Member Info for Looed

Pt. 7

21. ZM has also directly reached out to the Prime Minister and the Minister of Economy and Sustainable Development of Georgia attacking the transfer to FRUS just as he tried to do in this Court, and has also attacked the lawyers for FRC and FRUS who are asserting rights on behalf of these companies, all as prohibited by the TI Order. See, Exhibit I, which is an admission by a party opponent. ZM also claims in this diatribe to be still in charge of the subsidiaries of FRC, including FRGC and FEG, and asserts that it was he who invested hundreds of millions of dollars and not FRC. Id. This continued interference by ZM in violation of the TI Order must stop.

22. In yet another letter published on August 5, 2021, to the Minister of Economy and Sustainable Development, ZM claims to be the "“biggest shareholder and creditor of Frontera Resources Corporation,”" which he is not, and further claims that he has continued as "“General Director of Frontera Resources Georgia Corporation,”" which he told this Court no longer exists. He also claims FRGC has been replaced by Green Capital as the "“contracting party”" under the PSC even though any purported transfer to Green Capital has been blocked by courts both here and in Georgia. He then interferes directly with FRC, whom he refers to as the"“American Frontera,”" and says that it has stopped operating and that he, through FEG, and Green Capital, has taken over operations. He then asks to meet with the governmental official so he and Green Capital can discuss "“further development of the project”" in direct competition with FRC. A true and correct copy of this letter is attached as Exhibit J, and is also an admission by a party opponent. ZM will not stop violating this Court’'s TI Order unless and until this Court holds him in contempt.

23. This Court, in its TI Order, enjoined ZM from further converting FRC’'s assets and competing with FRC and/or its subsidiaries in violation of his Employment Agreement. This aforementioned conduct violates the Court’'s TI Order and should be sanctioned.

V. RELIEF REQUESTED

24. ZM’'s actions are in direct conflict with the TI Order and therefore constitute civil contempt of this Court’'s TI Order. See Int’'l Union United Mine Workers of Am. v. Bagwell, 512 U.S. 821 (1994).

25. As a result, Movants request that this Court issue a Show Cause Order to require ZM to appear and following presentation of evidence, to enter an order containing appropriate sanctions against him and for such other and further relief to which Movants may show themselves justly entitled.

Pt. 6

18. Even though it is undisputed that ZM was removed from FRC’'s board of directors and from his corporate management authorities and responsibilities on August 28, 2020, and terminated for cause on January 15, 2021, ZM continues to purport to represent FRC and/or its subsidiaries in court proceedings and in communications which have been reported in Georgia television broadcasts and in ZM’'s communications with the Georgian Prime Minister, Mr. Irakli Gharibashvili. In particular, on August 3, 2021, William M. Sieber, political officer for the U.S. Embassy in Tbilisi, Georgia, contacted Steve Nicandros, the current Chairman and CEO of FRC and advised him that the U.S. Embassy had received a request from ZM to talk about the future of FRC’'s operations in Georgia. Mr. Nicandros advised Mr. Sieber of FRC’'s termination of ZM for cause in early 2021 after removing him from all of his corporate responsibilities in August 2020.

19. On August 4, 2021, one of the leading TV channels in Georgia broadcast news with the title "“Government’'s raid on American company”" in which ZM gave an interview by phone with the representation that he was acting as "“Frontera’'s”" President and misrepresenting the company to be an American company. In the same broadcast, Green Capital’'s attorney and FEG’'s attorney, Mr. Giorgi Kishmaria, also gave a speech regarding the governmentt’'s purported illegal interference with Green Capital’'s business and seizure of Green Capital property. An English translation of this speech is attached here to as Exhibit G.

20. On August 5, 2021, ZM wrote a letter to the Prime Minister of Georgia, Mr. Irakli Gharibashvili,as a representative of FEG. A true and correct copy of that letter is attached to the August 9, 2021 Declaration of Ana Rekhviashvili, which is attached as Exhibit H as Annex 1. In the letter, ZM claims to continue to represent FEG despite the fact that he has been terminated and accuses the government of not enforcing decisions including that of the Tbilisi City Court and alleges that the government "“expropriated the private property by use of force through law enforcement authorities, misappropriated company-owned crude oil that was due for realization and as of this moment, they are making all efforts to legalize this illegal and criminal act.”" ZM concluded by requesting the Prime Minister take immediate measures "“to prevent this unlawfulness, stop the oppression and violence against our company.”" However, as this Court wells knows, ZM is no longer part of that "“company.”"

