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2/15/2024 10:32 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Marissa Gomez DEPUTY
CAUSE NO. DC-23-07534
BERNARD TUBEILEH andSINOSTAR § IN THE DISTRICT COURT OF
INVESTMENTS LLC,
Plaintiffs, DALLAS COUNTY, TEXAS
vs.
68th JUDICIAL DISTRICT
GLOBAL OIL & GAS TEXAS, LLC, and
GLOBAL OIL & GAS FIELDS
OKLAHOMA LLC,
Defendants.
and
GLOBAL OIL & GAS TEXAS, LLC, ET
AL.,
Counterclaim Plaintiffs,
Vv.
BERNARD TUBEILEH, ET AL.,
Counterclaim Defendants.
SUPPLEMENT TO DEFENDANTS/COUNTERCLAIM PLAINTIFFS’ RESPONSE TO
PLAINTIFFS’ TWO MOTIONS FOR PARTIAL SUMMARY JUDGMENT, TUBEILEH
LOANAGREEMENT AND MARCH SINOSTAR LOANAGREEMENT
Defendants/Counterclaim Plaintiffs Global Oil & Gas Texas, LLC and Global Oil & Gas
Fields Oklahoma, LLC (collectively “Defendants”) file this Supplement to their Response to
Plaintiffs’ Two Motions for Partial Summary Judgment, Tubeileh Loan Agreement and March
Sinostar Loan A greement (“Response”) to add the Business Records Declaration that is attached
as Exhibit1
Supplement to Defendants/Counterclaim Plaintiffs’ Response to Plaintiffs’ Two Motions for
Partial Summary Judgment, Tubeileh Loan A greement and March Sinostar Loan Agreement — 1
CONCLUSION
For the reasons explained in Defendants’ Response, Plaintiffs’ Motions for Partial
Summary Judgment on the Tubeileh Loan A greement and March Sinostar Loan A greement should
be DENIED in all respects, and Defendants should be afforded such other and further relief to
which the Court deems them entitled under the presented facts and circumstances.
Dated: February 15, 2024 Respectfully submitted,
/s/Joshua L. Fellenbaum
TUCKER ELLIS LLP
Joshua L. Fellenbaum (pro hac vice)
Michael C. Zellers (pro hac vice)
Jeffrey C. Sindelar Jr. (pro hac vice)
Stephanie A. Rzepka (Tx. State Bar No. 24102442)
950 Main Avenue Suite 1100
Cleveland, OH 44113
Tel: 216.592.5000
Fax: 216.592.5009
E-mail:joshua.fellenbaum@ tuckerellis.com
michael.zellers@ tuckerellis.com
jeffrey.sindelar@ tuckerellis.com
stephanie.rzepka@ tuckerellis.com
and
Christopher M. Staine
Texas State Bar No. 24104576
CROWE & DUNLEVY
2525 McKinnon St., Ste. 425
Dallas, TX 75201
(214) 420-2143
(214) 736-1763 (Fax)
christopher.staine@ crowedunlevy.com
ATTORNEYS FOR GLOBAL OIL & GAS TEXAS,
LLC AND GLOBAL OIL & GAS FIELDS
OKLAHOMA, LLC
Supplement to Defendants/Counterclaim Plaintiffs’ Response to Plaintiffs’ Two Motions for
Partial Summary Judgment, Tubeileh Loan A greement and March Sinostar Loan Agreement — 2
CERTIFICATE OF SERVICE
I hereby certify that on February 15, 2024, a true and correct copy of this document was
electronically served on all counsel and parties of record through the Court’s e-file system, in
accordance with the Texas Rules of Civil Procedure.
/s/Christopher M. Staine
Christopher M. Staine
Supplement to Defendants/Counterclaim Plaintiffs’ Response to Plaintiffs’ Two Motions for
Partial Summary Judgment, Tubeileh Loan A greement and March Sinostar Loan Agreement — 3
EXHIBIT 1
CAUSE NO. DC-23-07534
BERNARD TUBEILEH and SINOSTAR § IN THE DISTRICT COURT OF
INVESTMENTS LLC, §
Plaintiffs, DALLAS COUNTY, TEXAS
VS.
68th JUDICIAL DISTRICT
GLOBAL OIL & GAS TEXAS, LLC, and
GLOBAL OIL & GAS FIELDS
OKLAHOMA LLC,
Defendants.
and
GLOBAL OIL & GAS TEXAS, LLC, ET §
AL.,
Counterclaim Plaintiffs,
Vv.
BERNARD TUBEILEH, ET AL.,
Counterclaim Defendants.
BUSINESS RECORDS DECLARATION
I, Lori Land, state as follows:
1 My name is Lori Land. I am over 18 years of age, of sound mind, and capable of
making this declaration. The facts stated in this declaration are within my personal knowledge
and are true and correct. I make this declaration in support of the Response to Plaintiffs’ Two
Motions for Partial Summary Judgment, Tubeileh Loan Agreement and March Sinostar Loan
Agreement (“Response”), filed by Global Oil & Gas Texas, LLC and Global Oil & Gas Fields
Oklahoma, LLC.!
' All capitalized terms used but not otherwise defined in this Declaration are fully intended to
have the same meaning given to them in the Response.
1
2 1 am the Operations Manager of Global Oil & Gas Texas, LLC and Global Oil &
Gas Fields Oklahoma, LLC (collectively, the “Global U.S. Subsidiaries” or “Defendants”) and
am familiar with the manner in which Defendants’ records are created and maintained by virtue
of my duties and responsibilities.
3 Attached as Exhibit A to the Response is a true and correct copy of email
correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated February 16, 2023.
4 Attached as Exhibit B to the Response is a true and correct copy of the partially
executed Loan Agreement, dated February 15, 2023, signed by Dr. Detlef Mader and attached to
his email to Bernard Tubeileh, which upon complete execution would become the “February
Sinostar Loan” referred to in the TLA Motion, dated February 15, 2023.
5 Attached as Exhibit C to the Response is a true and correct copy of an email
between Bernard Tubeileh and Lori Land, dated February 16, 2023.
6 Attached as Exhibit D to the Response is a true and correct copy of email
correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated March 14-16, 2023.
7 Attached as Exhibit E to the Response is a true and correct copy of email
correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated March 17, 2023.
8. Attached as Exhibit F to the Response is a true and correct copy of email
correspondence between Bernard Tubeileh and tax advisors, dated May of 2022 through April 17,
2023.
9 Attached as Exhibit G to the Response is a true and correct copy of email
correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated August
26, 2022.
10. Attached as Exhibit H to the Response is a true and correct copy of an
Employment Agreement, signed by Bernard Tubeileh, dated March
31, 2019.
LS Attached as Exhibit I to the Response is a true and correc
t copy of email
8s mere
correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated September 10-11, 2021.
12. Attached as Exhibit J to the Response is a true and correct copy of email
correspondence between Dr. Detlef Mader and Bernard Tubeileh, dated May 13-16, 2022.
13. Attached as Exhibit K to the Response is a true and correct copy of a purported
Employment Agreement, signed by Bernard Tubeileh, dated June 10, 2022.
14, Attached as Exhibit L to the Response is a true and correct copy of an email
between Bernard Tubeileh and Lori Land, dated September 9, 2021.
15. Attached as Exhibit M to the Response is a true and correct copy of email
correspondence between Bernard Tubeileh and tax advisors, dated April 2022 through October
2022.
16. Attached as Exhibit N to the Response is a true and correct copy of email
correspondence between Bernard Tubeileh and tax advisors, dated August 2022 through October
2022.
17. Attached as Exhibit O to the Response is a true and correct copy of a Purchase of
Loan agreement signed by Bernard Tubeileh, dated February 15, 2023.
18. Attached as Exhibit P to the Response is a true and correct copy of a Well
Election Ballot to Participate in the Blackhorn # 2 Well. signed by Bernard Tubeileh, dated April
24, 2023.
19. Attached as Exhibit Q to the Response is a true and correct copy of a Loan
Amendment document between Sinostar and the Global U.S. Subsidiaries, signed by John Barnett
on behalf of Sinostar, dated April 8, 2019.
20. Attached as Exhibit R to the Response is a true and correct copy of a Loan
Agreement between GDT Global Derivative Trading GmbH and Global Oklahoma, dated
February 2, 2017.
21. The above-described Exhibits A-R (collectively, the “Records”) are the original
records or exact duplicates of the original records.
22. It is the regular practice of Defendants to make the Records at or near the time of
each act, event, condition, opinion, or diagnosis that was recorded.
23s It is the regular practice of Defendants for the Records to be made by, or from
information transmitted by, persons with knowledge of the matters set forth in the Records.
24. It is the regular practice of Defendants to keep the Records in the course of
regularly conducted business activity.
25. It is the regular practice of the business activity to make the Records.
26. My name is Lori Land, my date of birth is_ OT [ay | 1979 , and
my business address is 5601 Granite Parkway, Suite 370, Plano, Texas 75024. I declare under
penalty of perjury that the facts stated in this document are true and correct.
