1 IN THE HIGH COURT OF JUSTICE CLAIM NO ... - Platform

UNEP found contamination has reached groundwater in manylocations;46.3. 10 out of 15 investigated sites which SPDC records show as havingcompleted remediation still have pollution exceeding the SPDC andNigerian Government target values. In 8 of these sites pollution hadmigrated to the groundwater;46.4. In January 2010 a new Remediation Management System was adoptedby Shell Exploration and Production Companies in Nigeria. Thestudies found that while the new system still does not meet localregulatory requirements or international best practice.47. Alternatively the Claimant seeks a mandatory order that the Defendant carry outan appropriate clean up and remediation of the impacted land and waterways.Reservation48. The Claimant reserves the right to amend these particulars upon completion ofdisclosure herein, including but not limited to the issues of aggravated andexemplary damages as set out above.49. Further the Claimant seeks interest pursuant to section 35A of the Senior CourtsAct 1981 at such a rate and for such a period as the Court thinks fit.ALEXANDER LAYTON QCRICHARD HERMER QCDANIEL LEADER23 rd March 2012CLAIRE MCGREGOR28