Pt. 5

15. Not only did ZM violate this Court’'s TI Order by filing the Application with the Tbilisi City Court requesting the right to continue to operate and produce oil, on July 14, 2021, ZM also went to the location where the storage tanks were situated, and removed the officially placed seals on the oil storage tanks in an attempt to sell the oil extracted under the PSC. See July 14, 2021 letter from LEPL and GOGC to Investigation Services of Ministry of Finance of Georgia, LEPL National Bureau of Enforcement and Police of Dedoplistskaro Municipality attached as Annex 1 to Exhibit D, which is the August 2, 2021 Declaration of Ana Rekhviashvili. ZM is actually engaged in converting oil and gas from wells financed by FRC in violation of this Court’'s TI Order.

16. During the week of July 26, 2021, Movants’' counsel based in Tbilisi, Georgia sent a letter to LEPL requesting information about ZM’'s activities after Giorgi Tatishvili, Head of the Department of Oil and Gas, verbally advised Kakha Sharabidze, the Managing Partner of the Business Legal Bureau Law Firm, that ZM had twice showed up at the site where oil was stored, removed the officially placed seals and attempted to pump the oil in from the storage compartments into a tank he was driving. On a third occasion, ZM’'s son, Nikoloz Mamulaishvili, also arrived on the site and attempted to remove the officially placed seals and pump the seized oil into a tank he was driving. In response Mr. Giorgi Tatishvili, Head of the Department of Oil and Gas, sent the July 29, 2021 letter which is attached hereto as Annex 1 to Exhibit F, which is the July 30, 2021 Declaration of Ana Rekhviashvili.

17. ZM’'s conduct in seeking an Order from a Georgian court requesting that the officially placed seals from the wells and reservoirs holding oil produced under the PSC be removed so as to allow FEG, and its purported 50% owner, Green Capital, to continue to operate is in direct violation of this Court’'s TI Order. Further, ZM’'s action on July 14, 2021, where he removed the officially placed seal on the oil storage tanks in order to sell oil extracted under the PSC clearly constitutes a violation of the TI Order and should be immediately sanctioned with the strongest penalties available to the Court applied to ZM’'s conduct.
•• ZM is continuing to purportedly represent FRC and/or its subsidiaries; and reach out to Georgian government officials ostensibly on behalf of FRC and/or its subsidiaries.

Pt. 4

10. Thus, ZM and Green Capital have been shut down by the orders of two different courts, this Court in the TI Order and the Georgia Court in the Seizure/Suspension Order, but ZM and Green Capital have ignored the Orders of both courts. Actions by ZM Which Constitute a Violation of TI Order.

•• Requests by ZM to allow FEG to continue selling oil under the PSC.

11. On June 25, 2021, Green Capital, LLC, with ZM’'s assistance, filed an Application on Replacement of One Provisional Measure by Another in which Green Capital asked the Tbilisi City Court to lift the Seizure/Suspension Order which seized the oil, gas and other assets so that Green Capital was prohibited from selling, disposing and/or encumbering the shares in any form.

12. Green Capital’'s Application requests permission from the Tbilisi City Court to allow it to continue oil extraction/production operations under the Production Sharing Contract (“"PSC”") so as to continue to employ the people who have done the job operating under the PSC and allow Green Capital to continue selling oil and gas under the PSC. ZM has since sought to further support Green Capital. A true and correct copy of the July 26, 2021 Declaration of Ana Rekhviashvili which attaches the application filed by Green Capital as Annex 1 and the application filed by ZM on behalf of FEG as Annex 2, is attached hereto as Exhibit E. See Exhibit E, Annex 1 at p. 2.

13. On July 9, 2021, ZM, purporting to act as General Director of FRC’'s subsidiary, FEG, the operating company under the PSC, filed an Application on Engagement of a Third- Party in the Proceeding before the Tbilisi City Court supporting Green Capital’'s Application to lift the Seizure/Suspension Order. See Exhibit E, Annex 2. Thus ZM is directly assisting Green Capital in violation of this Court’'s TI Order.

14. In ZM’'s filing, he takes the position that the seizure of FEG’'s oil and gas was carried out illegally, and he requests that the Court "“immediately lift the illegal and unfounded seizures placed by the Tbilisi Enforcement Bureau on oil and gas, as well as, gas pipeline owned by [FEG].”" He also requests that the seals from the wells and reservoirs placed by the bailiff should also be lifted and notes that by removing these restrictions, FEG "“as an Operating Company, will sell oil and gas, the proceeds of which will be fully used to conduct oil and gas operations.”" See Exhibit E, Annex 2 at p. 4. Thus ZM is trying to regain control of the oil and gas wells financed by FRC, and sell the oil and gas from these wells in violation of this Court’'s TI Order.
ZM has physically tried to syphon and steal the seized oil in violation of theCourt’'s TI Order no less than three times.

