Saskatchewan · CCAA
Affidavit of Jason Mann, Sworn on November 25, 2025
Affidavit · 25 November 2025
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What we verified from this filing8 verified
- financial positionnote: Assets: approx. $17.3M current, $79.2M non-current (material portions: inventory/related-party amounts due to 4752 ~$10.4M; related-party amounts due to AgraCity and PP&E ~$42.9M). Liabilities: approx. $70.3M current, $20.4M non-current (majority of current liabilities is AP/accrued/deferred revenue at AgraCity ~$46.1M, largely Reconciliation Creditor deferred revenue; non-current liabilities include trade facility credit and related-party amounts ~$19.2M). · page: 20 · as at: 2025-09-30 · basis: Draft unaudited financial statements (per para 77) presented on a consolidated basis · scope: Consolidated - the Applicants and Stay LPs · currency: CAD · total assets: 96400000 · total liabilities: 90700000
- secured creditorsnote: Underlying BDC Loan (Letter of Offer dated 2021-07-05) was for $10,000,000; interest accruing at approx. $1,500/day since the stated date; borrowers defaulted around 2025-07-29; demand for repayment issued 2025-10-02; BDC filed receivership application 2025-11-19, with hearing scheduled 2025-11-28 · page: 22 · as of: 2025-09-24 · amount: 7500000 · debtor: Genesis Operating LP, Genesis Opco, Genesis Holding LP, Genesis Holdco (the Genesis Entities) · creditor: Business Development Bank of Canada (BDC) · currency: CAD · security: BDC Security: mortgage in stated amount of $11,000,000 over the Belle Plaine Lands; general assignment of rents and leases over the Belle Plaine Lands; first-ranking general security interest in all present and after-acquired personal property of Genesis Opco, Genesis Operating LP, Genesis Holdco and Genesis Holding LP; corporate guarantees of the full Loan amount by Genesis Holdco and Genesis Holding LP
- secured creditorsnote: Disputed: 2497 considers the VTB Mortgage satisfied due to post-closing purchase price adjustments for remediation; Deer Lodge disputes that characterization; Deer Lodge served with this application · page: 23 · as of: 2021-11-22 · debtor: 101072497 Saskatchewan Ltd. (2497) · creditor: Deer Lodge Hotels Ltd. · currency: CAD · security: Vendor take-back mortgage ("VTB Mortgage") originally granted in the amount of $1,200,000 over the Saskatoon Lands
- secured creditorsnote: Registration order is not priority; amount owing not stated · page: 24 · debtor: AgraCity, NewAgco · creditor: 101258391 Saskatchewan Ltd. · currency: CAD · security: Blanket registration: all present and after-acquired personal property
- secured creditorsnote: Professional services provider (law firm) holding blanket PPSA registration; amount owing not stated · page: 24 · debtor: AgraCity, NewAgco, Viking, Genesis Holdco, Genesis Opco, Genesis Holding LP, Genesis Operating LP, Mpower, Agronomax, 2676, FNA AgraCity · creditor: Miller Thomson LLP · currency: CAD · security: Blanket registration: all present and after-acquired personal property and proceeds
- secured creditorsnote: Individual PMSI amounts not stated in aggregate; no total quantified by the document. Components not summed per reporting rule. · page: 24 · debtor: AgraCity, Mpower, Genesis Opco, Genesis Operating LP · creditor: PPSA equipment financiers (PMSI class) · currency: CAD · security: Serialized equipment/vehicle PMSI registrations, including: Calidon Financial Services Inc. (Meridian grain bin, debtor AgraCity); Mitsubishi HC Capital Canada, Inc. (2021 Hitachi excavator, debtors AgraCity/Genesis Opco/Genesis Operating LP); Ford Credit Canada Company (Ford F150 trucks, debtor AgraCity); Toyota Industries Commercial Finance Canada, Inc. (Toyota forklifts, debtors AgraCity/Genesis Opco/Genesis Operating LP); 2504967 Ontario Ltd. o/a Abrams Auto Transport (vintage Mazda RX7 vehicles, debtor AgraCity); Kubota Canada Ltd. (compact track loader, debtor AgraCity); CWB National Leasing Inc. (debtor Genesis Operating LP, collateral not specified); Frontline Truck & Trailer (trailer, debtor Mpower); Hitachi Capital Canada Corp. (aluminium deck, debtor Mpower); RCAP Leasing Inc. (trailers, debtor Mpower); Meridian OneCap Credit Corp. (trailers, debtor Mpower); Bank of Montreal (2016 Freightliner Cascadia trailer, debtor Mpower); Ernie's Trailer Service (trailers, debtor Mpower)
- secured creditorsnote: Registration arose from a proposed loan to Genesis that was never advanced; Cortland is not owed anything by the Applicants; registration has been discharged · page: 25 · debtor: Genesis Holdco, Genesis Holding LP, Genesis Opco, Genesis Operating LP · creditor: Cortland Credit Lending Corporation / Cortland Credit Group Inc. · currency: CAD · security: PPSA registration: all present and after-acquired personal property
- secured creditorsnote: Court decision (Exhibit 12) requires Syngenta to remove its registration; security status disputed/ordered discharged · page: 25 · debtor: NewAgco · creditor: Syngenta Crop Protection, LLC · currency: CAD · security: PPSA registration: all personal property and lands of AgraCity within Saskatchewan