Member Info for Madpunter

Steve Nicandros responded that, at this moment, before we demonstrate commerciality and profitability, very low -because testing program has not been completed and the value has not been finally established, also because of pending lawsuits. Steve Hope then asked why Zaza Mamulaishvili's proposal is for the debt to come at a senior level? Steve Nicandros responded that, in this situation, any lender will need to have a confidence to be paid back, which is natural, and seniority is crucial for any new money to come in. Zaza Mamulaishvili responded that this new money will allow completion of the ongoing program and, if successful, will result in the Company being able to raise more money on a corporate level via new equity or debt, but on much better terms that are available now. Steve Hope stated that he would consider a loan from CEO of no more than $1 million at a subsidiary level, but any other money should come in at a parent level subject to board's unanimous approval and Outrider's approval. The Company also should continue to see if any other third party funding is available. However, allowing seniority over Outrider's notes is not an option. Zaza Mamulaishvili stated that the Company will continue searching for a third party funding but, as many times discussed previously, under current circumstances it is not possible unless Steve Hope and Outrider allow them. Steve Nicandros stated that everybody should concentrate on not allowing the Company to collapse. Andrew Szescila concurred with Steve Nicandros and stated that we need to do everything not to allow collapse, taking away the license, etc. Need to complete the program and move forward. Steve Hope noted that "I will wait to hear from further you and we will see what we can do." The meeting ended at 11 :45 CST.

As a senior note holder, he cannot allow to be in a position to be put behind senior management debt. "If I am put behind in seniority, I need to control the flow. I provided waivers, I should not be accused of bad things." "I made a proposal and happy to work with you on that proposal. But I am not willing to approve the proposal from Zaza." Zaza Mamuaishvili responded that he believed that, by putting forward his proposal, he was making a good thing for the Company and its shareholders, because "we do need to complete the ongoing operations." "However, if your [ ie, Steve Hope's] best proposal is to pay $2 million and then liquidate the Company, then NO! We will not allow you to do that!" Then Mr. Mamulaishvili asked Mr. Hope what would be the amount of funding form a third party that would be acceptable for Mr. Hope to put ahead of the secured creditor (Outrider). Steve Hope responded that to answer this question "he would need to know more details." Steve Hope then stated that "this Company is going bankrupt!" Zaza Mamulaishvili responded "this Company is NOT going bankrupt!" "You blocked JCAM's and other proposals and you want it to go bankrupt!" "I cannot allow you to do this, as I am fiduciary to the Company and its shareholders!" Zaza Mamulaishvili then stated that the Company badly needs new capital to complete the ongoing operations and that "we will do everything to raise money legally and avoid any takeover or bankruptcy!" "Can you (Steve Hope) think and give us answer what would be the funding amount that you would agree to put ahead of Outrider's secured debt?" Steve Hope responded that he could agree to up to $3 million but it should come at a parent level. If there is no other way, "we need to shit it down." Zaza Mamulaishvili: "No shutting down!" "Again, what is the amount that you would be OK with?" Steve Hope" "Perhaps $500,000? But I will have to look into it and think." Zaza Mamulaishvili stated that, although the money may eventually come at parent level, "we first urgently need to complete the ongoing operations and testings." Steve Nicandros also stated that "we need to stay focused on how to complete the ongoing operations." Zaza Mamulaishvili then offered Steve Hope to "think about it and please let us know what would be an acceptable amount of funding to come in below Frontera International Corporation level. Steve Hope asked "how much would the Company be worth at a fire sale?" 2