Pt. 3

6. After this Court enjoined him from competing with FRC or assisting Green Capital to do so, ZM has done exactly that and has thumbed his nose at the Court. ZM has (i) continued to try and convert FRC’'s oil and gas;, (ii) contacted Georgian and U.S. government officials in Georgia purportedly on behalf of FRC and/or its subsidiaries, FRGC and FEG; (iii) filed additional written pleadings in court along with Green Capital to continue the conversion of FRC’'s assets; (iv) publicly attacked the lawyers in Georgia who actually represent FRC and/or its subsidiaries; and (v) appeared on television in Georgia claiming that he and Green Capital are the ones who own the assets of FRC and/or its subsidiaries. His conduct in face of the Court’'s TI Order is astonishing, and entirely and completely disregards the TI Order. B. Efforts by ZM to Aid and Abet Green Capital Before TRO was Entered.

7. As this Court heard during the Temporary Injunction hearing, on March 31, 2021, the Tbilisi City Court, in a nine minute hearing, rendered a decision in favor of Green Capital after ZM, purporting to act on behalf of FRGC, admitted to FRGC allegedly owing Green Capital $5,800,000 resulting in the court issuing a judgment in favor of Green Capital in the amount of $5,800,000 and also ordering that Green Capital be registered as having a 50% ownership interest in FEG in place of FRGC, among other things (“"Green Capital Judgment”")2. ZM also waived FRGC’'s right to appeal the decision. See DX 21-03 which is attached for the Court’'s convenience as Exhibit C. In accordance with the Green Capital Judgment, on April 2, 2021, Green Capital was registered as the 50% owner of FEG and Green Capital retained ZM as its General Director. This was all done without notice to the Georgian government or FRC.

C. The Georgian Government’'s Successful Appeal of the Green Capital Judgment.

8. On April 21, 2021, the JSC Georgian Oil & Gas Corporation ("“GOGC”") and LEPL State Agency of Oil & Gas (“"LEPL”") appealed the Green Capital Judgment requesting that Sections 3, 4 and 5 of the Green Capital Judgment be declared null and void.

9. On April 26, 2021, Judge Archil Kochlamazashvili, the same judge who signed the Green Capital Judgment, granted the Application filed by GOGC and LEPL (the "“Seizure/Suspension Order”") and ordered that: (a) Green Capital’'s 50% share in FEG be seized and that Green Capital be prohibited from selling or disposing or encumbering the share in any form; (b) Green Capital be prohibited from selling, disposing or encumbering "“produced oil and gas and also of movable and immovable property intended for oil and gas operations”"; and (c) the Writ of Execution that was issued on April 1, 2021 following the Green Capital Judgment be suspended. See Exhibit D which is the August 2, 2021 Declaration of Ana Rekhviashvili at Annex 2.

Pt. 2

III.TEMPORARY INJUNCTION
3. After a lengthy evidentiary hearing, on June 11, 2021, this Court granted Movant’'s Application for Temporary Injunction effective that day and signed the TI Order to that effect on June 14, 2021.1 A true and correct copy of the TI Order is attached hereto as Exhibit A. The TI Order, at pp. 5-6 provides:
Accordingly, the Court orders that Zaza Mamulaishvili and the agents, servants, employees, independent contractors, attorneys, representatives and those persons in active concert or participation with Mr. Mamulaishvili are enjoined from further converting Frontera’'s personal property and competing with Frontera or its subsidiaries in violation of his Employment Agreement and as provided in the Employment Agreement including without limitation, operating Frontera’'s assets under the PSC, assisting Green Capital in operating, seizing, transferring, removing, controlling, dismantling, selling or otherwise converting these assets, taking or distribution these assets or the proceeds of same, or taking any other action with respect to the PSC or any interest assigned to FRUS by assignment signed by Mr. Mamulaishvili.

4. As demonstrated herein, ZM is in violation of almost every aspect of the TI Order and thus should be required to show cause as to why he should not be held in contempt for blatantly violating the terms of the Court’'s TI Order.

