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PLAINTIFF/COUNTER-DEFENDANT ZAZA MAMULAISHVILI’S SPECIAL APPEARANCE

Plaintiff/Counter-Defendant Zaza Mamulaishvili is not subject to personal jurisdiction on Nominal Defendant Frontera Resources Corporation’s (“FRC’s”) counterclaims against him.

I. Mr. Mamulaishvili Is Not Subject to General Jurisdiction in Texas

Mr. Mamulaishvili is not subject to general jurisdiction in Texas. Mr. Mamulaishvili is a citizen of the Republic of Georgia domiciled in Georgia. Although Mr. Mamulaishvili did have an apartment in Houston at one time, Mr. Mamulaishvili never intended to remain permanently in Texas, but always intended to return to his home in Georgia.

II. FRC’s Counterclaim Does Not Arise Out of Events Occurring in Texas

FRC’s counterclaim is based entirely on events occurring in Georgia, not Texas. FRC alleges that Mr. Mamulaishvili is using a Georgian company, Green Capital, LLC, to appropriate assets supposedly indirectly belonging to FRC. See FRC’s Countercl. ¶¶ 12-13. The mechanism for this alleged misappropriation is Mr. Mamulaishvili’s supposed manipulation (through unspecified means) of a judicial proceeding in Georgia. See id. The assets FRC claims it owns are all located in Georgia. See id. ¶ 3.
None of the events giving rise to FRC’s counterclaim occurred in Texas or have any connection to Texas. Instead, they arise out of events occurring in Georgia. Moreover, none of these events have any connection to the fraud and mismanagement committed by Steven Nicandros, Luis Giusti, and Tyler Nelson that are the basis of Mr. Mamulaishvili’s shareholder derivative claims. Accordingly, Mr. Mamulaishvili is not subject to specific jurisdiction on FRC’s counterclaim.

CONCLUSION

For the foregoing reasons, Mr. Mamulaishvili respectfully requests that the Court dismiss FRC’s counterclaims for lack of personal jurisdiction.

Respectfully submitted
ORRICK, HERRINGTON & SUTCLIFFE LLP

In addition to these filings in Harris County, the following actions are taking place -

- Frontera has filed a petition seeking annulment of the decision in the Tbilisi Court by no later than May 3, 2021, and
- The Government of Georgia has sought similar relief.

It seems the GG has already had some success -

"Frontera is in the process of appealing the court’'s decision on annulment. At the same time, the court denied Frontera’'s Annulment Application, it upheld the Government’s Annulment Application and granted an injunction as to Green Capital prohibiting it from disposing of oil or other assets that were under the ownership of FRGC and further enjoined the enforcement of the court’'s decision as to Green Capital."

Pt. 5

- Frontera/FRUS did not learn of the existence of the lawsuit initiated by Green Capital or the court’'s decision until April 2021. While the Georgian court has granted the Governmentt’s Annulment Application as to Green Capital, the actions of Mr. Mamulaishvili which constitute conversion and are in competition with Frontera will continue unabated unless immediately enjoined by this Court because the Georgian injunction does not apply to Mr. Mamulaishvili.

- There exists an imminent danger that if Mr. Mamulaishvili is allowed to improperly compete against Frontera and usurp Frontera Company Opportunities pending the outcome of the Arbitration Action by seizing and disposing of its assets, Frontera will suffer immediate and irreparable harm, for which it has no adequate remedy at law. This loss will occur before Frontera’'s Application for Temporary Restraining Order can be heard if Frontera is required to give advance notice to Mr. Mamulaishvili or his counsel prior to seeking a temporary restraining order.

- Frontera owned, possessed, or had the right to 100% of its ownership interest in FEG and all of the corresponding rights and obligations under the PSC by virtue of FRGC’'s April 13, 2019 Assignment of 100% of its ownership interest to FRUS and FRUS’' reciprocal intent to assume these rights and obligations under the PSC and become a party to the PSC and accordingly a shareholder and owner of 50% ownership interest in FEG. As these rights related to oil, gas and other minerals severed from realty, they constitute personal property that can be converted. Mr. Mamulaishvili wrongfully exercised dominion or control over the property and Frontera suffered injury as a result thereof.