Executed in Collin County, Texas, on the 14th day of February, 2024.
Lori LAND
Exhibit A
CAUSE NO. DC-23-07534
BERNARD TUBEILEH and SINOSTAR § IN THE DISTRICT COURT OF
INVESTMENTS LLC, §
Plaintiffs, DALLAS COUNTY, TEXAS
vs.
68th JUDICIAL DISTRICT
GLOBAL OIL & GAS TEXAS, LLC, and
GLOBAL OIL & GAS FIELDS
OKLAHOMA LLC,
Defendants.
and
GLOBAL OIL & GAS TEXAS, LLC, ET
AL.,
Counterclaim Plaintiffs,
¥
BERNARD TUBEILEH, ET AL.,
Counterclaim Defendants.
AFFIDAVIT OF TRANSLATION
STATE OF Illiao's )
SS.
county or CUO e. )
Paul Erling , being duly sworn, deposes and says as follows:
1
I am fluent in the German and English languages, have been translating documents for over 40 years
and am competent to translate from German into English.
My qualifications include Bachelor of Arts Degree from Yale University (studies in German,
Philosophy, and Mathematics), Master of Arts from University of Chicago, Member of the American
Translator’s Association, and translation experience in projects involving Finance, Contracts,
Construction, Environmental, Automotive, Medical Devices, etc.
Ys
I hereby certify that the attached document “Global_0035186-Global_00365187” is, to the best of my
knowledge and belief, a true and accurate translation from German into English.
A.
oe
Sworn to before me this
day of 4 bl ay Translator’s Signature
ill MA ft fy] U jal Seal
EDWARD J LOFTON
Notary Public, State of Illinois
they Pub Commission No. 788596
sy Commission Expires June 26, 2027
Form OPS-QF-011, rev. 1
Message
From: Dr. Detlef Mader [detlef.mader@gog-ag.de]
Sent: 2/16/2023 9:41:49 AM
To: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/en=b8d94f074f324fd48aed43979d20641 c-bernard.tub]
Subject: Re: Sinostar loan
Attachments: SinostarloanAgreement16022023.pdf
Dear Bernard,
Attached please find the signed Sinostar Loan Agreement.
Best regards,
Detlef
On 02/16/2023 at 04:06 AM, Bernard Tubeileh wrote:
Detlef,
The Sinostar loan is US$ 1,227,917.61 as of 02/15/2023;
Since the loan agreement expired on 12/31/2022, it must be renewed as soon as possible.
Attached is the new loan agreement.
Please sign (Global Oil & Gas Texas LLC and Global Oil & Gas Fields Oklahoma LLC) and return to
me.
BG, [Best Regards]
Bernard
Best regards,
Bernard Tubeileh
Head of American Operations
GLOBAL A Oil & Gas AG
Global Oil & Gas Fields
Oklahoma LLC Global Oil &
Gas Texas LLC
5830 Granite Pkwy, Suite #1025
Plano, Texas 75024
Mobile US: +1 918 724 3225
Office US:+ 1214 838 1614
Office DE: +49 (0) 6195 975 4930
Mobile DE: +49 (0) 175 20 4848 9
Email: Bernard.tubeileh@gog-ag.com
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER Global_0035186
_ a
This message may contain confidential information and is intended only for the individual or individuals named. If
you are not a named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender
immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-mail
transmission cannot be guaranteed to be secure or error-free. The sender therefore does not accept liability for
any errors or omissions in the contents of this message that arise as a result of e-mail transmission. This message is
provided for informational purposes and should not be construed as a solicitation.
Virus-free www.avast.com
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER Global_0035187
Message
From: Or. Detlef Mader [detlef.mader@gog-ag.de]
Sent: 2/16/2023 9:41:49 AM
To: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=b8d94f074f324fd48aed43979d20641c-bernard.tub]
Subject: Re: Sinostar loan
Attachments: SinostarLoanAgreement16022023.pdf
Lieber Bernard,
anbei das unterschriebene Sinostar Loan Agreement.
Herzliche GriiRe
Detlef
Am 16.2.2023 um 04:06 schrieb Bernard Tubeileh:
Detlef,
Das Sinostar-Darlehen betragt per 15.2.2023 US$ 1,227,917.61;
Da der Darlehensvertrag am 31.12.22 ausgelaufen war, muss dieser baldméglichst erneuert werden.
Anbei der neue Darlehensvertrag.
Bitte unterschreiben (Global Oil & Gas Texas LLC und Global Oil & Gas Fields Oklahoma LLC) und an mich
zurlickschicken.
BG
Bernard
Best regards
Bernard Tubeileh
Head of American Operations
GLOBAL 8 O11 & Gas as
Global Oil & Gas Fields Oklahoma LLC
Global Oil & Gas Texas LLC
5830 Granite Pkwy, Suite #1025.
Plano, Texas 75024
Mobile US: +1918 724 3225
Office US: +1214 838 1614
Office DE: +49 (0) 6195 975 4930
Mobile DE: +49 (0) 175 20 4848 9
Email: bernard tubeileh @gog-ag.com
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER Global_0035186
~ -
This message may contain confidential information and is intended only for the individual or individuals named. If
you are not a named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender
immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-mail
transmission cannot be guaranteed to be secure or error-free. The sender therefore does not accept liability for
any errors or omissions in the contents of this message that arise as a result of e-mail transmission. This message is
provided for informational purposes and should not be construed as a solicitation.
Virenfrel
wy
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER Global_0035187
CAUSE NO. DC-23-07534
BERNARD TUBEILEH and SINOSTAR IN THE DISTRICT COURT OF
INVESTMENTS LLC,
Plaintiffs, DALLAS COUNTY, TEXAS
Vs.
68th JUDICIAL DISTRICT
GLOBAL OIL & GAS TEXAS, LLC, and
GLOBAL OIL & GAS FIELDS
OKLAHOMA LLC,
Defendants.
and
GLOBAL OIL & GAS TEXAS, LLC, ET
AL.,
Counterclaim Plaintiffs,
v
BERNARD TUBEILEH, ET AL.,
Counterclaim Defendants.
AFFIDAVIT OF TRANSLATION
STATE OF (Ulinois )
58s
COUNTY OF Cook )
Pi ul Erlin: ; being duly sworn, deposes and says as follows:
Iam fluent in the German and English languages, have been translating documents for over 40 years
and am competent to translate from German into English.
My qualifications include Bachelor of Arts Degree from Yale University (studies in German,
Philosophy, and Mathematics), Master of Arts from University of Chicago, Member of the American
Translator’s Association, and translation experience in projects involving Finance, Contracts,
Construction, Environmental, Automotive, Medical Devices, etc.
I hereby certify that the attached document “Global_0045408- Global_0045409” is, to the best of my
knowledge and belief, a true and accurate translation from German into English.
Sworn to before me this
day otk Ma Translator’s Signature
y
td Wy UA]
Official Seal
(Wy EDWARD J LOFTON
Notary Public, State of Illinois
Ot: Pub! ‘Commission No. 788596
my Commission Expires June 26, 2027
Form OPS-QF-011, rev. 1
Message
From: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/en=b8d94f074f324fd48aed43979d20641 c-bernard.tub]
Sent: 2/16/2023 4:19:52 PM
To: Detlef Mader [detlef.mader@gog-ag.de]
Subject: Sinostar
Detlef,
Since Sinostar Investments LLC was dissolved this year and is now managed by me, some small assets are for sale.
| took over the loan completely.
The other assets are:
5.0-7.5% working interests in 18 horizontal wells, generating a total of approximately US$ 5500-6500 per month.
2-5.5% ORRI in 4 oil wells in Texas generating approximately US$2000-3000 per month. The ORRI would extend to all additional
wells drilled in Hardeman County.
| suggest that Global acquires the Ohio WI for market standard 48 months and the Texas ORRIs for market standard
60 months;
That is, US$ 288,000 for Ohio and US$ 150,000 for Texas;
Do you agree?
BG, [Best Regards]
Bernard
Best regards,
Bernard Tubeileh
Head of American Operations
GLOBAL @ ON
& Gas AG
Global Oil & Gas Fields Oklahoma LLC
Global Oil & Gas Texas LLC
5830 Granite Pkwy, Suite #1025
Plano, Texas 75024
Mobile US: +1918 724 3225
Office US: + 1214 838 1614
Office DE: +49 (0) 6195 975 4930
Mobile DE: +49 (0) 175 20 4848 9
Email: ernard.tubeileh@gog-ag.com
- -
This message may contain confidential information and is intended only for the individual or individuals named. If you are nota
Global_0045408
named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you
have received this email by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure
or error-free. The sender therefore does not accept liability for any errors or omissions inthe contents of this message that arise asa
result of e-mail transmission. This message is provided for informational purposes and should not be construed as a solicitation.
