exhibit 230: John Pay Deposition plus Shell letter dated 31 October 2002 to U.S. Securities & Exchange Commission from Tim Morrison, Group Controller, plus other confidential documents (338 pages)

Exhibit 231 John Pay Declaration (5 pages)

Exhibit 232 John Pay Declaration continues - signed 12 June 2007 (4 pages)

Exhibit 296 John Pay Deposition Volume 2, Jan 23 2007 page 236 onwards (41 pages)

Exhibit 297 John Pay Deposition page 276 onwards (52 pages)

Exhibit 298 John Pay Deposition page 327 onwards (52 pages)

Exhibit 299 John Pay Deposition page 378 onwards (62 pages)

Exhibit 300 John Pay Deposition page 439 onwards plus start of Word Index (26 pages)

Exhibit 301 John Pay Deposition from page 7 of Word Index (26 pages)

Shell confidential reserves fraud court documents published 19 December 2007

(Exhibit 385 is a 37 page Shell EP Reserves Review document, every page marked "Confidential": Review Team: 1) Independent Petroleum Consultants: (Ryder Scott: Tom Gardner and George Dames): 2) Group External Auditors: PWC (Edo Kienhuis and Michael Hurley) KPMG (Han van Delden): 3) Group Reserves Consultants (Rod Sidle and David Kluesner): 4) Group Internal Audit (Ken Marnoch): Observers (John Darley, Frank Coopman and John Bell)

Exhibit 385: Confidential EP Reserves Review March 16, 2004: Shell Exploration & Production Reserves Presentation to GAC 10-13 March 2004

Doc 458: MEMORANDUM OF APPROVAL OF $27 MILLION PAYMENT: 14 January 2008

( (EXTRACT: "WHEREAS, the Court and Shell recognize that the Pennsylvania State Employees’ Retirement System’s and the Pennsylvania Public School Employees’ Retirement System’s efforts (as Lead Plaintiff) and Bernstein Liebhard & Lifshitz, LLP’s efforts (as Lead Counsel) in vigorously pursuing through litigation the Non-U.S. Purchasers’ claims for more than three years, in satisfaction of their fiduciary obligations to the proposed class, were a substantial factor in Shell’s decision to enter into a settlement agreement to resolve the claims of the Non-U.S. Purchasers in an action filed in the Amsterdam Court of Appeals in The Netherlands (the “Non-U.S. Settlement”) and that the Non-U.S. Settlement will confer a significant benefit upon Non-U.S. Purchasers; and WHEREAS, Shell has agreed to pay Lead Counsel a fee of $27 million to compensate Lead Counsel for its role in achieving this significant benefit for the Non-U.S. Purchasers; and WHEREAS, Lead Counsel informs the Court that the agreed-upon fee represents 7.7 percent of the approximately $350 million Shell has agreed to pay the Non-U.S. Purchasers in the Non-U.S. Settlement;")

DOC: 463-4: BRIEF IN SUPPORT OF MOTION TO SEAL: Filed with the Court 25 JANUARY 2007

DOC 466-2: LEAD PLAINTIFF'S MEMORANDUM IN SUPPORT OF CLASS CERTIFICATION: Filed with the Court: 1 FEBRUARY 2008

DOC 467: ORDER DISMISSING INDIVIDUAL DEFENDANTS WITH PREJUDICE: Filed with the Court 4 FEBRUARY 2008

DOC 470: Notice of Motion to Seal: 19 February 2008

DOC 470-2: Brief in Support of Motion to Seal Materials: 19 February 2008

DOC 470-3: Proposed Order Granting Motion to Seal: 19 February 2008

DOC 470-4: Certificate of Service: 19 February 2008

DOC 477: COURT ORDER RELATING TO MOTION TO SEAL: filed 20 February 2008

DOC 478: ORDER GRANTING MOTION TO SEAL: Filed 20 February 2008

DOC 479: Resignation letter to Judge Joel A. Pisano from Liaison Counsel: 26 February 2008

DOC 480: Order authorising resignation and subsitution of Liaison Counsel: 27 Feb 2008

Doc

Shell Closes Book on 2004 Reserves Scandal as Claims Deadline Passes: 5 November 2010

THE ROYAL DUTCH SHELL RESERVES FRAUD UNFOLDS IN NEWS HEADLINES

Daily Telegraph: Shell drops 'bombshell' on reserves: 9 January 2004

The Times: How Shell blew a hole in a 100-year reputation: 10 January 2004

The West Australian: Investors howl for Shell's blood: 12 January 2004

London Evening Standard: Shell bosses lied to the City: 19 April 2004

(Former executives, led by ex-chairman Sir Philip Watts, admitted they had repeatedly lied to investors about the true level of Shell's oil and gas reserves.)

Houston Chronicle: 'Sick and tired about lying' at Shell: 19 April 2004

Bloomberg: Shell Loses AAA Credit Rating: 19 April 2004

Shell bosses 'fooled the market': 19 April 2004

The Guardian: Trail of emails reveals depths of deceit at the heart of Shell: 20 April 2004

The Guardian: Shell admits it misled investors: 20 April 2004

The Independent: Lies, cover-ups, fat cats and an oil giant in crisis: 20 April 2004

The Scotsman: Shell admits reserve 'lies': 20 April 2004

The Scotsman: Shell implodes as e-mails provide damning evidence: 20 April 2004

The Times: Deceitful Shell 'needs ten years' to rebuild exploration business: 20 April 2004

Financial Times: Observer Column: Shell-shocked: Corporate slogans consigned to the dustbin of history no. 94: "You can be sure of Shell.": 20 April 2004

Minneapolis Star Tribune: Dutch/Shell Group exec was 'sick and tired' of lying: 20 April 2004

Daily Telegraph: Memos expose Shell's years of lying: 8 May 2004

The Scotsman: Shell's reputation left in tatters: 21 April 2004

TheStarOnline: Shell report exposes lies, CFO sacked: 21 April 2004

Daily Telegraph: Shell suffers second cut to credit rating: 21 April 2004

Daily Telegraph: Sacked Shell boss 'escorted from HQ': 22 April 2004

The Times: A very British kind of scandal: why Shell is no Enron: 23 April 2004

Daily Telegraph: Shell's lies over reserves spark FSA investigation: 24 April 2004

Times: "Shell is a disreputable company in need of a strong injection of ethics": 25 April 2004 "

("an audience with Sir Phillip Watts")

The Mail On Sunday: Shell’s top bosses named in £8 billion lawsuit after being spared the sack: 25 April 2004

Daily Mail: Shell attacked from all sides: 26 April 2004

(OIL giant Shell urgently needs to embark on a damage limitation offensive with investors before regulatory probes and lawsuits send the crisis spiralling out of control.)

Daily Telegraph: Shell gives Watts a £1m golden farewell: 23 May 2004

Daily Telegraph: Shell slices still more off proven reserves: 25 May 2004

Daily Telegraph: Watts' pension pot tops £10m: 28 May 2004

fin24: Shell directors under fire: 20 June 2004

Extract: "The report came just a day after Dutch paper NRC Handelsblad quoted a former executive of one of the oil group's subsidiaries as saying half of the company's 400 most senior managers were aware of the problem."

London Evening Standard: Shell 'has lied for 10 years': 26 June 2004

Sadistic sacking of a Royal Dutch Shell whistleblower: 27 October 2010

Shell Closes Book on 2004 Reserves Scandal as Claims Deadline Passes: 5 November 2010

MIRROR IMAGE WEBPAGE

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