On April 30, 2015, FTI Consulting Canada Inc. was appointed as receiver of all the assets, undertakings and properties of Seacliff (the "Receiver") pursuant to the terms of the Security Agreement between Caterpillar Financial Services Ltd. and Seacliff dated October 13, 2010 and the Appointment Letter dated April 30, 2015 (the "Appointment Letter"). The Receiver has agreed to sell, assign and transfer certain assets to 2423515 Ontario Ltd. (the "Purchaser"), and the Purchaser has agreed to purchase such assets and assume certain liabilities of Seacliff, as per the terms of the Asset Purchase Agreement dated April 30, 2015 (the "APA").

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FTI Consulting
TD Waterhouse Tower
79 Wellington Street West
Suite 2010, P.O. Box 104
Toronto, Ontario M5K 1G8

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