Pt. 4

- On March 31, 2021, the judge in the case, Judge Archil Kochlamazishvili, issued a decision against FRGC ordering FRGC to pay USD $5,800,000 to Green Capital. Of particular importance, the court’'s decision gave Green Capital the exclusive right to conduct oil and gas operations on all of Frontera’'s holdings in Georgia, also ordered that Green Capital shall be acknowledged and listed as the party on the PSC instead of FRUS, the legal owner as a result of a prior assignment, and further ordered that Green Capital shall be registered as the owner of 50% ownership interest in FEG, the Operating Company under the PSC. Based upon the seal placed on the decision of the court, the decision seems to have gone into immediate effect which means that FRGC, by virtue of Mr. Mamulaishvili and his illicit collusion with Green Capital, waived its appeal rights with respect to the claims of Green Capital in an attempt to expedite the conversion and theft. As a result, Frontera’'s holdings have been converted and stolen behind a veil of secrecy. Mr. Mamulaishvili is operating the assets he illegally converted from Frontera in competition with Frontera and in violation of his covenant not to compete with Frontera.

- Under the Civil Procedure Code of Georgia, FRUS has the right to appeal the decision either to the Tbilisi Court of Appeals or the Supreme Court of Georgia. FRUS appealed the decision against it and was advised on April 28, 2021, that the same Georgian court that ruled against FRUS in the first instance considered Frontera’'s Annulment Application and refused to annul the decision. Frontera is in the process of appealing the court’'s decision on annulment. At the same time, the court denied Frontera’'s Annulment Application, it upheld the Government’s Annulment Application and granted an injunction as to Green Capital prohibiting it from disposing of oil or other assets that were under the ownership of FRGC and further enjoined theenforcement of the court’'s decision as to Green Capital. Nevertheless, Mr. Mamulaishvili is in the process of seizing the assets of Frontera and is converting them to his use and operating under the PSC in competition with Frontera and in violation of his covenant not to compete. These improper actions will continue before a hearing can be conducted on this matter, and a temporary restraining order is needed.

-On April 1, 2021, Green Capital filed an application requesting transfer and registration of FRGC’'s 50% ownership interest in FEG under Green Capital’'s name. The very next day, on April 2, 2021, the Public Registry granted the application and issued a new company extract for FEG indicating that Green Capital is the shareholder of FEG with a 50% ownership interest in FEG. Now, Green Capital and Mr. Mamulaishvili have the ability to dismantle or dispose of assets and redistribute value to their benefit.

Pt. 3

- Curiously, the legal proceedings advanced through the Georgian court system in not only a clandestine manner, but also in record time that has astounded legal experts in the country of Georgia. By April, 2021, and within a month after the lawsuit was filed without any notice to Frontera or the governmental agencies doing business with Frontera in Georgia, a judgment was entered purporting to transfer all of the assets of FRUS to Green Capital as 100% owner. These assets are now being operated by Green Capital and Mr. Mamulaishvili, thanks to Mr. Mamulaishvili’'s deception in a Georgia court, and despite Mr. Mamulaishvilii’'s having signed a document previously evidencing and confirming FRUS’' legal ownership when he was formerly an executive at Frontera.

- Importantly, neither FRUS, the entity to whom FRGC previously assigned 100% of its ownership interest in FEG, nor the Government of Georgia were given an opportunity to participate in the court hearings in the case, even though FRUS and the Government of Georgia were the only authorized parties to the PSC. Moreover, Mr. Mamulaishvili, signing in his former capacity as a director of FRGC’'s branch office and representative of FRGC, which he is not authorized to act on behalf of, admitted to facts that were not true to the detriment of Frontera. As further evidence of his conspiracy to act in concert with Green Capital to convert Frontera assets, Mr. Mamulaishvili signed a joint statement on March 31, 2021, in which FRGC waived any right to appeal the decision.

- The accelerated basis on which the case was rushed to judgment is also highly unusual and confirms suspicions about the conspiracy that led to the court’'s decision. With the lawsuit being filed on approximately March 4, 2021 and the court’'s decision on March 31, 2021, the case was decided in less than 30 days. This is an unprecedented short period of time for hearing and adjudicating a complex civil case involving a sizeable monetary claim, without anyof the high profile interested parties having notice or an opportunity to respond, especially during the COVID-19 pandemic that has backed up the Georgian court system extensively.