Global_0045409
Message
From: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=b8d94f074f324fd48aed43979d20641c-bernard.tub]
Sent: 2/16/2023 4:19:52 PM
To: Detlef Mader [detlef.mader@gog-ag.de]
Subject: Sinostar
Detlef,
Da die Sinostar Investments LLC in diesem Jahr aufgelést wird, und mittlerweile von mir ge-managed wird, stehen einige
kleine Assets zum Verkauf.
Das Darlehen habe ich komplett ibernommen.
Die weitere Assets sind:
5.0-7.5% Working Interests in 18 horizonte Quellen, die insgesamt ca. US$ 5500-6500 pro Monat generieren.
2-5.5% ORRI in 4 Olquellen in Texas, die ca. US$ 2000-3000 pro Monat generieren. Die ORR! wiirden sich auf alle
weiteren Quellen ausdehnen, die in Hardeman County gebohrt werden kénnten.
Ich wiirde vorschlagen, Global akquiriert die Ohio WI fur marktibliche 48 Monate und die Texas ORRIs fiir marktiibliche
60 Monate;
D.h. USS 288,000 fiir Ohio und USS 150,000 fiir Texas;
Bist Du einverstanden ?
BG
Bernard
Best regards
Bernard Tubeileh
Head of American Operations
GLOBAL ® Oi & Gas
AG
Global Oil & Gas Fields Oklahoma LLC
Global Oi! & Gas Texas LLC
5830 Granite Pkwy, Suite #1025
Plano, Texas 75024
Mobile US: +1 918 724 3225
Office US: +1214 838 1614
Office DE: +49 (0) 6195 975 4930
Mobile DE: +49 (0) 175 20 4848 9
Email: bernard.tubeileh@gog-ag.com
This message may contain confidential information and is intended only for the individual or individuals named. If you are not a
Global_0045408
named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you
have received this email by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure
or error-free. The sender therefore does not accept liability for any errors or omissions in the contents of this message that arise as a
result of e-mail transmission. This message is provided for informational purposes and should not be construed as a solicitation.
Global_0045409
Exhibit B
LOAN AGREEMENT
This Loan Agreement (the "Agreement") is entered into as of February 15h, 2023 (the “Effective
Date”), between and among Sinostar Investments LLC, whose address 502 S$ Locust, Skiatook,
Oklahoma 74070 (“Lender”), and Global Oil & Gas Texas LLC, a Texas limited liability company,
whose address is $830 Granite Pkwy, Suite 1025, Plano, Texas 75024 (the “Borrower”), Lender and
the Borrower are each referred to hereinafter as a “Party” and collectively as the “Parties”.
RECITALS
WHEREAS, the Borrower is in the oil and gas industry and has requested that Lender make a
loan and extend other financial assistance to or for the Borrower's benefit with regard to funding its
operations as further set forth herein;
WHEREAS, Lender has agreed to make a loan and to extend financial assistance to the
Borrower in accordance with the terms and conditions set forth in this Agreement.
The parties agree as follows:
1 Loan
* 4
i.i Loan. Subject to the terms of this Agreement, Lender hereby agrees to provide
financing to the Borrower of the principal amount of One Million and Two Hundred and Twenty-
Seven Thousand Nine Hundred and Seventeen and 61/100 Dollars ($1,227,917.61), or so much
thereof as may be disbursed to, or for the benefit of the Borrower by Lender (the “Loan”).
1.2 Note. A Promissory Note in a principal amount not to exceed One Million and Two
Hundred and Twenty-Seven Thousand Nine Hundred and Seventeen and 61/100 Dollars
($1,227,917.61). shall evidence the Loan under this Agreement, executed by the Borrower in a form
mutually satisfactory to Lender and Borrower (the “Note”). The Note shall be executed within
thirty (30) days of the Effective Date.
1.3 Ini Test. The Borrower shall pay Lender interest on the outstanding principal
balance of the Note at a rate equal to Twelve (15.0%) percent per annum, Interest charges shall be
computed on the basis of a month of 30 days for the actual days elapsed in a month, and shall be
paid in arrears.
1.4 Payments. Borrower shall to make US$ 50,000 payments per month, consisting of
the monthly interest due and the balance being principal payments. The entire principal balance
shall be due and payable no later than December 31, 2024. Notwithstanding the foregoing,
Borrower reserves the right to pre-pay any or all of the balance of the Note at any time, without
penalty or premium.
2 Event of Default
ACen ny
Global_0035188
24 Event of Default. Under the terms hereunder and under the Note, Lender may declare
a default and may require payment of amounts evidenced by the Note and required by this Agreement
upon (i) failure of the Borrower to pay amounts due and payable under the Note for a period of ten
(10) days after the due date; (ii) the dissolution or liquidation of the Borrower, or its failure to pay its
debts as they become due, or its admission in writing of its inability to pay its debts generally, or its
making of a general assignment for the benefit of creditors, or institution of a voluntary or involuntary
proceeding for bankruptcy, reorganization, dissolution or liquidation by or against the Borrower
which proceeding shall remain undismissed or unstayed for a period of thirty (30) days or more: or
(iii) failure of the Borrower to comply with any other monetary or non-monetary obligation or
provision in this Agreement for a period of thirty (30) days after written notice of such failure shall
have been given to the Borrower by Lender. Borrower and Global Oil & Gas Fields Oklahoma LLC,
an Oklahoma limited liability company, whose address is 5830 Granite Pkwy, Suite 1025, Plano,
Texas 75024, (*GOGF”) warrant this loan with all of Borrower's and GOGF’s assets; all of
Borrower’s and GOGP’s assets are securitizing this loan.
3 Lender's Rights and Remedies. Upon the occurrence of an event of default, Lender
may do any one or more of the following: :
3.1 Declare the Note to be immediately due and payable.
3.2 Lender's failure to exercise any right, remedy, or option under this Agreement or other
agreement between Lender and the Borrower or delay by Lender in exercising the same will not
operate as a waiver. Lender's rights and remedies hereunder will be cumulative and not exclusive.
4 Miscellaneous.
4] This Agreement cannot be changed or terminated orally. It may only be amended by a
written agreement duly executed by the Borrower and Lender.
42 This Agreement shall inure to the benefit of and bind Lender's and the Borrower's
respective representatives, successors, and assigns; provided, however, that Borrower may not assign
this Agreement or any rights hereunder without Lender’s prior written consent, and any prohibited
assignment shall be absolutely void. Lender shall be permitted to assign this Agreement in whole or
in part.
43 if any provision of this Agreement shall be prohibited or invalid under applicable law,
it shall be ineffective only to such extent, without invalidating the remainder of this Agreement.
44 This Agreement shall be interpreted in accordance with the laws of the State of Texas.
45 In the event of a default under the terms of this Agreement or the Note, the
prevailing party in any legal proceeding brought to enforce such default shall be entitled to recover
court costs and reasonable attorneys’ fees from the non-prevailing party.
4.6 Any notice required hereunder shall be in writing, and addressed to the party to be
notified as follows:
AN
Global_0035189
If to Lender: Sinostar Investments, LLC
502 S. Locust
Skiatook, Oklahoma 74070
If to the Borrower: Global Oil & Gas Texas LLC
5830 Granite Pkwy, Suite 1025
Plano, Texas 75024
or to such other address as each party may designate for itself by like notice.
47 The paragraph titles contained in this Agreement are without substantive meaning and
are not part of the Agreement.
48 This Agreement may be executed in any number of counterparts and by different
parties on separate counterparts each of which, when executed and delivered, shall be deemed to be an
original and all of which, when taken together, shall constitute but one and the same Agreement.
49 The Borrower and Lender acknowledge that this Agreement represents the entire
agreement between Lender and the Borrower, and the terms of such documents may not be
contradicted by evidence of prior, contemporaneous, or subsequent oral agreements that have or will
be exchanged between Lender and the Borrower.
5. WAIVER OF JURY TRIAL
5.1 The Borrower's legal counsel has advised the Borrower that (i) there may be a
constitutional right to a jury trial in connection with any claim, dispute, or lawsuit arising out of
this Agreement, and (ii) such constitutional right may be waived. After consultation with its
counsel (which has included the Borrower's counsel's review of this Agreement), the Borrower
believes that it is in its best interest in this commercial transaction te waive such right.
Accordingly, the Borrower hereby waives the Borrower's right te a jury trial, and further
agrees that the best forum for hearing any claim, dispute, or lawsuit, if any, arising in
connection with this Agreement or the Borrower's relationship with Lender shall be a court of
competent jurisdiction sitting without a jury. Lender hereby waives Lender's right to a jury
trial, and further agrees that the best forum for hearing any claim, dispute, or lawsuit, if any,
arising in connection with this Agreement or Lender's relationship with the Borrower shall be a
court of competent jurisdiction sitting without a jury.
This Agreement shall be deemed to be made, executed and delivered by Borrower and Lender
as of the Effective Date.
