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Posted by JimSlade on the 7th November :-

Doc - Harris County (Houston, Texas)
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

Posted by Earsbern on the 7th November :-

Document 13, Texas
Post 1 of 2
IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION OUTRIDER MASTER FUND, LP, § § PLAINTIFF, § § v. § § CIVIL ACTION NO 4:19-CV-02714 § STEVE C. NICANDROS, and ZAZA MAMULAISHVILI, § § § DEFENDANTS. § PLAINTIFF’S MOTION TO CONTINUE SCHEDULING CONFERENCE Plaintiff Outrider Master Fund, LP (“Plaintiff” or “OMF”) files this its Motion to Continue Scheduling Conference to move for a continuance of at least eight (8) weeks for the Scheduling Conference in this case, which is currently scheduled for December 5, 2019, and in support thereof state as follows: Neither of the Defendants, Steve C. Nicandros (“Nicandros”) and Zaza Mamulaishvili (“Mamulaishvili”), (collectively, “Defendants”) have answered or otherwise made an appearance in this lawsuit. Plaintiff has filed a Motion for Default Judgment against Nicandros, which is
currently pending. Plaintiff recently served Mamulaishvili, who is also now in default, and is in the process of preparing a Motion for Default Judgment against Mamulaishvili as well. On July 24, 2019, the Court issued its Order Setting Conference [Dkt. 2], setting the Scheduling Conference for December 5, 2019, and ordering that Plaintiff and Defendants file a joint case management plan at least 14 days before that date—November 21, 2019. However, given the Defendants’ failure to respond or otherwise appear in this lawsuit to date, Plaintiff respectfully asks to continue the Scheduling Conference for at least eight (8) weeks so that Plaintiff can pursue its Motions for Default Judgment against Nicandros and Mamulaishvili. WHEREFORE PREMISES CONSIDERED, Plaintiff respectfully requests that this Honorable Court enter an order continuing the Scheduling Conference to a date on or after January 30, 2020.
Respectfully submitted, /s/ Natalie A. Sears Ross H. Parker Texas State Bar No. 24007804 rparker@munsch.com Natalie A. Sears Texas State Bar No. 24098400 nsears@munsch.com MUNSCH HARDT KOPF & HARR, P.C. 500 N. Akard Street, Suite 3800 Dallas, Texas 75201 Telephone No. (214) 955-7500 Facsimile No. (214) 855-7584 ATTORNEYS FOR PLAINTIFF OUTRIDER MASTER FUND, LP CERTIFICATE OF SERVICE I hereby certify that on November 6, 2019, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which will automatically send a notification ofsuch filing (NEF) on all counsel of record. /s/ Natalie A. Sears Natalie A. Sears

Posted by bugsy-b on the 6th November :-

Georgian Legal News, Amcham
"Amendments to the Law On State
Property
A bill with the following amendments to Article
36 of the Law On State Property has been
submitted to the Parliament of Georgia:
• State property may be transferred to the
holder of a mineral production licence for
temporary use without an auction;
• State property may only be transferred for
mineral resources production purposes within
the scope of the licence;

http://www.amcham.ge/res/news/0000/deloitte_2019-10-11.pdf

Posted by StarRage on the 6th November :-
The land area to be transferred under the right to use must not exceed 3 hectares

i.e 0.3 sq kilometres

Posted by spar on the 6th November :-
In reply to the link posted this is measures now being taken to stop any other transfer of mineral resources in the future. Has ZN succeeded in the transfer? Let’s wait and see ATB

Posted by offtheball on the 6th November :-
Ah, That makes a bit more sense. I thought Block 12 was transferred months ago ? Surely the amendment is to prevent something similar happening in the future ? Can't see a backdated amendment to try and stop it but you never know ..... Has the transfer completed and the GG been caught napping ?

Posted by StarRage on the 6th November :-
oftb, it's pretty unclear. The mortgage agreement stipulated asset transfer was unlawful. The court documents mentioned that FRR had attempted to transfer the asset. We have seen evidence that the transfer was rejected due to incomplete information (though it could possibly have been completed at a later date we don't know about) and we know the Cayman courts have agreed to supervise the liquidation due to (in part) the attempted asset transfer. Will most likely boil down to technical legalities in the end.

Posted by Zibrahimovic on the 6th November :-
SR you were quick to try and pish on bugsys post by claiming it only applied to a third of an acre until someone pointed out maybe the change in law was made to stop a land grab by Hope which is very plausible.

Posted by keysersoze on the 6th November :-
Starage if the legislation is not in force how can they stop FRR from transferring the block. The transfer may have been successful now that FRUS is registered. As per MPs comments previously.

Furthermore, any arbitrator will recognise this and not penalise Frr. Unless GG are playing games, hence why arbitration was postponed.

Posted by StarRage on the 6th November :-
keyser, I don't believe Bugsy's post has anything to do with FRR. The mortgage agreement that SN/ZM signed specifically stated that transfer of the asset was prohibited. My view is that ZM/SN are trying it on but will eventually get caught by the forces of justice, which means we are all fked. My opinion of course.

Posted by Oopsi on the 5th November :-

This is about an amicable parting as I have seen (quite unusual for us). Lawyers “come off the record” for two main reasons:

- Not being paid
- Conflict with their client / can’t properly advance their client’s case.