Pt.2

- In particular, Green Capital, LLC, is 100% owned by Mr. Mamulaishvili’'s cousin and operated with the help of other family members, including his son and daughter. Mr. Mamulaishvili is in the process of seizing Frontera’'s assets in Georgia and registering Green Capital as the owner of Frontera’'s holdings despite the Company having invested hundreds of millions of dollars in these holdings. Frontera has no adequate remedy at law as Mr. Mamulaishvili is unable to respond in damages, and has transferred all of his assets out of Texas and the US.

-Also in accordance with the provisions of the PSC, on April 24, 2020, FRGC and FRUS signed a joint statement (“"Joint Statement”") which was sent to GOGC, reconfirming FRGC’'s April 13, 2019 assignment of 100% of its ownership interest in FEG and all of the corresponding rights and obligations under the PSC to FRUS and FRUS’'s reciprocal intent to assume these rights and obligations under the PSC and become a party to the PSC and accordingly a shareholder and owner of 50% ownership interest in FEG.

- For reasons unbeknownst to Frontera or any of its subsidiaries, and compounded by the fog/restrictions of the international COVID-19 crisis, the assignment of shares in FEG was not properly reflected in the records of the Public Registry by the Government of Georgia,thus resulting in FRGC incorrectly remaining as a registered shareholder of FEG instead of FRUS. Despite his dismissal from Frontera, Mr. Mamulaishvili took advantage of this administrative error/oversight in order to orchestrate and enable the conversion and theft of Frontera’'s holdings. This included remaining as a director of FEG for illicit purposes despite his prior dismissal.

-Unbeknownst to Frontera due to permitted confidentiality procedures associated with Georgia’'s legal system, on approximately March 4, 2021, Green Capital LLC, a limited liability company registered under the laws of Georgia, quietly filed a lawsuit against FRGC in Tbilisi City Court, Georgia, with intent to steal and take control of Frontera’'s holdings in
Georgia without challenge. Green Capital, owned by Mr. Mamulaishvillii’'s close relative, claimed that FRGC owed it money and had breached its contractual obligations to Green Capital. Even though Mr. Mamulaishvili was aware that FRGC no longer owned any of Frontera’'s assets, and even though he was removed from all of his corporate management authority and
responsibilities on August 28, 2020.

This is a long document that goes over a lot of the same information as the earlier posts. These are some edits. Pt.1

-Because of information recently discovered regarding wrongful conduct by Mr. Mamulaishvili, now including his attempt to convert and steal the holdings of the Company from Frontera despite having been relieved of his duties, Frontera is at risk of suffering irreparable harm unless this Court grants a TRO immediately. Here, the Employment Agreement between the parties specifically provides that a breach of Mr. Mamulaishvilii’'s covenant not to compete entitles Frontera to an injunction issued by any court of competent jurisdiction, restraining any further or continued breach or violation of the covenant not to compete. See, Exhibit 1-A to Declaration of Steve Nicandros, attached as Exhibit 1. Further, the contract provides that Frontera’'s right to an injunction is cumulative and in addition to and not in lieu of any other remedies to which the Company is entitled. Frontera initiated an arbitration action against Mr. Mamulaishvili alleging that he breached the Employment Agreement by engaging in wrongful conduct by failing to perform his duties using his full time, attention and energies. Frontera also asserted causes of action for breach of fiduciary duty and tortious interference. The arbitration did not seek injunctive relief against Mr. Mamulaishvili.

- Specifically, as part of a corporate financing initiative that involved a transaction between two wholly owned affiliates, Frontera assigned operational control and ownership of its business in the country of Georgia to its wholly owned subsidiary Frontera Resources U.S. LLC ("“FRUS”") on April 13, 2020, and Mr. Mamulaishvili actually signed the assignment (the "“Assignment”") that consummated the transaction. Frontera provided notice to the Georgian Oil and Gas Corporation of this Assignment by letter dated April 15, 2019. This letter was signed by Mr. Mamulaishvili as President and CEO of FRGC, thus there is no doubt that Mr. Mamulaishvili was aware that this assignment occurred.

- Just recently, in April of 2021, Frontera has discovered that Mr. Mamulaishvili is using Frontera’'s brand to operate shadow unauthorized companies (the "“Fake Frontera Companies”") that he created and orchestrated to be owned by his family members to conduct business associated with Frontera’'s holdings out of the view of Frontera’'s board of directors. He has clandestinely and illegally moved all of Frontera’'s assets in Georgia to one of the Fake Frontera Companies in the country of Georgia, Green Capital, LLC, which is also family owned, in order to hijack and steal all of Frontera’'s assets.