BORROWER WARRANTOR & GUARANTOR
Global Oil & Gas Texas LLC Global Oil & Gas Fields Oklahoma LLC
By: QE. PevE! DER By: D22ie ~ FNBZA Le mneen
\ W
t
|
3
V } V VU V/
VV
AG 247, AGSDOSI3
Global_0035190
ns: (LES vena tts; CEES 06a
LENDER
Sinostar Investments, LLC
By: ae
Its:
Global_0035191
Exhibit C
Message
From: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=b8d94f074f324fd48aed43979d20641c-bernard.tub]
Sent: 2/16/2023 9:53:41 PM
To: Lori Land [/o=ExchangeLabs/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=4160fb679e114d24ae4353097fcScfe0-lori.land]
Subject: FW: Sinostar
Lori,
According to my contract, any direct and indirect sales of oil and gas assets from my side have to be offered to Global
first.
As Sinostar will be dissolved, and | indirectly own it, | had to offer the WI in the 18 Ohio wells and the ORRIs in the
Hardeman county wells (which includes the right an ORRI in any future well in Hardeman County) to Global/Dr Mader.
The Adler ORRI will probably be sold to John Miller’s company;
Dr Mader agreed to buy the Ohio WI for USS 288,000 and the Hardeman ORRI (incl all subsequent rights to ORRIs) for
USS 150,000.
It appears that the Kentucky Mineral package will be smaller, c. USS 1.8 mio (not 100% sure yet what the exact size will
be);
The South Texas Minerals will be c. US$ 1.75 mio including a US$ 100,000 commission for BH and Elliot Doyle.
Global should receive USS 4.95 mio in the next 1-2 weeks, so we'll have an extra USS 1.4 mio.
Of this we need to pay the Fatheree 2.
The Rest should be used to catch up on the ORRI purchases from me and the acquisition of the Ohio WI and Hardeman
ORRI from Sinostar.
As soon as | have the exact numbers with regard to the Hopkins county Minerals I’ll let you know;
Bernard
Bernard Tubeileh
Head of American Operations
GLOBAL © Ol & Gas ag
Global Oil & Gas Fields Oklahoma LLC
Global Oil & Gas Texas LLC
5830 Granite Pkwy, Suite #1025
Plano, Texas 75024
Mobile US: +1 918 724 3225
Office US: +1214 838 1614
Office DE: +49 (0) 6195 975 4930
Mobile DE: +49 (0) 175 20 4848 9
Global_0045412
Email: bernard.tubeileh @gog-ag.com
—— ann aa
This message may contain confidential information and is intended only for the individual or individuals named. If you are not a
named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you
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or error-free. The sender therefore does not accept liability for any errors or omissions in the contents of this message that arise as a
result of e-mail transmission. This message is provided for informational purposes and should not be construed as a solicitation.
From: "Dr. Detlef Mader"
Date: Thursday, February 16, 2023 at 10:28 AM
To: Bernard Tubeileh
Subject: Re: Sinostar
Lieber Bernard,
ja, bitte bereite die Transaktionen vor.
Herzliche GriRe
Detlef
Am 16.2.2023 um 17:19 schrieb Bernard Tubeileh:
Detlef,
Da die Sinostar Investments LLC in diesem Jahr aufgelést wird, und mittlerweile von mir ge-managed
wird, stehen einige kleine Assets zum Verkauf.
Das Darlehen habe ich komplett ibernommen.
Die weitere Assets sind:
5.0-7.5% Working Interests in 18 horizonte Quellen, die insgesamt ca. US$ 5500-6500 pro Monat
generieren.
2-5.5% ORRI in 4 Olquellen in Texas, die ca. US$ 2000-3000 pro Monat generieren. Die ORRI wiirden sich
auf alle weiteren Quellen ausdehnen, die in Hardeman County gebohrt werden kénnten.
Ich wiirde vorschlagen, Global akquiriert die Ohio WI fur marktiibliche 48 Monate und die Texas ORRIs
fiir marktiibliche 60 Monate;
D.h. USS 288,000 fiir Ohio und USS 150,000 fiir Texas;
Bist Du einverstanden ?
BG
Bernard
Best regards
Bernard Tubeileh
Global_0045413.
Head of American Operations
GLOBAL 8 CH & Gas AG
Global Oil & Gas Fields Oklahoma LLC
Global Oil & Gas Texas LLC
5830 Granite Pkwy, Suite #1025
Plano, Texas 75024
Mobile US: +1 918 724 3225
Office US: +1214 838 1614
Office DE: +49 (0) 6195 975 4930
Mobile DE: +49 (0) 175 20 4848 9
Email: bernard.tubeileh@gog-ag.com
- anne anne
This message may contain confidential information and is intended only for the individual or individuals named. If
you are not a named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender
immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-mail
transmission cannot be guaranteed to be secure or error-free. The sender therefore does not accept liability for
any errors or omissions in the contents of this message that arise as a result of e-mail transmission. This message is
provided for informational purposes and should not be construed as a solicitation.
Virentrei om
Global_0045414
Exhibit D
CAUSE NO. DC-23-07534
BERNARD TUBEILEH and SINOSTAR IN THE DISTRICT COURT OF
INVESTMENTS LLC,
Plaintiffs, DALLAS COUNTY, TEXAS
vs.
68th JUDICIAL DISTRICT
GLOBAL OIL & GAS TEXAS, LLC, and
GLOBAL OIL & GAS FIELDS
OKLAHOMA LLC,
Defendants.
and
GLOBAL OIL & GAS TEXAS, LLC, ET
AL.,
Counterclaim Plaintiffs,
Vv.
BERNARD TUBEILEH, ET AL.,
Counterclaim Defendants.
AFFIDAVIT OF TRANSLATION
STATE OF UUlints )
jase
county or COdk )
Pa ul Erlin: , being duly sworn, deposes and says as follows:
I am fluent in the German and English languages, have been translating documents for over 40 years
and am competent to translate from German into English.
My qualifications include Bachelor of Arts Degree from Yale University (studies in German,
Philosophy, and Mathematics), Master of Arts from University of Chicago, Member of the American
Translator’s Association, and translation experience in projects involving Finance, Contracts,
Construction, Environmental, Automotive, Medical Devices, etc.
I hereby certify that the attached document “Global_0035715” is, to the best of my knowledge and
belief, a true and accurate translation from German into English.
VI 2.3
x
Sworn to before me this
PVa
day of Translator’s Signature
}U4 We t) A l
Official Seal
EDWARD J LOFT
Notary Public, State ofONIllinois
Commission No. 7885
otal Pub ‘My Commission Expires June 96
26, 2027
Form OPS-QF-011, rev. 1
Message
From: Bernard Tubeileh [bernard.tubeileh@gog-ag.com]
Sent: 3/14/2023 5:10:32 PM
To: Dr. Detlef Mader [detlef.mader@gog-ag.de]
Subject: Loan
Detlef,
As you know, I purchased the Sinostar loan from Sinostar because they want to completely go out
business in the short to medium term (but will still o r short-term bridge financing).
Since Global still owes me around $760k from the sale of ORRIs, and I already have to pay tax on these
proceeds, I er to exceptionally include this amount in the loan agreement instead of a short- +term
payment from limited cash resources. Given the extraordinary payments that would come from the higher
income expected from the minerals packages, Global would be able to repay this increased loan in the
short term in order to avoid interest expenses.
If you agree, I will prepare the documentation;
BG [Best Regards]
Bernard
Sent from my iPhone
Global_0035715
Message
From: Bernard Tubeileh [bernard.tubeileh@gog-ag.com]
Sent: 3/14/2023 5:10:32 PM
To: Dr. Detlef Mader (detlef.mader@gog-ag.de]
Subject: Loan
Detlef,
wie Du weisst habe ich das Sinostar Darlehen von Sinostar erworben, da die sich kurz- bis mittelfristig
aus dem Geschaft ganz zurtickziehen wollen (werden aber noch ein weile kurzfristige Briickenfinanzierungen
machen) .
Da Global mir noch ca $760k aus dem Verkauf von ORRIs schuldet, ich diese Erlése aber hier schon
versteuern muss, biete ich an, statt einer kurzfristigen Auszahlung aus gerade eng bemessenen Cash-
Mitteln, diesen Betrag ausnahmsweise in den Darlehensvertrag mit reinzunehmen. Sobald auBergewohnliche
Zahlungen, wie die aus den schon bald erwarteten héheren Einnahmen aus den Minerals-Paketen reinkommen,
kénnte Global dieses erhéhte Darlehen kurzfristig zuriickzahlen um dem Zinsaufwand zu entgehen.
Falls Du einverstanden bist, wiirde ich die Dokumentation vorbereiten;
BG
Bernard
Sent from my iPhone
Global_0035715.
——— —————
CAUSE NO. DC-23-07534
BERNARD TUBEILEH and SINOSTAR IN THE DISTRICT COURT OF
INVESTMENTS LLC,
Plaintiffs, DALLAS COUNTY, TEXAS
vs.
68th JUDICIAL DISTRICT
GLOBAL OIL & GAS TEXAS, LLC, and
GLOBAL OIL & GAS FIELDS
OKLAHOMA LLC,
Defendants.
and
GLOBAL OIL & GAS TEXAS, LLC, ET
AL.,
Counterclaim Plaintiffs,
v
BERNARD TUBEILEH, ET AL.,
Counterclaim Defendants.
