Rule 4.

7

Form 4.2

Winding-Up Petition G4S Care and Justice Solutions UK LTD Registered No. 00390328
(a) Insert title of court

To The High Court Companies Court 7 Rolls Buildings Fetter Lane London EC4A 1NL The petition of Kazuri Properties CiC c/o 81 Bayham Street London NW1 0AG 1. G4S Care and Justice Solutions (UK) Ltd Registered Company Number 00390328 (hereinafter called “the company”) was incorporated on

(b) Insert full name(s) and address(es) of petitioner(s)

(c) Insert full name and registered no. of company subject to petition

(d) Insert date of incorporation (e) Insert address of registered office

21 March 2009 under the Companies Act 19__ or 2006 2. The registered office of the company is at Sutton Park House 15 Carshalton Road Sutton, SM1 4LD United Kingdom 3. The nominal capital of the company is £ 50,131,000 divided into 1,552m shares of £ 2.52p each. The amount of the capital paid up or credited as paid up is (g) £235 110 000 as at the last AGM. 4. The principal objects for which the company was established are as follows: Provider of outsourced care and justice solutions including prisons, offender management, home detention curfew monitoring, prison escort services and other objects stated in the company’s articles

(f) Insert amount of nominal capital and how it is divided (g) Insert amount of capital paid up or credited as paid up

(h) Set out the grounds on which a winding-up order is sought (j) Delete as applicable

5. G4S care and Justice Services Ltd (UK) failed to pay an invoice for £35 000 for work contracted and undertaken. 6. The company /is not an insurance undertaking; a credit institution; an investment undertaking providing services involving the holding of funds or securities for third parties; or a collective investment undertaking as referred to in Article 1.2 of the EC Regulation. 7. For the reasons stated in the statement of truth of (k) Kazuri Properties CiC filed in support here of it is considered that the EC Regulation on insolvency proceedings will apply and will be main proceedings as defined in Article 3 of the EC Regulation

(k) Insert name of person making the statement of truth

(l) Insert whether main, secondary or territorial proceedings (ll) Insert date of service

k. Verbal and written agreements prefer that there was a complicit, verbal and written undertaking from G4S Care and Justice Services Ltd to pay for work commissioned over a period of 5 months to Kazuri Properties CiC.

Kazuri Properties CiC undertook substantial work to identify, model and create an alternative to custody for women commissioned by G4S. There are written and verbal agreements that this was contracted work, not as G4S Care and Justice Solutions Ltd tried to claim later, speculative subject to the government’s “appetite.” In any event the company interest company (CiC) would never have entered into speculative work with G4S, given its tarnished reputation and lack of credibility in the market. This disingenuous remark, reflects on their corporate ethos of lies, bullying and a narcissistic, sociopathic culture: they would have known about the fraud in the tagging contract, double billing at HMP Parc which is still to be made public and the unlawful killing of Jimmy Mubenga. Still they sought to draw a very small social enterprise into their nefarious world of lies and deceit, by not disclosing material facts, which would have precluded Kazuri Properties CiC further involvement with G4S. In spite of various letters and invoices, since March 2013, no payment or explanation for non payment has been forthcoming. We believe the company to be in a financially precarious situation , given FIVE investigations of its government contracts by the Serious Fraud Office, The Cabinet Office, The National Audit Office, the Ministry of Justice and the Public Accounts Select Committee. The company has a heavy debt burden and does not have a senior management team that can be trusted any longer to manage public service contracts, this is evidenced by a rapid decline in share price. We are aware that Cevian and other hedge fund operators are trying to divest the profit making cash transfer services of G4S. Our contract was with G4S Care and Justice Solutions UK Ltd, which is the entity being investigated under the fraudulent delivery of the tagging contract. The Ministry of Justice have confirmed that they will not be awarded any further contracts if they do not undergo a process of “corporate purging” and renewal and until such time as they are given a clean bill of health by all the investigating authorities. This was confirmed in a private meeting with a director of the Ministry of Justice on September 18 2013. We do not believe the company has the intention to pay the amounts due, having requested them for over 8 months. It has recently increased its shares and has suffered a lower credit rating .On 9 March 2009, the group obtained a BBB Stable credit rating from Standard & Poor’s. Following the G4S board Olympics contract review, Standard & Poor’s, on 5th November 2012, downgraded the credit rating of G4S plc to BBB- with a Stable outlook. There was a substantial company contribution into the employee pension scheme which indicates mishandling of pension funds. G4S group Outlook Statement 7/5/2013 states "...group margins are expected to continue to be impacted adversely in the short term" Net borrowings at £1 993 000 000 exceed net assets at £ 1 231 000 000.The parent company, G4S PLC is trading in insolvency. Basically, G4S owes twice as much to the
banks as the value of the assets on its balance sheet. To put that in perspective, when investors

pay 252p per share they get net assets – total assets of the company less monies owed to creditors – of £1.04bn, or 74p per share. But the net debt – debt less available cash – stands at £1.95bn, or 138p per share, at the end of June, up £267m from the same time last year. The recent share offering is simply a band aid solution and leverages more debt into a bankrupt corporate pariah. The business model is unethical and unsustainable, at zero hour contracts, mass redundancies and tax avoidance by creating wholly owned offshore subsidies.

(7A) (j) A statutory demand was served on the company on March 19 2013 (ll). More than 4 months have elapsed between the service of the statutory demand and the presentation of this petition for the reasons set out in the statement of truth of (k) filed in support hereof.] 8. In the circumstances it is just and equitable that the company should be wound up The petitioner(s) therefore pray(s) as follows:(1) that G4S Care and Justice Solutions (UK) Ltd may be wound up by the court under the provisions of the Insolvency Act 1986
(m) If the company is the petitioner, delete “the company”. Add the full name and address of any other person on whom it is intended to serve this petition

Note: It is intended to serve this petition on (m) G4S care and Justice Services Ltd and Investment and hedge fund firms with substantial holdings:
Invesco: 248,239,496 (15.99%) Prudential: 89,325,538 (6.33%) Investment Funds Tweedy, Brown Company LLC: 71,420,862 (5.06%) William H. Gates III: 45,224,081 (3.2%) BlackRock, Inc: 66,544,177 Cevian Capital II G.P Limited 72,142,365 (5.11%)”

Endorsement
This petition having been presented to the court on ________________________ will be heard at (n) [Royal Courts of Justice, Strand, London, WC2A 2LL] [(n) ________________________________ County Court ________________________________________________________] [(o) ____________________________________ District Registry _________________________________________________________] on: Date____________________________________________________________________ Time _________________________________________________hours (or as soon thereafter as the petition can be heard) The solicitor to the petitioner is:Name___________________________________________________________________

(n) Insert name and address of Court (o) Insert name and address of District Registry

Address_________________________________________________________________ ________________________________________________________________________ Telephone no_____________________________________________________________ Reference________________________________________________________________ (j) [Whose London Agents are:Name___________________________________________________________________ Address__________________________________________________________________ ________________________________________________________________________ Telephone no. ____________________________________________________________ Reference________________________________________________________________

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