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Tacora - Motion Materials
The following motion materials have been filed in the proceedings:
 Draft Revised CCAA Termination Order
[Redline] Draft Revised CCAA Termination Order
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October 7, 2024 |
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| Factum of the Applicant Re: CCAA Termination Order (returnable October 7, 2024) |
October 4, 2024 |
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| Motion Record of the Applicant Re: CCAA Termination Order |
October 1, 2024 |
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Revised Draft Approval and Reverse Vesting Order
Revised Draft Approval and Reverse Vesting Order redline comparison to the version included at Tab 4 of the Motion Record of Tacora
Revised Schedule "B" to the Subscription Agreement
Revised Schedule "B" to the Subscription Agreement redline comparison to the version included at Exhibit "A" to the Affidavit of Heng Vuong sworn July 21, 2024
Revised Draft Stay Extension, DIP, and Fees Approval Order
Revised Draft Stay Extension, DIP, and Fees Approval Order redline comparison to the version included at Tab 5 of the Motion Record of Tacora
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July 25, 2024 |
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| Factum of the Monitor Re: Approval of Reports and Fees |
July 24, 2024 |
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Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Re: Sale Approval Motion (Returnable July 26, 2024)
Book of Authorities of Cargill, Incorporated and Cargill International Trading PTE Ltd. Re: Sale Approval Motion (Returnable July 26, 2024)
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July 24, 2024 |
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| Factum of the Applicant Re: Approval and Reverse Vesting Order and Stay Extension, DIP, and Fees Approval Order (returnable July 26, 2024) |
July 24, 2024 |
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On this motion, Tacora is seeking the:
(1) Approval and Reverse Vesting Order in the form included at Tab 4 of the Motion Record, among other things:
a. approving the Subscription Agreement entered into between Tacora and the Investors;
b. approving the Transactions contemplated in the Subscription Agreement;
c. granting releases in favour of certain parties; and
(2) Stay Extension, DIP, and Fees Approval Order in the form included at Tab 5 of the Motion Record, among other things:
a. approving the Monitor's Reports and the activities of the Monitor referred to therein;
b. approving the fees of the Monitor and its counsel;
c. approving the Third Amended and Restated DIP Agreement entered into between Tacora and Cargill; and
d. extending the Stay Period to October 7, 2024.
Motion Record of the Applicant Re: Approval and Reverse Vesting Order and Stay Extension, DIP and Fees Approval Order (Returnable July 26, 2024)
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July 22, 2024 |
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| Reply Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Re: Disclaimer and Global Process Motions (returnable June 26, 2024) |
June 25, 2024 |
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| Responding Factum of the Applicant, Tacora Resources Inc. Re: Disclaimer Motion and Global Process Motion (Returnable June 26, 2024) |
June 24, 2024 |
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| Addendum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Re: Reconstituted Preliminary Threshold Motion (returnable June 26, 2024) |
June 24, 2024 |
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| Supplement to the Responding Factum of the Monitor Dated April 6, 2024 |
June 20, 2024 |
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Factum of the Applicant, Tacora Resources Inc. Re: Reconstituted Preliminary Threshold Motion (Returnable June 26, 2024)
Supplementary Book of Authorities of the Applicant, Tacora Resources Inc. Re: Reconstituted Preliminary Threshold Motion (Returnable June 26, 2024)
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June 20, 2024 |
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Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Re: Disclaimer Motion (Returnable June 26, 2024)
Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Re: Global Process Motion (Returnable June 26, 2024)
Book of Authorities of Cargill, Incorporated and Cargill International Trading PTE Ltd. Re: Disclaimer Motion and Global Process Motion (Returnable June 26, 2024)
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June 20, 2024 |
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| Responding Record of the Applicant Re: Disclaimer Motion (Returnable June 26, 2024) |
June 14, 2024 |
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| Motion Record of the Applicant Re: Preliminary Threshold Motion (Returnable June 26, 2024) |
June 12, 2024 |
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| Motion Record of Cargill, Incorporated and Cargill International Trading PTD Ltd. Re: Motion to Set Aside Disclaimer (Returnable June 26, 2024) |
June 11, 2024 |
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| Motion Record of Cargill, Incorporated and Cargill International Trading PTE Ltd. (Global Process Motion) Returnable June 26, 2024 |
June 11, 2024 |
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| Reply Factum of the Applicant Re: Sales Process Motion (Returnable June 5, 2024) |
June 4, 2024 |
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| Responding Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Re: Tacora Sales Process and Stay Extension Motion |
June 4, 2024 |
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| Factum of the Applicant Re: Sales Process, KERP and Stay Extension Orders (Returnable June 5, 2024) |
June 3, 2024 |
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| Notice of Motion of Cargill (Motion to Set Aside Disclaimer) |
May 31, 2024 |
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Notice of Motion of the Applicant (Returnable June 26, 2024)
Motion Record of the Applicant Re: Sale Process and Stay Extension
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May 31, 2024 |