AFFIDAVIT OF TRANSLATION
STATE OF (( \(qois )
COUNTY OF )
Paul Erling , being duly sworn, deposes and says as follows:
ting documents for over 40 years
1 am fluent in the German and English languages, have been transla
and am competent to translate from German into English.
s in German,
My qualification s include Bachelor of Arts Degree from Yale University (studie
ity of Chicago , Membe r of the American
Philosophy, and Mathematics), Master of Arts from Univers
involving Finance , Contracts,
Translator’s Association, and translation experience in projects
etc.
Construction, Environmental, Automotive, Medical Devices,
1 15387” is, to the best of my
I hereby certify that the attached document “Global_0115386-Global_0
Preview
l 2/15/2024 10:32 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Marissa Gomez DEPUTY CAUSE NO. DC-23-07534 BERNARD TUBEILEH andSINOSTAR § IN THE DISTRICT COURT OF INVESTMENTS LLC, Plaintiffs, DALLAS COUNTY, TEXAS vs. 68th JUDICIAL DISTRICT GLOBAL OIL & GAS TEXAS, LLC, and GLOBAL OIL & GAS FIELDS OKLAHOMA LLC, Defendants. and GLOBAL OIL & GAS TEXAS, LLC, ET AL., Counterclaim Plaintiffs, Vv. BERNARD TUBEILEH, ET AL., Counterclaim Defendants. SUPPLEMENT TO DEFENDANTS/COUNTERCLAIM PLAINTIFFS’ RESPONSE TO PLAINTIFFS’ TWO MOTIONS FOR PARTIAL SUMMARY JUDGMENT, TUBEILEH LOANAGREEMENT AND MARCH SINOSTAR LOANAGREEMENT Defendants/Counterclaim Plaintiffs Global Oil & Gas Texas, LLC and Global Oil & Gas Fields Oklahoma, LLC (collectively “Defendants”) file this Supplement to their Response to Plaintiffs’ Two Motions for Partial Summary Judgment, Tubeileh Loan Agreement and March Sinostar Loan A greement (“Response”) to add the Business Records Declaration that is attached as Exhibit1 Supplement to Defendants/Counterclaim Plaintiffs’ Response to Plaintiffs’ Two Motions for Partial Summary Judgment, Tubeileh Loan A greement and March Sinostar Loan Agreement — 1 CONCLUSION For the reasons explained in Defendants’ Response, Plaintiffs’ Motions for Partial Summary Judgment on the Tubeileh Loan A greement and March Sinostar Loan A greement should be DENIED in all respects, and Defendants should be afforded such other and further relief to which the Court deems them entitled under the presented facts and circumstances. Dated: February 15, 2024 Respectfully submitted, /s/Joshua L. Fellenbaum TUCKER ELLIS LLP Joshua L. Fellenbaum (pro hac vice) Michael C. Zellers (pro hac vice) Jeffrey C. Sindelar Jr. (pro hac vice) Stephanie A. Rzepka (Tx. State Bar No. 24102442) 950 Main Avenue Suite 1100 Cleveland, OH 44113 Tel: 216.592.5000 Fax: 216.592.5009 E-mail:joshua.fellenbaum@ tuckerellis.com michael.zellers@ tuckerellis.com jeffrey.sindelar@ tuckerellis.com stephanie.rzepka@ tuckerellis.com and Christopher M. Staine Texas State Bar No. 24104576 CROWE & DUNLEVY 2525 McKinnon St., Ste. 425 Dallas, TX 75201 (214) 420-2143 (214) 736-1763 (Fax) christopher.staine@ crowedunlevy.com ATTORNEYS FOR GLOBAL OIL & GAS TEXAS, LLC AND GLOBAL OIL & GAS FIELDS OKLAHOMA, LLC Supplement to Defendants/Counterclaim Plaintiffs’ Response to Plaintiffs’ Two Motions for Partial Summary Judgment, Tubeileh Loan A greement and March Sinostar Loan Agreement — 2 CERTIFICATE OF SERVICE I hereby certify that on February 15, 2024, a true and correct copy of this document was electronically served on all counsel and parties of record through the Court’s e-file system, in accordance with the Texas Rules of Civil Procedure. /s/Christopher M. Staine Christopher M. Staine Supplement to Defendants/Counterclaim Plaintiffs’ Response to Plaintiffs’ Two Motions for Partial Summary Judgment, Tubeileh Loan A greement and March Sinostar Loan Agreement — 3 EXHIBIT 1 CAUSE NO. DC-23-07534 BERNARD TUBEILEH and SINOSTAR § IN THE DISTRICT COURT OF INVESTMENTS LLC, § Plaintiffs, DALLAS COUNTY, TEXAS VS. 68th JUDICIAL DISTRICT GLOBAL OIL & GAS TEXAS, LLC, and GLOBAL OIL & GAS FIELDS OKLAHOMA LLC, Defendants. and GLOBAL OIL & GAS TEXAS, LLC, ET § AL., Counterclaim Plaintiffs, Vv. BERNARD TUBEILEH, ET AL., Counterclaim Defendants. BUSINESS RECORDS DECLARATION I, Lori Land, state as follows: 1 My name is Lori Land. I am over 18 years of age, of sound mind, and capable of making this declaration. The facts stated in this declaration are within my personal knowledge and are true and correct. I make this declaration in support of the Response to Plaintiffs’ Two Motions for Partial Summary Judgment, Tubeileh Loan Agreement and March Sinostar Loan Agreement (“Response”), filed by Global Oil & Gas Texas, LLC and Global Oil & Gas Fields Oklahoma, LLC.! ' All capitalized terms used but not otherwise defined in this Declaration are fully intended to have the same meaning given to them in the Response. 1 2 1 am the Operations Manager of Global Oil & Gas Texas, LLC and Global Oil & Gas Fields Oklahoma, LLC (collectively, the “Global U.S. Subsidiaries” or “Defendants”) and am familiar with the manner in which Defendants’ records are created and maintained by virtue of my duties and responsibilities. 3 Attached as Exhibit A to the Response is a true and correct copy of email correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated February 16, 2023. 4 Attached as Exhibit B to the Response is a true and correct copy of the partially executed Loan Agreement, dated February 15, 2023, signed by Dr. Detlef Mader and attached to his email to Bernard Tubeileh, which upon complete execution would become the “February Sinostar Loan” referred to in the TLA Motion, dated February 15, 2023. 5 Attached as Exhibit C to the Response is a true and correct copy of an email between Bernard Tubeileh and Lori Land, dated February 16, 2023. 6 Attached as Exhibit D to the Response is a true and correct copy of email correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated March 14-16, 2023. 7 Attached as Exhibit E to the Response is a true and correct copy of email correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated March 17, 2023. 8. Attached as Exhibit F to the Response is a true and correct copy of email correspondence between Bernard Tubeileh and tax advisors, dated May of 2022 through April 17, 2023. 9 Attached as Exhibit G to the Response is a true and correct copy of email correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated August 26, 2022. 10. Attached as Exhibit H to the Response is a true and correct copy of an Employment Agreement, signed by Bernard Tubeileh, dated March 31, 2019. LS Attached as Exhibit I to the Response is a true and correc t copy of email 8s mere correspondence between Bernard Tubeileh and Dr. Detlef Mader, dated September 10-11, 2021. 12. Attached as Exhibit J to the Response is a true and correct copy of email correspondence between Dr. Detlef Mader and Bernard Tubeileh, dated May 13-16, 2022. 13. Attached as Exhibit K to the Response is a true and correct copy of a purported Employment Agreement, signed by Bernard Tubeileh, dated June 10, 2022. 14, Attached as Exhibit L to the Response is a true and correct copy of an email between Bernard Tubeileh and Lori Land, dated September 9, 2021. 15. Attached as Exhibit M to the Response is a true and correct copy of email correspondence between Bernard Tubeileh and tax advisors, dated April 2022 through October 2022. 16. Attached as Exhibit N to the Response is a true and correct copy of email correspondence between Bernard Tubeileh and tax advisors, dated August 2022 through October 2022. 17. Attached as Exhibit O to the Response is a true and correct copy of a Purchase of Loan agreement signed by Bernard Tubeileh, dated February 15, 2023. 18. Attached as Exhibit P to the Response is a true and correct copy of a Well Election Ballot to Participate in the Blackhorn # 2 Well. signed by Bernard Tubeileh, dated April 24, 2023. 19. Attached as Exhibit Q to the Response is a true and correct copy of a Loan Amendment document between Sinostar and the Global U.S. Subsidiaries, signed by John Barnett on behalf of Sinostar, dated April 8, 2019. 20. Attached as Exhibit R to the Response is a true and correct copy of a Loan Agreement between GDT Global Derivative Trading GmbH and Global Oklahoma, dated February 2, 2017. 21. The above-described Exhibits A-R (collectively, the “Records”) are the original records or exact duplicates of the original records. 22. It is the regular practice of Defendants to make the Records at or near the time of each act, event, condition, opinion, or diagnosis that was recorded. 23s It is the regular practice of Defendants for the Records to be made by, or from information transmitted by, persons with knowledge of the matters set forth in the Records. 24. It is the regular practice of Defendants to keep the Records in the course of regularly conducted business activity. 