tab 3a tab a - alvarez and marsal · 2018-09-20 · li-31 this is exhibit "a" referred to...
TRANSCRIPT
Tab ATab 3A
LI-31
This is Exhibit "A"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin Zuyu wn Hartister and Solicitor
Notary Public and Commissioner of Oaths in and for the Province of Ontario.
My commission is of tinlimitod duration.
Martin Zeyu Wu Banittef& Solicitor, Notary Public &lite 609, 33 city Centre. Diive Mississauga, ON'L5B•2N5 Tel: (905)-306 9000 Fax: (905) 306 9002
LI-31
This is Exhibit "A"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin Zuyu wn Hartister and Solicitor
Notary Public and Commissioner of Oaths in and for the Province of Ontario.
My commission is of tinlimitod duration.
Martin Zeyu Wu Banittef& Solicitor, Notary Public &lite 609, 33 city Centre. Diive Mississauga, ON'L5B•2N5 Tel: (905)-306 9000 Fax: (905) 306 9002
LI-31
This is Exhibit "A"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin Zuyu wn Hartister and Solicitor
Notary Public and Commissioner of Oaths in and for the Province of Ontario.
My commission is of tinlimitod duration.
Martin Zeyu Wu Banittef& Solicitor, Notary Public &lite 609, 33 city Centre. Diive Mississauga, ON'L5B•2N5 Tel: (905)-306 9000 Fax: (905) 306 9002
• •
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Tab 1E3Tab 3B
This is Exhibit "B"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin 7.cytt Wit Banister and Solicitor
Notary Public and Commissioner °faiths in and for the Pmt•inco otOntario.
My commi.ssion is of unlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
This is Exhibit "B"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin 7.cytt Wit Banister and Solicitor
Notary Public and Commissioner °faiths in and for the Pmt•inco otOntario.
My commi.ssion is of unlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
This is Exhibit "B"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin 7.cytt Wit Banister and Solicitor
Notary Public and Commissioner °faiths in and for the Pmt•inco otOntario.
My commi.ssion is of unlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
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Tab 3C
This is Exhibit "C"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
414
Commissioner for Taking Affidavits (or as may be)
Martin Zeyu Wu Barrister and Solicitor
Notary Public and Commissioner of Oaths in and for the Pmvince of Ontario.
My commission is of unlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
This is Exhibit "C"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
414
Commissioner for Taking Affidavits (or as may be)
Martin Zeyu Wu Barrister and Solicitor
Notary Public and Commissioner of Oaths in and for the Pmvince of Ontario.
My commission is of unlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
This is Exhibit "C"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
414
Martin Zeyu Wu Barrister and Solicitor
Notary Public and Commis loner of Oaths in and for the Province of Ontario.
My commission is of unlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
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Tab 3D
This is Exhibit "D"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin Zcyu Wu Barrister and Solicitor
Notary Public and Commissioncrof Oaths in and for the Pinvince of Ontario:
My commission is of unlimited duration.
Martin Zeyu Wu Barrister* Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B 2N5 Tel: (905) 306 9000 Fax: (905) 306 9002
This is Exhibit "D"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin Zcyu Wu Barrister and Solicitor
Notary Public and Commissioncrof Oaths in and for the Pinvince of Ontario:
My commission is of unlimited duration.
Martin Zeyu Wu Barrister* Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B 2N5 Tel: (905) 306 9000 Fax: (905) 306 9002
This is Exhibit "D"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin Zcyu Wu Barrister and Solicitor
Notary Public and Commissioncrof Oaths in and for the Pinvince of Ontario:
My commission is of unlimited duration.
Martin Zeyu Wu Barrister* Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B 2N5 Tel: (905) 306 9000 Fax: (905) 306 9002
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Tab 3E
This is Exhibit "E"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
3
Commissioner for Taking Affidavits (or as may be)
Martin Zcyu Wit Barrister and Solicitor
Notary Public and Commissioner of Oaths in and for thc Province of•Onturio.
My commission is of tmlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, I,5B 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
This is Exhibit "E"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
3
Commissioner for Taking Affidavits (or as may be)
Martin Zcyu Wit Barrister and Solicitor
Notary Public and Commissioner of Oaths in and for thc Province of•Onturio.
My commission is of tmlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, I,5B 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
This is Exhibit "E"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
3
Martin Zcyu Wit Barrister and Solicitor
Notary Public and Commissioner of Oaths in and for thc Province of•Onturio.
My commission is of tmlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, I,5B 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
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Sep 10, 2018 at 6:08:36 A Mississaug.
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This is Exhibit "F"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin ZeyuWo Batista and Solicitor
Notary Public and Commissioner of Oaths in and for the Province °Mould°.
My commission is of unlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B- 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
This is Exhibit "F"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin ZeyuWo Batista and Solicitor
Notary Public and Commissioner of Oaths in and for the Province °Mould°.
My commission is of unlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B- 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
This is Exhibit "F"
referred to in the Affidavit of
DOUG QUAN
sworn September 10, 2018
Commissioner for Taking Affidavits (or as may be)
Martin ZeyuWo Batista and Solicitor
Notary Public and Commissioner of Oaths in and for the Province °Mould°.
My commission is of unlimited duration.
Martin Zeyu Wu Barrister & Solicitor, Notary Public Suite 609, 33 City Centre Drive Mississauga, ON L5B- 2N5 Tel: (905)306 9000 Fax: (905) 306 9002
MD Health Pharmacy Accreditation #300990 Audit & Exhibits 186 Main St South
Brampton, ON L6W 2E2
Exhibit 3: Prescription Hardcopies
o Patient Verbal Verification Dates listed In the table below
o Attached are 2 pages of the prescription hardcopies received from MD Health Pharmacy
Table 2 - Patient Verbal Verification Dates
1
2 854909
3 872651
4 I 870523
5 874103:
6 870522
7 '868150
8 860538
9 1 885015.
10 i870524
11, 854905
itrayr
e, Tic
0011A.
Nov 15, 2017
Nov 15, 2017
Mar 5,2018
1 Feb 20, 2018
Mar 08, 2018
Feb 20, 2018
Feb 09;2018 ,
Dec 18, 2018
Apr 3.1., 2018
Feb 20, 2018
Nov 15, 2017
e; April 20,2018 • May 2, 2018 • April 20, 2018 • May 2, 2018
• April .13, 2018
• May ; 2018
• April 20, 2018
• May 2, 2018
• April 20, 2018. • May2, 2018
• April 20, 2018 • May 2,2018 • April 20, 2018 • May 2, 2018
• April 20, 2018 • May 2, 2018
• April 20, 2018' • May 2, 2018
• April 20, 2018 • May ; 2018 • April 20, 2018 • May 2,: 2018
Phbne,Number not,in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
•
ClaimSecure Inc. Confidential
MD Health Pharmacy Accreditation #300990 Audit & Exhibits 186 Main St South
Brampton, ON L6W 2E2
Exhibit 3: Prescription Hardcopies
o Patient Verbal Verification Dates listed In the table below
o Attached are 2 pages of the prescription hardcopies received from MD Health Pharmacy
Table 2 - Patient Verbal Verification Dates
1
2 854909
3 872651
4 I 870523
5 874103:
6 870522
7 '868150
8 860538
9 1 885015.
10 i870524
11, 854905
itrayr
e, Tic
0011A.
Nov 15, 2017
Nov 15, 2017
Mar 5,2018
1 Feb 20, 2018
Mar 08, 2018
Feb 20, 2018
Feb 09;2018 ,
Dec 18, 2018
Apr 3.1., 2018
Feb 20, 2018
Nov 15, 2017
e; April 20,2018 • May 2, 2018 • April 20, 2018 • May 2, 2018
• April .13, 2018
• May ; 2018
• April 20, 2018
• May 2, 2018
• April 20, 2018. • May2, 2018
• April 20, 2018 • May 2,2018 • April 20, 2018 • May 2, 2018
• April 20, 2018 • May 2, 2018
• April 20, 2018' • May 2, 2018
• April 20, 2018 • May ; 2018 • April 20, 2018 • May 2,: 2018
Phbne,Number not,in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
•
ClaimSecure Inc. Confidential
ittrojet,
MD Health Pharmacy Accreditation #300990 Audit & Exhibits 186 Main St South
Brampton, ON L6W 2E2
Exhibit 3: Prescription Hardcopies
o Patient Verbal Verification Dates listed in the table below
o Attached are 2 pages of the prescription hardcopies received from MD Health Pharmacy
Table 2 - Patient Verbal Verification Dates
1 854905
2 854909
3 872651
4 I 870523
5 874103:
6 870522
7 :868150
8 860538
9 l 885015.
10 870524
11, -854905
Nov 15, 2017
Nov 15, 2017 • •
Mar 5,2018
Feb 20, 2018
Mar 08, 2018 •
I Feb 20, 2018
Feb 09;2018 ,
Dec 18, 2018 •
• Apr 3.1., 2018
• • Feb 20, 2018 • •
Nov 15, 2017 •
April 20,2018 May 2, 2918 April 20, 2018 May 2, 2018
April 20, 208 May 2, 2018
April 20, 2018 May 2, 2018
April 20, 2018. May2, 2018
April 20, 2018 May 2, 2018 April 20, 2018 May 2, 2012
April 20, 2018 May 2, 2018
April 20, 2018' May 2, 2018
April 20, 2018 May 2, 2018
April 20, 2018 May 2, 2018
Phble,Nnmber not: in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
Phone Number not in service
PhOne Number not in service
ClaimSecure Inc. Confidential
Rx:860538 Mon 18-Dec-201717:56
13.312.1 O GB
MD HEALTH PHARMACY 00001/0003
Rx:885015 Wed 11-Apr-2018 11:39
RX-37
•
Rx:854905 Wed 15-Nov-201712:12
Rx:868150 Fri 09-Feb-201815:44
CS: - 55:1111..1111.111111103 ip000 F
04117/2018 11:57AM FAX 9054567403 7 -
Rx:870522 Tue 20-Feb-201817:45 ' SS
11111111.11111111MNIIII 100 TAB EzetroliOmg Ezelirnibe ( Ezeir01) 10mg DIN: 02247521 196.37/100 Dr. Keshmirian, J 186 Main Street South Brampton ON Phone; (905) 456-7774 TAKE 1 TABLET EACH DAY Orig Rx:$5.51153 Auth:200 Ronn:0 Prev:20-Nov-17(855854) Ago:92 First 20-Nov-17(855853) Coat:198,37 Mkup155.00 Fee:11.99 Total:463.36 Pato.00 Disc1.73 Old Price:460.63 T.P.:455.63 ES1(151.32); C4(1313)(150.78); CSID13)(15355) kitergles
200 TAB Losec 20mg Omeprazoie Magnesium (LOSEC) 20mg Mfr, PMS DIN: 02190915 246.56/100 On Kant -1573oo Days: 100 Dr. Keshmitlan, J Doc# 01:67128 186 Main Street South No Script Image Brampton ON REFILL (14 date e Phone: (905) 456-7774 PR II, TAKE 1 TABLET TWICE DAILY Orig Re:854939 Auth:400 R7307.0 Prev:1544ov-17(864939) Ago 86 Plist:15-Nov1705400) Coat:493,12 Mkup:400.09 Feo:11.99 Total:905.11 Pat0.04 Disc:12.12 Old Price:897.99 T.P.:892.99 - ESI(450,89); OSIDE11(442.10) MORRO • Z•MInt•Clophteanolntn2 CLORODGREUESOUPRAZOICOMPR-DROJORG -Se -iPaleg 70n10 EaCtrALOPRAIS (b. QFt. Whitnalgem,cyp2_
-4riTi4P - PapUt Ulcer Agents
200 TAB Loses 20mg Omeprazole Magnesium (LOSEC) 20mg Mfr. PMS DIN: 02190915 246.56/100 On mend: -14730 Days: 100
Dr. Keshmirian, J Dou.e 01:67128 186 Main Street South NEW RX Brampton ON No Sc Phone: (905) 458-7774 REPRI
TAKE 1 TABLET TWICE DAILY Orig Rx:890536 AUth:400 Rem:200 (1) Cost:40112 Mkup:400.00 Foe:11.99 Tota1i905.11 Pat:6.00 '1315c:7.12 TP.:892 90 - 681(450;89). 010(18)(442.101 OR • 2.P1a4s Tkog ctoeitosneuasomaPIWOLai MIEPRA7.0111 OROMRo kw Unto eacrrst.opasis in on. no mop :motto OYP2... DUPM1P ttc.UlOer Agents
Counsel Dew: Phatmedel: 0 Yee 0 Patlent [Phone El Agent; U No 0 Had before. reason: Allergies Conditions
270 CAP Lyrica 150mg Pmgebslin 150mg Mfr PMS DIN: 02268460 145.76/60 on firma -311474 Days: 90
Brampton ON REFILL (29 d Phone: (905) 456-7774
186 Main Street South No Script Image Keshrhiriart, J Doc# 01:67128
TAKE 1 CAPSULE THREE TIMES DAIL DIRECTED . Orig Rx:8$4909 Auth:10110 Ram:270 (1) Prav:09•Feb•18(865113) Ago:61 First 15-Nov47(864909) Cost:665.92 Mkup:196.78 Fee:11.99 Total:864.69 Pab0.00 Diec:286,77 Old Moe:57742 T.P.:57742 - CS(577-92) DUP/THP - Antloonyulaant;
_ Allergies --Plato §
Rx:870524 Tue 20-Feb.2018 17:46
ESI: 32-312-0V PGX5 M13 CS; BX-37065- 100 TAB Crestor 40mg Rosuvastaiin Calcium 40mg DIN: 02247164 64_89/30 On nanu:-soiso Days: 100 Dr. Keshmirian, J 186 Main street South No
Dada :6712p0t1 tart
Pl3rone:t"
(905) ON
458-7774 REFILL (8 d
TAKEi TABLET EACH DAY AS DIREC ode fix:856956 AtIth:200 Pm:2041047(855856) Ago42 First:20-Nov-17(565856) Cose218,30 Mkup:180.00. Foe:11.99 Totel:408.29 Pab0.00 T.P.:383.50 • ES1(104.97);
Disc:24.79 CSIDEXt88.531
old Price:388.50
•.:Iums:±Iyhyperilolderrsles teadco•A Nuf Wass vrtoniunge (stem)
Zolmitriptan 2.5mg Mfr; AST 90 TAB Zomig 2.5mg
DIN: 02238660 90.73/6 on Nand: -89940 Days; 90 Dr. Keshmirian, J Dolt 01:67128 186 Main Street South NEW RX Brampton ON No Sod Phone: (905)45817774 PRI TAKE 1 TABLET AS DIRECTED WHE tfrED ONCE DAILY Orig Rx:854905 Auth:200 Ronr110 (11 Cost:1,360.95 MI:up:408.n Fee:11.99 Total:1.nrizs Pat:540 Mac:143.19 T.P.:1633.04 ES1(824 41); OS(Dt3)(809.03) ORG/DRG • 3-Cipratax 10mg SSBIS; SNR1515HT-10 Al3ORISTS, DRGIDRG -3•Clpraka 20m0 85RIS; SNR18/5HT-1D ACIONIST8 • Additional DUE issues - cheek profile
Counsel Date: Phannedst: 0 Yes ❑Patient °Phone 0 Agent 0 NO U Hod berm reason:
F.61: 32-31 -INNOVGXSPN974M8 CS: RX-3706
Mir MN On Hand:4371es Days: 100
Doc* 01:87128 No Script 'ma e
REFILL (8 da
Mir: MIN
Rx:860538 Mon 18-Dec-201717:56
13.312.1 O GB
MD HEALTH PHARMACY 00001/0003
Rx:885015 Wed 11-Apr-2018 11:39
RX-37
•
Rx:854905 Wed 15-Nov-201712:12
Rx:868150 Fri 09-Feb-201815:44
CS: - 55:1111..1111.111111103 ip000 F
04117/2018 11:57AM FAX 9054567403 7 -
Rx:870522 Tue 20-Feb-201817:45 ' SS
11111111.11111111MNIIII 100 TAB EzetroliOmg Ezelirnibe ( Ezeir01) 10mg DIN: 02247521 196.37/100 Dr. Keshmirian, J 186 Main Street South Brampton ON Phone; (905) 456-7774 TAKE 1 TABLET EACH DAY Orig Rx:$5.51153 Auth:200 Ronn:0 Prev:20-Nov-17(855854) Ago:92 First 20-Nov-17(855853) Coat:198,37 Mkup155.00 Fee:11.99 Total:463.36 Pato.00 Disc1.73 Old Price:460.63 T.P.:455.63 ES1(151.32); C4(1313)(150.78); CSID13)(15355) kitergles
200 TAB Losec 20mg Omeprazoie Magnesium (LOSEC) 20mg Mfr, PMS DIN: 02190915 246.56/100 On Kant -1573oo Days: 100 Dr. Keshmitlan, J Doc# 01:67128 186 Main Street South No Script Image Brampton ON REFILL (14 date e Phone: (905) 456-7774 PR II, TAKE 1 TABLET TWICE DAILY Orig Re:854939 Auth:400 R7307.0 Prev:1544ov-17(864939) Ago 86 Plist:15-Nov1705400) Coat:493,12 Mkup:400.09 Feo:11.99 Total:905.11 Pat0.04 Disc:12.12 Old Price:897.99 T.P.:892.99 - ESI(450,89); OSIDE11(442.10) MORRO • Z•MInt•Clophteanolntn2 CLORODGREUESOUPRAZOICOMPR-DROJORG -Se -iPaleg 70n10 EaCtrALOPRAIS (b. QFt. Whitnalgem,cyp2_
-4riTi4P - PapUt Ulcer Agents
200 TAB Loses 20mg Omeprazole Magnesium (LOSEC) 20mg Mfr. PMS DIN: 02190915 246.56/100 On mend: -14730 Days: 100
Dr. Keshmirian, J Dou.e 01:67128 186 Main Street South NEW RX Brampton ON No Sc Phone: (905) 458-7774 REPRI
TAKE 1 TABLET TWICE DAILY Orig Rx:890536 AUth:400 Rem:200 (1) Cost:40112 Mkup:400.00 Foe:11.99 Tota1i905.11 Pat:6.00 '1315c:7.12 TP.:892 90 - 681(450;89). 010(18)(442.101 OR • 2.P1a4s Tkog ctoeitosneuasomaPIWOLai MIEPRA7.0111 OROMRo kw Unto eacrrst.opasis in on. no mop :motto OYP2... DUPM1P ttc.UlOer Agents
Counsel Dew: Phatmedel: 0 Yee 0 Patlent [Phone El Agent; U No 0 Had before. reason: Allergies Conditions
270 CAP Lyrica 150mg Pmgebslin 150mg Mfr PMS DIN: 02268460 145.76/60 on firma -311474 Days: 90
Brampton ON REFILL (29 d Phone: (905) 456-7774
186 Main Street South No Script Image Keshrhiriart, J Doc# 01:67128
TAKE 1 CAPSULE THREE TIMES DAIL DIRECTED . Orig Rx:8$4909 Auth:10110 Ram:270 (1) Prav:09•Feb•18(865113) Ago:61 First 15-Nov47(864909) Cost:665.92 Mkup:196.78 Fee:11.99 Total:864.69 Pab0.00 Diec:286,77 Old Moe:57742 T.P.:57742 - CS(577-92) DUP/THP - Antloonyulaant;
_ Allergies --Plato §
Rx:870524 Tue 20-Feb.2018 17:46
ESI: 32-312-0V PGX5 M13 CS; BX-37065- 100 TAB Crestor 40mg Rosuvastaiin Calcium 40mg DIN: 02247164 64_89/30 On nanu:-soiso Days: 100 Dr. Keshmirian, J 186 Main street South No
Dada :6712p0t1 tart
Pl3rone:t"
(905) ON
458-7774 REFILL (8 d
TAKEi TABLET EACH DAY AS DIREC ode fix:856956 AtIth:200 Pm:2041047(855856) Ago42 First:20-Nov-17(565856) Cose218,30 Mkup:180.00. Foe:11.99 Totel:408.29 Pab0.00 T.P.:383.50 • ES1(104.97);
Disc:24.79 CSIDEXt88.531
old Price:388.50
•.:Iums:±Iyhyperilolderrsles teadco•A Nuf Wass vrtoniunge (stem)
Zolmitriptan 2.5mg Mfr; AST 90 TAB Zomig 2.5mg
DIN: 02238660 90.73/6 on Nand: -89940 Days; 90 Dr. Keshmirian, J Dolt 01:67128 186 Main Street South NEW RX Brampton ON No Sod Phone: (905)45817774 PRI TAKE 1 TABLET AS DIRECTED WHE tfrED ONCE DAILY Orig Rx:854905 Auth:200 Ronr110 (11 Cost:1,360.95 MI:up:408.n Fee:11.99 Total:1.nrizs Pat:540 Mac:143.19 T.P.:1633.04 ES1(824 41); OS(Dt3)(809.03) ORG/DRG • 3-Cipratax 10mg SSBIS; SNR1515HT-10 Al3ORISTS, DRGIDRG -3•Clpraka 20m0 85RIS; SNR18/5HT-1D ACIONIST8 • Additional DUE issues - cheek profile
Counsel Date: Phannedst: 0 Yes ❑Patient °Phone 0 Agent 0 NO U Hod berm reason:
F.61: 32-31 -INNOVGXSPN974M8 CS: RX-3706
Mir MN On Hand:4371es Days: 100
Doc* 01:87128 No Script 'ma e
REFILL (8 da
Mir: MIN
Rx:860538 Mon 18-Dec-201717:56
E5111111WI1 O GIIIIB
•
Rx:854905 Wed 16-Nov-201712:12
90 TAB Zomig 2,5mg Zolmitriptan 2.5mg Mfr; AST DIN: 02238660 90.73/6 on Nand: -89940 Days: 90 Dr. Keshmirian, J 186 Main Street South Brampton ON Phone: (905) 45817774 TAKE 1 TABLET AS DIRECTED WHE LIKED ONCE DAILY
Doc# 01:67128 NEW RX
No Soli PRI
Rx:868150
_ •
Fri 09-Feb-201815:44
CS: - 69:111111.1111.11.03 (p000 r
MD HEALTH PHARMACY 00001/0003
Rx:885015 Wed 11-Apr-2018 11:39
CS: RX-37 270 CAP Lyrica 150mg Pmgebslin 150mg Mfr PMS DIN: 02268450 145.76/60 on Nona -311474 Days: 90
04117/2018 11: 57AM FAX 9054567403
Rx:870522 Tue 20-Feb-201817:45 ' SS
11111
12w
;
EMIR -INNtriir.11X6P14874M8 cS: RX-3706
1
100 TAB Ezetro110mg Ezelimibe ( Ezeirol ) 10mg Mfr: MN DIN: 02247521 196.37/100 on nand; .e71 es Days: 100 Dr. Keshmirian, J Doo# 01:67128 186 Main Street South No Script Ima e Brampton ON REFILL (8 da Phone; (905) 456-7774 TAKE 1 TABLET EACH DAY Orig Rx:$561153 Auth:200 Ront:0 Prev:20-Nov-17(855654) Ago:92 FIrst20.-Nov-17(656663) Coat 198.37 Miu.p165.0.0 Fee:11.99 Tote1:46126 Pat0.00 Disc:7.72 Old Price:460.63 T.P.:455.63 ESI(151.32); CAD8)(150.78); CSIDEt](153.55)
kiternies
200 TAB Losec 20mg Omeprozoie Magnesium (LOSEC) 20rng Mfr, PMS DIN: 02190915 245.56/100 On Hand:-15730o Days: 100 Dr. Keshmirian, J Doo# 01:67128 186 Main Street South No Script Image Brampton ON REFILL (14 date e Phone: (005) 456-7774 PR II, TAKE 1 TABLET TWICE DAILY Orig liv48$4039 Auth:400 RaiTa Prey:I5-Nov-17(864939) Ago 86 Plist:16-Nov17064930) Coat:493,12 Mkup:400.00 Ftiort 1.99 Tota1:005.11 Pat0.04 Disc:12.12 Old Prica:897.99 T.P.:89299 - ESI(450,89); OSID131(442.10) IMMO • zilunt•Clophteand MRS CLORODGREUESOUPRAZOIE; OORPFL., IMMO - Se-iPaleg Oft EarALOPRAIS (b. QFt. Whitnalgem,cyp2_
-0riTi4P - Peat Ulcer Agents
200 TAB Losec 20mg Omeprazole Magnesium (LOSEC) 20mg Mfr. PMS DIN: 02190915 246.56/100 On mend: -1173o0 Days: 100 Dr. Keshmirian, J Doog 01:67128 186 Main Street South NEW RX Brampton ON No Sc Phone: (905) 458-7774 REPRI
TAKE 1 TABLET TWICE DAILY Orig Rx:1190636 Atith:400 Rem:200 (1) Cost:49112 Mkup:400.00 Fee:11.99 Tota1i905.11 Pat:6.00 'Disc:7.12 TP.:692 90 - ESI(450,89): 0168161)(442.101 OR • 2•Pla4bc rknectOsitiooseuasoiesPRAZOiel MIEPRA7.0111 OReMRO kw urn sacrottoinesis is On. ea MGV3ELEOTCO OYP2... DUPMIP tio.Uloer Agontu Counsel owe: Ramada. 0 Yee 0 Pailent 0 Phbfie El Agent; U No 0 Had before. reason: Allergies Conditions
Keshrhlrian, J Doc# 01:67128 186 Main Street South No Script Image Brampton ON REFILL (29 d Phone'. (905) 456-7774 TAKE 1 CAPSULE THREE TIMES DAIL DIRECTED . Orig Ric:664909 Auth:1 Rem:270 (1) Prav:09•Fetw1 8(668113) Ago:61 Pirs615•Nov-17(864909) Cost:665.92 Mkup:196.76 Fee:11.99 Total:864.69 Pat0.00 Diec:286.77 Old Price:677.92 T.P.:577.92 - OV677-92) DUP/THP - Antisonyulaant;
_ Allergies
Rx:870524
32-312-1 0V PGX5 MEI CS; RX-37066- 100 TAB Crestor 40mg Rosuvastaiin Calcium 40mg DIN: 02247164 64_89/30 On Hand: -80160 Days: 100 Dr. Keshmirian, J 186 Main street South No
Dada :6712p0t1ko0
8
Pl3rone:t"(905ON) 458-7774 REFILL (8 d
TAKE 1 TABLET EACH DAY AS DIREC Orig Flx:866056 AUth:200 Pre4:20-Nov-17(856856) Ago:82 Firet.:20-Nov-1763656661 Cost.216.30 Mkup:180.00. Fee:11.99 Totel:4011.29 Pat0.00 T.P.:383.60 • ES1(184.97); CS(08)(188.53)
Pict:24.79 old Price:368.50
•xium:±1yhyperlipldorrslcs iimeco•A uctase tresistois (S/arm)
Orig Rs:664906 Auth:200 Fienr110 (1 Cost 1,360.95 iiikup:408.29 Fee:11.99 Total:1.781 is Pat:6,00 bisc:143.19 T.P.:1633.04 ES1(824 .01); OS(D0)(809.03) OREM RG • 3-Clpralex 10mg SSBIS; SNRIS16HT-10 ADORISTS, DRGIDRG -3•01prakir 2010 SSRIS; SNRISSHT-1D AGONISTS • Additional DUE issues - cheek profile
Counsel Date Pherinectst OW'S q Patient 0 Phone 0 Agent
No U Had before, mason:
Tue 20-Feb.2018 17:46
Mfr: MIN
Rx:854905 Wed 15440v-2017 12:12 SS
CS: RX.29 5-00030001PF OS: RX.37065•0000200
Rx:854909 Wed 15.Nov-2017 12SS:14
#q3
04/17/2018 11: 49AM FAX 90 54667903 MD HEALTH PHARMACY
lk-rv. Ana nalik,- @0001/0002
06-Mar-201810b8
90 TAB Zornig_2.0119 Zolmitriptan 2.5mg . Mfr: AST pI N: 02P8660 90,73/6 on Hard -69940 Days: 90
Dr. Keshmirien, J DWI 01:67128 186 Maki Street South NEW RX Brampton ON No Sod Phone: (905) 466-7774
TAKE 1 TABLET AS DIRECTED WHEN REQUIRED ONCE DAILY Orig Ex:864906 Atith:200 Rern:110 (1) Cost:1.386.95 Mkup:406.29 Fen:11.99 Total:1,78123 Pat:5.00 Disc:143.19 T.P.:1633.04 - ESI(824,01); 0$(091(809.03) OROIDRQ - 3-Ciprelex 10mg $SRI$; ISNRI$15H7-1D AGONISTS DRWORG - 3-04prolex 20mg SOME: 8NRISIEHT•10 AGONISTS • Additional DUE 109tree • Cheek Draft
Counsel Daft. Phermaolat OYes ❑Walt 0 Phone r]Agent U No 0 Hee before. reason: Anemia;
-.Cot rlgiglta
270 CAP Lyrica 150mg Pregabatin 150mg Mfr: PMS PIN: 02268450 145,76/60 on Hand: 411474 Days: 90
Dr, Koshmlrian, J Doc I01:87126 186 Main Street South NEW RX Brampton ON No Sod Phone: (905) 456-7774 TAKE 1 CAPSULE THREE TIMES DAIL DIRECTED
01PF • • Vit. 01..2111
240 TAB Serormet 200mg - QueliapIne Fumarate 200mg Mir, AZC t DIN' 02236953 203.61/100 on Henn:-310740 Days: 60 Dr:Kashmtrian, J DWI 01:67128 186 Mein Street South No Script Image Brampton ON REFILL (4 Phone: (905) 456-7774 RE 177,---KETTATILET871:-WITE DAILY AS DIRE T oaf, PA:eager ---- Audi:7230- -fterm4130 ( Prey:Oa-Jan-10(8821/2) Ago:56 Firat:15•Ncer•17(8548137)
2) Coot:704.58 Mkup:520.00 Pee:11.99 Total:1,236.6E Pat:0,00 Dhic:20.42 Old Price:1,221.23 T.P.:1216.23 • 681(640.86); C3(138)(576.37) motile • 2-Adopt 54,a OT PROLoNOING OENTSialsErtarete: or Prom., PIM= • 2.0101144 044 QT PROLOMMOO AGENT5105TMPAE: not-- Additional DUE Issues . cheek profile
.4"..pnclitions • •••••
Rx:870523
_ : .312. . GXSPN74M8 c ...... ....-.........-____________ 100 TAB Creator Orng Rosuvastatin Calcium 20 Mg (Creator) 20mg Mk MIN DI : 02-247_163 55.29/30 on Kane: -mos_____-____ Dim 100 ----- Dr. KeetimIriao, J --- 186 Main Street South DocAti01:67128 Brampton ON
REFILL Is da No Script Image • Phone: (505) 456.7774
TAKE 1 TABLET EACH DAY AS DIREC .... --
-67ifiTixTaiiiii -A-uti-576 ----- Iien76 Pre1a20•Nov-17(865856). Ago:92 Firsi.'20•Nov.17(855956) Pet0.00
Cost:184,30 Aikup:140.00 Fee:11.99 Total:338.29 isc:10.35 T.P.:325.94 - ESI(160.75t CS(08X180.19) Old erke:aao.o4 .5,_ouptrup. Amhyp.mothwmov HaleCo•A Raskielatit Inhibitors Maims) '-'"4-0.-s7"......
Rx:874103 or-2018 15:39
20-Feb-201817:d5 SS
Orlg Rx:864909 Auth:600 Rem:330 (1) Coat:655.92 tillwp;198.78 Fee:11.99 Total:1181489 Pat:6.00
Conditions 7:1:1166°V:112"wantil °API*
Counsel Date: Pharmacist
❑ No Had before, Muir Allergies
ESI: 32-312-INNOVNGIIH293h48 100 TAB ArimIdex 1mg Anastrozole mg Mfr: MIN DIN: 02224135. 164,15/30 on Hand: -45280 Days: 100 I Dr. KeshMirlan, J Docit 01:67128 186 Main Street South NEW RX Brampton ON No Son I e Phone: (905) 456-7774 TAKE 1 TABLET EACH DAY ;4911=874183 Auflu400 ^ Rem:300 (3) Cost:547.17 NIkup:400.00 Paa:11.99 Totall959.16 Pat0.00 T.P.:468.66 • ESI(466,56); CSID121(0.00) Disc:482.00
Dlem299,85
Counsel Dale: _ pharmacist ...__ °Yes n Patient ❑Phone ❑Agent:- 0 No .0 Had before. reason. Alletpies Conditions
Rx:854905 Wed 15440v-2017 12:12 SS
CS: RX.29 5-00030001PF OS: RX.37065•0000200
Rx:854909 Wed 15.Nov-2017 12SS:14
#q3
04/17/2018 11: 49AM FAX 90 54667903 MD HEALTH PHARMACY
lk-rv. Ana nalik,- @0001/0002
06-Mar-201810b8
90 TAB Zornig_2.0119 Zolmitriptan 2.5mg . Mfr: AST pI N: 02P8660 90,73/6 on Hard -69940 Days: 90
Dr. Keshmirien, J DWI 01:67128 186 Maki Street South NEW RX Brampton ON No Sod Phone: (905) 466-7774
TAKE 1 TABLET AS DIRECTED WHEN REQUIRED ONCE DAILY Orig Ex:864906 Atith:200 Rern:110 (1) Cost:1.386.95 Mkup:406.29 Fen:11.99 Total:1,78123 Pat:5.00 Disc:143.19 T.P.:1633.04 - ESI(824,01); 0$(091(809.03) OROIDRQ - 3-Ciprelex 10mg $SRI$; ISNRI$15H7-1D AGONISTS DRWORG - 3-04prolex 20mg SOME: 8NRISIEHT•10 AGONISTS • Additional DUE 109tree • Cheek Draft
Counsel Daft. Phermaolat OYes ❑Walt 0 Phone r]Agent U No 0 Hee before. reason: Anemia;
-.Cot rlgiglta
270 CAP Lyrica 150mg Pregabatin 150mg Mfr: PMS PIN: 02268450 145,76/60 on Hand: 411474 Days: 90
Dr, Koshmlrian, J Doc I01:87126 186 Main Street South NEW RX Brampton ON No Sod Phone: (905) 456-7774 TAKE 1 CAPSULE THREE TIMES DAIL DIRECTED
01PF • • Vit. 01..2111
240 TAB Serormet 200mg - QueliapIne Fumarate 200mg Mir, AZC t DIN' 02236953 203.61/100 on Henn:-310740 Days: 60 Dr:Kashmtrian, J DWI 01:67128 186 Mein Street South No Script Image Brampton ON REFILL (4 Phone: (905) 456-7774 RE 177,---KETTATILET871:-WITE DAILY AS DIRE T oaf, PA:eager ---- Audi:7230- -fterm4130 ( Prey:Oa-Jan-10(8821/2) Ago:56 Firat:15•Ncer•17(8548137)
2) Coot:704.58 Mkup:520.00 Pee:11.99 Total:1,236.6E Pat:0,00 Dhic:20.42 Old Price:1,221.23 T.P.:1216.23 • 681(640.86); C3(138)(576.37) motile • 2-Adopt 54,a OT PROLoNOING OENTSialsErtarete: or Prom., PIM= • 2.0101144 044 QT PROLOMMOO AGENT5105TMPAE: not-- Additional DUE Issues . cheek profile
.4"..pnclitions • •••••
Rx:870523
_ : .312. . GXSPN74M8 c ...... ....-.........-____________ 100 TAB Creator Orng Rosuvastatin Calcium 20 Mg (Creator) 20mg Mk MIN DI : 02-247_163 55.29/30 on Kane: -mos_____-____ Dim 100 ----- Dr. KeetimIriao, J --- 186 Main Street South DocAti01:67128 Brampton ON
REFILL Is da No Script Image • Phone: (505) 456.7774
TAKE 1 TABLET EACH DAY AS DIREC .... --
-67ifiTixTaiiiii -A-uti-576 ----- Iien76 Pre1a20•Nov-17(865856). Ago:92 Firsi.'20•Nov.17(855956) Pet0.00
Cost:184,30 Aikup:140.00 Fee:11.99 Total:338.29 isc:10.35 T.P.:325.94 - ESI(160.75t CS(08X180.19) Old erke:aao.o4 .5,_ouptrup. Amhyp.mothwmov HaleCo•A Raskielatit Inhibitors Maims) '-'"4-0.-s7"......
Rx:874103 or-2018 15:39
20-Feb-201817:d5 SS
Orlg Rx:864909 Auth:600 Rem:330 (1) Coat:655.92 tillwp;198.78 Fee:11.99 Total:1181489 Pat:6.00
Conditions 7:1:1166°V:112"wantil °API*
Counsel Date: Pharmacist
❑ No Had before, Muir Allergies
ESI: 32-312-INNOVNGIIH293h48 100 TAB ArimIdex 1mg Anastrozole mg Mfr: MIN DIN: 02224135. 164,15/30 on Hand: -45280 Days: 100 I Dr. KeshMirlan, J Docit 01:67128 186 Main Street South NEW RX Brampton ON No Son I e Phone: (905) 456-7774 TAKE 1 TABLET EACH DAY ;4911=874183 Auflu400 ^ Rem:300 (3) Cost:547.17 NIkup:400.00 Paa:11.99 Totall959.16 Pat0.00 T.P.:468.66 • ESI(466,56); CSID121(0.00) Disc:482.00
Dlem299,85
Counsel Dale: _ pharmacist ...__ °Yes n Patient ❑Phone ❑Agent:- 0 No .0 Had before. reason. Alletpies Conditions
Rx:854905 Wed 15440v-2017 12:12 SS
CS: RX.29 5-00030001PF OS: RX.37065•0000200
Rx:854909 Wed 15.Nov-2017 12SS:14
#q3
04/17/2018 11: 49AM FAX 90 54667903 MD HEALTH PHARMACY
lk-rv. Ana nal& - @0001/0002
o6-Mar-2o18 10b8
90 TAB Zornig_2.0119 Zolmitriptan 2.5mg . Mfr: AST pI N: 02P8660 90,73/6 on tient -MD Days: 90
Dr. Keshmirien, J DWI 01:67128 186 Maki Street South NEW RX Brampton ON No Scri Phone: (905) 466-7774 TAKE 1 TABLET AS DIRECTED WHEN REQUIRED ONCE DAILY Orig Ex:864905 Atith:200 Rern:110 (1) Cost:1.386.95 Mkup:406.29 Fen:11.99 Total:1,78123 Pat:5.00 Disc:143.19 T.P.:1633.04 - ESI(824,01); 0$(091(809.03) OROIDRQ - 3-Ciprelex 10mg $SRI$; ISNRI$15H7-1D AGONISTS DRWORG - 3-04prolex 20mg SOME: 8NRISIEHT•10 AGONISTS • Additional DUE 109tree • Cheek Draft
Counsel Dale: Phermadat OYes q Petkot 0 Phone r]Agent U No 0 Hee before. reason: Anemia;
-.Cot rlgiglta
270 CAP Lyrica 150mg Pregabatin 150mg Mfr: PMS PIN: 02268450 145,76/60 on Hand: 411474 Days: 90
Dr, Keshmtrian, J Doc I01:87126 186 Main Street South NEW RX Brampton ON No Sod Phone: (905) 456-7774 TAKE 1 CAPSULE THREE TIMES DAIL DIRECTED
• •••••
Rx:870523
_ : .312. . GXSPN74M8 c ...... ....-.........-____________ 100 TAB Creator Orng Rosuvastatin Calcium 20 Mg (Creator) 20mg Mk MIN DI : 02-247_163 55.29/30 on Kane: -mos_____-____ Dim 100 ----- Dr. KeetimIriao, J --- 186 Main Street South DocAi01:67128 Brampton ON
REFILL Is da No Script Image • Phone: (505) 456.7774
TAKE 1 TABLET EACH DAY AS DIREC .... --
-67ifiTixTaiiiii -A-uti-576 ----- Iien76 Pre1a20•Nov-17(865856). Ago:92 Firsi.'20•Nov.17(855956) Pet0.00
Cost:184,30 Aikup:140.00 Fee:11.99 Total:338.29 isc:10.35 T.P.:325.94 - ESI(160.75t CS(08X180.19) Old erke:aao.o4 - ,_oupfrup. Amhyp.mothwmov ItheaCo•A Raskrelate Inhibitors Maims) . '-'......
Rx:874103 or-2018 15:39
20-Feb-201817:d5 SS
01PF • • Vit. 01..2111
240 TAB Serormet 200mg - QueliapIne Fumarate 200mg Mir, AZC t DIN' 02236953 203.61/100 on Henn:-310740 Days: 60 Dr:Kashmtrian, J DWI 01:67128 186 Mein Street South No Script Image Brampton ON REFILL (4 Phone: (905) 456-7774 RE 177,---KETTABLET871:-WITE DAILY AS DIRE T oaf, PA:eager ---- Audi:7230- -ftern:480 ( Prey:Oa-Jan-10(8821/2) Ago:56 Firat:15•Ncer•17(854687)
2) Coot:704.58 Mkup:520.00 Pee:11.99 Total:1,236.6E Pat:0,00 Dhic:20.42 Old Price:1,221.23 T.P.:1216.23 • 681(640.86); C3(08)(576.37) motile • 2-Adopt 54,a OT PROLostairic hOENTSialsEriartrear Nom., PIM= • 2.0101144 044 QT PROLOMMOO asousatUenolliE: not-- Additional DUE lemon . cheek profile
.4"..pnclitions
Orlg Rx:864909 Auth:600 Rem:330 (1) Coat:655.92 tillwp;198.78 Fee:11.99 Total:1181489 Pat:6.00
TL3CD-PU:P."niTH56:itf:io. Conditions 7:1:1166°V:112"wantil °API* -
Counsel Date: Pharmacist
q No Had MOM WNW Allergies
1111ESI: 01111MMIIIIMMI
32-312-INNOVNGIIH293h48 100 TAB ArimIdex 1mg Anastrozole mg Mfr: MIN DIN: 02224135. 164,15/30 on Hand: -45280 Days: 100 I Dr. KeshMirlan, J Docit 01:67128 186 Main Street South NEW RX Brampton ON No Script IOoage Phone: (905) 456-7774 TAKE 1 TABLET EACH DAY ;4911=874183 Aullu400 ^ Eem:300 (3) Cost:547.17 NIkup:400.00 Pea:11.99 Total:459.16 Pat0.00 T.P.:468.66 • ESI(466,56); CSIDER0.00) Disc:482.00
Dlem299,85
Counsel Dale: Pharmacist ...__ °Yes n Patient q Phone q Agent -
No .0 Had before. reason. Alletpies Conditions
4;4
MD Health Pharmacy Accreditation # 300990
Audit & Exhibits 186 Main St South Brampton, ON L6W 2E2
Exhibit 4: Physician Verification re Dr. Keshmirian
ClaimSecure Inc, Confidential 5
4;4
MD Health Pharmacy Accreditation # 300990
Audit & Exhibits 186 Main St South Brampton, ON L6W 2E2
Exhibit 4: Physician Verification re Dr. Keshmirian
ClaimSecure Inc, Confidential 5
4;4
MD Health Pharmacy Accreditation # 300990
Audit & Exhibits 186 Main St South Brampton, ON L6W 2E2
Exhibit 4: Physician Verification re Dr. Keshmirian
ClaimSecure Inc, Confidential 5
clabensecure 1 City Centre Drive
Suite 620 Mississauga ON 15131M2 1-888-479-7587 ext. 3038
Fax: 905-949-3029
To: Dr. Jalal Keshmirian Phone: 905-456-7774 Fax: 905-456-1158
From: Anna Malik, Auditor Date: May 28, 2018
Re: Physician Prescription Verification yes: tklidth.ts WEIL_ CC:
E) Urgent El For Review 0 Please Comment 0 Please Reply 0 Please Recycle
Dear Dr. Keshmirian,
ClaimSecure Inc. manages health benefit claims on behalf of drug plan sponsors, which include employers, insurers and third party administrators (TPAs).
The attached list of claims dispensed by MD Health Pharmacy, paid for by ClaimSecure, has been selected for an audit review. As per our records and prescription review, you are the prescribing physician of those claims.
Could you kindly verify/confirm if you have indeed prescribed the medications listed for the patients by indicating a YES or NO in the space provided on the attached sheets.
Please fax the completed form to my attention once completed.
Should you have any questions or concerns please do not hesitate to contact me.
Thank you, Anna Malik Auditor
c5c/ainisecure
Toll Free 1-888-479-7587 Ext. 3038 Fax: 905-949-3029
The information contained in this transmission is privileged and confidential, and intended only for the use of the individual or entity to whom it is addressed. If yon are not the intended recipient, you are hereby notified that any distribution, copying, disclosure, or taking of any action in reliance on the contents of this transmission is strictly prohibited and review by an individual other than the intended recipient shall not constitute waiver of privilege.
If you have received this transmission in error, please notify the sender immediately and return the original transmission to the sender marked private and confidential.
If all pages are not clearly received, please contact the sender immediately.
clabensecure 1 City Centre Drive
Suite 620 Mississauga ON 15131M2 1-888-479-7587 ext. 3038
Fax: 905-949-3029
To: Dr. Jalal Keshmirian Phone: 905-456-7774 Fax: 905-456-1158
From: Anna Malik, Auditor Date: May 28, 2018
Re: Physician Prescription Verification yes: tklidth.ts WEIL_ CC:
E) Urgent El For Review 0 Please Comment 0 Please Reply 0 Please Recycle
Dear Dr. Keshmirian,
ClaimSecure Inc. manages health benefit claims on behalf of drug plan sponsors, which include employers, insurers and third party administrators (TPAs).
The attached list of claims dispensed by MD Health Pharmacy, paid for by ClaimSecure, has been selected for an audit review. As per our records and prescription review, you are the prescribing physician of those claims.
Could you kindly verify/confirm if you have indeed prescribed the medications listed for the patients by indicating a YES or NO in the space provided on the attached sheets.
Please fax the completed form to my attention once completed.
Should you have any questions or concerns please do not hesitate to contact me.
Thank you, Anna Malik Auditor
c5c/ainisecure
Toll Free 1-888-479-7587 Ext. 3038 Fax: 905-949-3029
The information contained in this transmission is privileged and confidential, and intended only for the use of the individual or entity to whom it is addressed. If yon are not the intended recipient, you are hereby notified that any distribution, copying, disclosure, or taking of any action in reliance on the contents of this transmission is strictly prohibited and review by an individual other than the intended recipient shall not constitute waiver of privilege.
If you have received this transmission in error, please notify the sender immediately and return the original transmission to the sender marked private and confidential.
If all pages are not clearly received, please contact the sender immediately.
clabensecure 1 City Centre Drive
Suite 620 Mississauga ON 15131M2 1-888-479-7587 ext. 3038
Fax: 905-949-3029
To: Dr. Jalal Keshmirian Phone: 905-456-7774 Fax: 905-456-1158
From: Anna Malik, Auditor Date: May 28, 2018
Re: Physician Prescription Verification yes: tklidth.ts WEIL_ CC:
E) Urgent El For Review 0 Please Comment 0 Please Reply 0 Please Recycle
Dear Dr. Keshmirian,
ClaimSecure Inc. manages health benefit claims on behalf of drug plan sponsors, which include employers, insurers and third party administrators (TPAs).
The attached list of claims dispensed by MD Health Pharmacy, paid for by ClaimSecure, has been selected for an audit review. As per our records and prescription review, you are the prescribing physician of those claims.
Could you kindly verify/confirm if you have indeed prescribed the medications listed for the patients by indicating a YES or NO in the space provided on the attached sheets.
Please fax the completed form to my attention once completed.
Should you have any questions or concerns please do not hesitate to contact me.
Thank you, Anna Malik Auditor
c5c/ainisecure
Toll Free 1-888-479-7587 Ext. 3038 Fax: 905-949-3029
The information contained in this transmission is privileged and confidential, and intended only for the use of the individual or entity to whom it is addressed. If yon are not the intended recipient, you are hereby notified that any distribution, copying, disclosure, or taking of any action in reliance on the contents of this transmission is strictly prohibited and review by an individual other than the intended recipient shall not constitute waiver of privilege.
If you have received this transmission in error, please notify the sender immediately and return the original transmission to the sender marked private and confidential.
If all pages are not clearly received, please contact the sender immediately.
