The present Notice of Motion has been filed by the abovenamed Plaintiffs for expunging/striking off parts of the Affidavit of Evidence in Lieu of Examination-In-Chief of the Defendants’ Witness - Mr. Patrick Keel, wherein he states that he is “making this Affidavit as an expert in Texas civil law”. The reliefs sought by the Plaintiffs is based on their contention that Mr. Keel has not confined his evidence to what the Texas Law is, but has proceeded to apply that law. In other words, in the present Notice of Motion, the Plaintiffs raise an issue as to the proper scope of expert evidence on a point of foreign law. This issue arises in the following circumstances:

(a) The Plaintiffs are seeking to enforce a Judgment dated 21st September 2010 of the District Court, 14th Judicial District, Dallas County, Texas, U.S.A. (“Texas Court”) in Case No.09-15036 (“Texas Case”) directing the Defendants, jointly or severally, to pay the Plaintiffs a sum of USD 7.5 million. The Defendants have sought to resist the enforcement of that Judgment on various grounds including, inter alia, a plea that the Texas Court did not have jurisdiction over the Defendants and, consequently to ren