25. It is the regular practice of the business activity to make the Records. 26. My name is Lori Land, my date of birth is_ OT [ay | 1979 , and my business address is 5601 Granite Parkway, Suite 370, Plano, Texas 75024. I declare under penalty of perjury that the facts stated in this document are true and correct. Executed in Collin County, Texas, on the 14th day of February, 2024. Lori LAND Exhibit A CAUSE NO. DC-23-07534 BERNARD TUBEILEH and SINOSTAR § IN THE DISTRICT COURT OF INVESTMENTS LLC, § Plaintiffs, DALLAS COUNTY, TEXAS vs. 68th JUDICIAL DISTRICT GLOBAL OIL & GAS TEXAS, LLC, and GLOBAL OIL & GAS FIELDS OKLAHOMA LLC, Defendants. and GLOBAL OIL & GAS TEXAS, LLC, ET AL., Counterclaim Plaintiffs, ¥ BERNARD TUBEILEH, ET AL., Counterclaim Defendants. AFFIDAVIT OF TRANSLATION STATE OF Illiao's ) SS. county or CUO e. ) Paul Erling , being duly sworn, deposes and says as follows: 1 I am fluent in the German and English languages, have been translating documents for over 40 years and am competent to translate from German into English. My qualifications include Bachelor of Arts Degree from Yale University (studies in German, Philosophy, and Mathematics), Master of Arts from University of Chicago, Member of the American Translator’s Association, and translation experience in projects involving Finance, Contracts, Construction, Environmental, Automotive, Medical Devices, etc. Ys I hereby certify that the attached document “Global_0035186-Global_00365187” is, to the best of my knowledge and belief, a true and accurate translation from German into English. A. oe Sworn to before me this day of 4 bl ay Translator’s Signature ill MA ft fy] U jal Seal EDWARD J LOFTON Notary Public, State of Illinois they Pub Commission No. 788596 sy Commission Expires June 26, 2027 Form OPS-QF-011, rev. 1 Message From: Dr. Detlef Mader [detlef.mader@gog-ag.de] Sent: 2/16/2023 9:41:49 AM To: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/en=b8d94f074f324fd48aed43979d20641 c-bernard.tub] Subject: Re: Sinostar loan Attachments: SinostarloanAgreement16022023.pdf Dear Bernard, Attached please find the signed Sinostar Loan Agreement. Best regards, Detlef On 02/16/2023 at 04:06 AM, Bernard Tubeileh wrote: Detlef, The Sinostar loan is US$ 1,227,917.61 as of 02/15/2023; Since the loan agreement expired on 12/31/2022, it must be renewed as soon as possible. Attached is the new loan agreement. Please sign (Global Oil & Gas Texas LLC and Global Oil & Gas Fields Oklahoma LLC) and return to me. BG, [Best Regards] Bernard Best regards, Bernard Tubeileh Head of American Operations GLOBAL A Oil & Gas AG Global Oil & Gas Fields Oklahoma LLC Global Oil & Gas Texas LLC 5830 Granite Pkwy, Suite #1025 Plano, Texas 75024 Mobile US: +1 918 724 3225 Office US:+ 1214 838 1614 Office DE: +49 (0) 6195 975 4930 Mobile DE: +49 (0) 175 20 4848 9 Email: Bernard.tubeileh@gog-ag.com CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER Global_0035186 _ a This message may contain confidential information and is intended only for the individual or individuals named. If you are not a named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free. The sender therefore does not accept liability for any errors or omissions in the contents of this message that arise as a result of e-mail transmission. This message is provided for informational purposes and should not be construed as a solicitation. Virus-free www.avast.com CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER Global_0035187 Message From: Or. Detlef Mader [detlef.mader@gog-ag.de] Sent: 2/16/2023 9:41:49 AM To: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=b8d94f074f324fd48aed43979d20641c-bernard.tub] Subject: Re: Sinostar loan Attachments: SinostarLoanAgreement16022023.pdf Lieber Bernard, anbei das unterschriebene Sinostar Loan Agreement. Herzliche GriiRe Detlef Am 16.2.2023 um 04:06 schrieb Bernard Tubeileh: Detlef, Das Sinostar-Darlehen betragt per 15.2.2023 US$ 1,227,917.61; Da der Darlehensvertrag am 31.12.22 ausgelaufen war, muss dieser baldméglichst erneuert werden. Anbei der neue Darlehensvertrag. Bitte unterschreiben (Global Oil & Gas Texas LLC und Global Oil & Gas Fields Oklahoma LLC) und an mich zurlickschicken. BG Bernard Best regards Bernard Tubeileh Head of American Operations GLOBAL 8 O11 & Gas as Global Oil & Gas Fields Oklahoma LLC Global Oil & Gas Texas LLC 5830 Granite Pkwy, Suite #1025. Plano, Texas 75024 Mobile US: +1918 724 3225 Office US: +1214 838 1614 Office DE: +49 (0) 6195 975 4930 Mobile DE: +49 (0) 175 20 4848 9 Email: bernard tubeileh @gog-ag.com CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER Global_0035186 ~ - This message may contain confidential information and is intended only for the individual or individuals named. If you are not a named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free. The sender therefore does not accept liability for any errors or omissions in the contents of this message that arise as a result of e-mail transmission. This message is provided for informational purposes and should not be construed as a solicitation. Virenfrel wy CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER Global_0035187 CAUSE NO. DC-23-07534 BERNARD TUBEILEH and SINOSTAR IN THE DISTRICT COURT OF INVESTMENTS LLC, Plaintiffs, DALLAS COUNTY, TEXAS Vs. 68th JUDICIAL DISTRICT GLOBAL OIL & GAS TEXAS, LLC, and GLOBAL OIL & GAS FIELDS OKLAHOMA LLC, Defendants. and GLOBAL OIL & GAS TEXAS, LLC, ET AL., Counterclaim Plaintiffs, v BERNARD TUBEILEH, ET AL., Counterclaim Defendants. AFFIDAVIT OF TRANSLATION STATE OF (Ulinois ) 58s COUNTY OF Cook ) Pi ul Erlin: ; being duly sworn, deposes and says as follows: Iam fluent in the German and English languages, have been translating documents for over 40 years and am competent to translate from German into English. My qualifications include Bachelor of Arts Degree from Yale University (studies in German, Philosophy, and Mathematics), Master of Arts from University of Chicago, Member of the American Translator’s Association, and translation experience in projects involving Finance, Contracts, Construction, Environmental, Automotive, Medical Devices, etc. I hereby certify that the attached document “Global_0045408- Global_0045409” is, to the best of my knowledge and belief, a true and accurate translation from German into English. Sworn to before me this day otk Ma Translator’s Signature y td Wy UA] Official Seal (Wy EDWARD J LOFTON Notary Public, State of Illinois Ot: Pub! ‘Commission No. 788596 my Commission Expires June 26, 2027 Form OPS-QF-011, rev. 1 Message From: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/en=b8d94f074f324fd48aed43979d20641 c-bernard.tub] Sent: 2/16/2023 4:19:52 PM To: Detlef Mader [detlef.mader@gog-ag.de] Subject: Sinostar Detlef, Since Sinostar Investments LLC was dissolved this year and is now managed by me, some small assets are for sale. | took over the loan completely. The other assets are: 5.0-7.5% working interests in 18 horizontal wells, generating a total of approximately US$ 5500-6500 per month. 2-5.5% ORRI in 4 oil wells in Texas generating approximately US$2000-3000 per month. The ORRI would extend to all additional wells drilled in Hardeman County. | suggest that Global acquires the Ohio WI for market standard 48 months and the Texas ORRIs for market standard 60 months; That is, US$ 288,000 for Ohio and US$ 150,000 for Texas; Do you agree? BG, [Best Regards] Bernard Best regards, Bernard Tubeileh Head of American Operations GLOBAL @ ON & Gas AG Global Oil & Gas Fields Oklahoma LLC Global Oil & Gas Texas LLC 5830 Granite Pkwy, Suite #1025 Plano, Texas 75024 Mobile US: +1918 724 3225 Office US: + 1214 838 1614 Office DE: +49 (0) 6195 975 4930 Mobile DE: +49 (0) 175 20 4848 9 Email: ernard.tubeileh@gog-ag.com - - This message may contain confidential information and is intended only for the individual or individuals named. If you are nota Global_0045408 named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free. The sender therefore does not accept liability for any errors or omissions inthe contents of this message that arise asa result of e-mail transmission. This message is provided for informational purposes and should not be construed as a solicitation. Global_0045409 Message From: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=b8d94f074f324fd48aed43979d20641c-bernard.tub] Sent: 2/16/2023 4:19:52 PM To: Detlef Mader [detlef.mader@gog-ag.de] Subject: Sinostar Detlef, Da die Sinostar Investments LLC in diesem Jahr aufgelést wird, und mittlerweile von mir ge-managed wird, stehen einige kleine Assets zum Verkauf. Das Darlehen habe ich komplett ibernommen. Die weitere Assets sind: 5.0-7.5% Working Interests in 18 horizonte Quellen, die insgesamt ca. US$ 5500-6500 pro Monat generieren. 