Physician Verification - Dr. Keshmirian
.. fit 0 e ;141 0- qiiz:1;- :',7;1 ; TZ:i1P,:;:., •&•-:'! Witt .1)-SYkstPCP Ylr, 1140 . Pa ---' thl' '' ,,f ifeSqlbefID 1 SEROQUEL 200MG 240 60 , 12-Feb-18 868685 ' 67128 2 3
LOSEC 20mg TAB 200 - 100 • 18-Dec-17 860538 67128 SEROQUEL 200MG 240 , 60 ' 18-Dec-17 860556 67128
4 ZOMIG 2.5MG TAB * 90 ' 90 18-Dec-17 860542 ,- 67128 5 CRESTOR 20 MG 100 , 100 18-Dec-17 860572 67128 6 7
ZOMIG RAPIMELT 2.5 MG 100 ' 90 18-Dec-17 ! 860543 67128 Seroquel 300mg Tab i 200 100 18-Dec-17 860557 . 67128
8 SEROQUEL XR 400MG 100 100 18-Dec-17 860558 67128 CRESTOR 40MG TAB —1 100 i 100 18-Dec-17 i 860573 : 67128 . _ _ . ___
10 11
CRESTOR 20 MG 100 100
100 x_20-Nov-17 I 855855 67128 ......._ CRESTOR 40MG TAB 100 ' 20-Nov-17 855856 67128
12 -1.3 14 ......._. 15 16 17
—18 19
SEROQUEL 200MG i 240 , 60 15-Nov-17 854919 1 67128 SEROQUEL 200MG 240 i 60 -1- 15-Nov-17
i 15-Nov-17 , 854887 ' 854939
67128 67128 LOSEC 20mg TAB 200 100
LOSEC 20mg TAB . , 200 100 : 15-Nov-17 854901 67128 ZOMIG 2.5MG TAB * . 90 90 15-Nov-17 85.4874. 67128 ZOMIG 2.5MG TAB * , 90 90 1 15-Nov-17
15-Nov-17 _.
854905 67128 67128 67128 67128
Seroquel i00mg Tab i 200 100 200
100 90
100
: 854888
i
ZOMIG RAPIMELT 2.5 MG1 15-Nov-17 854906 20 Seroquel 300mg Tab i 15-Nov-17 854920 21 22 23
ZOMIG RAPIMELT 2.5 MG 1 100 90 j 15-Nov-17 . 854875 67128 CRESTOR 20 MG 1 100
100 100 15-Nov-17 1 854895
i 854937 67128 ____ 67121
__ _ CRESTOR 20 MG i 100 15-Nov-17
24 _25 :21.6 27 28 I
SEROQUEL XR 400MG I 100 I 100 1 15-Nov-17 15-Nov-17
854922 1 854890
854936
67128 ; SEROQUEL XR 400MG 100 100 67128
67128 CRESTOR 40MG TAB 1 100 100 ' 15-Nov-17 CRESTOR 40MG 40MG TAB 100 100 . 15-Nov-17 - 854894 67128 ARIMIDEX 1mg TAB i 100 100 ' 15-Nov-17 , 854902 67128
29 CRESTOR 20 MG I 100 , 100 8-Nov-17 : 853378 67128 30 I CRESTOR 20 MG ! 100 . 100 8-Nov-17 i 853346 67128 31 SEROQUEL XR 400MG 100 100 i 8-Nov-17 853329 67128 32 I LOSEC 20mg TAB . _ !.._ 33 SEROQUEL 206IVI--G-.
200 100 _.. 60
_....p-Oct-17,... ! 17-Oct-17
. 849608 : 849657
67128 240 : 1 67128
ClaimSecure Inc. Confidential 5/28/2018 Page 1
Physician Verification - Dr. Keshmirian
.. fit 0 e ;141 0- qiiz:1;- :',7;1 ; TZ:i1P,:;:., •&•-:'! Witt .1)-SYkstPCP Ylr, 1140 . Pa ---' thl' '' ,,f ifeSqlbefID 1 SEROQUEL 200MG 240 60 , 12-Feb-18 868685 ' 67128 2 3
LOSEC 20mg TAB 200 - 100 • 18-Dec-17 860538 67128 SEROQUEL 200MG 240 , 60 ' 18-Dec-17 860556 67128
4 ZOMIG 2.5MG TAB * 90 ' 90 18-Dec-17 860542 ,- 67128 5 CRESTOR 20 MG 100 , 100 18-Dec-17 860572 67128 6 7
ZOMIG RAPIMELT 2.5 MG 100 ' 90 18-Dec-17 ! 860543 67128 Seroquel 300mg Tab i 200 100 18-Dec-17 860557 . 67128
8 SEROQUEL XR 400MG 100 100 18-Dec-17 860558 67128 CRESTOR 40MG TAB —1 100 i 100 18-Dec-17 i 860573 : 67128 . _ _ . ___
10 11
CRESTOR 20 MG 100 100
100 x_20-Nov-17 I 855855 67128 ......._ CRESTOR 40MG TAB 100 ' 20-Nov-17 855856 67128
12 -1.3 14 ......._. 15 16 17
—18 19
SEROQUEL 200MG i 240 , 60 15-Nov-17 854919 1 67128 SEROQUEL 200MG 240 i 60 -1- 15-Nov-17
i 15-Nov-17 , 854887 ' 854939
67128 67128 LOSEC 20mg TAB 200 100
LOSEC 20mg TAB . , 200 100 : 15-Nov-17 854901 67128 ZOMIG 2.5MG TAB * . 90 90 15-Nov-17 85.4874. 67128 ZOMIG 2.5MG TAB * , 90 90 1 15-Nov-17
15-Nov-17 _.
854905 67128 67128 67128 67128
Seroquel i00mg Tab i 200 100 200
100 90
100
: 854888
i
ZOMIG RAPIMELT 2.5 MG1 15-Nov-17 854906 20 Seroquel 300mg Tab i 15-Nov-17 854920 21 22 23
ZOMIG RAPIMELT 2.5 MG 1 100 90 j 15-Nov-17 . 854875 67128 CRESTOR 20 MG 1 100
100 100 15-Nov-17 1 854895
i 854937 67128 ____ 67121
__ _ CRESTOR 20 MG i 100 15-Nov-17
24 _25 :21.6 27 28 I
SEROQUEL XR 400MG I 100 I 100 1 15-Nov-17 15-Nov-17
854922 1 854890
854936
67128 ; SEROQUEL XR 400MG 100 100 67128
67128 CRESTOR 40MG TAB 1 100 100 ' 15-Nov-17 CRESTOR 40MG 40MG TAB 100 100 . 15-Nov-17 - 854894 67128 ARIMIDEX 1mg TAB i 100 100 ' 15-Nov-17 , 854902 67128
29 CRESTOR 20 MG I 100 , 100 8-Nov-17 : 853378 67128 30 I CRESTOR 20 MG ! 100 . 100 8-Nov-17 i 853346 67128 31 SEROQUEL XR 400MG 100 100 i 8-Nov-17 853329 67128 32 I LOSEC 20mg TAB . _ !.._ 33 SEROQUEL 206IVI--G-.
200 100 _.. 60
_....p-Oct-17,... ! 17-Oct-17
. 849608 : 849657
67128 240 : 1 67128
ClaimSecure Inc. Confidential 5/28/2018 Page 1
Physician Verification - Dr. Keshmirian
.. fit 0 e ;141 0- qiiz:1;- :',7;1 ; TZ:i1P,:;:., •&•-:'! Witt .1)-SYkstPCP Ylr, 1140 . Pa ---' thl' '' ,,f ifeSqlbefID 1 SEROQUEL 200MG 240 60 • 12-Feb-18 868685 67128 2 3
LOSEC 20mg TAB 200 - 100 • 18-Dec-17 860538 67128 SEROQUEL 200MG 240 , 60 ' 18-Dec-17 860556 67128
4 ZOMIG 2.5MG TAB * 90 ' 90 18-Dec-17 860542 ,- 67128 5 CRESTOR 20 MG 100 , 100 18-Dec-17 860572 67128 6 7
ZOMIG RAPIMELT 2.5 MG 100 ' 90 18-Dec-17 ! 860543 67128 Seroquel 300mg Tab i 200 100 18-Dec-17 860557 . 67128
8 SEROQUEL XR 400MG 100 100 18-Dec-17 860558 67128 CRESTOR 40MG TAB —1 100 i 100 18-Dec-17 i 860573 : 67128 _ ___
10 11
CRESTOR 20 MG 100 100
100 x_20-Nov-17 I 855855 67128 ......._ CRESTOR 40MG TAB 100 ' 20-Nov-17 855856 67128
12 -1.3 14 ......._. 15 16 17
—18 19
SEROQUEL 200MG i 240 , 60 15-Nov-17 854919 1 67128 SEROQUEL 200MG 240 i 60 -1- 15-Nov-17
i 15-Nov-17 , 854887 ' 854939
67128 67128 LOSEC 20mg TAB 200 100
LOSEC 20mg TAB ; , 200 100 : 15-Nov-17 854901 67128 ZOMIG 2.5MG TAB * . 90 90 15-Nov-17 85.4874. 67128 ZOMIG 2.5MG TAB * ; 90 90 1 15-Nov-17
15-Nov-17 _.
854905 67128 67128 67128 67128
Seroquel i00mg Tab i 200 100 200
100 90
100
: 854888
i
ZOMIG RAPIMELT 2.5 MG1 15-Nov-17 854906 20 Seroquel 300mg Tab i 15-Nov-17 854920 21 22 23
ZOMIG RAPIMELT 2.5 MG 1 100 90 j 15-Nov-17 . 854875 67128 CRESTOR 20 MG 1 1 100
100 100 15-Nov-17 _ ....._. 1 854895
i 854937 . 67128 ___
67128 • — .__..
CRESTOR 20 MG i 100 15-Nov-17 24
_25 :21.6 27 28 I
SEROQUEL XR 400MG I 100 I 100 1 15-Nov-17 15-Nov-17
854922 1 854890
854936
67128 ; SEROQUEL XR 400MG 100 100 67128
67128 CRESTOR 40MG TAB 1 100 100 ' 15-Nov-17 CRESTOR 40MG 40MG TAB 100 100 . 15-Nov-17 - 854894 67128 ARIMIDEX 1mg TAB i 100 100 ' 15-Nov-17 , 854902 67128
29 CRESTOR 20 MG I 100 , 100 8-Nov-17 : 853378 67128 30 I CRESTOR 20 MG ! 100 . 100 8-Nov-17 i 853346 67128 31 SEROQUEL XR 400MG 100 100 i 8-Nov-17 853329 67128 32 I LOSEC 20mg TAB . _ i.._ 33 SEROQUEL 2061V1--G-.
200 100 _.. 60
_. p-Oct-17,... ! 17-Oct-17
. 849608 : 849657
67128 240 : 1 67128
ClaimSecure Inc. Confidential 5/28/2018 Page 1
Da: Oiler lit.
37 38 39 40 ;
Physician Verification - Dr. Keshmirian
34. 35 . 36 ;
41 42.1 IZOMIG RAPIMELT2.5 MG(_ 100 I
43' 1CRESTOR 20 MG I 100 1
44 ! !SEROQUEL XR 400MG 1 100 !
--45: SEROQUEl. XR 400MG 100 .
46 , 1CRESTOR 40MG TAB 100 '
47 1 ICRESTOR 40MG TAB 100 , ------1 48 I IARIMIDEX 1mg TAB 100 i
49 !ZOMIG 2.5MG TAB * 90 :
501 IZOMIG 2.5MG TAB * 90 i
51 J !ZOMIG RAPIMELT2.5 MG I 100 '
52 I IZOMIG RAPIMELT2.5 MG; 100
53 I ;ZOMIG 2.5MG TAB * ; 90 :
54 'ZOMIG RAPIMELT 2.5 MG i 100
55 J ;ZOMIG RAPIMELT 2.5 MGI 100 '
56 E IZOMIG 2.5MG TAB * ; 90
57 ':ZOMIG 2.5MG TAB * I 90
58 1 IZOMIG RAPIMELT 2,5 MG1 100 r-
59 i IZOMIG RAPIMELT 2.5 MG! 100
60 I IZOMIG RAPIELT 2.5 MG! 100 i
61 IZOMIG 2.5MG TAB * 90
62 'ZOMIG 2,5MG TAB * 90
i 63 SEROQUEL 200MG 240
64 ! (ZQMIG 2.5MG TAB * 90
65 i LOSEC 20mg TAB 200 _..! 66 ' ZOMIG RAPIMELT2.5 M61 100
ClaimSecure Inc. Confidential 5/28/2018
iZOMIG 2.5MG TAB * 90 !SEROQUEL 200MG 240 I LOSEC 20mgTAB , 200 ! ZOMIG 2.5MG TAB * 90 . iSeroquel 300mg Tab 200 : IZOMIG RAPIMELT2.5 MG; 100 * iSeroquel 300mg Tab i 200 ICRESTOR 20 MG I 100
0#0:ettP
i —
Page 2
90 17-Oct-17 ! 849642 67128 60
100 ~ 17-Oct-17 17-Oct-17
: 849621 i 849647
67128 67128
90 17-Oct-17 849605 67128 100 ! , 17-Oct-17 849655 67128 100 17-Oct-17 ' 849643
I 849620 67128
100 17-Oct-17 67128 100 17-0447 I 849632 67128 100 17-Oct-17 ! 849606 67128 100 17-Oct-17 ! 849667 67128 100 17.Oct-17 s 849622 67128 100 17-Oct-17 849658 67128 100 i 17-Oct-17 : 849668 67128 100 100 "
17-Oct-17 i 849631 ' 67128 17-Oct-17 ; 849602 , 67128
90 : 13-Oct-17 I 849080 : 67128 90 ' 13-Oct-17 849117
100 13-Oct-17 ! 849079 67128 100 13-Oct-17 ; 849118 67128 90 11-Oct-17 ' 848704 67128
100 11-Oct-17 848649 67128 100 11-Oct-17
-,- 848705 67128 67128 90 11-Oct-17 848650 1
90 11-Oct-17 848818 i 67128 100 11-Oct-17 : 848817 j 67128 100 11-Oct-17 848742 67128 100 11.Oct-17 = 848780 67128 90 11-Oct-17 ' 848743 67128 90 11-Oct-17 848781 67128 60 6-Oct-17 I 848190 67128
67128 90 ' 6-Oct-17 ; 848200 100 6-Oct-17 I 848194 I— 67128 100 6-Oct-17 848199 , 67128
Da: Oiler lit.
37 38 39 40 ;
Physician Verification - Dr. Keshmirian
34. 35 . 36 ;
41 42.1 IZOMIG RAPIMELT2.5 MG(_ 100 I
43' 1CRESTOR 20 MG I 100 1
44 ! !SEROQUEL XR 400MG 1 100 !
--45: SEROQUEl. XR 400MG 100 .
46 , 1CRESTOR 40MG TAB 100 '
47 1 ICRESTOR 40MG TAB 100 , ------1 48 I IARIMIDEX 1mg TAB 100 i
49 !ZOMIG 2.5MG TAB * 90 :
501 IZOMIG 2.5MG TAB * 90 i
51 J !ZOMIG RAPIMELT2.5 MG I 100 '
52 I IZOMIG RAPIMELT2.5 MG; 100
53 I ;ZOMIG 2.5MG TAB * ; 90 :
54 'ZOMIG RAPIMELT 2.5 MG i 100
55 J ;ZOMIG RAPIMELT 2.5 MGI 100 '
56 E IZOMIG 2.5MG TAB * ; 90
57 ':ZOMIG 2.5MG TAB * I 90
58 1 IZOMIG RAPIMELT 2,5 MG1 100 r-
59 i IZOMIG RAPIMELT 2.5 MG! 100
60 I IZOMIG RAPIELT 2.5 MG! 100 i
61 IZOMIG 2.5MG TAB * 90
62 'ZOMIG 2,5MG TAB * 90
i 63 SEROQUEL 200MG 240
64 ! (ZQMIG 2.5MG TAB * 90
65 i LOSEC 20mg TAB 200 _..! 66 ' ZOMIG RAPIMELT2.5 M61 100
ClaimSecure Inc. Confidential 5/28/2018
iZOMIG 2.5MG TAB * 90 !SEROQUEL 200MG 240 I LOSEC 20mgTAB , 200 ! ZOMIG 2.5MG TAB * 90 . iSeroquel 300mg Tab 200 : IZOMIG RAPIMELT2.5 MG; 100 * iSeroquel 300mg Tab i 200 ICRESTOR 20 MG I 100
0#0:ettP
i —
Page 2
90 17-Oct-17 ! 849642 67128 60
100 ~ 17-Oct-17 17-Oct-17
: 849621 i 849647
67128 67128
90 17-Oct-17 849605 67128 100 ! , 17-Oct-17 849655 67128 100 17-Oct-17 ' 849643
I 849620 67128
100 17-Oct-17 67128 100 17-0447 I 849632 67128 100 17-Oct-17 ! 849606 67128 100 17-Oct-17 ! 849667 67128 100 17.Oct-17 s 849622 67128 100 17-Oct-17 849658 67128 100 i 17-Oct-17 : 849668 67128 100 100 "
17-Oct-17 i 849631 ' 67128 17-Oct-17 ; 849602 , 67128
90 : 13-Oct-17 I 849080 : 67128 90 ' 13-Oct-17 849117
100 13-Oct-17 ! 849079 67128 100 13-Oct-17 ; 849118 67128 90 11-Oct-17 ' 848704 67128
100 11-Oct-17 848649 67128 100 11-Oct-17
-,- 848705 67128 67128 90 11-Oct-17 848650 1
90 11-Oct-17 848818 i 67128 100 11-Oct-17 : 848817 j 67128 100 11-Oct-17 848742 67128 100 11.Oct-17 = 848780 67128 90 11-Oct-17 ' 848743 67128 90 11-Oct-17 848781 67128 60 6-Oct-17 I 848190 67128
67128 90 ' 6-Oct-17 ; 848200 100 6-Oct-17 I 848194 I— 67128 100 6-Oct-17 848199 , 67128
Day gs..9101 arms lit a
34. !ZOMIG 2.5MG TAB * 90 90 17-Oct-17 I 849642 67128
35 , !SEROQUEL 200MG 240 60 17-Oct-17 : 849621 1 67128
36 LOSEC 20mg TAB 200 ! 100 ~ 17-Oct-17 849647 I 67128
37 ZOMIG 2.5MG TAB * 90 90 17-Oct-17 849605 67128
38 iSeroque1300mg Tab 200 100 , 17-Oct-17 849655 67128 39 IZOMIG RAPIMELT 2.5 MG 100 100 17-Oct-17 ' 849643 67128
40 ; iSeroquel 300mg Tab i 200 100 17-Oct-17 i 849620 67128
41 ICRESTOR 20 MG I 1 100 100 17-Oct-17 849632 67128
IZOMIG RAPIMELT 2.5 MG(- 100 1 100 17-Oct-17 1 849606 67128 421 43 1 1CRESTOR 20 MG ,
1 100 ; i
100 17-Oct-17 849667 67128
44 SEROQUEL XR 400MG 1 100 ! 100 17.Oct-17 849622 67128
45 SEROQUEl. XR 400MG 100 . 100 17-Oct-17 849658 67128
46 ICRESTOR 40MG TAB 100 100 17-Oct-17 849668 67128
47 I CRESTOR 40MG TAB 100 100 17-Oct-17 849631 67128
48 ARIMIDEX 1mg TAB 100 100 " 17-Oct-17 ; 849602 67128 49 IZOMIG 2.5MG TAB * 90 • 90 13-Oct-17 I 849080 : 67128
50_1 IZOMIG 2.5MG TAB * 90 90 13-Oct-17 ; 849117
51 J IZOMIG RAPIMELT 2.5 MG 100 100 13-Oct-17 849079 67128
52 1 !ZOMIG RAPIMELT 2.5 MG! 100 100 13-Oct-17 , 849118 67128 •
53 I ;ZOMIG 2.5MG TAB * ; 90 : 90 11-Oct-17 ' 848704 67128
54 'ZOMIG RAPIMELT 2.5 MG i 100 100 11-Oct-17 848649 67128
_55.1 ;ZOMIG RAPIMELT 2.5 MGI 100 100 11-Oct-17 848705 67128 IZOMIG 2.5MG TAB * ; 90 90 11-Oct-17 56 848650 1 67128
57 'ZOMIG 2.5MG TAB * I 90 90 11-Oct-17 848818 i 67128
58 1 1ZOMIG RAPIMELT MG; 100 r-
100 11-Oct-17 , 848817 i 67128
59 ! jZOMIG RAPIMELT 2.5 MG: 100 j 100 11-Oct-17 848742 67128
60 IZOMIG RAPIMELT 2.5 MG 100 i 100 11.Oct-17 = 848780 67128
61 2.5MG TAB * 1 90 90 11-Oct-17 ' 848743 67128
62 'ZOMIG 2,5MG TAB * 90 90 11-Oct-17 848781 i 67128
63 SEROQUEL 200MG 240 60 6-Oct-17 848190 67128
64 " (My)* 2.5MG TAB * 90 90 ' 6-Oct-17 ; 848200 i 67128
65 ; LOSEC 20mg TAB 200 100 6-Oct-17 848194 I- 67128
66 ZOMIG RAPIMELT 2.5 M61 100 100 6-Oct-17 848199 , 67128
Physician Verification - Dr. Keshmirian
ClaimSecure Inc. Confidential 5/28/2018 Page 2
Physician Verification - Dr. Keshmirian
=#;•Fir#-NarnA 11•1*Ititil - 7; — — r--- ,,_E:,;,..4:4cokiitity DAWSOPISIODilsiteiWD1 e 9_,,,:ii. Ctik500ii,
67128 1 67 1Seroque1300mgTab i 200 I 100 6-Oct-17 , 848189 68 69
i CRESTOR 20 MG ; 100 100 6-Oct-17 ' 848212 67128 CRESTOR 40MG TAB 1 100 100 6-Oct-17 I 848211 1 67128 1
70 iSEROQUEL XR 400MG 100 100 6-Oct-17 848191 67128 71 iARIMIDEX 1mg TAB ! 100 100 6-Oct-17 848196 1 67128 72 73
'ZOMIG 2.5MG TAB * 90 ! V 90 !
90 26-Sep-17 , 846734 , 67128 i ZOMIG 2.5MG TAB * 90 26-Sep-17 846700
-
67128 1 74 75 76
:ZOMIG RAPIMELT 2.5 MG 100 ! 100 100
26-Sep-17 T 26-Sep-17
846733 846699
67128 67128
- i ZOMIG RAPIMELT 2.5 MG ZOMIG 2.5MG TAB *
100 ; ; 90
100 i 90
' 13-Sep-17 ' 845350 . 67128
77 78 79
1.ZOMIG RAP1MELT 2.5 MG1 100 13-Sep-17 845349 67128 (ZOMIG RAPIMELT 2.5 MG! 100 ' 100 i 13-Sep-17 • 845322 67128 1ZOMIG 2.5MG TAB * ! 90 ; 90 1 13-Sep-17 845323 t 67128
80 1SEROQUEL 200MG • 240 60 12-Sep-17 845006 i 67128 81 82 83
' ZOMIG 2.5MG TAB * 90 90 ! 12-Sep-17 845025 : 67128 ISEROQUEL 200MG 240 60 12-Sep-17 845036 67128 I20MIG 2.5MG TAB * 90 90 12-Sep-17 844999 67128
84 85 86
LOSEC 20mg TAB j 200 ;i 100 ; 12-Sep-17 845032 1 67128 _ 1CRESTOR 40MG TAB 100 i 100 ! 12-Sep-17
-1844990 67128
ICRESTOR 40MG TAB 100 t 100 12-Sep-17 845017 I 67128 87 1ZOMIG RAPIMELT 2.5 MG 100 ! 100 12-Sep-17 844998 ; 67128 88 CRESTOR 20 MG 100 ; 100 12-Sep-17 845018 i 67128
67128 89 90
,Seroquel 300mg Tab 200 100 i 12-Sep-17 845005
Seroquel 300mg Tab 200 100 12-Sep-17 i 845035 67128 91 92 93
I CRESTOR 20 MG ; 100 100 1 12-Sep-17 1 844991 ! 67128 IZOMIG RAPIMELT 2.5 MGI 100 I 100 !
• 12-Sep-17 ! 845024 67128
!SEROQUEL XR 400MG , 100 100 12-Sep-17 845007 67128 94 !SEROQUELXR 400MG ' 100 100 12-Sep-17 i 845037 ' 67128 95 96 97 98 ;
•
ARIMIDEX lmg TAB ! 100 ' 100 12-Sep-17 844997 . 67128 LOSEC 20mg TAB ' 200
90 : 100
90 . 12-Sep-17 845002
: 844476 67128 67128
.. . . _ ' ZOMIG 2.5MG TAB * 8-Sep-17 .ZOMIG 2.5MG TAB * • 90 . 90 8-Sep-17 ! 844414 ; 67128
99 ZOMIG RAPIMELT 2.5 MG1 100 100 8-Sep-17 844475 ; 67128
ClaimSecure Inc. Confidential 5128/2018 Page 3
Physician Verification - Dr. Keshmirian
=#;•Fir#-NarnA 11•1*Ititil - 7; — — r--- ,,_E:,;,..4:4cokiitity DAWSOPISIODilsiteiWD1 e 9_,,,:ii. Ctik500ii,
67128 1 67 1Seroque1300mgTab i 200 I 100 6-Oct-17 , 848189 68 69
i CRESTOR 20 MG ; 100 100 6-Oct-17 ' 848212 67128 CRESTOR 40MG TAB 1 100 100 6-Oct-17 I 848211 1 67128 1
70 iSEROQUEL XR 400MG 100 100 6-Oct-17 848191 67128 71 iARIMIDEX 1mg TAB ! 100 100 6-Oct-17 848196 1 67128 72 73
'ZOMIG 2.5MG TAB * 90 ! V 90 !
90 26-Sep-17 , 846734 , 67128 i ZOMIG 2.5MG TAB * 90 26-Sep-17 846700
-
67128 1 74 75 76
:ZOMIG RAPIMELT 2.5 MG 100 ! 100 100
26-Sep-17 T 26-Sep-17
846733 846699
67128 67128
- i ZOMIG RAPIMELT 2.5 MG ZOMIG 2.5MG TAB *
100 ; ; 90
100 i 90
' 13-Sep-17 ' 845350 . 67128
77 78 79
1.ZOMIG RAP1MELT 2.5 MG1 100 13-Sep-17 845349 67128 (ZOMIG RAPIMELT 2.5 MG! 100 ' 100 i 13-Sep-17 • 845322 67128 1ZOMIG 2.5MG TAB * ! 90 ; 90 1 13-Sep-17 845323 t 67128
80 1SEROQUEL 200MG • 240 60 12-Sep-17 845006 i 67128 81 82 83
' ZOMIG 2.5MG TAB * 90 90 ! 12-Sep-17 845025 : 67128 ISEROQUEL 200MG 240 60 12-Sep-17 845036 67128 I20MIG 2.5MG TAB * 90 90 12-Sep-17 844999 67128
84 85 86
LOSEC 20mg TAB j 200 ;i 100 ; 12-Sep-17 845032 1 67128 _ 1CRESTOR 40MG TAB 100 i 100 ! 12-Sep-17
-1844990 67128
ICRESTOR 40MG TAB 100 t 100 12-Sep-17 845017 I 67128 87 1ZOMIG RAPIMELT 2.5 MG 100 ! 100 12-Sep-17 844998 ; 67128 88 CRESTOR 20 MG 100 ; 100 12-Sep-17 845018 i 67128
67128 89 90
,Seroquel 300mg Tab 200 100 i 12-Sep-17 845005
Seroquel 300mg Tab 200 100 12-Sep-17 i 845035 67128 91 92 93
I CRESTOR 20 MG ; 100 100 1 12-Sep-17 1 844991 ! 67128 IZOMIG RAPIMELT 2.5 MGI 100 I 100 !
• 12-Sep-17 ! 845024 67128
!SEROQUEL XR 400MG , 100 100 12-Sep-17 845007 67128 94 !SEROQUELXR 400MG ' 100 100 12-Sep-17 i 845037 ' 67128 95 96 97 98 ;
•
ARIMIDEX lmg TAB ! 100 ' 100 12-Sep-17 844997 . 67128 LOSEC 20mg TAB ' 200
90 : 100
90 . 12-Sep-17 845002
: 844476 67128 67128
.. . . _ ' ZOMIG 2.5MG TAB * 8-Sep-17 .ZOMIG 2.5MG TAB * • 90 . 90 8-Sep-17 ! 844414 ; 67128
99 ZOMIG RAPIMELT 2.5 MG1 100 100 8-Sep-17 844475 ; 67128
ClaimSecure Inc. Confidential 5128/2018 Page 3
Physician Verification - Dr. Keshmirian
=#; • orst- Name '' --stliatil - ,.... — - -.Drug:_-_._,,..i3A-poiritity DAW.440) 10 filen,FfP,a_ 0 I 100 6-Oct-17
...:04.;
, 848189 04--q0010;
67128 1 67 ISeroque1300mgTab , 200 68 i CRESTOR 20 MG ; 100 100 6-Oct-17 ' 848212 , 67128 69 CRESTOR 40MG TAB 1 100 100 6-Oct-17 I 848211 I 67128 70 iSEROQUEL XR 400MG 100 100 6-Oct-17 848191 i 67128 71 iARIMIDEX 1mg TAB ! 100 100 6-Oct-17 848196 1 67128 72 73
'ZOMIG 2.5MG TAB * 90 90
90 26-Sep-17 , 846734 , 67128 i ZOMIG 2.5MG TAB * 90 26-Sep-17 846700 67128 1
74 75 76
:ZOMIG RAPIMELT 2.5 MG 100 100 100
26-Sep-17 T 26-Sep-17
846733 846699 -
67128 67128
- i ZOMIG RAPIMELT2.5 MG ZOMIG 2.5MG TAB *
100 ; 90
100 i 90
' 13-Sep-17 ' 845350 , 67128
77 78 79
ZOMIG RAPIMELT2.5 MG1 100 13-Sep-17 845349 67128 (ZOMIG RAPIMELT2.5 MG! 100 100 i 13-Sep-17 ; 845322 ' 67128 1ZOMIG 2.5MG TAB * 90 ; 90 13-Sep-17 845323 t 67128
80 1SEROQUEL 200MG , 240 60 12-Sep-17 845006 i 67128 81 82 83
' ZOMIG 2.5MG TAB * 90 90 12-Sep-17 845025 : 67128 ISEROQUEL 200MG 240 , 60 12-Sep-17 845036 67128 120MIG 2.5MG TAB * 90 90 12-Sep-17 844999 67128
84 85 86
LOSEC 20mg TAB j 200 1i 100 12-Sep-17 845032 1 67128 _
1CRESTOR 40MG TAB 100 i 100 12-Sep-17 -1844990 67128
ICRESTOR 40MG TAB 100 t 100 12-Sep-17 845017 I 67128
87 1ZOMIG RAPIMELT 2.5 MG 100 ! 100 12-Sep-17 844998 ' 67128 88 CRESTOR 20 MG 100 : 100 12-Sep-17
12-Sep-17 ; 845018 i 845005 i
67128 67128 • 89
90 ,Seroquel 300mg Tab 200 100 'Seroquel 300mg Tab 200 100 12-Sep-17 i 845035 ! 67128
91 92 93
1CRESTOR 20 MG 100 100 1 12-Sep-17 1 844991 ! 67128 IZOMIG RAPIMELT 2.5 MGI 100 ! 100 !
• 12-Sep-17 ! 845024 1 67128
!SEROQUEL XR 400MG , 100 100 12-Sep-17 ' 845007 67128 94 ISEROQUELXR 400MG ' 100 100 12-Sep-17 i 845037 ' 67128 95 • 96 97 98 i
ARIMIDEX lmg TAB , 100 ' 100 12-Sep-17 844997 . 67128 LOSEC 20mg TAB ' 200
90 : 100
90 . !
12-Sep-17 845002 844476 '
67128 67128
.. . __. ' ZOMIG 2.5MG TAB * 8-Sep-17 : .ZOMIG 2.5MG TAB * • 90 . 90 8-Sep-17 ! 844414 ; 67128
99 i ZOMIG RAPIMELT2.5 MG 100 i 100 8-Sep-17 844475 : 67128
ClaimSecure Inc. Confidential 5128/2018 Page 3
Physician Verification - Dr. Keshmirian
ClalmSecure Inc. Confidential 5/28/2018 Page 4
67128
—
67128 67128 67128 67128
TimNaltie !Last110)Wej, ;iMailRfOginEa CiOW:§400! y g'F*N0170 :ZOMIG RAP(MELT 2.5 MG' 100 100 8-Sep-17 844413 j SEROQUEL 200MG 240 60 6-Sep-17 aitOQUEL 200iV1G ' 240 ! 60 6-Sep-17 844186
103 LOSEC 20mg TAB 200 f 100 1 6-Sep-17 844160 _ 104 I.LOSEC 20mg TAB I 200 100 6-Sep-17 1 844232 105 120MIG 2.5MG TAB * 90 90 6-Sep-17 ' 844217 106 !ZOMIG 2.5MG TAB * I 90 90 i 6-Sep-17 844162 107 !Servo ue I 300mg Tab I 200 " 100 6-Sep-17 : 844185 1
108 ;ZOMIG RAPIMELT 2.5 MGI 100 100 6-Sep-17 844216 I 109: lSeroquel 300mg Tab 1 200 100 6-Sep-17 844224 1 1101 I CRESTOR 20 MG 1 100 1 100 6-Sep-17 844207 111' IZOMIG RAPIMELT 2.5 MG! 100 I 100 ; 6-Sep-17 j 844163 I 112; ICRESTOR 20 MG i 100 I 100 6-Sep-17 844174 1131 1SEROQUEL XR 400MG ' 100 100 i 6-Sep-17 844226 j 114: CRESTOR 40MG TAB 100 1 100 ; 6-Sep-17 844173 115; ICRESTOR 40MG TAB 100 100 ! 6-Sep-17 . 844206 i 1161 ISEROQUEL XR 400MG 100 ' 100 l 6-Sep-17 844187 1171 IARIMIDEX 1mg TAB 100 • 100 1 6-Sep-17 844161 118 I S EROQUEL 200MG 1 240 1 60 6-Sep-17 844307: 119i I SEROQUEL 200MG 240 i 60 6-Sep-17 1 844272 , 1201 LOSEC 20mg TAB ; 200 ; 100 i 6-Sep-17 - 844245 ' 121: LOSEC 20mg TAB i 200 100 I 6-Sep-17 844291 i 1221 ZOMIG 2.5MG TAB* 90 90 6-Sep-17 844302 t 123' ;ZOMIG 2.5MG TAB * 90 " 90 6-Sep-17 844249 12Z Seroquel 300mg Tab : 200 I 100 : 6-Sep-17 844306 125i ;ZOMIG RAPIMELT 2.5 MG; 100 : 100 ! 6-Sep-17
J
844248 iSeroquel 300mg Tab 200 1 100 6-Sep-17 844271--;
1271 IZOMIG RAPIMELT 2.5 MG 100 ' 100 6-Sep-17 844301 128; ICRESTOR 20 MG 100 , 100 6-Sep-17 844269
129i iSEROQUEL XR 400MG ' 100 ; 100 1 6-Sep-17 844273
1301 !CRESTOR 20 MG : 100 100 6-Sep-17 844288
131! CRESTOR 40MG TAB 100 ! 100 f 6-Sep-17 844268
132! CRESTOR 40MG TAB 100 100 i 6-Sep-17 : 844287 ,
67128 • 67128 67128 67128 67128 67128 1
— 67128 ;1 67128 67128
67128 ' 67128 67128
. 67128 67128 67128 . . ...__ 67128 67128 67128 67128 67128 67128 67128 67128 67128 67128
67128 67128_._ 67128
Physician Verification - Dr. Keshmirian
ClalmSecure Inc. Confidential 5/28/2018 Page 4
67128
—
67128 67128 67128 67128
TimNaltie !Last110)Wej, ;iMailRfOginEa CiOW:§400! y g'F*N0170 :ZOMIG RAP(MELT 2.5 MG' 100 100 8-Sep-17 844413 j SEROQUEL 200MG 240 60 6-Sep-17 aitOQUEL 200iV1G ' 240 ! 60 6-Sep-17 844186
103 LOSEC 20mg TAB 200 f 100 1 6-Sep-17 844160 _ 104 I.LOSEC 20mg TAB I 200 100 6-Sep-17 1 844232 105 120MIG 2.5MG TAB * 90 90 6-Sep-17 ' 844217 106 !ZOMIG 2.5MG TAB * I 90 90 i 6-Sep-17 844162 107 !Servo ue I 300mg Tab I 200 " 100 6-Sep-17 : 844185 1
108 ;ZOMIG RAPIMELT 2.5 MGI 100 100 6-Sep-17 844216 I 109: lSeroquel 300mg Tab 1 200 100 6-Sep-17 844224 1 1101 I CRESTOR 20 MG 1 100 1 100 6-Sep-17 844207 111' IZOMIG RAPIMELT 2.5 MG! 100 I 100 ; 6-Sep-17 j 844163 I 112; ICRESTOR 20 MG i 100 I 100 6-Sep-17 844174 1131 1SEROQUEL XR 400MG ' 100 100 i 6-Sep-17 844226 j 114: CRESTOR 40MG TAB 100 1 100 ; 6-Sep-17 844173 115; ICRESTOR 40MG TAB 100 100 ! 6-Sep-17 . 844206 i 1161 ISEROQUEL XR 400MG 100 ' 100 l 6-Sep-17 844187 1171 IARIMIDEX 1mg TAB 100 • 100 1 6-Sep-17 844161 118 I S EROQUEL 200MG 1 240 1 60 6-Sep-17 844307: 119i I SEROQUEL 200MG 240 i 60 6-Sep-17 1 844272 , 1201 LOSEC 20mg TAB ; 200 ; 100 i 6-Sep-17 - 844245 ' 121: LOSEC 20mg TAB i 200 100 I 6-Sep-17 844291 i 1221 ZOMIG 2.5MG TAB* 90 90 6-Sep-17 844302 t 123' ;ZOMIG 2.5MG TAB * 90 " 90 6-Sep-17 844249 12Z Seroquel 300mg Tab : 200 I 100 : 6-Sep-17 844306 125i ;ZOMIG RAPIMELT 2.5 MG; 100 : 100 ! 6-Sep-17
J
844248 iSeroquel 300mg Tab 200 1 100 6-Sep-17 844271--;
1271 IZOMIG RAPIMELT 2.5 MG 100 ' 100 6-Sep-17 844301 128; ICRESTOR 20 MG 100 , 100 6-Sep-17 844269
129i iSEROQUEL XR 400MG ' 100 ; 100 1 6-Sep-17 844273
1301 !CRESTOR 20 MG : 100 100 6-Sep-17 844288
131! CRESTOR 40MG TAB 100 ! 100 f 6-Sep-17 844268
132! CRESTOR 40MG TAB 100 100 i 6-Sep-17 : 844287 ,
67128 • 67128 67128 67128 67128 67128 1
— 67128 ;1 67128 67128
67128 ' 67128 67128
. 67128 67128 67128 . . ...__ 67128 67128 67128 67128 67128 67128 67128 67128 67128 67128
67128 67128_._ 67128
Physician Verification - Dr. Keshmirian
5/28/2018 Page 4 ClalmSecure Inc. Confidential
eT?•;•-: ;Quantity TiNt:Nairie M Dispense=[ !Lastlila)niaj• Ci4rig§aPpfy (!i*cfrili'09D
:ZOMIG RAP(MELT 2.5 MG 100 100 8-Sep-17 844413 j 67128 SEROQUEL 200MG 240 60
60 6-Sep-17 844225 1 67128
200MG 240 ! 6-Sep-17 844186 67128 103 LOSEC 20mg TAB 200 100 i 6-Sep-17 ; 844160 _ 67128 104 1•LOSEC 20mg TAB C 200 100 1 6-Sep-17 844232 67128 105 106
120MIG 2.5MG TAB * 90 90 90
----; : 1
6-Sep-17 6-Sep-17
' 844217 67128 844162 67128 !ZOMIG 2.5MG TAB * — 90
107 lSeroquel 300mg Tab I 200 ' 100 ' 6-Sep-17 844185 1 ; 67128 108 ;ZOMIG RAPIMELT 2.5 MGi 100 100 6-Sep-17 : 844216 I 67128 109 iSeroquel 300mg Tab 1 200 100 6-Sep-17 844224 1 67128 1101 I CRESTOR 20 MG 100 1 100 1 6-Sep-17 844207 67128 111 4ZOMIG RAPIMELT 2.5 MG, 100 I 100 6-Sep-17 j 844163 67128 1121 ICRESTOR 20 MG i 100 I 100 6-Sep-17 844174 67128 113; ISEROQUEL XR 400MG ' 100 100 6-Sep-17 844226 j 67128 114: CRESTOR 40MG TAB 100 1 100 6-Sep-17 844173 67128 115 ICRESTOR 40MG TAB 100 100 ! 6-Sep-17 . 844206 i 67128 116. ISEROQUEL XR 400MG 100 ' 100 l 6-Sep-17 i 844187 67128 117. IARIMIDEX 1mg TAB 100 • 100 1 6-Sep-17 i 844161 67128 118 I S EROQUEL 200MG 1 240 60 ; 6-Sep-17 • 844307: 67128 119k I SEROQUEL 200MG 240 60 6-Sep-17 I 844272 , 67128 120, LOSEC 20mg TAB ; 200 100 i 6-Sep-17 - 844245 ' 67128 121 LOSEC 20mg TAB 200 : 100 I 6-Sep-17 844291 I 67128 122 ZOMIG 2.5MG TAB* 90 90 6-Sep-17 844302 i 67128 123 ;ZOMIG 2.5MG TAB * 90 90 6-Sep-17 844249 l 67128
iSeroquel 300mg Tab : 200 I 100 . 6-Sep-17 844306 1 67128 125j ;ZOMIG RAPIMELT 2.5 MG; 100 : 100 6-Sep-17 844248 ; 67128 1261 iSeroquel 300mg Tab 200 1 100 6-Sep-17 J 844271.--1 ^ 67128 1271 IZOMIG RAPIMELT 2.5 MG 100 100 6-Sep-17 844301 67128 128' ICRESTOR 20 MG 100 , 100 6-Sep-17 844269 ! 67128 1291 iSEROQUEL XR 400MG 100 ; 100 i 6-Sep-17 . 844273 ; 67128 1301 !CRESTOR 20 MG : 100 100 6-Sep-17 - 844288 , 67128 131. CRESTOR 40MG TAB 100 . ; 100 f 6-Sep-17 i 844268 67128
CRESTOR 40MG TAB 100 6-Sep-17 : 844287 , 67128 132! i 100 i
•
•
1
I 100
100
• 240
1SEROQUEL XR 400MG
:ARIMIDEX 1mg TAB SEROQUEL 200MG •
LOSEC 20mg TAB
90
100 200
;ZOMIG 2.5MG TAB * !ZOMIG RAPIMELT 2.5 MG 1 iSeroquel 300mg Tab
100 I ,ARIMIDEX lmg TAB -
90 ZOMIG 2.5MG TAB
ClaimSecure Inc. Confidential 5/28/2018 Page 5
Physician Verification - Dr. Keshmirian
--Actu-knotirOweso restri er:1 i43)1Sferate:
ISEROQUEL XR 400MG 100
iSEROQUEL 200MG : 240
LOSEC 20mg TAB ! 200 1 SEROQUEL 200MG
. 240
LOSEC 20mg TAB
,
200
ZOMIG 2.5MG TAB 90
ISEROQUEL XR 400MG 100 • ISeroquel 300mg Tab 200 ; ZOMIG RAPIMELT 2.5 MG! 100 Seroquel 300mg Tab 200 CRESTOR 20 MG 100_,
CRESTOR 20 MG s 100
;ZOMIG RAPIMELT 2.5 MG; 100
;CRESTOR 40MG TAB 100
ISEROQUEL XR 400MG 100
ICRESTOR 40MG TAB ; 100 !
ARIMIDEX 1mg TAB - 100 IZOMIG 2.5MG TAB * : 90 .
ZOMIG 2.5MG TAB_* 90
ZOMIG RAPIMELT 2.5 MG; 100
ZOMIG RAPIMELT 2.5 MG 100 i
SEROQUEL 200MG -1 240 SEROQUEL 200MG 240 !
LOSEC 20mg TAB 2
100 6-Sep-17 844308 67128 100 6-Sep-17 844247 67128 60 - 1-Sep-17 843785 67128
100 1-Sep-17 843787 67128 90 1-Sep-17 843779 67128
100 1-Sep-17 843778 67128 100 I 1-Sep-17 843784 i 67128 100 1-Sep-17 843777 67128
100 1-Sep-17 843786 67128 60 29-Aug-17 843135 67128
100 29-Aug-17 , 843180 67128 60 29-Aug-17 843186 67128
100 29-Aug-17 , 843122 67128 90 29-Aug-17 843107 67128 90 29-Aug-17 ; 843175 67128
100 r 29 -Aug-17 1 843136 67128 100 29-Aug-17 843132 67128 100 ; 29-Aug-17 . 843174 67128' 100 29-Aug-17 i 843185 67128 100 29-Aug-17 843113 67128 100 ; 29-Aug-17 i 843153 67128 100 29-Aug-17 843106 67128 100 29-Aug-17 ! 843112 1 67128 100 29-Aug-17 843187 ; 67128 100 29-Aug-17 843150 67128 100 29-Aug-17 843105 67128
90 29-Aug-17 843321 67128 90 ; 29-Aug-17 843342 67128
100 29-Aug-17 843320 67128 100 i 29-Aug-17 i 843341 67128 60 1 23-Aug-17 842938 67128 90 23-Aug-17 842962, 67128
100 23-Aug-17 842947 67128 I
162
163 164 165
157
158
159
160
161
153
15
155
156
15
15 15
14
14 14
14
14
13
14
14
13 13
14
14
14
13
13
13
13
200
;t;
I 100
100
• 240
1SEROQUEL XR 400MG
:ARIMIDEX 1mg TAB SEROQUEL 200MG •
LOSEC 20mg TAB
90
100 200
;ZOMIG 2.5MG TAB * !ZOMIG RAPIMELT 2.5 MG 1 iSeroquel 300mg Tab
100 I ,ARIMIDEX lmg TAB -
90 ZOMIG 2.5MG TAB
ClaimSecure Inc. Confidential 5/28/2018 Page 5
Physician Verification - Dr. Keshmirian
--Actu-knotirOweso restri er:1 i43)1Sferate:
ISEROQUEL XR 400MG 100
iSEROQUEL 200MG : 240
LOSEC 20mg TAB ! 200 1 SEROQUEL 200MG
. 240
LOSEC 20mg TAB
,
200
ZOMIG 2.5MG TAB 90
ISEROQUEL XR 400MG 100 • ISeroquel 300mg Tab 200 ; ZOMIG RAPIMELT 2.5 MG! 100 Seroquel 300mg Tab 200 CRESTOR 20 MG 100_,
CRESTOR 20 MG s 100
;ZOMIG RAPIMELT 2.5 MG; 100
;CRESTOR 40MG TAB 100
ISEROQUEL XR 400MG 100
ICRESTOR 40MG TAB ; 100 !
ARIMIDEX 1mg TAB - 100 IZOMIG 2.5MG TAB * : 90 .
ZOMIG 2.5MG TAB_* 90
ZOMIG RAPIMELT 2.5 MG; 100
ZOMIG RAPIMELT 2.5 MG 100 i
SEROQUEL 200MG -1 240 SEROQUEL 200MG 240 !