FRONTERA RESOURCES CORPORATION Minutes of the Meeting and Record of Respective Resolutions of the Board of Directors Held On April 25, 2018 At 10:30 A.M. CST By way of telephonic conference A meeting of the duly constituted Board of Directors (the "Board") of Frontera Resources Corporation (the "Company") was duly called and held on the date and time indicated above, by way of telephonic conference call whereby all participant could hear and speak to each other. The following members of the Board were attending: Mr. Steve C. Nicandros Mr. Zaza Mamulaishvili Mr. Stephen M. Hope Mr. Andrew J. Szescila Mr. Levan Bakhutashvili, Corporate Secretary Apologies were received from Mr. Luis Giusti who was not able to attend the meeting. It was noted that due notice had been given of the matters to be discussed at the meeting and that a quorum was present. Mr. Nicandros acted as Chairman of the meeting and Mr. Bakhutashvili as Secretary. Chairman opened the meeting and turned it over to Zaza Mamulaishvili, the Company's President and CEO. Mr. Mamulaishvili started with an update regarding status of operations at wells T-45 and Ud-2. No change at Ud-2 well which is flowing gas and water, with pressure at 600psi. At T-45, flow is 2 barrels per hour (approx. 50 barrels per day), 70% oil and 30% water, still in the testing as the well is cleaning itself. The Company is getting ready to frac Dino-2 well this week. Directors asked questions about operations and discussions ensued about T-45, Ud-2 and Dino-2 wells. It was noted that both T-45 and Ud-2 wells were at a "clean-up" stage. Steve Nicandros then offered to speak about recent email exchanges between Steve Hope and Zaza Mamulaishvili about the overall situation of the Company. Steve Hope mentioned that his view is that he wants the Company to succ~ed, however he has been the largest note holder of the Company for more than 6 years but never has been paid so far, instead he had been sued albeit he put it behind.

Posted by Taffy52 @ 13:48, plus subsequent posts @ 13:49, 13:51, 13:52 and 13:54 :-

Im going to copy here the minutes from FRR’s board meeting in April 2018. Apologies if old news but some might find interesting. Will follow with email exchange in September 2018 regarding loan notes.Will be several posts.

Posted by robberyrob on the SAVP bb @ 07:10, with the mistake posted @ 07:11 rectified :-

Not true trek.

Golden eagle was set up to get oil leases in Alaska from NordAq when NordAq defaulted on repayments of a loan AK and Lothian made to it while Devine was in charge. Despite NordAq (Devine) raising further funds. Via a farm in for NordAq.

When Devine left NordAq the new owners of NordAq wanted the leases back. You can see there was lawsuits between AK and Lothian Vs NordAq. I was mentioning it on this board at the time, and I believe the lawsuits was subsequently completed in private.

The link I posted yesterday showed that golden eagle (AK) has passed the licences back to nordaq but kept a 1.5% royalty. This seems to indicate That AK has had to transfer ownership back to Nordaq for whatever reason. This happened on Oct 18, so I expect will show up in the accounts for GE over the next year or so.

I don’t have facts, I don’t think many people will have bit it’s all a bit murky. I did hear a rumour, unsubstianted and I believe it was alleged in the court documents that the ex ceo of nordaq (Devine), subsequently went to work for Lothian (of whom AK is the 100% owner of holding all the shares today I believe) which, if true raises a question as to why he would be in favour with Lothian and AK having lost money to a deal with Nordaq. They did get some oil leases next to a rumoured 5billion barrel oil discovery though.....

I don’t expect this post to be up for long.
http://dog.dnr.alaska.gov/Documents/Leasing/2018-10-04_Assignment_Decision_NordAq_Energy_Inc_Golden_Eagle_Petroleum_Limited_v1_0.pdf

Just a bit of background really.

Posted by TrekMadone @ 07:23 :-

This is useful. It names all people involved in the LLP. Means nowt to me but the company has a suspension notice which is suspended pending objection. Their auditors also resigned but did say nothing to do with and breaches.

It’s a bit fiddly but you find your way around it. Suggest you work through the names to tie into anything you know with FRR.

https://m.thegazette.co.uk/company/OC352451

Trek

Posted by bugsy-b yesterday :-

Another company ..... ;-) Owlbrooke LLP.. 217 Bergzen Court 7 Branch Road London E14 7JZ..
https://www.companiesintheuk.co.uk/director/14436381/andrew-knott

"However earlier on in the decision the judge says "We emphasise that we place no restriction on the public identification of the members of the Icebreaker Partnerships" and "the names of the members of each partnership may be readily discovered by search".

The investors who tried to avoid taxes... (About 45% down the list)... Naughty naughty..

http://taxavoiders.blogspot.com/2014/05/breaking-ice.html

ANDREW ALLISTER KNOTT 217 BERGZEN COURT 7 BRANCH ROAD , LONDON E14 7JZ

Posted by Ivyspivey yesterday :-

https://beta.companieshouse.gov.uk/company/SC465839/filing-history/MzIxNDk2NDc5MWFkaXF6a2N4/document?format=pdf&download=0

For 2017 accounts

Golden Eagle Petroleum-Dec 2018

https://beta.companieshouse.gov.uk/company/SC465839/filing-history/MzIyMjMxNzIyM2FkaXF6a2N4/document?format=pdf&download=0

Posted by TrekMadone yesterday :-

Re address, changed to 40 Bank St, same address as Savannah Petroleum. Not exactly hidden. Previous address was also care of savp. Link is too long but it’s on companies house. See annual return 2015.

