From: Shapiro, Hal ‘To: Yousef Al Otalba Ce: Richard Miniz'; Magi Elawad' ‘Sent: Thu Mar 29 16:41:35 2012 ‘Subject RE: Legal Acton against Abu Dhabi Group CONFIDENTIAL and PRIVILEGED ‘Suggested Next Steps Legal Stops 1. The Abu Ohabi Group (and te owners and related entities) andthe Pakistani banks (Bank Afalh and United Bark Limited) should retain US. counsel promt. ‘2. _Tho UAE parties should retain soparate counsel rom the Pakistani banks, as the UAE legal interests Potentially diverge from the Pakistan banks (laity may be cut of atthe Pakistani lev. . ldeally, the UAE enttis would help the Pakistani partes select counsel thet work well together. & Counsel must determine i ajintdafense agroements advisable her, allowing the defendants to work together and shield thelr ascussons under the artorey-clen:pivlege, 2. Counsel need to promptly gather fact to determine the strength ofthe case, including 12 the extent © which elloged terrist groups in fact conducted barking transactions through the Pakistani cntties, whether the Pakistani parties knew or should have known o he alleged transactions, whether the UAE parties knew or should have known ofthe alleged transactions, anc whether relevant, appropriate banking procedures were employed. 3 (Counsel need to detormine what legal defenses may apply, incucing jurisdiction of U.S. la tothe foreign partes at seve, , jurisdiction over the alleged subject matter ofthe case, & whether the law cited by the plantitis appcable tothe casein question, and whether ther bases fora mation to dams exit 44, All communications with possible co-defendants and plaints should occur only trough counsel. (Communications Poltical Response.CommunieatonsiPaiical Response 1. This area needs to be managed at thre levels: corporatefbank; Indvidual/Abu Dhabi principals; and LUAE/Abu Dhabi Government ‘As with he legal strategy, there should be coordinated but distinct plans and spokespersons for each ofthe entiies above. 2.__-As we have seen in previous cases, the plaints wil attempt to extract a settlement by frst threatening ‘both legal action and public attacks against the standing and reputation of the Abu Dhabi leadership and the Government of the UAE. We precict thatthe oppostion strategy wil attempt to link the suspected actions of the Pakistani banks direct tothe leadership of the UAE and Abu Dhabi to do as much reputational damage 1 possible in an effort to extract the maximum settlement or prepare the most favorable foundation for tigation Iti be ertical to take all nacesary slope to isolate actione of banks from Abu Dhabi leadership and UAE Government. This plan would necessitate minimal, ary, pubic comment om Abu Dhabi or UAE ‘oficals. Al efforts should be taken to dct media ard poltical inquiries tothe barks, 4. _As always, all communications and potical engagement should be directed by appropriate legal counsel to assure total alignment wih egal strategy. ‘5. —Hillinquiries are best handled through phone cals or meetings rather than in wring 6. On communications, next steps would include: {In cooperation with legal counsel, THG and Embassy wil develop communications plan for Abu Dhabi leadership and UAE Government. This would inluce: © Grating holding statements; (© preparing and briefing spokespersons: (© __ preparing comprehensive background paper on UAE counterterorsm intatives and cooperation with us. (© contingency planning to anticipate opponents attacks and new facts allaged or lsclosed; and© preparing and briefing spokaepersene; © __preparing comprehensive background paper on UAE counterterrorism inatwes and cooperation with Us: © contingency planing to anticipate opponents attacks and new facts aleged or disclosed; and © establishing mec and pote! montering. danty separate communications counselor banks: (© UAE advisors should coordinate strategy and comments with bank advisors: (© banks should prepare holding statements and propare spokespersons; and ‘© long-term iigaton suppor plan should be devised i case progresses in U.S. cours.