LOSEC 20mg TAB 2
100 6-Sep-17 844308 67128 100 6-Sep-17 844247 67128 60 - 1-Sep-17 843785 67128
100 1-Sep-17 843787 67128 90 1-Sep-17 843779 67128
100 1-Sep-17 843778 67128 100 I 1-Sep-17 843784 i 67128 100 1-Sep-17 843777 67128
100 1-Sep-17 843786 67128 60 29-Aug-17 843135 67128
100 29-Aug-17 , 843180 67128 60 29-Aug-17 843186 67128
100 29-Aug-17 , 843122 67128 90 29-Aug-17 843107 67128 90 29-Aug-17 ; 843175 67128
100 r 29 -Aug-17 1 843136 67128 100 29-Aug-17 843132 67128 100 ; 29-Aug-17 . 843174 67128' 100 29-Aug-17 i 843185 67128 100 29-Aug-17 843113 67128 100 ; 29-Aug-17 i 843153 67128 100 29-Aug-17 843106 67128 100 29-Aug-17 ! 843112 1 67128 100 29-Aug-17 843187 ; 67128 100 29-Aug-17 843150 67128 100 29-Aug-17 843105 67128
90 29-Aug-17 843321 67128 90 ; 29-Aug-17 843342 67128
100 29-Aug-17 843320 67128 100 i 29-Aug-17 i 843341 67128 60 1 23-Aug-17 842938 67128 90 23-Aug-17 842962, 67128
100 23-Aug-17 842947 67128 I
162
163 164 165
157
158
159
160
161
153
15
155
156
15
15 15
14
14 14
14
14
13
14
14
13 13
14
14
14
13
13
13
13
200
;t;
90 90
ZOMIG 2.5MG TAB ZOMIG 2.5MG TAB
2 LOSEC 20mg TAB
ClaimSecure Inc. Confidential 5/28/2018 Page 5
Physician Verification - Dr. Keshmirian
flP ,Acxt4-ko'otWPAtxsutt i43)1Sferate: A read; -eel
1SEROQUEL XR 400MG 100 :ARIMIDEX 1mg TAB 100 ; 'SEROQUEL 200MG • 240 ! LOSEC 20mg TAB 200 ;
;ZOMIG 2.5MG TAB * 90 IZOMIG RAPIMELT 2.5 MGI 100 iSeroquel 300mg Tab ' 200
,ARIMIDEX 1mg TAB 100 1 ISEROQUEL XR 400MG 100 iSEROQUEL 200MG 240 LOSEC 20mg TAB 200 1 SEROQUEL 200MG . 240 LOSEC 20mg TAB 200
f Seroquel 300mg Tab I 200 CRESTOR 20 MG 100_, CRESTOR 20 MG s 100 .
;ZOMIG RAPIMELT 2.5 MG; 100 ' ;CRESTOR 40MG TAB ' 100 i ISEROQUEL XR 400MG I 100 ICRESTOR 40MG TAB ; 100 ! ARIMIDEX 1mg TAB - 100 liOMIG 2.5MG TAB * : 90 . ZOMIG 2.5MG TAB_* ' 90 .: ZOMIG RAPIMELT 2.5 MG; 100 . ZOMIG RAPIMELT 2.5 MG= 100 i SEROQUEL 200MG -1 240 I SEROQUEL 200MG 240
100 6-Sep-17 844308 67128 100 6-Sep-17 844247 67128 60 1-Sep-17 843785 67128
100 1-Sep-17 I
!
843787 843779
67128 67128 90 1-Sep-17
100 1-Sep-17 843778 67128 100 I 1-Sep-17 843784 i 67128 100 1-Sep-17 843777 67128 100 1-Sep-17 843786 67128 60 29-Aug-17 843135 67128
100 29-Aug-17 , 843180 67128 60 29-Aug-17 843186 67128
100 29-Aug-17 843122 67128 90 29-Aug-17 I 843107 67128 90 29-Aug-17 ; 843175 67128
100 100
(
...,L 29-Aug-17 1 843136 67128 29-Aug-17
. 843132 67128
67128 ' 100 ; 29-Aug-17 843174 100 29-Aug-17 i 843185
__- 67128
100 I 29-Aug-17 843113 67128 67128 100 ; 29-Aug-17 1
i 843153 ;
100 100
, !
29-Aug-17 843106 i 67128 29-Aug-17 843112 1 67128
100 100 100
: 29-Aug-17 843187 . . 67128 29-Aug-17 843150 67128 29-Aug-17 843105 67128
90 ;
29-Aug-17 843321 843342
67128
67128 90 29-Aug-17 100 i
1 29-Aug-17 843320 67128
100 29-Aug-17 t 843341 67128 . - 67128 I 60 1 23-Aug-17 842938
90 23-Aug-17 842962, 67128 100 23-Aug-17 842947 67128
162 163 164 165
157 158 159 160 161
153 15 155 156
15
15 15
14 14 14 14
14
13
14
14
13 13
14 14 14
13 13
13 13
ISEROQUEL XR 400MG 100 • I Seroquel 300mg Tab i 200 ; .ZOMIG RAPIMELT 2.5 MG! 100 4 .
;t;
5/28/2018 Page 6 ClaimSecure Inc. Confidential
Physician Verification - Dr. Keshmirlan
git*fltitif 008-0.00:01 .5110401- P 90 90 23-Aug-17 842917 i 67128
200 100 23-Aug-17 i -4 842924 ! 67128 90 23-Aug-17 67128 90 842975
200 100 23-Aug-17 842937 67128 100 100 23-Aug-17 842974 67128 100 100 23-Aug-17 842916 67128 100 100 23-Aug-17 842928 67128 200 100 23-Aug-17 842961 67128 100 100 23-Aug-17 842971 67128 100 100 23-Aug-17_ 842963 67128 100 V1007 23-Aug-17 842927 i 67128 100 100 23-Aug-17 842970 67128 100 100 23-Aug-17 842939 67128 100 i 100 23-Aug-17 842915 67128 200 100 22-Aug-17 • 842574 ' 67128 200 ! 100 22-Aug-17 ; 842601 67128 240 ; 60 —22-Aug-17 ; 842619 67128 90 90 22-Aug-17 842610 67128
r--- 60 22-Aug-17 842585 67128 240 90 90 22-Aug-17 842579 j 67128
100 100 22-Aug-17 842620 I 67128 200 100 22-Aug-17 842584 67128 100 1 100 i
1- 22-Aug-17 842609 67128
100 100 1 22-Aug-17 842568 67128 100 100 i 22-Aug-17 i 842578 67128 200 100 22-Aug-17 842618 67128 100 1 100 1 22-Aug-17 842598 67128 100 i 100 22-Aug-17 842586 67128 100 i 100 22-Aug-17 842567 67128 100 ; 100 22-Aug-17 842597 67128 100 i 100 22-Aug-17. 842577 67128 240 60 I 19-Aug-17 842239 67128 200 100 19-Aug-17 842222 67128
,ZOMIG 2.5MG TAB * LOSEC 20mg TAB ,ZOMIG 2.5MG TAB * Seroquel 300mg Tab ZOMIG RAPIMELT 2.5 MG ZOMIG RAPIMELT 2.5 MG CRESTOR 20 MG Seroquel 300mg Tab CRESTOR 20 MG SEROQUEL XR 400MG CRESTOR 40MG TAB CRESTOR 40MG TAB SEROQUEL XR 400MG ARIMIDEX 1mg TAB 179 LOSEC 20mg TAB LOSEC 20mg TAB
18 181
SEROQUEL 200MG ZOMIG 2.5MG TAB *
• SEROQUEL 200MG ZOMIG 2.5MG TAB * SEROQUEL XR 400MG ' Seroquel 300mg Tab ZOMIG RAPIMELT 2.5 MG; CRESTOR 20 MG
ZOMIG RAP1MELT 2.5 MGI Seroquel 300mg Tab CRESTOR 20 MG 1 EROQUEL XR 400MG
CRESTOR 40MG TAB RESTOR 40MG TAB i RIMIDEX 1mg TAB j EROQUEL 200MG OSEC 20mg TAB
16 16 16 16 17 17 17 17 17 7
17 17 17
182 183 18 185 186 187 188 189 190 191 192 193 194 195 196 197 198
5/28/2018 Page 6 ClaimSecure Inc. Confidential
Physician Verification - Dr. Keshmirlan
git*fltitif 008-0.00:01 .5110401- P 90 90 23-Aug-17 842917 i 67128
200 100 23-Aug-17 i -4 842924 ! 67128 90 23-Aug-17 67128 90 842975
200 100 23-Aug-17 842937 67128 100 100 23-Aug-17 842974 67128 100 100 23-Aug-17 842916 67128 100 100 23-Aug-17 842928 67128 200 100 23-Aug-17 842961 67128 100 100 23-Aug-17 842971 67128 100 100 23-Aug-17_ 842963 67128 100 V1007 23-Aug-17 842927 i 67128 100 100 23-Aug-17 842970 67128 100 100 23-Aug-17 842939 67128 100 i 100 23-Aug-17 842915 67128 200 100 22-Aug-17 • 842574 ' 67128 200 ! 100 22-Aug-17 ; 842601 67128 240 ; 60 —22-Aug-17 ; 842619 67128 90 90 22-Aug-17 842610 67128
r--- 60 22-Aug-17 842585 67128 240 90 90 22-Aug-17 842579 j 67128
100 100 22-Aug-17 842620 I 67128 200 100 22-Aug-17 842584 67128 100 1 100 i
1- 22-Aug-17 842609 67128
100 100 1 22-Aug-17 842568 67128 100 100 i 22-Aug-17 i 842578 67128 200 100 22-Aug-17 842618 67128 100 1 100 1 22-Aug-17 842598 67128 100 i 100 22-Aug-17 842586 67128 100 i 100 22-Aug-17 842567 67128 100 ; 100 22-Aug-17 842597 67128 100 i 100 22-Aug-17. 842577 67128 240 60 I 19-Aug-17 842239 67128 200 100 19-Aug-17 842222 67128
,ZOMIG 2.5MG TAB * LOSEC 20mg TAB ,ZOMIG 2.5MG TAB * Seroquel 300mg Tab ZOMIG RAPIMELT 2.5 MG ZOMIG RAPIMELT 2.5 MG CRESTOR 20 MG Seroquel 300mg Tab CRESTOR 20 MG SEROQUEL XR 400MG CRESTOR 40MG TAB CRESTOR 40MG TAB SEROQUEL XR 400MG ARIMIDEX 1mg TAB 179 LOSEC 20mg TAB LOSEC 20mg TAB
18 181
SEROQUEL 200MG ZOMIG 2.5MG TAB *
• SEROQUEL 200MG ZOMIG 2.5MG TAB * SEROQUEL XR 400MG ' Seroquel 300mg Tab ZOMIG RAPIMELT 2.5 MG; CRESTOR 20 MG
ZOMIG RAP1MELT 2.5 MGI Seroquel 300mg Tab CRESTOR 20 MG 1 EROQUEL XR 400MG
CRESTOR 40MG TAB RESTOR 40MG TAB i RIMIDEX 1mg TAB j EROQUEL 200MG OSEC 20mg TAB
16 16 16 16 17 17 17 17 17 7
17 17 17
182 183 18 185 186 187 188 189 190 191 192 193 194 195 196 197 198
5/28/2018 Page 6 ClaimSecure Inc. Confidential
Physician Verification - Dr. Keshmirlan
aPrOkig:N4-nigra ,;21: "74::
,ZOMIG 2.5MG TAB * 16 LOSEC 20mg TAB ,ZOMIG 2.5MG TAB * j Seroquel 300mg Tab ZOMIG RAPIMELT 2.5 MG ZOMIG RAPIMELT 2.5 MGi CRESTOR 20 MG j Seroquel 300mg Tab CRESTOR 20 MG SEROQUEL XR 400MG CRESTOR 40MG TAB CRESTOR 40MG TAB SEROQUEL XR 400MG ARIMIDEX 1mg TAB 179 LOSEC 20mg TAB LOSEC 20mg TAB
18 181
SEROQUEL 200MG ZOMIG 2.5MG TAB * i SEROQUEL 200MG ZOMIG 2.5 MG TAB * SEROQUEL XR 400MG ' Seroquel 300mg Tab ; ZOMIG RAPIMELT 2.5 MG; CRESTOR 20 MG
ZOMIG RAPIMELT 2.5 MG I Seroquel 300mg Tab i CRESTOR 20 MG 1 EROQUEL XR 400MG
CRESTOR 40MG TAB RESTOR 40MG TAB RIMIDEX 1mg TAB j EROQUEL 200MG OSEC 20mg TAB
16 16 16 17 17 17 17 17 7
17 17 17
182 183 18 185 186 187 188 189 190 191 192 193 194 195 196 197 198
gi-Wititif 008-0.00.01 P efID
90 90 23-Aug-17 842917 i 67128 200 100 23-Aug-17 i 842924 67128 90 90 ; 23-Aug-17
-4 842975 67128
200 100 23-Aug-17 842937 67128
.100 100 23-Aug-17 842974 j 67128 100 100 23-Aug-17 ; 842916 67128 100 100 23-Aug-17 842928 67128 200 100 23-Aug-17 842961 67128 100 100 23-Aug-17 842971 67128 100 100. 23-Aug-17 842963 3 67128 100 : 100 23-Aug-17 1 842927 i 67128 100 10.0 23-Aug-17 842970 1 67128 100 100 23-Aug-17 842939 67128 100 i 100 i 23-Aug-17 842915 67128 200 100 22-Aug-17 842574 67128 200 ! 100 22-Aug-17 842601 i 67128 240 , 60 22-Aug-17 = 842619 i 67128 90 90 22-Aug-17 842610 1 67128 240 ' ,
60 22-Aug-17 ' 842585 67128 90 90 22-Aug-17 , 842579 ! 67128
100 100 22-Aug-17 , 842620 I 67128 200 = 100 22-Aug-17 842584 67128 100 ; 100 i 22-Aug-17 842609 67128 100 100 1 22-Aug-17 842568 67128 100 100 i 22-Aug-17 842578 67128 200 100 ! 22-Aug-17 842618 67128 100 100 1 22-Aug-17 842598 67128 100 i 100 22-Aug-17 842586 1 67128 100 i 100 22-Aug-17 842567 67128 100 100 22-Aug-17 842597 67128 100 100 22-Aug-17 842577 67128 240 60 j 19-Aug-17 842239 67128 200 100 19-Aug-17 842222 67128
Physician Verification - Dr. Keshmirian
firitilkiife MatNOM - . CWantity:RatOtifigsi, .,,'Ditii.460-fiCW: ,., INIToy=. ?regilheYlp 67128 1991 ILOSEC 20mg TAB 200 ' 100 • I 19-Aug-17 842253 I
2001 I SEROQUEL 200MG 240 60 19-Aug-17 842260 67128 201 IZOMIG 2.5MG TAB * I 90 90 ; 19-Aug-17 842237 67128 . 202' ZOMIG 2.5MG TAB * 90 r 90 19-Aug-17 I842252 1 67128 203' 204 2051 206
;Seroquel 300mg Tab 200 100 19-Augr17 842259 67128 IZOMIG RAPIMELT 2.5 MG i 100 100 i 19-Aug-17 1 842251 : 67128 IZOMIG RAPIMELT 2.5 MG: 100 100 19-Aug-17 842236 67128 (Seroquel 300mg Tab 200 100 19-Aug-17 842238 67128
2071 208 209: 2101 211 212. 213:
'CRESTOR 20 MG i 100 100
1 ;
100 100
i 19-Aug-17 19-Aug-17
842221 ' 842271
67128 CRESTOR 20 MG 67128 . Y-
1SEROQ1JEL XR 400MG 100 ; 100 1 19-Aug-17 842240 67128 CRESTOR 40MG TAB 100.. i 100 19-Aug-17 842220 67128
1SEROQUE1 XR 400MG 100 100 ) 19-Aug-17 ! 842261 67128 CRESTOR 40MG TAB 100 . 100 : ' 19-Aug-17 : 842270 . 67128
' 1ARIMIDEX 1mg TAB 100 100 90
19-Aug-17 ; 842235 67128 214' 215
IZOMIG 2.5MG TAB * , 90 18-Aug-17 841999 67128 IZOMIG 2.5MG TAB * , 90 . 90 18-Aug-17 841991 67128
2161 2171
IZOMIG RAPIMELT 2.5 MG! 100 100 j 18-Aug-17 841998 ! . 67128 ; ! 1ZOMIG RAP1MELT 2.5 MGI 100 ; 100 I 18-Aug-17 i 841990: 67128
2181 219f
LOSEC 20mg TAB 1 200 1 100 17-Aug-17 841881 67128 1LOSEC 20mg TAB 200 i 100 17-Aug-17 841910 67128
220; 221;
223
IZOMIG 2.5MG TAB * . 90 90
90 ' 17-Aug-17 841893 67128 ZOMIG 2.5MG TAB * 90
. ., 17-Aug-17 841912 67128
222: ZOMIG' RAPIMELT 2.5 MG; 100 ' 100 17-Aug-17 .... 841914 67128 ZOMIG RAPIMELT 2.5 MG! 100 100 17-Aug-17 841892 67128
224i Seroquel 300mg Tab ' 200 100 j 17-Aug-17 841899 67128 ' 225! Seroquel 300mg Tab 200 100 27-Aug-17 841920 67128 I 226; 22-77 2281
CRESTOR 20 MG 1 100 100 , _ I 17-Aug-17 841926 1 67128 I CRESTOR 20 MG 100 100 ' 17-Aug-17 841898 67128 SEROQUEL XR 400MG 100 • 100 ; 17-Aug-17 841922 1 67128
229; 23(X 231 i
SEROQUEL XR 400MG 100 i 100 17-Aug-17 841901 67128 j CRESTOR 40MG TAB 100 i 100 17-Aug-17 841925 . 67128 -CRESTOR 40MG TAB 100 100 17-Aug-17 1 841896 i 67128
ClaimSecure Inc. Confidential 5/28/2018 Page 7
Physician Verification - Dr. Keshmirian
firitilkiife MatNOM - . CWantity:RatOtifigsi, .,,'Ditii.460-fiCW: ,., INIToy=. ?regilheYlp 67128 1991 ILOSEC 20mg TAB 200 ' 100 • I 19-Aug-17 842253 I
2001 I SEROQUEL 200MG 240 60 19-Aug-17 842260 67128 201 IZOMIG 2.5MG TAB * I 90 90 ; 19-Aug-17 842237 67128 . 202' ZOMIG 2.5MG TAB * 90 r 90 19-Aug-17 I842252 1 67128 203' 204 2051 206
;Seroquel 300mg Tab 200 100 19-Augr17 842259 67128 IZOMIG RAPIMELT 2.5 MG i 100 100 i 19-Aug-17 1 842251 : 67128 IZOMIG RAPIMELT 2.5 MG: 100 100 19-Aug-17 842236 67128 (Seroquel 300mg Tab 200 100 19-Aug-17 842238 67128
2071 208 209: 2101 211 212. 213:
'CRESTOR 20 MG i 100 100
1 ;
100 100
i 19-Aug-17 19-Aug-17
842221 ' 842271
67128 CRESTOR 20 MG 67128 . Y-
1SEROQ1JEL XR 400MG 100 ; 100 1 19-Aug-17 842240 67128 CRESTOR 40MG TAB 100.. i 100 19-Aug-17 842220 67128
1SEROQUE1 XR 400MG 100 100 ) 19-Aug-17 ! 842261 67128 CRESTOR 40MG TAB 100 . 100 : ' 19-Aug-17 : 842270 . 67128
' 1ARIMIDEX 1mg TAB 100 100 90
19-Aug-17 ; 842235 67128 214' 215
IZOMIG 2.5MG TAB * , 90 18-Aug-17 841999 67128 IZOMIG 2.5MG TAB * , 90 . 90 18-Aug-17 841991 67128
2161 2171
IZOMIG RAPIMELT 2.5 MG! 100 100 j 18-Aug-17 841998 ! . 67128 ; ! 1ZOMIG RAP1MELT 2.5 MGI 100 ; 100 I 18-Aug-17 i 841990: 67128
2181 219f
LOSEC 20mg TAB 1 200 1 100 17-Aug-17 841881 67128 1LOSEC 20mg TAB 200 i 100 17-Aug-17 841910 67128
220; 221;
223
IZOMIG 2.5MG TAB * . 90 90
90 ' 17-Aug-17 841893 67128 ZOMIG 2.5MG TAB * 90
. ., 17-Aug-17 841912 67128
222: ZOMIG' RAPIMELT 2.5 MG; 100 ' 100 17-Aug-17 .... 841914 67128 ZOMIG RAPIMELT 2.5 MG! 100 100 17-Aug-17 841892 67128
224i Seroquel 300mg Tab ' 200 100 j 17-Aug-17 841899 67128 ' 225! Seroquel 300mg Tab 200 100 27-Aug-17 841920 67128 I 226; 22-77 2281
CRESTOR 20 MG 1 100 100 , _ I 17-Aug-17 841926 1 67128 I CRESTOR 20 MG 100 100 ' 17-Aug-17 841898 67128 SEROQUEL XR 400MG 100 • 100 ; 17-Aug-17 841922 1 67128
229; 23(X 231 i
SEROQUEL XR 400MG 100 i 100 17-Aug-17 841901 67128 j CRESTOR 40MG TAB 100 i 100 17-Aug-17 841925 . 67128 -CRESTOR 40MG TAB 100 100 17-Aug-17 1 841896 i 67128
ClaimSecure Inc. Confidential 5/28/2018 Page 7
Physician Verification - Dr. Keshmirian
fin-M*10 Mat NOM . Cifialltiti RatfStifigSipitli.460-ipat: ,., INfoY=... ?regilbeWlp
67128 1991 ILOSEC 20mg TAB 200 ' 100 • I 19-Aug-17 842253 I 2001 I SEROQUEL 200MG 240 60 19-Aug-17 842260 67128 201 IZOMIG 2.5MG TAB * I 90 90 ; 19-Aug-17 842237 67128 . 202' ZOMIG 2.5MG TAB * 90 r 90 19-Aug-17 1 842252 1 67128 203' 204 2051 206
;Seroquel 300mg Tab 200 100 19-Augr17 842259 67128 IZOMIG RAPIMELT 2.5 MG i 100 100 i 19-Aug-17 i 842251 : 67128 IZOMIG RAPIMELT 2.5 MG: 100 100 19-Aug-17 842236 67128 (Seroquel 300mg Tab 200 100 19-Aug-17 842238 67128
2071 208 209: 2101 211 212. 213:
'CRESTOR 20 MG i 100 100
1 ;
100 100
i 19-Aug-17 19-Aug-17
842221 ' 842271
67128 CRESTOR 20 MG 67128 . Y-
1SEROQ1JEL XR 400MG 100 ; 100 1 19-Aug-17 842240 67128 CRESTOR 40MG TAB 100.. i 100 19-Aug-17 842220 67128
1SEROQUE1 XR 400MG 100 100 ) 19-Aug-17 ! 842261 67128 CRESTOR 40MG TAB 100 . 100 : ' 19-Aug-17 : 842270 . 67128
' 1ARIMIDEX 1mg TAB 100 100 90
19-Aug-17 ; 842235 67128 214' 215
IZOMIG 2.5MG TAB * 90 18-Aug-17 841999 67128 IZOMIG 2.SMG TAB * , 90 90 18-Aug-17 841991 67128
2161 2171
IZOMIG RAPIMELT 2.5 MG! 100 100 j 18-Aug-17 841998 ! . 67128 ; ! 1ZOMIG RAP1MELT 2.5 MGI 100 ; 100 I 18-Aug-17 i 841990: 67128
2181 219f
LOSEC 20mg TAB 1 200 I 100 17-Aug-17 841881 67128 1LOSEC 20mg TAB 200 i 100 17-Aug-17 841910 67128
220; 221;
223
IZOMIG 2.5MG TAB * . 90 90
90 ' 17-Aug-17 841893 67128 ZOMIG 2.5MG TAB * 90
. ., 17-Aug-17 841912 67128
222: ZOMIG' RAPIMELT 2.5 MG; 100 ' 100 17-Aug-17 .... 841914 67128 ZOMIG RAPIMELT 2.5 MG! 100 100 17-Aug-17 841892 67128
224i Seroquel 300mg Tab ' 200 100 j 17-Aug-17 841899 67128 ' 225! Seroquel 300mg Tab 200 100 27-Aug-17 841920 67128 I 226; 22-77 2281
CRESTOR 20 MG 1 100 100 , _ I 17-Aug-17 841926 67128 I CRESTOR 20 MG 100 100 ' 17-Aug-17 841898 67128 SEROQUEL XR 400MG 100 • 100 ; 17-Aug-17 841922 1 67128
229; 23(X 231i
SEROQUEL XR 400MG 100 i 100 17-Aug-17 841901 67128 j CRESTOR 40MG TAB 100 i 100 17-Aug-17 841925 . 67128 -CRESTOR 40MG TAB 100 100 17-Aug-17 841896 i 67128
ClaimSecure Inc. Confidential 5/28/2018 Page 7
Physician Verification - Dr. Keshmirian
:Z t First i .'..0,g0,traffif. i-:•t:T.;:'; ., ._.:43 ;i,i'WZ:7.,',ZOIiiiPi::;g:,46-ZI: !Rkfifititif, Pitt$00. -; -;.gpir",:r1!1-07D-EiftZ 4Ibt::NO- 1!!0-0.10A .M ' •.il
232
233
234
ARIMIDEX 1mg TAB 100 I 100 ' 17-Aug-17 841911 67128 SEROQUEL 200MG 240 . 60 : 17-Aug-17 841900 67128 ' SEROQUEL 200MG 240 ' 60 : 17-Aug-17 841921 67128 .
235 ZOM1G 2.5MG TAB * 90 90 17-Aug-17 I 841853 i 67128 ,
236
237
ZOMIG RAPIMELT2.5 MG! 100 i 100 100
: !
17-Aug-17 841854 67128 ZOMIG RAPIMELT2.5 MG 100 17-Aug-17 . 841846 f 67128
238 ZOMIG 2.5MG TAB * , 90 I 90 17-Aug-17 ; 841845 .
841705
67128
67128 239 240
ZOMIG 2.5MG TAB * 90 . 90
100
, .i 16-Aug-17 e
ZOMIG RAPIMELT2.5 MG 100 ' 1 16-Aug-17 841704 67128
241
242
ZOMIG 2.5MG TAB * 90 4 90 1 ----t—
i
9-Aug-17 ; 840841 67128
ZOMIG 2.5MG TAB * 90 i 90 9-Aug-17 840811 i 67128
243 244
245
ZOMIG RAPIMELT2.5 MG 100 i 100 I 9-Aug-17 840840 ' 67128 _-
! ZOMIG RAP1M ELT 2.5 MG 100 i
SEROQUEL 200MG 240 I 100 1 9-Aug-17 840810 67128 60 8-Aug-17 840775 67128 . __
246 SEROQUEL 200MG 200 100 ' 8-Aug-17 840747 67128
247 LOSEC 20mg TAB 200 • 100 i 8-Aug-17 840773 i 67128
2.48 249 250
LOSEC 20mg TAB t200 ZOMIG 2.5MG TAB * 90 :
100 8-Aug-17 840753 67128 90 i 8-Aug-17 840755 67128
ZOMIG 2.5MG TAB * 90 1 90 8-Aug-17 .._ 840759 67128
251 SEROQUEL XR 400MG 100 I 100 8-Aug-17 840748 l 67128
252 ZOMIG RAPIMELT2.5 MG 100 i 100 8-Aug-17 840758 67128
253 2541
2551
2561
2571 2581
Seroquel 300mg Tab ! 200 1 100 — 8-Aug-17 840774 67128
Seroquel 300mg Tab 200
r OMIG RAP1M ELT 2.5 MGI 100 !
100 8-Aug-17 840746 j 67128 , 100 _ 8-Aug-17 840754 F 67128 •
RESTOR 40MG TAB 1 100 ' 100 8-Aug-17 840762 67128
CRESTOR 40MG TAB 1 100 • 100 — 8-Aug-17 j 840756 ' 67128 : RIMIDEX 1mg TAB I 100 . 100 8-Aug-17 840757 . 67128
ClaimSecure Inc. Confidential 5/28/2018 Page 8
Physician Verification - Dr. Keshmirian
:Z t First i .'..0,g0,traffif. i-:•t:T.;:'; ., ._.:43 ;i,i'WZ:7.,',ZOIiiiPi::;g:,46-ZI: !Rkfifititif, Pitt$00. -; -;.gpir",:r1!1-07D-EiftZ 4Ibt::NO- 1!!0-0.10A .M ' •.il
232
233
234
ARIMIDEX 1mg TAB 100 I 100 ' 17-Aug-17 841911 67128 SEROQUEL 200MG 240 . 60 : 17-Aug-17 841900 67128 ' SEROQUEL 200MG 240 ' 60 : 17-Aug-17 841921 67128 .
235 ZOM1G 2.5MG TAB * 90 90 17-Aug-17 I 841853 i 67128 ,
236
237
ZOMIG RAPIMELT2.5 MG! 100 i 100 100
: !
17-Aug-17 841854 67128 ZOMIG RAPIMELT2.5 MG 100 17-Aug-17 . 841846 f 67128
238 ZOMIG 2.5MG TAB * , 90 I 90 17-Aug-17 ; 841845 .
841705
67128
67128 239 240
ZOMIG 2.5MG TAB * 90 . 90
100
, .i 16-Aug-17 e
ZOMIG RAPIMELT2.5 MG 100 ' 1 16-Aug-17 841704 67128
241
242
ZOMIG 2.5MG TAB * 90 4 90 1 ----t—
i
9-Aug-17 ; 840841 67128
ZOMIG 2.5MG TAB * 90 i 90 9-Aug-17 840811 i 67128
243 244
245
ZOMIG RAPIMELT2.5 MG 100 i 100 I 9-Aug-17 840840 ' 67128 _-
! ZOMIG RAP1M ELT 2.5 MG 100 i
SEROQUEL 200MG 240 I 100 1 9-Aug-17 840810 67128 60 8-Aug-17 840775 67128 . __
246 SEROQUEL 200MG 200 100 ' 8-Aug-17 840747 67128
247 LOSEC 20mg TAB 200 • 100 i 8-Aug-17 840773 i 67128
2.48 249 250
LOSEC 20mg TAB t200 ZOMIG 2.5MG TAB * 90 :
100 8-Aug-17 840753 67128 90 i 8-Aug-17 840755 67128
ZOMIG 2.5MG TAB * 90 1 90 8-Aug-17 .._ 840759 67128
251 SEROQUEL XR 400MG 100 I 100 8-Aug-17 840748 l 67128
252 ZOMIG RAPIMELT2.5 MG 100 i 100 8-Aug-17 840758 67128
253 2541
2551
2561
2571 2581
Seroquel 300mg Tab ! 200 1 100 — 8-Aug-17 840774 67128
Seroquel 300mg Tab 200
r OMIG RAP1M ELT 2.5 MGI 100 !
100 8-Aug-17 840746 j 67128 , 100 _ 8-Aug-17 840754 F 67128 •
RESTOR 40MG TAB 1 100 ' 100 8-Aug-17 840762 67128
CRESTOR 40MG TAB 1 100 • 100 — 8-Aug-17 j 840756 ' 67128 : RIMIDEX 1mg TAB I 100 . 100 8-Aug-17 840757 . 67128
ClaimSecure Inc. Confidential 5/28/2018 Page 8
Physician Verification - Dr. Keshmirian
•_ Tifgilal*340Naffit: , .;;s.a. ,,,;:., , - ,.. !goofy, piveisow ,-,.,,a, it--70-falitez .34.._,_ .i.: FAktgilbAIP .v 232
233
234
ARIMIDEX 1mg TAB 100 I 100 17-Aug-17 841911 67128 SEROQUEL 200MG 240 • 60 : 17-Aug-17 841900 67128 _ .. SEROQUEL 200MG 240 60 17-Aug-17 841921 67128
235 ZOM1G 2.5MG TAB * 90 90 17-Aug-17 I 841853 i 67128
236
237
ZOMIG RAPIMELT2.5 MG! 100 , 100 100
. 17-Aug-17 841854 67128 ZOMIG RAPIMELT2.5 MG1 100 17-Aug-17 . 841846 f 67128
238 ZOMIG 2.5MG TAB * 90 I 90 17-Aug-17 841845 . 67128
239 240
ZOMIG 2.5MG TAB * 90 , 90
100
- .i 16-Aug-17 e 841705 67128 T ZOMIG RAPIMELT2.5 MG 100 ' 1 16-Aug-17 841704 67128
241
242
ZOMIG 2.5MG TAB * 90 4
90 1 ----t-
i
9-Aug-17 ;_840841 67128
ZOMIG 2.5MG TAB * 90 i 90 9-Aug-17 840811 i 67128
243 244
245
ZOMIG RAPIMELT2.5 MG 100 ] 100 I 9-Aug-17 840840 ' 67128 ZOMIG RAP1M ELT 2.5 MG
SEROQUEL 200MG
100
240 !
100 I
"
9-Aug-17 840810 67128 60 8-Aug-17 840775 67128 ____
246 SEROQUEL 200MG 200 100 , 8-Aug-17 840747 67128
247 LOSEC 20mg TAB •
200 • 100 i 8-Aug-17 840773 i 67128
2.48 249 250
LOSEC 20mg TAB ' ZOMIG 2.5MG TAB *
200 90 :
100 8-Aug-17 840753 67128 90 1 8-Aug-17 840755 67128 •
ZOMIG 2.5MG TAB * ! 90 1 90 I 8-Aug-17 840759 ........ 67128
251 SEROQUEL XR 400MG 100 I 100 8-Aug-17 840748 l 67128
252 ZOMIG RAPIMELT2.5 MG 100 i 100 8-Aug-17 840758 67128
253 i 2541
255;
2561
257! 2581 _
Seroquel 300mg Tab ! 200 I 100 : -- -
i 8-Aug-17 840774 67128
Seroquel 300mg Tab
r OMIG RAP1MELT 2.5 MGI 200 , .
100 r
100 8-Aug-17 840746 j 67128 100 8-Aug-17 840754 F 67128
RESTOR 40MG TAB , 100 ' 100 r 8-Aug-17 840762 67128
CRESTOR 40MG TAB 1 RIMIDEX 1mg TAB I
100 100 8-Aug-17 __.... j 840756 . ' 67128 "
100 . 100 8-Aug-17 840757 67128 1
ClaimSecure Inc. Confidential 5/28/2018 Page 8
ASTRAZENECA CANADA INC. -and- SAMEH SADEK also known as SAM Court File No. CV-18-602745-00 CL SADEK et al.
Plaintiff Defendants
ONTARIO SUPERIOR COURT OF JUSTICE
(COMMERCIAL LIST)
Proceeding commenced at Toronto
AFFIDAVIT OF DOUG QUAN SWORN SEPTEMBER 10, 2018
BLAKE, CASSELS & GRAYDON LLP Banisters & Solicitors 199 Bay Street Suite 4000, Commerce Court West Toronto ON M5L 1A9
R. Seumas M. Woods LSO #301691 Tel: 416-863-3876 [email protected]
Erin Hoult LSO #54002C Tel: 416-863-4011 Fax: 416-863-2653 [email protected]
Lawyers for the plaintiff
'40
ASTRAZENECA CANADA INC. -and- SAMEH SADEK also known as SAM Court File No. CV-18-602745-00 CL SADEK et al.
Plaintiff Defendants
ONTARIO SUPERIOR COURT OF JUSTICE
(COMMERCIAL LIST)
Proceeding commenced at Toronto
AFFIDAVIT OF DOUG QUAN SWORN SEPTEMBER 10, 2018
BLAKE, CASSELS & GRAYDON LLP Banisters & Solicitors 199 Bay Street Suite 4000, Commerce Court West Toronto ON M5L 1A9
R. Seumas M. Woods LSO #301691 Tel: 416-863-3876 [email protected]
Erin Hoult LSO #54002C Tel: 416-863-4011 Fax: 416-863-2653 [email protected]
Lawyers for the plaintiff
'40
ASTRAZENECA CANADA INC. -and- SAMEH SADEK also known as SAM Court File No. CV-18-602745-00 CL SADEK et al.
Plaintiff Defendants
ONTARIO SUPERIOR COURT OF JUSTICE
(COMMERCIAL LIST)
Proceeding commenced at Toronto
AFFIDAVIT OF DOUG QUAN SWORN SEPTEMBER 10, 2018
BLAKE, CASSELS & GRAYDON LLP Banisters & Solicitors 199 Bay Street Suite 4000, Commerce Court West Toronto ON M5L 1A9
R. Seumas M. Woods LSO #301691 Tel: 416-863-3876 [email protected]
Erin Hoult LSO #54002C Tel: 416-863-4011 Fax: 416-863-2653 [email protected]
Lawyers for the plaintiff
'40
Tab 4
Court File No. CV-18-602745-00-CL
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
BETWEEN:
ASTRAZENECA CANADA INC.
Plaintiff
- and -
SAMEH SADEK also known as SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL CLINIC INC., SRX INVESTMENT INC.,
SHEPHERD RX PHARMACY INC. and LILIAN FAM
Defendants
CONSENT
The undersigned, Alvarez & Marsal Canada Inc. ("A&M"), hereby consents to the
appointment of A&M as receiver, without security, of all of the assets, undertakings and
properties of Sameh Sadek also known as Sam Sadek, St. Maharial Pharmacy Inc. dba MD
Health Pharmacy, St. Maharial Clinic Inc., SRX Investment Inc., Shepherd RX Pharmacy Inc.
and Lilian Fam (collectively, the "Defendants"), pursuant to the provisions of section 101 of the
Courts of Justice Act, R.S.O. 1990, c. C.43, as amended, and the tetras of an order substantially
in the form filed in the above proceeding.
DATED at Toronto, this day of September, 2018.
ALVAREZ & MARSAL CANADA INC.
Name: Title:
41-1
Court File No. CV-18-602745-00-CL
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
BETWEEN:
ASTRAZENECA CANADA INC.
Plaintiff
- and -
SAMEH SADEK also known as SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL CLINIC INC., SRX INVESTMENT INC.,
SHEPHERD RX PHARMACY INC. and LILIAN FAM
Defendants
CONSENT
The undersigned, Alvarez & Marsal Canada Inc. ("A&M"), hereby consents to the
appointment of A&M as receiver, without security, of all of the assets, undertakings and
properties of Sameh Sadek also known as Sam Sadek, St. Maharial Pharmacy Inc. dba MD
Health Pharmacy, St. Maharial Clinic Inc., SRX Investment Inc., Shepherd RX Pharmacy Inc.
and Lilian Fam (collectively, the "Defendants"), pursuant to the provisions of section 101 of the
Courts of Justice Act, R.S.O. 1990, c. C.43, as amended, and the tetras of an order substantially
in the form filed in the above proceeding.
DATED at Toronto, this day of September, 2018.
ALVAREZ & MARSAL CANADA INC.
Name: Title:
41-1
Court File No. CV-18-602745-00-CL
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
BETWEEN:
ASTRAZENECA CANADA INC.
Plaintiff
- and -
SAMEH SADEK also known as SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL CLINIC INC., SRX INVESTMENT INC.,
SHEPHERD RX PHARMACY INC. and LILIAN FAM
Defendants
CONSENT
The undersigned, Alvarez & Marsal Canada Inc. ("A&M"), hereby consents to the
appointment of A&M as receiver, without security, of all of the assets, undertakings and
properties of Sameh Sadek also known as Sam Sadek, St. Maharial Pharmacy Inc. dba MD
Health Pharmacy, St. Maharial Clinic Inc., SRX Investment Inc., Shepherd RX Pharmacy Inc.
and Lilian Fam (collectively, the "Defendants"), pursuant to the provisions of section 101 of the
Courts of Justice Act, R.S.O. 1990, c. C.43, as amended, and the tetras of an order substantially
in the form filed in the above proceeding.
DATED at Toronto, this day of September, 2018.
ALVAREZ & MARSAL CANADA INC.
Name: Title:
41-1
ASTRAZENECA CANADA INC. - and - SAMEH SADEK, ET AL.
Plaintiff Defendants Court File No. CV-18-602745-00-CL
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
Proceedings commenced at Toronto
CONSENT
AIRD & BERLIS LLP Brookfield Place
181 Bay Street, Suite 1800 Toronto, ON M5J 2T9
Ian Aversa (LSUC # 55449N) Tel: (416) 865-3082 Fax: (416) 863-1515 Email: [email protected]
Kyle Plunkett (LSUC # 61044N) Tel: (416) 865-3406 Fax: (416) 863-1515 Email: kplunketta,airdberlis.com
Lawyers for Alvarez & Marsal Canada Inc. 33638309.2
ASTRAZENECA CANADA INC. - and - SAMEH SADEK, ET AL.
Plaintiff Defendants Court File No. CV-18-602745-00-CL
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
Proceedings commenced at Toronto
CONSENT
AIRD & BERLIS LLP Brookfield Place
181 Bay Street, Suite 1800 Toronto, ON M5J 2T9
Ian Aversa (LSUC # 55449N) Tel: (416) 865-3082 Fax: (416) 863-1515 Email: [email protected]
Kyle Plunkett (LSUC # 61044N) Tel: (416) 865-3406 Fax: (416) 863-1515 Email: kplunketta,airdberlis.com
Lawyers for Alvarez & Marsal Canada Inc. 33638309.2
ASTRAZENECA CANADA INC. - and - SAMEH SADEK, ET AL.
Plaintiff Defendants Court File No. CV-18-602745-00-CL
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
Proceedings commenced at Toronto
CONSENT
AIRD & BERLIS LLP Brookfield Place
181 Bay Street, Suite 1800 Toronto, ON M5J 2T9
Ian Aversa (LSUC # 55449N) Tel: (416) 865-3082 Fax: (416) 863-1515 Email: [email protected]
Kyle Plunkett (LSUC # 61044N) Tel: (416) 865-3406 Fax: (416) 863-1515 Email: kplunketta,airdberlis.com
Lawyers for Alvarez & Marsal Canada Inc. 33638309.2
Tab 5
Court File No. CV- I 8-602745-00-CL
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
THE HONOURABLE MR. TUESDAY, THE 11TH DAY
JUSTICE DUNPHY OF SEPTEMBER, 2018
ASTRAZENECA CANADA INC. Plaintiff
- and -
SAMEH SADEK also known as SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL
CLINIC INC., SRX INVESTMENT INC., SHEPHERD RX PHARMACY INC. and LILIAN FAM
Defendants
ORDER (appointing Receiver)
THIS MOTION made ex parte by Astrazeneca Canada Inc. (the "Plaintiff') for an Order
pursuant to section 101 of the Courts of Justice Act, R.S.O. 1990, c. C.43, as amended (the
"CJA") appointing Alvarez & Marsal Canada Inc. ("A&M") as receiver (in such capacity, the
"Receiver"), without security, of all of the domestic assets, undertakings and properties of
Sameh Sadek also known as Sam Sadek, St. Maharial Pharmacy Inc. dba MD Health Pharmacy,
St. Maharial Clinic Inc., SRX Investment Inc., Shepherd RX Pharmacy Inc. and Lilian Fam
(collectively, the "Defendants" and, individually, a "Defendant"), and for related relief, was
heard this day at 330 University Avenue, Toronto, Ontario.
ON READING the Motion Record and Factum of the Plaintiff dated August 8, 2018, the
Supplemental Motion Record of the Plaintiff dated August 17, 2018, the Second Supplemental
Motion Record of the Plaintiff dated September 5, 2018, and the Motion Record for a Receiver,
the Factum and Book of Authorities of the Plaintiff dated September 10, 2018, and the Orders of
23451639.11
Court File No. CV- I 8-602745-00-CL
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
THE HONOURABLE MR. TUESDAY, THE 11TH DAY
JUSTICE DUNPHY OF SEPTEMBER, 2018
ASTRAZENECA CANADA INC. Plaintiff
- and -
SAMEH SADEK also known as SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL
CLINIC INC., SRX INVESTMENT INC., SHEPHERD RX PHARMACY INC. and LILIAN FAM
Defendants
ORDER (appointing Receiver)
THIS MOTION made ex parte by Astrazeneca Canada Inc. (the "Plaintiff') for an Order
pursuant to section 101 of the Courts of Justice Act, R.S.O. 1990, c. C.43, as amended (the
"CJA") appointing Alvarez & Marsal Canada Inc. ("A&M") as receiver (in such capacity, the
"Receiver"), without security, of all of the domestic assets, undertakings and properties of
Sameh Sadek also known as Sam Sadek, St. Maharial Pharmacy Inc. dba MD Health Pharmacy,
St. Maharial Clinic Inc., SRX Investment Inc., Shepherd RX Pharmacy Inc. and Lilian Fam
(collectively, the "Defendants" and, individually, a "Defendant"), and for related relief, was
heard this day at 330 University Avenue, Toronto, Ontario.
ON READING the Motion Record and Factum of the Plaintiff dated August 8, 2018, the
Supplemental Motion Record of the Plaintiff dated August 17, 2018, the Second Supplemental
Motion Record of the Plaintiff dated September 5, 2018, and the Motion Record for a Receiver,
the Factum and Book of Authorities of the Plaintiff dated September 10, 2018, and the Orders of
23451639.11
Court File No. CV- I 8-602745-00-CL
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
THE HONOURABLE MR. TUESDAY, THE 11TH DAY
JUSTICE DUNPHY OF SEPTEMBER, 2018
ASTRAZENECA CANADA INC. Plaintiff
- and -
SAMEH SADEK also known as SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL
CLINIC INC., SRX INVESTMENT INC., SHEPHERD RX PHARMACY INC. and LILIAN FAM
Defendants
ORDER (appointing Receiver)
THIS MOTION made ex parte by Astrazeneca Canada Inc. (the "Plaintiff') for an Order
pursuant to section 101 of the Courts of Justice Act, R.S.O. 1990, c. C.43, as amended (the
"CJA") appointing Alvarez & Marsal Canada Inc. ("A&M") as receiver (in such capacity, the
"Receiver"), without security, of all of the domestic assets, undertakings and properties of
Sameh Sadek also known as Sam Sadek, St. Maharial Pharmacy Inc. dba MD Health Pharmacy,
St. Maharial Clinic Inc., SRX Investment Inc., Shepherd RX Pharmacy Inc. and Lilian Fam
(collectively, the "Defendants" and, individually, a "Defendant"), and for related relief, was
heard this day at 330 University Avenue, Toronto, Ontario.
ON READING the Motion Record and Factum of the Plaintiff dated August 8, 2018, the
Supplemental Motion Record of the Plaintiff dated August 17, 2018, the Second Supplemental
Motion Record of the Plaintiff dated September 5, 2018, and the Motion Record for a Receiver,
the Factum and Book of Authorities of the Plaintiff dated September 10, 2018, and the Orders of
23451639.11
414 2
the Honourable Justice Dunphy dated August 9, 2018 (the "August 9 Order"), August 17, 2018
(the "August 17 Order") and September 5, 2018 (the "September Order" and, together with
the August 9 Order and the August 17 Order, the "Mareva Orders"), and on hearing the
submissions of counsel for the Plaintiff, and on reading the consent of A&M to act as the
Receiver,
APPOINTMENT
1. THIS COURT ORDERS that, pursuant to section 101 of the CJA, A&M is hereby
appointed Receiver, without security, of all of the assets, undertakings and properties of the
Defendants, including all proceeds thereof to the extent that such assets, undertakings and
properties are located in Canada (the "Domestic Property"). Without limiting the generality of
the foregoing, the Domestic Property includes all of the right, title and interest of the Defendants
in and to the real property with the following legal descriptions:
PIN 14360 - 1750 (LT) Interest/Estate Fee Simple
Description PART OF LOT 11, PLAN 43M1663, DES PART 6, PL 43R30324; MISSISSAUGA. S/T EASEMENT FOR ENTRY AS IN PR806741. S/T EASEMENT FOR ENTRY AS IN PR1007490.
Address 5045 CHURCHILL MEADOWS BOULEVARD MISSISSAUGA, ONTARIO, L5M 7Z8
PIN 13439 - 0416 (LT) Interest/Estate Fee Simple
Description PT LT 26, PL 396, DES PART 1, 43R29866; MISSISSAUGA. S/T EASEMENT OVER PT LT 26, PL 396, DES PART 1, 43R29866, AS IN PR1037379.
Address 2334 HAMMOND ROAD MISSISSAUGA, ONTARIO, L5K 1T2
RECEIVER'S POWERS
2. THIS COURT ORDERS that the Receiver is hereby empowered and authorized, but not
obligated, to act at once in respect of the Domestic Property and, without in any way limiting the
generality of the foregoing, the Receiver is hereby expressly empowered and authorized to do
any of the following where the Receiver considers it necessary or desirable:
23451639.11
414 2
the Honourable Justice Dunphy dated August 9, 2018 (the "August 9 Order"), August 17, 2018
(the "August 17 Order") and September 5, 2018 (the "September Order" and, together with
the August 9 Order and the August 17 Order, the "Mareva Orders"), and on hearing the
submissions of counsel for the Plaintiff, and on reading the consent of A&M to act as the
Receiver,
APPOINTMENT
1. THIS COURT ORDERS that, pursuant to section 101 of the CJA, A&M is hereby
appointed Receiver, without security, of all of the assets, undertakings and properties of the
Defendants, including all proceeds thereof to the extent that such assets, undertakings and
properties are located in Canada (the "Domestic Property"). Without limiting the generality of
the foregoing, the Domestic Property includes all of the right, title and interest of the Defendants
in and to the real property with the following legal descriptions:
PIN 14360 - 1750 (LT) Interest/Estate Fee Simple
Description PART OF LOT 11, PLAN 43M1663, DES PART 6, PL 43R30324; MISSISSAUGA. S/T EASEMENT FOR ENTRY AS IN PR806741. S/T EASEMENT FOR ENTRY AS IN PR1007490.