New details

https://s3.eu-west-2.amazonaws.com/document-api-images-live.ch.gov.uk/docs/QvjSs_u1CJQ-J8h1QQKVE6C8NzvYzztxzUW3jERBLRM/application-pdf?X-Amz-Algorithm=AWS4-HMAC-SHA256&X-Amz-Content-Sha256=UNSIGNED-PAYLOAD&X-Amz-Credential=ASIAWRGBDBV3NBLL2QFQ%2F20190521%2Feu-west-2%2Fs3%2Faws4_request&X-Amz-Date=20190521T175448Z&X-Amz-Expires=60&X-Amz-Security-Token=AgoJb3JpZ2luX2VjEIf%2F%2F%2F%2F%2F%2F%2F%2F%2F%2FwEaCWV1LXdlc3QtMiJGMEQCIF3IeAK7cMuOgm%2BQQgqdCXx3C6kWn4y0mz%2F5FXfOpVrCAiBg%2FKem16qbxqnWNQY79SK%2FrWyobwvkLTZqNx3iPSjc3CrjAwiQ%2F%2F%2F%2F%2F%2F%2F%2F%2F%2F8BEAEaDDQ0OTIyOTAzMjgyMiIMtw0aqDx60WZakdcnKrcDYcuphi78%2FTazTOoMtATq7bf10e9rgy%2Fx7ewObNufTUpeRdaDOsF7Ss1xcesWYvpEzxmre%2FI7bPck2VboaZ76EL00yIhI7NonThRQXzFobGXi25EBMaaeWar87XptyzLG6q6onY5JsVcSoN22sSHe68RG5xlwH%2Ff3EOCvrvThtH95mRCRGahRiYMZPsmcJodQtLrPK%2F6r8j0%2BsDauq0%2Bh1WciXQ8MIgWzsXU2xZwGEOWC6aVyDcFE6zsL0bERl56476Zxa3dI9ZrKLbp0DuXLcnHItEMRXIp3kej2T7%2BeUqeVaL6gzDdf0C9WnRMOyfYltOQlVBWi%2FXpD6UVKmZpBZS%2BdqETNtOy1Q%2Bee3c08ZjGDT%2FGr3OZ3zlkQuTAfDIWCjTNyA5TxBtWczvpT4NDs3%2BKsgxlXaZa6EPPrvzHMU5XsUEAd998cwJHCriiT5rLXWI3pwrL8Oh7P3NJHsztqC9T3hC%2FZ5wrZhVj8G1FTNeyUVtt82ehMSMvHuO27K9F6fJWOVIoDc7honfRtbSvzLpmQ%2F1oB4k76LtK3GSR0cUG4u4KOsPCXs8fWhuI0qVeW1ut6UbNuPzCeqJDnBTq1AXn1Ocllxh%2By1EBpr7x%2BYFe15VlsA64BlktcyFPA1HON4OnYBk2LD9cj%2FjvVbbDVEuba21Tzaf9utZWRwuPtuJEQ91eURd1I6YoYjP4fAEWaNgm9fcQF7MZxTglfVmnzkpRgED4375zxiOBojzptdZOW1Mq0O7fwty4VK8lt38jsum1RYwGjbOF6%2Fhxp%2FZnQLZnquNQC8imPKk6Ij8cuiDjZStvi2rv7IUqIfnVye0Wpfw7sYKM%3D&X-Amz-SignedHeaders=host&X-Amz-Signature=c6329791e52c03ee23d39651e29eb375d07b94b3b0b347c576409b64d918c153

What I am surprised at is assets in is the assets if duedil.com is correct.

https://www.duedil.com/company/gb/SC465839/golden-eagle-petroleum-limited/financials

Again all registered and declared to savp.

Trek, this post will probably delete in 24hrs like the other one.

Makes more sense on TheGazette. Assets are indicated in footnotes as investment property. As of 30/12/17 a cool $30m. A very successful person and again all in the public domain and directorships have been declared.

