Proceedings.

Ontario · Receivership (court-appointed)

This Motion is to obtain an Order (the “ Settlement Approval Order ”), for the following relief, among other things: (a) approving the settlement agreement entered into among the Receiver (including in its capacity as trustee in bankruptcy of the Debtor (the “ Trustee ”)), National Bank of Canada (“ NBC ”), Joseph Delonghi (“ Mr. Delonghi ”), Roma Breese, Lighting Fund Investments Inc., M&G Hotels Limited, 16 – 20 Newbridge Investments Inc., 136 The East Mall Inc., Flexwrks Inc. and Lumen Power Technologies Inc. (collectively, the “ Related Parties ” and together with the Receiver (including in its capacity as Trustee) and NBC, the “ Settling Parties ”) on July 3, 2026 (the “ Settlement Agreement ”); and (b) such other relief as counsel may request and this Court may permit

Application / notice of application · 9 July 2026

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