Address 5045 CHURCHILL MEADOWS BOULEVARD MISSISSAUGA, ONTARIO, L5M 7Z8
PIN 13439 - 0416 (LT) Interest/Estate Fee Simple
Description PT LT 26, PL 396, DES PART 1, 43R29866; MISSISSAUGA. S/T EASEMENT OVER PT LT 26, PL 396, DES PART 1, 43R29866, AS IN PR1037379.
Address 2334 HAMMOND ROAD MISSISSAUGA, ONTARIO, L5K 1T2
RECEIVER'S POWERS
2. THIS COURT ORDERS that the Receiver is hereby empowered and authorized, but not
obligated, to act at once in respect of the Domestic Property and, without in any way limiting the
generality of the foregoing, the Receiver is hereby expressly empowered and authorized to do
any of the following where the Receiver considers it necessary or desirable:
23451639.11
414 2
the Honourable Justice Dunphy dated August 9, 2018 (the "August 9 Order"), August 17, 2018
(the "August 17 Order") and September 5, 2018 (the "September Order" and, together with
the August 9 Order and the August 17 Order, the "Mareva Orders"), and on hearing the
submissions of counsel for the Plaintiff, and on reading the consent of A&M to act as the
Receiver,
APPOINTMENT
1. THIS COURT ORDERS that, pursuant to section 101 of the CJA, A&M is hereby
appointed Receiver, without security, of all of the assets, undertakings and properties of the
Defendants, including all proceeds thereof to the extent that such assets, undertakings and
properties are located in Canada (the "Domestic Property"). Without limiting the generality of
the foregoing, the Domestic Property includes all of the right, title and interest of the Defendants
in and to the real property with the following legal descriptions:
PIN 14360 - 1750 (LT) Interest/Estate Fee Simple
Description PART OF LOT 11, PLAN 43M1663, DES PART 6, PL 43R30324; MISSISSAUGA. S/T EASEMENT FOR ENTRY AS IN PR806741. S/T EASEMENT FOR ENTRY AS IN PR1007490.
Address 5045 CHURCHILL MEADOWS BOULEVARD MISSISSAUGA, ONTARIO, L5M 7Z8
PIN 13439 - 0416 (LT) Interest/Estate Fee Simple
Description PT LT 26, PL 396, DES PART 1, 43R29866; MISSISSAUGA. S/T EASEMENT OVER PT LT 26, PL 396, DES PART 1, 43R29866, AS IN PR1037379.
Address 2334 HAMMOND ROAD MISSISSAUGA, ONTARIO, L5K 1T2
RECEIVER'S POWERS
2. THIS COURT ORDERS that the Receiver is hereby empowered and authorized, but not
obligated, to act at once in respect of the Domestic Property and, without in any way limiting the
generality of the foregoing, the Receiver is hereby expressly empowered and authorized to do
any of the following where the Receiver considers it necessary or desirable:
23451639.11
3
(a) to take possession of and exercise control over the Domestic Property and any and
all proceeds, receipts and disbursements arising out of or from the Domestic
Property, but, for greater certainty, excluding any business and/or operations
carried on by any of the Defendants;
(b) to receive, preserve, and protect the Domestic Property, or any part or parts
thereof, including, but not limited to, the changing of locks and security codes, the
relocating of Domestic Property to safeguard it, the engaging of independent
security personnel, the taking of physical inventories and the placement of such
insurance coverage as may be necessary or desirable;
(c) to identify and segregate any Domestic Property that in the Receiver's reasonable
judgment constitutes property that: (a) is exempt from forced seizure or sale
pursuant to the Execution Act, R.S.O. 1990, c. E-24 (the "Execution Act"); or (b)
constitutes "consumer goods", as that term is defined in the Personal Property
Security Act, R.S.O. 1990, c. P.10 (the "PPSA"), and in the case of property so
segregated, to hold such property pending further order of this Court;
(d) to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
(e) to engage consultants, appraisers, agents, experts, auditors, accountants,
managers, insurance brokers, realtors, counsel and such other persons from time
to time and on whatever basis, including on a temporary basis, to assist with the
exercise of the Receiver's powers and duties, including without limitation those
conferred by this Order;
(f) to receive and collect all monies and accounts now owed or hereafter owing to the
Defendants and to exercise all remedies of the Defendants in collecting such
monies, including, without limitation, to enforce any security held by any
Defendant;
(g) to settle, extend or compromise any indebtedness owing to any Defendant;
23451639.11
3
(a) to take possession of and exercise control over the Domestic Property and any and
all proceeds, receipts and disbursements arising out of or from the Domestic
Property, but, for greater certainty, excluding any business and/or operations
carried on by any of the Defendants;
(b) to receive, preserve, and protect the Domestic Property, or any part or parts
thereof, including, but not limited to, the changing of locks and security codes, the
relocating of Domestic Property to safeguard it, the engaging of independent
security personnel, the taking of physical inventories and the placement of such
insurance coverage as may be necessary or desirable;
(c) to identify and segregate any Domestic Property that in the Receiver's reasonable
judgment constitutes property that: (a) is exempt from forced seizure or sale
pursuant to the Execution Act, R.S.O. 1990, c. E-24 (the "Execution Act"); or (b)
constitutes "consumer goods", as that term is defined in the Personal Property
Security Act, R.S.O. 1990, c. P.10 (the "PPSA"), and in the case of property so
segregated, to hold such property pending further order of this Court;
(d) to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
(e) to engage consultants, appraisers, agents, experts, auditors, accountants,
managers, insurance brokers, realtors, counsel and such other persons from time
to time and on whatever basis, including on a temporary basis, to assist with the
exercise of the Receiver's powers and duties, including without limitation those
conferred by this Order;
(f) to receive and collect all monies and accounts now owed or hereafter owing to the
Defendants and to exercise all remedies of the Defendants in collecting such
monies, including, without limitation, to enforce any security held by any
Defendant;
(g) to settle, extend or compromise any indebtedness owing to any Defendant;
23451639.11
3
(a) to take possession of and exercise control over the Domestic Property and any and
all proceeds, receipts and disbursements arising out of or from the Domestic
Property, but, for greater certainty, excluding any business and/or operations
carried on by any of the Defendants;
(b) to receive, preserve, and protect the Domestic Property, or any part or parts
thereof, including, but not limited to, the changing of locks and security codes, the
relocating of Domestic Property to safeguard it, the engaging of independent
security personnel, the taking of physical inventories and the placement of such
insurance coverage as may be necessary or desirable;
(c) to identify and segregate any Domestic Property that in the Receiver's reasonable
judgment constitutes property that: (a) is exempt from forced seizure or sale
pursuant to the Execution Act, R.S.O. 1990, c. E-24 (the "Execution Act"); or (b)
constitutes "consumer goods", as that term is defined in the Personal Property
Security Act, R.S.O. 1990, c. P.10 (the "PPSA"), and in the case of property so
segregated, to hold such property pending further order of this Court;
(d) to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
(e) to engage consultants, appraisers, agents, experts, auditors, accountants,
managers, insurance brokers, realtors, counsel and such other persons from time
to time and on whatever basis, including on a temporary basis, to assist with the
exercise of the Receiver's powers and duties, including without limitation those
conferred by this Order;
(f) to receive and collect all monies and accounts now owed or hereafter owing to the
Defendants and to exercise all remedies of the Defendants in collecting such
monies, including, without limitation, to enforce any security held by any
Defendant;
(g) to settle, extend or compromise any indebtedness owing to any Defendant;
23451639.11
-4
(h) to execute, assign, issue and endorse documents of whatever nature in respect of
any of the Domestic Property, whether in the Receiver's name or in the name and
on behalf of any Defendant, for any purpose pursuant to this Order;
(i) to initiate, prosecute and continue the prosecution of any and all proceedings and
to defend all proceedings now pending or hereafter instituted with respect to any
Defendant, the Domestic Property or the Receiver, and to settle or compromise
any such proceedings. The authority hereby conveyed shall extend to such appeals
or applications for judicial review in respect of any order or judgment pronounced
in any such proceeding;
(j) to undertake any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to have
been, Domestic Property, including, without limitation, the transfer of any funds
of the Defendants to any related or unrelated parties;
(k) subject to any applicable exemption under the Execution Act or the PPSA to
which the individual Defendants are entitled, to market any or all of the Domestic
Property, including advertising and soliciting offers in respect of the Domestic
Property or any part or parts thereof and negotiating such terms and conditions of
sale as the Receiver in its discretion may deem appropriate;
(1) subject to any applicable exemption under the Execution Act or the PPSA to
which the individual Defendants are entitled, to sell, convey, transfer, lease or
assign the Domestic Property or any part or parts thereof out of the ordinary
course of business;
(i) without the approval of this Court in respect of any transaction not
exceeding $250,000, provided that the aggregate consideration for all such
transactions does not exceed $500,000; and
(ii) with the approval of this Court in respect of any transaction in which the
purchase price or the aggregate purchase price exceeds the applicable
amount set out in the preceding clause,
23451639.11
-4
(h) to execute, assign, issue and endorse documents of whatever nature in respect of
any of the Domestic Property, whether in the Receiver's name or in the name and
on behalf of any Defendant, for any purpose pursuant to this Order;
(i) to initiate, prosecute and continue the prosecution of any and all proceedings and
to defend all proceedings now pending or hereafter instituted with respect to any
Defendant, the Domestic Property or the Receiver, and to settle or compromise
any such proceedings. The authority hereby conveyed shall extend to such appeals
or applications for judicial review in respect of any order or judgment pronounced
in any such proceeding;
(j) to undertake any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to have
been, Domestic Property, including, without limitation, the transfer of any funds
of the Defendants to any related or unrelated parties;
(k) subject to any applicable exemption under the Execution Act or the PPSA to
which the individual Defendants are entitled, to market any or all of the Domestic
Property, including advertising and soliciting offers in respect of the Domestic
Property or any part or parts thereof and negotiating such terms and conditions of
sale as the Receiver in its discretion may deem appropriate;
(1) subject to any applicable exemption under the Execution Act or the PPSA to
which the individual Defendants are entitled, to sell, convey, transfer, lease or
assign the Domestic Property or any part or parts thereof out of the ordinary
course of business;
(i) without the approval of this Court in respect of any transaction not
exceeding $250,000, provided that the aggregate consideration for all such
transactions does not exceed $500,000; and
(ii) with the approval of this Court in respect of any transaction in which the
purchase price or the aggregate purchase price exceeds the applicable
amount set out in the preceding clause,
23451639.11
-4
(h) to execute, assign, issue and endorse documents of whatever nature in respect of
any of the Domestic Property, whether in the Receiver's name or in the name and
on behalf of any Defendant, for any purpose pursuant to this Order;
(i) to initiate, prosecute and continue the prosecution of any and all proceedings and
to defend all proceedings now pending or hereafter instituted with respect to any
Defendant, the Domestic Property or the Receiver, and to settle or compromise
any such proceedings. The authority hereby conveyed shall extend to such appeals
or applications for judicial review in respect of any order or judgment pronounced
in any such proceeding;
(j) to undertake any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to have
been, Domestic Property, including, without limitation, the transfer of any funds
of the Defendants to any related or unrelated parties;
(k) subject to any applicable exemption under the Execution Act or the PPSA to
which the individual Defendants are entitled, to market any or all of the Domestic
Property, including advertising and soliciting offers in respect of the Domestic
Property or any part or parts thereof and negotiating such terms and conditions of
sale as the Receiver in its discretion may deem appropriate;
(1) subject to any applicable exemption under the Execution Act or the PPSA to
which the individual Defendants are entitled, to sell, convey, transfer, lease or
assign the Domestic Property or any part or parts thereof out of the ordinary
course of business;
(i) without the approval of this Court in respect of any transaction not
exceeding $250,000, provided that the aggregate consideration for all such
transactions does not exceed $500,000; and
(ii) with the approval of this Court in respect of any transaction in which the
purchase price or the aggregate purchase price exceeds the applicable
amount set out in the preceding clause,
23451639.11
-5 449-
and in each such case notice under subsection 63(4) of the PPSA, or section 31 of
the Ontario Mortgages Act, as the case may be, shall not be required;
(m) to apply for any vesting order or other orders necessary to convey the Domestic
Property or any part or parts thereof to a purchaser or purchasers thereof, free and
clear of any liens or encumbrances affecting such Domestic Property;
(n) to report to, meet with and discuss with such affected Persons (as defined below)
as the Receiver deems appropriate on all matters relating to the Domestic Property
and the receivership, and to share information; subject in all cases to such terms
as to confidentiality as the Receiver deems advisable;
(o) to make inquiries of any recipient financial institution in respect of any and all
funds transferred by any of the Defendants to any related or unrelated parties,
including, but not limited to, the circumstances in which such transfer was
prepared, issued or effected;
(p) to register a copy of this Order and any other Orders in respect of the Domestic
Property against title to any of the Domestic Property;
(q) to apply for any permits, licences, approvals or permissions as may be required by
any governmental authority and any renewals thereof for and on behalf of and, if
thought desirable by the Receiver, in the name of any Defendant;
(r) to enter into agreements with any trustee in bankruptcy appointed in respect of
any Defendant, including, without limiting the generality of the foregoing, the
ability to enter into occupation agreements for any property owned or leased by
any Defendant;
(s) to exercise any shareholder, partnership, joint venture or other rights which any
Defendant may have; and
(t) to take any steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations, including opening any mail addressed to
any Defendant,
23451639.11
-5 449-
and in each such case notice under subsection 63(4) of the PPSA, or section 31 of
the Ontario Mortgages Act, as the case may be, shall not be required;
(m) to apply for any vesting order or other orders necessary to convey the Domestic
Property or any part or parts thereof to a purchaser or purchasers thereof, free and
clear of any liens or encumbrances affecting such Domestic Property;
(n) to report to, meet with and discuss with such affected Persons (as defined below)
as the Receiver deems appropriate on all matters relating to the Domestic Property
and the receivership, and to share information; subject in all cases to such terms
as to confidentiality as the Receiver deems advisable;
(o) to make inquiries of any recipient financial institution in respect of any and all
funds transferred by any of the Defendants to any related or unrelated parties,
including, but not limited to, the circumstances in which such transfer was
prepared, issued or effected;
(p) to register a copy of this Order and any other Orders in respect of the Domestic
Property against title to any of the Domestic Property;
(q) to apply for any permits, licences, approvals or permissions as may be required by
any governmental authority and any renewals thereof for and on behalf of and, if
thought desirable by the Receiver, in the name of any Defendant;
(r) to enter into agreements with any trustee in bankruptcy appointed in respect of
any Defendant, including, without limiting the generality of the foregoing, the
ability to enter into occupation agreements for any property owned or leased by
any Defendant;
(s) to exercise any shareholder, partnership, joint venture or other rights which any
Defendant may have; and
(t) to take any steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations, including opening any mail addressed to
any Defendant,
23451639.11
-5 449-
and in each such case notice under subsection 63(4) of the PPSA, or section 31 of
the Ontario Mortgages Act, as the case may be, shall not be required;
(m) to apply for any vesting order or other orders necessary to convey the Domestic
Property or any part or parts thereof to a purchaser or purchasers thereof, free and
clear of any liens or encumbrances affecting such Domestic Property;
(n) to report to, meet with and discuss with such affected Persons (as defined below)
as the Receiver deems appropriate on all matters relating to the Domestic Property
and the receivership, and to share information; subject in all cases to such terms
as to confidentiality as the Receiver deems advisable;
(o) to make inquiries of any recipient financial institution in respect of any and all
funds transferred by any of the Defendants to any related or unrelated parties,
including, but not limited to, the circumstances in which such transfer was
prepared, issued or effected;
(p) to register a copy of this Order and any other Orders in respect of the Domestic
Property against title to any of the Domestic Property;
(q) to apply for any permits, licences, approvals or permissions as may be required by
any governmental authority and any renewals thereof for and on behalf of and, if
thought desirable by the Receiver, in the name of any Defendant;
(r) to enter into agreements with any trustee in bankruptcy appointed in respect of
any Defendant, including, without limiting the generality of the foregoing, the
ability to enter into occupation agreements for any property owned or leased by
any Defendant;
(s) to exercise any shareholder, partnership, joint venture or other rights which any
Defendant may have; and
(t) to take any steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations, including opening any mail addressed to
any Defendant,
23451639.11
-6
and in each case where the Receiver takes any such actions or steps, it shall be exclusively
authorized and empowered to do so, to the exclusion of all other Persons (as defined below),
including the Defendants, and without interference from any other Person.
3. THIS COURT ORDERS that the Receiver is hereby empowered and authorized, but not
obligated, to act at once in respect of all of the assets, undertakings and properties of the
Defendants, including all proceeds thereof to the extent that such assets, undertakings and
properties are located outside of Canada (the "Foreign Property", and together with the
Domestic Property, the "Property") and, without in any way limiting the generality of the
foregoing, the Receiver is hereby expressly empowered and authorized to do any of the
following where the Receiver considers it necessary or desirable:
(a) to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
(b) to undertake any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to have
been, Foreign Property, including, without limitation, the transfer of any funds of
the Defendants to any related or unrelated parties;
(c) to report to, meet with and discuss with such affected Persons (as defined below)
as the Receiver deems appropriate on all matters relating to the Foreign Property
and the receivership, and to share information, subject in all cases to such terms as
to confidentiality as the Receiver deems advisable; and
(d) to take any steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations, including opening any mail addressed to
any Defendant.
DUTY TO PROVIDE ACCESS AND CO-OPERATION TO THE RECEIVER
4. THIS COURT ORDERS that (i) the Defendants, (ii) all of their current and former
directors, officers, employees, agents, accountants, legal counsel and shareholders (as
23451639,11
-6
and in each case where the Receiver takes any such actions or steps, it shall be exclusively
authorized and empowered to do so, to the exclusion of all other Persons (as defined below),
including the Defendants, and without interference from any other Person.
3. THIS COURT ORDERS that the Receiver is hereby empowered and authorized, but not
obligated, to act at once in respect of all of the assets, undertakings and properties of the
Defendants, including all proceeds thereof to the extent that such assets, undertakings and
properties are located outside of Canada (the "Foreign Property", and together with the
Domestic Property, the "Property") and, without in any way limiting the generality of the
foregoing, the Receiver is hereby expressly empowered and authorized to do any of the
following where the Receiver considers it necessary or desirable:
(a) to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
(b) to undertake any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to have
been, Foreign Property, including, without limitation, the transfer of any funds of
the Defendants to any related or unrelated parties;
(c) to report to, meet with and discuss with such affected Persons (as defined below)
as the Receiver deems appropriate on all matters relating to the Foreign Property
and the receivership, and to share information, subject in all cases to such terms as
to confidentiality as the Receiver deems advisable; and
(d) to take any steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations, including opening any mail addressed to
any Defendant.
DUTY TO PROVIDE ACCESS AND CO-OPERATION TO THE RECEIVER
4. THIS COURT ORDERS that (i) the Defendants, (ii) all of their current and former
directors, officers, employees, agents, accountants, legal counsel and shareholders (as
23451639,11
-6
and in each case where the Receiver takes any such actions or steps, it shall be exclusively
authorized and empowered to do so, to the exclusion of all other Persons (as defined below),
including the Defendants, and without interference from any other Person.
3. THIS COURT ORDERS that the Receiver is hereby empowered and authorized, but not
obligated, to act at once in respect of all of the assets, undertakings and properties of the
Defendants, including all proceeds thereof to the extent that such assets, undertakings and
properties are located outside of Canada (the "Foreign Property", and together with the
Domestic Property, the "Property") and, without in any way limiting the generality of the
foregoing, the Receiver is hereby expressly empowered and authorized to do any of the
following where the Receiver considers it necessary or desirable:
(a) to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
(b) to undertake any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to have
been, Foreign Property, including, without limitation, the transfer of any funds of
the Defendants to any related or unrelated parties;
(c) to report to, meet with and discuss with such affected Persons (as defined below)
as the Receiver deems appropriate on all matters relating to the Foreign Property
and the receivership, and to share information, subject in all cases to such terms as
to confidentiality as the Receiver deems advisable; and
(d) to take any steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations, including opening any mail addressed to
any Defendant.
DUTY TO PROVIDE ACCESS AND CO-OPERATION TO THE RECEIVER
4. THIS COURT ORDERS that (i) the Defendants, (ii) all of their current and former
directors, officers, employees, agents, accountants, legal counsel and shareholders (as
23451639,11
7
applicable), and all other persons acting on their instructions or behalf, and (iii) all other
individuals, firms, corporations, governmental bodies or agencies, or other entities having notice
of this Order, including, without limitation, any brokers, banks, credit card processors, creditors,
financial institutions, or suppliers (all of the foregoing, collectively, being "Persons" and each
being a "Person") shall forthwith advise the Receiver of the existence of any Property in such
Person's possession or control, shall grant immediate and continued access to the Domestic
Property to the Receiver, and shall deliver all such Domestic Property to the Receiver upon the
Receiver's request.
5. THIS COURT ORDERS that all Persons shall forthwith advise the Receiver of the
existence of any client records and prescription information, books, documents, securities,
contracts, orders, corporate and accounting records, and any other papers, records and
information of any kind related to the business or affairs of the Defendants, any transfers of
money or Property, or obligations incurred by the Defendants, out of the ordinary course of
business or personal conduct and any computer programs, computer tapes, computer disks, or
other data storage media containing any such information (the foregoing, collectively, the
"Records") in that Person's possession or control, and shall provide to the Receiver or permit the
Receiver to make, retain and take away copies thereof and grant to the Receiver unfettered
access to and use of accounting, computer, software and physical facilities relating thereto,
provided however that nothing in this paragraph 5 or in paragraph 6 of this Order shall require
the delivery of Records, or the granting of access to Records, which may not be disclosed or
provided to the Receiver due to the privilege attaching to solicitor-client communication or due
to statutory provisions prohibiting such disclosure.
6. THIS COURT ORDERS that if any Records are stored or otherwise contained on a
computer or other electronic system of infollnation storage, whether by independent service
provider or otherwise, all Persons in possession or control of such Records shall forthwith give
unfettered access to the Receiver for the purpose of allowing the Receiver to recover and fully
copy all of the information contained therein whether by way of printing the information onto
paper or making copies of computer disks or such other manner of retrieving and copying the
information as the Receiver in its discretion deems expedient, and shall not alter, erase or destroy
any Records without the prior written consent of the Receiver. Further, for the purposes of this
23451639.11
7
applicable), and all other persons acting on their instructions or behalf, and (iii) all other
individuals, firms, corporations, governmental bodies or agencies, or other entities having notice
of this Order, including, without limitation, any brokers, banks, credit card processors, creditors,
financial institutions, or suppliers (all of the foregoing, collectively, being "Persons" and each
being a "Person") shall forthwith advise the Receiver of the existence of any Property in such
Person's possession or control, shall grant immediate and continued access to the Domestic
Property to the Receiver, and shall deliver all such Domestic Property to the Receiver upon the
Receiver's request.
5. THIS COURT ORDERS that all Persons shall forthwith advise the Receiver of the
existence of any client records and prescription information, books, documents, securities,
contracts, orders, corporate and accounting records, and any other papers, records and
information of any kind related to the business or affairs of the Defendants, any transfers of
money or Property, or obligations incurred by the Defendants, out of the ordinary course of
business or personal conduct and any computer programs, computer tapes, computer disks, or
other data storage media containing any such information (the foregoing, collectively, the
"Records") in that Person's possession or control, and shall provide to the Receiver or permit the
Receiver to make, retain and take away copies thereof and grant to the Receiver unfettered
access to and use of accounting, computer, software and physical facilities relating thereto,
provided however that nothing in this paragraph 5 or in paragraph 6 of this Order shall require
the delivery of Records, or the granting of access to Records, which may not be disclosed or
provided to the Receiver due to the privilege attaching to solicitor-client communication or due
to statutory provisions prohibiting such disclosure.
6. THIS COURT ORDERS that if any Records are stored or otherwise contained on a
computer or other electronic system of infollnation storage, whether by independent service
provider or otherwise, all Persons in possession or control of such Records shall forthwith give
unfettered access to the Receiver for the purpose of allowing the Receiver to recover and fully
copy all of the information contained therein whether by way of printing the information onto
paper or making copies of computer disks or such other manner of retrieving and copying the
information as the Receiver in its discretion deems expedient, and shall not alter, erase or destroy
any Records without the prior written consent of the Receiver. Further, for the purposes of this
23451639.11
7
applicable), and all other persons acting on their instructions or behalf, and (iii) all other
individuals, firms, corporations, governmental bodies or agencies, or other entities having notice
of this Order, including, without limitation, any brokers, banks, credit card processors, creditors,
financial institutions, or suppliers (all of the foregoing, collectively, being "Persons" and each
being a "Person") shall forthwith advise the Receiver of the existence of any Property in such
Person's possession or control, shall grant immediate and continued access to the Domestic
Property to the Receiver, and shall deliver all such Domestic Property to the Receiver upon the
Receiver's request.
5. THIS COURT ORDERS that all Persons shall forthwith advise the Receiver of the
existence of any client records and prescription information, books, documents, securities,
contracts, orders, corporate and accounting records, and any other papers, records and
information of any kind related to the business or affairs of the Defendants, any transfers of
money or Property, or obligations incurred by the Defendants, out of the ordinary course of
business or personal conduct and any computer programs, computer tapes, computer disks, or
other data storage media containing any such information (the foregoing, collectively, the
"Records") in that Person's possession or control, and shall provide to the Receiver or permit the
Receiver to make, retain and take away copies thereof and grant to the Receiver unfettered
access to and use of accounting, computer, software and physical facilities relating thereto,
provided however that nothing in this paragraph 5 or in paragraph 6 of this Order shall require
the delivery of Records, or the granting of access to Records, which may not be disclosed or
provided to the Receiver due to the privilege attaching to solicitor-client communication or due
to statutory provisions prohibiting such disclosure.
6. THIS COURT ORDERS that if any Records are stored or otherwise contained on a
computer or other electronic system of infollnation storage, whether by independent service
provider or otherwise, all Persons in possession or control of such Records shall forthwith give
unfettered access to the Receiver for the purpose of allowing the Receiver to recover and fully
copy all of the information contained therein whether by way of printing the information onto
paper or making copies of computer disks or such other manner of retrieving and copying the
information as the Receiver in its discretion deems expedient, and shall not alter, erase or destroy
any Records without the prior written consent of the Receiver. Further, for the purposes of this
23451639.11
8
paragraph, all Persons shall provide the Receiver with all such assistance in gaining immediate
access to the information in the Records as the Receiver may in its discretion require including
providing the Receiver with instructions on the use of any computer or other system and
providing the Receiver with any and all access codes, account names and account numbers that
may be required to gain access to the information.
6A. THIS COURT ORDERS that, in respect to the Records subject to the Regulated Health
Professions Act, 1991, the Pharmacy Act, 1991, the Drug and Pharmacies Regulation Act, 1990
or any other applicable governing Ontario or Canadian statute (collectively, the "Pharmacy
Regulations"), the Receiver shall: (i) take all steps reasonably necessary to maintain the integrity
of the confidential aspect of such Records; (ii) to the extent possible, provide such Records to the
Ontario College of Pharmacists ("College") or any pharmacy to which the College directs the
Receiver to provide such Records; (iii) if necessary, appoint a pharmacist licensed and qualified
to practice in the Province of Ontario to act as custodian (the "Custodian") for such Records;
(iv) not allow anyone other than the Receiver, the College, a pharmacy designated by the College
or the Custodian to have access to such Records; (iv) have access to such Records for any
purposes required pursuant to the Pharmacy Regulations that requires the Defendants, from time
to time, to perform certain obligations.
7. THIS COURT ORDERS that the Receiver shall provide each of the relevant landlords
with notice of the Receiver's intention to remove any fixtures from any leased premises at least
seven (7) days prior to the date of the intended removal. The relevant landlord shall be entitled
to have a representative present in the leased premises to observe such removal and, if the
landlord disputes the Receiver's entitlement to remove any such fixture under the provisions of
the lease, such fixture shall remain on the premises and shall be dealt with as agreed between any
applicable secured creditors, such landlord and the Receiver, or by further Order of this Court
upon application by the Receiver on at least two (2) days notice to such landlord and any such
secured creditors.
23451639.11
8
paragraph, all Persons shall provide the Receiver with all such assistance in gaining immediate
access to the information in the Records as the Receiver may in its discretion require including
providing the Receiver with instructions on the use of any computer or other system and
providing the Receiver with any and all access codes, account names and account numbers that
may be required to gain access to the information.
6A. THIS COURT ORDERS that, in respect to the Records subject to the Regulated Health
Professions Act, 1991, the Pharmacy Act, 1991, the Drug and Pharmacies Regulation Act, 1990
or any other applicable governing Ontario or Canadian statute (collectively, the "Pharmacy
Regulations"), the Receiver shall: (i) take all steps reasonably necessary to maintain the integrity
of the confidential aspect of such Records; (ii) to the extent possible, provide such Records to the
Ontario College of Pharmacists ("College") or any pharmacy to which the College directs the
Receiver to provide such Records; (iii) if necessary, appoint a pharmacist licensed and qualified
to practice in the Province of Ontario to act as custodian (the "Custodian") for such Records;
(iv) not allow anyone other than the Receiver, the College, a pharmacy designated by the College
or the Custodian to have access to such Records; (iv) have access to such Records for any
purposes required pursuant to the Pharmacy Regulations that requires the Defendants, from time
to time, to perform certain obligations.
7. THIS COURT ORDERS that the Receiver shall provide each of the relevant landlords
with notice of the Receiver's intention to remove any fixtures from any leased premises at least
seven (7) days prior to the date of the intended removal. The relevant landlord shall be entitled
to have a representative present in the leased premises to observe such removal and, if the
landlord disputes the Receiver's entitlement to remove any such fixture under the provisions of
the lease, such fixture shall remain on the premises and shall be dealt with as agreed between any
applicable secured creditors, such landlord and the Receiver, or by further Order of this Court
upon application by the Receiver on at least two (2) days notice to such landlord and any such
secured creditors.
23451639.11
8
paragraph, all Persons shall provide the Receiver with all such assistance in gaining immediate
access to the information in the Records as the Receiver may in its discretion require including
providing the Receiver with instructions on the use of any computer or other system and
providing the Receiver with any and all access codes, account names and account numbers that
may be required to gain access to the information.
6A. THIS COURT ORDERS that, in respect to the Records subject to the Regulated Health
Professions Act, 1991, the Pharmacy Act, 1991, the Drug and Pharmacies Regulation Act, 1990
or any other applicable governing Ontario or Canadian statute (collectively, the "Pharmacy
Regulations"), the Receiver shall: (i) take all steps reasonably necessary to maintain the integrity
of the confidential aspect of such Records; (ii) to the extent possible, provide such Records to the
Ontario College of Pharmacists ("College") or any pharmacy to which the College directs the
Receiver to provide such Records; (iii) if necessary, appoint a pharmacist licensed and qualified
to practice in the Province of Ontario to act as custodian (the "Custodian") for such Records;
(iv) not allow anyone other than the Receiver, the College, a pharmacy designated by the College
or the Custodian to have access to such Records; (iv) have access to such Records for any
purposes required pursuant to the Pharmacy Regulations that requires the Defendants, from time
to time, to perform certain obligations.
7. THIS COURT ORDERS that the Receiver shall provide each of the relevant landlords
with notice of the Receiver's intention to remove any fixtures from any leased premises at least
seven (7) days prior to the date of the intended removal. The relevant landlord shall be entitled
to have a representative present in the leased premises to observe such removal and, if the
landlord disputes the Receiver's entitlement to remove any such fixture under the provisions of
the lease, such fixture shall remain on the premises and shall be dealt with as agreed between any
applicable secured creditors, such landlord and the Receiver, or by further Order of this Court
upon application by the Receiver on at least two (2) days notice to such landlord and any such
secured creditors.
23451639.11
9-
NO PROCEEDINGS AGAINST THE RECEIVER
8. THIS COURT ORDERS that no proceeding or enforcement process in any court or
tribunal (each, a "Proceeding"), shall be commenced or continued against the Receiver except
with the written consent of the Receiver or with leave of this Court.
NO PROCEEDINGS AGAINST THE DEFENDANTS OR THE DOMESTIC PROPERTY
9. THIS COURT ORDERS that no Proceeding in Canada (a "Domestic Proceeding")
against or in respect of any of the Defendants or the Domestic Property shall be commenced or
continued except with the written consent of the Receiver or with leave of this Court, and,
subject to paragraph 37 hereof, any and all Domestic Proceedings currently under way against or
in respect of any of the Defendants or the Domestic Property are hereby stayed and suspended
pending further Order of this Court.
NO EXERCISE OF RIGHTS OR REMEDIES
10. THIS COURT ORDERS that all rights and remedies against any Defendant, the
Receiver, or affecting the Domestic Property, are hereby stayed and suspended except with the
written consent of the Receiver or leave of this Court, provided however that this stay and
suspension does not apply in respect of (i) any "eligible financial contract" as defined in the
Bankruptcy and Insolvency Act, R.S.C., 1985, c. B-3 (the "BIA"), or (ii) any rights and remedies
in respect of a Proceeding that is not a Domestic Proceeding, further provided that nothing in this
paragraph shall (a) empower the Receiver or any Defendant to carry on any business which any
Defendant is not lawfully entitled to carry on, (b) exempt the Receiver or any Defendant from
compliance with statutory or regulatory provisions relating to health, safety or the environment,
(c) prevent the filing of any registration to preserve or perfect a security interest, or (d) prevent
the registration of a claim for lien.
NO INTERFERENCE WITH THE RECEIVER
11. THIS COURT ORDERS that no Person shall discontinue, fail to honour, alter, interfere
with, repudiate, terminate or cease to perform any right, renewal right, contract, agreement,
23451639.11
9-
NO PROCEEDINGS AGAINST THE RECEIVER
8. THIS COURT ORDERS that no proceeding or enforcement process in any court or
tribunal (each, a "Proceeding"), shall be commenced or continued against the Receiver except
with the written consent of the Receiver or with leave of this Court.
NO PROCEEDINGS AGAINST THE DEFENDANTS OR THE DOMESTIC PROPERTY
9. THIS COURT ORDERS that no Proceeding in Canada (a "Domestic Proceeding")
against or in respect of any of the Defendants or the Domestic Property shall be commenced or
continued except with the written consent of the Receiver or with leave of this Court, and,
subject to paragraph 37 hereof, any and all Domestic Proceedings currently under way against or
in respect of any of the Defendants or the Domestic Property are hereby stayed and suspended
pending further Order of this Court.
NO EXERCISE OF RIGHTS OR REMEDIES
10. THIS COURT ORDERS that all rights and remedies against any Defendant, the
Receiver, or affecting the Domestic Property, are hereby stayed and suspended except with the
written consent of the Receiver or leave of this Court, provided however that this stay and
suspension does not apply in respect of (i) any "eligible financial contract" as defined in the
Bankruptcy and Insolvency Act, R.S.C., 1985, c. B-3 (the "BIA"), or (ii) any rights and remedies
in respect of a Proceeding that is not a Domestic Proceeding, further provided that nothing in this
paragraph shall (a) empower the Receiver or any Defendant to carry on any business which any
Defendant is not lawfully entitled to carry on, (b) exempt the Receiver or any Defendant from
compliance with statutory or regulatory provisions relating to health, safety or the environment,
(c) prevent the filing of any registration to preserve or perfect a security interest, or (d) prevent
the registration of a claim for lien.
NO INTERFERENCE WITH THE RECEIVER
11. THIS COURT ORDERS that no Person shall discontinue, fail to honour, alter, interfere
with, repudiate, terminate or cease to perform any right, renewal right, contract, agreement,
23451639.11
9-
NO PROCEEDINGS AGAINST THE RECEIVER
8. THIS COURT ORDERS that no proceeding or enforcement process in any court or
tribunal (each, a "Proceeding"), shall be commenced or continued against the Receiver except
with the written consent of the Receiver or with leave of this Court.
NO PROCEEDINGS AGAINST THE DEFENDANTS OR THE DOMESTIC PROPERTY
9. THIS COURT ORDERS that no Proceeding in Canada (a "Domestic Proceeding")
against or in respect of any of the Defendants or the Domestic Property shall be commenced or
continued except with the written consent of the Receiver or with leave of this Court, and,
subject to paragraph 37 hereof, any and all Domestic Proceedings currently under way against or
in respect of any of the Defendants or the Domestic Property are hereby stayed and suspended
pending further Order of this Court.
NO EXERCISE OF RIGHTS OR REMEDIES
10. THIS COURT ORDERS that all rights and remedies against any Defendant, the
Receiver, or affecting the Domestic Property, are hereby stayed and suspended except with the
written consent of the Receiver or leave of this Court, provided however that this stay and
suspension does not apply in respect of (i) any "eligible financial contract" as defined in the
Bankruptcy and Insolvency Act, R.S.C., 1985, c. B-3 (the "BIA"), or (ii) any rights and remedies
in respect of a Proceeding that is not a Domestic Proceeding, further provided that nothing in this
paragraph shall (a) empower the Receiver or any Defendant to carry on any business which any
Defendant is not lawfully entitled to carry on, (b) exempt the Receiver or any Defendant from
compliance with statutory or regulatory provisions relating to health, safety or the environment,
(c) prevent the filing of any registration to preserve or perfect a security interest, or (d) prevent
the registration of a claim for lien.
NO INTERFERENCE WITH THE RECEIVER
11. THIS COURT ORDERS that no Person shall discontinue, fail to honour, alter, interfere
with, repudiate, terminate or cease to perform any right, renewal right, contract, agreement,
23451639.11
id a - 1 0 -
licence or permit in favour of or held by any Defendant, without written consent of the Receiver
or leave of this Court.
CONTINUATION OF SERVICES
12. THIS COURT ORDERS that all Persons having oral or written agreements with any
Defendant or statutory or regulatory mandates for the supply of goods and/or services, including,
without limitation, all computer software, communication and other data services, centralized
banking services, payroll services, insurance, transportation services, utility or other services to
the Defendant are hereby restrained until further Order of this Court from discontinuing, altering,
interfering with or terminating the supply of such goods or services as may be required by the
Receiver, and that the Receiver shall be entitled to the continued use of any Defendant's current
telephone numbers, facsimile numbers, internet addresses and domain names, provided in each
case that the normal prices or charges for all such goods or services received after the date of this
Order are paid by the Receiver in accordance with normal payment practices of such Defendant
or such other practices as may be agreed upon by the supplier or service provider and the
Receiver, or as may be ordered by this Court.
RECEIVER TO HOLD FUNDS
13. THIS COURT ORDERS that all funds, monies, cheques, instruments, and other forms of
payments received or collected by the Receiver from and after the making of this Order from any
source whatsoever, including, without limitation, the sale of all or any of the Domestic Property
and the collection of any accounts receivable in whole or in part, whether in existence on the date
of this Order or hereafter coming into existence, shall be deposited into one or more new
accounts to be opened by the Receiver (the "Post Receivership Accounts") and the monies
standing to the credit of such Post Receivership Accounts from time to time, net of any
disbursements provided for herein, shall be held by the Receiver to be paid in accordance with
the terms of this Order or any further Order of this Court. The Receiver shall segregate any funds
received by it that constitute Foreign Property, and record and keep such Foreign Property
separate and apart from any Domestic Property, pending further Order of this Court.
EMPLOYEES
23451639.11
id a - 1 0 -
licence or permit in favour of or held by any Defendant, without written consent of the Receiver
or leave of this Court.
CONTINUATION OF SERVICES
12. THIS COURT ORDERS that all Persons having oral or written agreements with any
Defendant or statutory or regulatory mandates for the supply of goods and/or services, including,
without limitation, all computer software, communication and other data services, centralized
banking services, payroll services, insurance, transportation services, utility or other services to
the Defendant are hereby restrained until further Order of this Court from discontinuing, altering,
interfering with or terminating the supply of such goods or services as may be required by the
Receiver, and that the Receiver shall be entitled to the continued use of any Defendant's current
telephone numbers, facsimile numbers, internet addresses and domain names, provided in each
case that the normal prices or charges for all such goods or services received after the date of this
Order are paid by the Receiver in accordance with normal payment practices of such Defendant
or such other practices as may be agreed upon by the supplier or service provider and the
Receiver, or as may be ordered by this Court.
RECEIVER TO HOLD FUNDS
13. THIS COURT ORDERS that all funds, monies, cheques, instruments, and other forms of
payments received or collected by the Receiver from and after the making of this Order from any
source whatsoever, including, without limitation, the sale of all or any of the Domestic Property
and the collection of any accounts receivable in whole or in part, whether in existence on the date
of this Order or hereafter coming into existence, shall be deposited into one or more new
accounts to be opened by the Receiver (the "Post Receivership Accounts") and the monies
standing to the credit of such Post Receivership Accounts from time to time, net of any
disbursements provided for herein, shall be held by the Receiver to be paid in accordance with
the terms of this Order or any further Order of this Court. The Receiver shall segregate any funds
received by it that constitute Foreign Property, and record and keep such Foreign Property
separate and apart from any Domestic Property, pending further Order of this Court.
EMPLOYEES
23451639.11
id a - 10 -
licence or permit in favour of or held by any Defendant, without written consent of the Receiver
or leave of this Court.
CONTINUATION OF SERVICES
12. THIS COURT ORDERS that all Persons having oral or written agreements with any
Defendant or statutory or regulatory mandates for the supply of goods and/or services, including,
without limitation, all computer software, communication and other data services, centralized
banking services, payroll services, insurance, transportation services, utility or other services to
the Defendant are hereby restrained until further Order of this Court from discontinuing, altering,
interfering with or terminating the supply of such goods or services as may be required by the
Receiver, and that the Receiver shall be entitled to the continued use of any Defendant's current
telephone numbers, facsimile numbers, internet addresses and domain names, provided in each
case that the normal prices or charges for all such goods or services received after the date of this
Order are paid by the Receiver in accordance with normal payment practices of such Defendant
or such other practices as may be agreed upon by the supplier or service provider and the
Receiver, or as may be ordered by this Court.
RECEIVER TO HOLD FUNDS
13. THIS COURT ORDERS that all funds, monies, cheques, instruments, and other forms of
payments received or collected by the Receiver from and after the making of this Order from any
source whatsoever, including, without limitation, the sale of all or any of the Domestic Property
and the collection of any accounts receivable in whole or in part, whether in existence on the date
of this Order or hereafter coming into existence, shall be deposited into one or more new
accounts to be opened by the Receiver (the "Post Receivership Accounts") and the monies
standing to the credit of such Post Receivership Accounts from time to time, net of any
disbursements provided for herein, shall be held by the Receiver to be paid in accordance with
the terms of this Order or any further Order of this Court. The Receiver shall segregate any funds
received by it that constitute Foreign Property, and record and keep such Foreign Property
separate and apart from any Domestic Property, pending further Order of this Court.
EMPLOYEES
23451639.11
-11- 423
14. THIS COURT ORDERS that all employees of the Defendants, if any, shall remain the
employees of the Defendants until such time as the Receiver, on the Defendants' behalf, may
terminate the employment of such employees. The Receiver shall not be liable for any employee-
related liabilities, including any successor employer liabilities as provided for in section
14.06(1.2) of the BIA, other than such amounts as the Receiver may specifically agree in writing
to pay, or in respect of its obligations under subsections 81.4(5) or 81.6(3) of the BIA or under
the Wage Earner Protection Program Act.
PIPEDA
15. THIS COURT ORDERS that, pursuant to clause 7(3)(c) of the Canada Personal
Information Protection and Electronic Documents Act, the Receiver shall disclose personal
information of identifiable individuals to prospective purchasers or bidders for the Domestic
Property and to their advisors, but only to the extent desirable or required to negotiate and
attempt to complete one or more sales of the Domestic Property (each, a "Sale"). Each
prospective purchaser or bidder to whom such personal information is disclosed shall maintain
and protect the privacy of such infoimation and limit the use of such information to its evaluation
of the Sale, and if it does not complete a Sale, shall return all such information to the Receiver,
or in the alternative destroy all such information. The purchaser of any Domestic Property shall
be entitled to continue to use the personal information provided to it, and related to the Domestic
Property purchased, in a manner which is in all material respects identical to the prior use of such
information by any Defendant, and shall return all other personal information to the Receiver, or
ensure that all other personal information is destroyed.
LIMITATION ON ENVIRONMENTAL LIABILITIES
16. THIS COURT ORDERS that nothing herein contained shall require the Receiver to
occupy or to take control, care, charge, possession or management (separately and/or
collectively, "Possession") of any of the Domestic Property that might be environmentally
contaminated, might be a pollutant or a contaminant, or might cause or contribute to a spill,
discharge, release or deposit of a substance contrary to any federal, provincial or other law
respecting the protection, conservation, enhancement, remediation or rehabilitation of the
environment or relating to the disposal of waste or other contamination including, without
23451639.11
-11- 423
14. THIS COURT ORDERS that all employees of the Defendants, if any, shall remain the
employees of the Defendants until such time as the Receiver, on the Defendants' behalf, may
terminate the employment of such employees. The Receiver shall not be liable for any employee-
related liabilities, including any successor employer liabilities as provided for in section
14.06(1.2) of the BIA, other than such amounts as the Receiver may specifically agree in writing
to pay, or in respect of its obligations under subsections 81.4(5) or 81.6(3) of the BIA or under
the Wage Earner Protection Program Act.
PIPEDA
15. THIS COURT ORDERS that, pursuant to clause 7(3)(c) of the Canada Personal
Information Protection and Electronic Documents Act, the Receiver shall disclose personal
information of identifiable individuals to prospective purchasers or bidders for the Domestic
Property and to their advisors, but only to the extent desirable or required to negotiate and
attempt to complete one or more sales of the Domestic Property (each, a "Sale"). Each
prospective purchaser or bidder to whom such personal information is disclosed shall maintain
and protect the privacy of such infoimation and limit the use of such information to its evaluation
of the Sale, and if it does not complete a Sale, shall return all such information to the Receiver,
or in the alternative destroy all such information. The purchaser of any Domestic Property shall
be entitled to continue to use the personal information provided to it, and related to the Domestic
Property purchased, in a manner which is in all material respects identical to the prior use of such
information by any Defendant, and shall return all other personal information to the Receiver, or
ensure that all other personal information is destroyed.
LIMITATION ON ENVIRONMENTAL LIABILITIES
16. THIS COURT ORDERS that nothing herein contained shall require the Receiver to
occupy or to take control, care, charge, possession or management (separately and/or
collectively, "Possession") of any of the Domestic Property that might be environmentally
contaminated, might be a pollutant or a contaminant, or might cause or contribute to a spill,
discharge, release or deposit of a substance contrary to any federal, provincial or other law
respecting the protection, conservation, enhancement, remediation or rehabilitation of the
environment or relating to the disposal of waste or other contamination including, without
23451639.11
-11- 423
14. THIS COURT ORDERS that all employees of the Defendants, if any, shall remain the
employees of the Defendants until such time as the Receiver, on the Defendants' behalf, may
terminate the employment of such employees. The Receiver shall not be liable for any employee-
related liabilities, including any successor employer liabilities as provided for in section
14.06(1.2) of the BIA, other than such amounts as the Receiver may specifically agree in writing
to pay, or in respect of its obligations under subsections 81.4(5) or 81.6(3) of the BIA or under
the Wage Earner Protection Program Act.
PIPEDA
15. THIS COURT ORDERS that, pursuant to clause 7(3)(c) of the Canada Personal
Information Protection and Electronic Documents Act, the Receiver shall disclose personal
information of identifiable individuals to prospective purchasers or bidders for the Domestic
Property and to their advisors, but only to the extent desirable or required to negotiate and
attempt to complete one or more sales of the Domestic Property (each, a "Sale"). Each
prospective purchaser or bidder to whom such personal information is disclosed shall maintain
and protect the privacy of such infoimation and limit the use of such information to its evaluation
of the Sale, and if it does not complete a Sale, shall return all such information to the Receiver,
or in the alternative destroy all such information. The purchaser of any Domestic Property shall
be entitled to continue to use the personal information provided to it, and related to the Domestic
Property purchased, in a manner which is in all material respects identical to the prior use of such
information by any Defendant, and shall return all other personal information to the Receiver, or
ensure that all other personal information is destroyed.
