Member Info for JimSlade

It was there yesterday afternoon when I looked.

Its on GOGC website media section

Did someone have a contact in GOGC so we can get some clarity.

JRjnr - What makes you think that?

JRjny surely they 100% for nothing if they see through the 90 days?

Surely they would have emailed a copy.

All very odd. If they issued the cancellation notice on the 27th then today we supposedly release a statement saying we are happy with the outcome.

I agree. Hold off until we get some clarity.

This is an extract from the OC Media report. I think the key point is refusing to give up land no using for extraction. Assume on that basis we keep TARIBANI and MTSAREKHEVI (MGC).
Georgia had accused the company of violating the terms of their contract, signed in 1997. They claimed that Frontera refused to return to the state land they were no longer using for extraction.

After Georgia filed the appeal at the International Arbitration Tribunal in January 2018, Frontera responded with a counterclaim, claiming $3.5 billion in damages. The company accused the government of trying to take resource-rich lands from them.

According to a statement released by the state-owned Georgian Oil and Gas Corporation, the tribunal upheld their claim that Frontera committed a ‘material breach of the contract’ by refusing to give up the land. These lands, the statements reads, comprise ‘99% of the entire contract area’.

Maybe B-2-0 was on the right track after all. B-2-0 if your out there have you any comment? Does MIRZAANI stay with us?

I think your correct

I’m in

Yes it is.

UNITED STATES BANKRUPTCY COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
IN RE:
FRONTERA RESOURCES CAUCASUS CORP
DEBTORS(S),
electronically or mailed to the parties listed below:
WARREN E GLUCK
HOLLAND & KNIGHT LLP
31 W 52ND STREET
NEW YORK, NY IOO19
I do hereby certiff that on lt day of \-btt
CASE NO. 19-13418
.2019. a copy ofthe above and foregoing has been this date served
$
$
$ CHAPTER 15
NOTICE OF APPEARANCE AND REQUEST
FOR SERVICE OF NOTICES AND PLEADINGS
PLEASE TAKE NOTICE that the undersigned hereby enters an appearance on behalf of:
HARRIS COUNTY
secured creditor(s) in the above-referenced proceedings, The undersigned hereby requests notice and copies ofall motions notices,
reports, briefs, applications, adversary proceedings, proposed orders, confirmed copies oforders, any proposed disclosure statement
or plan of reorganization that has been filed with the courl, any other documents or instruments filed in the above-referenced
proceedings and any other matter in which notice is required pursuant to 11 U.S.C. Sec. 1109(b) and Bankruptcy Rules 2002(a) and
(b), 3017(a), and 9013 ofthe Federal Rules ofBankruptcy Procedure.
Copies should be mailed to the secured creditor(s) in care of the undersigned at the address set forlh below.
Certificate of Service
TRUSTEE (NY)
74 CHAPEL STREET
ALBANY, NY 12207
LINEBARGER GOGGAN BLAIR & SAMPSON, LLP
PO Box 3064
HOUSTON, TX77253-3064
Telephone: (713) 844-3400
Facsimile: (713) 844-3503
Email houston .com
0s874400 TX

I have it. Its just confirmation of Chapter 15 Petition for recognition of foreign proceeding, with a Fed Ex delivery receipt

I can't see any new docs just the same 6 from last week., I previously provided doc 2.

Monday, October 28, 2019
misc Add Judge Mon 8:35 AM
Judge Michael E. Wiles added to the case. (Porter, Minnie)


Friday, October 25, 2019
6 ? 2 pgs ans Statement Fri 6:34 PM
Statement pursuant to Fed. R. of Bankr. P. 9017 and Fed. R. of Civ. P. 44.1 Related [+] filed by Warren E. Gluck on behalf of Frontera Resources Caucasus Corp., David Griffin. (Gluck, Warren)


5 ? 5 pgs motion Motion to Allow Fri 6:31 PM
Motion to Allow Entry of Order Specifying Form and Manner of Service of Notice filed by Warren E. Gluck on behalf of Frontera Resources Caucasus Corp., David Griffin. (Gluck, Warren)


