MANAGING EXECUTIVE

Dear Sir, URGENT

RE CEASE AND DESIST

1 We confirm that our registered company name is "Van der Merwe Dorning and Associates" with Pieter van der Merwe as the director.

2 Our trading name and style has always been “VDMA” and/or "VDMA Attorneys".

3 According to the media reports, the Gupta family and some, if not all, of their various business entities are being represented in South Africa by a firm of attorneys called "Van der Merwe & Associates" of which the partner is Gert van der Merwe.

4 Our brand and trading style, "VDMA" and VDMA Attorneys", is well known in our market.

5 We, VDMA Attorneys, hereby confirm that we do not act for or represent any member of the Gupta family or any of their business entities, including but not limited to Oakbay Investments and Optimum Mine trust.

6 Furthermore, we are in no way linked to or in association or in any other way involved with "Van der Merwe & Associates" or "Gert van der Merwe".

7 It has come to our attention that various media reports are using the references "VDMA" and "VDMA Attorneys" when referring to Gert van der Merwe and/or Van Der Merwe & Associates.

8 The use of these abbreviations has created the false impression that it is our firm that is acting for the Gupta family and their various entities.

9 We have been inundated with calls from not only our valued clients but also from a variety of members of the public who are under the incorrect impression that we are representing the Gupta and/or their various entities.

10 You are hereby called upon to immediately cease and desist from using or referring to "VDMA" or "VDMA Attorneys" in any way whatsoever when referring to Van der Merwe & Associates, Gert van der Merwe, the Gupta family and/or any of their business entities without our written consent.

11 To the extent that you have published any article in the public domain with the use of “VDMA” and/or “VDMA Attorneys” you are to immediately publish a retraction and replace it with Van de Merwe & Associates or Gert van der Merwe and or their specific trading style that does not in any way resemble “VDMA” and/or “VDMA Attorneys”.

12 We furthermore require a written undertaking from you within 24 hours of receipt of this letter that you will immediately cease and desist from utilising our trading names, "VDMA" or "VDMA Attorneys", without our written consent.

13 We thank you in advance for your co-operation.

14 Our rights remain strictly reserved.

Yours faithfully,

VDMA ATTORNEYS

Pieter van der Merwe

Issued by VDMA Attorneys, 20 October 2016