LIMITATION ON ENVIRONMENTAL LIABILITIES
16. THIS COURT ORDERS that nothing herein contained shall require the Receiver to
occupy or to take control, care, charge, possession or management (separately and/or
collectively, "Possession") of any of the Domestic Property that might be environmentally
contaminated, might be a pollutant or a contaminant, or might cause or contribute to a spill,
discharge, release or deposit of a substance contrary to any federal, provincial or other law
respecting the protection, conservation, enhancement, remediation or rehabilitation of the
environment or relating to the disposal of waste or other contamination including, without
23451639.11
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limitation, the Canadian Environmental Protection Act, the Ontario Environmental Protection
Act, the Ontario Water Resources Act, or the Ontario Occupational Health and Safety Act and
regulations thereunder (the "Environmental Legislation"), provided however that nothing
herein shall exempt the Receiver from any duty to report or make disclosure imposed by
applicable Environmental Legislation. The Receiver shall not, as a result of this Order or
anything done in pursuance of the Receiver's duties and powers under this Order, be deemed to
be in Possession of any of the Domestic Property within the meaning of any Environmental
Legislation, unless it is actually in possession.
LIMITATION ON THE RECEIVER'S LIABILITY
17. THIS COURT ORDERS that the Receiver shall incur no liability or obligation as a result
of its appointment or the carrying out the provisions of this Order, save and except for any gross
negligence or wilful misconduct on its part. Nothing in this Order shall derogate from the
protections afforded the Receiver by section 14.06 of the BIA or by any other applicable
legislation.
RECEIVER'S ACCOUNTS
18. THIS COURT ORDERS that the Receiver and counsel to the Receiver shall be paid their
reasonable fees and disbursements, in each case at their standard rates and charges unless
otherwise ordered by the Court on the passing of accounts, and that the Receiver and counsel to
the Receiver shall be entitled to and are hereby granted a charge (the "Receiver's Charge") on
the Domestic Property, as security for such fees and disbursements, both before and after the
making of this Order in respect of these proceedings, and that the Receiver's Charge shall form a
first charge on the Domestic Property in priority to all security interests, trusts, liens, charges and
encumbrances, statutory or otherwise (collectively, "Encumbrances"), in favour of any Person
other than (a) any validly perfected security interest under the PPSA, or such other applicable
legislation, and (b) statutory super-priority deemed trusts and liens for unpaid employee source
deductions ((a) and (b), collectively, the "Priority Charges").
23451639.11
- 12 -
limitation, the Canadian Environmental Protection Act, the Ontario Environmental Protection
Act, the Ontario Water Resources Act, or the Ontario Occupational Health and Safety Act and
regulations thereunder (the "Environmental Legislation"), provided however that nothing
herein shall exempt the Receiver from any duty to report or make disclosure imposed by
applicable Environmental Legislation. The Receiver shall not, as a result of this Order or
anything done in pursuance of the Receiver's duties and powers under this Order, be deemed to
be in Possession of any of the Domestic Property within the meaning of any Environmental
Legislation, unless it is actually in possession.
LIMITATION ON THE RECEIVER'S LIABILITY
17. THIS COURT ORDERS that the Receiver shall incur no liability or obligation as a result
of its appointment or the carrying out the provisions of this Order, save and except for any gross
negligence or wilful misconduct on its part. Nothing in this Order shall derogate from the
protections afforded the Receiver by section 14.06 of the BIA or by any other applicable
legislation.
RECEIVER'S ACCOUNTS
18. THIS COURT ORDERS that the Receiver and counsel to the Receiver shall be paid their
reasonable fees and disbursements, in each case at their standard rates and charges unless
otherwise ordered by the Court on the passing of accounts, and that the Receiver and counsel to
the Receiver shall be entitled to and are hereby granted a charge (the "Receiver's Charge") on
the Domestic Property, as security for such fees and disbursements, both before and after the
making of this Order in respect of these proceedings, and that the Receiver's Charge shall form a
first charge on the Domestic Property in priority to all security interests, trusts, liens, charges and
encumbrances, statutory or otherwise (collectively, "Encumbrances"), in favour of any Person
other than (a) any validly perfected security interest under the PPSA, or such other applicable
legislation, and (b) statutory super-priority deemed trusts and liens for unpaid employee source
deductions ((a) and (b), collectively, the "Priority Charges").
23451639.11
- 12 -
limitation, the Canadian Environmental Protection Act, the Ontario Environmental Protection
Act, the Ontario Water Resources Act, or the Ontario Occupational Health and Safety Act and
regulations thereunder (the "Environmental Legislation"), provided however that nothing
herein shall exempt the Receiver from any duty to report or make disclosure imposed by
applicable Environmental Legislation. The Receiver shall not, as a result of this Order or
anything done in pursuance of the Receiver's duties and powers under this Order, be deemed to
be in Possession of any of the Domestic Property within the meaning of any Environmental
Legislation, unless it is actually in possession.
LIMITATION ON THE RECEIVER'S LIABILITY
17. THIS COURT ORDERS that the Receiver shall incur no liability or obligation as a result
of its appointment or the carrying out the provisions of this Order, save and except for any gross
negligence or wilful misconduct on its part. Nothing in this Order shall derogate from the
protections afforded the Receiver by section 14.06 of the BIA or by any other applicable
legislation.
RECEIVER'S ACCOUNTS
18. THIS COURT ORDERS that the Receiver and counsel to the Receiver shall be paid their
reasonable fees and disbursements, in each case at their standard rates and charges unless
otherwise ordered by the Court on the passing of accounts, and that the Receiver and counsel to
the Receiver shall be entitled to and are hereby granted a charge (the "Receiver's Charge") on
the Domestic Property, as security for such fees and disbursements, both before and after the
making of this Order in respect of these proceedings, and that the Receiver's Charge shall form a
first charge on the Domestic Property in priority to all security interests, trusts, liens, charges and
encumbrances, statutory or otherwise (collectively, "Encumbrances"), in favour of any Person
other than (a) any validly perfected security interest under the PPSA, or such other applicable
legislation, and (b) statutory super-priority deemed trusts and liens for unpaid employee source
deductions ((a) and (b), collectively, the "Priority Charges").
23451639.11
48C -13-
19. THIS COURT ORDERS that the Receiver and its legal counsel shall pass its accounts
from time to time, and for this purpose the accounts of the Receiver and its legal counsel are
hereby referred to a judge of the Commercial List of the Ontario Superior Court of Justice.
20. THIS COURT ORDERS that prior to the passing of its accounts, the Receiver shall be at
liberty from time to time to apply reasonable amounts, out of the monies in its hands, against its
fees and disbursements, including legal fees and disbursements, incurred at the standard rates
and charges of the Receiver or its counsel, and such amounts shall constitute advances against its
remuneration and disbursements when and as approved by this Court.
FUNDING OF THE RECEIVERSHIP
21. THIS COURT ORDERS that the Receiver be at liberty and it is hereby empowered to
borrow by way of a revolving credit or otherwise, such monies from time to time as it may
consider necessary or desirable, provided that the outstanding principal amount does not exceed
$150,000 (or such greater amount as this Court may by further Order authorize) at any time, at
such rate or rates of interest as it deems advisable for such period or periods of time as it may
arrange, for the purpose of funding the exercise of the powers and duties conferred upon the
Receiver by this Order, including interim expenditures. The whole of the Domestic Property
shall be and is hereby charged by way of a fixed and specific charge (the "Receiver's
Borrowings Charge") as security for the payment of the monies borrowed, together with
interest and charges thereon, in priority to all Encumbrances in favour of any Person, other than
the Priority Charges and the Receiver's Charge.
22. THIS COURT ORDERS that neither the Receiver's Charge, Receiver's Borrowings
Charge nor any other security granted by the Receiver in connection with its borrowings under
this Order shall be enforced without leave of this Court.
23. THIS COURT ORDERS that the Receiver is at liberty and authorized to issue certificates
substantially in the form annexed as Schedule "A" hereto (the "Receiver's Certificates") for any
amount borrowed by it pursuant to this Order.
24. THIS COURT ORDERS that the monies from time to time borrowed by the Receiver
pursuant to this Order or any further order of this Court and any and all Receiver's Certificates
23451639.11
48C -13-
19. THIS COURT ORDERS that the Receiver and its legal counsel shall pass its accounts
from time to time, and for this purpose the accounts of the Receiver and its legal counsel are
hereby referred to a judge of the Commercial List of the Ontario Superior Court of Justice.
20. THIS COURT ORDERS that prior to the passing of its accounts, the Receiver shall be at
liberty from time to time to apply reasonable amounts, out of the monies in its hands, against its
fees and disbursements, including legal fees and disbursements, incurred at the standard rates
and charges of the Receiver or its counsel, and such amounts shall constitute advances against its
remuneration and disbursements when and as approved by this Court.
FUNDING OF THE RECEIVERSHIP
21. THIS COURT ORDERS that the Receiver be at liberty and it is hereby empowered to
borrow by way of a revolving credit or otherwise, such monies from time to time as it may
consider necessary or desirable, provided that the outstanding principal amount does not exceed
$150,000 (or such greater amount as this Court may by further Order authorize) at any time, at
such rate or rates of interest as it deems advisable for such period or periods of time as it may
arrange, for the purpose of funding the exercise of the powers and duties conferred upon the
Receiver by this Order, including interim expenditures. The whole of the Domestic Property
shall be and is hereby charged by way of a fixed and specific charge (the "Receiver's
Borrowings Charge") as security for the payment of the monies borrowed, together with
interest and charges thereon, in priority to all Encumbrances in favour of any Person, other than
the Priority Charges and the Receiver's Charge.
22. THIS COURT ORDERS that neither the Receiver's Charge, Receiver's Borrowings
Charge nor any other security granted by the Receiver in connection with its borrowings under
this Order shall be enforced without leave of this Court.
23. THIS COURT ORDERS that the Receiver is at liberty and authorized to issue certificates
substantially in the form annexed as Schedule "A" hereto (the "Receiver's Certificates") for any
amount borrowed by it pursuant to this Order.
24. THIS COURT ORDERS that the monies from time to time borrowed by the Receiver
pursuant to this Order or any further order of this Court and any and all Receiver's Certificates
23451639.11
48C -13-
19. THIS COURT ORDERS that the Receiver and its legal counsel shall pass its accounts
from time to time, and for this purpose the accounts of the Receiver and its legal counsel are
hereby referred to a judge of the Commercial List of the Ontario Superior Court of Justice.
20. THIS COURT ORDERS that prior to the passing of its accounts, the Receiver shall be at
liberty from time to time to apply reasonable amounts, out of the monies in its hands, against its
fees and disbursements, including legal fees and disbursements, incurred at the standard rates
and charges of the Receiver or its counsel, and such amounts shall constitute advances against its
remuneration and disbursements when and as approved by this Court.
FUNDING OF THE RECEIVERSHIP
21. THIS COURT ORDERS that the Receiver be at liberty and it is hereby empowered to
borrow by way of a revolving credit or otherwise, such monies from time to time as it may
consider necessary or desirable, provided that the outstanding principal amount does not exceed
$150,000 (or such greater amount as this Court may by further Order authorize) at any time, at
such rate or rates of interest as it deems advisable for such period or periods of time as it may
arrange, for the purpose of funding the exercise of the powers and duties conferred upon the
Receiver by this Order, including interim expenditures. The whole of the Domestic Property
shall be and is hereby charged by way of a fixed and specific charge (the "Receiver's
Borrowings Charge") as security for the payment of the monies borrowed, together with
interest and charges thereon, in priority to all Encumbrances in favour of any Person, other than
the Priority Charges and the Receiver's Charge.
22. THIS COURT ORDERS that neither the Receiver's Charge, Receiver's Borrowings
Charge nor any other security granted by the Receiver in connection with its borrowings under
this Order shall be enforced without leave of this Court.
23. THIS COURT ORDERS that the Receiver is at liberty and authorized to issue certificates
substantially in the form annexed as Schedule "A" hereto (the "Receiver's Certificates") for any
amount borrowed by it pursuant to this Order.
24. THIS COURT ORDERS that the monies from time to time borrowed by the Receiver
pursuant to this Order or any further order of this Court and any and all Receiver's Certificates
23451639.11
#gG- 14 -
evidencing the same or any part thereof shall rank on a pani passu basis, unless otherwise agreed
to by the holders of any prior issued Receiver's Certificates.
25. THIS COURT ORDERS that the Plaintiff or the Receiver shall be entitled, on a
subsequent motion on not less than seven (7) days' notice to those Persons likely to be affected
thereby, to seek priority of the Receiver's Charge and/or the Receiver's Borrowings Charge,
ahead of any Encumbrances over which such charges have not obtained priority.
SERVICE AND NOTICE
26. THIS COURT ORDERS that the E-Service Protocol of the Commercial List (the
"Protocol") is approved and adopted by reference herein and, in these proceedings, the service
of documents made in accordance with the Protocol (which can be found on the Commercial List
website at http ://www.ontariocourts.ca/scj/practice/practice-directionsitoronto/eservice-
commercial/) shall be valid and effective service. Subject to Rule 17.05 of the Ontario Rules of
Civil Procedure (the "Rules"), this Order shall constitute an order for substituted service
pursuant to Rule 16.04 of the Rules. Subject to Rule 3.01(d) of the Rules and paragraph 21 of
the Protocol, service of documents in accordance with the Protocol will be effective on
transmission. This Court further orders that a Case Website shall be established in accordance
with the Protocol with the following URL: www.alvarezandmarsal.com/mdhealth.
27. THIS COURT ORDERS that if the service or distribution of documents in accordance
with the Protocol is not practicable, the Receiver is at liberty to serve or distribute this Order, any
other materials and orders in these proceedings, any notices or other correspondence, by
forwarding true copies thereof by prepaid ordinary mail, courier, personal delivery or facsimile
transmission to the Defendants' creditors or other interested parties at their respective addresses
as last shown on the records of the Defendants and that any such service or distribution by
courier, personal delivery or facsimile transmission shall be deemed to be received on the next
business day following the date of forwarding thereof, or if sent by ordinary mail, on the third
business day after mailing.
23451639.11
#gG- 14 -
evidencing the same or any part thereof shall rank on a pani passu basis, unless otherwise agreed
to by the holders of any prior issued Receiver's Certificates.
25. THIS COURT ORDERS that the Plaintiff or the Receiver shall be entitled, on a
subsequent motion on not less than seven (7) days' notice to those Persons likely to be affected
thereby, to seek priority of the Receiver's Charge and/or the Receiver's Borrowings Charge,
ahead of any Encumbrances over which such charges have not obtained priority.
SERVICE AND NOTICE
26. THIS COURT ORDERS that the E-Service Protocol of the Commercial List (the
"Protocol") is approved and adopted by reference herein and, in these proceedings, the service
of documents made in accordance with the Protocol (which can be found on the Commercial List
website at http ://www.ontariocourts.ca/scj/practice/practice-directionsitoronto/eservice-
commercial/) shall be valid and effective service. Subject to Rule 17.05 of the Ontario Rules of
Civil Procedure (the "Rules"), this Order shall constitute an order for substituted service
pursuant to Rule 16.04 of the Rules. Subject to Rule 3.01(d) of the Rules and paragraph 21 of
the Protocol, service of documents in accordance with the Protocol will be effective on
transmission. This Court further orders that a Case Website shall be established in accordance
with the Protocol with the following URL: www.alvarezandmarsal.com/mdhealth.
27. THIS COURT ORDERS that if the service or distribution of documents in accordance
with the Protocol is not practicable, the Receiver is at liberty to serve or distribute this Order, any
other materials and orders in these proceedings, any notices or other correspondence, by
forwarding true copies thereof by prepaid ordinary mail, courier, personal delivery or facsimile
transmission to the Defendants' creditors or other interested parties at their respective addresses
as last shown on the records of the Defendants and that any such service or distribution by
courier, personal delivery or facsimile transmission shall be deemed to be received on the next
business day following the date of forwarding thereof, or if sent by ordinary mail, on the third
business day after mailing.
23451639.11
#gG - 14 -
evidencing the same or any part thereof shall rank on a pani passu basis, unless otherwise agreed
to by the holders of any prior issued Receiver's Certificates.
25. THIS COURT ORDERS that the Plaintiff or the Receiver shall be entitled, on a
subsequent motion on not less than seven (7) days' notice to those Persons likely to be affected
thereby, to seek priority of the Receiver's Charge and/or the Receiver's Borrowings Charge,
ahead of any Encumbrances over which such charges have not obtained priority.
SERVICE AND NOTICE
26. THIS COURT ORDERS that the E-Service Protocol of the Commercial List (the
"Protocol") is approved and adopted by reference herein and, in these proceedings, the service
of documents made in accordance with the Protocol (which can be found on the Commercial List
website at http ://www.ontariocourts.ca/scj/practice/practice-directionsitoronto/eservice-
commercial/) shall be valid and effective service. Subject to Rule 17.05 of the Ontario Rules of
Civil Procedure (the "Rules"), this Order shall constitute an order for substituted service
pursuant to Rule 16.04 of the Rules. Subject to Rule 3.01(d) of the Rules and paragraph 21 of
the Protocol, service of documents in accordance with the Protocol will be effective on
transmission. This Court further orders that a Case Website shall be established in accordance
with the Protocol with the following URL: www.alvarezandmarsal.com/mdhealth.
27. THIS COURT ORDERS that if the service or distribution of documents in accordance
with the Protocol is not practicable, the Receiver is at liberty to serve or distribute this Order, any
other materials and orders in these proceedings, any notices or other correspondence, by
forwarding true copies thereof by prepaid ordinary mail, courier, personal delivery or facsimile
transmission to the Defendants' creditors or other interested parties at their respective addresses
as last shown on the records of the Defendants and that any such service or distribution by
courier, personal delivery or facsimile transmission shall be deemed to be received on the next
business day following the date of forwarding thereof, or if sent by ordinary mail, on the third
business day after mailing.
23451639.11
- 15 -
GENERAL
28. THIS COURT ORDERS that the Receiver may from time to time apply to this Court for
advice and directions in the discharge of its powers and duties hereunder.
29. THIS COURT ORDERS that nothing in this Order shall prevent the Receiver from acting
as a trustee in bankruptcy of any Defendant.
30. THIS COURT HEREBY REQUESTS the aid and recognition of any court, tribunal,
regulatory or administrative body having jurisdiction in Canada or in any foreign jurisdiction to
give effect to this Order and to assist the Receiver and its agents in carrying out the terms of this
Order. All courts, tribunals, regulatory and administrative bodies are hereby respectfully
requested to make such orders and to provide such assistance to the Receiver, as an officer of this
Court, as may be necessary or desirable to give effect to this Order or to assist the Receiver and
its agents in carrying out the terms of this Order.
31. THIS COURT ORDERS that the Receiver be at liberty and is hereby authorized and
empowered to apply to any court, tribunal, regulatory or administrative body, wherever located,
for the recognition of this Order and for assistance in carrying out the terms of this Order, and
that the Receiver is authorized and empowered to act as a representative in respect of the within
proceedings for the purpose of having these proceedings recognized in a jurisdiction outside
Canada.
32. THIS COURT ORDERS that the Plaintiff shall have its costs of this motion, up to and
including entry and service of this Order, and the costs of the Plaintiff's motion to obtain the
Mareva Orders, in each case on a full indemnity basis, to be paid by the Receiver from the
Defendants' estates with such priority and at such time as this Court may determine.
MISCELLANEOUS AND PROCEDURAL MATTERS
33. THIS COURT ORDERS that any interested party may apply to this Court to vary or
amend this Order on not less than seven (7) days' notice to the Receiver and to any other party
likely to be affected by the order sought or upon such other notice, if any, as this Court may
order.
23451639.11
- 15 -
GENERAL
28. THIS COURT ORDERS that the Receiver may from time to time apply to this Court for
advice and directions in the discharge of its powers and duties hereunder.
29. THIS COURT ORDERS that nothing in this Order shall prevent the Receiver from acting
as a trustee in bankruptcy of any Defendant.
30. THIS COURT HEREBY REQUESTS the aid and recognition of any court, tribunal,
regulatory or administrative body having jurisdiction in Canada or in any foreign jurisdiction to
give effect to this Order and to assist the Receiver and its agents in carrying out the terms of this
Order. All courts, tribunals, regulatory and administrative bodies are hereby respectfully
requested to make such orders and to provide such assistance to the Receiver, as an officer of this
Court, as may be necessary or desirable to give effect to this Order or to assist the Receiver and
its agents in carrying out the terms of this Order.
31. THIS COURT ORDERS that the Receiver be at liberty and is hereby authorized and
empowered to apply to any court, tribunal, regulatory or administrative body, wherever located,
for the recognition of this Order and for assistance in carrying out the terms of this Order, and
that the Receiver is authorized and empowered to act as a representative in respect of the within
proceedings for the purpose of having these proceedings recognized in a jurisdiction outside
Canada.
32. THIS COURT ORDERS that the Plaintiff shall have its costs of this motion, up to and
including entry and service of this Order, and the costs of the Plaintiff's motion to obtain the
Mareva Orders, in each case on a full indemnity basis, to be paid by the Receiver from the
Defendants' estates with such priority and at such time as this Court may determine.
MISCELLANEOUS AND PROCEDURAL MATTERS
33. THIS COURT ORDERS that any interested party may apply to this Court to vary or
amend this Order on not less than seven (7) days' notice to the Receiver and to any other party
likely to be affected by the order sought or upon such other notice, if any, as this Court may
order.
23451639.11
- 15 -
GENERAL
28. THIS COURT ORDERS that the Receiver may from time to time apply to this Court for
advice and directions in the discharge of its powers and duties hereunder.
29. THIS COURT ORDERS that nothing in this Order shall prevent the Receiver from acting
as a trustee in bankruptcy of any Defendant.
30. THIS COURT HEREBY REQUESTS the aid and recognition of any court, tribunal,
regulatory or administrative body having jurisdiction in Canada or in any foreign jurisdiction to
give effect to this Order and to assist the Receiver and its agents in carrying out the terms of this
Order. All courts, tribunals, regulatory and administrative bodies are hereby respectfully
requested to make such orders and to provide such assistance to the Receiver, as an officer of this
Court, as may be necessary or desirable to give effect to this Order or to assist the Receiver and
its agents in carrying out the terms of this Order.
31. THIS COURT ORDERS that the Receiver be at liberty and is hereby authorized and
empowered to apply to any court, tribunal, regulatory or administrative body, wherever located,
for the recognition of this Order and for assistance in carrying out the terms of this Order, and
that the Receiver is authorized and empowered to act as a representative in respect of the within
proceedings for the purpose of having these proceedings recognized in a jurisdiction outside
Canada.
32. THIS COURT ORDERS that the Plaintiff shall have its costs of this motion, up to and
including entry and service of this Order, and the costs of the Plaintiff's motion to obtain the
Mareva Orders, in each case on a full indemnity basis, to be paid by the Receiver from the
Defendants' estates with such priority and at such time as this Court may determine.
MISCELLANEOUS AND PROCEDURAL MATTERS
33. THIS COURT ORDERS that any interested party may apply to this Court to vary or
amend this Order on not less than seven (7) days' notice to the Receiver and to any other party
likely to be affected by the order sought or upon such other notice, if any, as this Court may
order.
23451639.11
I48Y-16-
34. THIS COURT ORDERS that the Plaintiff is granted leave to bring this motion without
notice.
35. THIS COURT ORDERS that the Motion Record for a Receiver, the Factum, and Book of
Authorities, of the Plaintiff, all dated September 10, 2018, and this Order (the "Sealed
Materials") are hereby sealed and that no one shall have access to the Sealed Materials except
for the parties in this proceeding and their respective legal counsel until five (5) days from the
date of this Order have elapsed, subject to paragraph 36 of this Order.
36. THIS COURT ORDERS that this Order:
(a) may be provided by the Receiver to such persons at such times as the Receiver in
its sole discretion deems necessary or advisable to permit or assist the Receiver in
the exercise of the Receiver's powers and duties conferred by this Order; and
(b) shall be served on the persons listed on the Service List attached at Schedule "B"
hereto in accordance with paragraphs 26 and 27 of this Order within ten days of
the date of this Order, or at such earlier time at the Receiver may determine in its
discretion.
PLAINTIFF'S MOTION FOR JUDGMENT
37. THIS COURT ORDERS that, notwithstanding paragraphs 9 and 10 of this Order, the
Plaintiff is granted leave to (a) bring a motion for judgment in this action and to take out any
judgment or order arising therefrom, (b) take any steps in furtherance of or that follow from such
judgment or order (except to the extent such steps would interfere with the Receiver's exclusive
powers in paragraph 2 of this Order), (c) bring any motion to add parties to this action, (d) take
any steps to enforce any judgment or order in a Proceeding that is not a Domestic Proceeding,
and (e) take any steps permitted by the Mareva Orders and/or to bring any motion to vary or
amend the Mareva Orders, in each case without further notice to the Defendants unless required
by law. The Plaintiff's motion for judgment shall be returnable on a date to be set by this Court
at a 9:30 appointment.
23451639.11
I48Y-16-
34. THIS COURT ORDERS that the Plaintiff is granted leave to bring this motion without
notice.
35. THIS COURT ORDERS that the Motion Record for a Receiver, the Factum, and Book of
Authorities, of the Plaintiff, all dated September 10, 2018, and this Order (the "Sealed
Materials") are hereby sealed and that no one shall have access to the Sealed Materials except
for the parties in this proceeding and their respective legal counsel until five (5) days from the
date of this Order have elapsed, subject to paragraph 36 of this Order.
36. THIS COURT ORDERS that this Order:
(a) may be provided by the Receiver to such persons at such times as the Receiver in
its sole discretion deems necessary or advisable to permit or assist the Receiver in
the exercise of the Receiver's powers and duties conferred by this Order; and
(b) shall be served on the persons listed on the Service List attached at Schedule "B"
hereto in accordance with paragraphs 26 and 27 of this Order within ten days of
the date of this Order, or at such earlier time at the Receiver may determine in its
discretion.
PLAINTIFF'S MOTION FOR JUDGMENT
37. THIS COURT ORDERS that, notwithstanding paragraphs 9 and 10 of this Order, the
Plaintiff is granted leave to (a) bring a motion for judgment in this action and to take out any
judgment or order arising therefrom, (b) take any steps in furtherance of or that follow from such
judgment or order (except to the extent such steps would interfere with the Receiver's exclusive
powers in paragraph 2 of this Order), (c) bring any motion to add parties to this action, (d) take
any steps to enforce any judgment or order in a Proceeding that is not a Domestic Proceeding,
and (e) take any steps permitted by the Mareva Orders and/or to bring any motion to vary or
amend the Mareva Orders, in each case without further notice to the Defendants unless required
by law. The Plaintiff's motion for judgment shall be returnable on a date to be set by this Court
at a 9:30 appointment.
23451639.11
I48Y -16-
34. THIS COURT ORDERS that the Plaintiff is granted leave to bring this motion without
notice.
35. THIS COURT ORDERS that the Motion Record for a Receiver, the Factum, and Book of
Authorities, of the Plaintiff, all dated September 10, 2018, and this Order (the "Sealed
Materials") are hereby sealed and that no one shall have access to the Sealed Materials except
for the parties in this proceeding and their respective legal counsel until five (5) days from the
date of this Order have elapsed, subject to paragraph 36 of this Order.
36. THIS COURT ORDERS that this Order:
(a) may be provided by the Receiver to such persons at such times as the Receiver in
its sole discretion deems necessary or advisable to permit or assist the Receiver in
the exercise of the Receiver's powers and duties conferred by this Order; and
(b) shall be served on the persons listed on the Service List attached at Schedule "B"
hereto in accordance with paragraphs 26 and 27 of this Order within ten days of
the date of this Order, or at such earlier time at the Receiver may determine in its
discretion.
PLAINTIFF'S MOTION FOR JUDGMENT
37. THIS COURT ORDERS that, notwithstanding paragraphs 9 and 10 of this Order, the
Plaintiff is granted leave to (a) bring a motion for judgment in this action and to take out any
judgment or order arising therefrom, (b) take any steps in furtherance of or that follow from such
judgment or order (except to the extent such steps would interfere with the Receiver's exclusive
powers in paragraph 2 of this Order), (c) bring any motion to add parties to this action, (d) take
any steps to enforce any judgment or order in a Proceeding that is not a Domestic Proceeding,
and (e) take any steps permitted by the Mareva Orders and/or to bring any motion to vary or
amend the Mareva Orders, in each case without further notice to the Defendants unless required
by law. The Plaintiff's motion for judgment shall be returnable on a date to be set by this Court
at a 9:30 appointment.
23451639.11
- 17 - 4y 9
CONTINUATION OF THE MAREVA ORDERS
38. THIS COURT ORDERS that the Mareva Orders shall not in any way affect or limit the
powers and duties of the Receiver conferred by this Order.
39. THIS COURT ORDERS that the Receiver shall disclose to the Plaintiff all relevant
information acquired or received by the Receiver regarding the Defendants, the Domestic
Property, and the Foreign Property, subject in all cases to such terms as to confidentiality as the
Receiver deems advisable.
40. THIS COURT ORDERS that, subject to paragraph 38 of this Order, the Mareva Orders
remain in full force and effect in all other respects.
41. THIS COURT ORDERS that TD Canada Trust forthwith freeze and prevent any removal
or transfer of monies or assets held in any account (the "DS Account"), until
further Order of the Court.
42. THIS COURT ORDERS that TD Canada Trust forthwith disclose and deliver up to the
Receiver and the Plaintiff any and all records held by it concerning the DS Account.
Justice Dunphy
23451639.11
- 17 - 4y 9
CONTINUATION OF THE MAREVA ORDERS
38. THIS COURT ORDERS that the Mareva Orders shall not in any way affect or limit the
powers and duties of the Receiver conferred by this Order.
39. THIS COURT ORDERS that the Receiver shall disclose to the Plaintiff all relevant
information acquired or received by the Receiver regarding the Defendants, the Domestic
Property, and the Foreign Property, subject in all cases to such terms as to confidentiality as the
Receiver deems advisable.
40. THIS COURT ORDERS that, subject to paragraph 38 of this Order, the Mareva Orders
remain in full force and effect in all other respects.
41. THIS COURT ORDERS that TD Canada Trust forthwith freeze and prevent any removal
or transfer of monies or assets held in any account (the "DS Account"), until
further Order of the Court.
42. THIS COURT ORDERS that TD Canada Trust forthwith disclose and deliver up to the
Receiver and the Plaintiff any and all records held by it concerning the DS Account.
Justice Dunphy
23451639.11
- 17 - 4y 9
CONTINUATION OF THE MAREVA ORDERS
38. THIS COURT ORDERS that the Mareva Orders shall not in any way affect or limit the
powers and duties of the Receiver conferred by this Order.
39. THIS COURT ORDERS that the Receiver shall disclose to the Plaintiff all relevant
information acquired or received by the Receiver regarding the Defendants, the Domestic
Property, and the Foreign Property, subject in all cases to such terms as to confidentiality as the
Receiver deems advisable.
40. THIS COURT ORDERS that, subject to paragraph 38 of this Order, the Mareva Orders
remain in full force and effect in all other respects.
41. THIS COURT ORDERS that TD Canada Trust forthwith freeze and prevent any removal
or transfer of monies or assets held in any account (the "DS Account"), until
further Order of the Court.
42. THIS COURT ORDERS that TD Canada Trust forthwith disclose and deliver up to the
Receiver and the Plaintiff any and all records held by it concerning the DS Account.
Justice Dunphy
23451639.11
SCHEDULE "A"
RECEIVER CERTIFICATE
CERTIFICATE NO.
AMOUNT $
1. THIS IS TO CERTIFY that Alvarez & Marsal Canada Inc., the receiver (the "Receiver")
of all of the assets, undertakings and properties of Sameh Sadek also known as Sam Sadek, St.
Maharial Pharmacy Inc. dba MD Health Pharmacy, St. Maharial Clinic Inc., SRX Investment
Inc., Shepherd RX Pharmacy Inc. and Lilian Fam, including all proceeds thereof, to the extent
such assets, undertakings and properties are located in Canada (collectively, the "Domestic
Property") appointed by Order of the Ontario Superior Court of Justice (Commercial List) (the
"Court") dated the 11th day of September, 2018 (the "Order") made in an action having Court
file number CV-18-602745-00-CL, has received as such Receiver from the holder of this
certificate (the "Lender") the principal sum of $ , being part of the total principal
sum of $ which the Receiver is authorized to borrow under and pursuant to the
Order.
2. The principal sum evidenced by this certificate is payable on demand by the Lender with
interest thereon calculated and compounded [daily] [monthly not in advance on the
of each month] after the date hereof at a notional rate per annum equal to the rate of
cent above the prime commercial lending rate of Bank of from time to time.
3. Such principal sum with interest thereon is, by the terms of the Order, together with the
principal sums and interest thereon of all other certificates issued by the Receiver pursuant to the
Order or to any further order of the Court, a charge upon the whole of the Domestic Property, in
priority to the security interests of any other person (other than the Priority Charges, as defined
in the Order), but subject to the priority of the charges set out in the Order and in the Bankruptcy
and Insolvency Act, R.S.C. 1985, c. B-3 (the "BIA"), and the right of the Receiver to indemnify
itself out of such Property in respect of its remuneration and expenses.
23451639.11
day
per
SCHEDULE "A"
RECEIVER CERTIFICATE
CERTIFICATE NO.
AMOUNT $
1. THIS IS TO CERTIFY that Alvarez & Marsal Canada Inc., the receiver (the "Receiver")
of all of the assets, undertakings and properties of Sameh Sadek also known as Sam Sadek, St.
Maharial Pharmacy Inc. dba MD Health Pharmacy, St. Maharial Clinic Inc., SRX Investment
Inc., Shepherd RX Pharmacy Inc. and Lilian Fam, including all proceeds thereof, to the extent
such assets, undertakings and properties are located in Canada (collectively, the "Domestic
Property") appointed by Order of the Ontario Superior Court of Justice (Commercial List) (the
"Court") dated the 11th day of September, 2018 (the "Order") made in an action having Court
file number CV-18-602745-00-CL, has received as such Receiver from the holder of this
certificate (the "Lender") the principal sum of $ , being part of the total principal
sum of $ which the Receiver is authorized to borrow under and pursuant to the
Order.
2. The principal sum evidenced by this certificate is payable on demand by the Lender with
interest thereon calculated and compounded [daily] [monthly not in advance on the
of each month] after the date hereof at a notional rate per annum equal to the rate of
cent above the prime commercial lending rate of Bank of from time to time.
3. Such principal sum with interest thereon is, by the terms of the Order, together with the
principal sums and interest thereon of all other certificates issued by the Receiver pursuant to the
Order or to any further order of the Court, a charge upon the whole of the Domestic Property, in
priority to the security interests of any other person (other than the Priority Charges, as defined
in the Order), but subject to the priority of the charges set out in the Order and in the Bankruptcy
and Insolvency Act, R.S.C. 1985, c. B-3 (the "BIA"), and the right of the Receiver to indemnify
itself out of such Property in respect of its remuneration and expenses.
23451639.11
day
per
SCHEDULE "A"
RECEIVER CERTIFICATE
CERTIFICATE NO.
AMOUNT $
1. THIS IS TO CERTIFY that Alvarez & Marsal Canada Inc., the receiver (the "Receiver")
of all of the assets, undertakings and properties of Sameh Sadek also known as Sam Sadek, St.
Maharial Pharmacy Inc. dba MD Health Pharmacy, St. Maharial Clinic Inc., SRX Investment
Inc., Shepherd RX Pharmacy Inc. and Lilian Fam, including all proceeds thereof, to the extent
such assets, undertakings and properties are located in Canada (collectively, the "Domestic
Property") appointed by Order of the Ontario Superior Court of Justice (Commercial List) (the
"Court") dated the 11th day of September, 2018 (the "Order") made in an action having Court
file number CV-18-602745-00-CL, has received as such Receiver from the holder of this
certificate (the "Lender") the principal sum of $ , being part of the total principal
sum of $ which the Receiver is authorized to borrow under and pursuant to the
Order.
2. The principal sum evidenced by this certificate is payable on demand by the Lender with
interest thereon calculated and compounded [daily] [monthly not in advance on the
of each month] after the date hereof at a notional rate per annum equal to the rate of
cent above the prime commercial lending rate of Bank of from time to time.
3. Such principal sum with interest thereon is, by the terms of the Order, together with the
principal sums and interest thereon of all other certificates issued by the Receiver pursuant to the
Order or to any further order of the Court, a charge upon the whole of the Domestic Property, in
priority to the security interests of any other person (other than the Priority Charges, as defined
in the Order), but subject to the priority of the charges set out in the Order and in the Bankruptcy
and Insolvency Act, R.S.C. 1985, c. B-3 (the "BIA"), and the right of the Receiver to indemnify
itself out of such Property in respect of its remuneration and expenses.
23451639.11
day
per
-2
4. All sums payable in respect of principal and interest under this certificate are payable at
the main office of the Lender at Toronto, Ontario.
5. Until all liability in respect of this certificate has been terminated, no certificates creating
charges ranking or purporting to rank in priority to this certificate shall be issued by the Receiver
to any person other than the holder of this certificate without the prior written consent of the
holder of this certificate.
6. The charge securing this certificate shall operate so as to permit the Receiver to deal with
the Domestic Property as authorized by the Order and as authorized by any further or other order
of the Court.
7. The Receiver does not undertake, and it is not under any personal liability, to pay any
sum in respect of which it may issue certificates under the terms of the Order.
DATED the day of , 20_.
ALVAREZ & MARSAL CANADA INC., solely in its capacity as Receiver of the Property, and not in its personal capacity
Per:
Name:
Title:
23451639.11
-2
4. All sums payable in respect of principal and interest under this certificate are payable at
the main office of the Lender at Toronto, Ontario.
5. Until all liability in respect of this certificate has been terminated, no certificates creating
charges ranking or purporting to rank in priority to this certificate shall be issued by the Receiver
to any person other than the holder of this certificate without the prior written consent of the
holder of this certificate.
6. The charge securing this certificate shall operate so as to permit the Receiver to deal with
the Domestic Property as authorized by the Order and as authorized by any further or other order
of the Court.
7. The Receiver does not undertake, and it is not under any personal liability, to pay any
sum in respect of which it may issue certificates under the terms of the Order.
DATED the day of , 20_.
ALVAREZ & MARSAL CANADA INC., solely in its capacity as Receiver of the Property, and not in its personal capacity
Per:
Name:
Title:
23451639.11
-2
4. All sums payable in respect of principal and interest under this certificate are payable at
the main office of the Lender at Toronto, Ontario.
5. Until all liability in respect of this certificate has been terminated, no certificates creating
charges ranking or purporting to rank in priority to this certificate shall be issued by the Receiver
to any person other than the holder of this certificate without the prior written consent of the
holder of this certificate.
6. The charge securing this certificate shall operate so as to permit the Receiver to deal with
the Domestic Property as authorized by the Order and as authorized by any further or other order
of the Court.
7. The Receiver does not undertake, and it is not under any personal liability, to pay any
sum in respect of which it may issue certificates under the terms of the Order.
DATED the day of , 20_.
ALVAREZ & MARSAL CANADA INC., solely in its capacity as Receiver of the Property, and not in its personal capacity
Per:
Name:
Title:
23451639.11
4 3
SCHEDULE "B" SERVICE LIST
Defendants
TO: SAMEH SADEK ALSO KNOWN AS SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL CLINIC INC., SRX INVESTMENT INC. and SHEPHERD RX PHARMACY INC.
E-mail: [email protected]
AND TO: LILIAN FAM 5045 Churchill Meadows Blvd. Mississauga ON L5M 7Z8
E-mail: [email protected]
Banks named in August 9, 2018 and September 5, 2018 Orders of the Honourable Justice Dunphy
AND TO: RBC ROYAL BANK Kathrine Smirle 200 Bay Street Toronto, ON M5J 2J5 [email protected]
AND TO: THE BANK OF NOVA SCOTIA Ian Arellano, Executive Vice-President and General Counsel 44 King Street West Toronto, ON M5H 1H1 [email protected]
AND TO: CANADIAN IMPERIAL BANK OF COMMERCE Stephen Scholtz Senior Vice-President and General Counsel (Canada) 199 Bay Street, Commerce Court West, 11th Floor Toronto, ON M5L 1A2 [email protected]
23451639.11
4 3
SCHEDULE "B" SERVICE LIST
Defendants
TO: SAMEH SADEK ALSO KNOWN AS SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL CLINIC INC., SRX INVESTMENT INC. and SHEPHERD RX PHARMACY INC.
E-mail: [email protected]
AND TO: LILIAN FAM 5045 Churchill Meadows Blvd. Mississauga ON L5M 7Z8
E-mail: [email protected]
Banks named in August 9, 2018 and September 5, 2018 Orders of the Honourable Justice Dunphy
AND TO: RBC ROYAL BANK Kathrine Smirle 200 Bay Street Toronto, ON M5J 2J5 [email protected]
AND TO: THE BANK OF NOVA SCOTIA Ian Arellano, Executive Vice-President and General Counsel 44 King Street West Toronto, ON M5H 1H1 [email protected]
AND TO: CANADIAN IMPERIAL BANK OF COMMERCE Stephen Scholtz Senior Vice-President and General Counsel (Canada) 199 Bay Street, Commerce Court West, 11th Floor Toronto, ON M5L 1A2 [email protected]
23451639.11
4 3
SCHEDULE "B" SERVICE LIST
Defendants
TO: SAMEH SADEK ALSO KNOWN AS SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL CLINIC INC., SRX INVESTMENT INC. and SHEPHERD RX PHARMACY INC.
E-mail: [email protected]
AND TO: LILIAN FAM 5045 Churchill Meadows Blvd. Mississauga ON L5M 7Z8
E-mail: [email protected]
Banks named in August 9, 2018 and September 5, 2018 Orders of the Honourable Justice Dunphy
AND TO: RBC ROYAL BANK Kathrine Smirle 200 Bay Street Toronto, ON M5J 2J5 [email protected]
AND TO: THE BANK OF NOVA SCOTIA Ian Arellano, Executive Vice-President and General Counsel 44 King Street West Toronto, ON M5H 1H1 [email protected]
AND TO: CANADIAN IMPERIAL BANK OF COMMERCE Stephen Scholtz Senior Vice-President and General Counsel (Canada) 199 Bay Street, Commerce Court West, 11th Floor Toronto, ON M5L 1A2 [email protected]
23451639.11
493 4
AND TO: TD CANADA TRUST Ellen Patterson Group Head and General Counsel TD Bank Group 12th Floor, TD Tower, TD Centre PO Box 1, Stn. Toronto Dom. Toronto, Ontario M5K 1A2 [email protected]
Legal Demands Department 4720 Tahoe Boulevard, 3rd Floor Mississauga, ON L4W 5P2 Phone: 877-372-3972 Fax: 855-569-1640 ATTN: Rosanna Paolitto
AND TO: BANK OF MONTREAL Miguel Mendes Senior Counsel & VP, BMO Financial Group 1 First Canadian Place, 21st Floor Toronto, Ontario M5X 1A1 [email protected]
AND TO: HSBC BANK CANADA Lilac Bosma Senior Vice-President and General Counsel 1100-885 West Georgia Street Vancouver, BC V6C 3E8 E-mail: lilac.bosmaAhsbc.ca
HSBC Branch 1675 The Chase Mississauga, ON L5M 5Y7
HSBC Branch 101-3029 Argentia Rd Mississauga, ON L5N8P7
23451639.11
493 4
AND TO: TD CANADA TRUST Ellen Patterson Group Head and General Counsel TD Bank Group 12th Floor, TD Tower, TD Centre PO Box 1, Stn. Toronto Dom. Toronto, Ontario M5K 1A2 [email protected]
Legal Demands Department 4720 Tahoe Boulevard, 3rd Floor Mississauga, ON L4W 5P2 Phone: 877-372-3972 Fax: 855-569-1640 ATTN: Rosanna Paolitto
AND TO: BANK OF MONTREAL Miguel Mendes Senior Counsel & VP, BMO Financial Group 1 First Canadian Place, 21st Floor Toronto, Ontario M5X 1A1 [email protected]
AND TO: HSBC BANK CANADA Lilac Bosma Senior Vice-President and General Counsel 1100-885 West Georgia Street Vancouver, BC V6C 3E8 E-mail: lilac.bosmaAhsbc.ca
HSBC Branch 1675 The Chase Mississauga, ON L5M 5Y7
HSBC Branch 101-3029 Argentia Rd Mississauga, ON L5N8P7
23451639.11
493 4
AND TO: TD CANADA TRUST Ellen Patterson Group Head and General Counsel TD Bank Group 12th Floor, TD Tower, TD Centre PO Box 1, Stn. Toronto Dom. Toronto, Ontario M5K 1A2 [email protected]
Legal Demands Department 4720 Tahoe Boulevard, 3rd Floor Mississauga, ON L4W 5P2 Phone: 877-372-3972 Fax: 855-569-1640 ATTN: Rosanna Paolitto
AND TO: BANK OF MONTREAL Miguel Mendes Senior Counsel & VP, BMO Financial Group 1 First Canadian Place, 21st Floor Toronto, Ontario M5X 1A1 [email protected]
AND TO: HSBC BANK CANADA Lilac Bosma Senior Vice-President and General Counsel 1100-885 West Georgia Street Vancouver, BC V6C 3E8 E-mail: lilac.bosmaAhsbc.ca
HSBC Branch 1675 The Chase Mississauga, ON L5M 5Y7
HSBC Branch 101-3029 Argentia Rd Mississauga, ON L5N8P7
23451639.11
5
AND TO: NATIONAL BANK OF CANADA Dominic Paradis Vice-President, Legal Affairs and Corporate Secretary Corporate Secretary's Office 600 De La Gauchetiere Street West, 4th Floor Montreal, Quebec H3B 4L2 [email protected]
Parties to other proceedings involving the defendants
McKesson Canada Corporation v. St. Maharial Pharmacy Inc. et al.
AND TO: MILLS & MILLS LLP 2 St. Clair Avenue West — Suite 700 Toronto, ON M4V 1L5
Richard Worsfold Tel: 416-682-7113 Fax: 416-863-3997 E-mail: [email protected]
Lawyers for the plaintiff in the above-noted proceeding, McKesson Canada Corporation
ESI Canada v. St. Maharial Pharmacy Inc. dba MD Health pharmacy
AND TO: STIKEMAN ELLIOTT LLP 5300 Commerce Court West 199 Bay Street Toronto, ON M5L 1B9
Alex Rose Tel: 416-869-5261 E-mail: [email protected]
Lawyers for the applicant in the above-noted proceeding, ESI Canada
23451639.11
5
AND TO: NATIONAL BANK OF CANADA Dominic Paradis Vice-President, Legal Affairs and Corporate Secretary Corporate Secretary's Office 600 De La Gauchetiere Street West, 4th Floor Montreal, Quebec H3B 4L2 [email protected]
Parties to other proceedings involving the defendants
McKesson Canada Corporation v. St. Maharial Pharmacy Inc. et al.
AND TO: MILLS & MILLS LLP 2 St. Clair Avenue West — Suite 700 Toronto, ON M4V 1L5
Richard Worsfold Tel: 416-682-7113 Fax: 416-863-3997 E-mail: [email protected]
Lawyers for the plaintiff in the above-noted proceeding, McKesson Canada Corporation
ESI Canada v. St. Maharial Pharmacy Inc. dba MD Health pharmacy
AND TO: STIKEMAN ELLIOTT LLP 5300 Commerce Court West 199 Bay Street Toronto, ON M5L 1B9
Alex Rose Tel: 416-869-5261 E-mail: [email protected]
Lawyers for the applicant in the above-noted proceeding, ESI Canada
23451639.11
5
AND TO: NATIONAL BANK OF CANADA Dominic Paradis Vice-President, Legal Affairs and Corporate Secretary Corporate Secretary's Office 600 De La Gauchetiere Street West, 4th Floor Montreal, Quebec H3B 4L2 [email protected]
Parties to other proceedings involving the defendants
McKesson Canada Corporation v. St. Maharial Pharmacy Inc. et al.
AND TO: MILLS & MILLS LLP 2 St. Clair Avenue West — Suite 700 Toronto, ON M4V 1L5
Richard Worsfold Tel: 416-682-7113 Fax: 416-863-3997 E-mail: [email protected]
Lawyers for the plaintiff in the above-noted proceeding, McKesson Canada Corporation
ESI Canada v. St. Maharial Pharmacy Inc. dba MD Health pharmacy
AND TO: STIKEMAN ELLIOTT LLP 5300 Commerce Court West 199 Bay Street Toronto, ON M5L 1B9
Alex Rose Tel: 416-869-5261 E-mail: [email protected]
Lawyers for the applicant in the above-noted proceeding, ESI Canada
23451639.11
-6
Teva Canada Limited v. St. Maharial Pharmacy Inc. et al.