Att: 1 ? 4 pgs Exhibit A: (PROPOSED) Order
Att: 2 ? 3 pgs Exhibit B: (PROPOSED) Notice
4 ? 2 pgs ans Declaration Fri 6:20 PM
Declaration of Warren E. Gluck in Support Related [+] filed by Warren E. Gluck on behalf of Frontera Resources Caucasus Corp., David Griffin. (Gluck, Warren)


3 ? 22 pgs ans Declaration Fri 6:18 PM
Declaration Benjamin Hobden in Support Related [+] filed by Warren E. Gluck on behalf of Frontera Resources Caucasus Corp., David Griffin. (Gluck, Warren)


Att: 1 ? Exhibit 1: Excerpts of Cayman Islands Insolvency Laws
2 ? 29 pgs ans Declaration Fri 6:12 PM
Declaration of David Griffin in Support Related [+] filed by Warren E. Gluck on behalf of Frontera Resources Caucasus Corp., David Griffin. (Gluck, Warren)


Att: 1 ? 8 pgs Exhibit 1: Supervision Order
Att: 2 ? 40 pgs Exhibit 2: Amended and Restated Memorandum and Articles of Association
Att: 3 ? 52 pgs Exhibit 3: Frontera International Corporation Note Agreement
Att: 4 ? Exhibit Ex. 4 Third Amendment to Note Agreement and Second Amendment to Global Note
Att: 5 ? Exhibit Ex. 5 Frontera Resources Caucasus Corporation Resolution
Att: 6 ? Exhibit 6: Notice of Voluntary Winding Up
Att: 7 ? 2 pgs Exhibit 7: Declaration of Solvency
Att: 8 ? Exhibit 8: Supervision Petition
Att: 9 ? 7 pgs Exhibit 9: Third Affidavit of David Martin Griffin
Att: 10 ? Exhibit 10: Statutory Notices
Att: 11 ? Exhibit 11: Publication in Cayman Islands Gazette
Att: 12 ? Exhibit 12: List filed Pursuant to Bankruptcy Rule 1007(a)(4)
1 ? misc Petition for Recognition of Foreign Proceeding (Chapter 15) Fri 5:46 PM
Chapter 15 Petition for Recognition of Foreign Proceeding . Fee Amount $1717 Filed by Warren E. Gluck of Holland & Knight LLP on behalf of Frontera Resources Caucasus Corp., David Griffin. (Gluck, Warren)


Att: 1 ? Exhibit 1: (PROPOSED) Recognition Order

158. Critical information concerning the Potential Claims is located in the United States in
the form of: (1) the books and records of FRCC and FRGC; (2) pleadings and strategy memoranda in
the Arbitration; (3) transaction documents and other corporate records concerning the Assignment and
Farmout Agreement; and (4) accounting records of FRCC and FRGC, which are in the possession of
either the Frontera Group or its external auditor, PricewaterhouseCoopers (“PwC”), each of which
maintain a place of business in Texas.
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159. Finally, the Liquidators respectfully request that the Court permit the Liquidators to
examine any witness located in the United States, including the FRCC Directors and Levan
Bakhutashvili, who, according to FRCC’s register of directors and officers, is FRCC’s Vice President,
General Counsel and Corporate Secretary, each of which appear to reside in the United States.
160. Examining witnesses with knowledge of the causes of the insolvency of FRCC and who
can assist in realization of FRCC’s remaining assets, is an essential tool in the Liquidators’ efforts. An
examination is crucial to the Liquidators’ attempt to understand FRCC’s past and current asset position,
given, among other things, the ambiguity over the true nature of the Assignment, which occurred
immediately prior to the placement of FRCC into voluntary liquidation, and the potential losses of
FRCC, as the sole shareholder of FRGC, in the event that the Georgian Government prevails in the
Arbitration.
161. Under the circumstances, the Liquidators respectfully request that, pursuant to
11 U.S.C. § 1521(a)(4), the Court allow them to commence discovery in the United States with respect
to: (1) all entities in the Frontera Group incorporated or otherwise doing business in the United States;
and (2) the FRCC Directors and officers: Steven C. Nicandros and Zaza Mamulaishvili, both in their
capacity as FRCC Directors and directors of any other member of the Frontera Group; (3) Levan
Bakhutashvili, in his capacity as Vice President, General Counsel and Corporate Secretary of FRCC;
(4) PwC; (5) any professional advisors engaged by the Frontera Group in relation to the Assignment
and Arbitration; and (6) any other related persons and entities.
162. Obtaining this information will substantially assist the Liquidators in realizing assets of
FRCC and determining whether, where and how FRCC should commence actions asserting the
Potential Claims.
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163. For all of these reasons, I respectfully request that this Court enter an Order: (i)
recognizing my colleague Andrew Morrison and I as duly authorized foreign representatives of FRCC;
(ii) recognizing the Cayman Liquidation of FRCC as a foreign main proceeding under Chapter 15 of
the Bankruptcy Code; (iii) granting the addit

