[Strömberg]: Notice of Intended Prosecution

[Connor]

Security Classification: SECURE
Document Classification and Security Act 1995
Encrypted by the Strömberg International Legal Consultants​

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NOTICE OF INTENDED PROSECUTION - LETTER BEFORE CLAIM​

To whom it may concern within the Russian Ministry of Defence,

Our law firm, Strömberg International Legal Consultants, represents our client the Office of Financial Markets and Defence Procurement Administration of the Department of Finance and Department of Defence in Sweden respectively in the interest of points of law. If you are represented by legal counsel, please direct this letter to your respective lawyers immediately and have them notify us of such representation. It should be noted that all correspondence is to go via our firm and you should not contact our client in reference to this letter.

It has been brought to our attention that the sale of three Oscar-class Cruise Missile Submarines (also known as Project 949 Granit Submarine) was not supplied as part of an expected defence sale dated April 1998. A substantial sum of monies to the amount of $3,901,704,960.00 remains outstanding and awaiting full refund to the aforementioned clients.

I am duty-bound to inform you that Strömberg International Legal Consultants has collated a significant amount of evidence (including financial data and physical advertisement) that we intend to take to civil court should this not be actioned immediately.

We demand that you provide us with written assurance within three days of receiving this letter that a full refund has been made payable to the Kingdom of Sweden. If you fail to comply with the demand, our client is entitled to use your failure to comply as evidence of wilful infringement and seek monetary damages and equitable relief for your actions via the judicial system. If in the event that you fail to communicate with us, please be advised that our client has asked us to communicate to you that it will be looking to pursue all available legal remedies and should we be forced to go via the judicial system they will be requesting court costs, counsel fees and other appropriate expenses. Your liability and exposure under such legal action could be considerable and will likely result in a monetary loss which we will pursue. We will be acting on behalf of our client and any further correspondence will be official, on behalf of our client and the judicial system of our choosing.

Before taking legal action, however, my client wishes to give you one opportunity to make full payment by following the instruction given within this letter.

We acknowledge that this sale was made by the former JSC Rosoboronexport which, by content still publicly available, was recognised as 'Russia’s only state-controlled intermediary in the area of exports and imports of the entire range of military and double-purpose products, technologies and services' making your government solely liable for this debt.

I look forward to hearing from you.

Regards.
Sven Hansson
Head of State Practice
Strömberg International Legal Consultants

@John

 

[John]

Office of the Ministry of Defence for the Russian Empire
Message to the United States of America
Private & Encrypted

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To: Sven Hansson, Head of State Practice, Strömberg International Legal Consultants (Connor)
From: Marshal Igor Sergeyev, Minister of Defence of the Russian Empire

To Mr. Hansson,

Thank you for contacting me regarding this urgent matter. As with the change of leadership in Russia, so did too the leadership of Rosoboronexport and therefore it took some digging for us to find the order you are refering to.

After a thorough investigation we have concluded that Rosoboronexport, and by extension the Russian Ministry of Defence, is at fault for this and we are willing to follow through with a full refund on your order. However, the claim is for $3,901,704,960.00. The price of the x3 Oscar-class submarines came to $3,601,704,960.00.

So building on this, it is my assumption that you are also trying to claim the $300,000,000.00 payment made to become a partner of Rosoboronexport. As such, I would like to make you aware of the following statement, which is clearly posted on the Rosoboronexport advertisement and website:

"Partnership
Partners is the term used by Rosoboronexport for nations with special status under Russia's export policy. Partners are nations that Russia considers close allies with the Kremlin and as such Partners have access to products which non-partners do not and as such can purchase more advanced equipment.

Alternatively, nations can purchase a Partnership Account with Rosoboronexport for a one-time payment of 300,000,000.00$ and be granted access to all partnership products without having to be considered an ally of Russia. Do keep in mind, however, that the partnership of a nation can be denied or terminated at any time without proper explanation. The one time payment of 300,000,000.00$ is non-refundable.

By purchasing a Partnership Account you are agreeing to these terms."

Sweden agreed to the terms set forth by purchasing a partnership and therefore understands that the partnership can not be refunded.

To close, we are happy to refund your payment of $3,601,704,960.00 - or we are willing to construct the x3 Oscar-class submarines for your navy anyway.

I look forward to your response.

Kindest Regards,
Marshal Igor Sergeyev
Minister of Defence
Russian Empire

 

[Connor]

Security Classification: SECURE
Document Classification and Security Act 1995
Encrypted by the Strömberg International Legal Consultants​

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Dear Marshal Igor Sergeyev,

Thank you for your prompt response to our letter, we are pleased that you have accepted liability for the contractual obligations of the Oscar-class Cruise Missile Submarines (also known as Project 949 Granit Submarine). I have liaised with our client who has confirmed that they are not part of the Rosboronexport Partnership programme and had not paid for, subscribed, registered or contractually agreed to any part of this arrangement as a result of this order. Our client has provided evidence to this effect. Our own findings, coupled with your correspondence, identify that the remaining $300,000,000.00 you dispute is likely a 10% markup on the production value of the assets purchased.

However, with this being said, our client is happy to accept a settlement of $3,601,704,960.00 monetary transfer. The remaining $300,000,000.00 will go undisputed by our client and the debt seen as resolved in totality thus this dispute cannot be resurrected in the future, providing the settlement is paid in full.

Regards.
Sven Hansson
Head of State Practice
Strömberg International Legal Consultants

@John

 

[John]

Office of the Ministry of Defence for the Russian Empire
Message to the United States of America
Private & Encrypted

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To: Sven Hansson, Head of State Practice, Strömberg International Legal Consultants (Connor)
From: Marshal Igor Sergeyev, Minister of Defence of the Russian Empire

To Mr. Hansson,

I am writing this to inform you that a wire has been sent for a total sum of $3,601,704,960.00.

I would like to take this moment to send my apologies on behalf of the Russian Government and Rosoboronexport for this mistake and I do hope that it does not prevent future business between Sweden and Russia.

Kindest Regards,
Marshal Igor Sergeyev
Minister of Defence
Russian Empire