AND TO: BENNETT JONES LLP 100 King Street West, Suite 3400 Toronto, ON M5X 1A4
Dominique T. Hussey Tel: 416-777-6230 E-mail: [email protected]
Lawyers for the plaintiff in the above-noted proceeding, Teva Canada Limited
170735 Ontario Inc. et al. v. Emily Rx Pharm Inc. et al.
AND TO: BISCEGLIA & ASSOCIATES PROFESSIONAL CORPORATION
7941 Jane Street, Suite 200 Concord, ON L4K 4L6
Emilio Bisceglia Tel: (905)-695-5200 E-mail: [email protected]
Lawyers for the plaintiffs in the above-noted proceeding, 170735 Ontario Inc., MD Investments Inc. and MD Health Medical Centre (Brampton) Inc.
AND TO: BLANEY MCMURTRY LLP
2 Queen Street East, Suite 1500 Toronto, ON MSC 3G5
Lou Brzezinski Tel: (416)-594-2952 Fax: (416)-594-5084 E-mail : [email protected]
Varouj an Arman Tel: (416)-596-2884 Fax: (416)-593-2960 E-mail: [email protected]
Lawyers for the defendant in the above-noted proceeding, Emily Rx Phann Inc.
23451639.11
-6
Teva Canada Limited v. St. Maharial Pharmacy Inc. et al.
AND TO: BENNETT JONES LLP 100 King Street West, Suite 3400 Toronto, ON M5X 1A4
Dominique T. Hussey Tel: 416-777-6230 E-mail: [email protected]
Lawyers for the plaintiff in the above-noted proceeding, Teva Canada Limited
170735 Ontario Inc. et al. v. Emily Rx Pharm Inc. et al.
AND TO: BISCEGLIA & ASSOCIATES PROFESSIONAL CORPORATION
7941 Jane Street, Suite 200 Concord, ON L4K 4L6
Emilio Bisceglia Tel: (905)-695-5200 E-mail: [email protected]
Lawyers for the plaintiffs in the above-noted proceeding, 170735 Ontario Inc., MD Investments Inc. and MD Health Medical Centre (Brampton) Inc.
AND TO: BLANEY MCMURTRY LLP
2 Queen Street East, Suite 1500 Toronto, ON MSC 3G5
Lou Brzezinski Tel: (416)-594-2952 Fax: (416)-594-5084 E-mail : [email protected]
Varouj an Arman Tel: (416)-596-2884 Fax: (416)-593-2960 E-mail: [email protected]
Lawyers for the defendant in the above-noted proceeding, Emily Rx Phann Inc.
23451639.11
-6
Teva Canada Limited v. St. Maharial Pharmacy Inc. et al.
AND TO: BENNETT JONES LLP 100 King Street West, Suite 3400 Toronto, ON M5X 1A4
Dominique T. Hussey Tel: 416-777-6230 E-mail: [email protected]
Lawyers for the plaintiff in the above-noted proceeding, Teva Canada Limited
170735 Ontario Inc. et al. v. Emily Rx Pharm Inc. et al.
AND TO: BISCEGLIA & ASSOCIATES PROFESSIONAL CORPORATION
7941 Jane Street, Suite 200 Concord, ON L4K 4L6
Emilio Bisceglia Tel: (905)-695-5200 E-mail: [email protected]
Lawyers for the plaintiffs in the above-noted proceeding, 170735 Ontario Inc., MD Investments Inc. and MD Health Medical Centre (Brampton) Inc.
AND TO: BLANEY MCMURTRY LLP
2 Queen Street East, Suite 1500 Toronto, ON MSC 3G5
Lou Brzezinski Tel: (416)-594-2952 Fax: (416)-594-5084 E-mail : [email protected]
Varouj an Arman Tel: (416)-596-2884 Fax: (416)-593-2960 E-mail: [email protected]
Lawyers for the defendant in the above-noted proceeding, Emily Rx Phann Inc.
23451639.11
7
AND TO: POTESTIO LAW 253 Jevlan Drive Vaughan, ON L4L 7Z6
Timothy Gindy Dir: (905)-850-2642 Fax: (905)-850-8544 E-mail: [email protected]
Lawyers for the defendant in the above-noted proceeding, Medhat Saad, also known as Matty Saad
Creditors (if not named above)
AND TO: MAXIUM FINANCIAL SERVICES INC. AND CWB MAXIUM FINANCIAL INC. 30 Vogell Rd. #1 Richmond Hill, ON L4B 3K6
AND TO: STUART BUDD & SONS LTD. 2430 S Service Rd W Oakville, ON L6L M59
AND TO: KOHL & FRITSCH LIMITED 7622 Keele Street Concord, ON L4K 2R5
Other
AND TO: STI TECHNOLOGIES LTD. 38 Solutions Drive #200 Halifax, NS B3S 1L8
AND TO: CLAIMSECURE INC. 1 City Centre Dr #620 Mississauga, ON L5B 1M2
AND TO: CAMERON STEWART LIFESCIENCE CANADA INC. 3470 Superior Court Oakville, ON L6L 0C4
23451639.11
7
AND TO: POTESTIO LAW 253 Jevlan Drive Vaughan, ON L4L 7Z6
Timothy Gindy Dir: (905)-850-2642 Fax: (905)-850-8544 E-mail: [email protected]
Lawyers for the defendant in the above-noted proceeding, Medhat Saad, also known as Matty Saad
Creditors (if not named above)
AND TO: MAXIUM FINANCIAL SERVICES INC. AND CWB MAXIUM FINANCIAL INC. 30 Vogell Rd. #1 Richmond Hill, ON L4B 3K6
AND TO: STUART BUDD & SONS LTD. 2430 S Service Rd W Oakville, ON L6L M59
AND TO: KOHL & FRITSCH LIMITED 7622 Keele Street Concord, ON L4K 2R5
Other
AND TO: STI TECHNOLOGIES LTD. 38 Solutions Drive #200 Halifax, NS B3S 1L8
AND TO: CLAIMSECURE INC. 1 City Centre Dr #620 Mississauga, ON L5B 1M2
AND TO: CAMERON STEWART LIFESCIENCE CANADA INC. 3470 Superior Court Oakville, ON L6L 0C4
23451639.11
7
AND TO: POTESTIO LAW 253 Jevlan Drive Vaughan, ON L4L 7Z6
Timothy Gindy Dir: (905)-850-2642 Fax: (905)-850-8544 E-mail: [email protected]
Lawyers for the defendant in the above-noted proceeding, Medhat Saad, also known as Matty Saad
Creditors (if not named above)
AND TO: MAXIUM FINANCIAL SERVICES INC. AND CWB MAXIUM FINANCIAL INC. 30 Vogell Rd. #1 Richmond Hill, ON L4B 3K6
AND TO: STUART BUDD & SONS LTD. 2430 S Service Rd W Oakville, ON L6L M59
AND TO: KOHL & FRITSCH LIMITED 7622 Keele Street Concord, ON L4K 2R5
Other
AND TO: STI TECHNOLOGIES LTD. 38 Solutions Drive #200 Halifax, NS B3S 1L8
AND TO: CLAIMSECURE INC. 1 City Centre Dr #620 Mississauga, ON L5B 1M2
AND TO: CAMERON STEWART LIFESCIENCE CANADA INC. 3470 Superior Court Oakville, ON L6L 0C4
23451639.11
8
AND TO: MINISTRY OF FINANCE (ONTARIO) Legal Service Branch 33 King Street West, 6th Floor Oshawa, ON L1H 8H5
Kevin O'Hara Tel: 905-433-6934 Fax: 905-436-4510 Email: [email protected]
AND TO: DEPARTMENT OF JUSTICE Counsel for the Canada Revenue Agency The Exchange Tower 130 King Street West, Suite 3400 PO Box 36 Toronto, ON M5X 1K6
Diane Winters Tel: 416-973-3172 Fax: 416-973-0810 Email: diane.winters@justice. gc.ca
AND TO: ONTARIO COLLEGE OF PHARMACISTS Investigations and Resolutions 483 Huron Street Toronto, ON M5R 2R4 Phone: 1-800-220-1921 Fax: 416-847-8499
ATTN: Complaints Intake Assistant complaintsocpinfo.com
ATTN: Shelina Manji, Investigator [email protected]
AND TO:
23451639.11
8
AND TO: MINISTRY OF FINANCE (ONTARIO) Legal Service Branch 33 King Street West, 6th Floor Oshawa, ON L1H 8H5
Kevin O'Hara Tel: 905-433-6934 Fax: 905-436-4510 Email: [email protected]
AND TO: DEPARTMENT OF JUSTICE Counsel for the Canada Revenue Agency The Exchange Tower 130 King Street West, Suite 3400 PO Box 36 Toronto, ON M5X 1K6
Diane Winters Tel: 416-973-3172 Fax: 416-973-0810 Email: diane.winters@justice. gc.ca
AND TO: ONTARIO COLLEGE OF PHARMACISTS Investigations and Resolutions 483 Huron Street Toronto, ON M5R 2R4 Phone: 1-800-220-1921 Fax: 416-847-8499
ATTN: Complaints Intake Assistant complaintsocpinfo.com
ATTN: Shelina Manji, Investigator [email protected]
AND TO:
23451639.11
8
AND TO: MINISTRY OF FINANCE (ONTARIO) Legal Service Branch 33 King Street West, 6th Floor Oshawa, ON L1H 8H5
Kevin O'Hara Tel: 905-433-6934 Fax: 905-436-4510 Email: [email protected]
AND TO: DEPARTMENT OF JUSTICE Counsel for the Canada Revenue Agency The Exchange Tower 130 King Street West, Suite 3400 PO Box 36 Toronto, ON M5X 1K6
Diane Winters Tel: 416-973-3172 Fax: 416-973-0810 Email: diane.winters@justice. gc.ca
AND TO: ONTARIO COLLEGE OF PHARMACISTS Investigations and Resolutions 483 Huron Street Toronto, ON M5R 2R4 Phone: 1-800-220-1921 Fax: 416-847-8499
ATTN: Complaints Intake Assistant complaintsocpinfo.com
ATTN: Shelina Manji, Investigator [email protected]
AND TO:
23451639.11
Tab 6Tab 6
RevisedJanuafy-11, 2014 G.213(1) BIA (National Receiver) and s. 101 CJA (Ontario) Receiver
Court File No.
CV-18-602745-00-CI,
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
THE HONOURABLE
JUSTICE MR.
WEEKDAYTIIESDAY, THE #11 TH
DAY OF MONTH, 20YR
ASTRAZENECA CANADA INC. PLAIlsaIFF1
- and -
DEFENDANT
OF SEPTEMBER. 2018
Plaintiff
Defendant
SAMEH SADEK also known as SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL
CLINIC INC., SRX INVESTMENT INC., SHEPHERD RX PHARMACY INC. and LILIAN FAM
Defendants
ORDER (appointing Receiver)
THIS MOTION made by-ex parte by Astrazeneca Canada Inc. (the `_`_Plaintiff2D for an
Order pursuant to section443-(4)-ef4he Bankruptcy and insol-veney-A-eti--1- -',C, 1985, c. B 3, as
1 The Model Order Subcommittee notes that a receivership proceeding may be commenced by action or by application. -This-model order is drafted on the-bas-i-s4hat4he receiverchip proceeding-i-s-commenced by way of an action,
2-Section 2/13(1) of the BIA provides that the Court may appoint a receiver on application by a secured-cedior".
21:64.4441771712\9
RevisedJanuafy-11, 2014 G.213(1) BIA (National Receiver) and s. 101 CJA (Ontario) Receiver
Court File No.
CV-18-602745-00-CI,
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
THE HONOURABLE
JUSTICE MR.
WEEKDAYTIIESDAY, THE #11 TH
DAY OF MONTH, 20YR
ASTRAZENECA CANADA INC. PLAIlsaIFF1
- and -
DEFENDANT
OF SEPTEMBER. 2018
Plaintiff
Defendant
SAMEH SADEK also known as SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL
CLINIC INC., SRX INVESTMENT INC., SHEPHERD RX PHARMACY INC. and LILIAN FAM
Defendants
ORDER (appointing Receiver)
THIS MOTION made by-ex parte by Astrazeneca Canada Inc. (the `_`_Plaintiff2D for an
Order pursuant to section443-(4)-ef4he Bankruptcy and insol-veney-A-eti--1- -',C, 1985, c. B 3, as
1 The Model Order Subcommittee notes that a receivership proceeding may be commenced by action or by application. -This-model order is drafted on the-bas-i-s4hat4he receiverchip proceeding-i-s-commenced by way of an action,
2-Section 2/13(1) of the BIA provides that the Court may appoint a receiver on application by a secured-cedior".
21:64.4441771712\9
G.213(1) B1A (National Receiver) and s. 101 CJA (Ontario) Receiver
Court File No.
CV-18-602745-00-CI,
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
THE HONOURABLE
JUSTICE MR.
WEEKDAYTIJESDAY, THE #11 TH
DAY OF MONTH, 20YR
ASTRAZENECA CANADA INC. PLAIlsaIFF1
- and -
DEFENDANT
OF SEPTEMBER. 2018
Plaintiff
Defendant
SAMEH SADEK also known as SAM SADEK, ST. MAHARIAL PHARMACY INC. dba MD HEALTH PHARMACY, ST. MAHARIAL
CLINIC INC., SRX INVESTMENT INC., SHEPHERD RX PHARMACY INC. and LILIAN FAM
Defendants
ORDER (appointing Receiver)
THIS MOTION made by-ex parte by Astrazeneca Canada Inc. (the `_`_Plaintiff2D for an
Order pursuant to section443-(4)-ef-the Bankruptcy and in-sol-veney-A-et-i-fg,G, 1985, c. B 3, as
1 The Model Order Subcommittee notes that a receivership proceeding may be commenced by action or by application. -This-model order is drafted on the-bas-i-s4hat4he receiverchip proceeding-i-s-commenced by way of an action,
2-Section 2/13(1) of the BIA provides that the Court may appoint a receiver on application by a secured-cedior".
21:64.4441771712\9
DUC6TUR: 1771712 \ 9
2
amended (the "BIA") and section 101 of the Courts of Justice Act, R.S.O. 1990, c. C.43, as
amended (the L"CJAL") appointing [RECEIVER'S NAME]Alvarez & Marsal Canada Inc.
("A&M") as receiver fand-hranageil---(in such capacitiescapacity, the -Receiver-_), without
security, of all of the domestic assets, undertakings and properties of [DEBTOR'S NAME] (the
'Debtor"}asquired-for, or-use-d-in-re-l-ation-4o-a-business-eaffied-on-by the-DebterSameh Sadek
also known as Sam Sadek, St Maharial Pharmacy Inc dha MD Health Pharmacy, St Maharial
C1' • I SRX Investment Inc She .herd RX Pharmacy Inc and Lilian Fam (collectively
"Defendants" and, individually, a "Defendant"), and for related relief, was heard this day at 330
University Avenue, Toronto, Ontario.
ON READING the affidavit of [NAME] sworn [DATE] and the Exhibits theretoMotion
Record and Factum of the Plaintiff dated August 8, 2018, the Supplemental Motion Record of
the Plaintiff dated August 17, 2018, the Second Supplemental Motion Record of the Plaintiff
dated September 5, 2018, and t e Motion Record for a Receiver, the Factum and Book of
Authorities of the Plaintiff dated September 10, 2018, and the Orders of the Honourable Justice
Dunphy dated August 9, 2018 (the "August 9 Order"), August 17, 2018 (the "August 17
Order") and September 5, 2018 (the "September Order" and, together with the Au• • • q -
and the August 17 Order, the "Mareva Orders"), and on hearing the submissions of counsel for
{NAMES-fr-no-ene-appearing-for-INAMEI-aftheugh-duty-served-as appears-from the-affirlav-it-of-
Gervice of [NAME] sworn [DATE}the Plaintiff, and on reading the consent of [RECEIVER'S
NAME]A&M to act as the Receiver,
SERVICE
-1, T-HIS-GO-UR-T-ORDERS-that-the-time-for-serviee-ef-the-Net4ee-of-Motion-and4he-Motiew
is-hereby-ahridged-and-val-idate(43- so that-this motion is properly-returnable-tedad hereby-
dispenses with further service thereof.
er4Ilan-as-autherized-133414-e-Cmtario Rules of Civil Pre validating irregular service is required pursuant to Rule 16.08 of the Rules of Civil Procedure and may be granted in-apprepfiete-oire-umstanees,
23451639 11
4191 DUC6TUR: 1771712 \ 9
2
amended (the "BIA") and section 101 of the Courts of Justice Act, R.S.O. 1990, c. C.43, as
amended (the L"CJAL") appointing [RECEIVER'S NAME]Alvarez & Marsal Canada Inc.
("A&M") as receiver fand-hranageil---(in such capacitiescapacity, the -Receiver-_), without
security, of all of the domestic assets, undertakings and properties of [DEBTOR'S NAME] (the
'Debtor"}asquired-for, or-use-d-in-re-l-ation-4o-a-business-eaffied-on-by the-DebterSameh Sadek
also known as Sam Sadek, St Maharial Pharmacy Inc dha MD Health Pharmacy, St Maharial
C1' • I SRX Investment Inc She .herd RX Pharmacy Inc and Lilian Fam (collectively
"Defendants" and, individually, a "Defendant"), and for related relief, was heard this day at 330
University Avenue, Toronto, Ontario.
ON READING the affidavit of [NAME] sworn [DATE] and the Exhibits theretoMotion
Record and Factum of the Plaintiff dated August 8, 2018, the Supplemental Motion Record of
the Plaintiff dated August 17, 2018, the Second Supplemental Motion Record of the Plaintiff
dated September 5, 2018, and t e Motion Record for a Receiver, the Factum and Book of
Authorities of the Plaintiff dated September 10, 2018, and the Orders of the Honourable Justice
Dunphy dated August 9, 2018 (the "August 9 Order"), August 17, 2018 (the "August 17
Order") and September 5, 2018 (the "September Order" and, together with the Au• • • q -
and the August 17 Order, the "Mareva Orders"), and on hearing the submissions of counsel for
{NAMES-fr-no-ene-appearing-for-INAMEI-aftheugh-duty-served-as appears-from the-affirlav-it-of-
Gervice of [NAME] sworn [DATE}the Plaintiff, and on reading the consent of [RECEIVER'S
NAME]A&M to act as the Receiver,
SERVICE
-1, T-HIS-GO-UR-T-ORDERS-that-the-time-for-serviee-ef-the-Net4ee-of-Motion-and4he-Motiew
is-hereby-ahridged-and-val-idate(43- so that-this motion is properly-returnable-tedad hereby-
dispenses with further service thereof.
er4Ilan-as-autherized-133414-e-Cmtario Rules of Civil Pre validating irregular service is required pursuant to Rule 16.08 of the Rules of Civil Procedure and may be granted in-apprepfiete-oire-umstanees,
23451639 11
4191 DUC6TUR: 1771712 \ 9
2
amended (the "BIA") and section 101 of the Courts of Justice Act, R.S.O. 1990, c. C.43, as
amended (the L"CJAL") appointing [RECEIVER'S NAME]Alvarez & Marsal Canada Inc.
("A&M") as receiver fartd-tn-anagetl---(in such capacitiescapacity, the -Receiver-_), without
security, of all of the domestic assets, undertakings and properties of [DEBTOR'S NAME] (the
'Debtor"}asquired-for, or-use-d-in-re-l-ation-4e-a-business-eaffied-on-by the-DebterSameh Sadek
also known as Sam Sadek, St Maharial Pharmacy Inc dha MD Health Pharmacy, St Maharial
Cl• • I SRX Investment Inc She .herd RX Pharmacy Inc and Lilian Fam (collectively
"Defendants" and, individually, a "Defendant"), and for related relief, was heard this day at 330
University Avenue, Toronto, Ontario.
ON READING the affidavit of [NAME] sworn [DATE] and the Exhibits theretoMotion
Record and Factumf the Plaintiff dated A t 8. 2018 the Sunnlemental Motion Record of
the Plaintiff dated A t 17. 2018 the Second S lemental Motion Record of the Plaintiff
dated September 5, 2018, and t e Motion Record for a Receiver, the Factum and Book of
Authorities f the Plaintiff dated S t b 10, 2018 and the Orders of the Honourable Justice
Dunphy dated August 9, 2018 (the "August 9 Order"), August 17, 2018 (the "August 17
Order") and September 5, 2018 (the "September Order" and, together with the Au• • I q -
and the August 17 Order, the "Mareva Orders"), and on hearing the submissions of counsel for
{NAMES-17-no-ene-appearing-for-lNAME1-aftheugh-duty-served-as appears-from the-affirfav-it-of-
Gervice of [NAME] sworn [DATE}the Plaintiff, and on reading the consent of [RECEIVER'S
NAME]A&M to act as the Receiver,
SERVICE
-1, THIS COURT ORDERS that the time for service of the Notice of Motion and the Motion
&-her-ebabfi4ge-d--and--Ya144ate4 so that-this motion is properly-returnable-tedad hereby-
dispenses with further service thereof.
er4Ilan-as-autherized-133414-&-Cmtario Rules of Civil Pre validating irregular service is required pursuant to Rule 16.08 of the Rules of Civil Procedure and may be granted iti-apprepfiete-oire-umstanees,
23451639 11
4191
-144:4S I OR: 1771741V9
3
APPOINTMENT
2-THIS COURT ORDERS that pursuant to section 213(1) of the BIA and section 101 of
the CJA, [RECEIVER'S NAME]A&M is hereby appointed Receiver, without security, of all of
the assets, undertakings and properties of the Debtor acquired for, or used in relation to a
bu-s-i-ness-earried-oft-by-the-Debt-erDefendants, including all proceeds thereof (the "Property" to
the extent that '14 assets, undertakings and properties _are located in Canada (the "Domestic
Property"), Without limiting the generality of the foregoing, the Domestic Property includes all
of the right, title and interest of the Defendants in and to the real property with the following
legal descriptions.
PIN 14360 - 1750 (LT) Interest/Estate Fee Simple
Description PART OF LO 11, PLAN 43M1663, DES PART 6, PL 43R30324; MISSISSAUGA S/T EASEMENT FOR ENTRY AS TN PR806741. S/T EASEMENT FOR ENTRY AS IN PR1007490.
Address_ 5045 CHURCHILL MEADOWS BOULEVARD MISSISSAUGA, ONTARIO, L5M 7Z8
PIN 13439 - 0416 (LT) Interest/Estate Fee Simple
Description PT LT 26 PL 396 DES PART 1 43R29866• MTSSISSAIIGA S/T EASEMENT OVER PT LT 26 PL 396 DES PART 1 43R29866 AS IN PR1037379
Address 2334 HAMMOND ROAD MISSISSAUGA, ONTARIO, L5K I T2
RECEIVER'S POWERS
3,-THIS COURT ORDERS that the Receiver is hereby empowered and authorized, but
not obligated, to act at once in respect of the Domestic Property and, without in any way limiting
the generality of the foregoing, the Receiver is hereby expressly empowered and authorized to do
any of the following where the Receiver considers it necessary or desirable:
(a) to take possession of and exercise control over the Domestic Property and any and
all proceeds, receipts and disbursements arising out of or from the
23451639.11
-144:4S I OR: 1771741V9
3
APPOINTMENT
2-THIS COURT ORDERS that pursuant to section 213(1) of the BIA and section 101 of
the CJA, [RECEIVER'S NAME]A&M is hereby appointed Receiver, without security, of all of
the assets, undertakings and properties of the Debtor acquired for, or used in relation to a
bu-s-i-ness-earried-oft-by-the-Debt-erDefendants, including all proceeds thereof (the "Property" to
the extent that '14 assets, undertakings and properties _are located in Canada (the "Domestic
Property"), Without limiting the generality of the foregoing, the Domestic Property includes all
of the right, title and interest of the Defendants in and to the real property with the following
legal descriptions.
PIN 14360 - 1750 (LT) Interest/Estate Fee Simple
Description PART OF LO 11, PLAN 43M1663, DES PART 6, PL 43R30324; MISSISSAUGA S/T EASEMENT FOR ENTRY AS TN PR806741. S/T EASEMENT FOR ENTRY AS IN PR1007490.
Address_ 5045 CHURCHILL MEADOWS BOULEVARD MISSISSAUGA, ONTARIO, L5M 7Z8
PIN 13439 - 0416 (LT) Interest/Estate Fee Simple
Description PT LT 26 PL 396 DES PART 1 43R29866• MTSSISSAIIGA S/T EASEMENT OVER PT LT 26 PL 396 DES PART 1 43R29866 AS IN PR1037379
Address 2334 HAMMOND ROAD MISSISSAUGA, ONTARIO, L5K I T2
RECEIVER'S POWERS
3,-THIS COURT ORDERS that the Receiver is hereby empowered and authorized, but
not obligated, to act at once in respect of the Domestic Property and, without in any way limiting
the generality of the foregoing, the Receiver is hereby expressly empowered and authorized to do
any of the following where the Receiver considers it necessary or desirable:
(a) to take possession of and exercise control over the Domestic Property and any and
all proceeds, receipts and disbursements arising out of or from the
23451639.11
-144:4S I OR: 1771741V9
3
APPOINTMENT
2-THIS COURT ORDERS that pursuant to section 213(1) of the BIA and section 101 of
the CJA, [RECEIVER'S NAME]A&M is hereby appointed Receiver, without security, of all of
the assets, undertakings and properties of the Debtor acquired for, or used in relation to a
bu-siness-earfied-oft-by-the-Debt-erDefendants, including all proceeds thereof (the "Property" to
the extent that '14 assets, undertakings and properties _are located in Canada (the "Domestic
Property"), Without limiting the generality of the foregoing, the Domestic Property includes all
of the right, title and interest of the Defendants in and to the real property with the following
legal descriptions.
PIN 14360 - 1750 (LT) Interest/Estate Fee Simple
Description PART OF LO 11, PLAN 43M1663, DES PART MISSISSAUGA S/T EASEMENT FOR ENTRY AS TN PR806741. FOR ENTRY AS IN PR1007490.
6, PL 43R30324; S/T EASEMENT
Address 5045 CHURCHILL MEADOWS BOULEVARD ONTARIO, L5M 7Z8
PIN 13439 - 0416 (LT) Interest/Estate Fee Simple
MISSISSAUGA,
Description PT LT 26 PL 396 DES PART 1 43R29866• MTSSISSAIIGA S/T EASEMENT OVER PT LT 26 PL 396 DES PART 1 43R29866 AS IN PR1037379
Address 2334 HAMMOND ROAD MISSISSAUGA, ONTARIO, L5K I T2
RECEIVER'S POWERS
3,-THIS COURT ORDERS that the Receiver is hereby empowered and authorized, but
not obligated, to act at once in respect of the Domestic Property and, without in any way limiting
the generality of the foregoing, the Receiver is hereby expressly empowered and authorized to do
any of the following where the Receiver considers it necessary or desirable:
(a) to take possession of and exercise control over the Domestic Property and any and
all proceeds, receipts and disbursements arising out of or from the
23451639.11
DOLS I OR: 1771'11219
4
Property;Domestic Property. but, for greater certainty, excluding any business
and/or operations carried on by any of the Defendants;
(b) to receive, preserve, and protect the Domestic Property, or any part or parts
thereof, including, but not limited to, the changing of locks and security codes, the
relocating of Domestic Property to safeguard it, the engaging of independent
security personnel, the taking of physical inventories and the placement of such
insurance coverage as may be necessary or desirable;
(c) to manege-T-eper-ate-;-arid-earr-y-en4he-husine-ss-ef-the-Debter3-inc-fudit+g-the-powers-
to enter into any agreements, incur any obligations in the-erdinary-c-ourse-of
business, cease to carry on all or any part of the business, or cease to perform any
entraets-ef4he-De1ter-identifv
forced seizure or sale pursuant to the Execution Act, R.S.O. 1990, c E-24 (the
"Execution Act"); or (b) constitutes "consumer goods", as that term is defined in
the F- • al Property15'_ecuoLv_zict 8,S_O 1990. c P 10 (the "PPSA") and in th-
case of property so segregated, to hold such property pending further order of this
Court;
(Al to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
is) (61)-to engage consultants, appraisers, agents, experts, auditors, accountants,
managers, insurance brokers, realtors, counsel and such other persons from time
to time and on whatever basis, including on a temporary basis, to assist with the
exercise of the Receiver's powers and duties, including without limitation those
conferred by this Order;
(e) to purchase or lease such machinery, equipment, inventories, supplies,
premises or other-assets-to contiftue-the-business e€the Debtor-or any pail
-pafts-thefeef;-
23451639 11
Sol
DOLS I OR: 1771'11219
4
Property;Domestic Property. but, for greater certainty, excluding any business
and/or operations carried on by any of the Defendants;
(b) to receive, preserve, and protect the Domestic Property, or any part or parts
thereof, including, but not limited to, the changing of locks and security codes, the
relocating of Domestic Property to safeguard it, the engaging of independent
security personnel, the taking of physical inventories and the placement of such
insurance coverage as may be necessary or desirable;
(c) to manege-T-eper-ate-;-arid-earr-y-en4he-husine-ss-ef-the-Debter3-inc-fudit+g-the-powers-
to enter into any agreements, incur any obligations in the-erdinary-c-ourse-of
business, cease to carry on all or any part of the business, or cease to perform any
entraets-ef4he-De1ter-identifv
forced seizure or sale pursuant to the Execution Act, R.S.O. 1990, c E-24 (the
"Execution Act"); or (b) constitutes "consumer goods", as that term is defined in
the F- • al Property15'_ecuoLv_zict 8,S_O 1990. c P 10 (the "PPSA") and in th-
case of property so segregated, to hold such property pending further order of this
Court;
(Al to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
is) (61)-to engage consultants, appraisers, agents, experts, auditors, accountants,
managers, insurance brokers, realtors, counsel and such other persons from time
to time and on whatever basis, including on a temporary basis, to assist with the
exercise of the Receiver's powers and duties, including without limitation those
conferred by this Order;
(e) to purchase or lease such machinery, equipment, inventories, supplies,
premises or other-assets-to contiftue-the-business e€the Debtor-or any pail
-pafts-thefeef;-
23451639 11
Sol
DOLS I OR: 1771'11219
4
Property;Domestic Property. but, for greater certainty, excluding any business
and/or operations carried on by any of the Defendants;
(b) to receive, preserve, and protect the Domestic Property, or any part or parts
thereof, including, but not limited to, the changing of locks and security codes, the
relocating of Domestic Property to safeguard it, the engaging of independent
security personnel, the taking of physical inventories and the placement of such
insurance coverage as may be necessary or desirable;
(c) to manege-T-eper-ate-;-arid-earr-y-en4he-husine-ss-ef-the-Debter3-inc-fudit+g-the-powers-
to enter into any agreements, incur any obligations in the-erdinary-c-ourse-of
business, cease to carry on all or any part of the business, or cease to perform any
entraets-ef4he-De1ter-identifv
forced seizure or sale pursuant to the Execution Act, R.S.O. 1990, c E-24 (the
"Execution Act"): or (b) constitutes "consumer goods", as that term is defined in
the F- • al Property15'_ecuoLv_zict 8,S_O 1990. c P 10 (the "PPSA") and in th-
case of property so segregated, to hold such property pending further order of this
Court;
(Al to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
is) (61)-to engage consultants, appraisers, agents, experts, auditors, accountants,
managers, insurance brokers, realtors, counsel and such other persons from time
to time and on whatever basis, including on a temporary basis, to assist with the
exercise of the Receiver's powers and duties, including without limitation those
conferred by this Order;
(e) to purchase or lease such machinery, equipment, inventories, supplies,
premises or other-assets-to contiftue-the-business e€the Debtor-or any pail
-pafts-thefeef;-
23451639 11
Sol
OQUS 1 OK: 1 71 I 711_ \ 9
-5
to receive and collect all monies and accounts now owed or hereafter owing to the
DebtorDefenclants and to exercise all remedies of the DebtorDefendants in
collecting such monies, including, without limitation, to enforce any security held
by the Debtorany Defendant;
(g) to settle, extend or compromise any indebtedness owing to the Debtorany_
Defendant;
(h) to execute, assign, issue and endorse documents of whatever nature in respect of
any of the Domestic Property, whether in the Receiverl's name or in the name and
on behalf of tie—Debtorany Defendant, for any purpose pursuant to this Order;
(i) to initiate, prosecute and continue the prosecution of any and all proceedings and
to defend all proceedings now pending or hereafter instituted with respect to the
Debtorany Defendant, the Domestic Property or the Receiver, and to settle or
compromise any such proceedings.4 The authority hereby conveyed shall extend to
such appeals or applications for judicial review in respect of any order or
judgment pronounced in any such proceeding;
(j) to undertak- any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to., have
been, Domestic ' roperty. including, without limitation, the transfer of any funds
of the Defendants to any related or unrelated pa ies;
(k) subject to any applicable exemption under the Execution Act or t e PPSA to
which the individual Defendants are entitled, to market any or all of the Domestic
Property, including advertising and soliciting offers in respect of the Domestic
Property or any part or parts thereof and negotiating such terms and conditions of
sale as the Receiver in its discretion may deem appropriate;
4 This-model order does-not-ineluele-speeific-author-ity-perntitting-the-Reeei-ver to-either file an assignment-in-
bankruptcy may have-the-effect of altering the-priorities among creditors, and therefore the specific authority of the Court should-be-sought if the Reeeiver wishes to take one of these steps.
23451639 11
OQUS 1 OK: 1 71 I 711_ \ 9
-5
to receive and collect all monies and accounts now owed or hereafter owing to the
DebtorDefenclants and to exercise all remedies of the DebtorDefendants in
collecting such monies, including, without limitation, to enforce any security held
by the Debtorany Defendant;
(g) to settle, extend or compromise any indebtedness owing to the Debtorany_
Defendant;
(h) to execute, assign, issue and endorse documents of whatever nature in respect of
any of the Domestic Property, whether in the Receiverl's name or in the name and
on behalf of tie—Debtorany Defendant, for any purpose pursuant to this Order;
(i) to initiate, prosecute and continue the prosecution of any and all proceedings and
to defend all proceedings now pending or hereafter instituted with respect to the
Debtorany Defendant, the Domestic Property or the Receiver, and to settle or
compromise any such proceedings.4 The authority hereby conveyed shall extend to
such appeals or applications for judicial review in respect of any order or
judgment pronounced in any such proceeding;
(j) to undertak- any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to., have
been, Domestic ' roperty. including, without limitation, the transfer of any funds
of the Defendants to any related or unrelated pa ies;
(k) subject to any applicable exemption under the Execution Act or t e PPSA to
which the individual Defendants are entitled, to market any or all of the Domestic
Property, including advertising and soliciting offers in respect of the Domestic
Property or any part or parts thereof and negotiating such terms and conditions of
sale as the Receiver in its discretion may deem appropriate;
4 This-model order does-not-ineluele-speeific-author-ity-perntitting-the-Reeei-ver to-either file an assignment-in-
bankruptcy may have-the-effect of altering the-priorities among creditors, and therefore the specific authority of the Court should-be-sought if the Reeeiver wishes to take one of these steps.
23451639 11
OQUS 1 OK: 1 71 I 711_ \ 9
-5
to receive and collect all monies and accounts now owed or hereafter owing to the
DebtorDefenclants and to exercise all remedies of the DebtorDefendants in
collecting such monies, including, without limitation, to enforce any security held
by the Debtorany Defendant;
(g) to settle, extend or compromise any indebtedness owing to the Debtorany_
Defendant;
(h) to execute, assign, issue and endorse documents of whatever nature in respect of
any of the Domestic Property, whether in the Receiverl's name or in the name and
on behalf of tie—Debtorany Defendant, for any purpose pursuant to this Order;
(i) to initiate, prosecute and continue the prosecution of any and all proceedings and
to defend all proceedings now pending or hereafter instituted with respect to the
Debtorany Defendant, the Domestic Property or the Receiver, and to settle or
compromise any such proceedings.4 The authority hereby conveyed shall extend to
such appeals or applications for judicial review in respect of any order or
judgment pronounced in any such proceeding;
(j) to undertak- any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or t•_ have
been, Domestic ' roperty. including, without limitation, the transfer of any funds
of the Defendants to any related or unrelated pa ies;
biect licable xemntion underthe ExecutionAct or t e PPSA to
which the individual Defendants are entitled, to market any or all of the Domestic
Property, including advertising and soliciting offers in respect of the Domestic
Property or any part or parts thereof and negotiating such terms and conditions of
sale as the Receiver in its discretion may deem appropriate;
4 This-model order does-not-ineluele-speeific-authority-permitting-the-Reeeiver to-either file an assignment-in-
bankruptcy may have-the-effect of altering the-priorities among creditors, and therefore the specific authority of the Court should-be-sought if the Reeeiver wishes to take one of these steps.
DUOS FOR: 177179: \9
6
(k) subject to any applicabl
wh. thefividual Defendants are entitled._to sell, convey, transfer, lease or
assign the Domestic Property or any part or parts thereof out of the ordinary
course of business
(i) without the approval of this Court in respect of any transaction not
exceeding $ ,250,000, provided that the aggregate consideration
for all such transactions does not exceed $ 500,000; and
(ii) with the approval of this Court in respect of any transaction in which the
purchase price or the aggregate purchase price exceeds the applicable
amount set out in the preceding clause;,
and in each such case notice under subsection 63(4) of the Ontario-Personal-
Property Security Act, [PPSA, or section 31 of the Ontario Mortgages Act, as the
case may be,j5 shall not be required,-and-in each case the-Ontario
&hall-net-apply.;
(n) (1) to apply for any vesting order or other orders necessary to convey the Domestic
Property or any part or parts thereof to a purchaser or purchasers thereof, free and
clear of any liens or encumbrances affecting such Domestic Property;
(n) (m)-to report to, meet with and discuss with such affected Persons (as defined
below) as the Receiver deems appropriate on all matters relating to the Domestic
Property and the receivership, and to share information;; subject in all cases to
such terms as to confidentiality as the Receiver deems advisable;
a)o make inquiries of anv recipient financial institution in respect of anv and all
fundstransferreilly_ any of the Defendants to anv related or unrelated arties _
including, but not limited to, the circumstances in which such transfer was
prepared, issued or effected;
other provinces. If this is done, those statutes must be reviewed to ensure that the Receiver is exempt from or can
exemption.
23451639.11
503
DUOS FOR: 177179: \9
6
(k) subject to any applicabl
wh. thefividual Defendants are entitled._to sell, convey, transfer, lease or
assign the Domestic Property or any part or parts thereof out of the ordinary
course of business
(i) without the approval of this Court in respect of any transaction not
exceeding $ ,250,000, provided that the aggregate consideration
for all such transactions does not exceed $ 500,000; and
(ii) with the approval of this Court in respect of any transaction in which the
purchase price or the aggregate purchase price exceeds the applicable
amount set out in the preceding clause;,
and in each such case notice under subsection 63(4) of the Ontario-Personal-
Property Security Act, [PPSA, or section 31 of the Ontario Mortgages Act, as the
case may be,j5 shall not be required,-and-in each case the-Ontario
&hall-net-apply.;
(n) (1) to apply for any vesting order or other orders necessary to convey the Domestic
Property or any part or parts thereof to a purchaser or purchasers thereof, free and
clear of any liens or encumbrances affecting such Domestic Property;
(n) (m)-to report to, meet with and discuss with such affected Persons (as defined
below) as the Receiver deems appropriate on all matters relating to the Domestic
Property and the receivership, and to share information;; subject in all cases to
such terms as to confidentiality as the Receiver deems advisable;
a)o make inquiries of anv recipient financial institution in respect of anv and all
fundstransferreilly_ any of the Defendants to anv related or unrelated arties _
including, but not limited to, the circumstances in which such transfer was
prepared, issued or effected;
other provinces. If this is done, those statutes must be reviewed to ensure that the Receiver is exempt from or can
exemption.
23451639.11
503
DUOS FOR: 177179: \9
6
(k) subject to any applicabl
wh. thefividual Defendants are entitled._to sell, convey, transfer, lease or
assign the Domestic Property or any part or parts thereof out of the ordinary
course of business
(i) without the approval of this Court in respect of any transaction not
exceeding $ ,250,000, provided that the aggregate consideration
for all such transactions does not exceed $ 500,000; and
(ii) with the approval of this Court in respect of any transaction in which the
purchase price or the aggregate purchase price exceeds the applicable
amount set out in the preceding clause;,
and in each such case notice under subsection 63(4) of the Ontario-Personal-
Property Security Act, [PPSA, or section 31 of the Ontario Mortgages Act, as the
case may be,j5 shall not be required,-and-in each case the-Ontario
shall-net-apply.;
(n) (1) to apply for any vesting order or other orders necessary to convey the Domestic
Property or any part or parts thereof to a purchaser or purchasers thereof, free and
clear of any liens or encumbrances affecting such Domestic Property;
(n) (m)-to report to, meet with and discuss with such affected Persons (as defined
below) as the Receiver deems appropriate on all matters relating to the Domestic
Property and the receivership, and to share information;; subject in all cases to
such terms as to confidentiality as the Receiver deems advisable;
a)o make inquiries of anv recipient financial institution in respect of anv and all
fundstransferreilly_ any of the Defendants to anv related or unrelated arties _
including, but not limited to, the circumstances in which such transfer was
prepared, issued or effected;
other provinces. If this is done, those statutes must be reviewed to ensure that the Receiver is exempt from or can
exemption.
23451639.11
503
436)(2S-101(: 1771742\9
- 7 -
(p) 49-to register a copy of this Order and any other Orders in respect of the Domestic
Property against title to any of the Dome ' Property;
01) (e)--to apply for any permits, licences, approvals or permissions as may be required
by any governmental authority and any renewals thereof for and on behalf of and,
if thought desirable by the Receiver, in the name of the Debtorany Defendant;
(1) (p)-to enter into agreements with any trustee in bankruptcy appointed in respect of
the--Debterany Defendant, including, without limiting the generality of the
foregoing, the ability to enter into occupation agreements for any property owned
or leased by the Debtor; any Defendant;
(s) (q-)-to exercise any shareholder, partnership, joint venture or other rights which the-
Debtorany Defendant may have; and
(r) to take any steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations,, including opening any mail addressed
to any Defendant,
and in each case where the Receiver takes any such actions or steps, it shall be exclusively
authorized and empowered to do so, to the exclusion of all other Persons (as defined below),
including the DebterDefendants, and without interference from any other Person.
I
Defendants, including all roceeds thereof to the extent that such assets, undertakings and
properties are located outside of Canada (the "Foreign Property", and together with the
Domestic Pro y the "Pro er "1 and without in any way limiting the generality of the
fore oing. the Receiver is hereby ex ressly empowered and authorized to do any of the following
where th- Receiver considers it necessary or desirable:
(4) to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
$04
23451639.11
436)(2S-101(: 1771742\9
- 7 -
(p) 49-to register a copy of this Order and any other Orders in respect of the Domestic
Property against title to any of the Dome ' Property;
01) (e)--to apply for any permits, licences, approvals or permissions as may be required
by any governmental authority and any renewals thereof for and on behalf of and,
if thought desirable by the Receiver, in the name of the Debtorany Defendant;
(1) (p)-to enter into agreements with any trustee in bankruptcy appointed in respect of
the--Debterany Defendant, including, without limiting the generality of the
foregoing, the ability to enter into occupation agreements for any property owned
or leased by the Debtor; any Defendant;
(s) (q-)-to exercise any shareholder, partnership, joint venture or other rights which the-
Debtorany Defendant may have; and
(r) to take any steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations,, including opening any mail addressed
to any Defendant,
and in each case where the Receiver takes any such actions or steps, it shall be exclusively
authorized and empowered to do so, to the exclusion of all other Persons (as defined below),
including the DebterDefendants, and without interference from any other Person.
I
Defendants, including all roceeds thereof to the extent that such assets, undertakings and
properties are located outside of Canada (the "Foreign Property", and together with the
Domestic Pro y the "Pro er "1 and without in any way limiting the generality of the
fore oing. the Receiver is hereby ex ressly empowered and authorized to do any of the following
where th- Receiver considers it necessary or desirable:
(4) to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
$04
23451639.11
436)(2S-101(: 1771742\9
- 7 -
(p) 49-to register a copy of this Order and any other Orders in respect of the Domestic
Property against title to any of the Dome ' Property;
01) (e)--to apply for any permits, licences, approvals or permissions as may be required
by any governmental authority and any renewals thereof for and on behalf of and,
if thought desirable by the Receiver, in the name of the Debtorany Defendant;
(1) (p)-to enter into agreements with any trustee in bankruptcy appointed in respect of
the--Debterany Defendant, including, without limiting the generality of the
foregoing, the ability to enter into occupation agreements for any property owned
or leased by the Debtor; any Defendant;
(s) (q-)-to exercise any shareholder, partnership, joint venture or other rights which the-
Debtorany Defendant may have; and
(r) to take any steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations,, including opening any mail addressed
to any Defendant,
and in each case where the Receiver takes any such actions or steps, it shall be exclusively
authorized and empowered to do so, to the exclusion of all other Persons (as defined below),
including the DebterDefendants, and without interference from any other Person.
I
Defendants, including all roceeds thereof to the extent that such assets, undertakings and
properties are located outside of Canada (the "Foreign Property", and together with the
Domestic Pro y the "Pro er "1 and without in any way limiting the generality of the
fore oing. the Receiver is hereby ex ressly empowered and authorized to do any of the following
where th- Receiver considers it necessary or desirable:
(4) to access all information relating to the Defendants' accounts or finance activities
at any financial institution, with any trade creditor, with any supplier or with any
third party;
$04
23451639.11
DOCS1 UR: 177171219
8
Q to undertake any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to have
been, Foreign Property, including, without limitation, the transfer of any funds of
the Defendants o anv related or unrelated alb
(g) to report to, meet with and discuss with such affected Persons (as defined below)
lasthe_Reeeiveems__nganpriatenifal attersrelating to the Foreign Property_
and the receivership, and to share information subject in all cases to such terms as
to conficlentiaJity as the Receiver deems advisable., and
(d)to take anv steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations. including o • - t' .1 se • • • • - -• •
any Defendant.
DUTY TO PROVIDE ACCESS AND CO-OPERATION TO THE RECEIVER
4. THIS COURT ORDERS that (i) the DebtecDefendants, (ii) all of itstheir current and
former directors, officers, employees, agents, accountants, legal counsel and shareholders_(as_
applicable), and all other persons acting on its-their instructions or behalf, and (iii) all other
individuals, firms, corporations, governmental bodies or agencies, or other entities having notice
of this Order. including,
financial institutions, or suppliers (all of the foregoing, collectively, being .2."Persons" and each
being a'"_`Person' ") shall forthwith advise the Receiver of the existence of any Property in such
Person'-'s possession or control, shall grant immediate and continued access to the Domestic
Property to the Receiver, and shall deliver all such Domestic Property to the Receiver upon the
Receive's request.
5. THIS COURT ORDERS that all Persons shall forthwith advise the Receiver of the
existence of anyelient_recordsandpre.seription_informatiort, books, documents, securities,
contracts, orders, corporate and accounting records, and any other papers, records and
information of any kind related to the business or affairs of the Debtor,Defendants, any transfers
of money or Property, or obligations incurred by the Defendants, out of the ordinary course of
business or personal conduct and any computer programs, computer tapes, computer disks, or
5o5
23451639 11
DOCS1 UR: 177171219
8
Q to undertake any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to have
been, Foreign Property, including, without limitation, the transfer of any funds of
the Defendants o anv related or unrelated alb
(g) to report to, meet with and discuss with such affected Persons (as defined below)
lasthe_Reeeiveems__nganpriatenifal attersrelating to the Foreign Property_
and the receivership, and to share information subject in all cases to such terms as
to conficlentiaJity as the Receiver deems advisable., and
(d)to take anv steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations. including o • - t' .1 se • • • • - -• •
any Defendant.
DUTY TO PROVIDE ACCESS AND CO-OPERATION TO THE RECEIVER
4. THIS COURT ORDERS that (i) the DebtecDefendants, (ii) all of itstheir current and
former directors, officers, employees, agents, accountants, legal counsel and shareholders_(as_
applicable), and all other persons acting on its-their instructions or behalf, and (iii) all other
individuals, firms, corporations, governmental bodies or agencies, or other entities having notice
of this Order. including,
financial institutions, or suppliers (all of the foregoing, collectively, being .2."Persons" and each
being a'"_`Person' ") shall forthwith advise the Receiver of the existence of any Property in such
Person'-'s possession or control, shall grant immediate and continued access to the Domestic
Property to the Receiver, and shall deliver all such Domestic Property to the Receiver upon the
Receive's request.
