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COHN LIFLAND PEARLMANHERRMANN & KNOPF, LLPPeter S . PearhnanFed. Bar No. - PP8416Park 80 Plaza West - OneSaddle Brook, NJ 07663(201) 845-9600Attorney for Plaintiff

UNITED STATES DISTRICT COURTFOR THE DISTRICT OF NEW JERSEY

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THOMAS BENNETT III, Individually and on ) CASE NO.Behalf of all Others Similarly Situated, )

CLASS ACTION COMPLAINTPlaintiff, ) FOR VIOLATIONS OF

FEDERAL SECURITIES LAWSvs . )

N.V. KONINKLIJKE NEDERLANDSCUEJURY TRIAL DEMANDED

PETROLEUM MAATSCHAPPIJ, a/k/a ROYALDUTCH PETROLEUM COMPANY, THE SHELLTRANSPORT AND TRADING COMPANY,PLC,SHELL PETROLEUM, N.V., THE SHELLPETROLEUM COMPANY, LTD., MAARTENVAN DER BERGH, JUDY BOYNTON,MALCOLM BRINDED, S .L. MILLER,HARRY J.M. ROELS, PAUL D. SKINNER,M. MOODY-STUART, JEROEN VAN DERVEER, AND PH LIP R . WATTS

Defendants.

PLAINTIFF'S CLASS ACTION COMPLAIN T

Plaintiff has alleged the following based upon the investigation of plaintiff's counsel, whic h

included a review of United States Securities and Exchange Commission ("SEC") filings by Royal

Dutch Petroleum Company ("Royal Dutch") and the Shell Transport and Trading Company, PLC

("Shell Transport"), as well as regulatory filings and reports, securities analysts reports an d

advisories about Royal Dutch and/or Shell Transport, press releases and other public statements

issued by Royal Dutch and/or Shell Transport, and media reports about Royal Dutch and/or Shell

Transport, and plaintiff believes that substantial additional evidentiary support will exist for th e

allegations set forth herein after a reasonable opportunity for discovery.

NATURE OF THE ACTIO N

1 . This is a federal class action on behalf ofpurchasers of the securi ties, including the

common stock traded in overseas markets and the American Depository Receipts ("ADRs") of

Royal Dutch Petroleum Company ("Royal Dutch") (NYSE : RD) and/or The Shell Transport and

Trading Company, PLC ("Shell Transport") (NYSE: SC) between December 3, 19.99 and January

9, 2004, inclusive (the "Class Period"), seeking to pursue remedies under the Securities Exchange

Act of 1934 ( the "Exchange Act") .

JURISDICTION AND VENUE

2. This Court has jurisdiction over the subject matter of this action pursuant to §27 of

the Exchange Act (15 U .S.C. §78aa) and 28 U.S.C. §1331 .

3 . Plaintiff brings this action pursuant to the Securities Exchange Act of 1934 a s

amended (15 U.S.C . §§ 78j(b) and 78t(a)), and Rule lOb-5 promulgated thereunder (17 C.F.R.

§240.1 Ob-5) . Venue is proper in this District pursuant to Section 27 of the Exchange Act, 15 U .S.C.

§78aa, and 28 U.S.C. § 1391(b) and (c) . Defendants engage in the major manufacturing and sale of

petrochemical and related products along the Eastern Seaboard and maintain a fuel, lubricant, an d

specialty additives research, manufacturing, and sales facility in Linden, New Jersey .

4. In connection with the acts alleged in this complaint, defendants, directly or

indirectly, used the means and instrumentalities of interstate commerce , including, but not limited

to, the mails, interstate telephone communications and the facili ties of the national securities

markets .

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PARTIES

5 . Plaintiff, as set forth in the accompanying certification, incorporated by reference

herein, purchased the ADRs ofRoyal Dutch at artificially inflated prices during the Class Period and

has been damaged thereby.

6. Defendant Royal Dutch Petroleum Company ("Royal Dutch") is a Netherland s

corporation with its principal executive office located at 30, Carel van Bylandtlaan, 2596 HR The

Hague, The Netherlands . Royal Dutch is a 60% owner of Shell Pe troleum Netherlands and Shel l

Petroleum UK .

7. Defendant The Shell Transport and Trading Company, PLC ("Shell Transport") is an

English corporation with its principal executive offices located at Shell Centre , London SE1, 7NA.

Shell Transport is a 40% owner of Shell Petroleum Netherlands and Shell Petroleum UK.

8 . Defendant Shell Petro leum N.V. ("Shell Petroleum Netherlands") is incorporated in

The Netherlands and is 60% owned by Royal Dutch and 40% owned by Shell Transport .

9 . Defendant The Shell Petroleum Company Limited ("Shell Petroleum UK") i s

registered in England and Wales and is 60% owned by Royal Dutch and 40% owned by Shel l

Transport.

10. The following defendants, each of whom was an execu tive officer of Royal Dutch

or Shell Transport, served as Group Managing Directors (as defined below) at the various times

during the Class Period : Maarten van den Bergh , JudyBoynton, Malcolm Brinded , S .L. Miller, Harry

J. M. Roels, Paul D. Skinner, M. Moody-Stuart, Jeroen van der Veer, and Philip R . Watts ("Watts") .

11 . Additionally, defendant Watts was, at all relevant times, Director and Managing

Director of Shell Transport and Chairman of Shell Transport since 2001 . Watts also served as Chie f

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Executive Officer, Exploration and Production, from 1997-2001 and, in that capacity, led Shel l

Transport' s oil and gas exploration unit when some of the recategorized rese rves described below

were booked .

12. Defendants Maarten van den Bergh, Judy Boynton, Malcolm Brinded, S .L. Miller,

Harry J . M. Roels, Paul D . Skinner, M. Moody-Stuart, Jeroen van der Veer, and Philip R. Watts are

collectively referred to hereafter as the "Individual Defendants ." During the Class Period, each of

the Individual Defendants, as senior executive officers and/or directors of Royal Dutch and/or Shel l

Transport, were privy to non -public information concerning its business , finances, products, markets

and present and future business prospects via access to internal corporate documents, conversations

and connections with other corporate officers and employees, attendance at m anagement and Board

of Directors meetings and committees thereof and via reports and other information provided to

them in connection therewith . Because of their possession of such information, the Individual

Defendants knew of or recklessly disregarded the fact that adverse facts specified herein had not

been disclosed to, and were being concealed from, the investing public .

PLAINTIFF'S CLASS ACTION ALLEGATIONS

13 . Plaintiff brings this action as a class action pursuant to Federal Rules of Civil

Procedure 23(a) and 23(b)(3) on behalf of himself and all purchasers of Royal Dutch and/or Shell

Transport securities, including ADRs and ordinary shares, from December 3, 1999 to January 9 ,

2004 . Excluded from the Class are defendants herein , members of the immediate family of each o f

the defendants, any person, firm, trust, corporation, officer, director or other individual or entity in

which any defendant has a controlling interest or which is related to or affiliated with any of th e

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defendants, and the legal representatives, agents, affiliates , heirs, successors-in-interest or assigns

of any such excluded party.

14. The members of the Class are so numerous that joinder of all members is

impracticable . The precise number of Class members is unknown to plaintiff at this time but i s

believed to be in the thousands. In addition, the names and addresses of the Class members can be

ascertained from the books and records of Royal Dutch and Shell Transport or their respective

transfer agents . Notice can be provided to such record owners by a combination of published notice

and first-class mail, using techniques and a form of notice similar to those customarily used in class

actions arising under the federal securities laws .

15. Plaintiff will fairly and adequately represent and protect the interests of the members

of the Class . Plaintiff has retained competent counsel experienced in class action litigation under

the federal securities laws to further ensure such protection and intends to prosecute this action

vigorously.

16. Plaintiffs claims are typical of the claims of the othermembers of the Class because

plaintiff's and all the class members' damages arise from and were caused by the same false and

misleading representations and omissions made by or chargeable to defendants . Plaintiff does not

have any interests antagonis tic to, or in conflict with, the Class .

17. A class ac tion is superior to other available methods for the fair and e fficient

adjudication of this controversy . Since the damages suffered by individual class members may be

relatively small, the expense and burden of individual litigation make it virtually impossible for the

class members to seek redress for the wrongful conduct alleged. Plaintiffknows of no difficulty tha t

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will be encountered in the management of this litigation that would preclude its maintenance as a

class action.

18. Common questions of law and fact exist as to all members of the Class an d

predominate over any questions affecting individual members of the Class . Among the questions

of law and fact common to the Class are :

a. Whether the federal securities laws were violated by defendants ' acts as

alleged herein ;

b. Whether Royal Dutch 's and/or Shell Transport's publiclydisseminated press

releases and statements during the Class Period omitted and/or misrepresented material facts ;

c. Whether defendants breached any duty to convey material facts or to correct

material facts previously disseminated ;

d. Whether defendants acted willfully, with knowledge or recklessly, in omittin g

and/or misrepresenting material facts ; and

e. The extent of injuries sustained by members of the Class and the appropriat e

measure of damages .

SUBSTANTIVE ALLEGATIONS

Background of Royal Dutch/Shell

25 . Royal Dutch and Shell Transport are separate holding companies that own; directly

or indirectly, investments in numerous operating and holding companies engaged in the business o f

producing, refining, storing, transporting, supplying and distributing petroleum and petroleum

products . In addition, the operating companies owned by Royal Dutch and Shell Transpo rt are

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engaged in various activities related to oil and natural gas, chemicals, power generation, renewable

resources and other businesses in over 145 countries .

