Querella Holdings

Second Amended Complaint alleging "a large-scale and coordinated fraudulent scheme orchestrated by Defendants Kolomoisky and Bogolyubov and their agents and affiliates (both in the U.S. and abroad), including Defendant PrivatBank, that resulted in the misappropriation of millions of dollars of assets and property belonging to Plaintiffs" in Vadim M. Shulman, described as a resident of Monaco; Bracha Foundation, described as "a Liechtenstein foundation beneficially owned by Shulman", and Hornbeam Corporation, of Panama v. Igor Valeryevich Kolomoisky, described as "a billionaire Ukrainian businessman and "oligarch" who ... currently resides in the Ukraine and maintains citizenship in multiple countries including Ukraine, Israel, and Cyprus"; Gennadiy Borisovich Bogolyubov, described as "a billionaire Ukrainian businessman and "oligarch" who ... currently resides in the Ukraine and maintains citizenship in multiple countries including Ukraine, Israel, United Kingdom and Cyprus"; Mordechai Korf, of Miami, Florida, USA; Panikos Symeou, described as an attorney in Cyprus; Joint Stock Company Commercial Bank PrivatBank, of Ukraine; Warren Steel Holdings, LLC, of Delaware, USA; Optima Acquisitions, LLC, of Delaware, USA; Optima Group, LLC, of Delaware, USA; CC Metals and Alloys, LLC, of Delaware, USA; Felman Trading, Inc., of New Jersey, USA; Felman Production, LLC, of Delaware, USA; Optima Fixed Income, LLC, of Florida, USA; Optima Ventures, LLC, of Delaware, USA; Querella Holdings, Ltd., of Cyprus; Optima International of Miami, Inc., of Florida, USA; 5251 36th Street, LLC, of Florida, USA; Georgian American Alloys, Inc., of Delaware, USA, and Halliwel Assets, Inc., of the British Virgin Islands, at the Court of Chancery of the State of Delaware, USA.