145. Ultimately, any potential claims resulting from this investigation will be overseen,
managed and resolved by the Liquidators from the Cayman Islands.
146. As a result, I believe that all relevant creditors, directors, stakeholders, and shareholders
regard FRCC to be a Cayman Islands company.
147. Under the circumstances, I respectfully submit that the Cayman Islands is the COMI of
FRCC and that there is no basis for rebutting the presumption that the Cayman Islands is FRCC’s
COMI.
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148. In accordance with 11 U.S.C. § 1515(c), I am aware of no other pending foreign
insolvency proceedings, except the Cayman Liquidation, in which FRCC is the subject of the
proceeding.
149. FRCC maintains assets in this District.
150. On 20 September 2019, the Liquidators, using funds belonging to the estate of FRCC,
sent a $25,000 retainer to an account held by Holland & Knight LLP.
151. In accordance with Bankruptcy Rule 1007-1, there are no known and pending actions
in the United States in which FRCC or creditors of FRCC are parties. I note that FRCC also does not
seek provisional relief against any party at this time. The disclosures required under Bankruptcy Rule
7007.1 are attached hereto as Exhibit 12.
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RELIEF REQUESTED IN THE UNITED STATES
152. In addition to recognition of the Cayman Liquidation as a foreign main proceeding, the
Liquidators respectfully request relief authorizing discovery pursuant to 11 U.S.C. § 1521(a)(4).
153. As a result of the inaction and potentially intentional concealment of information and
documentation by the FRCC Directors, the Liquidators have been unsuccessful in their attempts to
obtain the books and records of FRCC.
154. As the sole executives of FRCC, it is a near-certainty that the FRCC Directors will be
in possession of documents in the United States that will be relevant to the Cayman Liquidation.
155. For example, these documents will be invaluable in the Liquidators’ efforts to determine
the alleged value of the shares in FRGC and the supposed multi-million dollar liabilities of FRCC, as
well as ascertain information regarding the terms of the Assignment, and whether that transaction was
in fact an arm’s length transaction for full value.
156. The Liquidators may also have potential claims against the FRCC Directors and/or other
parties arising out of the management of FRCC and/or in relation to the Assignment and the Arbitration,
all of which are the subject of ongoing investigation (the “Potential Claims”).
157. For example, the Liquidators may have potential claims against the FRCC Directors,
FRGC, and/or FRUS if the Assignment was not an arm’s length transaction for full value.