26. Royal Dutch and Shell Transport operate under an alliance made in 1907, by which

the two companies agreed to merge their interests on a 60:40 basis while remaining separate and

distinct entities . Arrangements between Royal Dutch and Shell Transport provide, inter alia, that,

notwithstanding variations in shareholdings, Royal Dutch and Shell Transport shall share in the

aggregate net assets and in the aggregate dividends and interest received from all holding and

operating companies in the proportion of 60 :40. It is further arranged that the burden of all taxes

in the nature of or corresponding to an income tax leviable in respect of such dividends and interests

shall fall in the same proportion .

27. Royal Dutch is entitled to have its nominees elected as a majority of, and Shell

Transport is entitled to have its nominees elected as the balance of, the members of the Boards of

Directors of the two Group Holding Companies, Shell Petroleum N.V. ("Shell Petroleum

Netherlands") and The Shell Petroleum Company Limited ("Shell Petroleum UK") . Every member

of the Board of Management of Royal Dutch and everyManaging Director of Shell Transport is also

a member of the Presidium of the Board of Directors of Shell Petroleum Netherlands and a

Managing Director of Shell Petroleum UK. As such, they are generally known as "Group Managing

Directors ." They are also appointed by the Boards of Shell Petroleum Netherlands and Shell

Petroleum UK to a joint committee known as the Committee of Managing Directors, which considers

and develops objectives and long-term plans .

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28. Royal Dutch, Shell Transport, Shell Petroleum Netherlands , Shell Petroleum UK, and

their respective subsidia ries are referred to collectively herein as "Royal Dutch/Shell" or the

"Company . "

Materially False and Misleading Statements Made During the Class Period

29 . In the petroleum industry, there are two key measures of a company's operating

performance and future prospects . Those two key measures are reported reserves and futur e

discounted cash flows . During the Class Period, Royal Dutch/Shell's reporting of reported reserves

and future discounted cash flows was materially false and misleading . By reporting materially false

and misleading reported reserves and future discounted cash flows, Royal Dutch/Shell was able to

inflate the price of the respective ordinary shares and ADRs, maintain its credit rating, and maintai n

its status in the petroleum industry as a leader .

A. Shell Transport and Royal Dutch 's Forms 20-F for the fiscal yearended December 31, 1998

30. The Class Pe riod commences on December 3, 1999. At that time, both Shell

Transport and Royal Dutch filed with the SEC an annual report on Form 20-F . With respect to

reported reserves, the Company stated:

Critical Accounting Policies

In order to prepare the Financial Statements In conformity withgenerally accepted accounting principles in the Netherlands andthe USA, management has to make estimates and assumptions .The matters described below are considered to be the most critical inunderstanding the judgments that are involved in preparing theFinancial Statements and the uncertainties that could impact theamounts reported on the results of operations, financial condition andcash flows. Accounting policies are described in Note 2 to theFinancial Statements .

Estimation of oil and gas reserves

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Oil and gas reserves have been estimated in accordance withindustry standards and SEC regulations. Proved oil and gasreserves are the estimated quantities of crude oil, natural gas andnatural gas liquids that geological and engineering datademonstrate with reasonable certainty to be recoverable in futureyears from known reservoirs under existing economic andoperating conditions. These estimates do not include probable orpossible reserves . Estimates of oil and gas reserves are inherentlyimprecise and represent only approximate amounts and are subject tofuture revision, as they are based on available reservoir data, pricesand costs as of the date the estimate is made . Accordingly, thefinancial measures that are based on proved reserves are also subjectto change. (Emphasis added . )

31 . Additionally and with respect to reported reserves , Royal Dutch/Shell stated :

Supplementary Information -- Oil and Gas

Reserves

Proved reserves are the estimated quantities of oil and gas whichgeological and engineering data demonstrate with reasonablecertainty to be recoverable in future years from known reservoirsunder existing economic and operating conditions . Proveddeveloped reserves are those reserves which can be expected tobe recovered through existing wells with existing equipment andoperating methods. The reserves reported exclude volumesattributable to oil and gas discoveries which are not at presentconsidered proved. Such reserves will be included whentechnical, fiscal and other conditions allow them to beeconomically developed and produced.

Proved reserves are shown net of any quan tities of crude oil ornatural gas that are expected to be taken by others as royalties inkind but do not exclude certain quantities related to royaltiesexpected to be paid in cash or those related to fixed margincontracts . Proved reserves include certain quan tities of crude oilor natural gas which will be produced under arrangements whichinvolve Group companies in upstream risks and rewards but donot transfer title of the product to those companies . (Emphasisadded) .

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32. With respect to future cash flows related to proved oil and gas reserve quantities, a

key measure of prospective operating performance based in substantial part on proved oil and gas

reserves, both Forms 20-F stated :

The carrying amounts of fixed assets are reviewed for possibleimpairment whenever events or changes in circumstances indicatethat the carrying amounts of those assets are written down to fairvalue. For this purpose, assets are grouped based on separatelyidentifiable and largely independent cash flows . Estimates of currentcash flows of assets related to hydrocarbon production activities arebased on proved reserves, except in circumstances where it isprobable that additional resources will be developed and contributeto cash flows in the future.

United States accounting principles require the disclosure of astandardized measure of discounted future cash flows, relating toproved oil and gas reserve quantities and based on prices and costs atthe end of each year, currently enacted tax rates and a 10% discountfactor . The information so calculated does not provide a reliablemeasure of future cash flows from proved reserves, nor does it permita realistic comparison to be made of one entity and another becausethe assumptions used cannot reflect the varying circumstanceswithing each entity. In addition, a substantial but unknownproportion of future real cash flows from oil and gas productionactivities is expected to derive from reserves which have alreadybeen discovered, but which cannot yet be regarded as proved .

33 . For fiscal year 1998, Royal Dutch/Shell reported that future net cash flows related

to proved oil and gas reserve quantities were $59,460,000 . According to annual reports, a 10%

percent discount factor or ($28,791,000) was subtracted from the future net cash flows . As such,

Royal Dutch/Shell reported that its standardized measure of discounted future cash flows for fiscal

year 1998 were $30,669,000 .

B. Shell Transport and Royal Dutch's Forms 20-F for the fiscal yearended December 31, 1999

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34. On April 11, 2000, Shell Transport and Royal Dutch each filed an annual report with

the SEC on Form 20-F . Each Form 20-F stated :

Critical Accounting Policie s

In order to prepare the Financial Statements in conformi ty withgenerally accepted accounting principles in the Netherlands andthe USA, management has to make estimates and assumptions .The matters described below are considered to be the most critical inunderstanding the judgments that are involved in preparing theFinancial Statements and the uncertainties that could impact theamounts reported on the results ofoperations, financial condition andcash flows. Accounting policies are described in Note 2 to theFinancial Statements .


O il and gas reserves have been estimated in accordance withindustry standards and SEC regulations . Proved oil and gasreserves are the estimated quantities of crude o il, natural gas andnatural gas liquids that geological and engineering datademons trate with reasonable certainty to be recoverable in futureyears from known reservoirs under existing economic andoperating conditions . These estimates do not include probable orpossible reserves . Estimates of oil and gas reserves are inherentlyimprecise and represent only approximate amounts and are subject to

future revision, as they are based on available reservoir data, pricesand costs as of the date the estimate is made . Accordingly, thefinancial measures that are based on proved reserves are also subjectto change. (Emphasis added . )

35 . Additionally and with respect to reported rese rves , Royal Dutch/Shell stated:

Supplementary Information - Oil and Gas

Reserves

Proved reserves are the estimated quantities of oil and gas whichgeological and engineering data demonstrate with reasonablecertainty to be recoverable in future years from known reservoirsunder existing economic and operating conditions . Proveddeveloped reserves are those reserves which can be expected tobe recovered through existing wells with existing equipment andoperating methods . The reserves reported exclude volume s

-11-

attributable to oil and gas discoveries which are not at presentconsidered proved. Such reserves will be included whentechnical, fiscal and other conditions allow them to beeconomically developed and produced .

Proved reserves are shown net of any quantities of crude oil ornatural gas that are expected to be taken by others as royalties inkind but do not exclude certain quantities related to royaltiesexpected to be paid in cash or those related to fixed margincontracts . Proved reserves include certain quantities of crude oilor natural gas which will be produced under arrangements whichinvolve Group companies in upstream risks and rewards but donot transfer title of the product to those companies . (Emphasisadded) .

36 . Moreover, each stated that Royal Dutch/Shell's proved oil and gas reserves for fiscal

year 1999 were 19, 869 million barrels .



reserves , both Forms 20-F stated :

The carrying amounts of fixed assets are reviewed for possibleimpairment whenever events or changes in circumstances indicatethat the carrying amounts of those assets are written down to fairvalue. For this purpose, assets are grouped based on separatelyidentifiable and largely independent cash flows. Estimates ofcurrentcash flows of assets related to hydrocarbon production activities arebased on proved reserves, except in circumstances where it isprobable that additional resources will be developed and contributeto cash flows in the future.

United States accounting principles require the disclosure of astandardized measure of discounted future cash flows, relating toproved oil and gas reserve quantities and based on prices and costs atthe end of each year, currently enacted tax rates and a 10% discountfactor . The information so calculated does not provide a reliablemeasure of future cash flows from proved reserves , nor does it permita realistic comparison to be made of one entity and another becausethe assumptions used cannot reflect the varying circumstanceswithing each entity . In addition, a substantial but unknow n

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proportion of future real cash flows from oil and gas production

activities is expected to derive from reserves which have alreadybeen discovered, but which cannot yet be regarded as proved.

