Alberta · Receivership (court-appointed)
Statement of Claim filed November 3, 2025
Application / notice of application · 3 November 2025
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What we verified from this filing3 verified
- secured creditorsnote: Total indebtedness outstanding under the Credit Facility as at Oct 17, 2025, comprising principal and accrued interest, exclusive of interest accruing thereafter and exclusive of fees/costs/expenses. Debtors acknowledged validity/enforceability of security and indebtedness in Current Forbearance Agreement dated Nov 1, 2023 (amended 9 times). Demand letters and s.244 BIA notices issued Aug 31, 2022 (Dentons), June 19, 2023 and Oct 17, 2025 (Cassels). Mortgage principal ($280,000,000.00) is a registered/charging amount, not a balance. · page: 2 · as of: 2025-10-17 · amount: 68353231.21 · debtor: Independent Renewable Resources Corp. (IRRC) · creditor: Cortland Credit Lending Corporation · currency: CAD · security: General security agreement (IRRC GSA) over all present and after-acquired personal property, perfected by PPSA registrations in Alberta and Saskatchewan; collateral mortgage (IRRC Mortgage) dated Feb 16, 2022, registered principal amount $280,000,000.00, charging the Echo Refinery land (Surface Parcel #149547055), perfected at Saskatchewan Land Titles Office Feb 23, 2022; share pledge agreement; environmental indemnity agreement; general assignment of material projects; transfer and assignment of insurance
- secured creditorsnote: IEH is a related party (78.6% shareholder of IRRC, co-Debtor) providing an unlimited guarantee and security for IRRC's Indebtedness; claim against IEH sought is 'the maximum amount permitted under the IEH Guarantee' — no fixed balance stated for IEH separately (guarantee is unlimited). · page: 3 · as of: NOI/demand filing date (Oct 17, 2025 Demands) · debtor: Independent Energy Holdings Inc. (IEH) · creditor: Cortland Credit Lending Corporation · currency: CAD · security: Unlimited continuing guarantee (IEH Guarantee) dated Feb 16, 2022, guaranteeing IRRC's obligations without requirement that Cortland first exhaust recourse against IRRC; general security agreement (IEH GSA) over all present and after-acquired personal property; share pledge agreement (IEH Share Pledge) over IEH's shares in IRRC
- secured creditorsnote: Related-party (shareholder) security; confirmation of these documents from Raptor was received only in Nov 2023 and Feb 2024 — Raptor failed to provide further confirmation despite repeated requests, and never delivered original stock transfer powers; status of Raptor security as currently confirmed/enforceable is disputed/incomplete per pleading (IRRC's failure to obtain confirmation cited as an event of default). · page: 6 · debtor: Independent Renewable Resources Corp. (IRRC) · creditor: Cortland Credit Lending Corporation · currency: CAD · security: Limited recourse guarantee (Raptor Guarantee, dated Dec 22, 2022) and share pledge agreement (Raptor Share Pledge, dated Dec 22, 2022) granted by Raptor Enterprises Inc. (a 10% shareholder of IRRC) in favour of Cortland