134. Upon the commencement of the voluntary liquidation in May 2019, the powers of the
FRCC Directors ceased and all activities of FRCC have been managed from the Cayman Islands by
the Liquidators.
135. The liquidation of FRCC is primarily taking place in the Cayman Islands, where both
Liquidators reside. Except for the preparing of the Petition, all of the work to date relating to the
Cayman Liquidation has been conducted from within the Cayman Islands and all of the work is
supervised by, and ultimately subject to, the supervision of the Cayman Court.
136. FRCC holds assets in the Cayman Islands, in the form of funds held in a client account
of Conyers Dill & Pearman (“Conyers”) in the Cayman Islands. The Liquidators have hired Conyers
as Cayman Islands counsel and Holland & Knight LLP as United States counsel, each to assist with
the Cayman Liquidation.
137. The Liquidators have caused the requisite statutory notices, including a notice of our
appointment as the Liquidators, and filings to be filed, published, and served with the Cayman Islands
Registrar of Companies, the Cayman Islands Gazette, and the Cayman Court.
138. We have issued numerous letters, including to the FRCC Directors, requesting further
information regarding property derivatively impacted by FRCC’s estate, such as information regarding
FRGC’s assets and affairs.
139. In addition, we have requested FRCC’s books and records from the FRCC Directors,
who have largely failed to produce the books and records.
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140. We also have taken steps to investigate the potential value of FRCC’s only known asset,
being the shares in FRGC, by investigating the circumstances and parties involved in the PSC, the
Arbitration, the Assignment and the Farmout Agreement. The investigation has been performed
exclusively from the Liquidators’ offices in the Cayman Islands.
141. Although the FRCC Directors have largely failed to provide FRCC’s books and records,
or otherwise substantively respond to the majority of the Liquidators’ requests for information, the
Liquidators have performed a thorough review of the documents they have been able to obtain, and
those obtained from publicly available information through the Liquidators’ investigation, all of which
are stored in the Cayman Islands, to attempt to understand FRCC’s assets and investments.
142. The Liquidators have also spent time corresponding with stakeholders and responding
to their queries and concerns surrounding the Cayman Liquidation.
143. Based on investigations to date, the Liquidators are developing a litigation strategy with
Cayman Islands counsel.
144. However, further investigation is essential, in particular with respect to the
unsubstantiated debt of FRCC, the Arbitration, the Assignment, the Farmout Agreement, and any
FRCC assets in the United States.

122. For these reasons, among others, the Liquidators are the persons responsible for
representing FRCC in the Cayman Liquidation and in all related matters, including this matter, as its
“foreign representative” within the meaning of section 101(24) of the Bankruptcy Code.
B. The Cayman Court is a Foreign Court and the
Cayman Liquidation is a Foreign Proceeding
123. I also have been advised that a “foreign court” is defined in section 1502(3) of the
Bankruptcy Code as “a judicial or other authority competent to control or supervise a foreign
proceeding.”
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124. I respectfully submit that the Cayman Court clearly qualifies as a “foreign court” for
purposes of section 1502(3).
125. I understand that a “foreign proceeding” is defined as a “collective judicial . . .
proceeding in a foreign county … under a law related to insolvency or the adjustment of debt in which
proceeding the assets and affairs of the debtor are subject to control or supervision by a foreign court,
for the purpose of reorganization or liquidation.” 11 U.S.C. § 101(23).
126. The Cayman Liquidation clearly qualifies as such, as it is by definition a liquidation
proceeding pursuant to and governed by the Companies Law and the CWR, under the supervision of
the Cayman Court, and existing for the benefit of all of FRCC’s creditors and stakeholders.
C. The Cayman Liquidation is a Foreign Main Proceeding
127. Finally, I am aware of the requirements for recognition as a foreign main and non-main
proceeding under Section 1517(b)(l) and (2) of the Bankruptcy Code, respectively.
128. I believe that the Cayman Liquidation qualifies as a foreign main proceeding and that
the Cayman Islands is FRCC’s center of main interests (“COMI”).
129. As demonstrated by the facts included herein, I further believe that FRCC is engaged
in non-transient economic activity in the Cayman Islands.
130. As noted above, FRCC was formed as an exempt company under the laws of the
Cayman Islands. Since its formation, including at the time of the voluntary liquidation, FRCC has
maintained its registered office in the Cayman Islands.
131. I am advised that under United States law, this fact supports a statutory presumption
that the Cayman Islands is FRCC’s COMI.
132. There is considerable additional evidence that FRCC’s COMI is the Cayman Islands.
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133. The former sole shareholder of FRCC, FIC, is a Cayman Islands registered entity, and
FRCC’s principal asset is shares in another Cayman Islands entity, FRGC. FRCC’s former registered
office provider, Maples, as well as the collateral agent under the 2020 Notes and related loan
documents, MaplesFS, are both incorporated in and operate from the Cayman Islands.