Alberta · Receivership (court-appointed)
Sworn Affidavit of Ben Neufeld (FCC)
Affidavit · 3 April 2025
AI summary
A plain-English summary drawn only from this filing: what it is, why it matters, and the parties, amounts and dates it turns on.
What we verified from this filing3 verified
- secured creditorsnote: Postponed/subordinated to FCC per postponement agreement dated October 3, 2023 (Exhibit G); amount not stated · page: 2 · debtor: Special D Baking Ltd. · creditor: ATB Financial · currency: CAD · security: Security interest in equipment of Special D Baking Ltd.
- secured creditorsnote: Subordinated to FCC's Cash Flow Loan and Forbearance Agreement per Priority Agreement effective December 4, 2024 (Exhibit V); amount not stated · page: 5 · creditor: API Industrial Services Inc. · currency: CAD · security: Construction Lien
- secured creditorsnote: Balance owing per loan balances report as of April 1, 2025, with interest, legal and enforcement costs continuing to accrue; arises under Loan Agreement 820635 (2023) and Loan Agreement 850759 (2024, per Forbearance Agreement); ATB Financial holds equipment security over Special D but has postponed/subordinated it to FCC (Exhibit G, no amount stated); API Industrial Services Inc. holds a Construction Lien subordinated to FCC per Priority Agreement effective Dec 4, 2024 · page: 6 · as of: 2025-04-01 · amount: 10895427.63 · debtor: Land Assembly Company (Edmonton) Ltd. and Special D Baking Ltd. (jointly and severally with guarantors Richard Scott Manley and Richard James Manley) · creditor: Farm Credit Canada (FCC) · currency: CAD · security: 2023 Mortgage (registration ceiling up to $10,000,000.00, instrument 232 352 720, over Plan 8220320 Block 5 Lot 12); 2024 Mortgage (registration ceiling up to $1,000,000.00, instrument 252 027 160, over Plan 5740AI Block 85 Lots 20-23); 2023 Security Agreement (GSA over Special D equipment/personal property, PPSA reg. 23101706271); 2024 Security Agreement; 2024 GSA Agreement; Assignment of Rents and Leases (caveats, instruments 232 352 721 and 252 028 549); Assignment of Insurance Policies and Proceeds; unlimited personal guarantees of Scott and James