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| Aide Memoire of Cargill, Incorporated and Cargill International Trading Pte Ltd. (Case Conference - May 24, 2024) |
May 24, 2024 |
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| Aide Memoire of Tacora Resources Inc. |
May 21, 2024 |
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| Factum of Applicant, Tacora Resources Inc. Re: Stay Extension and Amended DIP Agreement (Returnable April 25, 2024) |
April 24, 2024 |
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Aide Memoire of the Consortium of Noteholders (Re Amended DIP Motion)
Responding Motion Record of the Consortium of Noteholders (Re Amended DIP Motion Returnable April 25, 2024)
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April 24, 2024 |
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| Factum of the Applicant, Tacora Resources Inc. Re: Stay Extension, Amended DIP and Claims Procedure Order Returnable April 23, 2024 |
April 22, 2024 |
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Motion Record of the Applicant, Tacora Resources Inc. Regarding Stay Extension Order and Claims Procedure Order Returnable April 2023, 2024
Motion Record of the Applicant, Tacora Resources Inc
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April 21, 2024 |
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| Book of Authorities of the Applicant, Tacora Resources Inc. RE: MFC Dispute |
April 15, 2024 |
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| Reply Factum of the Applicant, Tacora Resources Inc. Re: MFC Dispute |
April 14, 2024 |
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Notice of Motion of the Monitor Re: Sealing Order and MFC Royalty Dispute
Responding Factum of 1128349 B.C. Ltd. Re: MFC Dispute
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April 12, 2024 |
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| Joint Transcript Brief (MFC Dispute Returnable April 16, 2024) |
April 11, 2024 |
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| Reply Factum of the Consortium Noteholder Group Re: Approval of Successful Bid |
April 9, 2024 |
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Reply Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Re: Threshold Motion and Cross-Motion
Supplementary Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd.
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April 9, 2024 |
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| Reply Factum of the Applicant Re: Approval of Successful Bid |
April 9, 2024 |
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| Factum of the Applicant, Tacora Resources Inc. (MFC Dispute Returnable April 16, 2024) |
April 8, 2024 |
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Responding Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Regarding: RVO Motion
Book of Authorities of Cargill, Incorporated and Cargill International Trading PTE Ltd; Responding Factum Re: RVO Motion
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April 6, 2024 |
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Factum of the Consortium Noteholders responding to Cargill's Preliminary Motion and Cross Motion
Responding Factum of the Consortium Noteholder Group
Book of Authorities of the Consortium Noteholder Group
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April 6, 2024 |
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Responding Factum of the Monitor
Responding Factum of the Applicant, Tacora Resources Inc. (Preliminary Threshold Motion)
Responding Factum of the Applicant, Tacora Resources Inc. (Cross-Motion)
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April 6, 2024 |
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| Motion of the Monitor of the Applicant regarding a Sealing Order |
April 4, 2024 |
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| Reply Motion Record of the Applicant, Tacora Resources Inc. (MFC Dispute Returnable April 16, 2024) |
April 2, 2024 |
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| Responding Motion Record of 1128349 B.C. Ltd |
March 27, 2024 |
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Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Regarding Preliminary Threshold Motion
Factum of Cargill, Incorporated and Cargill International Trading PTE Ltd. Regarding Responding Cross Motion
Book of Authorities of Cargill, Incorporated and Cargill International Trading PTE Ltd. Regarding Responding Cross Motion
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March 27, 2024 |
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Factum of the Applicant, Tacora Resources Inc., regarding approval of successful bid (returnable April 10-12, 2024)
Factum of the Applicant, Tacora Resources Inc.
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March 27, 2024 |
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Factum of the Consortium Noteholder Group in support of the motion brought by Tacora Resources Inc. for an Approval and Reverse Vesting Order (the "Sale Approval Order")
Factum of the Consortium Noteholder Group
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March 27, 2024 |
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| Motion Record of the Applicant, Tacora Resources Inc. (MFC Dispute Returnable April 16, 2024) |
March 23, 2024 |
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Responding to Tacora Motion for Extension of the Stay Period and Replacement of the DIP and Supporting Cargill Cross-Motion, returnable March 18, 2024.
Book of Authorities of Cargill, Incorporated and Cargill International Trading Pte Ltd
Factum Cargill, Incorporated and Cargill International Trading Pte Ltd
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March 17, 2024 |
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| Written Submissions of the Consortium Noteholder Group (DIP Motion - March 18, 2024) |
March 17, 2024 |
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| Factum of the Applicant Regarding the Second Amended and Restated Initial Order and A&L Premium Finance Agreement Approval Order (Returnable March 18, 2024) |
March 15, 2024 |
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Motion Record of Cargill, Incorporated and Cargill International Trading Pte Ltd. For Cargill's Responding Cross-Motion (Motion Returnable March 18, 2024)
Motion Record of Cargill, Incorporated and Cargill International Trading Pte Ltd.