IV. FACTUAL BACKGROUND
A. Introduction.
5. ZM swore to this Court that FRC has had "“no office, employees, or any operations in the Republic of Georgia since 2019”" (May 7, 2021 Supplemental Declaration of ZM at para. 5), but after the Court questioned him with respect to that statement, he admitted he was one of the employees of FRC in Georgia until he was terminated on January 15, 2021. He also admitted in his testimony that he was sitting in the same office, and using the same email he had used while working for FRC. He further admitted he was producing oil and gas from the same wells financed by FRC and from the same fields using the same subsidiaries of FRC, including Frontera Resources Georgia Corporation (“"FRGC”") and Frontera Eastern Georgia (“"FEG”"). He also admitted selling oil and gas and diverting the proceeds to others, including Green Capital. All of this conduct violated ZM’'s covenant not to compete under paragraph 22(a)(iii) of his Employment Agreement (the "“Agreement”"), including the prohibition on ZM continuing to compete against FRC or assist others to compete in the same business or usurp opportunities the Company holds or in which it is seeking an interest.

Pt. 1
FRONTERA RESOURCES CORPORATION AND FRONTERA RESOURCES US, LLC MOTION TO REQUIRE COUNTER-DEFENDANT, ZAZA MAMULAISHVILI, TO SHOW CAUSE AS TO WHY HE SHOULD NOT BE HELD INCONTEMPT FOR VIOLATING THE COURT’'S JUNE 11, 2021 ORDER GRANTING TEMPORARY INJUNCTION
TO THE HONORABLE JUDGE CHRISTINE WEEMS:

Nominal Defendant Frontera Resources Corporation (“"FRC”") and Third-Party Frontera Resources US, LLC (“"FRUS”") file this Motion to Require Counter-Defendant, Zaza Mamulaishvili (“"ZM”"), to Show Cause as to why he should not be held in contempt for violating the June 11, 2021 Order Granting Temporary Injunction (“"TI Order”") and in support thereof would respectfully show the Court as follows:

I. SUMMARY OF ARGUMENT
1. FRC files this Motion to hold ZM in contempt of the TI Order, which ZM has ignored with impunity and has violated in every way imaginable.

II. SERVICE OF PROCESS
2. Counter-Defendant, Zaza Mamulaishvili, may be served with process at his registration and home addresses in the Republic of Georgia, which are Kekelidze Street N5, Apt. 6, Tbilisi and Paliashvili Street N12, Tbilisi, respectively. Tex. R. Civ. P. 108a dealing with service of process in foreign countries provides that service of process may be effected upon a party in a foreign country if service of a citation and petition is made "“(a) in the manner prescribed by the law of the foreign country for service in that country in an action in any of its courts of general jurisdiction”" or "“(c) in the manner provided by Rule 106. The Civil Procedure Code of Georgia (“"CPCG”") allows service of process by courier services, phone, fax, and other technical means of communication or by using a different service procedure agreed between the parties (if applicable). If the first attempt of service is failed, the CPCG requires one more effort of service at the same address or a different address known to the parties. In a case where the party to be served refuses to receive a court summons, order or notice, service shall be considered performed where service of process is attempted twice. Additionally, the CPCG allows publication of court summons, orders and notices through widely spread newspapers. In practice, Georgian courts publish their notices via the office online Gazette of Parliament of Georgia Matsne. Movants will attempt service of process on ZM at both of the addresses known for ZM as well as via the official online Gazette and by email delivery to ZM at zmamulaishvili@gmail.com. Additionally, a copy of this pleading is being served on ZM’'s counsel of record in accordance with the Certificate of Service herein.

Letter from Ministry to Police Dept:-

Investigation Service of Ministry of Finance of Georgia

LEPL National Bureau of Enforcement Police of Dedoplistskaro Municipality N 05-153 14.07.2021

We would like to inform you that according to Tbilisi City Court ruling of April 26, 2021 (see Annex 1) and the writ of execution of April 26, 2021 issued on the basis of the mentioned ruling (see Annex 2):

1. 50% share in Frontera Eastern Georgia’'s chartered capital, which was transferred to Green Capiital LLC was seized and Green Capiital LLC was prohibited from selling, disposing and/or encumbering the shares in any form.

2. Green Capiital LLC (including the persons appointed by the latter in Frontera Eastern Georgia LCC), Frontera Resources Georgia Corporation branch in Georgia and Frontera Easttern Georgia LLC were prohibited from directly and/or through affiliated companies and/or through third parties selling/disposing and in any way encumbering extracted oil and gas, as well as the movable and immovable property aimed for oil and gas operations and owned by Frontera, Branch and Frontera Eastern Georgia LLC at the time of rendering the “"March 31 Decisiion”"; and oil and gas and other assetts/properties were seized;

Based on the mentioned writ of execution the oil storage tanks on the 12th license block were sealed jointly by the agency, the corporation and the representatives of the National Bureauof Enforcement; and according to the Letter N41815 of National Bureau of Enforcement dated July 07, 2021 (see Annex 3) Georgian Oil and Gas Corporation was instructed to carry out all necessary measures for the storage of the seized property and to transfer oil to another storage tank if required.