Pt. 4

16. Mr. Mamulaishvili no longer has any assets I know of in the U.S. His Company car has disappeared. He has stopped paying rent on leases he and his family entered into as his landlord has been in contact with Frontera. The Company has uncovered evidence that Mr. Mamulaishvili was wiring money from Frontera to himself before abandoning accounts belonging to the Company that were ultimately recovered by Frontera. I am not aware of any other assets that Mr.Mamulaishvili maintains in the United States.

17. Frontera seeks an order restraining Mr. Mamulaishvili and those acting by, through or under him from competing with Frontera or its subsidiaries in violation of his Employment Agreement and as provided in that Employment Agreement, including without limitation, operating the assets under the PSC, assisting Green Capital in operating, seizing, transferring, removing, controlling, dismantling, selling or otherwise converting these assets, taking or distributing 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. Without this relief, Frontera's interests in the PSC will be lost with no means of recover

(signed by SN dated 27/4/21)

Pt. 3

11. On March 31, 2021, the judge in the case, Judge Archil Kochlamogishvili, again without a hearing and without notice to the actual parties to the PSC, issued a decision against FRGC ordering FRGC to pay USD $5,800,000 to Green Capital, and (a) gave Green Capital the exclusive right to conduct oil and gas operations on all of Frontera’'s holdings in Georgia, (b) ordered that Green Capital shall be acknowledged and listed as the party to the PSC instead of FRUS to whom this interest was assigned, and further ordered that Green Capital shall be registered as the owner of a 50% ownership interest in the Operating Company for the PSC, which is FEG.

12. Based upon the seal placed on the decision of the court, the decision seems to have gone into immediate effect, which means that FRGC, by virtue of Mr. Mamulaishvili and his illicit collusion with Green Capital, waived FRGC’'s appeal rights in an attempt to expedite the conversion and theft.

13. On April 1, 2021, Green Capital filed an application requesting transfer and negotiation of FRGC’'s 50% ownership interest in FEG under Green Capital’'s name. The very next day, on April 2, 2021, the Public Registry granted the application and issued a new company extract for FEG indicating that Green Capital is the shareholder of FEG with a 50% ownership in in FEG.

14. Now, Green Capital and Mr. Mamulaishvili have the ability to dismantle or dispose of assets and redistribute value to their benefit. In the absence of injunctive relief, Mr. Mamulaishvili and his cousin at Green Capital could further transfer or sell these oil and gas interests, and could take the money from existing well production, or dismantle and sell the oil and gas producing assets. These assets and proceeds from these assets could disappear and Mr. Mamulaishvili and Green Capital in Georgia will be unable to respond in damages. Frontera’'s investment of hundreds of millions of dollars could be lost.

15. Frontera only learned of this lawsuit in April 2021, and has filed a petition seeking annulment of the decision in the Tbilisi Court by no later than May 3, 2021, and the Government of Georgia has sought similar relief, but the actions of Mr. Mamulaishvili in competition with Frontera will continue unabated unless immediately enjoined by this Court. Mr. Mamulaishvili has subjected himself to the jurisdiction of this Court by filing this lawsuit, and by entering into this Employment Agreement in Houston, Texas.

Pt. 2
Specifically,Mr.Mamulaishvili has stolen the Company Opportunities and is competing in violation of his Employment Agreement, even though he was removed by the Board of Directors of the Company on August 28, 2020 and terminated for cause onJanuary 15, 2021. Paragraph 22 of the Employment Agreement contains the obligation of Mr. Mamulaishvili not to "“compete with Frontera......for three (3) years after the Term of Employment.”" See, Paragraph 22(a)(i), (ii), and (iii) (the "“Covenant Not to Compete”"). Thus, Mr. Mamulaishvili cannot compete with Frontera or its subsidiaries until January 15, 2024. Paragraph 22(e) contains Mr. Mamulaishvillii’'s agreement that a breach or violation of this Covenant Not to Compete by him "“shall entitle this Company as a matter of right, to an injunction issued by any court of competent jurisdiction, restraining any further or continued breach or violation of this covenant.”" Frontera seeks such an injunction here.

5. On June 28, 1997, Frontera through its wholly owned subsidiary, Frontera Resources Georgia Corporation (“"FRGC”") entered into a Production Sharing Contract and refinery Study (the "“PSC”") with the Ministry of Fuel and Energy of Georgia and the State Company Georgian Oil.