Trek, this message will self destruct in 60 seconds.

https://www.thegazette.co.uk/company/SC465839/filing-history/MzIxNDk2NDc5MWFkaXF6a2N4

The $150m is NOT A LOAN! It is a PSA. GC will not be paid interest, but a share of future production. IMHO it is a backstop in case the Injunction is not granted. FRR have more than one bite at the cherry. If the Preliminary injunction is not granted, they apply for the Full Injunction. If this is not granted, they Appeal. While this is happening FRR are still selling oil and gas and the asset is in another FRR company, that SH/O doesn't even know (see P7/21 lines 21-27 Hopes Response). My previous estimates for production show that if SN and ZM sign a Declaration of Solvency, they can pay the $22.9m within 12 months. IMHO they don't want to show the revenue and flow rates unless they have no choice, as it might impact on the NDA with BP. IMHO as the $150m PSA will give a bigger piece of the pie, it is Plan B, but it also allows leverage in discussions with BP, as FRR could prove up zones 21, 23 and 25 and greatly increase production.

Part 2

37. Despite numerous requests over a period of weeks, Lothian inexplicably refused
to provide this basic information. Instead, Outrider and Lothian jointly engaged in a campaign to
Case 16-08008 Document 1 Filed in TXSB on 07/21/16 Page 13 of 22
14 pressure Frontera through a series of increasingly hostile calls and emails that implied that
Frontera had fiduciary or other legal duties to open its books and records to an unknown third party with undisclosed intentions towards it. Finally, in mid-July 2016, following repeated refusals by Lothian to reveal the nature of its intended investments, the identity of its principals, the sources of its funds, and other such basic information, Frontera declined to disclose its confidential, proprietary and trade secret information to Lothian.
38. Upon information and belief, Outrider has used and has shared Frontera’s
confidential and trade secret information improperly acquired through MND, in breach of
MND’s confidentiality agreement, to induce Lothian to join in an effort to strip Frontera of its
mineral interests or otherwise to capture Frontera’s most valuable assets, to the detriment of
Frontera’s shareholders and Holdings’ other creditors.”

Always difficult to draw conclusions on this stuff - but if you track back on the Lothian suite of companies - there are quite a few - they clearly have not done anything of note. They can safely be assumed to be shell or dormant companies set up to be used when an opportunity presents itself.

Of course this may have nothing to do with the current set of circumstances - but one thing is crystal clear. In 2016 Hope introduced a company to FRR that had absolutely a zero track record in anything - operations, fund raising, trading or anything else for that matter. There has to be a reason for that introduction - and call me naive but I don’t think it was for the benefit of anyone but Hope, Knott and Musayev.

Posted by Devex on ii yesterday :-

Agreed - good to see Mr TOT back in action! A few more points regarding Lothian.

Lothian Oil and Gas Partners originally had two directors but Andrew Knott resigned on 12th December 2017, leaving just Taleh Musayev as a director. On the same day a Company called LOGP1 Ltd was registered as a “Director” - but Taleh Musayev is the only declared director for this “company within a company”. We can safely assume LOGP1 Ltd stands for Lothian Oil and Gas Partners.I

Then there is Lothian Partners Ltd and Lothian Capital Partners Ltd (amongst others of the Lothian “brand”) both only with Musayev as a Director. On 19th March 2019 the name was changed to Scintilla Financial Management Ltd, but apart from that there appears to be no other activity . So a business that appears to be inactive changed it’s name just a few months ago. May be completely irrelevant but does seem odd.

Then there is Lothian Capital Partners 1 Ltd - incorporated a long while back with Andrew Knott as Director - he remains in this role as of today and the company is reporting as dormant. So we have a Lothian Oil and Gas Partners 1 - recently renamed Scintilla - (Musayev) and a Lothian Capital Partners 1 (Knott). Don’t ask me to interpret but people usually set up, maintain and name companies for a reason - and the word Lothian is a common feature

For the record here is the transcript of the FRR court submission from 2016 regarding Lothian and Outrider - when of course Knott was clearly a Director - and clearly also knows Hope:

