Keller & Sons Farming Ltd et Keller Holdings Ltd

The purpose of this third report of the Receiver is to advise and update this Honourable Court with respect to: a) the activities of the Receiver since the date of the Second Report, b) the Receiver's efforts to realize on the assets of Keller, c) the Receiver's analysis of the claims of various stakeholders to the proceeds from the sale of Keller's assets, d) the professional fees of the Receiver and its legal counsel, e) the Receiver's interim statement of receipts and disbursements, f) the Receiver's proposed distribution of excess funds on hand, and g) the Receiver's conclusions and recommendations — Court officer report

The appeal of the Appellants be and is hereby dismissed, with costs to the Respondent Ernst & Young Inc., in its capacity as Receiver of the undertaking, property and assets of the Debtors — Endorsement / reasons

THIS COURT ORDERS that the motion of Shilo Farms Ltd. and Marcus Keller for greater disclosure of the contents of the Second Confidential Report and the Supplement to the Second Confidential Report be and the same is hereby dismissed. THIS COURT ORDER AND DECLARES that the Transaction is hereby approved, and the execution and delivery of the Sale Agreement by the Receiver is hereby authorized and approved — Application / notice of application

THIS COURT ORDERS AND DECLARES that the Second Confidential Report, the Supplement, and the content of the disclosure made by counsel for the Receiver and counsel for the plaintiff to counsel for SFL and Keller during the course of the hearing held this day as to the amount of the offer which the Receiver proposes to accept shall be treated as confidential and sealed and shall neither form part of the public record nor be disclosed to any other party to this proceeding — Order (other)

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Sale Approval Motion returnable 08 Apr 2016 — Application / notice of application

Sale Approval, returnable 08 Apr 2016 — Application / notice of application

The purpose of this second report of the Receiver is to advise and update this Honourable Court with respect to: a) the activities of the Receiver since the date of the First Report, b) the Receiver's efforts to sell the assets of Keller, c) the Receiver's interim statement of receipts and disbursements, and d) the Receiver's conclusions and recommendations — Court officer report

Service List as at 24 Mar 2016 — Service list

Notice of Motion — Application / notice of application

THIS COURT APPROVES the First Report and the activities of the Receiver described therein, including the Receiver's Interim Statement of Receipts and Disbursements. All capitalized terms not otherwise defined herein shall have the meanings set out m the First Report. THIS COURT ORDERS AND DECLARES that the First Confidential Report shall be treated as confidential and sealed and shall neither form part of the public record nor be disclosed to any party to this proceeding or otherwise, except: (a) by further Order of the Court, following notice to the Receiver of such motion or; (b) upon the date on which the Receiver files with the Court a written notice certifying that a transaction or transactions relating to all the assets dealt with under the First Confidential Report have closed to the satisfaction of the Receiver, whichever shall first occur, whereupon the First Confidential Report shall form part of the public record and no longer be sealed — Court officer report

Motion Brief of the Receiver, Ernst & Young Inc — Factum / brief

The purpose of this first report of the Receiver (the "First Report") is to advise and update this Honourable Court with respect to: a) the background of Keller, b) the activities of the Receiver since the date of the Order, c) the Receiver's efforts to sell the assets of Keller, d) the Receiver's interim statement of receipts and disbursements, and e) the Receiver's conclusions and recommendations — Court officer report

Service List as at 05 Jan 2016 — Service list

Acquisition Opportunity Overview

Notice & Statement of the Receiver — Notice to creditors

THIS COURT ORDERS that pursuant to s.243(1) of the BIA and s.55 of the QBA, Ernst & Young Inc. is hereby appointed Receiver — Order (other)

An order that pursuant to section 243(1) of the Bankruptcy and Insolvency Act, RSC 1985 c.B-3 as amended (the "BIA") and section 55 of The Court of Queen's Bench Act, C.C.S.M. c.C280 as amended, Ernst & Young Inc. be appointed Receiver and Manager, without security, of all the assets, undertakings and properties of the Defendants — Order (other)

Service List as at 06 Oct 2015 — Service list

The Appointment of a Receiver pursuant to Section 243 of the Bankruptcy and Insolvency Act, R.S.G. 1985 c.B-3, as amended and Section 55 of The Court of Queen's Bench Act, G.G.S.M. c. C280 — Receivership order

EY Consent

Part 1 of 5 Based upon the facts set out herein: (a) there is clear default under the RBC Credit Agreement and the NBC Credit Agreement which Keller is unable to remedy; (b) Holdings is also in default under the Guarantee which Holdings is unable to remedy; and (c) RBC has lost confidence in the defendants and their ability to manage their operations. I have also been advised by Markus Keller that Keller does not have the funds to continue to carry on the potato farming operation and as previously set out herein the Banks are not prepared to advance any further loans. Furthermore he has advised me that there are various treatments that he believes are required to be applied to the Keller lands prior to the winter. As Keller does not have the funds to pay for these treatments I believe that a Receiver or Receiver-Manager is urgently required to take control of, and deal with these matters prior to the onset of winter — Factum / brief

Part 2 of 5 - Exhibits 1 to 10 both inclusive

Part 3 of 5 - Exhibits 11 to 20 both inclusive

Part 4 of 5 - Exhibits 21 to 27 both inclusive

Part 5 of 5 - Exhibits 28 to 33 both inclusive

Statement of Claim