Today we became aware that Zaza Mamulaishvili, the registered director of Frontera Easttern Georgia arbitrarily removed the seals on oil storage tanks and attempts to sell/dispose oil extracted on the license block, by which the latter (Zaza Mamulaishvili) grossly interferes in and hinders the process of enforcement of the court decision.

Herewith, would like to inform you that 345.5 tons of state-owned oil is placed in the sealed oil storage tanks.

Based on all above-mentioned, we ask you to immediately take all the measures within your competence that are provided by the law in order to verify the above information and eliminate illegal actions.

Withal, we - LEPL State Agency of Oil and Gas and JSC Oil and Gas Corporation express our readiness to provide relevant support.

Letter from Georgian Ministry to 'our' FRC Lawyers in Georgia end July 2021 - mentions "criminal proceedings".

Mr. Kakha Sharabidze,

In response to your letter, which has been received by the Agency on July 29 of the following year and by which you requested the information regarding the incident that occurred at the collection center of Dedoplistskaro on the 12th license block, we would like to inform you the following:

As you are already aware, according to the Tbilisi City Court ruling of April 26, 2021, and the writ of execution of April 26, 2021, issued on the basis of the mentioned ruling:

1. 50% share in Frontera Eastern Georgia’s chartered capital, which was transferred to Green Capital LLC was seized and Green Capital LLC was prohibited from selling, disposing and/or encumbering the shares in any form.

2. Green Capital LLC (including the persons appointed by the latter in Frontera Eastern Georgia LCC), Frontera Resources Georgia Corporation branch in Georgia and Frontera Eastern Georgia LLC were prohibited from directly and/or through affiliated companies and/or through third parties selling/disposing and in any way encumbering extracted oil and gas, as well as the movable and immovable property aimed for oil and gas operations and owned by Frontera, Branch and Frontera Eastern Georgia LLC at the time of rendering the “March 31 Decision”; and oil and gas and other assets/properties were seized;

Based on the mentioned writ of execution the oil storage tanks on the 12th license block were sealed jointly by the agency, the corporation, and the representatives of the National Bureau; and according to the Letter N41815 of National Bureau of Enforcement dated July 07, 2021, the Corporation was instructed to carry out all necessary measures for the storage of the seized property and to transfer oil to another storage tank if required.

The Agency and the Corporation became aware, that Zaza Mamulaishvili, the registered director of Frontera Eastern Georgia arbitrarily removed the seals on oil storage tanks and attempted to sell/dispose oil extracted on the license block, by which the latter (Zaza Mamulaishvili) grossly interfered in the process of enforcement of the court decision.

Herewith, we would like to inform you that 345.5 tons of state-owned oil were placed in the sealed oil storage tanks.
Investigation Service of Ministry of Finance of Georgia, LEPL National Bureau of Enforcement and Police of Dedoplistskaro Municipality were informed regarding the abovementioned. As far as we are concerned, criminal proceedings have been already initiated against Mr. Zaza Mamulaishvili.

Sincerely,

George Tatishvili Head of the Agency

Pt. 2 (final part)

III. LEGAL PRINCIPLES

7. In determining whether ZM is in contempt, this Court is cognizant of and guided by the principle that the essence of contempt is not an offense against a particular judge’'s personal sensibilities, but is instead an affront to the authority, justice, or dignity of the Court, which conduct obstructs the proper and effective administration of justice and the ability to impose the rule of law in our society. See Brown v. United States, 356 U.S. 148 (1958).

8. Contempt has been defined as an act that is reasonably calculated to impede, embarrass or obstruct the Court in the lawful discharge of its duties. See ex parte Soape, 347 S.W.2d 621 (Tex. 1961).

IV. RANGE OF PUNISHMENT

9. The range of punishment for contempt is a fine of not more than $500 or
confinement in the county jail for a period of not more than six months, or by both a fine and a period of confinement.

V. SHOW CAUSE ORDER

10. IT IS THEREFORE ORDERED that Respondent, ZM, appear before this Court at
_____________, on the _____ day of August, 2021, to show cause why he should not be held in contempt of court and punished accordingly.