38. For fiscal year 1999, Royal Dutch/Shell reported that future net cash flows relate d




year 1999 were $54,799,000 .

C. Shell Transport and Royal Dutch's Forms 20 -F for the fiscal yearended December 31, 2000

39. On Apri112, 2001, Shell Transport and Royal Dutch each fi led an annual report with

the SEC on Form 20-F. Each Form 20-F stated:


In order to prepare the Financial Statements in conformity withgenerally accepted accounting principles in the Netherlands andthe USA, management has to make estimates and assumptions .The matters described below are considered to be the most critical inunderstanding the judgments that are involved in preparing theFinancial Statements and the uncertainties that could impact theamounts reported on the results of operations, financial condition andcash flows . Accounting policies are described in Note 2 'to theFinancial Statements .

Estimation of oil and gas rese rves

Oil and gas reserves have been estimated in accordan ce withindustry standards and SEC regulations . Proved oil and gasreserves are the estimated quantities of crude oil, natural gas andnatural gas liquids that geological and engineering datademonstrate with reasonable certainty to be recoverable in futureyears from known reservoirs under existing economic andoperating conditions. These estimates do not include probable orpossible reserves. Estimates of oil and gas reserves are inherentlyimprecise and represent only approximate amounts and are subject t o

-13-

future revision, as they are based on available reservoir data, pricesand costs as of the date the estimate is made . Accordingly, thefinancial measures that are based on proved reserves are also subjectto change . (Emphasis added.)

40. Additionally and with respect to reported reserves , Royal Dutch /Shell stated :

Supplementary Information -- Oil and Ga s

Reserves

Proved reserves are the estimated quantities of oil and gas whichgeological and engineering data demonstrate with reasonablecertainty to be recoverable in future years from known reservoirsunder existing economic and operating conditions. Proveddeveloped reserves are those reserves which can be expected tobe recovered through existing wells with existing equipment andoperating methods . The reserves reported exclude volumesattributable to oil and gas discoveries which are not at presentconsidered proved . Such reserves will be included whentechnical, fiscal and other conditions allow them to beeconomically developed and produced.

Proved reserves are shown net of any quantities of crude oil ornatural gas that are expected to be taken by others as royalties inkind but do not exclude certain quantities related to royaltiesexpected to be paid in cash or those related to fixed margincontracts . Proved reserves include certain quantities of crude oilor natural gas which will be produced under arrangements whichinvolve Group companies in upstream risks and rewards but donot transfer title of the product to those companies . (Emphasisadded) .

41 . Moreover, each stated Royal Dutch/Shell's proved oil and gas reserved was 19,09 5

million barrels .

42 . With respect to future cash flows related to proved oil and gas reserve quantities, a



The carrying amounts of fixed assets are reviewed for possibleimpairment whenever events or changes in circumstances indicate

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that the carrying amounts of those assets are written down to fairvalue. For this purpose, assets are grouped based on separatelyidentifiable and largely independent cash flows. Estimates of currentcash flows of assets related to hydrocarbon production activities arebased on proved reserves, except in circumstances where it isprobable that additional resources will be developed and contributeto cash flows in the future .

United States accounting principles require the disclosure of astandardized measure of discounted future cash flows, relating toproved oil and gas reserve quantities and based on prices and costs atthe end of each year, currently enacted tax rates and a 10% discountfactor. The information so calculated does not provide a reliablemeasure of future cash flows from proved reserves, nor does it permita realistic comparison to be made of one entity and another becausethe assumptions used cannot reflect the varying circumstanceswithing each entity. In addition, a substantial but unknownproportion of future real cash flows from oil and gas productionactivities is expected to derive from reserves which have alreadybeen discovered, but which cannot yet be regarded as proved .

43. For fiscal year 2000, Royal Dutch/Shell reported that future net cash flows related

to proved oil and gas reserve quantities were $114,861,000. According to annual reports , a 10%



year 2000 were $63,041,000 .

D. Shell Transport and Royal Dutch's Forms 20-F for the fiscal yearended December 31, 200 1

44. On April 14, 2002 , Shell Transpo rt and Royal Dutch each filed an annual repo rt with

the SEC on Form 20-F . Each Form 20-F stated :

Critical Accounting Po licies

In order to prepare the Financial Statements in conformity withgenerally accepted accounting principles in the Netherlands andthe USA, management has to make estimates and assumptions.The matters described below are considered to be the most critical in

-15-

understanding the judgments that are involved in preparing theFinancial Statements and the uncertainties that could impact theamounts reported on the results of operations, financial condition andcash flows . Accounting policies are described in Note 2 to theFinancial Statements.


Oil and gas reserves have been estimated in accordance withindustry standards and SEC regulations . Proved oil and gasreserves are the estimated quantities of crude o il , natural gas andnatural gas liquids that geological and engineering datademonstrate with reasonablecertainty to be recoverable in futureyears from known reservoirs under existing economic andoperating conditions . These estimates do not include probable orpossible reserves . Estimates of oil and gas reserves are inherentlyimprecise and represent only approximate amounts and are subject tofuture revision, as they are based on available reservoir data, pricesand costs as of the date the estimate is made . Accordingly, thefinancial measures that are based on proved reserves are also subjectto change. (Emphasis added.)

45 . Additionally and wi th respect to reported reserves, Royal Dutch/Shell stated :


Reserves

Proved reserves are the estimated quantities of oil and gas whichgeological and engineering data demonstrate with reasonablecertaintyto be recoverable in future years from known reservoirsunder existing economic and operating conditions . Proveddeveloped reserves are those reserves which can be expected tobe recovered through existing wells with existing equipment andoperating methods. The reserves reported exclude volumesattributable to oil and gas discoveries which are not at presentconsidered proved. Such reserves will be included whentechnical, fiscal and other conditions allow them to beeconomically developed and produced.

Proved reserves are shown net of any quantities of crude oil ornatural gas that are expected to be taken by others as royalties inkind but do not exclude certain quantities related to royaltiesexpected to be paid in cash or those related to fixed margincontracts. Proved reserves include certain quantities of crude oil

-16-

or natural gas which wi ll be produced under arrangements whichinvolve Group companies in upstream risks and rewards but donot transfer title of the product to those companies. (Emphasisadded) .

46. Moreover, each stated that proved oil and gas reserves for 2001 were 19,095 million

barrels .


key measure of prospective operating performance based in substantial part on proved oil and ga s


The carrying amounts of fixed assets are reviewed for possibleimpairment whenever events or changes in circumstances indicatethat the carrying amounts of those assets are written down to fairvalue. For this purpose, assets are grouped based on separatelyidentifiable and largely independent cash flows . Estimates of currentcash flows of assets related to hydrocarbon production activities arebased on proved reserves, except in circumstances where it isprobable that additional resources will be developed and contributeto cash flows in the future .

United States accounting principles require the disclosure of astandardized measure of discounted future cash flows, relating toproved oil and gas reserve quantities and based on prices and costs atthe end of each year, currently enacted tax rates and a 10% discountfactor . The information so calculated does not provide a reliablemeasure of future cash flows from proved reserves, nor does it permita realistic comparison to be made of one entity and another becausethe assumptions used cannot reflect the varying circumstanceswithing each entity. In addition, a substantial but unknownproportion of future real cash flows from oil and gas productionactivities is expected to derive from reserves which have alreadybeen discovered, but which cannot yet be regarded as proved .


to proved oil and gas reserve quantities were $86,354,000. According to annual reports, a 10%


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Royal Dutch/Shell reported that its standardized measure of discounted future cash flows for fisc al

year 2001 were $45,878,000 .

E. Shell Transport and Royal Dutch 's Forms 20-F for the fiscal yearended December 31, 2002

On March 31, 2003, Shell Transport and royal Dutch each filed an annual report with the

SEC on Form 20-F . Each Form 20-F stated :


In order to prepare the Financial Statements in conformity withgenera lly accepted accounting principles in the Netherlands andthe USA, management has to make estimates and assumptions.The matters described below are considered to be the most critical inunderstanding the judgments that are involved in preparing theFinancial Statements and the uncertainties that could impact theamounts reported on the results ofoperations, financial condition andcash flows . Accounting policies are described in Note 2 to theFinancial Statements .


Oil and gas reserves have been estimated in accordance withindustry standards and SEC regulations . Proved oil and gasreserves are the estimated quantities of crude oil , natural gas andnatural gas liquids that geological and engineering datademonstrate with reasonable certainty to be recoverable in futureyears from known reservoirs under existing economic andoperating conditions . These estimates do not include probable orpossible reserves . Estimates of oil and gas reserves are inherentlyimprecise and represent only approximate amounts and are subject tofuture revision, as they are based on available reservoir data, pricesand costs as of the date the estimate is made . Accordingly, thefinancial measures that are based on proved reserves are also subjectto change. (Emphasis added . )

49. Additionally and with respect to reported reserves, Royal Dutch/Shell stated :


Reserves

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Proved reserves are the estimated quantities of oil and gas whichgeological and engineering data demonstrate with reasonablecertainty to be recoverable in future years from known reservoirsunder existing economic and operating conditions. Proveddeveloped reserves are those reserves which can be expected tobe recovered through existing wells with existing equipment andoperating methods . The reserves reported exclude volumesattributable to oil and gas discoveries which are not at presentconsidered proved . Such reserves will be included whentechnical, fiscal and other conditions allow them to beeconomically developed and produced.

