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2
The TRO was granted by Judge McFarland on May 4, 2021, and is attached as Exhibit 2.
3 See, Verification of Steve Nicandros verifying the facts in this Motion, and the Frontera Organizational Chart
attached as Exhibit 3 to this Motion.
4 See, Assignment attached as Exhibit 4.
5 See, PSC attached as Exhibit 5.
118225056\V-6 3
3. Third, ZM’s allegations that the Assignment of the PSC to FRUS has been
nullified by language in an arbitration award is untrue, as the government of Georgia has
suspended any termination of the PSC (the “Suspension of Termination”).6
4. Fourth, ZM’s allegation that FRGC still had the right to operate under the PSC
even after ZM approved the Assignment assigning such right to FRUS on April 13, 2019, is
absurd, and contradicts ZM’s own approval of the Assignment, twice, on April 15, 2019 (the
“First Notice”)7
and April 24, 2020 (the “Second Notice”).8
5. Fifth, ZM’s allegation that FRGC still had the right to operate under the PSC even
though he approved the Assignment of that right to FRUS is again completely false. After this
Assignment, there was also nothing for Outrider Master Fund, LP (“Outrider”) or any other
company to foreclose upon with respect to FRGC’s operating interest under the PSC in any
liquidation process in the Cayman Islands.
6. Sixth, ZM’s allegation that a company called Green Capital Ltd. (“Green
Capital”) owns a 50% operating interest in the PSC through FRGC is false, because FRGC no
longer has any interest under the PSC to takeover. This argument also makes no sense as Green
Capital has no track record, experience or expertise in the oil and gas industry and is operated by
a radiologist with ties to ZM’s family. This argument has been rejected by the Court in Georgia
and should be rejected by this Court.
7. Finally, ZM misses the point of Frontera’s TRO, which was granted, and of the
request for a Temporary Injunction. Frontera seeks to enjoin ZM from violating the Employment
Agreement he signed with Frontera by continuing to compete with Frontera, and the
6 See, Country of Georgia Suspension of Termination attached as Exhibit 6.
7 See, First Notice dated April 15, 2019 and attached as Exhibit 7.
8 See, Second Notice dated April 24, 2019 and attached as Exhibit 8.
118225056\V-6 4
Employment Agreement expressly provides for such injunctive relief.9
If the Court does not
issue the injunction, ZM will simply complete the process of stealing Frontera’s assets before a
trial can be conducted, and Frontera will have no legal remedy.
III. FRONTERA IS THE BENEFICIAL OWNER OF THE ASSETS
MADE THE SUBJECT OF THE TRO