6. On April 13, 2019, Frontera’'s wholly owned subsidiary, FRGC, assigned 100% of its rights and obligations under the PSC to Frontera Resources U.S. LLC ("“FRUS”"), which was confirmed in a letter signed by Mr. Mamulaishvili, a true and correct copy of which is attached hereto as Exhibit B. FRGC also assigned to FRUS 50% ownership of the Operating Company for the PSC, Frontera Eastern Georgia LLC ("“FEG”"), and the Government of Georgia owns the other 50% interest in FEG.

7. On April 24, 2020, FRGC and FRUS reconfirmed that FRUS now owned 100% of FRGC’'s interest in the PSC, but for reasons unbeknownst to Frontera the assignment of shares to FRUS was never properly reflected in the Public Registry of theGovernment of Georgia, so FRGC incorrectly remained as the registered shareholder instead of FRUS, and Mr. Mamulaishvili has taken advantage of this administrative error. 8. On August 28, 2020, Mr. Mamulaishvili was removed from Frontera’'s Board
of Directors and from his corporate management authority and responsibility (see, a true and correct copy of a letter from the Board of Directors signed by us and attached as Exhibit C).

9. On January 15, 2021, Mr. Mamulaishvili was terminated for cause under the Employment Agreement (see, a true and correct copy of the termination letter attached as Exhibit D).

10. On March 4, 2021, a company owned by Mr. Mamulaishvilii’'s cousin and controlled by Mr. Mamulaishvili and his family, Green Capital LLC ("“Green Capital”"), filed a lawsuit against FRGC in Tbilisi City Court, Georgia, with no notice to the parties to the PSC, FRUS and the Government of Georgia.

Pt.1

DECLARATION OF STEVE NICANDROS

1. My name is Steve Nicandros. I am over the age of 21 years and have never
been convicted of a crime involving moral turpitude. I am the Chief Executive Officer and Chairman of the Board of Frontera Resources Corporation ("“Frontera”"). In this position I have personal knowledge of the facts sworn to in this Declaration, and these facts are true and correct within my personal knowledge.

2. I have read Nominal Defendant Frontera Resources Corporation’'s Counterclaim and Application for Temporary Restraining Order, Temporary Injunction and Permanent Injunction Against Counter-Defendant Zaza Mamulaishvili ("“Mr. Mamulaishvili”"), filed subject to and without waiver of the pending arbitration seeking relief from Mr. Mamulaishvili, which was initiated prior to Plaintiff’'s action, and theppeal of the Motion to Compel Arbitration in this case, and the facts stated in the Application for Temporary Restraining Order, Temporary Injunction and Permanent Injunction are true and correct within my personal knowledge.

3. Frontera has spent more than $500,000,000 in connection with its oil and gas exploration in the Country of Georgia, and is the largest U.S. Investor in Georgia. Frontera is about to lose all of that investment and the associated value it created unless the Plaintiff, Mr. Mamulaishvili, is immediately restrained from competing with Frontera and its subsidiaries in violation of his employment agreement (the "“Employment Agreement”"). Not only is Mr. Mamulaishvili wrongfully competing with Frontera, but he is in the process of stealing its assets and operating them for his benefit, and Frontera has no adequate remedy at law.

4. A true and correct copy of the Employment Agreement with Mr. Mamulaishvili is attached as Exhibit A to this Declaration. Mr. Mamulaishvili has wrongfully "“competed with and usurped business opportunities of Frontera regarding oil and gas exploration, developing, drilling, production, geophysical or geotechnical work, seismic exploration, geophysical consulting, prospect development, prospect promotion, or design, sale, fabrication, assembly or operation of pipelines or refineries or the marketing or distribution of liquid or gaseous hydrocarbons or hydrocarbon products”" (the "“Company Opportunities”"), which is prohibited by Paragraph 22(a)(ii) of his Employment Agreement.

Pt.4

Mr. Mamulaishvili no longer has any assets in the U.S. His Company car has disappeared. He has stopped paying rent on leases he and his family entered into as his landlord has been in contact with Frontera. The Company has uncovered evidence that Mr. Mamulaishvili was wiring money from Frontera to himself before abandoning accounts belonging to the Company that were ultimately recovered by Frontera. No other assets that Mr. Mamulaishvili maintains in the United States have been identified.
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 is 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 distributing these assets or the proceeds of same, or taking any other action with respect to the PSC or any interestassigned to FRUS by assignment signed by Mr. Mamulaishvili.