Proved reserves are shown net of any quantities of crude oil ornatural gas that are expected to be taken by others as royalties inkind but do not exclude certain quan tities related to royaltiesexpected to be paid in cash or those related to fixed margincontracts . Proved reserves include certain quantities of crude oilor natural gas which will be produced under arrangements whichinvolve Group companies in upstream risks and rewards but donot transfer title of the product to those companies . (Emphasisadded) .

50. Moreover, each stated that Royal Dutch/Shell's proved oil and gas reserves were

19,347 million barrels .

51 . With respect to future cash flows related to proved oil and gas reserve quantities, a

key measure of prospective operating performance based in substantial part on proved oil and ga s


The carrying amounts of fixed assets are reviewed for possibleimpairment whenever events or changes in circumstances indicatethat the carrying amounts of those assets are written down to fairvalue. For this purpose, assets are grouped based on separatelyidentifiable and largely independent cash flows. Estimates of current

cash flows of assets related to hydrocarbon production activities arebased on proved reserves, except in circumstances where it is

probable that additional resources will be developed and contributeto cash flows in the future .

United States accounting principles require the disclosure of astandardized measure of discounted future cash flows, relating to

proved oil and gas reserve quantities and based on prices and costs a t

-19-

the end of each year, currently enacted tax rates and a 10% discountfactor. The information so calculated does not provide a rei blemeasure of future cash flows from proved reserves, nor does it permita realistic comparison to be made of one entity and another because

the assumptions used cannot reflect the varying circumstanceswithing each entity. In addition, a substantial but unknownproportion of future real cash flows from oil and gas production

activities is expected to derive from reserves which have alreadybeen discovered, but which cannot yet be regarded as proved .



percent discount factor or ($57,483,000) was subtracted from the future net cash flows. As such,


year 2002 were $65,702,000 .

53 . The statements contained in ¶¶ 30-52 were each materially false and misleading

because the defendants failed to disclose and indicate : (1) that Royal Dutch/Shell had overstated it s

proved oil and gas reserve figures by 20% ; (2) that Royal Dutch/Shell accomplished the

overstatement by including in its proved oil and gas reserves figures, when its venture partners did

not, estimates from the Gorgon Joint Venture in Australia and the Nigerian Projects in Africa when

such projects did not meet industry and SEC standards for proved reserves ; (3) that the inclusion of

Gorgon Joint Venture in Australia and the Nigerian Projects in Africa and other projects was

accomplished through the booking of its proved oil and gas reserves figures on the basis of initial

letters of intent rather than on the basis of when such projects had been contracted ; and .(4) as a

result, Royal Dutch/Shell's true market value was materially overstated at all relevant times .

THE TRUTH BEGINS TO EMERGE

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54. On January 9, 2004, Royal Dutch/Shell announced that, following internal reviews,

some proved hydrocarbon reserves would be recategorized . The total non-recurring

recategorization, relative to the proved reserves as stated at December 31, 2002, represented 3 .9

billion barrels of oil equivalent ("boe") of proved reserves, or 20% of proved reserves at that date .

Over 90% of the total change was a reduction in the proved undeveloped category; the balance was

a reduction in the proved developed category . Additionally, the Company stated that of the

recategorization, two thirds (2.7 billion barrels) relates to crude oil and natural gas liquids, and one

third (1 .2 billions boe or 7 .2 trillion standard cubic feet) to natural gas . Moreover, Royal Dutch/Shell

indicated that the FAS69 standardized measure of discounted future cash flows associated with the

proved reserves will be impacted. The estimated 10% reduction in the standardized measure i s

significantly less than the 20% change to proved reserves, as the majority of the recategorization

relates to proved undeveloped reserves and to relatively low margin producing areas and that further

analysis is ongoing to determine the extent to which the recategorization will impact on prior year

reported proved reserves and the results will be disclosed . Lastly, the Company stated that reserves

affected were mainly booked in the period 1996 to 2002 . A significant proportion of the

recategorization related to the current status of project maturity and that a number of countries are

affected by the change, with the largest impact in Nigeria and Australia. The majority of the overall

recategorization would be reported under "Other Eastern Hemisphere ."

55. On the news, Shell Transport ADRs fell 6 .9%, or $3 .12 per share, on heavy volume

to close at $41 .69 per share on the NYSE on January 9, 2004 . Shell Transport ordinary shares fell

6 .8% on the London exchange from a U . S . equivalent of $7 .36 to $6 .86. Additionally, Royal Dutch

ADRs fell 7 .8%, or $4.15 per share, on heavy volume to close at $48 .61 per share on the NYSE on

-21-

January 9, 2004. Royal Dutch ordinary shares fell 7.1% from the U.S. equivalent of $52.91 to

$49.15 .

POST-CLASS PERIOD REVELATIONS

56. On January 12, 2004, The Wall Street Journal ran an article titled: "Shell Cuts

Reserve Estimate 20% As SEC Scrutinized Oil Industry ." In the article, authors, Chip Cummins,

Susan Warren, and Michael Schroeder, stated that "Royal Dutch/Shell Group's disclosure that it

overstated its proven reserves by 20% rattled energy investors and is raising questions about whether

the oil industry has inflated a lifeblood measure of its future prospects ." The article quoted Lynn

Turner, a former SEC chief accountant, as stating : "[T]he revision, looked like more than a mistake .

A 20% restatement of proven reserves is a humongous error[ .] . . . For a company like Shell to have

missed its proven reserves by that much is not an oversight . It's an intentional misapplication of the

SEC's rules . "

57. With respect to proved reserves, the article stated : "Reserves are at the heart of an

oil and gas company because they represent what can be taken from the ground in the future . Since

companies must replace the oil and gas they produce each year just to stay even, reserve growth is

a crucial indicator of how well a company is doing . If the reserve size falls, the company is less

valuable to investors and its stock price will tumble . "

58. On January 14, 2004, The Wall Street Journal ran an article titled : "Shell's Watts

Draws Fire, Chairman Criticized Amid Overbooking Flap, Likely SEC Probe ." In the article,

authors, Chip Cummins and Michael Schroeder, stated :

As the Securities and Exchange Commission looks poised to delveinto a huge overbooking of reserves by Royal Dutch/Shell Group, thecompany's chairman, Philip Watts, has come under increasing fire forhis stewardship of one of the world's largest oil producers .

-22-

Last week, Shell said it erroneously overbooked reserves by 20%.Reserves are a crucial indicator of an oil company's value . Shares inthe group's two holding companies -- Royal Dutch Petroleum Co . ofthe Netherlands, and Shell Transport & Trading Co . of London --have fallen sharply since the disclosure Friday.

The unprecedented size of the overstatement makes an SECinvestigation likely. "The Shell matter seems significant," said SECCommissioner Roel Campos. "I am sure our enforcement staff willlook into it . It is hard to see how [Shell] could miss so badly. "

59 . Additionally, the article stated that "[a]nalysts and investors have criticized Shell

lackluster performance under Sir Philip against indust rypeers such as Exxon Mobil Corp ., of Irving,

Texas, and crosstownrival BP PLC . Sir Philip has cut the company's p roduction-growth estimates .

Shell also has performed poorly in recent years against Exxon and BP in finding and developing new

prospects , which it needs to replace oil and natural -gas propert ies depleted by production."

DEFENDANTS VIOLATION OF GAAP RULE S

60. Given the accounting irregularities described above, the Company announced

discounted cash flows and proved reserves were in violation of GAAP, and the following principles :

a. The principle that "interim financial reporting should be based upon the same

accounting principles and practices used to prepare annual financial statements" was violated (AP B

No. 28, ¶ 10) ;

b. The principle that "financial reporting should provide information that i s

useful to present to potential investors and creditors and other users in making rational investment,

credit, and similar decisions" was violated (FASB Statement of Concepts No . 1, 1 34);

The principle that "financial reporting should provide information about th e

economic resources of an enterprise, the claims to those resources, and effects of transactions ,

-23-

events, and circumstances that change resources and claims to those resources" was violated (FAS B

Statement of Concepts No. 1, ¶40);

d. The principle that "financial reporting should provide information about a n

enterprise's financial performance during a period" was violated (FASB Statement of Concepts No .

1, ¶ 42) ;

e. The principle that "completeness, meaning that nothing is left out of th e

information that may be necessary to insure that it validly represents underlying events an d

conditions" was violated (FASB Statement of Concepts No. 2, ¶ 79) ;

f. The principle that " financial reporting should be reliable in that it represent s

what it purports to represent" was violated (FASB Statement of Concepts No . 2, ¶¶ 58-59); and

g. The principle that "conservatism be used as a prudent reac tion to uncertainty

to try to ensure that uncertainties and risks inherent in business situations are adequately considered"

was violated (FASB Statement of Concepts No . 2, ¶ 95).

61 . The adverse information concealed by defendants during the Class Period and

detailed above was in violation of Item 303 of Regulation S-K under the federal securities law (1 7

C.F.R. 229.303) .

DEFENDANTS ' VIOLATION OF INDUSTRY AND SEC RULE S

62 . The Society of Petroleum Engineers ("SPE"), an independent professional society,

has established industry standard guidelines for classifying and accounting for reserves . According

to SPE, these classifications are a key factor in determining the value of the reserves, and reserves

are classified as either "proved" or "unproved . "

63 . According to the SPE, proved reserves are reserves that :

-24-

can be estimated with reasonable certainty to be recoverable undercurrent economic conditions. Current economic conditions includeprices and costs prevailing at the time of the estimate. Provedreserves may be developed or undeveloped. . . [Proved reserves]must have facilities to process and transport those reserves to marketthat are operational at the time of the estimate, or there is acommitment or reasonable expectations to install such facilities in thefuture.