I have come off the record twice, for both the above reasons.

I’m not sure this motion is a result of Frontera not paying fees. If it was costs, then I think the firm would have said this as I can’t see that being privileged. The discussions with the firm have been going on for several months. My best guess (and we can only guess) is that it relates to not being able to properly put forward Frontera’s case/ conflict with the instructions given. Don’t forget the firm have already been slapped on the wrists once for putting forward a position which the judge did not accept as being true. They would be loathe to do this again.

Once the notice to dismiss without prejudice was rejected by Outrider, the firm applied to come off the record with the consent of Frontera. Had they been able to secure the dismissal, they would have stayed on the record and concluded the matter (as this would not require them to advance any legal points). The reality is that Frontera are going to have to pay Outrider’s costs if they want out. I don’t think any of us (including the judges that have heard the case so far) believed the case to have any serious legal merit. However, litigation is not always about winning and who has the strongest position. It is as much about tactics and putting your opponent in a forum that causes them maximum distress and inconvenience.

The first paragraph makes it abundantly clear that Frontera do not wish to continue prosecuting this case at this time and have sought to discontinue the action. The question is why? What has changed? Is it because of the advice they have received? Is it due to some external factor? Can we no longer afford the fees? Is the litigation superfluous? Are we throwing in the towel? As always, more questions than answers. It’s a binary bet. I think this latest development shows that we are closer to knowing the answer quite soon.

Posted by Freeatlast on the 5th November :-

Ave8r....with respect....the important part, in my view, is H/OR are desperate you get information.
We haven't provided discovery....the same as liquidators are in dark....we've bought time until 18th Nov 2019.
Discovery is bound to hand info on a plate to liquidators.
It's all to let the deal be done IMV.

It's all bollx.
Our council advised frr that they,(our council) should be fired, because of inability to dismiss the whole case, without prejudice to frr. * we're not paying his bills,and we want toe continue too skin Hopeless for $56 MIL.

It says.....' frr have not yet found replacement council'
So.....we've bought time.
But for what ?
It's not for just getting a new law firm, that's for sure.
Jmho

Posted by CF73 on the 5th November :-
Freeatlast, I see what you are saying, looking at the below,

"(1) that the motion will be unopposed and (2) that Defendants would extend the due date on plaintiff’s responses to discovery sufficiently to permit plaintiffs to hire new counsel to assist with their responses."

Posted by pophead on the 5th November :-
And there it is in line (2) spot on guys. Someone asked for a precis of the whole legal document. you guys have really gone for it here. What did Trump say again?????

Posted by CF73 on the 5th November :-
pophead, well what did Trump say again??

Posted by pophead on the 5th November :-
CF73 How to delay your opposition in a court battle until it become pointless and financially crippling to continue. This one just seems so much a delay tactic.

Posted by Freeatlast on the 5th November :-
I'm getting fed up with you people.
Post up where it says we've dropped the case !!!
It's not about some poxy lawyers fees !!!!!
Docs as, as yet we have not found replacement council. Why would it say that if we were quitting case.
Frr only said they would quit the fiduciary case if without prejudice. THEY KNEW HOPE WOULD'NT DO THAT.
So....then they get what they want....which is more time......till 18th Nov., and Hope to have to pay his legals.
Meanwhile.....now we see U.S. congressmen are coming to Georgia. ( thanks Sonny. )
It's all about the big picture.....not hopeless,and outsnider....FFS

Early stages of fiduciary case, we're good for Hope. He thought he would get juicy info from discovery.......WRONG.
He's being out smarted..

Post 4
III. ARGUMENT Local Rule 11-5 governs a motion to withdraw as counsel. (a) Order Permitting Withdrawal. Counsel may not withdraw from an action until relieved by order of Court after written notice has been given reasonably in advance to the client and to all other parties who have appeared in the case. (b) Conditional Withdrawal. When withdrawal by an attorney from an action is not accompanied by simultaneous appearance of substitute counsel or agreement of the party to appear pro se, leave to withdraw may be subject to the condition that papers may continue to be served on counsel for forwarding purposes, unless and until the client appears by other counsel or pro se. When this condition is imposed, counsel must notify the party of this condition. Any filed consent by the party to counsel’s withdrawal under these circumstances must include acknowledgment of this condition. Here, notice was provided to Plaintiffs well in advance of the motion hearing date, in mid-October. The withdrawal was a result of discussions between Plaintiffs and their current counsel that occurred over a period of months. Plaintiffs do not object. Counsel has provided a copy of the motion to Plaintiffs immediately upon filing it. Defendants do not object to the substance of this motion. There is no prejudice to Plaintiffs, particularly given that Plaintiffs have indicated they would voluntarily dismiss this action without prejudice if Defendants agreed. IV. CONCLUSION Undersigned counsel, TAYLOR ENGLISH DUMA, LLP, and its attorneys, William B. DeClercq, Eric S. Fisher, and John Mills respectfully request the Court enter an order relieving them as counsel. Plaintiffs and Defendants do not object; Defendants simply request a status conference be set to address the various consequences that will occur as a result of the Court’s order relieving Plaintiff’s counsel. DATED: November 5, 2019 Respectfully submitted, TAYLOR ENGLISH DUMA LLP /s/ William DeClercq William DeClercq SBN 240538

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