A lot of new filings in Texas as the case moves into a new phase for ZM. This is the Allegation filing:-

NOTICE OF ALLEGATIONS OF CONTEMPT AND ORDER SETTING SHOW CAUSE HEARING

NOTICE IS HEREBY GIVEN to Respondent, Zaza Mamalaishvili (“"ZM”") that certain conduct by you, more fully set forth in the Motion to Require Counter-Defendant Zaza Mamulaishvili to Show Cause as to why he Should not be Held in Contempt and herein below, is considered by this Court to be prima facie evidence of contempt of court.

I. FACTUAL ALLEGATIONS

1. ZM is the Counter-Defendant in the above entitled and numbered cause.

2. On June 11, 2021, The Court granted the Application of Frontera Resources Corporation ("“FRC”") and Third-Party Frontera Resources US, LLC’'s (“"FRUS”") Application for Temporary Injunction effective immediately. The Court signed the Temporary Injunction Order on June 14, 2021 (the "“TI Order”").

3. The TI Order at pp. 5-6 provides: Accordingly, the Court orders that Zaza Mamulaishvili and the agents, servants, employees, independent contractors, attorneys, representatives and those persons in active concert or participation with Mr. Mamulaishvili are enjoined from further converting Frontera’'s personal property and competing with Frontera or its subsidiaries in violation of his Employment Agreement and as provided in the Employment Agreement including without limitation, operating Frontera’'s assets under the PSC, assisting Green Capital in operating, seizing, transferring, removing, controlling, dismantling, selling or otherwise converting these assets, taking or distribution these assets or the proceeds of same, or taking any other action with respect to the PSC or any interest assigned to FRUS by assignment signed by Mr. Mamulaishvili.

4. Since the date of the TI Order, Movant has presented evidence that ZM has (i) continued to try and convert FRC’'s oil and gas; (ii) contacted government officials in Georgia purportedly on behalf of FRC and/or its subsidiaries, FRGC and FEG; (iii) filed additional written pleadings in court along with Green Capital to continue the conversion of FRC’'s assets; (iv) publicly attacked the lawyers in Georgia who actually represent FRC and/or its subsidiaries; and (v) appeared on television in Georgia claiming that he and Green Capital are the ones who own the assets of FRC and/or its subsidiaries.

II. ALLEGATIONS OF CONTEMPT

5. The conduct of ZM, as described herein above, is contumacious for the reason that it constitutes a direct violation of a lawful order of this Court thereby interfering with the effective administration of the Court.

6. The conduct of ZM, as described hereinabove, is contumacious because it constitutes a violation of a court order and thus interferes with the respect of the rule of law required in a lawful society.

The excellent find by cymro1864 is more to do with claims made by the journalist that Alughisvili is linked to the PM (which Alughishvili has denied) as well as comments on his business interests (also disputed). The latest article is mostly a cut & paste of other articles that discuss the oil spill from a while back. I don't think the articles state when the alledged pipe sale took place, but it reads as a historical transaction. The article also says that 'our' FRR is not to blame for the oil leak.

Whilst this points to a pattern of activity by ZM & Son Ltd that may play into the case against ZM and his cohorts, I don't think it's a road block to the positive positioning adopted by FRR and the GG.

The case in Texas was originally ZM v SN, TN, LG and FRC (collectively, 'FRC'). The case 'splits' during the Appeal as follows

Appeal to enforce Arbitration - FRC is appealing the decision that found in favor of ZM. All briefs are submitted and case is now before the court to decide next steps.

Appeal against the T.I. - ZM is appealing the decision that found in favor of FRC. Court has given FRC an additional two weeks to file their reply brief. This is due in part to ZM's attempts to disrupt the court. Further extensions have not been ruled out.

Short delay granted at the request of FRC side -https://search.txcourts.gov/SearchMedia.aspx?MediaVersionID=2618130c-6ad0-4ec1-bec9-03ef907eefc0&coa=coa01&DT=Motion&MediaID=f69128a6-1c84-4c29-b1b1-44f98e9c1b28

ZM remains as charming as ever - "While Frontera Resources Corporation timely served requests for production to Appellant, Zaza Mamulaishvili, Mamulaishvili objected to all 71 requests for production and only agreed to produce documents responsive to 8 of the requests. Frontera is making one last effort to confer and will need to file a motion to compel before the tribunal in order to have it timely heard in order to make all of the other deadlines in the Case Management Order workable"

Turns out the video clip is from July 2020, not this year as the FB link states.

This is the original source - https://rustavi2.ge/ka/news/171022

The translator has found a new 6min video from Rustavi TV broadcast end July. It shows ZM being interviewed in what is clearly the FRR office. Some of the footage might be old as they don't appear to be socially distant in some of the shots. We won't know for sure until the translation is done.