64. With respect to guidance by the SEC, the definition for proved oil and gas reserve s

can be found in Rule 4-10(a) of Regulation S-X of the Securities Exchange Act of 1934, whic h

states :

Proved oil and gas reserves . Proved oil and gas reserves are theestimated quantities of crude oil, natural gas, and natural gas liquidswhich geological and engineering data demonstrate with reasonablecertainty to be recoverable in future years from known reservoirsunder existing economic and operating conditions, i .e ., prices andcosts as of the date the estimate is made . Prices include considerationof changes in existing prices provided only by contractualarrangements, but not on escalations based upon future conditions.See also FAS 25 Suspension ofCertain Accounting Requirements forOil and Gas Producing Entities 1 34 (Feb . 1979) .

65. Moreover, the SEC states : "The concept of reasonable certainty imp lies that, as more

technical data becomes available , a positive , or upward, revision is much more likely than a negative,

or downward revision ." SEC Div. of Corp . Fin : Frequently Requested Accounting and Fin .

Reporting Interpretations and Guidance ("SEC Guidance") (Mar . 31, 2001) .

66 . Royal Dutch/Shell's overstatement of its proved reserves by 20% is in clear violatio n

ofthe above-reference principles . More specifically, Royal Dutch/Shell violated both SPE and SEC

rules by including, in its proved reserves figures, the Gorgon Joint Venture in Australia and the

Nigerian Projects in Africa when such projects neither meet industrynor SEC standards for proved

-25-

reserves and when its venture partners did not include such amounts in its calculation of its proved

oil and gas reserves .

67. As a result of these violations, Royal Dutch/Shell announced on February 19, 2004

that the SEC had launched a formal probe into the shocking restatement of proved reserves .

ADDITIONAL SCIENTER ALLEGATIONS

68. As alleged herein, defendants acted with scienter in that defendants knew that the

public documents and statements issued or disseminated by or in the name of the Company were

materially false and misleading ; knew or recklessly disregarded that such statements or documents

would be issued or disseminated to the investing public ; and knowingly and substantially participate d

or acquiesced in the issuance or dissemination of such statements or documents as primary violators

of the federal securities laws. As set forth elsewhere herein in detail, defendants, by virtue of their

receipt ofinformation reflecting the true facts regarding Royal Dutch/Shell and its business practices,

their control over and/or receipt of Royal Dutch/Shell's allegedly materially misleading

misstatements and/or their associations with the Company which made them privy to confidential

proprietary information concerning Royal Dutch/Shell, were active and culpable participants in the

fraudulent scheme alleged herein. Defendants knew and/or recklessly disregarded the falsity and

misleading nature of the information which they caused to be disseminated to the investing public.

The ongoing fraudulent scheme described in this complaint could not have been perpetrated over

a substantial period of time, as has occurred, without the knowledge and complicity of the personnel

at the highest level of the Company, including the Individual Defendants .

-26-

69. Additionally, the Defendants were motivated to overstate Royal Dutch /Shell's proven

reserves in order to maintain the Company' s credit rating and the appearance that it was effectively

competing in the industry.

STATUTORY SAFE HARBOR

70. The federal statutory safe harbor provided for forward-looking statements under

certain circumstances does not apply to any of the allegedly false statements pleaded in thi s

Complaint. Many of the specific statements pleaded herein were not identified as "forward-looking

statements" when made. To the extent there were any forward-looking statements, there were no

meaningful cautionary statements identifying important factors that could cause actual results to

differ materially from the statements made therein . Further, Defendants are liable for the forward-

looking statements pleaded because, at the time each ofthose forward-looking statements was made,

the speaker knew the forward-looking statement was false and the forward-looking statement wa s

authorized and/or approved by an executive officer of Royal Dutch and Shell Transport who kne w

that those statements were false when made .

APPLICABILITY OF PRESUMPTION OF RELIANCE :FRAUD-ON- THE-MARKET DOCTRINE

71 . At all relevant times, the market for Royal Dutch's and Shell Transport's ADRs an d

ordinary shares was an efficient market for the following reasons, among others :

a. Royal Dutch' s and Shell Transport's ADRs stock met the requirements for

listing, and was listed and actively traded , on the NYSE , a highly efficient market;

b. Royal Dutch ordinary shares were listed and actively traded on the

Amsterdam Stock Exchange, a highly efficient and automated market;

-27-

c . Shell Transport ordinary shares were listed and actively traded on the Londo n

Stock Exchange, a highly efficient and automated market ;

d. As a regulated issuer, Royal Dutch/Shell filed periodic public reports with th e

SEC and the NYSE ;

e. Royal Dutch's and Shell Transport's ADRs were followed by securitie s

analysts employed by major brokerage firms who wrote reports that were distributed to the sale s

force and certain customers of their respective brokerage firms and that were publicly available an d

entered the public marketplace ; and

f. Royal Dutch/Shell regularly issued press releases which were carried by

national newswires. Each of these releases was publicly available and entered the publi c

marketplace .

72. As a result, the market for Royal Dutch and Shell Transport's ordinary shares and

ADRs promptly digested current information with respect to Royal Dutch and She ll Transport 's

securities from all publicly-available sources and reflected such information in the price of Royal

Dutch and Shell Transport's ordinary shares and ADRs . Under these circumstances , all purchasers

of Royal Dutch and Shell Transport' s securities during the Class Period suffered similar injury

through their purchase of securities at artificially inflated prices and a presumption of relianc e

applies .

-28-

COUNT I

For Violations Of Section 10(b)Of The Exchange Act And Rule 10b-5

Promulgated Thereunder Against the All Defendants

73. Plaintiff repeats and realleges the allegations set forth above as though fully set fort h

herein .

74. During the Class Period, Defendants carried out a plan, scheme and course ofconduct

which was intended to and, throughout the Class Period, did : (i) deceive the investing public,

including plaintiff and other Class members, as alleged herein ; (ii) artificially inflate and maintain

the market price of Royal Dutch and Shell Transport's securities ; and (iii) cause plaintiff and other

members of the Class to purchase Royal Dutch and Shell Transport's securities at artificially inflated

prices. In furtherance of this unlawful scheme, plan and course of conduct, Defendants took the

actions set forth herein.

75 . These defendants : (a) employed devices, schemes, and artifices to defraud ; (b) made

untrue statements of material fact and/or omitted to state material facts necessary to make the

statements not misleading; and (c) engaged in acts, practices and a course of business which

operated as a fraud and deceit upon the purchasers of the securities of Royal Dutch and Shell

Transport in an effort to maintain artificially high market prices for Royal Dutch and Shell

Transport's securities in violation of Section 10(b) of the Exchange Act and Rule lOb-5 . These

defendants are sued as primary participants in the wrongful and illegal conduct charged herein . The

Individual Defendants are also sued herein as controlling persons of Royal Dutch/Shell, as alleged

below .

-29-

76. In addi tion to the duties of full disclosure imposed on these defendants as a result of

their making of affirmative statements and repo rts , or participation in the making of affirmative

statements and reports to the investing pub lic, they each had a duty to disseminate truthful

information promptly that would be material to investors in compliance with the integrated disclosu re

provisions of the SEC as embodied in SEC Regulation S-X (17 C .F.R. § 210 .01 et Seq .) and S-K (17

C.F.R. § 229 . 10 et seq.) and other SEC regulations, including accurate and truthful information with

respect to the Company's operations , financial condition and performance so that the market prices

of the pub licly traded securities of Royal Dutch and Shell Transport would be based on truthful,

complete and accurate information .

77. The Defendants , acting in concert, directly and indirectly, by the use of the mails or

other means or instrumentalities of interstate commerce, engaged and participated in a continuous

course of conduct to conceal adverse material information about the business, business practices,

performance, operations and future prospects of Royal Dutch/Shell as specified herein. These

defendants employed devices, schemes and artifices to defraud, while in possession of material

adverse non-public information and engaged in acts, practices, and a course of conduct as alleged

herein in an effort to assure investors of Royal Dutch/Shell's value and performance and substantial

growth. This included the making of, or the participation in the making of, untrue statements of

material facts and omitting to state material facts necessary in order to make the statements made

about Royal Dutch/Shell and its business, operations and future prospects in the light of the

circumstances under which they were made, not misleading, as set forth more particularly herein,

and engaging in transactions, practices and a course ofbusiness which operated as a fraud and deceit

upon the purchasers of Royal Dutch and Shell Transport's securities during the Class Period .

-30-

78. The Individual Defendants ' primary liability, and controlling person liabi lity, arises

from the following facts : (I) each of the defendants was a high- level executive and/or director at the

Company during the Class Period; (ii) each of the defendants , by virtue of his responsibi lities and

activities as a senior executive officer and /or director ofthe Company, was p rivy to and participated

in the creation , development and report ing of the Company 's internal budgets , plans , projections

and/or reports ; (iii) these defendants enjoyed significant personal contact and familiarity wi th each

other and were advised of and had access to other members of the Company's m anagement team,

internal reports, and other data and information about the Company 's financial condition and

performance at all relevant times; and (iv) these defendants were aware of the Company's

dissemination of information to the investing pub lic which they knew or recklessly disregarded was

materially false and misleading .

