Statement of Allegations: In the Matter of Richard Opekar et al.

IN THE MATTER OF THE SECURITIES ACT
R.S.O. 1990, c. S.5, AS AMENDED

AND

IN THE MATTER OF
RICHARD OPEKAR, ROBERT OPEKAR,
JOHN A. TINDALE AND LAVER LIMITED

STATEMENT OF ALLEGATIONS OF STAFF
OF THE ONTARIO SECURITIES COMMISSION

Staff of the Ontario Securities Commission make the following allegations:

1. Ram Petroleums Limited ("Ram") is incorporated under the laws of Canada. Ramis a reporting issuer in Ontario. Shares of Ram trade on The Toronto StockExchange.

2. Each of Richard Opekar, Robert Opekar, John A. Tindale and Laver Limited(individually, a "Respondent" and collectively, the "Respondents") is, or was duringthe financial year of Ram ended December 31, 1999, a director, officer, significantshareholder (beneficial ownership of 10% or more of the voting rights of Ram) orindividual that has, or may have, access to material undisclosed information.

3. Ram failed to file annual financial statements for its financial year ended December31, 1999 on or before May 19, 2000, contrary to subsection 78(1) of the SecuritiesAct (Ontario).

4. By virtue of his/her/its relationship, each Respondent has, or may have, access toinformation regarding the affairs of Ram that has not been generally disclosed.

5. It would be prejudicial to the public interest to allow the Respondents to trade in thesecurities of Ram until such time as all disclosure required by Ontario securities lawhas been made by Ram.

6. It is therefore in the public interest for the Commission to order that all trading,whether direct or indirect, in the securities of Ram by the Respondents cease untilsuch time as Ram has made all filings it is required to make under Ontario securitieslaw.