“…Then, in June 2016, Outrider introduced yet another entity to Frontera, Lothian
Partners (“Lothian”), which Outrider represented was interested in investing in Frontera.
Mirroring its prior conduct in concert with MND, Outrider demanded that Frontera provide
Lothain access to its confidential information in order to evaluate a potential investment by
Lothian in Frontera. At that time, Frontera, through its financial advisors Rothschild, was
already engaged in good faith efforts to reacquire or restructure its debt. Notwithstanding
Frontera’s past experience with Outrider, however, it responded to Lothian’s overture in good
faith.
36. During an introductory conversation between Lothian and Rothschild, Rothschild
requested basic information regarding Lothian’s identity, the sources of the funds it proposed to invest, the nature of its proposed investment, its past experience in similar investments, and related basic information that any oil and gas exploration company would reasonably request prior to considering disclosures of confidential information to a third party.
This information was especially crucial, in light of Frontera’s past experience with Outrider and its fraudulent attempt to present MND as a “Trojan horse” investor to obtain Frontera’s trade secrets and confidential information in aid of a hostile takeover bid.

Posted by bugsy-b @ 20:36 :-

Knott snippet

"The lawsuit NordAq brought against Devine also names two other parties from the United Kingdom as defendants -- Lothian Investment Partners and its sole shareholder, Andrew Knott.

In his lawsuit, Devine says the defendants are suing to distract NordAq shareholders after they lost "hundreds of millions" in value because Nuoxin didn't fulfill its commitment.

Devine says the defendants made their allegations based on false affidavits and misrepresentations in order to take the company from him..

What a nest of vipers...

https://advisornews.com/oarticle/former-oil-exec-says-company-made-allegations-against-him-to-distract-shareholders#.XOGugchKjIU

Posted by Ivyspivey @ 20:50 and 20:51 :-

Think you will find sole director is Michael Knott
https://beta.companieshouse.gov.uk/company/SC466102/officers

Posted by bugsy-b @ 21:04 and 21:08 :-

Ivy, This was a lawsuit from a year or two back ..
Ivy, He was summoned on 20th Dec 2016 as then head of Lothian investment partners..

Posted by Avi8r ' 21:10 :-

Brothers?
Andrew Allister Knott and Michael Knott, born 6 yrs apart, but check Lothian Investment Partners balance sheet year end 2017: https://bit.ly/2Qclutp. Michael Knott listed as a director and Andrew Knott listed as an immediate controlling party.

Posted by Ivyspivey @ 21:21 :-

Saw that Alistair had resigned from Lothian O&G Partners a year or so ago.
Just had to nip out and trim a few overhanging branches should of realised you never get things wrong lol.

The following post was posted by TrekMadone @ 16:16 :-

Posted by tot on ii :-

Thanks SB and also to Duknweev for posting further details about Andrew Knott. He does look like a weasel to me and given his history with MAN group he will have considerable experience of high frequency trading and short selling, so I wouldn’t wish to rule out him being involved in some way with shorting FRR’s stock to make it more difficult for them to raise equity finance, thus assisting Hope’s agenda.

Sweet Karolina on Advfn has a very similar posting style to Tom Winnifrith who frequently uses the terms ‘BB morons’ and ‘fuckwits’ to refer to the likes of us, so it would not surprise me at all to discover that there is some connection there. And let’s not forget that one of Winnifrith’s acolytes’ Easy Brent directly interfered in FRR’s business activities in writing to the State Agency for Oil and Gas in an attempt to get them to rescind the license for Block XII. I will therefore be bringing this matter to the company’s attention.

We now have to hope that giving Stephen Hope a right of veto on the FRR board does not prove to be a fatal mistake, and that’s why a jury trial is essential. Cross examination of Hope by any decent barrister should easily convince a jury how conflicted and self serving he has been imho, and if counsel can extract admissions of connivance with the likes of Andrew Knott and others that should lead to a substantial award of damages imo.

Tot

Posted by Symore_Bottoms on ii :-

' But I tell you what, having heavyweight, Rothchilds, in our corner will help' - taken from the end of the first paragraph below. Anyone care to elaborate on the link between FRR and the Rothchilds?

Great to see you back Mr ToT, and as usual, magnificent input to the discussion. Yes, this Andrew Knott fella looks a bit dodgy and the type that would also ‘sail close to the wind’. If this does go to a Jury trial, FRR would well be within their rights to summons him to the witness box regarding his dealings with Hope and FRR when he was at Lothians. And we don’t know what info FRR already has it’s in possession. But I tell you what, having heavyweight, Rothchilds, in our corner will help compared to this snooty nose kid.