79. The Individual Defendants had actual knowledge of the misrepresentations and

omissions of material facts set forth herein, or acted with reckless disregard for the truth in that they

failed to ascertain and to disclose such facts, even though such facts were readily available to them .

Such defendants' material misrepresentations and/or omissions were done knowingly or recklessly

and for the purpose and effect of concealing Royal Dutch/Shell's operating condition, business

practices and future business prospects from the investing public and supporting the artificially

inflated price of its stock. As demonstrated by their overstatements and Misstatements of the

Company's financial condition and performance throughout the Class Period, these Defendants, if

they did not have actual knowledge of the misrepresentations and omissions alleged, were reckless

in failing to obtain such knowledge by deliberately refraining from taking those steps necessary to

discover whether those statements were false or misleading .

-31-

80. As aresult of the dissemination of the materially false and misleading information and

failure to disclose material facts, as set forth above, the market price of Royal Dutch and Shell

Transport's securities was artificially inflated during the Class Period . Unaware of the fact that the

market price of Royal Dutch and Shell Transport's securities was artificially inflated, and relying

directly or indirectly on the false and misleading statements made by these defendants, or upon the

integrity of the market in which the securities trade, and/or on the absence of material adverse

information that was known to or recklessly disregarded by these defendants but not disclosed in

public statements during the Class Period, plaintiff and the other members of the Class acquired

Royal Dutch and Shell Transport's securities during the Class Period at artificially high prices and

were damaged thereby.

81 . At the time of said misrepresentations and omissions, plaintiff and other members of

the Class were unaware of their falsity, and believed them to be true . Had plaintiff and the other

members of the Class and the marketplace known of the true performance , business practices , future

prospects and int rinsic value of Royal Dutch/Shell, which were not disclosed by these defendants,

plaintiff and other members ofthe Class would not have purchased or otherwise acquired their Royal

Dutch and Shell Transport's securities during the Class Pe riod , or, if they had acquired such

securities during the Class Pe riod , they would not have done so at the art ificially inflated prices

which they paid .

82. By virtue of the foregoing, these defendants each violated Section 10 (b) of the

Exchange Act and Rule I Ob-5 promulgated thereunder.

-32-

83. As a direct and proximate result of defendants' wrongful conduct, plaintiff and the

other members of the Class suffered damages in connection with their purchases of the securities o f

Royal Dutch and Shell Transport during the Class Period .

COUNT I I

For Violations Of Section 20(a) Of TheExchange Act Against the Individual Defendants

84. Plaintiff repeats and realleges the allegations set forth above as if set forth full y

herein.

85. The Individual Defendants were and acted as controlling persons of Royal

Dutch/Shell within the meaning of Section 20(a) of the Exchange Act as alleged herein . By virtue

of their high-level positions with the Company, participation in and/or awareness of the Company' s

operations and/or intimate knowledge of the Company's actual performance, the Individua l

Defendants had the power to influence and control and did influence and control, directly or

indirectly, the decision-making of the Company, including the content and dissemination of the

various statements which plaintiff contends are false and misleading . Each of the Individual

Defendants was provided with or had access to copies of the Company's reports, press releases,

public filings and other statements alleged by plaintiff to be misleading prior to and/or shortly afte r

these statements were issued and had the ability to prevent the issuance of the statements or cause

the statements to be corrected .

86. In addition, each of the Individual Defendants had direct involvement in the day-to-

day operations of the Company and, therefore, is presumed to have had the power to control or

influence the particular transactions giving rise to the securities violations as alleged herein, and

exercised the same .

-33-

87. As set forth above, the Individual Defendants each violated Sec tion 10(b) and Rule

lOb-5 by their acts and omissions as alleged in this Complaint. By virtue of their controlling

positions , the Individual Defendants are liable pursuant to Section 20(a) of the Exchange Act . As

a direct and proximate result of these defendants' wrongful conduct , plaintiffand other members of

the Class suffered damages in connection with their purchases of the Company's securities during

the Class Period.

PRAYER FOR RELIEF

WHEREFORE, plaintiff, on behalf of himself and the Class, prays for judgment as follows :

a. declaring this action to be a plaintiffclass actionproperly maintained pursuant

to Rule 23(a) and (b)(3) of the Federal Rules of Civil Procedure ;

b. awarding monetary damages against all defendants, jointly and severally, in

favor of plaintiff and the other members of the Class for all losses and damages suffered as a resul t

of the acts and transactions complained of herein , together with prejudgment interest from the date

of the wrongs to the date of the judgment herein ;

awarding plaintiff and the other membersof the Class their costs and expenses

of this litigation, including reasonable attorneys' fees, accountants' fees and experts' fees and othe r

costs and disbursements ; and

d. awarding plaintiff and the other members of the Class such other and furthe r

relief as may be just and proper under the circumstances .

-34-

JURY TRIAL DEMANDED

Plaintiff hereby demands a trial by jury.

Dated: March -3, 2004

By:

377619 .wpd

COHN LIFLAND PEARLMANHERRMANN & KNOPF, LLP

Peter SI PearlmanPark 8 Plaza West - OneSaddlebrook, NJ 07663Tel: (201) 845-9600Fax: (201) 845-942 3

BERGER & MONTAGUE, P.C.Sherrie R. SavettGlen L. Abramson1622 Locust StreetPhiladelphia, PA 19103Tel: (215) 875-3000Fax: (215) 875-4604

James M. Orman1845 Walnut Street14' FloorPhiladelphia , PA 19103Tel . : (215) 523-7800Fax: (215) 523-9290

Attorneys for Plaintiff

-35-

CERTIFICATION PURSUANT TO THE FEDERAL SECURITIES LAW S

Thomas Bennett III ("Plaintiff"), duly swears and says, as to the claims asserted underthe federal securities laws, that :

1 . I have reviewed a draft complaint to be filed against Royal Dutch and ShellTransport, et al ., I approve of its contents , and I authorize its filing .

2 . 1 did not purchase the security that is the subject of this action at the direction ofmy counsel or in order to participate in this private action .

3 . I am willing to serve as a representative plaintiff on behalf of the class,including providing testimony at deposition and trial, if necessary .

4 . My transactions in the securities of Royal Dutch and Shell Transport during theClass Period are as follows :

Date Shares Purchased Purchase Price

02/16/00 15 $57.8125

05110101 15 $59.571 7

01/04/02 . 30 $49 .168 1

05/23/03 15 $44 .92

01/22/04 15 $48.35

5 . I have not sought to serve as a class representative in any other action filedunder the United States federal securities laws in the past three (3) years preceding the date onwhich this certification is signed, except :

6 . I have not accepted and will not accept any payment for serving asrepresentative plaintiff on behalf of the class beyond my pro rata share of any recovery, or asordered or approved by the court, including any award for reasonable costs and expenses(including lost wages) directly relating to the representation of the class .

I declare under penal ty of perjury under the laws of the United States that the foregoingis -true and correct . Executed this &. day of. _ . , . 2003, at

By. f . - . ._ .

THO ENNETT III

United States District Court

THOMAS BENNETT III, Individually andon behalf of itself and all others similarlysituated,

Plaintiff,

V .

N.V. KONINKLLIKE NEDERLANDSCUEPETROLEUM MATTSCHAPPIJ, a/k/aROYAL DUTCH PETROLEUM CO ., THESHELL TRANSPORT and TRADING CO .,PLC, SHELL PETROLEUM, N.V. THESHELL PETROLEUM CO., LTD., )MAARTEN VAN DER BERGH, JUDY )BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J .M. ROELS, PAUL D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS .

Defendants .

TO : (Name and Address of Defendant)

C. ,

-U

N

n

-J o

N .V . Koninklikjke Nederlandsche PetroleumMattschappij, a/k/a Royal Dutch Petroleum Co .c/o SHELL OIL COMPANY/CORPORATION SERVICE COMPANY830 Bear Tavern RoadTrenton, NJ 08628

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNEY :Peter S . Pearlman, Esq .

Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West On eSaddle Brook, NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after service of this summons onyou, exclusive of the day of service . If you fail to do so, judgment by default will be taken against you for the reliefdemanded in the complaint . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service.

CLERK DATE

DISTRICT OF New Jersey

SUMMONS IN A CIVIL CAS E

Case No .

BY DEPUTY CLERK

RETURN OF SERVICE

Service of the summons and Complaint made by meDATE

NAME OF SERVER TITLE

Check one box below to indicate appropriate method of service

❑ Service Personally upon the defendant. Place where served .

0 Left copies thereof at the defendant 's dwelling house or usual place of abode with a person of suitable age and discretio nthen residing therein .

Name of person with whom the summons and complaint were left :

❑ Returned unexecuted :

❑ Other (specify) :

STATEMENT OF SERVICE FEESTRAVEL SERVICES TOTAL

DECLARATION OF SERVE R

I declare under penalty of perjury under the Taws of the United States of America that the foregoinginformation contained in the Return of Service and Statement Fees is true and correc t

Executed on

Date Signature of Serve r

Address of Server

I J As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure . (Rev. 8/0 1


-------- -------------------------------------------- )THOMAS BENNETT III, Individually and )on behalf of itself and all others similarly )situated, )

Plaintiff,

V .

N.V . KONINKLJJKE NEDERLANDSCHEPETROLEUM MATTSCHAPPIJ, a/k/aROYAL DUTCH PETROLEUM CO ., THESHELL TRANSPORT and TRADING CO .,PLC, SHELL PETROLEUM, N .V. THESHELL PETROLEUM CO ., LTD.,MAARTEN VAN DER BERGH, JUDYBOYNTON, MALCOLM BRINDED, S .L.MILLER, HARRY J.M. ROELS, PAUL D .SKINNER, M. MOODY-STUART,JEROEN VAN DER VEER, and PHILIPR. WATTS .

