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Curo Canada Corp. and LendDirect Corp. - Motion Materials

 Factum of the Foreign Representative (Third Recognition Order)
May 16, 2024
This factum is filed in support of a motion for an order (the "Third Recognition Order"), to recognize and give full force and effect in Canada the Combined Order if granted by the U.S. Bankruptcy Court at the rescheduled hearing on May 16, 2024. The Foreign Orders along with the Third Recognition Order, if granted, will permit the Foreign Representative to implement the Plan, and the restructuring transaction contemplated thereby, and successfully emerge from these Restructuring Proceedings.
 
 Motion Record of the Foreign Representative (Recognition of Foreign Orders and Termination of Canadian Recognition Proceedings)
May 13, 2024
A Notice of Motion for the Recognition of Foreign Orders and Termination of Canadian Recognition Proceedings, which includes, among other things:
i) An order ("Third Recognition Order") recognizing and enforcing in Canada the following orders of the U.S. Bankruptcy Court: a) Order Approving the Debtors' Disclosure Statement For, and Confirming, the Joint Prepackaged Plan of CURO Group Holdings Corp. and its Debtor Affiliates Pursuant to Chapter 11 of the Bankruptcy Code (the "Combined Order"); (b) Order Granting Debtors' Emergency Motion to Estimate Unliquidated Claim of Leon's Furniture Limited, Trans Global Insurance Company, and Trans Global Life Insurance Company (the "Estimation Order"); and (c) Second Interim Order (I) Authorizing the Debtors to (A) Continue to Operate Their Cash Management System and Maintain Existing Bank Accounts, (B) Maintain Existing Business Forms and (C) Perform Intercompany Transactions; and (II) Granting Related Relief (the "Second Interim Cash Management Order");
ii) An order providing, among other things, the termination of the Canadian Recognition Proceedings, the discharge and release of the Information Officer, and the release of FTI, the Information Officer's counsel and counsel to the Foreign Representative and the Canadian Debtors
iii) An order approving the Pre-Filing Report of the Proposed Information Officer dated March 26, 2024, the First Report of the Information Officer dated April 3, 2024, the Second Report of the Information Officer dated April 22, 2024, the Third Report of the Information Officer (the "Third Report"), to be filed, and the activities of the Information Officer and the fees and disbursements of the Information Officer and its counsel.
 
 Motion Record of the Foreign Representative
April 18, 2024
A Notice of Motion for the Second Recognition Order, recognizing and enforcing in Canada the following orders of the U.S. Bankruptcy Court:
i) The Final Securitization Order, authorizing certain Debtors to continue selling and servicing consumer loan receivables and related rights;
ii) The Final Securitization Order, authorizing certain Debtors to enter into amendments to the Securitization Transaction Documents and granting related relief;
iii) The Final Critical Vendor Order, authorizing the Debtors to pay certain critical vendor claims and granting related relief.
 
 Factum of the Foreign Representative (Recognition Order)
April 3, 2024
This factum is filed in support of a motion under section 49 the Companies' Creditors Arrangement Act (the "CCAA") by CURO Group Holdings Corp. ("CURO Parent") in its capacity as the foreign representative (in such capacity, the "Foreign Representative") of itself and the other Debtors for an order recognizing and enforcing in Canada certain orders made by the United States Bankruptcy Court for the Southern District of Texas (the "U.S. Bankruptcy Court") in connection with the Debtors' Chapter 11 Cases
 
 Motion Record of the Foreign Representative
April 1, 2024
The motion is for an order pursuant to section 49 of the Companies' Creditors Arrangement Act, R.S.C. 1985, c. C-36, as amended (the "CCAA") recognizing and enforcing in Canada the following orders of the United States Bankruptcy Court for the Southern District of Texas (the "U.S. Bankruptcy Court") in the cases (the "Chapter 11 Cases") commenced by the Debtors under chapter 11 of title 11 of the United States Code (the "Bankruptcy Code"): i) Securitization Amendment Order, ii) Critical Vendor Order, iii) Utilities Order, iv) Final Taxes Order, v) Disclosure Statement Order, vi) Revised Customer Programs Order.
 
 Affidavit (Second) of Alec Hoy (sworn March 25, 2024)
March 25, 2024
This affidavit was filed in support of a motion of the proposed Foreign Representative for relief pursuant to Part IV of the Companies' Creditor Arrangement Act, R.S.C. 1985, c. C-36, as amended.
 
 Affidavit (First) of Alec Hoy (sworn March 25, 2024)
March 25, 2024
This affidavit was filed in support of a motion of the proposed Foreign Representative for relief pursuant to Part IV of the Companies' Creditor Arrangement Act, R.S.C. 1985, c. C-36, as amended.
 
 Application Record
March 25, 2024
This is the Application Records of CURO Group Holdings Corp. ("CURO Parent"), Inc. for, inter alia:
(a) The Interim Order;
(b) Appointing the Applicant as the foreign representative;
(c) Declaring that the centre of main interest is the United States of America and recognizing the Chapter 11 Cases as a "foreign main proceeding";
(d) Appointing FTI Canada as information officer
 
 Factum of the Applicant (Application for Recognition of Foreign Main Proceeding)
March 25, 2024
This factum is filed in support of an application under Part IV of the Companies' Creditors Arrangement Act (the "CCAA") and section 106 of the Courts of Justice Act, R.S.O. 1990, c C.43, by CURO Group Holdings Corp. ("CURO Parent") as the proposed foreign representative (in such capacity, the "Proposed Foreign Rep") of itself, CURO Canada Corp. ("CURO Canada") and LendDirect Corp. ("LendDirect" and together with CURO Canada, the "Canadian Debtors"). On March 25, 2024, CURO Parent, the Canadian Debtors, and certain other affiliates (the "Debtors") filed voluntary petitions for relief pursuant to chapter 11 of title 11 of the United States Code (the "U.S. Bankruptcy Code") with the United States Bankruptcy Court for the Southern District of Texas (the "U.S. Bankruptcy Court") to commence insolvency proceedings (the "Chapter 11 Cases")
 

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