5. THIS COURT ORDERS that all Persons shall forthwith advise the Receiver of the
existence of anyelient_recordsandpre.seription_informatiort, books, documents, securities,
contracts, orders, corporate and accounting records, and any other papers, records and
information of any kind related to the business or affairs of the Debtor,Defendants, any transfers
of money or Property, or obligations incurred by the Defendants, out of the ordinary course of
business or personal conduct and any computer programs, computer tapes, computer disks, or
5o5
23451639 11
DOCS1 UR: 177171219
8
Q to undertake any investigations deemed necessary by the Receiver with respect to
the location and/or disposition of assets reasonably believed to be, or to have
been, Foreign Property, including, without limitation, the transfer of any funds of
the Defendants o anv related or unrelated alb
(g) to report to, meet with and discuss with such affected Persons (as defined below)
as the Receiver deems ap ropriate on all matters relating to the Foreign Property
and the receivership, and to share information subject in all cases to such terms as
to confidentiality as the Receiver deems advisable., and
(cl to take anv steps reasonably incidental to the exercise of these powers or the
performance of any statutory obligations. including o • - t' .1 se • • • • - -• •
any Defendant.
DUTY TO PROVIDE ACCESS AND CO-OPERATION TO THE RECEIVER
4. THIS COURT ORDERS that (i) the DebtecDefendants, (ii) all of itsthcir current and
former directors, officers, employees, agents, accountants, legal counsel and shareholders_(as_
applicable), and all other persons acting on its-their instructions or behalf, and (iii) all other
individuals, firms, corporations, governmental bodies or agencies, or other entities having notice
of this Order. including,
financial institutions, or suppliers (all of the foregoing, collectively, being .2."Persons" and each
being a'"_`Person' ") shall forthwith advise the Receiver of the existence of any Property in such
Person'-'s possession or control, shall grant immediate and continued access to the Domestic
Property to the Receiver, and shall deliver all such Domestic Property to the Receiver upon the
Receive's request.
5. THIS COURT ORDERS that all Persons shall forthwith advise the Receiver of the
existence of anyelient_resordsandpre.seription_informatiort, books, documents, securities,
contracts, orders, corporate and accounting records, and any other papers, records and
information of any kind related to the business or affairs of the Debtor,Defendants, any transfers
of money or Property, or obligations incurred by the Defendants, out of the ordinary course of
business or personal conduct and any computer programs, computer tapes, computer disks, or
5o5
23451639 11
-9
other data storage media containing any such information (the foregoing, collectively, the
1"Recordsn.") in that Person!' s possession or control, and shall provide to the Receiver or permit
the Receiver to make, retain and take away copies thereof and grant to the Receiver unfettered
access to and use of accounting, computer, software and physical facilities relating thereto,
provided however that nothing in this paragraph 5 or in paragraph 6 of this Order shall require
the delivery of Records, or the granting of access to Records, which may not be disclosed or
provided to the Receiver due to the privilege attaching to solicitor-client communication or due
to statutory provisions prohibiting such disclosure.
6. THIS COURT ORDERS that if any Records are stored or otherwise contained on a
computer or other electronic system of information storage, whether by independent service
provider or otherwise, all Persons in possession or control of such Records shall forthwith give
unfettered access to the Receiver for the purpose of allowing the Receiver to recover and fully
copy all of the information contained therein whether by way of printing the information onto
paper or making copies of computer disks or such other manner of retrieving and copying the
information as the Receiver in its discretion deems expedient, and shall not alter, erase or destroy
any Records without the prior written consent of the Receiver. Further, for the purposes of this
paragraph, all Persons shall provide the Receiver with all such assistance in gaining immediate
access to the information in the Records as the Receiver may in its discretion require including
providing the Receiver with instructions on the use of any computer or other system and
providing the Receiver with any and all access codes, account names and account numbers that
may be required to gain access to the information.
6A. THIS COURT ORDERS that, in the Records subject to e 'e o'e
Professions Act, 1991, the Pharmacy Act, 1991, the Drug and Pharmacies Regulation Act, 1990
or a other applicable governing nntario or Canadian statute (collectively. the "Pharmacy
1 maintain
of the con
ntario College of Pharmacists ("College", or any pharmacy to which the College directs the
Receiver to provide such Records (iiil if necessary. annoint a pharmacist licensed and qualified
for such Records;
(iv) not allow anyone other than the Receiver, the College, a pharmacy designated by the College
23451639 11
504
-9
other data storage media containing any such information (the foregoing, collectively, the
1"Recordsn.") in that Person!' s possession or control, and shall provide to the Receiver or permit
the Receiver to make, retain and take away copies thereof and grant to the Receiver unfettered
access to and use of accounting, computer, software and physical facilities relating thereto,
provided however that nothing in this paragraph 5 or in paragraph 6 of this Order shall require
the delivery of Records, or the granting of access to Records, which may not be disclosed or
provided to the Receiver due to the privilege attaching to solicitor-client communication or due
to statutory provisions prohibiting such disclosure.
6. THIS COURT ORDERS that if any Records are stored or otherwise contained on a
computer or other electronic system of information storage, whether by independent service
provider or otherwise, all Persons in possession or control of such Records shall forthwith give
unfettered access to the Receiver for the purpose of allowing the Receiver to recover and fully
copy all of the information contained therein whether by way of printing the information onto
paper or making copies of computer disks or such other manner of retrieving and copying the
information as the Receiver in its discretion deems expedient, and shall not alter, erase or destroy
any Records without the prior written consent of the Receiver. Further, for the purposes of this
paragraph, all Persons shall provide the Receiver with all such assistance in gaining immediate
access to the information in the Records as the Receiver may in its discretion require including
providing the Receiver with instructions on the use of any computer or other system and
providing the Receiver with any and all access codes, account names and account numbers that
may be required to gain access to the information.
6A. THIS COURT ORDERS that, in the Records subject to e 'e o'e
Professions Act, 1991, the Pharmacy Act, 1991, the Drug and Pharmacies Regulation Act, 1990
or a other applicable governing nntario or Canadian statute (collectively. the "Pharmacy
1 maintain
of the con
ntario College of Pharmacists ("College", or any pharmacy to which the College directs the
Receiver to provide such Records (iiil if necessary. annoint a pharmacist licensed and qualified
for such Records;
(iv) not allow anyone other than the Receiver, the College, a pharmacy designated by the College
23451639 11
504
-9
other data storage media containing any such information (the foregoing, collectively, the
1"Recordsn.") in that Person!' s possession or control, and shall provide to the Receiver or permit
the Receiver to make, retain and take away copies thereof and grant to the Receiver unfettered
access to and use of accounting, computer, software and physical facilities relating thereto,
provided however that nothing in this paragraph 5 or in paragraph 6 of this Order shall require
the delivery of Records, or the granting of access to Records, which may not be disclosed or
provided to the Receiver due to the privilege attaching to solicitor-client communication or due
to statutory provisions prohibiting such disclosure.
6. THIS COURT ORDERS that if any Records are stored or otherwise contained on a
computer or other electronic system of information storage, whether by independent service
provider or otherwise, all Persons in possession or control of such Records shall forthwith give
unfettered access to the Receiver for the purpose of allowing the Receiver to recover and fully
copy all of the information contained therein whether by way of printing the information onto
paper or making copies of computer disks or such other manner of retrieving and copying the
information as the Receiver in its discretion deems expedient, and shall not alter, erase or destroy
any Records without the prior written consent of the Receiver. Further, for the purposes of this
paragraph, all Persons shall provide the Receiver with all such assistance in gaining immediate
access to the information in the Records as the Receiver may in its discretion require including
providing the Receiver with instructions on the use of any computer or other system and
providing the Receiver with any and all access codes, account names and account numbers that
may be required to gain access to the information.
6A. THIS COURT ORDERS that, in the Records subject to e 'e o'e I
Professions Act, 1991, the Pharmacy Act, 1991, the Drug and Pharmacies Regulation Act, 1990
64
lat><ons"l. the Receiver shall: (il take all steps reasonably necessary to maintain
of the con h
ntario College of Pharmacists ("College", or any pharmacy to which the College directs the
Receiver to provide such Records (iiil if necessary. appoint a pharmacist licensed and qualified
,, for such Records;
(iv) not allow anyone other than the Receiver, the College, a pharmacy designated by the College
23451639 11
504
DQCS•11)R1 1771712W
- 10 -
DLthefatstadian_tohzseacs&astos ,s:(iy)hayeacces,sIQsuc y_
purposcs rewired ursuant to the Pharmacy Regulations that requires e_aefenclanta_fromAinie_
to time, to perform certain obligations.
7. THIS COURT ORDERS that the Receiver shall provide each of the relevant landlords
with notice of the Receiver's intention to remove any fixtures from any leased premises at least
seven (7) days prior to the date of the intended removal. The relevant landlord shall be entitled
to have a representative present in the leased premises to observe such removal and, if the
landlord disputes the Receiver's entitlement to remove any such fixture under the provisions of
the lease, such fixture shall remain on the premises and shall be dealt with as agreed between any
applicable secured creditors, such landlord and the Receiver, or by further Order of this Court
upon application by the Receiver on at least two (2) days notice to such landlord and any such
secured creditors.
NO PROCEEDINGS AGAINST THE RECEIVER
8. THIS COURT ORDERS that no proceeding or enforcement process in any court or
tribunal (each, a il"Proceedingil"), shall be commenced or continued against the Receiver except
with the written consent of the Receiver or with leave of this Court.
NO PROCEEDINGS AGAINST THE D-EBT-ORDEFD OR THE DOMESTIC
PROPERTY
9. THIS COURT ORDERS that no Proceeding inCanadaDDnesticErosteding'1)_
against or in respect of any of the DebtorDefendants or the Domestic Property shall be
commenced or continued except with the written consent of the Receiver or with leave of this
Court3 and, subject to paragraph 37 hereof, any and all Domestic Proceedings currently under
way against or in respect of any of the DebtorDefendants or the Domestic Property are hereby
stayed and suspended pending further Order of this Court.
NO EXERCISE OF RIGHTS OR REMEDIES
10. THIS COURT ORDERS that all rights and remedies against the Debtorany Defendant,
the Receiver, or affecting the Domestic Property, are hereby stayed and suspended except with
sot
23451639 11
DQCS•11)R1 1771712W
- 10 -
DLthefatstadian_tohzseacs&astos ,s:(iy)hayeacces,sIQsuc y_
purposcs rewired ursuant to the Pharmacy Regulations that requires e_aefenclanta_fromAinie_
to time, to perform certain obligations.
7. THIS COURT ORDERS that the Receiver shall provide each of the relevant landlords
with notice of the Receiver's intention to remove any fixtures from any leased premises at least
seven (7) days prior to the date of the intended removal. The relevant landlord shall be entitled
to have a representative present in the leased premises to observe such removal and, if the
landlord disputes the Receiver's entitlement to remove any such fixture under the provisions of
the lease, such fixture shall remain on the premises and shall be dealt with as agreed between any
applicable secured creditors, such landlord and the Receiver, or by further Order of this Court
upon application by the Receiver on at least two (2) days notice to such landlord and any such
secured creditors.
NO PROCEEDINGS AGAINST THE RECEIVER
8. THIS COURT ORDERS that no proceeding or enforcement process in any court or
tribunal (each, a il"Proceedingil"), shall be commenced or continued against the Receiver except
with the written consent of the Receiver or with leave of this Court.
NO PROCEEDINGS AGAINST THE D-EBT-ORDEFD OR THE DOMESTIC
PROPERTY
9. THIS COURT ORDERS that no Proceeding inCanadaDDnesticErosteding'1)_
against or in respect of any of the DebtorDefendants or the Domestic Property shall be
commenced or continued except with the written consent of the Receiver or with leave of this
Court3 and, subject to paragraph 37 hereof, any and all Domestic Proceedings currently under
way against or in respect of any of the DebtorDefendants or the Domestic Property are hereby
stayed and suspended pending further Order of this Court.
NO EXERCISE OF RIGHTS OR REMEDIES
10. THIS COURT ORDERS that all rights and remedies against the Debtorany Defendant,
the Receiver, or affecting the Domestic Property, are hereby stayed and suspended except with
sot
23451639 11
DQCS•11)R1 1771712W
- 10 -
DLtheCllstachan_tohzseacs&astos s:(iy)hayeaccea,stQsuc y_
to time, to perform certain obligations.
7. THIS COURT ORDERS that the Receiver shall provide each of the relevant landlords
with notice of the Receiver's intention to remove any fixtures from any leased premises at least
seven (7) days prior to the date of the intended removal. The relevant landlord shall be entitled
to have a representative present in the leased premises to observe such removal and, if the
landlord disputes the Receiver's entitlement to remove any such fixture under the provisions of
the lease, such fixture shall remain on the premises and shall be dealt with as agreed between any
applicable secured creditors, such landlord and the Receiver, or by further Order of this Court
upon application by the Receiver on at least two (2) days notice to such landlord and any such
secured creditors.
NO PROCEEDINGS AGAINST THE RECEIVER
8. THIS COURT ORDERS that no proceeding or enforcement process in any court or
tribunal (each, a il"Proceedingil"), shall be commenced or continued against the Receiver except
with the written consent of the Receiver or with leave of this Court.
NO PROCEEDINGS AGAINST THE D OR THE DOMESTIC
PROPERTY
9. THIS COURT ORDERS that no Proceeding inCanadaDDnesticErosteding'1)_
against or in respect of any of the DebtorDefendants or the Domestic Property shall be
commenced or continued except with the written consent of the Receiver or with leave of this
Court3 and, subject to paragraph 37 hereof, any and all Domestic Proceedings currently under
way against or in respect of any of the DebtorDefendants or the Domestic Property are hereby
stayed and suspended pending further Order of this Court.
NO EXERCISE OF RIGHTS OR REMEDIES
10. THIS COURT ORDERS that all rights and remedies against the Debtorany Defendant,
the Receiver, or affecting the Domestic Property, are hereby stayed and suspended except with
sot
23451639 11
ROCS I OR: 1771742\9
the written consent of the Receiver or leave of this Court, provided however that this stay and
suspension does not apply in respect of Li)_any —'.`eligible financial contracC" as defined in the
BIA, and rights and
remedies in respect of a Proceeding that is not a Domestic Proceeding, further provided that
nothing in this paragraph shall (ia) empower the Receiver or the Debtorany Defendant to carry on
any business which the Debtorany Defendant is not lawfully entitled to carry on, (it) exempt the
Receiver or the Debtorany Defendant from compliance with statutory or regulatory provisions
relating to health, safety or the environment, prevent the filing of any registration to
preserve or perfect a security interest, or (ivd) prevent the registration of a claim for lien.
NO INTERFERENCE WITH THE RECEIVER
11. THIS COURT ORDERS that no Person shall discontinue, fail to honour, alter, interfere
with, repudiate, terminate or cease to perform any right, renewal right, contract, agreement,
licence or permit in favour of or held by the Debtorany Defendant, without written consent of the
Receiver or leave of this Court.
CONTINUATION OF SERVICES
12. THIS COURT ORDERS that all Persons having oral or written agreements with the-
Debtorany Defendant or statutory or regulatory mandates for the supply of goods and/or services,
including!, without limitation, all computer software, communication and other data services,
centralized banking services, payroll services, insurance, transportation services, utility or other
services to the DebtorDefendant are hereby restrained until further Order of this Court from
discontinuing, altering, interfering with or terminating the supply of such goods or services as
may be required by the Receiver, and that the Receiver shall be entitled to the continued use of
the Debtoriany Defendant's current telephone numbers, facsimile numbers, internet addresses and
domain names, provided in each case that the normal prices or charges for all such goods or
services received after the date of this Order are paid by the Receiver in accordance with normal
payment practices of the Debtorsuch Defendant or such other practices as may be agreed upon by
the supplier or service provider and the Receiver, or as may be ordered by this Court.
507
23451639.11
ROCS I OR: 1771742\9
the written consent of the Receiver or leave of this Court, provided however that this stay and
suspension does not apply in respect of Li)_any —'.`eligible financial contracC" as defined in the
BIA, and rights and
remedies in respect of a Proceeding that is not a Domestic Proceeding, further provided that
nothing in this paragraph shall (ia) empower the Receiver or the Debtorany Defendant to carry on
any business which the Debtorany Defendant is not lawfully entitled to carry on, (it) exempt the
Receiver or the Debtorany Defendant from compliance with statutory or regulatory provisions
relating to health, safety or the environment, prevent the filing of any registration to
preserve or perfect a security interest, or (ivd) prevent the registration of a claim for lien.
NO INTERFERENCE WITH THE RECEIVER
11. THIS COURT ORDERS that no Person shall discontinue, fail to honour, alter, interfere
with, repudiate, terminate or cease to perform any right, renewal right, contract, agreement,
licence or permit in favour of or held by the Debtorany Defendant, without written consent of the
Receiver or leave of this Court.
CONTINUATION OF SERVICES
12. THIS COURT ORDERS that all Persons having oral or written agreements with the-
Debtorany Defendant or statutory or regulatory mandates for the supply of goods and/or services,
including!, without limitation, all computer software, communication and other data services,
centralized banking services, payroll services, insurance, transportation services, utility or other
services to the DebtorDefendant are hereby restrained until further Order of this Court from
discontinuing, altering, interfering with or terminating the supply of such goods or services as
may be required by the Receiver, and that the Receiver shall be entitled to the continued use of
the Debtoriany Defendant's current telephone numbers, facsimile numbers, internet addresses and
domain names, provided in each case that the normal prices or charges for all such goods or
services received after the date of this Order are paid by the Receiver in accordance with normal
payment practices of the Debtorsuch Defendant or such other practices as may be agreed upon by
the supplier or service provider and the Receiver, or as may be ordered by this Court.
507
23451639.11
ROCS I OR: 1771742\9
the written consent of the Receiver or leave of this Court, provided however that this stay and
suspension does not apply in respect of Li)_any —'.`eligible financial contracC" as defined in the
BIA, and rights and
remedies in respect of a Proceeding that is not a Domestic Proceeding, further provided that
nothing in this paragraph shall (ia) empower the Receiver or the Debtorany Defendant to carry on
any business which the Debtorany Defendant is not lawfully entitled to carry on, (it) exempt the
Receiver or the Debtorany Defendant from compliance with statutory or regulatory provisions
relating to health, safety or the environment, prevent the filing of any registration to
preserve or perfect a security interest, or (ivd) prevent the registration of a claim for lien.
NO INTERFERENCE WITH THE RECEIVER
11. THIS COURT ORDERS that no Person shall discontinue, fail to honour, alter, interfere
with, repudiate, terminate or cease to perform any right, renewal right, contract, agreement,
licence or permit in favour of or held by the Debtorany Defendant, without written consent of the
Receiver or leave of this Court.
CONTINUATION OF SERVICES
12. THIS COURT ORDERS that all Persons having oral or written agreements with the-
Debtorany Defendant or statutory or regulatory mandates for the supply of goods and/or services,
including!, without limitation, all computer software, communication and other data services,
centralized banking services, payroll services, insurance, transportation services, utility or other
services to the DebtorDefendant are hereby restrained until further Order of this Court from
discontinuing, altering, interfering with or terminating the supply of such goods or services as
may be required by the Receiver, and that the Receiver shall be entitled to the continued use of
the Debtoriany Defendant's current telephone numbers, facsimile numbers, internet addresses and
domain names, provided in each case that the normal prices or charges for all such goods or
services received after the date of this Order are paid by the Receiver in accordance with normal
payment practices of the Debtorsuch Defendant or such other practices as may be agreed upon by
the supplier or service provider and the Receiver, or as may be ordered by this Court.
507
23451639.11
UOUSTOK: 1771792\9
- 12 -
RECEIVER TO HOLD FUNDS
13. THIS COURT ORDERS that all funds, monies, cheques, instruments, and other forms of
payments received or collected by the Receiver from and after the making of this Order from any
source whatsoever, including., without limitation, the sale of all or any of the Domestic Property
and the collection of any accounts receivable in whole or in part, whether in existence on the date
of this Order or hereafter coming into existence, shall be deposited into one or more new
accounts to be opened by the Receiver (the L"Post Receivership Accounts''!) and the monies
standing to the credit of such Post Receivership Accounts from time to time, net of any
disbursements provided for herein, shall be held by the Receiver to be paid in accordance with
the terms of this Order or any further Order of this Court. The Receiver shall segregate any funds
received by it that constitute Foreign Property, and record and keep such Foreign Property
EMPLOYEES
14. THIS COURT ORDERS that all employees of the DebtorDefendants, if any, shall remain
the employees of the DebtorDefendants until such time as the Receiver, on the
Debtor'5Defendants' behalf, may terminate the employment of such employees. The Receiver
shall not be liable for any employee-related liabilities, including any successor employer
liabilities as provided for in section 14.06(1.2) of the BIA, other than such amounts as the
Receiver may specifically agree in writing to pay, or in respect of its obligations under
f,'ectionssubsectiQns 81.4(5) or 81.6(3) of the BIA or under the Wage Earner Protection Program
Act.
PIPEDA
15. THIS COURT ORDERS that, pursuant to clause 7(3)(c) of the Canada Personal
Information Protection and Electronic Documents Act, the Receiver shall disclose personal
information of identifiable individuals to prospective purchasers or bidders for the Domestic
Property and to their advisors, but only to the extent desirable or required to negotiate and
attempt to complete one or more sales of the Domestic Property (each, a L"Sale"). Each
prospective purchaser or bidder to whom such personal information is disclosed shall maintain
23451639 11
UOUSTOK: 1771792\9
- 12 -
RECEIVER TO HOLD FUNDS
13. THIS COURT ORDERS that all funds, monies, cheques, instruments, and other forms of
payments received or collected by the Receiver from and after the making of this Order from any
source whatsoever, including., without limitation, the sale of all or any of the Domestic Property
and the collection of any accounts receivable in whole or in part, whether in existence on the date
of this Order or hereafter coming into existence, shall be deposited into one or more new
accounts to be opened by the Receiver (the L"Post Receivership Accounts''!) and the monies
standing to the credit of such Post Receivership Accounts from time to time, net of any
disbursements provided for herein, shall be held by the Receiver to be paid in accordance with
the terms of this Order or any further Order of this Court. The Receiver shall segregate any funds
received by it that constitute Foreign Property, and record and keep such Foreign Property
EMPLOYEES
14. THIS COURT ORDERS that all employees of the DebtorDefendants, if any, shall remain
the employees of the DebtorDefendants until such time as the Receiver, on the
Debtor'5Defendants' behalf, may terminate the employment of such employees. The Receiver
shall not be liable for any employee-related liabilities, including any successor employer
liabilities as provided for in section 14.06(1.2) of the BIA, other than such amounts as the
Receiver may specifically agree in writing to pay, or in respect of its obligations under
f,'ectionssubsectiQns 81.4(5) or 81.6(3) of the BIA or under the Wage Earner Protection Program
Act.
PIPEDA
15. THIS COURT ORDERS that, pursuant to clause 7(3)(c) of the Canada Personal
Information Protection and Electronic Documents Act, the Receiver shall disclose personal
information of identifiable individuals to prospective purchasers or bidders for the Domestic
Property and to their advisors, but only to the extent desirable or required to negotiate and
attempt to complete one or more sales of the Domestic Property (each, a L"Sale"). Each
prospective purchaser or bidder to whom such personal information is disclosed shall maintain
23451639 11
UOUSTOK: 1771792\9
- 12 -
RECEIVER TO HOLD FUNDS
13. THIS COURT ORDERS that all funds, monies, cheques, instruments, and other forms of
payments received or collected by the Receiver from and after the making of this Order from any
source whatsoever, including., without limitation, the sale of all or any of the Domestic Property
and the collection of any accounts receivable in whole or in part, whether in existence on the date
of this Order or hereafter coming into existence, shall be deposited into one or more new
accounts to be opened by the Receiver (the L"Post Receivership Accounts''!) and the monies
standing to the credit of such Post Receivership Accounts from time to time, net of any
disbursements provided for herein, shall be held by the Receiver to be paid in accordance with
the terms of this Order or any further Order of this Court. The Receiver shall segregate any funds
received by it that constitute Foreign Property, and record and keep such Foreign Property
EMPLOYEES
14. THIS COURT ORDERS that all employees of the DebtorDefendants, if any, shall remain
the employees of the DebtorDefendants until such time as the Receiver, on the
Debtor'5Defendants' behalf, may terminate the employment of such employees. The Receiver
shall not be liable for any employee-related liabilities, including any successor employer
liabilities as provided for in section 14.06(1.2) of the BIA, other than such amounts as the
Receiver may specifically agree in writing to pay, or in respect of its obligations under
f,'ectionssubsectiQns 81.4(5) or 81.6(3) of the BIA or under the Wage Earner Protection Program
Act.
PIPEDA
15. THIS COURT ORDERS that, pursuant to clause 7(3)(c) of the Canada Personal
Information Protection and Electronic Documents Act, the Receiver shall disclose personal
information of identifiable individuals to prospective purchasers or bidders for the Domestic
Property and to their advisors, but only to the extent desirable or required to negotiate and
attempt to complete one or more sales of the Domestic Property (each, a L"Sale"). Each
prospective purchaser or bidder to whom such personal information is disclosed shall maintain
23451639 11
- 13 -
and protect the privacy of such information and limit the use of such information to its evaluation
of the Sale, and if it does not complete a Sale, shall return all such information to the Receiver, or
in the alternative destroy all such information. The purchaser of any Domestic Property shall be
entitled to continue to use the personal information provided to it, and related to the Domestic
Property purchased, in a manner which is in all material respects identical to the prior use of such
information by the Debtorany Defendant, and shall return all other personal information to the
Receiver, or ensure that all other personal information is destroyed.
LIMITATION ON ENVIRONMENTAL LIABILITIES
16. THIS COURT ORDERS that nothing herein contained shall require the Receiver to
occupy or to take control, care, charge, possession or management (separately and/or collectively,
111Possessioe") of any of the I ornstic Property that might be environmentally contaminated,
might be a pollutant or a contaminant, or might cause or contribute to a spill, discharge, release
or deposit of a substance contrary to any federal, provincial or other law respecting the
protection, conservation, enhancement, remediation or rehabilitation of the environment or
relating to the disposal of waste or other contamination including, without limitation, the
Canadian Environmental Protection Act, the Ontario Environmental Protection Act, the Ontario
Water Resources Act, or the Ontario Occupational Health and Safety Act and regulations
thereunder (the L"Environmental Legislation'"'), provided however that nothing herein shall
exempt the Receiver from any duty to report or make disclosure imposed by applicable
Environmental Legislation. The Receiver shall not, as a result of this Order or anything done in
pursuance of the Receiverl's duties and powers under this Order, be deemed to be in Possession
of any of the Domestic Property within the meaning of any Environmental Legislation, unless it
is actually in possession.
LIMITATION ON THE RECEIVER'S LIABILITY
17. THIS COURT ORDERS that the Receiver shall incur no liability or obligation as a result
of its appointment or the carrying out the provisions of this Order, save and except for any gross
negligence or wilful misconduct on its part, or in respect of its obligations under sections 81.4(5)
er--8-1A-3-)-ef--the-BIA-or-under-the--Wage-Earner---Preteetio;z Progr n--Ac4,-, Nothing in this Order
21451639.11
- 13 -
and protect the privacy of such information and limit the use of such information to its evaluation
of the Sale, and if it does not complete a Sale, shall return all such information to the Receiver, or
in the alternative destroy all such information. The purchaser of any Domestic Property shall be
entitled to continue to use the personal information provided to it, and related to the Domestic
Property purchased, in a manner which is in all material respects identical to the prior use of such
information by the Debtorany Defendant, and shall return all other personal information to the
Receiver, or ensure that all other personal information is destroyed.
LIMITATION ON ENVIRONMENTAL LIABILITIES
16. THIS COURT ORDERS that nothing herein contained shall require the Receiver to
occupy or to take control, care, charge, possession or management (separately and/or collectively,
111Possessioe") of any of the I ornstic Property that might be environmentally contaminated,
might be a pollutant or a contaminant, or might cause or contribute to a spill, discharge, release
or deposit of a substance contrary to any federal, provincial or other law respecting the
protection, conservation, enhancement, remediation or rehabilitation of the environment or
relating to the disposal of waste or other contamination including, without limitation, the
Canadian Environmental Protection Act, the Ontario Environmental Protection Act, the Ontario
Water Resources Act, or the Ontario Occupational Health and Safety Act and regulations
thereunder (the L"Environmental Legislation'"'), provided however that nothing herein shall
exempt the Receiver from any duty to report or make disclosure imposed by applicable
Environmental Legislation. The Receiver shall not, as a result of this Order or anything done in
pursuance of the Receiverl's duties and powers under this Order, be deemed to be in Possession
of any of the Domestic Property within the meaning of any Environmental Legislation, unless it
is actually in possession.
LIMITATION ON THE RECEIVER'S LIABILITY
17. THIS COURT ORDERS that the Receiver shall incur no liability or obligation as a result
of its appointment or the carrying out the provisions of this Order, save and except for any gross
negligence or wilful misconduct on its part, or in respect of its obligations under sections 81.4(5)
er--8-1A-3-)-ef--the-BIA-or-under-the--Wage-Earner---Preteetio;z Progr n--Ac4,-, Nothing in this Order
21451639.11
- 13 -
and protect the privacy of such information and limit the use of such information to its evaluation
of the Sale, and if it does not complete a Sale, shall return all such information to the Receiver, or
in the alternative destroy all such information. The purchaser of any Domestic Property shall be
entitled to continue to use the personal information provided to it, and related to the Domestic
Property purchased, in a manner which is in all material respects identical to the prior use of such
information by the Debtorany Defendant, and shall return all other personal information to the
Receiver, or ensure that all other personal information is destroyed.
LIMITATION ON ENVIRONMENTAL LIABILITIES
16. THIS COURT ORDERS that nothing herein contained shall require the Receiver to
occupy or to take control, care, charge, possession or management (separately and/or collectively,
111Possessioe") of any of the I ornstic Property that might be environmentally contaminated,
might be a pollutant or a contaminant, or might cause or contribute to a spill, discharge, release
or deposit of a substance contrary to any federal, provincial or other law respecting the
protection, conservation, enhancement, remediation or rehabilitation of the environment or
relating to the disposal of waste or other contamination including, without limitation, the
Canadian Environmental Protection Act, the Ontario Environmental Protection Act, the Ontario
Water Resources Act, or the Ontario Occupational Health and Safety Act and regulations
thereunder (the L"Environmental Legislation'"'), provided however that nothing herein shall
exempt the Receiver from any duty to report or make disclosure imposed by applicable
Environmental Legislation. The Receiver shall not, as a result of this Order or anything done in
pursuance of the Receiverl's duties and powers under this Order, be deemed to be in Possession
of any of the Domestic Property within the meaning of any Environmental Legislation, unless it
is actually in possession.
LIMITATION ON THE RECEIVER'S LIABILITY
17. THIS COURT ORDERS that the Receiver shall incur no liability or obligation as a result
of its appointment or the carrying out the provisions of this Order, save and except for any gross
negligence or wilful misconduct on its part, or in respect of its obligations under sections 81.4(5)
er--8-1A-3-)-ef--the-BIA-or-under-the--Wage-Earner---Preteetio;z Progr n--Ac4,-, Nothing in this Order
21451639.11
1344GSTUI{: I 7 7171219
- 14 -
shall derogate from the protections afforded the Receiver by section 14.06 of the BIA or by any
other applicable legislation.
RECEIVER='S ACCOUNTS
18. THIS COURT ORDERS that the Receiver and counsel to the Receiver shall be paid their
reasonable fees and disbursements, in each case at their standard rates and charges unless
otherwise ordered by the Court on the passing of accounts, and that the Receiver and counsel to
the Receiver shall be entitled to and are hereby granted a charge (the 11"Receiverts Charge') on
the Domestic Property, as security for such fees and disbursements, both before and after the
making of this Order in respect of these proceedings, and that the Receiver's Charge shall form a
first charge on theiDomestic Property in priority to all security interests, trusts, liens, charges and
encumbrances, statutory or otherwise , in favour of any Person,-
but-subject-to sections-14,06(-7*-84,4(4*-and-8-1,6{-2)-ef-the BIA.6 other than (a) any validly
perfected security interest under the PPSA, or such other a.. • - • • , • • • er- riority deemed trusts and liens for unpaid em yee source deductions ((al and (bl
ollectivel the "Priori Charges"l.
19. THIS COURT ORDERS that the Receiver and its legal counsel shall pass its accounts
from time to time, and for this purpose the accounts of the Receiver and its legal counsel are
hereby referred to a judge of the Commercial List of the Ontario Superior Court of Justice.
20. THIS COURT ORDERS that prior to the passing of its accounts, the Receiver shall be at
liberty from time to time to apply reasonable amounts, out of the monies in its hands, against its
fees and disbursements, including legal fees and disbursements, incurred at the standard rates and
charges of the Receiver or its counsel, and such amounts shall constitute advances against its
remuneration and disbursements when and as approved by this Court.
FUNDING OF THE RECEIVERSHIP
21. THIS COURT ORDERS that the Receiver be at liberty and it is hereby empowered to
borrow by way of a revolving credit or otherwise, such monies from time to time as it may
6-Nete4hat-sutaseet-ien-24-3-(6)-efthe-BIA-pr-oviEies4hat-the-Coui4-may-net-make-sue-h-an-er-d that-tlie-s-eeured-eredi4ers-who-kveutd-lae-ii reasenable-tietiee-anki-au-opportunity to make representations".
23451639 11
1344GSTUI{: I 7 7171219
- 14 -
shall derogate from the protections afforded the Receiver by section 14.06 of the BIA or by any
other applicable legislation.
RECEIVER='S ACCOUNTS
18. THIS COURT ORDERS that the Receiver and counsel to the Receiver shall be paid their
reasonable fees and disbursements, in each case at their standard rates and charges unless
otherwise ordered by the Court on the passing of accounts, and that the Receiver and counsel to
the Receiver shall be entitled to and are hereby granted a charge (the 11"Receiverts Charge') on
the Domestic Property, as security for such fees and disbursements, both before and after the
making of this Order in respect of these proceedings, and that the Receiver's Charge shall form a
first charge on theiDomestic Property in priority to all security interests, trusts, liens, charges and
encumbrances, statutory or otherwise , in favour of any Person,-
but-subject-to sections-14,06(-7*-84,4(4*-and-8-1,6{-2)-ef-the BIA.6 other than (a) any validly
perfected security interest under the PPSA, or such other a.. • - • • , • • • er- riority deemed trusts and liens for unpaid em yee source deductions ((al and (bl
ollectivel the "Priori Charges"l.
19. THIS COURT ORDERS that the Receiver and its legal counsel shall pass its accounts
from time to time, and for this purpose the accounts of the Receiver and its legal counsel are
hereby referred to a judge of the Commercial List of the Ontario Superior Court of Justice.
20. THIS COURT ORDERS that prior to the passing of its accounts, the Receiver shall be at
liberty from time to time to apply reasonable amounts, out of the monies in its hands, against its
fees and disbursements, including legal fees and disbursements, incurred at the standard rates and
charges of the Receiver or its counsel, and such amounts shall constitute advances against its
remuneration and disbursements when and as approved by this Court.
FUNDING OF THE RECEIVERSHIP
21. THIS COURT ORDERS that the Receiver be at liberty and it is hereby empowered to
borrow by way of a revolving credit or otherwise, such monies from time to time as it may
6-Nete4hat-sutaseet-ien-24-3-(6)-efthe-BIA-pr-oviEies4hat-the-Coui4-may-net-make-sue-h-an-er-d that-tlie-s-eeured-eredi4ers-who-kveutd-lae-ii reasenable-tietiee-anki-au-opportunity to make representations".
23451639 11
1344GSTUI{: I 7 7171219
- 14 -
shall derogate from the protections afforded the Receiver by section 14.06 of the BIA or by any
other applicable legislation.
RECEIVER='S ACCOUNTS
18. THIS COURT ORDERS that the Receiver and counsel to the Receiver shall be paid their
reasonable fees and disbursements, in each case at their standard rates and charges unless
otherwise ordered by the Court on the passing of accounts, and that the Receiver and counsel to
the Receiver shall be entitled to and are hereby granted a charge (the 11"Receiverts Charge') on
the Domestic Property, as security for such fees and disbursements, both before and after the
making of this Order in respect of these proceedings, and that the Receiver's Charge shall form a
first charge on the Pomestic Property in priority to all security interests, trusts, liens, charges and
encumbrances, statutory or otherwise , in favour of any Person,-
but-subject-to sections-14,06(-7*-84,4(4*-and-8-1,6{-2)-ef-the BIA.6 other than (a) any validly
perfected security interest under the PPSA, or such other a.. • - • • , • • . • er- riority deemed trusts and liens for unpaid em yee source deductions ((al and (bl
ollectivel the "Priori gml.
19. THIS COURT ORDERS that the Receiver and its legal counsel shall pass its accounts
from time to time, and for this purpose the accounts of the Receiver and its legal counsel are
hereby referred to a judge of the Commercial List of the Ontario Superior Court of Justice.
20. THIS COURT ORDERS that prior to the passing of its accounts, the Receiver shall be at
liberty from time to time to apply reasonable amounts, out of the monies in its hands, against its
fees and disbursements, including legal fees and disbursements, incurred at the standard rates and
charges of the Receiver or its counsel, and such amounts shall constitute advances against its
remuneration and disbursements when and as approved by this Court.
FUNDING OF THE RECEIVERSHIP
21. THIS COURT ORDERS that the Receiver be at liberty and it is hereby empowered to
borrow by way of a revolving credit or otherwise, such monies from time to time as it may
6-Nete4hat-sutaseet-ien-24-3-(6)-efthe-BIA-pr-oviEies4hat-the-Coui4-may-net-make-sue-h-an-er-d tha4-thesued creditors wha would be matorially affected by theorder•wero.given..reao opportunity to make representations".
DUCSTUR: 1771742 \
- 15 -
consider necessary or desirable, provided that the outstanding principal amount does not exceed
150,000 (or such greater amount as this Court may by further Order authorize) at any
time, at such rate or rates of interest as it deems advisable for such period or periods of time as it
may arrange, for the purpose of funding the exercise of the powers and duties conferred upon the
Receiver by this Order, including interim expenditures. The whole of the Domestic Property
shall be and is hereby charged by way of a fixed and specific charge (the E"Receiverl's
Borrowings Charge") as security for the payment of the monies borrowed, together with
interest and charges thereon, in priority to all secufity interests, trusts, 'ie»s, charges and
,Encumbrances in favour of any Person, but subordinate in
prieritHeother than the Priority Charg- the Receiver's Charge-and--t-h-e-eharges-as-set-eut--m--
sections 14.06(7), 81.4(4), and 81.6(2) of the BIA.
22. THIS COURT ORDERS that neither the Receivers Charge, Receive 's Borrowings
Charge nor any other security granted by the Receiver in connection with its borrowings under
this Order shall be enforced without leave of this Court.
23. THIS COURT ORDERS that the Receiver is at liberty and authorized to issue certificates
substantially in the form annexed as Schedule L"AL" . hereto (the 2."Receiver's Certificatesl!") for
any amount borrowed by it pursuant to this Order.
24. THIS COURT ORDERS that the monies from time to time borrowed by the Receiver
pursuant to this Order or any further order of this Court and any and all Receiver's Certificates
evidencing the same or any part thereof shall rank on a pari passu basis, unless otherwise agreed
to by the holders of any prior issued Receiver's Certificates.
25. THIS COURT ORDERS that the Plaintiff or the Receiver shall be entitled, on a
subsequent motion on not less than seven ( ) days' notice to those Persons likely to he affected
thereby, to seek priority of the Receiver's Charge and/or the Receiver's Borrowings Charge,
ahead f anv i •
23451639,11
DUCSTUR: 1771742 \
- 15 -
consider necessary or desirable, provided that the outstanding principal amount does not exceed
150,000 (or such greater amount as this Court may by further Order authorize) at any
time, at such rate or rates of interest as it deems advisable for such period or periods of time as it
may arrange, for the purpose of funding the exercise of the powers and duties conferred upon the
Receiver by this Order, including interim expenditures. The whole of the Domestic Property
shall be and is hereby charged by way of a fixed and specific charge (the E"Receiverl's
Borrowings Charge") as security for the payment of the monies borrowed, together with
interest and charges thereon, in priority to all secufity interests, trusts, 'ie»s, charges and
,Encumbrances in favour of any Person, but subordinate in
prieritHeother than the Priority Charg- the Receiver's Charge-and--t-h-e-eharges-as-set-eut--m--
sections 14.06(7), 81.4(4), and 81.6(2) of the BIA.
22. THIS COURT ORDERS that neither the Receivers Charge, Receive 's Borrowings
Charge nor any other security granted by the Receiver in connection with its borrowings under
this Order shall be enforced without leave of this Court.
23. THIS COURT ORDERS that the Receiver is at liberty and authorized to issue certificates
substantially in the form annexed as Schedule L"AL" . hereto (the 2."Receiver's Certificatesl!") for
any amount borrowed by it pursuant to this Order.
24. THIS COURT ORDERS that the monies from time to time borrowed by the Receiver
pursuant to this Order or any further order of this Court and any and all Receiver's Certificates
evidencing the same or any part thereof shall rank on a pari passu basis, unless otherwise agreed
to by the holders of any prior issued Receiver's Certificates.
25. THIS COURT ORDERS that the Plaintiff or the Receiver shall be entitled, on a
subsequent motion on not less than seven ( ) days' notice to those Persons likely to he affected
thereby, to seek priority of the Receiver's Charge and/or the Receiver's Borrowings Charge,
ahead f anv i •
23451639,11
DUCSTUR: 1771742 \
- 15 -
consider necessary or desirable, provided that the outstanding principal amount does not exceed
150,000 (or such greater amount as this Court may by further Order authorize) at any
time, at such rate or rates of interest as it deems advisable for such period or periods of time as it
may arrange, for the purpose of funding the exercise of the powers and duties conferred upon the
Receiver by this Order, including interim expenditures. The whole of the Domestic Property
shall be and is hereby charged by way of a fixed and specific charge (the E"Receiverl's
Borrowings Charge") as security for the payment of the monies borrowed, together with
interest and charges thereon, in priority to all secufity interests, trusts, 'ie»s, charges and
,Encumbrances in favour of any Person, but subordinate in
prieritHeother than the Priority Charg- the Receiver's Charge-and--t-h-e-eharges-as-set-eut--m--
sections 14.06(7), 81.4(4), and 81.6(2) of the BIA.
22. THIS COURT ORDERS that neither the Receivers Charge, Receive 's Borrowings
Charge nor any other security granted by the Receiver in connection with its borrowings under
this Order shall be enforced without leave of this Court.
23. THIS COURT ORDERS that the Receiver is at liberty and authorized to issue certificates
substantially in the form annexed as Schedule L"AL" . hereto (the 2."Receiver's Certificatesl!") for
any amount borrowed by it pursuant to this Order.
24. THIS COURT ORDERS that the monies from time to time borrowed by the Receiver
pursuant to this Order or any further order of this Court and any and all Receiver's Certificates
evidencing the same or any part thereof shall rank on a pari passu basis, unless otherwise agreed
to by the holders of any prior issued Receiver's Certificates.
25. THIS COURT ORDERS that the Plaintiff or the Receiver shall be entitled, on a
subsequent motion on not less than seven ( ) days' notice to those Persons likely to he affected
thereby, to seek priority of the Receiver's Charge and/or the Receiver's Borrowings Charge,
ahead f anv i •
23451639,11
DUCSTURI 1771712\9
- 16 -
SERVICE AND NOTICE
25—THIS COURT ORDERS that the E-Service Protocol of the Commercial List (the
"Protocol") is approved and adopted by reference herein and, in this—proceed-Ingthtse_
proceedings, the service of documents made in accordance with the Protocol (which can be found
on the Commercial List website at
httpf/-Avww,ont-arioceurts,ea/-sej ractIce-/-practiee-dire-c-ti onsitterontole-serviec-protocallhl/p : //./
shall be valid
and effective service. Subject to Rule 17.05 of the Ontario Rules of Civil Procedure (the
"Rules"), this Order shall constitute an order for substituted service pursuant to Rule 16.04 of the
Rules of Civil Procedure. Subject to Rule 3.01(d) of the Rules of Civil Procedure and paragraph
21 of the Protocol, service of documents in accordance with the Protocol will be effective on
transmission. This Court further orders that a Case Website shall be established in accordance
with the Protocol with the following URL: alvarezandmarsal.com/mdhealth.
27. 26-.--THIS COURT ORDERS that if the service or distribution of documents in
accordance with the Protocol is not practicable, the Receiver is at liberty to serve or distribute
this Order, any other materials and orders in these proceedings, any notices or other
correspondence, by forwarding true copies thereof by prepaid ordinary mail, courier, personal
delivery or facsimile transmission to the Debtor'sDefendants' creditors or other interested parties
at their respective addresses as last shown on the records of the DebtorDefendants and that any
such service or distribution by courier, personal delivery or facsimile transmission shall be
deemed to be received on the next business day following the date of forwarding thereof, or if
sent by ordinary mail, on the third business day after mailing.
GENERAL
2_8,, 27. THIS COURT ORDERS that the Receiver may from time to time apply to this Court
for advice and directions in the discharge of its powers and duties hereunder.
29. 2-8,-THIS COURT ORDERS that nothing in this Order shall prevent the Receiver from
acting as a trustee in bankruptcy of the Debtorany Defendant.
23451639 11
DUCSTURI 1771712\9
- 16 -
SERVICE AND NOTICE
25—THIS COURT ORDERS that the E-Service Protocol of the Commercial List (the
"Protocol") is approved and adopted by reference herein and, in this—proceed-Ingthtse_
proceedings, the service of documents made in accordance with the Protocol (which can be found
on the Commercial List website at
httpf/-Avww,ont-arioceurts,ea/-sej ractIce-/-practiee-dire-c-ti onsitterontole-serviec-protocallhl/p : //./
shall be valid
and effective service. Subject to Rule 17.05 of the Ontario Rules of Civil Procedure (the
"Rules"), this Order shall constitute an order for substituted service pursuant to Rule 16.04 of the
Rules of Civil Procedure. Subject to Rule 3.01(d) of the Rules of Civil Procedure and paragraph
21 of the Protocol, service of documents in accordance with the Protocol will be effective on
transmission. This Court further orders that a Case Website shall be established in accordance
with the Protocol with the following URL: alvarezandmarsal.com/mdhealth.
27. 26-.--THIS COURT ORDERS that if the service or distribution of documents in
accordance with the Protocol is not practicable, the Receiver is at liberty to serve or distribute
this Order, any other materials and orders in these proceedings, any notices or other
correspondence, by forwarding true copies thereof by prepaid ordinary mail, courier, personal
delivery or facsimile transmission to the Debtor'sDefendants' creditors or other interested parties
at their respective addresses as last shown on the records of the DebtorDefendants and that any
such service or distribution by courier, personal delivery or facsimile transmission shall be
deemed to be received on the next business day following the date of forwarding thereof, or if
sent by ordinary mail, on the third business day after mailing.
GENERAL
2_8,, 27. THIS COURT ORDERS that the Receiver may from time to time apply to this Court
for advice and directions in the discharge of its powers and duties hereunder.
29. 2-8,-THIS COURT ORDERS that nothing in this Order shall prevent the Receiver from
acting as a trustee in bankruptcy of the Debtorany Defendant.
23451639 11
DUCSTURI 1771712\9
- 16 -
SERVICE AND NOTICE
25—THIS COURT ORDERS that the E-Service Protocol of the Commercial List (the
"Protocol") is approved and adopted by reference herein and, in thi-s—proceedIngthtse_
roceedin• s, the service of documents made in accordance with the Protocol (which can be found
on the Commercial List website at
httpf/-Avww,ont-arieceurts,ea/-sej ractic-e-/-practiee-dire-c-ti onsitterontole-service-protocallhl/p : //./
shall be valid
and effective service. Subject to Rule 17.05 of the Ontario Rules of Civil Procedure (the
"Rules"), this Order shall constitute an order for substituted service pursuant to Rule 16.04 of the
Rules of Civil Procedure. Subject to Rule 3.01(d) of the Rules of Civil Procedure and paragraph
21 of the Protocol, service of documents in accordance with the Protocol will be effective on
transmission. This Court further orders that a Case Website shall be established in accordance
with the Protocol with the following URL: alvarezandmarsal.com/mdhealth.