Anyway, one other major difference I want to highlight between our situation and MOIL and that is, in the MOIL undertaking, there was a specific provision relating to the Outrider appointed Director: ‘…will not vote in any meeting of the Board where conflicted’. Well, what did we give Hope when he joined our Board??? ‘Veto’ power, which he freely exercised by rejecting at least 2 lending proposals. Was he conflicted when he used his veto? May be that is why FRR went to Cali because they feel they can present a strong case (with their lawyers) and convince the Jury.

Who knows but with legal cases, it feels like rolling the dice…and I don’t know which way it’s ultimately going to go…

Posted by Zibrahimovic @ 19:54 :-

MadP.... Frontera were founded by Bill White deputy secretary of energy in the Clinton administration. The Rothschild were big supporters of the Clinton's so no doubt mixed in the circles...

There has long been rumour that FRR were a front for Rothschild and another for the CIA. Makes you laugh that with those supposed connections that we are fighting over the left leg of Gareth Bale lol..

Posted by tot on ii :-

Hi SB,

Sorry I’ve been missing in action but I have had some pressing domestic matters to deal with over the last few weeks. Good to catch up with some excellent postings today however, including your last one which has raised my spirits somewhat.

In an earlier post you mentioned the previous hostile actions of Hope including his conspiracies with MND and Lothian Partners. Now if you check out the latter at Companies House you will see that they are effectively dormant with only one Director by the name of Andrew Knott. He has numerous other directorships however, including one of Kalan’s favourites Savannah Petroleum, where he is now President. I therefore start to wonder if Hope has an informal agreement with SAVP to sell FRR’s assets to them if he gets his sticky little hands on them.

To add weight to this possibility if you look at Lothian’s accounts for the year ending 31/07/2018 there is a strange note which simply states that
" During the year the company acted as agent for a person". Acting as agent for Hope would of course enable Andrew Knott to talk to other parties with a view to jointly developing the assets if Outrider were to be able to seize them. This could possibly be the smoking gun if it can be demonstrated that Hope was again colluding with others to seize control in advance of the loan default, and I would love to be present in court if that comes out under cross examination.

If that’s not the smoking gun I am sure there will be other examples which might only emerge once FRR’s lawyers get Hope into the witness box. After all he must have done some advance planning as to what he would do with the assets if he got his hands on them, and I am sure that FRR will have devoted a lot of time to digging up the dirt.

ATB,
Tot

Posted by Devex on ii yesterday (the last 3 paragraphs) :-

The accrued liabilities at the end of HY1 2018 were just shy of $20 million. At the mid point in 2017 they were around $10 million - and part of the share headroom (which was never used) was ear marked to cover the main part of what are clearly vendor debts. I think it is a slam dunk bet that much of this debt is to Baker Hughes.

Throughout this process we have not seen any evidence whatsoever of the vendors engaging in the process, but of course if Hope wins they are unlikely to see any return at all. If I was a vendor faced with a) the write off of some historic lending and b) the loss of a potential share in a major development opportunity I would probably do everything I could to privately help the existing owner to retain the business and the rights that go with it.

I am pretty sure that behind the scenes there is a lot more going on than we will ever know

Why is there a need for an injunction, if Block 12 has been transferred, and why is SH/O contesting the injunction?

IMHO there are a number of possible reasons.
1) It may still be possible for SH/O to apply through the courts to try and unravel the transfer and possible deal with GC.
2) SH/O may now realise that he can't get the asset and that it will revert to the GG.
3) If SH/O still pursues the asset through the courts it might delay work or a deal for FRR, or may result in the loss of Block 12 to the GG.

IMHO FRR want the injunction to prevent the points above. Whereas, the points above, give SH/O bargaining chips, which may become obsolete after the injunction is granted.

IMHO the following is what has occured :-
FRR apply for a TRO, which was declined.
FRR transfer the asset and SH/O starts to liquidate FRCC after resigning.
SH/O applies for an extension to allow extra time on the opposition to an injunction.
SH/O applies for an extension to allow extra time on the defense to the FIduciary Duties Claim.
FRR has no objections to the extra time as long as there's no stay on the Discovery.
SH/O reserves the right to contest the Discovery at a later date.
The extensions are granted.

IMHO due to the above FRR have applied for a Preliminary injunction to allow the status quo until the court hearing.