The Court finds that Frontera will suffer immediate and irreparable harm if a Temporary

Restraining Order is not issued because the conduct of Mr. Mamulaishvili in converting Frontera personal property and in continuing to compete with Frontera in violation of this Employment Agreement is wrongful and if allowed to continue will deprive Frontera of its interest in the PSC, and its assets and Corporate Opportunities associated with the PSC could be lost. Frontera has no adequate remedy of law.

The Court further finds that Frontera has a probable right to relief on these claims.

Pt.3

(2) On March 31, 2021, the judge in the case, Judge Archil Kochlamogishvili, again without a hearing and without notice to the parties of the PSC, issued a decision against FRGC ordering FRGC to pay USD $5,800,000 to Green Capital, and (a) giving Green Capital the exclusive right to conduct oil and gas operations on all of Frontera’'s holdings in Georgia, (b) ordering that Green Capital shall be acknowledged and listed as the party to the PSC instead of FRUS to whom this interest was assigned, and further ordering that Green Capital shall be registered as the owner of a 50% ownership interest in the Operating Company for the PSC, which is FEG; and

(3) On April 1, 2021, Green Capital filed an application requesting transfer and negotiation of FRGC’'s 50% ownership interest in FEG under Green Capital’'s name. The very next day, on April 2, 2021, the Public Property granted the application and issued a new company extract for FEG indicating that Green Capital is the shareholder of FEG with a 50% ownership in in FEG.
Now, Mr. Mamulaishvili has the ability to dismantle or dispose of Frontera’'s assets and redistribute value to his benefit. In the absence of injunctive relief, Mr. Mamulaishvili could further transfer or sell these oil and gas interests, and could take the money from existing well production,ordismantleandselltheoilandgasproducingassets. Theseassetsandproceedsfrom these assets could disappear and Mr. Mamulaishvili will be unable to respond in damages. Frontera’'s investment of hundreds of millions of dollars could be lost with no means of recovery.

Frontera only learned of this lawsuit in April 2021. Under the Civil Procedure Code of Georgia, FRUS has the right to appeal the decision. FRUS appealed the decision against it and was advised on April 28, 2021, that the same Georgian court that ruled against FRUS in the first instance considered Frontera’'s Annulment Application and refused to annul the decision.
is in the process of appealing the court’'s decision on annulment. At the same time, the court denied Frontera’'s Annulment Application, it upheld the Governmentt’'s Annulment Application and granted an injunction as to Green Capital prohibiting it from disposing of oil or other assets that were under the ownership of FRGC and further enjoined the enforcement of the court’'s decision as to Green Capital. Frontera is in the process of filing an appeal, but the actions of Mr. Mamulaishvili in converting Frontera’'s assets and competition with Frontera will continue unabated unless immediately enjoined by this Court. Mr. Mamulaishvili has subjected himself to the jurisdiction of this Court by filing this lawsuit, and by entering into this Employment Agreement in Houston, Texas.

Pt.2

On June 28, 1997, Frontera through its wholly owned subsidiary, Frontera Resources Georgia Corporation ("“FRGC”") entered into a Production Sharing Contract and refinery Study (the "“PSC”") with the Ministry of Fuel and Energy of Georgia and the State Company Georgian Oil;

On April 13, 2019, Frontera’'s wholly owned subsidiary, FRGC, assigned 100% of the rights and obligations under the PSC to Frontera Resources U.S. LLC (“"FRUS”"), in an Assignment signed by Mr. Mamulaishvili, and FRGC also assigned to FRUS 50% ownership in the Operating Company for the PSC, Frontera Eastern Georgia LLC ("“FEG”"), with the Government of Georgia owning the other 50% interest in FEG;

On April 24, 2020, FRGC and FRUS reconfirmed that FRUS now owned 100% of FRGC’'s interest in FEG, but for reasons unbeknownst to Frontera the assignment of shares to FRUS was never properly reflected in the Public Registry of the Government of Georgia, so FRGC incorrectly remained as the registered shareholder instead of FRUS, and Mr. Mamulaishvili has taken advantage of this administrative error;

On August 28, 2020, Mr. Mamulaishvili was removed from Frontera’'s Board of Directors and from his corporate management authority and responsibility;