2-5.5% ORRI in 4 Olquellen in Texas, die ca. US$ 2000-3000 pro Monat generieren. Die ORR! wiirden sich auf alle weiteren Quellen ausdehnen, die in Hardeman County gebohrt werden kénnten. Ich wiirde vorschlagen, Global akquiriert die Ohio WI fur marktibliche 48 Monate und die Texas ORRIs fiir marktiibliche 60 Monate; D.h. USS 288,000 fiir Ohio und USS 150,000 fiir Texas; Bist Du einverstanden ? BG Bernard Best regards Bernard Tubeileh Head of American Operations GLOBAL ® Oi & Gas AG Global Oil & Gas Fields Oklahoma LLC Global Oi! & Gas Texas LLC 5830 Granite Pkwy, Suite #1025 Plano, Texas 75024 Mobile US: +1 918 724 3225 Office US: +1214 838 1614 Office DE: +49 (0) 6195 975 4930 Mobile DE: +49 (0) 175 20 4848 9 Email: bernard.tubeileh@gog-ag.com This message may contain confidential information and is intended only for the individual or individuals named. If you are not a Global_0045408 named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free. The sender therefore does not accept liability for any errors or omissions in the contents of this message that arise as a result of e-mail transmission. This message is provided for informational purposes and should not be construed as a solicitation. Global_0045409 Exhibit B LOAN AGREEMENT This Loan Agreement (the "Agreement") is entered into as of February 15h, 2023 (the “Effective Date”), between and among Sinostar Investments LLC, whose address 502 S$ Locust, Skiatook, Oklahoma 74070 (“Lender”), and Global Oil & Gas Texas LLC, a Texas limited liability company, whose address is $830 Granite Pkwy, Suite 1025, Plano, Texas 75024 (the “Borrower”), Lender and the Borrower are each referred to hereinafter as a “Party” and collectively as the “Parties”. RECITALS WHEREAS, the Borrower is in the oil and gas industry and has requested that Lender make a loan and extend other financial assistance to or for the Borrower's benefit with regard to funding its operations as further set forth herein; WHEREAS, Lender has agreed to make a loan and to extend financial assistance to the Borrower in accordance with the terms and conditions set forth in this Agreement. The parties agree as follows: 1 Loan * 4 i.i Loan. Subject to the terms of this Agreement, Lender hereby agrees to provide financing to the Borrower of the principal amount of One Million and Two Hundred and Twenty- Seven Thousand Nine Hundred and Seventeen and 61/100 Dollars ($1,227,917.61), or so much thereof as may be disbursed to, or for the benefit of the Borrower by Lender (the “Loan”). 1.2 Note. A Promissory Note in a principal amount not to exceed One Million and Two Hundred and Twenty-Seven Thousand Nine Hundred and Seventeen and 61/100 Dollars ($1,227,917.61). shall evidence the Loan under this Agreement, executed by the Borrower in a form mutually satisfactory to Lender and Borrower (the “Note”). The Note shall be executed within thirty (30) days of the Effective Date. 1.3 Ini Test. The Borrower shall pay Lender interest on the outstanding principal balance of the Note at a rate equal to Twelve (15.0%) percent per annum, Interest charges shall be computed on the basis of a month of 30 days for the actual days elapsed in a month, and shall be paid in arrears. 1.4 Payments. Borrower shall to make US$ 50,000 payments per month, consisting of the monthly interest due and the balance being principal payments. The entire principal balance shall be due and payable no later than December 31, 2024. Notwithstanding the foregoing, Borrower reserves the right to pre-pay any or all of the balance of the Note at any time, without penalty or premium. 2 Event of Default ACen ny Global_0035188 24 Event of Default. Under the terms hereunder and under the Note, Lender may declare a default and may require payment of amounts evidenced by the Note and required by this Agreement upon (i) failure of the Borrower to pay amounts due and payable under the Note for a period of ten (10) days after the due date; (ii) the dissolution or liquidation of the Borrower, or its failure to pay its debts as they become due, or its admission in writing of its inability to pay its debts generally, or its making of a general assignment for the benefit of creditors, or institution of a voluntary or involuntary proceeding for bankruptcy, reorganization, dissolution or liquidation by or against the Borrower which proceeding shall remain undismissed or unstayed for a period of thirty (30) days or more: or (iii) failure of the Borrower to comply with any other monetary or non-monetary obligation or provision in this Agreement for a period of thirty (30) days after written notice of such failure shall have been given to the Borrower by Lender. Borrower and Global Oil & Gas Fields Oklahoma LLC, an Oklahoma limited liability company, whose address is 5830 Granite Pkwy, Suite 1025, Plano, Texas 75024, (*GOGF”) warrant this loan with all of Borrower's and GOGF’s assets; all of Borrower’s and GOGP’s assets are securitizing this loan. 3 Lender's Rights and Remedies. Upon the occurrence of an event of default, Lender may do any one or more of the following: : 3.1 Declare the Note to be immediately due and payable. 3.2 Lender's failure to exercise any right, remedy, or option under this Agreement or other agreement between Lender and the Borrower or delay by Lender in exercising the same will not operate as a waiver. Lender's rights and remedies hereunder will be cumulative and not exclusive. 4 Miscellaneous. 4] This Agreement cannot be changed or terminated orally. It may only be amended by a written agreement duly executed by the Borrower and Lender. 42 This Agreement shall inure to the benefit of and bind Lender's and the Borrower's respective representatives, successors, and assigns; provided, however, that Borrower may not assign this Agreement or any rights hereunder without Lender’s prior written consent, and any prohibited assignment shall be absolutely void. Lender shall be permitted to assign this Agreement in whole or in part. 43 if any provision of this Agreement shall be prohibited or invalid under applicable law, it shall be ineffective only to such extent, without invalidating the remainder of this Agreement. 44 This Agreement shall be interpreted in accordance with the laws of the State of Texas. 45 In the event of a default under the terms of this Agreement or the Note, the prevailing party in any legal proceeding brought to enforce such default shall be entitled to recover court costs and reasonable attorneys’ fees from the non-prevailing party. 4.6 Any notice required hereunder shall be in writing, and addressed to the party to be notified as follows: AN Global_0035189 If to Lender: Sinostar Investments, LLC 502 S. Locust Skiatook, Oklahoma 74070 If to the Borrower: Global Oil & Gas Texas LLC 5830 Granite Pkwy, Suite 1025 Plano, Texas 75024 or to such other address as each party may designate for itself by like notice. 47 The paragraph titles contained in this Agreement are without substantive meaning and are not part of the Agreement. 48 This Agreement may be executed in any number of counterparts and by different parties on separate counterparts each of which, when executed and delivered, shall be deemed to be an original and all of which, when taken together, shall constitute but one and the same Agreement. 49 The Borrower and Lender acknowledge that this Agreement represents the entire agreement between Lender and the Borrower, and the terms of such documents may not be contradicted by evidence of prior, contemporaneous, or subsequent oral agreements that have or will be exchanged between Lender and the Borrower. 