Ontario · CCAA

Affidavit of C. Ian Ross, sworn November 20, 2013 in relation to the Allen-Vanguard motion and cross-motion by the Applicant, returnable February 11, 2014

Affidavit · 22 November 2013

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What we verified from this filing2 verified

financial positionnote: Total assets of $115,879,821 stated as at September 27, 2013; cash and cash equivalents of approximately $6,586,662 stated separately as at September 30, 2013 (different as-at date). No total liabilities figure is provided in these pages. · page: 2 · as at: 2013-09-27 · basis: as stated in affidavit (source/audit status not specified) · scope: GrowthWorks Canadian Fund Ltd. (the Fund) entity-level · currency: CAD · total assets: 115879821
secured creditorsnote: Described as a $20 million payment obligation plus certain related obligations (together the 'Roseway Obligations') that became due on September 30, 2013 and which the Fund was unable to pay. Of the total Roseway claim, approximately $1.9 million is disputed; the balance has been quantified but the exact figure is not stated separately from the $20 million obligation. Fund intends to distribute funds to satisfy the undisputed secured Roseway Obligations. · page: 2 · as of: 2013-09-30 · amount: 20000000 · debtor: GrowthWorks Canadian Fund Ltd. · creditor: Roseway Capital S.a.r.l. · currency: CAD · security: Secured claim (described as the "secured claim of Roseway")