On January 15, 2021, Mr. Mamulaishvili was terminated for cause under the Employment Agreement;
It appears from the sworn pleadings that Mr. Mamulaishvili is not only competing with Frontera in violation of the Employment Agreement, but he is trying to steal the Company, take the Company’'s Opportunities and convert its assets to his own use based upon the following verified actions listed in chronological order:
(1) On March 4, 2021, a company owned by Mr. Mamulaishvillii’'s close relative and controlled by Mr. Mamulaishvili and his family, Green Capital LLC ("“Green Capital”"), filed a lawsuit against FRGC in Tbilisi City Court, Georgia, with no notice to the actual parties to the PSC, which are FRUS and the Government of Georgia;

(A lot more documents have been made public. They make for grim reading) Pt.1

TEMPORARY RESTRAINING ORDER

On this day came for consideration Nominal Defendant, Frontera Resources Corporation’'s
Counterclaim and Application for Temporary Restraining Order ("“TRO”"), Temporary Injunction and Permanent Injunction against Counter-Defendant, Zaza Mamulaishvili (“"Mamulaishvili”") (the "“Counterclaims”"), and pursuant to Rule 680 of the Texas Rules of Civil Procedure, this Court finds from specific facts shown by the Counterclaim that immediate and irreparable injury, loss or damage will result to Frontera.

Frontera has spent more than $500,000,000 in connection with its oil and gas exploration in the Country of Georgia, and is the largest U.S. Investor in Georgia. Frontera is about to lose all of that investment and the associated value it created unless the Plaintiff, Mr. Mamulaishvili, is immediately restrained from competing with Frontera and its subsidiaries in violation of his employment agreement (the "“Employment Agreement”"). Not only is Mr. Mamulaishvili wrongfully competing with Frontera, but he is in the process of stealing its assets and operating them for his benefit, and Frontera has no adequate remedy at law.

In breach of the Employment Agreement, Mr. Mamulaishvili has wrongfully "“competed with and usurped business opportunities of Frontera regarding oil and gas exploration, developing, drilling, production, geophysical or geotechnical work, seismic exploration, geophysical consulting, prospect development, prospect promotion, or design, sale, fabrication, assembly or operation of pipelines or refineries or the marketing or distribution of liquid or gaseous hydrocarbons or hydrocarbon products”" (the "“Company Opportunities”"), which is prohibited by Paragraph 22(a)(ii) of his Employment Agreement. Additionally, Mr. Mamulaishvili’'s actions constituteconversionofpersonalpropertybelongingtoFrontera. Specifically,Mr.Mamulaishvili has stolen the Company Opportunities and is competing in violation of his Employment Agreement, even though he was removed from the Board of Directors of the Company on August 28, 2020 and terminated for cause on January 15, 2021. Paragraph 22 of the Employment Agreement contains the obligation of Mr. Mamulaishvili not to "“compete with Frontera......for three (3) years after the Term of Employment.”" See, Paragraph 22(a)(i), (ii), and (iii) (the "“Covenant Not to Compete”"). Thus, Mr. Mamulaishvili cannot compete with Frontera or its subsidiaries until January 15, 2024. Paragraph 22(e) contains Mr. Mamulaishvillii’'s agreement that a breach or violation of this Covenant Not to Compete by him "“shall entitle this Company as a matter of right, to an injunction issued by any court of competent jurisdiction, restraining any further or continued breach or violation of this covenant.”" Frontera seeks such an injunction here.

Another US$80K passed to Cornerstone for lobbying activities

https://disclosurespreview.house.gov/ld/ldxmlrelease/2021/Q1/301269728.xml

SN etc have applied for a filing extension given advising the court that -

Appellants’ counsel have experienced major life events that have delayed the preparation of the Appellate Brief. Appellants’ counsel was recently diagnosed with an illness and had to undergo an expedited surgery on April 8, 2021, from which he is now recovering. Appellants’ other counsel has had to dedicate time and energy toward her campaign to be President of the State Bar of Texas, and voting will end this month.

II. Appellants respectfully request an extension of time to serve their Appellate Brief.

4. “On motion complying with Rule 10.5(b), the appellate court may extend the time for filing a brief and may postpone submission of the case. A motion to extend the time to file a brief may be filed before or after the date the brief is due.” Tex. R. App. P. 38.6(d).

8. Accordingly, Appellants respectfully file this Motion for Extension of Time to File Brief and request an extension of time of twenty days from the date of this filing, to May 13, 2021, to file their Appellate Brief. This is the Appellants first request for an extension of time.