5. WAIVER OF JURY TRIAL 5.1 The Borrower's legal counsel has advised the Borrower that (i) there may be a constitutional right to a jury trial in connection with any claim, dispute, or lawsuit arising out of this Agreement, and (ii) such constitutional right may be waived. After consultation with its counsel (which has included the Borrower's counsel's review of this Agreement), the Borrower believes that it is in its best interest in this commercial transaction te waive such right. Accordingly, the Borrower hereby waives the Borrower's right te a jury trial, and further agrees that the best forum for hearing any claim, dispute, or lawsuit, if any, arising in connection with this Agreement or the Borrower's relationship with Lender shall be a court of competent jurisdiction sitting without a jury. Lender hereby waives Lender's right to a jury trial, and further agrees that the best forum for hearing any claim, dispute, or lawsuit, if any, arising in connection with this Agreement or Lender's relationship with the Borrower shall be a court of competent jurisdiction sitting without a jury. This Agreement shall be deemed to be made, executed and delivered by Borrower and Lender as of the Effective Date. BORROWER WARRANTOR & GUARANTOR Global Oil & Gas Texas LLC Global Oil & Gas Fields Oklahoma LLC By: QE. PevE! DER By: D22ie ~ FNBZA Le mneen \ W t | 3 V } V VU V/ VV AG 247, AGSDOSI3 Global_0035190 ns: (LES vena tts; CEES 06a LENDER Sinostar Investments, LLC By: ae Its: Global_0035191 Exhibit C Message From: Bernard Tubeileh [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=b8d94f074f324fd48aed43979d20641c-bernard.tub] Sent: 2/16/2023 9:53:41 PM To: Lori Land [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=4160fb679e114d24ae4353097fcScfe0-lori.land] Subject: FW: Sinostar Lori, According to my contract, any direct and indirect sales of oil and gas assets from my side have to be offered to Global first. As Sinostar will be dissolved, and | indirectly own it, | had to offer the WI in the 18 Ohio wells and the ORRIs in the Hardeman county wells (which includes the right an ORRI in any future well in Hardeman County) to Global/Dr Mader. The Adler ORRI will probably be sold to John Miller’s company; Dr Mader agreed to buy the Ohio WI for USS 288,000 and the Hardeman ORRI (incl all subsequent rights to ORRIs) for USS 150,000. It appears that the Kentucky Mineral package will be smaller, c. USS 1.8 mio (not 100% sure yet what the exact size will be); The South Texas Minerals will be c. US$ 1.75 mio including a US$ 100,000 commission for BH and Elliot Doyle. Global should receive USS 4.95 mio in the next 1-2 weeks, so we'll have an extra USS 1.4 mio. Of this we need to pay the Fatheree 2. The Rest should be used to catch up on the ORRI purchases from me and the acquisition of the Ohio WI and Hardeman ORRI from Sinostar. As soon as | have the exact numbers with regard to the Hopkins county Minerals I’ll let you know; Bernard Bernard Tubeileh Head of American Operations GLOBAL © Ol & Gas ag Global Oil & Gas Fields Oklahoma LLC Global Oil & Gas Texas LLC 5830 Granite Pkwy, Suite #1025 Plano, Texas 75024 Mobile US: +1 918 724 3225 Office US: +1214 838 1614 Office DE: +49 (0) 6195 975 4930 Mobile DE: +49 (0) 175 20 4848 9 Global_0045412 Email: bernard.tubeileh @gog-ag.com —— ann aa This message may contain confidential information and is intended only for the individual or individuals named. If you are not a named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free. The sender therefore does not accept liability for any errors or omissions in the contents of this message that arise as a result of e-mail transmission. This message is provided for informational purposes and should not be construed as a solicitation. From: "Dr. Detlef Mader" Date: Thursday, February 16, 2023 at 10:28 AM To: Bernard Tubeileh Subject: Re: Sinostar Lieber Bernard, ja, bitte bereite die Transaktionen vor. Herzliche GriRe Detlef Am 16.2.2023 um 17:19 schrieb Bernard Tubeileh: Detlef, Da die Sinostar Investments LLC in diesem Jahr aufgelést wird, und mittlerweile von mir ge-managed wird, stehen einige kleine Assets zum Verkauf. Das Darlehen habe ich komplett ibernommen. Die weitere Assets sind: 5.0-7.5% Working Interests in 18 horizonte Quellen, die insgesamt ca. US$ 5500-6500 pro Monat generieren. 2-5.5% ORRI in 4 Olquellen in Texas, die ca. US$ 2000-3000 pro Monat generieren. Die ORRI wiirden sich auf alle weiteren Quellen ausdehnen, die in Hardeman County gebohrt werden kénnten. Ich wiirde vorschlagen, Global akquiriert die Ohio WI fur marktiibliche 48 Monate und die Texas ORRIs fiir marktiibliche 60 Monate; D.h. USS 288,000 fiir Ohio und USS 150,000 fiir Texas; Bist Du einverstanden ? BG Bernard Best regards Bernard Tubeileh Global_0045413. Head of American Operations GLOBAL 8 CH & Gas AG Global Oil & Gas Fields Oklahoma LLC Global Oil & Gas Texas LLC 5830 Granite Pkwy, Suite #1025 Plano, Texas 75024 Mobile US: +1 918 724 3225 Office US: +1214 838 1614 Office DE: +49 (0) 6195 975 4930 Mobile DE: +49 (0) 175 20 4848 9 Email: bernard.tubeileh@gog-ag.com - anne anne This message may contain confidential information and is intended only for the individual or individuals named. If you are not a named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free. The sender therefore does not accept liability for any errors or omissions in the contents of this message that arise as a result of e-mail transmission. This message is provided for informational purposes and should not be construed as a solicitation. Virentrei om Global_0045414 Exhibit D CAUSE NO. DC-23-07534 BERNARD TUBEILEH and SINOSTAR IN THE DISTRICT COURT OF INVESTMENTS LLC, Plaintiffs, DALLAS COUNTY, TEXAS vs. 68th JUDICIAL DISTRICT GLOBAL OIL & GAS TEXAS, LLC, and GLOBAL OIL & GAS FIELDS OKLAHOMA LLC, Defendants. and GLOBAL OIL & GAS TEXAS, LLC, ET AL., Counterclaim Plaintiffs, Vv. BERNARD TUBEILEH, ET AL., Counterclaim Defendants. AFFIDAVIT OF TRANSLATION STATE OF UUlints ) jase county or COdk ) Pa ul Erlin: , being duly sworn, deposes and says as follows: I am fluent in the German and English languages, have been translating documents for over 40 years and am competent to translate from German into English. My qualifications include Bachelor of Arts Degree from Yale University (studies in German, Philosophy, and Mathematics), Master of Arts from University of Chicago, Member of the American Translator’s Association, and translation experience in projects involving Finance, Contracts, Construction, Environmental, Automotive, Medical Devices, etc. I hereby certify that the attached document “Global_0035715” is, to the best of my knowledge and belief, a true and accurate translation from German into English. VI 2.3 x Sworn to before me this PVa day of Translator’s Signature }U4 We t) A l Official Seal EDWARD J LOFT Notary Public, State ofONIllinois Commission No. 7885 otal Pub ‘My Commission Expires June 96 26, 2027 Form OPS-QF-011, rev. 1 Message From: Bernard Tubeileh [bernard.tubeileh@gog-ag.com] Sent: 3/14/2023 5:10:32 PM To: Dr. Detlef Mader [detlef.mader@gog-ag.de] Subject: Loan Detlef, As you know, I purchased the Sinostar loan from Sinostar because they want to completely go out business in the short to medium term (but will still o r short-term bridge financing). Since Global still owes me around $760k from the sale of ORRIs, and I already have to pay tax on these proceeds, I er to exceptionally include this amount in the loan agreement instead of a short- +term payment from limited cash resources. Given the extraordinary payments that would come from the higher income expected from the minerals packages, Global would be able to repay this increased loan in the short term in order to avoid interest expenses. If you agree, I will prepare the documentation; BG [Best Regards] Bernard Sent from my iPhone Global_0035715 Message From: Bernard Tubeileh [bernard.tubeileh@gog-ag.com] Sent: 3/14/2023 5:10:32 PM To: Dr. Detlef Mader (detlef.mader@gog-ag.de] Subject: Loan Detlef, wie Du weisst habe ich das Sinostar Darlehen von Sinostar erworben, da die sich kurz- bis mittelfristig aus dem Geschaft ganz zurtickziehen wollen (werden aber noch ein weile kurzfristige Briickenfinanzierungen machen) . Da Global mir noch ca $760k aus dem Verkauf von ORRIs schuldet, ich diese Erlése aber hier schon versteuern muss, biete ich an, statt einer kurzfristigen Auszahlung aus gerade eng bemessenen Cash- Mitteln, diesen Betrag ausnahmsweise in den Darlehensvertrag mit reinzunehmen. Sobald auBergewohnliche Zahlungen, wie die aus den schon bald erwarteten héheren Einnahmen aus den Minerals-Paketen reinkommen, kénnte Global dieses erhéhte Darlehen kurzfristig zuriickzahlen um dem Zinsaufwand zu entgehen. Falls Du einverstanden bist, wiirde ich die Dokumentation vorbereiten; BG Bernard Sent from my iPhone Global_0035715. ——— ————— CAUSE NO. DC-23-07534 BERNARD TUBEILEH and SINOSTAR IN THE DISTRICT COURT OF INVESTMENTS LLC, Plaintiffs, DALLAS COUNTY, TEXAS vs. 68th JUDICIAL DISTRICT GLOBAL OIL & GAS TEXAS, LLC, and GLOBAL OIL & GAS FIELDS OKLAHOMA LLC, Defendants. and GLOBAL OIL & GAS TEXAS, LLC, ET AL., Counterclaim Plaintiffs, v BERNARD TUBEILEH, ET AL., Counterclaim Defendants. AFFIDAVIT OF TRANSLATION STATE OF (( \(qois ) COUNTY OF ) Paul Erling , being duly sworn, deposes and says as follows: ting documents for over 40 years 1 am fluent in the German and English languages, have been transla and am competent to translate from German into English. s in German, My qualification s include Bachelor of Arts Degree from Yale University (studie ity of Chicago , Membe r of the American Philosophy, and Mathematics), Master of Arts from Univers involving Finance , Contracts, Translator’s Association, and translation experience in projects etc. Construction, Environmental, Automotive, Medical Devices, 1 15387” is, to the best of my I hereby certify that the attached document “Global_0115386-Global_0