Here is the link - https://www.facebook.com/watch/?v=749454042474668

Pt. 7 (and final part)

J1 - Yes sir. This is what we have to do. We have to change the government and we have to elect them, but separately I ask you, at least, the attitude of the American establishment. In this situation, I think they are also a little confused, in the sense that Georgia is a partner for them, they are also trying to help us and maintain normal relationship with the government. Here, now they also sent us a Pfizer 500,000 doses, which was extremely important to us. But the Georgian dreams keeps doing the things that should not be done, e.g. appointing the judges, etc. More and more often we are told that this is how you are going to Russia. When will the patience bowl be filled? Can they forget Georgia and lose interest in this country or fight with the Georgian people to save something? The last question is mine and you should say goodbye.

ZM - One of the most important factors in Georgia-US relations is what is happening today. While the United States is withdrawing troops from Afghanistan, it was recently announced that it has also begun withdrawing troops from Iraq. Georgia's function in relation to the United States is changing. It will no longer be so important ...

J1 - Is the importance decresing or what?

ZM - It`s decreasing

J1 - However, maybe on the contrary, some kind of logistics center should be somewhere in this region? Maybe Georgia has this function?

ZM - Well, maybe this is the function that Georgia needs to acquire, for that both the opposition and the government need to work with the United States to make Georgia interesting for the United States again with this united position. There are a lot of our fans there and if we do nothing at all, there will still be people in Washington who are really very supportive of Georgia. But the question is, will all this be enough for us to withstand pressure from Russia? To endure Turkish-Russian relations? The growing influence of China, which will spread throughout the region and Georgia. Therefore, the most important thing here is how actively Georgia (government and opposition) will work with the United States to create a new function of interest in this bilateral relationship. Today this does not seem to be happening.

J1 - Is there any similar resource with this government?

ZM - I think it would be desirable for the Prime Minister to be more actively involved in all this and for the Gharibashvili administration to work more actively. From what I see, it does not happen. On the contrary, this relationship is becoming more and more tense and this gap in our relationship is getting deeper and deeper.

J1 - Thank you so much for participating in the show. Zaza Mamulaishvili was our guest.

https://www.youtube.com/watch?v=CJssbcGt3Fs

Pt. 6

J1 - And you are here again and you continue to work. It is an interesting story. Are you no longer called Frontera?

ZM - Yes, we are called Frontera Eastern Georgia.

J1 - OK, but what is Green Capital then?

ZM - Green Capital is one of the founders. He is a party to the contract.

J1 - Are you also planning to up “Fontera” brand as well?

ZM - Maybe but we are not planning it now.

J1 - But you will remain US company

ZM - Of course

J1 - Mr. Zaza, we have little time and I would like to ask you about the processes that are taking place in the relations between the Georgian government and the West. I would like to ask you about Gharibashvili's visit to America. You are a pretty informed person. What information do you have? Was Gharibashvili's visit to Washington planned? To what extent does Gharibashvili have a chance to be handshaken by Western politicians, and in particular US politicians, etc., especially after July 5, when he was associated with violence.

ZM - The Prime Minister of Georgia has been trying for a long time to organize his visit to the United States, in particular to Washington. But it does not turn out that way. Ther are many reasons behind. A person may go there and have a few minor meetings, but the mood is very different. It is different from what it was 2, 3 or 4 years ago. Especially what is happening lately - they are killing free speech, they are killing journalists, they are killing business, they are killing the economy, they are killing the population because the whole country is hungry. They have no job and no income. By the way, there is a lot of material that due to malnutrition, the Georgian generation is no longer growing fully. For decades to come, we will reap what is happening in Georgia now. Prime Minister Gharibashvili has no answers to this today. The answers that are expected of him in Washington.

J1 - Is he trying to get to Washington? I think he realizes that it will be uncomfortable for him and I do not think he is eager to get there

ZM - He tries to get there, but he himself realizes that it will not be an easy visit and many do not expect him there to come.

J1 - Mr. Zaza, the opposition, which has always had high hopes for its Western partners in this difficult process, still says that the Georgian Dream has crossed the red line once, crossed it twice, and that the Western partners will impose sanctions on either Georgia or Ivanishvili or Gharibashvili. We have also talked about sanctions many times in this show. Do you think that these sanctions are too abstract a hope for the Georgian political spectrum?

ZM - Sanctions are not a very abstract prospect because these sanctions have been talked about for a very long time in Washington, including in 2019, even in 2020 a bill was registered in Congress that provided for the sanctioning of public officials.