Defendants.

r 1 "

LJ

TO : (Name and Address of Defendant) THE SHELL TRANSPORT and TRADING CO ., PLCc/o SHELL OIL COMPANY/CORPORATION SERVICE COMPANY830 Bear Tavern Roa dTrenton, NJ 0862 8

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNEY :

Peter S . Pearlman, Esq .Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West OneSaddle Brook, NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after service of this summons onyou, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the reliefdemanded in the complaint . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service .

CLERK DATE

DIS'T'RICT OF New Jersey

SUMMONS IN A CIVIL CASE

Case No .

BY DEPUTY CLERK

RETURN OF SERVICE



Check one box below to indicate appropriate method of servic e

❑ Service Personally upon the defendant. Place where served :

❑ Left copies thereof at the defendant's dwelling house or usual place of abode with a person of suitable age and discretio nthen residing therein .

Name of person with whom the summons and complaint were left .




DECLARATION OF SERVER

I declare under penalty of perju ry under the laws of the United States of America that the foregoin ginformation contained in the Return of Service and Statement Fees is true and correct .

Executed onDate Signature of Serve r

Address of Server

I) As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure . (Rev. 8/01


------------------------------------------------------THOMAS BENNETT III, Individually and )on behalf of itself and all others similarly )situated, )

Plaintiff, )

V .

N. V. KONINKLUKE NEDERLANDSCHE )PETROLEUM MATTSCHAPPJJ, a/k/a )ROYAL DUTCH PETROLEUM CO., THE )SHELL TRANSPORT and TRADING CO ., )PLC, SHELL PETROLEUM, N .V. THE )SHELL PETROLEUM CO ., LTD., )MAARTEN VAN DER BERGH, JUDY )BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J.M. ROELS, PAUL . D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS . )

Defendants. )------------------------------------------------------

DISTRICT OF New Jerse y


Case No .

TO : (Nanre and Address of Defendant) SHELL PETROLEUM ,c/o SHELL OIL COMPANY/CORPORATION SERVICE COMPANY830 Bear Tavern Roa dTrenton, NJ 0862 8

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNEY :

Peter S . Pearlman, Esq .Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West OneSaddle Brook, NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after service of this summons onyou, exclusive of the day of service . If you fail to do so, judgment by default will be taken against you for the reliefdemanded in the complaint . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service .

CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVIC E


NAME OF SERVER TrrLE


❑ Service Personally upon the defendant. Place where served :



❑ Returned unexecuted .

❑ Other (specify :

STATEMENT OF SERVICE FEESTRAVEL SERVICES TOTA L


I declare under penalty of perjury under the laws of the United States of America that the foregoing

information contained in the Return of Service and Statement Fees is true and correct .

Executed onDate Signature of Server

Address of Server

I) As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure . (Rev. 8/0 1



--------------------------------------------------- )THOMAS BENNETT III , Individually and )on behalf of itself and all others similarly ) SUMMONS IN A CIVIL CASEsituated, )

Plaintiff, ) Case No .

v . )

N.V. KONINKLIJKE NEDERLANDSCHE )PETROLEUM MATTSCHAPPIJ, a/k/a ) 'v )ROYAL DUTCH PETROLEUM CO., THE) "SHELL TRANSPORT and TRADING CO ., )PLC, SHELL PETROLEUM, N .V. THE ) =='SHELL PETROLEUM CO., LTD., ) `--• ~~MAARTEN VAN DER BERGH, JUDY ) ' rBOYNTON, MALCOLM BRINDED, S .L .MILLER, HARRY J .M. ROELS, PAUL D . )SKINNER, M . MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS . )

Defendants . )---------------------------------------------------- -

TO: Name and Address of Derendanq N .V ., THE SHELL PETROLEUM CO ., LT Dc/o SHELL OIL COMPANY/CORPORATION SERVICE COMPAN Y830 Bear Tavern RoadTrenton, NJ 0862 8


Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West OneSaddle Brook, NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after service of this summons onyou, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the reliefdemanded in the complaint . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service .

CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVICE


NAME OF SERVER TfTL E


❑ Service Personally upon the defendant. Place where served:

❑ Left copies thereof at the defendant's dwelling house or usual place of abode with a person of suitable age and discretio n

then residing therein .

Name of person with whom the summons and complaint were lef t





I declare under penalty of perjury under the laws of the United States of America that the foregoinginformation contained in the Return of Service and Statement Fees is true and correct .

Executed on


Address of Serve r

I) As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure . (Rev. 8/01)



Plaintiff, )

v. )

N.V. KONINKLIJKE NEDERLANDSCHE )PETROLEUM MATTSCHAPPIJ, a/k/a )ROYAL DUTCH PETROLEUM CO ., THE)SHELL TRANSPORT and TRADING CO.,)PLC, SHELL PETROLEUM, N.V . THE )SHELL PETROLEUM CO ., LTD., )MAARTEN VAN DER BERGH, JUDY )

BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J .M. ROELS, PAUL D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS . )

Defendants. )------------------------------------ ------ ---------- )

TO : (Name and Address of Defendant) MAART EN



Case No .

N

U c-s r'

VAN DER BERGHc/o SHELL OIL COMPANY/CORPORATION SERVICE COMPANY830 Bear Tavern RoadTrenton, NJ 0862 8


Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West OneSaddle Brook, NJ 07663

(201) 845-9600


CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVIC E


NAME OF SERVER TrrLE


17 Service Personally upon the defendant . Place where served:

O Left copies thereof at the defendant's dwelling house or usual place of abode with a person of suitable age and discretionthen residing therein .






I declare under penalty of perjury under the laws of the United States of America that the foregoinginformation contained in the Return of Service and Statement Fees is true and correct

Executed on

Date Signature of Server

Address of Serve r

I As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure . ( Rev. 8/01



------------------------------------------------------ )

THOMAS BENNETT III, Individually and )

on behalf of itself and all others similarly ) SUMMONS IN A CIVIL CASEsituated, )

Plaintiff, ) Case No.

v. )

N.V. KONINKLIJKE NEDERLANDSCHB )PETROLEUM MATTSCHAPPIJ, a/k/a )ROYAL DUTCH PETROLEUM CO., THE)SHELL TRANSPORT and TRADING CO .,)PLC, SHELL PETROLEUM, N . V. THE )SHELL PETROLEUM CO ., LTD., )MAARTEN VAN DER BERGH, JUDY )BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J .M. ROELS, PAUL D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS . )

Defendants. )------------------------------------------------------

TO : (Name and Address of Defendant} JUDY BOYNTON

T

L J

c/o SHELL OIL COMPANY/CORPORATION SERVICE COMPANY830 Bear Tavern RoadTrenton, NJ 08628


Cohn Lifland Pearlman Herrmann & Knopf LLP

Park 80 Plaza West On e

Saddle Brook, NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after service of this summons onyou, exclusive of the day of service . If you fail to do so, judgment by default will be taken against you for the reliefdemanded in the complaint . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service.

CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVICE


NAME OF SERVER ME


❑ Service Personally upon the defendant . Place where served :

❑ Left copies thereof at the defendanrs dwelling house or usual place of abode with a person of suitable age and discretio nthen residing therei n

Name of person with -whom the summons and complaint were left

❑ Returned unexecuted


STATEMENT OF SERVICE FEE STRAVEL SE"CES TOTAL



Executed on


Address of Serve r

1) As to who may serve a summons see Rule 4 of the Federal Rules of Ci vil Procedure. ( Rev. 8/01)

United States District Cour t


Plaintiff, )

)

V . )

N.V. KONINKLIJKE NEDERLANDSCHE )PETROLEUM MATTSCHAPPU, a/k/a )ROYAL DUTCH PETROLEUM CO., THE )SHELL TRANSPORT and TRADING CO.,)PLC, SHELL PETROLEUM, N.V. THE )SHELL PETROLEUM CO., LTD., )MAARTEN VAN DER BERGH, JUDY )BOYNTON, MALCOLM BRINDED, S.L. )MILLER, HARRY J .M. ROELS, PAUL D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS. )

Defendants .

TO :Name and Address of Defendant) MALCOLM


SUMMONS IN A CIVIL' CASE

Case No.p ~N

Qnf*t

A6

C7T~ n

~,rntV

BRINDEDc/o SHELL OIL COMPANY/CORPORATION SERVICE COMPANY830 Bear Tavern RoadTrenton, NJ 0862 8

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNE YPeter S . Pearlman, Esq .Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West On eSaddle Brook, NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after service of this summons onyou, exclusive of the day of service . If you fail to do so, judgment by default will betaken against you for the reliefdemanded in the complaint . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service.

CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVICE


NAME OF SERVER TRLE

Check one box below to indicate appropriate me thod of service

❑ Service Personally upon the defendant. Place where served .







I declare under penalty of perju ry under the laws of the United States of America that the foregoin ginformation contained in the Return of Service and Statement Fees is true and correct .

Executed on


Address of Server

I J As to who may serve a summons see Rule 4 of the Federal Rules of CMI Procedure . [Rev. 8/0 1)


THOMAS BENNETT III, Individually andon behalf of itself and all others similarlysituated,

Plaintiff,

V.

N.V. KONINKLIJKE NEDERLANDSCHEPETROLEUM MATTSCHAPPIJ, a/k/aROYAL DUTCH PETROLEUM CO., THESHELL TRANSPORT and TRADING CO.,PLC, SHELL PETROLEUM, N .V. THE

)



Case No .