10. The undersigned has attempted to confer with opposing counsel, Claudia W. Frost, four times. The first time was yesterday on a phone call. The second and third were in calls today. The fourth was an email. As of the filing of this motion, it remains unclear whether Plaintiff/Appellee is opposed or unopposed. This motion for extension of time is not for purposes of delay, but so that justice may be done. The undersigned is also unaware of any prejudice to Plaintiff/Appellee that could result from the granting of this Motion.

For these reasons, Appellants respectfully request that the Court of Appeals extend their Appellate Brief deadline to May 13, 2021 and further request all such other and relief to which they may show themselves justly entitled.

The Court has granted the request -

RE: Court of Appeals Number: 01-21-00125-CV Trial Court Case Number: 2021-03816

Style: Steve Nicandros, Luis Giusti, Tyler Nelson and Frontera Resources Corporation v. Zaza Mamulaishvila, individuall and derivatively on behalf of Frontera Resources Corporation

Please be advised that on this date the Court GRANTED Appellant’s motion to extend time to file brief in the above cause, time extended to and including Thursday, May 13, 2021.

NO FURTHER EXTENSIONS WILL BE GRANTED ABSENT EXCEPTIONAL CIRCUMSTANCES.

The case was dormant as the Mourant legal team had no way to reach ZM.

ZM recently retained US based counsel for his action against SN / TN / DA & FRR. With the support of SN, the Mourant legal team where able to show the court that a new domestic link to ZM now exists. The court reinstated the case.

Given that, it would seem logical to think this order will be granted and ZM will finally be considered duly served.

A proposed order has been submitted to the judge by the Mourant team:-

MOURANT OZANNES, Plaintiff, VS. STEVE NICANDROS and ZAZA MAMULAISHVILI, Defendants.

ORDER ON JUDGMENT CREDITOR'S MOTION FOR SUBSTITUTE SERVICE

ON THIS DAY, The Court considered Plaintiff’s Motion for Substitute Service under Texas Rules of Civil Procedure 106. It appears that Plaintiff has attempted but failed to personally serve the Defendant, ZAZA MAMULAISHVILI at the Defendant’s last known usual place of abode or business. It further appears to the Court that the matter of service ordered herein will be reasonably effective to give said Defendant notice of the lawsuit. It is therefore,

ORDERED that the Motion for Substitute Service is GRANTED. It is further,

ORDERED, that service of process may be made on Defendant, ZAZA MAMULAISHVILI, either by:

1) leaving a copy of the citation together with a copy of Plaintiff’s First Amended Notice of Foreign-Country Judgment/Action Seeking Recognition of Same and this Order authorizing substitute service attached to anyone over the age of sixteen (16) years of age at Orrick, Herrington & Sutcliffe, LLP, 609 Main Street, 40th Floor, Houston, Texas 77002, care of Claudia Wilson-Frost, attorney for Zaza Mamulaishvili; or

2) by firmly affixing a true copy of the citation together with a copy of Plaintiff’s Original Petition and Discovery and this Order authorizing substitute service attached to the front door of Orrick, Herrington & Sutcliffe, LLP, 609 Main Street, 40th Floor, Houston, Texas 77002.

It is further ORDERED that, if service is made by either of the above methods, service shall comply with all of the following provisions:

(a) a copy of the citation, petition and this Order shall be mailed by BOTH certified mail, return receipt requested, and regular first class mail to the Defendant at the same address at which service is authorized above.

(b) the return of service shall not be made until 30 days after mailing or until the process server receives back the green card from the post office, whichever is earlier;

(c) the return of service shall include a statement setting out the date of mailing and the result of mailing by certified mail and the date of mailing and the result of mailing regular mail (i.e., whether the envelope was returned by the post office, or the green card came back signed, or whatever happened as a result of the mailing); and,

(d) the executed green card or copy of any envelope returned by the post office shall be attached to the return of citation.
The return of service of the person executing service pursuant to this Order shall otherwise be made in accordance with Rules 16 and 107 of the TEXAS RULES OF CIVIL PROCEDURE.

Service will be complete upon compliance with this Order regardless of whether Defendant signs the certified mail receipt.

sandy26 - let's trust in FSHG. I am sure there will be an update when appropriate. From the number of upticks the FSHG message has received it seems people are very supportive of this initiative.