J1 - Yes sir, though it is 2021 and nothing is happening. Ivanishvili realizes that nothing will happe

Pt. 5

ZM - It was unclear because we could not understand it for some period of time. One day, high-ranking officials of the Ministry of Economy, together with the employees of the Ministry of Internal Affairs and State Security Service, announced the expropriation of private property. Crude oil prepared for sale, which should ...

J1 - And what is the formal reason for this?

ZM - The reason given was that the shareholders were arguing with each other - Frontera Resources Georgia Corporation and Frontera Resources Corporation. One is a company that lost its rights to this project 2 years ago and the other that lost all its rights to this project 1 year and 4 months ago. Therefore, when these companies were arguing, they came and seized a completely different company. Frontera Eastern Georgia is not even a party to that dispute.

J1 - What did they present to you? What documents were submitted to you?

ZM - They presented the documentation - it's about plain language to say Ms. Nino, if I had a dispute with someone about an apartment, and they would seize the apartment and they would actually come and evict you from your apartment. Here it is. Frontera Eastern Georgia has absolutely nothing to do with it. It is an operating company. This company has won the state tender, obtained a license and has had this license for 24 years. By law they have this right to conduct operations.

J1 - What is their task? Tell us briefly why they came in and what you are going to do. I would like to ask a question on another topic as well.

ZM - Their task is quite clear. 2 things are messed up. It unites people who have been marked by sharply anti-Western and anti-American propaganda for years. These are state structures. These are the Oil and Gas Corporation under the Ministry of Economy, the Oil and Gas Agency, etc., and, on the other hand, this anti-Western propaganda and direction is happily carried out by corrupt officials.

J1 - What kind of interest is there? Do they want to replace you with someone else?

ZM - I do not know who they want to replace, but the reality is that after we have done a lot of work and invested a lot of capital and proved for the first time in the history of Georgia that Georgia has its own oil and gas reserves, only after all these they wanted to take all these for themselved. It has been certified by very famous American companies.

J1 - So, you can start a new dispute against this government, right? Did the fight was in vain for so long? I have been seeing so many ads lately that Frontera has lost the dispute in arbitration. They still have it boosted on Facebook. Was it for nothing?

ZM - They forgot to mention there that they paid 45 million to get a win over the company which is in process of liquidation.

J1 - So, all was in vain?

ZM - Of course. That company does not exist

Pt. 4

J1 - It also reads: "On July 14, Frontera addressed with a statement to the Prosecutor General of Georgia requesting the criminal proceedings to be instituted against you and that Frontera intends to hold Zaza Mamulaishvili and his associates accountable for all their illegal actions against Frontera in Georgia. Frontera is working closely with the Georgian government to bring it back to normal operation and at the same time appreciates the constructive support of the Georgian government." With that I think everything is said, but now you tell me what is happening.

ZM - I heard with this statement that it turns out that they have applied to the Prosecutor's Office of Georgia. I would like to use this broadcast and address Mr. Shotadze that I will be happy to answer all the questions at any time.

J1 - To be specific, you are not the one to whom the Georgian government won the dispute in arbitration.

ZM - Yes

J1 - Please tell us what you are doing now and then I would like to ask you for an opinion on international political issues.

ZM - With pleasure. So, let`s return for 1 second to the previous topic, the Georgian government paid 45 million GEL and won this arbitration dispute with the company which is currently in the liquidation phase.

J1 - Is this company struggling to get local Frontera in its hands?

ZM - No. Fights the third front, which is no longer in the overall picture for the last 2 years.

J1 - It is a difficult situation. Then let’s move on to what’s going on here. Why did they come in and why did they seal your terminal? Do you normally continue to work?

ZM - Despite this dispute ... such things often happen in business, shareholders argue, financiers argue. This is not new, but despite all this, we still continued and continue our work.

J1 - We remember letters from congressmen and senators - American business is being harassed by the Georgian government, Frontera is an American company, and so on. Is Frontera no longer an American company today?

ZM - Frontera still operates 100% with American capital. The treaty also treats it as an American entity.

J1 - So does government want from you now?

ZM - To be honest the biggest surprise for us is this. Because instead of rejoicing over the fact that after these trials, after this tense situation, after the dismissed employees, after the reduced incomes, we again gathered new investments, interested the new companies, brought new capital into the country and continued to work normally, about 2 years ago, now, completely unexpectedly, they have taken a very vague position regarding all this and ...

J1 - What is unclear? Everything is certain.