SHELL PETROLEUM CO ., LTD., )MAARTEN VAN DER BERGH, JUDY )BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J .M. ROELS, PAUL D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS .

Defendants .--------------------------------TO: (Name and Address of Defendant) S .L . MILLE R

c/o SHELL OIL COMPANY/CORPORATION830 Bear Tavern RoadTrenton, NJ 08628

F__a ;:0

oMrn

rn

C-,rC__ Fri

SERVICE COMPANY

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNEY :Peter S . Pearlman, Esq .Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West OneSaddle Brook, NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after service of this summons onyou, exclusive of the day of service . If you fail to do so, judgment by default will be taken against you for the reliefdemanded in the complaint . . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service.

CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVIC E

Service of the summons and Complaint made by me ~DATE

NAME OF SERvER TIR E


0 Service Personally upon the defendant. Place where served :


Name of person with whom the summons and complaint were left .





declare under penalty of perjury under the laws of the United States of America that the foregoinginformation contained in the Return of Service and Statement Fees is true and correct .

Executed on


Address of Serve r

1) As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure. (Rev. 8/01)



--------------------------------------------------- )THOMAS BENNETT III, Individually and )on behalf of itself and all others similarly )

situated, )

Plaintiff, )

V. )

N.V. KONINKLLIKE NEDERLANDSCHE )

PETROLEUM MATTSCHAPPIJ, a/k/a )ROYAL DUTCH PETROLEUM CO., THE)

SHELL TRANSPORT and TRADING CO.,)PLC, SHELL PETROLEUM, N.V. THE )SHELL PETROLEUM CO ., LTD., )

MAARTEN VAN DER BERGH, JUDY )BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J . M. ROELS , PAUL D. )

SKINNER , M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )

R. WATTS . )Defendants. )

-----------------------------------------------------


Case No .rl~C=D ~Z

C/)mY C,C

c-~cD r1. . c~ g

TO : Name and Address of Defendant) HARRY J . M . RO E L S

c/o SHELL OIL COMPANY/CORPORATION SERVICE COMPANY830 Bear Tavern RoadTrenton, NJ 0862 8

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNEY :Peter S . Pearlman, Esq .Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West OneSaddle Brook , NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after service of this summons onyou, exclusive of the day of senrice . If you fail to do so, judgment by default will be taken against you for the reliefdemanded in the complaint . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service.

CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVICE


NAME OF SERVER -mtE


O Service Personally upon the defendant . Place where served :


Name of person with whom the summons and complaint were left





I declare under penalty of perjury under the laws of the United States of America that the foregoin ginformation contained in the Return of Service and Statement Fees is true and correct .

Executed on


Address of Server

1) As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure . (Rev. 8/0 1



------------------------------------------------------

THOMAS BENNETT III, Individually and )on behalf of itself and all others similarly ) SUMMONS IN A CIVIL CAS Esituated, )

Plaintiff, ) Case No.

V. )

)

N.V. KONINKLIJKE NEDERLANDSCHE )PETROLEUM MATTSCHAPPIJ, a/k/a )ROYAL DUTCH PETROLEUM CO., THE )SHELL TRANSPORT and TRADING CO .,)PLC, SHELL PETROLEUM, N .V. THE )SHELL PETROLEUM CO ., LTD., )MAARTEN VAN DER BERGH, JUDY )BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J .M. ROELS, PAUL D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS . )

Defendants. )----------------------------------------------------- )

TO: (Name and Addles, of Defendant) PAUL D . SKINNER

c/o SHELL OIL COMPANY/CORPORATION830 Bear Tavern Roa dTrenton, NJ 08628

q C

1rn

~ ~~y rr

i ..C

SERVICE COMPANY

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNEY :Peter S . Pearlman, Esq .Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West On e

Saddle Brook, NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after se rvice of this summons onyou, exclusive of the day of service . If you fail to do so,judgment by default will be taken against you for the reliefdemanded in the complaint . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service .

CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVIC E


NAME OF SERVER mLE


❑ Service Personally upon the defendant. Place where served:



❑ Returned unexecuted:


STATEMENT OF SERVICE FEE SSE RVICES TOTAL



Executed on


Address of Server

1) As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure. (Rev . 8/01)


THOMAS BENNETT III, Individually andon behalf of itselfand all others similarlysituated,

Plaintiff,

V.

N.V. KONINKLIJKE NEDERLANDSCHEPETROLEUM MATTSCHAPPIT, a/k/aROYAL DUTCH PETROLEUM CO., THESHELL TRANSPORT and TRADING CO .,PLC, SHELL PETROLEUM, N.V. THESHELL PETROLEUM CO., LTD.,MAARTEN VAN DER BERGH, JUDY



Case No .

BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J.M. ROELS, PAUL D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS . )

MOODY-STUARTSHELL OIL COMPANY/CORPORATION

Tavern Road

NJ 0862 8

Defendants .

TO : (Name and Address of Defendant( M .c/o

0

~-a

-D

c

~C7

ri

J

rnc- °

SERVICE COMPANY

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNEY:Peter S . Pearlman, Esq .Cohn Lifland Pearlman Herrmann & Knopf LLP

Park 80 Plaza West One

Saddle Brook, NJ 07663(201) 845-960 0

an answer to the complaint which is on you with this summons, within 20 days after service of this summons onyou, exclusive of the day of service . If you fail to do so judgment by default will be taken against you for the reliefdemanded in the complaint . Any answer that you serve on the parties to this action must filed with the Clerk of thisCourt within a reasonable period of time after service.

CLERK DATE

BY DEPUTY CLERK

830 BearTrenton,

RETURN OF SERVICE

Service of the summons and Complaint made by meDAT E






❑ Returned unexecuted .


STATEMENT OF SERVICE FEE S

TRAVEL SERVICES TOTAL


I declare under penalty of perjury under the laws of the United States of America that the foregoing

information contained in the Return of Service and Statement Fees is true and co rrect.

Executed onDate Signature of Server

Address of Server

I) As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure . (Rev. 8/01)


-------------------------------------------------- )THOMAS BENNETT III, Individually and )on behalf of itself and all others similarly )situated, )

Plaintiff,

V.

N.V. KONINKLUKE NEDERLANDSCHE )PETROLEUM MATTSCHAPPU, a/k/a )ROYAL DUTCH PETROLEUM CO., THE)SHELL TRANSPORT and TRADING CO.,)PLC, SHELL PETROLEUM, N .V. THE )SHELL PETROLEUM CO ., LTD., )MAARTEN VAN DER BERGH, JUDY )BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J .M. ROELS, PAUL D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS . )

Defendants.--------------------------------TO: jName and Address of Defendant

830 Bear Tavern RoadTrenton, NJ 0862 8



Case No .

.. C

O CI) ~-

C-)x rn

C

r or. ;

JEROEN VAN DER VEE Rc/o SHELL OIL COMPANY/CORPORATION SERVICE COMPAN Y

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNEY:Peter S . Pearlman, Esq .Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West OneSaddle Brook, NJ 07663(201) 845-960 0


CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVIC E


NAME OF SERVER TITL E


O Service Personally upon the defendant Place where served:

❑ Left copies thereof at the defendant's dwelling house or usual place of abode with a person of suitable age and discretionthen residing therein .



❑ Other (specify) .



I declare under penalty of perjury under the laws of the United States of America that the foregoin g

information contained in the Return of Service and Statement Fees is true and correct .

Executed on


Address of Server

I ~ As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure . (Rev. 8/01)


-------------------------------------------------- )THOMAS BENNETT III, Individually and )on behalf of itself and all others similarly )situated, )

Plaintiff, )

v. )

N.V. KONINKLUKE NEDERLANDSCHE )PETROLEUM MATTSCHAPPU, a/k/a )ROYAL DUTCH PETROLEUM CO., THE)SHELL TRANSPORT and TRADING CO .,)PLC, SHELL PETROLEUM, N.V. THE )SHELL PETROLEUM CO ., LTD., )MAARTEN VAN DER BERGH, JUDY )

BOYNTON, MALCOLM BRINDED, S .L. )MILLER, HARRY J .M. ROELS, PAUL D. )SKINNER, M. MOODY-STUART, )JEROEN VAN DER VEER, and PHILIP )R. WATTS . )

Defendants. )------------------------------------------------------

TO: (Name and Address of Der fldant ) PHILIP R .

c/o SHELL830 BearTrenton,



Case No .

rn

WATTS

OIL COMPANY/CORPORATION SERVICE COMPANY

Tavern Road

NJ 0862 8

YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF'S ATTORNEY :Peter S . Pearlman, Esq .Cohn Lifland Pearlman Herrmann & Knopf LLPPark 80 Plaza West On eSaddle Brook, NJ 07663(201) 845-960 0


CLERK DATE

BY DEPUTY CLERK

RETURN OF SERVIC E





❑ Left copies thereof at the defendant's dwelling house or usual place of abode with a person of suitable age and discretionthen residing therein .




STATEMENT OF SERVICE FEE STRAVEL SERVICES TOTA L


I declare under penalty of perjury under the laws of the United States of America that the foregoin g

information contained in the Return of Service and Statement Fees is true and correct.

Executed on


Address of Serve r

1) As to who may serve a summons see Rule 4 of the Federal Rules of Civil Procedure . (Rev. 8/U 1)

~' r- n r-fir r., cohn lifland pearlman & knopf, llp...

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