27. 26,-THIS COURT ORDERS that if the service or distribution of documents in
accordance with the Protocol is not practicable, the Receiver is at liberty to serve or distribute
this Order, any other materials and orders in these proceedings, any notices or other
correspondence, by forwarding true copies thereof by prepaid ordinary mail, courier, personal
delivery or facsimile transmission to the Debtor'sDefendants' creditors or other interested parties
at their respective addresses as last shown on the records of the DebtorDefendants and that any
such service or distribution by courier, personal delivery or facsimile transmission shall be
deemed to be received on the next business day following the date of forwarding thereof, or if
sent by ordinary mail, on the third business day after mailing.
GENERAL
2_8,, 27. THIS COURT ORDERS that the Receiver may from time to time apply to this Court
for advice and directions in the discharge of its powers and duties hereunder.
29. 2-8,-THIS COURT ORDERS that nothing in this Order shall prevent the Receiver from
acting as a trustee in bankruptcy of the Debtorany Defendant.
23451639 11
DOCS.101k: 177171...19
-17-
30. 29,-THIS COURT HEREBY REQUESTS the aid and recognition of any court, tribunal,
regulatory or administrative body having jurisdiction in Canada or in the United Statesany_
foreign jurisdiction to give effect to this Order and to assist the Receiver and its agents in
carrying out the terms of this Order. All courts, tribunals, regulatory and administrative bodies
are hereby respectfully requested to make such orders and to provide such assistance to the
Receiver, as an officer of this Court, as may be necessary or desirable to give effect to this Order
or to assist the Receiver and its agents in carrying out the terms of this Order.
31 30. THIS COURT ORDERS that the Receiver be at liberty and is hereby authorized and
empowered to apply to any court, tribunal, regulatory or administrative body, wherever located,
for the recognition of this Order and for assistance in carrying out the terms of this Order, and
that the Receiver is authorized and empowered to act as a representative in respect of the within
proceedings for the purpose of having these proceedings recognized in a jurisdiction outside
Canada.
32 31. THIS COURT ORDERS that the Plaintiff shall have its costs of this motion, up to
and including entry and service of this Order, provided for byand the termscosts of the Plaintiff's
see.-Lif ity ided-by-the-Plaint4f€ssecurity-then-en-a--substaiiti-almotio to obtain en--a--substaiitial e_
Mareva Orders, in each case on a full indemnity basis to be paid by the Receiver from the
Debtees--estateDefendants' estates with such priority and at such time as this Court may
determine.
misCELLANEDEsANDTROcEDERAL_MATTERS_
31 32. THIS COURT ORDERS that any interested party may apply to this Court to vary or
amend this Order on not less than seven (7) days!' notice to the Receiver and to any other party
likely to be affected by the order sought or upon such other notice, if any, as this Court may
order.
3.4._ THIS COURT ORDERS that the Plaintiff is granted leave to bring this motion without
notice
35. THIS COURT ORDERS that the Motion Record fora Receiver the Factum and Book of
Allthorities.01thePlaintiff,_alLstatedSepteral
23451639 H
5124 DOCS.101k: 177171...19
-17-
30. 29,-THIS COURT HEREBY REQUESTS the aid and recognition of any court, tribunal,
regulatory or administrative body having jurisdiction in Canada or in the United Statesany_
foreign jurisdiction to give effect to this Order and to assist the Receiver and its agents in
carrying out the terms of this Order. All courts, tribunals, regulatory and administrative bodies
are hereby respectfully requested to make such orders and to provide such assistance to the
Receiver, as an officer of this Court, as may be necessary or desirable to give effect to this Order
or to assist the Receiver and its agents in carrying out the terms of this Order.
31 30. THIS COURT ORDERS that the Receiver be at liberty and is hereby authorized and
empowered to apply to any court, tribunal, regulatory or administrative body, wherever located,
for the recognition of this Order and for assistance in carrying out the terms of this Order, and
that the Receiver is authorized and empowered to act as a representative in respect of the within
proceedings for the purpose of having these proceedings recognized in a jurisdiction outside
Canada.
32 31. THIS COURT ORDERS that the Plaintiff shall have its costs of this motion, up to
and including entry and service of this Order, provided for byand the termscosts of the Plaintiff's
see.-Lif ity ided-by-the-Plaint4f€ssecurity-then-en-a--substaiiti-almotio to obtain en--a--substaiitial e_
Mareva Orders, in each case on a full indemnity basis to be paid by the Receiver from the
Debtees--estateDefendants' estates with such priority and at such time as this Court may
determine.
misCELLANEDEsANDTROcEDERAL_MATTERS_
31 32. THIS COURT ORDERS that any interested party may apply to this Court to vary or
amend this Order on not less than seven (7) days!' notice to the Receiver and to any other party
likely to be affected by the order sought or upon such other notice, if any, as this Court may
order.
3.4._ THIS COURT ORDERS that the Plaintiff is granted leave to bring this motion without
notice
35. THIS COURT ORDERS that the Motion Record fora Receiver the Factum and Book of
Allthorities.01thePlaintiff,_alLstatedSepteral
23451639 H
5124 DOCS.101k: 177171...19
-17-
30. 29,-THIS COURT HEREBY REQUESTS the aid and recognition of any court, tribunal,
regulatory or administrative body having jurisdiction in Canada or in the United Statesany_
foreign jurisdiction to give effect to this Order and to assist the Receiver and its agents in
carrying out the terms of this Order. All courts, tribunals, regulatory and administrative bodies
are hereby respectfully requested to make such orders and to provide such assistance to the
Receiver, as an officer of this Court, as may be necessary or desirable to give effect to this Order
or to assist the Receiver and its agents in carrying out the terms of this Order.
31 30. THIS COURT ORDERS that the Receiver be at liberty and is hereby authorized and
empowered to apply to any court, tribunal, regulatory or administrative body, wherever located,
for the recognition of this Order and for assistance in carrying out the terms of this Order, and
that the Receiver is authorized and empowered to act as a representative in respect of the within
proceedings for the purpose of having these proceedings recognized in a jurisdiction outside
Canada.
32 31. THIS COURT ORDERS that the Plaintiff shall have its costs of this motion, up to
and including entry and service of this Order, provided for byand the termscosts of the Plaintiff's
see.-Lif ity ided-by-the-Plaint4f€securitythenn-en-a--substaiiti-almotio to obtain en--a--substaiitial e_
Mareva Orders, in each case on a full indemnity basis to be paid by the Receiver from the
Debtees--estateDefendants' estates with such priority and at such time as this Court may
determine.
misCELLANEDEsANDTROcEDERAL_MATTERS_
31 32. THIS COURT ORDERS that any interested party may apply to this Court to vary or
amend this Order on not less than seven (7) days!' notice to the Receiver and to any other party
likely to be affected by the order sought or upon such other notice, if any, as this Court may
order.
3.4._ THIS COURT ORDERS that the Plaintiffisgxan t,
notice
35. THIS COURT ORDERS that the Motion Record fora Receiver the Factum and Book of
Allthorities.01thePlaintiff,_alLstatedSepteral
23451639 H
5124
DOUSiUR: 1771711.\9
- 18 -
for the parties in thi proceeding andtheir respective legal counsel until five ( 1 daysf he
3_6_ THIS COURT ORDERS that this Order:
a may be provided by the R c eiv r o s ,ch persons at such times as lie Re ivet in
its sole discretion deems necessary or advisable to permit or assist the Receiver in
j shall be served on the persons listed on the Service List attached at Schedule "B" hereto in accordanc with p phs 26 and 27 of this Order within en days of
the date of this Order or at such earlier time at the Receiver main determine in its
discretion.
PLAINTIFF'S MOTION FOR JUDGMENT
31. THIS CO RT ORDER hat no withstanding p g phs 9 and l0 of thi Ord r the Plaintiff is granted leave to (al bri g a motion forjugment in this cti „ and t take out any iudgment or order arising therefrom (bl take any steps in fu thelance of or that foll w rr m such
iudgment or order ( xcept to the exten such steps wo„ ld interfere with he Receiver's exclusive
now_ e> n paragraph 2 of this Order (c) bring any motion to add parties to this a tion (dl tale
anysteALtoufaccanyiudgmentaorclerinaPracetdingthaLtsnDL saDomestiQPro=ding._ and (el take any steps permitted by the Mareva Orders and/n to bring any motion to va y or amend the Mareva Orders, in each case without further notice to the Defendants unless required b law The Plaintiff's motion for 'ud m n s al r urea 1 a da s _ is uit at a 9.30 appointment.
CONTINUATION OF THE MAREVA ORDERS
3_8_ THIS COURT ORDERS that the Mareva Orders shall not in any way affect or limit the powers and duties of the Receiver conferred • this Order
39. THIS COURT ORDERS that the Receiver shall disclose to the Plaintiff all relevant information acquired or received by the Receiver regarding the Defendants the Domestic
23451639 11
615 DOUSiUR: 1771711.\9
- 18 -
for the parties in thi proceeding andtheir respective legal counsel until five (1 daysf he
3_6_ THIS COURT ORDERS that this Order:
a may be provided by the R c eiv r o s ,ch persons at such times as lie Re ivet in
its sole discretion deems necessary or advisable to permit or assist the Receiver in
j shall be served on the persons listed on the Service List attached at Schedule "B" hereto in accordanc with p phs 26 and 27 of this Order within en days of
the date of this Order or at such earlier time at the Receiver main determine in its
discretion.
PLAINTIFF'S MOTION FOR JUDGMENT
31. THIS CO RT ORDER hat no withstanding p g phs 9 and l0 of thi Ord r the Plaintiff is granted leave to (al bri g a motion forjugment in this cti „ and t take out any iudgment or order arising therefrom (bl take any steps in fu thelance of or that foll w rr m such
iudgment or order ( xcept to the exten such steps wo„ld interfere with he Receiver's exclusive
now_ e> n paragraph 2 of this Order (c) bring any motion to add parties to this a tion (dl tale
anysteALtoufaccanyiudgmentaorclerinaPracetdingthaLtsnDL saDomestiQPro=ding._ and (el take any steps permitted by the Mareva Orders and /n to bring any motion to va y or amend the Mareva Orders, in each case without further notice to the Defendants unless required b law The Plaintiff's motion for 'ud m n s al r urea 1 a da s _ is uit at a 9.30 appointment.
CONTINUATION OF THE MAREVA ORDERS
3_8_ THIS COURT ORDERS that the Mareva Orders shall not in any way affect or limit the powers and duties of the Receiver conferred • this Order
39. THIS COURT ORDERS that the Receiver shall disclose to the Plaintiff all relevant information acquired or received by the Receiver regarding the Defendants the Domestic
23451639 11
615 DOUSiUR: 1771711.\9
- 18 -
• ) ar hereby sealed any that no one shall have access to the c of a M + •
for the parties in thi proceeding andtheir respective legal counsel until five ( 1 daysf he
3_6_ THIS COURT ORDERS that this Order:
its sole discretion deems necessary or advisable to permit or assist the Receiver in
j shall be served on the persons listed on the Service List attached at Schedule "B" hereto in accordanc with p phs 26 and 27 of this Order within en clays of
the date of this Order or at such earlier time at the Receiver main determine in its
discretion.
PLAINTIFF'S MOTION FOR JUDGMENT
31. THIS CO RT ORDER hat no withstanding pgphs 9 and 10 of thi Ord r the Plaintiff is granted leave to (al bri e a motion forjuement in this
cti „ and t take out any iudgment or order arising therefrom (b) take any steps in furtherance of or that foll w rr m such
judgment or order ( xcept to the exten such steps wo„ ld interfere with he Receiver's exclusive
now_ e> n paragraph 2 of this Order (c) bring any motion to add parties to this a tion (dl tale
any step_s tomfaceanyiudgmentaorclerinaPracetdingthaLtsmtsaDomesticProuesthig._
and (el take any steps permitted by the Mareva Orders and /n to bring any motion to va y or amend the Mareva Orders, in each case without further notice to the Defendants unless required b law The Plaintiff's motion for 'ud m n s al r urea 1 a da s _ is uit at a 9.30 appointment.
CONTINUATION OF THE MAREVA ORDERS
3_8_ THIS COURT ORDERS that the Mareva Orders shall not in any way affect or limit the powers and duties of the Receiver conferred • this Order
39. THIS COURT ORDERS that the Receiver shall disclose to the Plaintiff all relevant information acquired or received by the Receiver regarding the Defendants the Domestic
23451639 11
615
DOLS I UR: 171171219 94. - 19 -
Property, and the Foreign Property, subject in all cases to such terms as to confidentiality as the
Receiver deems advisable,
40_
remain in full force and effect in all other respects.
41 THIS COURT ORDERS that TD Canada Trust forthwith freeze and preventany removal
urther Order of the Court.
42. THIS COURT ORDERS that TD Canada Trust forthwith disclose and deliver up to the
43.
23451639 11
DOLS I UR: 171171219 94. - 19 -
Property, and the Foreign Property, subject in all cases to such terms as to confidentiality as the
Receiver deems advisable,
40_
remain in full force and effect in all other respects.
41 THIS COURT ORDERS that TD Canada Trust forthwith freeze and preventany removal
urther Order of the Court.
42. THIS COURT ORDERS that TD Canada Trust forthwith disclose and deliver up to the
43.
23451639 11
DOLS I UR: 171171219 94. - 19 -
Property, and the Foreign Property, subject in all cases to such terms as to confidentiality as the
Receiver deems advisable,
40_
remain in full force and effect in all other respects.
41 THIS COURT ORDERS that TD Canada Trust forthwith freeze and preventany removal
urther Order of the Court.
42. THIS COURT ORDERS that TD Canada Trust forthwith disclose and deliver up to the
43.
23451639 11
Sr?'
SCHEDULE
RECEIVER CERTIFICATE
CERTIFICATE NO.
AMOUNT $
-1,-L_THIS IS TO CERTIFY that {RECEIVER'S NAME]Alvarez & Marsal Canada Inc., the
receiver (the ItReceivern of all of assets, undertakings and properties [DEBTORS NAME]
aequifeil-fer-,--er---usefl-in-relatien-te-a-hu-s-iness-c-afr-i-e-E1-eny tlie-Debterof Sameh Sadek also
nown as Sam Sadek. St. Maharial Pharmacy Inc. dba MD Hea th Pharmacy. St. Maharial Clinic
Inc., SRX Investment Inc , Shepherd RX Pharmacy Inc. and Lilian Fam, including all proceeds
thereof, to the extent such assets, undertakings and properties are located in Canada (collectively,
the "Domestic Property") appointed by Order of the Ontario Superior Court of Justice
(Commercial List) (the L'2_,CourtL':) dated the 11th day of , 20_September, 2018 (the
11"_`Order'-"') made in an action having Court file number —CV-18-602745-00-CL , has
received as such Receiver from the holder of this certificate (the L"L en d e r•L") the principal sum
of $ , being part of the total principal sum of $ which the Receiver is
authorized to borrow under and pursuant to the Order.
2. 2. The principal sum evidenced by this certificate is payable on demand by the Lender with
interest thereon calculated and compounded [daily][monthly not in advance on the day
of each month] after the date hereof at a notional rate per annum equal to the rate of per
cent above the prime commercial lending rate of Bank of from time to time.
3. 3. Such principal sum with interest thereon is, by the terms of the Order, together with the
principal sums and interest thereon of all other certificates issued by the Receiver pursuant to the
Order or to any further order of the Court, a charge upon the whole of the Domestic Property, in
priority to the security interests of any other person (other than the Priority Charges, as defined in
the Order), but subject to the priority of the charges set out in the Order and in the Bankruptcy
and Insolvency Act, R S C 1985, c B-3 (the "BIA"), and the right of the Receiver to indemnify
itself out of such Property in respect of its remuneration and expenses.
23451639.11
Sr?'
SCHEDULE
RECEIVER CERTIFICATE
CERTIFICATE NO.
AMOUNT $
-1,-L_THIS IS TO CERTIFY that {RECEIVER'S NAME]Alvarez & Marsal Canada Inc., the
receiver (the ItReceivern of all of assets, undertakings and properties [DEBTORS NAME]
aequifeil-fer-,--er---usefl-in-relatien-te-a-hu-s-iness-c-afr-i-e-E1-eny tlie-Debterof Sameh Sadek also
nown as Sam Sadek. St. Maharial Pharmacy Inc. dba MD Hea th Pharmacy. St. Maharial Clinic
Inc., SRX Investment Inc , Shepherd RX Pharmacy Inc. and Lilian Fam, including all proceeds
thereof, to the extent such assets, undertakings and properties are located in Canada (collectively,
the "Domestic Property") appointed by Order of the Ontario Superior Court of Justice
(Commercial List) (the L'2_,CourtL':) dated the 11th day of , 20_September, 2018 (the
11"_`Order'-"') made in an action having Court file number —CV-18-602745-00-CL , has
received as such Receiver from the holder of this certificate (the L"L en d e r•L") the principal sum
of $ , being part of the total principal sum of $ which the Receiver is
authorized to borrow under and pursuant to the Order.
2. 2. The principal sum evidenced by this certificate is payable on demand by the Lender with
interest thereon calculated and compounded [daily][monthly not in advance on the day
of each month] after the date hereof at a notional rate per annum equal to the rate of per
cent above the prime commercial lending rate of Bank of from time to time.
3. 3. Such principal sum with interest thereon is, by the terms of the Order, together with the
principal sums and interest thereon of all other certificates issued by the Receiver pursuant to the
Order or to any further order of the Court, a charge upon the whole of the Domestic Property, in
priority to the security interests of any other person (other than the Priority Charges, as defined in
the Order), but subject to the priority of the charges set out in the Order and in the Bankruptcy
and Insolvency Act, R S C 1985, c B-3 (the "BIA"), and the right of the Receiver to indemnify
itself out of such Property in respect of its remuneration and expenses.
23451639.11
Sr?'
SCHEDULE
RECEIVER CERTIFICATE
CERTIFICATE NO.
AMOUNT $
-1,-L_THIS IS TO CERTIFY that {RECEIVER'S NAME]Alvarez & Marsal Canada Inc., the
receiver (the ItReceivern of all of assets, undertakings and properties [DEBTORS NAME]
aequifeil-fer-,--er---usefl-in-relatien-te-a-hu-s-iness-c-afr-i-e-E1-eny tlie-Debterof Sameh Sadek also
nown as Sam Sadek. St. Maharial Pharmacy Inc. dba MD Hea th Pharmacy. St. Maharial Clinic
Inc., SRX Investment Inc , Shepherd RX Pharmacy Inc. and Lilian Fam, including all proceeds
thereof, to the extent such assets, undertakings and properties are located in Canada (collectively,
the "Domestic Property") appointed by Order of the Ontario Superior Court of Justice
(Commercial List) (the L'2_,CourtL':) dated the 11th day of , 20_September, 2018 (the
11"_`Order'-"') made in an action having Court file number —CV-18-602745-00-CL , has
received as such Receiver from the holder of this certificate (the L"L en d e r•L") the principal sum
of $ , being part of the total principal sum of $ which the Receiver is
authorized to borrow under and pursuant to the Order.
2. 2. The principal sum evidenced by this certificate is payable on demand by the Lender with
interest thereon calculated and compounded [daily][monthly not in advance on the day
of each month] after the date hereof at a notional rate per annum equal to the rate of per
cent above the prime commercial lending rate of Bank of from time to time.
3. 3. Such principal sum with interest thereon is, by the terms of the Order, together with the
principal sums and interest thereon of all other certificates issued by the Receiver pursuant to the
Order or to any further order of the Court, a charge upon the whole of the Domestic Property, in
priority to the security interests of any other person (other than the Priority Charges, as defined in
the Order), but subject to the priority of the charges set out in the Order and in the Bankruptcy
and Insolvency Act, R S C 1985, c B-3 (the "BIA"), and the right of the Receiver to indemnify
itself out of such Property in respect of its remuneration and expenses.
23451639.11
DOL2-6'13,44.: 1771712W
- 2 -
sums payable in respect of principal and interest under this certificate are payable at the
main office of the Lender at Toronto, Ontario.
5,5. Until all liability in respect of this certificate has been terminated, no certificates creating
charges ranking or purporting to rank in priority to this certificate shall be issued by the Receiver
to any person other than the holder of this certificate without the prior written consent of the
holder of this certificate.
64_ The charge securing this certificate shall operate so as to permit the Receiver to deal with
the Domestic Property as authorized by the Order and as authorized by any further or other order
of the Court.
7,7, The Receiver does not undertake, and it is not under any personal liability, to pay any sum
in respect of which it may issue certificates under the terms of the Order.
DATED the day of , 20_.
[RECEIVER'S .•176i-ME-IALVAREZ &
MARSAkCANADA INC, solely in its capacity as Receiver of the Property, and not in its personal capacity
Per:
Name:
Title:
$ii
DOCSTOR 81771742 v8 Model—Receivership_Ord 23451639 11
DOL2-6'13,44.: 1771712W
- 2 -
sums payable in respect of principal and interest under this certificate are payable at the
main office of the Lender at Toronto, Ontario.
5,5. Until all liability in respect of this certificate has been terminated, no certificates creating
charges ranking or purporting to rank in priority to this certificate shall be issued by the Receiver
to any person other than the holder of this certificate without the prior written consent of the
holder of this certificate.
64_ The charge securing this certificate shall operate so as to permit the Receiver to deal with
the Domestic Property as authorized by the Order and as authorized by any further or other order
of the Court.
7,7, The Receiver does not undertake, and it is not under any personal liability, to pay any sum
in respect of which it may issue certificates under the terms of the Order.
DATED the day of , 20_.
[RECEIVER'S .•176i-ME-IALVAREZ &
MARSAkCANADA INC, solely in its capacity as Receiver of the Property, and not in its personal capacity
Per:
Name:
Title:
$ii
DOCSTOR 81771742 v8 Model—Receivership_Ord 23451639 11
DOL2-6'13,44.: 1771712W
- 2 -
sums payable in respect of principal and interest under this certificate are payable at the
main office of the Lender at Toronto, Ontario.
5,5. Until all liability in respect of this certificate has been terminated, no certificates creating
charges ranking or purporting to rank in priority to this certificate shall be issued by the Receiver
to any person other than the holder of this certificate without the prior written consent of the
holder of this certificate.
64_ The charge securing this certificate shall operate so as to permit the Receiver to deal with
the Domestic Property as authorized by the Order and as authorized by any further or other order
of the Court.
7,7, The Receiver does not undertake, and it is not under any personal liability, to pay any sum
in respect of which it may issue certificates under the terms of the Order.
DATED the day of , 20_.
[RECEIVER'S .•176i-ME-IALVAREZ &
MARSAkCANADA INC, solely in its capacity as Receiver of the Property, and not in its personal capacity
Per:
Name:
Title:
$ii
DOCSTOR 81771742 v8 Model—Receivership_Ord 23451639 11
DUCS1 UR: 1771792\9
3
SCHEDULE "B" SERVICE LIST
Defendants
SAMEH SADEK ALSO KNOWN AS SAM SADEK,
PHARMACL_ST.ANIAHARI: CLINIC INC., SRX INVESTMENT INC and ,SHEPHERD
,E-mail• sadancftmailsom
J,ITJAN FAM 5045 Churchill Meadows Blvd Missi. •
BanliknameairtAllgu, t 9. 2.018_auct September 5,201' Qrderkof the honourable JusticQDunphy
AND TO., BBC ROYAL BANK 1athrine Styli& 200 Bay Street lititonto. ON MS 215 katistrine—smirle
AND_1101 THE BANK OF NOY • COTIA resident and_General Co uns_e1
44_King Street West Toronto ON M5H 1H1 [email protected]
AND TO* CANADIAN IMPERIAL BANK OF COMMERCE Stephen
199 Bay Street. Commerce Court West. llth_Floot Toronto. ON 1VI5L 1A2 ,[email protected]
AND TO TlEANADA TRUST Ellen Patterson
.23451639.11
s11 DUCS1 UR: 1771792\9
3
SCHEDULE "B" SERVICE LIST
Defendants
SAMEH SADEK ALSO KNOWN AS SAM SADEK,
PHARMACL_ST.ANIAHARI: CLINIC INC., SRX INVESTMENT INC and ,SHEPHERD
,E-mail• sadancftmailsom
J,ITJAN FAM 5045 Churchill Meadows Blvd Missi. •
BanliknameairtAllgu, t 9. 2.018_auct September 5,201' Qrderkof the honourable JusticQDunphy
AND TO., BBC ROYAL BANK 1athrine Styli& 200 Bay Street lititonto. ON MS 215 katistrine—smirle
AND_1101 THE BANK OF NOY • COTIA resident and_General Co uns_e1
44_King Street West Toronto ON M5H 1H1 [email protected]
AND TO* CANADIAN IMPERIAL BANK OF COMMERCE Stephen
199 Bay Street. Commerce Court West. llth_Floot Toronto. ON 1VI5L 1A2 ,[email protected]
AND TO TlEANADA TRUST Ellen Patterson
.23451639.11
s11 DUCS1 UR: 1771792\9
3
SCHEDULE "B" SERVICE LIST
Defendants
SAMEH SADEK ALSO KNOWN AS SAM SADEK,
PHARMACL_ST.ANIAHARI: CLINIC INC., SRX INVESTMENT INC and ,SHEPHERD
,E-mail• sadarx ftmailsom
ANIXTD; J,ITJAN FAM 5045 Churchill Meadows Blvd Missi. • *a_ON_J-15......4._
Banliknumed_inAilgu. t 9. 2.018_and.S_eptembvr 5,201' Orderkofthe honourable JusticQDunphy
AND TO., BBC ROYAL BANK 1athrine Smirl- 200 Bay Street lititonto. ON MS 215 katistrimsraide
ANDJ101 THE BANK OF NOY • COTIA resident and_Generd Co uns_el
44_King Street West Toronto ON M5H 1H1 [email protected]
AND TO* CANADIAN IMPERIAL BANK OF COMMERCE tephen Schultz
199 Bay Street. Commerce Court West. llth_Floot Toronto. ON IVI5L 1A2 ,[email protected]
AND TO TI:_iCANADA TRUST Ellen Patterson
.23451639.11
s11
I.XJCSIOK: 1771712 \ 9
4
Group Head and General Counsel TD Bank Group 12th Floor. TD Tower. TD Centre pO Box 1. Stn. Toronto Dom, Toronto. Ontario M5K 1A2 ellen.pattersoratd.corn
Legal Demands Department
4720 Tahoe Boulevard. 3rd Floor
Mississauga. ON L4W 5P2
Phone: 877-372-3972
Fax: 855-569-1640
ATTN: Rosanna Paolitto
AND TO: J3ANK OF MONTREAL Miguel Mendes Senior counsel & VP. BMO Financial Group I First Canadian Place. 21st Floor Toronto. Ontario M5X 1A1 [email protected]
AND TO: ILSBC BANK CANADA j Mac Bosma Senior Vice-President and General Counsel 1100-885 West Georgia Street Vancouver. BC V6C 3E8 E-mail:
HSBC Branch 1675 The Chase Mississauga. ON L5M 5Y7
HSBC Brand 101-3029 Argentia Rd Mississauga. ON L5N8P7
AND TO: NATIONAL BANK OF CANADA Dominic Paradis
BAGSTAR-N-1-77-1-742-444edel-Reseweah+p-Or-der-R--Reyes)-dee_ _ _ 23451639.11
52o I.XJCSIOK: 1771712 \ 9
4
Group Head and General Counsel TD Bank Group 12th Floor. TD Tower. TD Centre pO Box 1. Stn. Toronto Dom, Toronto. Ontario M5K 1A2 ellen.pattersoratd.corn
Legal Demands Department
4720 Tahoe Boulevard. 3rd Floor
Mississauga. ON L4W 5P2
Phone: 877-372-3972
Fax: 855-569-1640
ATTN: Rosanna Paolitto
AND TO: J3ANK OF MONTREAL Miguel Mendes Senior counsel & VP. BMO Financial Group I First Canadian Place. 21st Floor Toronto. Ontario M5X 1A1 [email protected]
AND TO: ILSBC BANK CANADA j Mac Bosma Senior Vice-President and General Counsel 1100-885 West Georgia Street Vancouver. BC V6C 3E8 E-mail:
HSBC Branch 1675 The Chase Mississauga. ON L5M 5Y7
HSBC Brand 101-3029 Argentia Rd Mississauga. ON L5N8P7
AND TO: NATIONAL BANK OF CANADA Dominic Paradis
BAGSTAR-N-1-77-1-742-444edel-Reseweah+p-Or-der-R--Reyes)-dee_ _ _ 23451639.11
52o I.XJCSIOK: 1771712 \ 9
4
Group Head and General Counsel TD Bank Group 12th Floor. TD Tower. TD Centre pO Box 1. Stn. Toronto Dom, Toronto. Ontario M5K 1A2 ellen.pattersoratd.corn
Legal Demands Department
4720 Tahoe Boulevard. 3rd Floor
Mississauga. ON L4W 5P2
Phone: 877-372-3972
Fax: 855-569-1640
ATTN: Rosanna Paolitto
AND TO: J3ANK OF MONTREAL Miguel Mendes Senior counsel & VP. BMO Financial Group I First Canadian Place. 21st Floor Toronto. Ontario M5X 1A1 [email protected]
AND TO: ILSBC BANK CANADA j Mac Bosma Senior Vice-President and General Counsel 1100-885 West Georgia Street Vancouver. BC V6C 3E8 E-mail:
HSBC Branch 1675 The Chase Mississauga. ON L5M 5Y7
HSBC Brand 101-3029 Argentia Rd IVIississaugg. ON L5N8P7
AND TO: NATIONAL BANK OF CANADA Dominic Paradis
BAGSTAR-N-1-77-1-742-444edel-Reseweah+p-Or-der-R--Reyes)-dee_ _ _ 23451639.11
52o
DUCSTOR: 1771712\9
Sal - 5 -
taa Corporate Secreta 's Office 600De La Gauchetiere Street West,4th Floor Montreal, Quebec_ L1313 4L2 dorninic.paradis@bn_c ca
Parties to other proceedings involving the defendants
MsJS=wSj;jmjjaCQrj2J2raCwLyjjcdjapjjawacyjxceL
MILLSA MILLS LLP 2 St,Clair Avenue West —Suite 700 Tor .nto, ON M4V 1L5
Richard Worsfold 40-_682-7113_
Fax; 416-86_ -3997 Riellar&Worafoiti@mill$andrnillssa_
Lawyers fiar the plaintiff in th_e_ab(we-noted proceeding, mdcesson catiada_corptation
AND TO: STIKEMAN ELLIOTT LLP 5300 Commerce Court_West 199 Bay Street lorizata._011M51.,1132
Alex Rose Tel: 416-869-5261 —F.-mail: [email protected]
La_wyersiortheapplicant the above-noted
psoceestiljg, R, Cana
DOCSTOR 41771742 v8 M del_ReceiNership_Order_AT Reyes).doc23451639.11
DUCSTOR: 1771712\9
Sal - 5 -
taa Corporate Secreta 's Office 600De La Gauchetiere Street West,4th Floor Montreal, Quebec_ L1313 4L2 dorninic.paradis@bn_c ca
Parties to other proceedings involving the defendants
MsJS=wSj;jmjjaCQrj2J2raCwLyjjcdjapjjawacyjxceL
MILLSA MILLS LLP 2 St,Clair Avenue West —Suite 700 Tor .nto, ON M4V 1L5
Richard Worsfold 40-_682-7113_
Fax; 416-86_ -3997 Riellar&Worafoiti@mill$andrnillssa_
Lawyers fiar the plaintiff in th_e_ab(we-noted proceeding, mdcesson catiada_corptation
AND TO: STIKEMAN ELLIOTT LLP 5300 Commerce Court_West 199 Bay Street lorizata._011M51.,1132
Alex Rose Tel: 416-869-5261 —F.-mail: [email protected]
La_wyersiortheapplicant the above-noted
psoceestiljg, R, Cana
DOCSTOR 41771742 v8 M del_ReceiNership_Order_AT Reyes).doc23451639.11
DUCSTOR: 1771712\9
6al - 5 -
taa Corporate Secreta 's Office 600De La Gauchetiere Street West,4th Floor Montreal, Quebec_ L1313 4L2 dorninic.paradis@bn_c ca
Parties to other proceedings involving the defendants
MsJS=wCsjmjjaCs2rj2J2raCwLyjjcdjapjjawacyjxc§L
MILLSA MILLS LLP 2 St,Clair Avenue West —Suite 700 Tor .nto, ON M4V 1L5
Richard Worsfold I1: 4 0-_682-7111_ Fax; 416-86_ -3997
Riellar&Worafold@mill$andmilissa_
Lawyers fiar the plaintiff in th_e_abPve-noted proceeding, mdcesson catiada_cprptation
AND TO: STIKEMAN ELLIOTT LLP 5300 Commerce Court_West 199 Bay Street lorizata._011M51.,1132
Alex Rose Tel: 416-869-5261 —F.-mail: [email protected]
DOCSTOR 41771742 v8 M del_ReceiNership_Order_AT Reyes).doc23451639.11
PUL:S•I OK: I 77 I 712W
-6
rem Canada Limited v. St. Maharial Pharmacy Inc. et al.
AND TO: BENNETT JONES LLP 100 King Street West. Suite 3400 Toronto. ON M5X 1A4
Dominique T. Hussey
Tel: 416-777-6230
F,-mail: husseydQ.bennettones.com
,awyers for the plaintiff in the above noted proceeding. Teva Canada Limited
AND TO;
7941 Jane Street. Suite 200
Concord. ON L4K 4L6
lio Risceglia
Tel: (905)-695-5200
E-mail: [email protected]
Lawyers for the plaintiffs in the above-noted proceeding. 170735 Ontario Inc.. JYID Investments Inc. and MD Health Medical Centre Brampton) Inc.
AZiI2 T0;
13AGSTAR4/-1-7-7-1-744-44.4e41-Reeerver-sliv-Afclereyes)-dee_ _ . 73451639 11
PUL:S•I OK: I 77 I 712W
-6
rem Canada Limited v. St. Maharial Pharmacy Inc. et al.
AND TO: BENNETT JONES LLP 100 King Street West. Suite 3400 Toronto. ON M5X 1A4
Dominique T. Hussey
Tel: 416-777-6230
F,-mail: husseydQ.bennettones.com
,awyers for the plaintiff in the above noted proceeding. Teva Canada Limited
AND TO;
7941 Jane Street. Suite 200
Concord. ON L4K 4L6
lio Risceglia
Tel: (905)-695-5200
E-mail: [email protected]
Lawyers for the plaintiffs in the above-noted proceeding. 170735 Ontario Inc.. JYID Investments Inc. and MD Health Medical Centre Brampton) Inc.
AZiI2 T0;
13AGSTAR4/-1-7-7-1-744-44.4e41-Reeerver-sliv-Afclereyes)-dee_ _ . 73451639 11
PUL:S• I OK: I 77 I 712W
-6
rem Canada Limited v. St. Maharial Pharmacy Inc. et al.
AND TO: BENNETT JONES LLP 100 King Street West. Suite 3400 Toronto. ON M5X 1A4
Dominique T. Hussey
Tel: 416-777-6230
E-mail: husseydQ.bennettones.com
,awyers for the plaintiff in the above noted proceeding. Teva Canada Limited
AND TO;
7941 Jane Street. Suite 200
Concord. ON L4K 4L6
Risceglia
Tel: (905)-695-5200
E-mail: [email protected]
Lawyers for the plaintiffs in the above-noted proceeding. 170735 Ontario Inc.. JYID Investments Inc. and MD Health Medical Centre Brampton) Inc.
AND TO ELAXEYIILLIMILLIX
13AGSTAR4/-1-7-7-1-744-44.4e41-Reeerver-sliv-Afclereyes)-dee_ _ . 73451639 11
625 -7
2 Queen Street East, Suite 1500
1=2Q,_aL\LIA5LIU5=
1, ALBrzezinski
Tel: (416)-594-2952
Faxi (416)-594-5044
E-mail: lbrzeei 'Ms ,g.• II
Varopiari Annan
Tel: (416)-596-2884
Fax. (416)-593-2960
JaYact5 for the dQfendut in_the abovQ7noted
POTFSJ10 LAW 253 Jevlan Drive
ghan.
DUCS1 UR 77171219
AND TO'
Timothy Cindy Dir: (905)-850-2647 L; ost5145Dr154.4
tim@potestiolaw coin
Lawyers for the defendant in the above-noted proceeding, Mg4hat Saad, also...known as Malty Saad_
Creditors (if not named above)
AND TO
AN II TO,
MAXIUMFINANCIAL SERVICES INC, AND CWB MAXIUM FINANCIAL INC. 30 Vogel) Rd. #1 RichmondEill.ML4331
JJA,RTM&SDNULU„ 2430 S Service Rd W
DQC—S-T-GR-II-1-7-7-1-742-v-8-MeE1eeeeiver-sl+ip—OFE1er—(-T----Reyes-)rE1ee23451639 11
625 -7
2 Queen Street East, Suite 1500
1=2Q,_aL\LIA5LIU5=
1, ALBrzezinski
Tel: (416)-594-2952
Faxi (416)-594-5044
E-mail: lbrzeei 'Ms ,g.• II
Varopiari Annan
Tel: (416)-596-2884
Fax. (416)-593-2960
JaYact5 for the dQfendut in_the abovQ7noted
POTFSJ10 LAW 253 Jevlan Drive
ghan.
DUCS1 UR 77171219
AND TO'
Timothy Cindy Dir: (905)-850-2647 L; ost5145Dr154.4
tim@potestiolaw coin
Lawyers for the defendant in the above-noted proceeding, Mg4hat Saad, also...known as Malty Saad_
Creditors (if not named above)
AND TO
AN II TO,
MAXIUMFINANCIAL SERVICES INC, AND CWB MAXIUM FINANCIAL INC. 30 Vogel) Rd. #1 RichmondEill.ML4331
JJA,RTM&SDNULU„ 2430 S Service Rd W
DQC—S-T-GR-II-1-7-7-1-742-v-8-MeE1eeeeiver-sl+ip—OFE1er—(-T----Reyes-)rE1ee23451639 11
625 -7
2 Queen Street East, Suite 1500
1=2Q,_aL\LIA5LIU5=
1, ALBrzezinski
Tel: (416)-594-2952
Faxi (416)-594-5044
E-mail: lbrzeei 'Ms ,g.• II
Varopiari Arman
Tel: (416)-596-2884
F_ax. (416)-593-2960
JaYact5 for the dQfendut in_the abovQ7noted
POTFSJ10 LAW 253 Jevlan Drive
ghan.
DUCS1 UR 77171219
AND TO'
Timothy Cindy Dir: (905)-850-2647 L; ost5145Dr154.4
tim@potestiolaw coin
Lawyers for the defendant in the above-noted proceeding, Mg4hat Saad, also...known as Mary Saad
Creditors (if not named above)
AND TO
AN II TO,
MAXIUMFINANCIAL SERVICES INC, AND CWB MAXIUM FINANCIAL INC. 30 Vogel) Rd. #1 RichmondEill.ML4331
JJA,RTM&SDNULU„ 2430 S Service Rd W
DQC—S-T-GR-II-1-7-7-1-742-v-8-MeE1eeeeiver-sl+ip—OFE1er—(-T----Reyes-)rE1ee23451639 11
4.-)01-6)-1(4-4:-14 4444\ 9
524 8
Oakville. ON L6L M59
AND TO: KOHL & FRITSCH LIMITED 7622 Keele Street Concord. ON L4K 2R5
Other
AND TO: SILIEELLINMLGIESIall. 38 Solutions Drive #200 Halifax. NS B3S 1L8
AND TO; CLAIMSECURE INC. 1 City Centre Dr #620 Mississauga. ON L5B 1M2
AND TO; CAMERON STEWART LIFESCIENCE CANADA INC. 3470 Superior Court Oakville. ON L6L 0C4
AND TO: IVIINISTRY OF FINANCE (ONTARIO) IszaLaenkeiltaach 33 King Street West. 6th Floor Oshawa. ON Ll H 8H5
Kevin O'Hara Tel: 905-433-6934 Fax: 905-436-4510 Email: [email protected]
AND TO: DEPARTMENT OF JUSTICE Counsel for the Canada Revenue Agency The Exchange Tpwer 130 King Street West. Suite 3400 po Box 36 Toronto. ON M5X 1K6
Plane Winters. Tel: 416-973-3172 Fax: 416-973-0810
AND TO: ONTARIO COLLEGE OF PHARMACISTS Investigations and Resolutions 483 Huron Street Toronto. ON M5R 2R4
DOGSTOR-4$44;1-74Z-,,,8-Mel—Reseivefship--Afdef—R—Reye*lee234 S1639.11
4.-)01-6)-1(4-4:-14 4444\ 9
524 8
Oakville. ON L6L M59
AND TO: KOHL & FRITSCH LIMITED 7622 Keele Street Concord. ON L4K 2R5
Other
AND TO: SILIEELLINMLGIESIall. 38 Solutions Drive #200 Halifax. NS B3S 1L8
AND TO; CLAIMSECURE INC. 1 City Centre Dr #620 Mississauga. ON L5B 1M2
AND TO; CAMERON STEWART LIFESCIENCE CANADA INC. 3470 Superior Court Oakville. ON L6L 0C4
AND TO: IVIINISTRY OF FINANCE (ONTARIO) IszaLaenkeiltaach 33 King Street West. 6th Floor Oshawa. ON Ll H 8H5
Kevin O'Hara Tel: 905-433-6934 Fax: 905-436-4510 Email: [email protected]
AND TO: DEPARTMENT OF JUSTICE Counsel for the Canada Revenue Agency The Exchange Tpwer 130 King Street West. Suite 3400 po Box 36 Toronto. ON M5X 1K6
Plane Winters. Tel: 416-973-3172 Fax: 416-973-0810
AND TO: ONTARIO COLLEGE OF PHARMACISTS Investigations and Resolutions 483 Huron Street Toronto. ON M5R 2R4
DOGSTOR-4$44;1-74Z-,,,8-Mel—Reseivefship--Afdef—R—Reye*lee234 S1639.11
4.-)01-6)-1(4-4:-14 4444\ 9
524 8
Oakville. ON L6L M59
AND TO: KOHL & FRITSCH LIMITED 7622 Keele Street Concord. ON L4K 2R5
Other
AND TO: SILIEELLINMLGIESIall. 38 Solutions Drive #200 Halifax. NS B3S 1L8
AND TO; CLAIMSECURE INC. 1 City Centre Dr #620 Mississauga. ON L5B 1M2
AND TO; CAMERON STEWART LIFESCIENCE CANADA INC. 3470 Superior Court Oakville. ON L6L 0C4
AND TO: IVIINISTRY OF FINANCE (ONTARIO) IszaLaenkeiltaach 33 King Street West. 6th Floor Oshawa. ON Ll H 8H5
Kevin O'Hara Tel: 905-433-6934 Fax: 905-436-4510 Email: [email protected]
AND TO: DEPARTMENT OF JUSTICE Counsel for the Canada Revenue Agency The Exchange Tpwer 130 King Street West. Suite 3400 po Box 36 Toronto. ON M5X 1K6
Plane Winters. Tel: 416-973-3172 Fax: 416-973-0810
AND TO: ONTARIO COLLEGE OF PHARMACISTS Investigations and Resolutions 483 Huron Street Toronto. ON M5R 2R4
DOGSTOR-4$44;1-74Z-,,,8-Mel—Reseivefship--Afdef—R—Reye*lee234 S1639.11
DUCSTUR: 1771712\9
5R5 -9
Phone: 1-800-220-1921 flax; 4167:47-84'9
nt ssistaitt [email protected]
ATTN:_Sheliqg Manjidnyestigillor
AND II •
DOCSTOR #1771742 v8 Model_Receivership_OrdeUT Reyes).doc23451639.11
DUCSTUR: 1771712\9
5R5 -9
Phone: 1-800-220-1921 flax; 4167:47-84'9
nt ssistaitt [email protected]
ATTN:_Sheliqg Manjidnyestigillor
AND II •
DOCSTOR #1771742 v8 Model_Receivership_OrdeUT Reyes).doc23451639.11
DUCSTUR: 1771712\9
5R5 -9
Phone: 1-800-220-1921 flax; 4167:47-84'9
nt ssistaitt [email protected]
ATTN:_Sheliqg Manjidnyestigillor
AND II •
DOCSTOR #1771742 v8 Model_Receivership_OrdeUT Reyes).doc23451639.11
Document comparison by Workshare 9.5 on Monday, September 10, 2018 2:52:31 PM Input:
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Statistics:
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Insertions 500
Deletions 203
Moved from 4
Moved to 4
Style change 0
Format changed 0
Total changes 711
Document comparison by Workshare 9.5 on Monday, September 10, 2018 2:52:31 PM Input:
Document 1 ID file://C:\Users\eri\Desktop\receivership-order-EN.doc Description receivership-order-EN Document 2 ID PowerDocs://TOR_2528/23451639/11 Description TOR 2528-#23451639-v11-Draft Order -_Receiver _ _ _ Rendering set Standard
Legend:
Insertion Deletion
Moved-from-
Moved to
Style change
Format change
Mem -deletion--
Inserted cell
Deleted cell
Moved cell
Split/Merged cell
Padding cell
Statistics:
Count
Insertions 500
Deletions 203
Moved from 4
Moved to 4
Style change 0
Format changed 0
Total changes 711
Document comparison by Workshare 9.5 on Monday, September 10, 2018 2:52:31 PM Input:
Document 1 ID file://C:\Users\eri\Desktop\receivership-order-EN.doc Description receivership-order-EN Document 2 ID PowerDocs://TOR_2528/23451639/11 Description TOR 2528-#23451639-v11-Draft Order -_Receiver _ _ _ Rendering set Standard
Legend:
Insertion Deletion
Moved-from-
Moved to
Style change
Format change
Mem -deletion--
Inserted cell
Deleted cell
Moved cell
Split/Merged cell
Padding cell
Statistics:
Count
Insertions 500
Deletions 203
Moved from 4
Moved to 4
Style change 0
Format changed 0
Total changes 711
ASTRAZENECA CANADA INC. -and- SAMEH SADEK also known as SAM Court File No. CV-18-602745-00 CL SADEK et al.
Plaintiff Defendants
ONTARIO SUPERIOR COURT OF JUSTICE
(COMMERCIAL LIST)
Proceeding commenced at Toronto
MOTION RECORD TO APPOINT A RECEIVER (Returnable September 11, 2018)
BLAKE, CASSELS & GRAYDON LLP Barristers & Solicitors 199 Bay Street Suite 4000, Commerce Court West Toronto ON M5L 1A9
R. Seumas M. Woods LSO #301691 Tel: 416-863-3876 [email protected]
Erin Hoult LSO #54002C Tel: 416-863-4011 Fax: 416-863-2653 [email protected]
Lawyers for the plaintiff
ASTRAZENECA CANADA INC. -and- SAMEH SADEK also known as SAM Court File No. CV-18-602745-00 CL SADEK et al.
Plaintiff Defendants
ONTARIO SUPERIOR COURT OF JUSTICE
(COMMERCIAL LIST)
Proceeding commenced at Toronto
MOTION RECORD TO APPOINT A RECEIVER (Returnable September 11, 2018)
BLAKE, CASSELS & GRAYDON LLP Barristers & Solicitors 199 Bay Street Suite 4000, Commerce Court West Toronto ON M5L 1A9
R. Seumas M. Woods LSO #301691 Tel: 416-863-3876 [email protected]
Erin Hoult LSO #54002C Tel: 416-863-4011 Fax: 416-863-2653 [email protected]
Lawyers for the plaintiff
...NO. ...Mb
ASTRAZENECA CANADA INC. -and- SAMEH SADEK also known as SAM Court File No. CV-18-602745-00 CL SADEK et al.
Plaintiff Defendants
ONTARIO SUPERIOR COURT OF JUSTICE
(COMMERCIAL LIST)
Proceeding commenced at Toronto
MOTION RECORD TO APPOINT A RECEIVER (Returnable September 11, 2018)
BLAKE, CASSELS & GRAYDON LLP Banisters & Solicitors 199 Bay Street Suite 4000, Commerce Court West Toronto ON M5L 1A9
R. Seumas M. Woods LSO #30169I Tel: 416-863-3876 [email protected]
Erin Hoult LSO #54002C Tel: 416-863-4011 Fax: 416-863-2653 [email protected]
Lawyers for the plaintiff