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March 14, 2024 |
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| Reply Record of the Applicant (Approval and Reverse Vesting Order) |
March 14, 2024 |
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Motion Record of the Applicant, Tacora Resources Inc., re a Second Amended and Restated Initial Order and A&L Premium Finance Agreement Approval Order
Motion Record of Tacora Resources Inc.
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March 11, 2024 |
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Aide Memoire of Tacora Resources Inc. in connection with a dispute between Tacora and 1128349 B.C. Ltd. ("MFC").
Aide Memoire of Tacora Resources Inc.
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March 4, 2024 |
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Responding motion record and motion record for the responding cross-motion of Cargill, Incorporated and Cargill International Trading PTE Ltd.
Motion Record Cargill
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March 1, 2024 |
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Aide Memoire of Cargill in connection with the case conference before Kimmel J. on February 9, 2024, at 12:00 p.m. (ET).
Aide Memoire of Cargill, Incorporated and Cargill International Trading Pte Ltd.
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February 9, 2024 |
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Aide Memoire of the Monitor in connection with the case conference before Kimmel J. on February 6, 2024, at 12:00 p.m. (ET).
Aide Memoire of the Monitor
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February 6, 2024 |
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Aide Memoire of Cargill in connection with the case conference before Kimmel J. on February 6, 2024, at 12:00 p.m. (ET).
Aide Memoire of Cargill, Incorporated and Cargill International Trading Pte Ltd.
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February 5, 2024 |
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Motion Record of Cargill, Incorporated and Cargill International Pte Ltd. (together, "Cargill") in support of Cargill's Preliminary Threshold Motion.
Motion Record for Cargill's Preliminary Threshold Motion
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February 5, 2024 |
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Aide Memoire of the Consortium Noteholder Group in connection with the case conference before Kimmel J. on February 6, 2024, at 12:00 p.m. (ET).
Aide Memoire of the Consortium Noteholder Group
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February 5, 2024 |
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Aide Memoire of Tacora Resources Inc. in connection with the case conference before Kimmel J. on February 6, 2024, at 12:00 p.m. (ET).
Aide Memoire of Tacora Resources Inc.
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February 5, 2024 |
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Motion Record of the Applicant, Tacora Resources Inc., in support of its motion (the "Sale Approval Motion") seeking an Approval and Reverse Vesting Order.
Motion Record of the Applicant (Approval and Reverse Vesting Order)
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February 2, 2024 |
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Motion record of the applicant re stay extension and approval of Premium Finance Agreement returnable January 24, 2024
Motion Record of Tacora Resources Inc
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January 17, 2024 |
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Motion in relation to insurance premium financing agreements
Motion Record of First Insurance Funding of Canada Inc.
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November 16, 2023 |
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Affidavit of Thomas Gray of Bennett Jones LLP, counsel to an ad-hoc group of holders, in the matter of a plan of compromise or an arrangement of Tacora Resources Inc.
Affidavit of Thomas Gray (Sworn October 26, 2023)
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October 26, 2023 |
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Comeback Motion of Tacora Resources Inc. for an Amended and Restated Initial Order, and Cross-Motion of the Ad Hoc Group of Noteholders, returnable October 24, 2023
Compendium of the Cargill, Incorporated and Cargill International Trading PTE Ltd.
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October 24, 2023 |
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| Reply Factum of the Applicant Regarding Comeback Motion Returnable October 24, 2023 |
October 23, 2023 |
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| Reply Factum of the Ad Hoc Group of Noteholders |
October 23, 2023 |
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Comeback Motion of Tacora Resources Inc. for an Amended and Restated Initial Order, and Cross-Motion of the Ad Hoc Group of Noteholders, returnable October 24, 2023
Reply Factum of Cargill, Incorporated and Cargill International Trading LTD.
Book of Authorities of Cargill, Incorporated and Cargill International Trading LTD.
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October 23, 2023 |
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Comeback Motion of Tacora Resources Inc. for an Amended and Restated Initial Order, and Cross-Motion of the Ad Hoc Group of Noteholders, returnable October 24, 2023
Factum of Cargill, Incorporated and Cargill International Trading LTD.
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October 22, 2023 |
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| Factum of the Applicant Regarding the Comeback Hearing Returnable October 24, 2023 |
October 22, 2023 |
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| Factum of the Applicant Regarding the AHG Cross-Motion Returnable October 24, 2023 |
October 22, 2023 |
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Factum of the Ad Hoc Group of Noteholders Returnable October 24, 2023
Book of Authorities of the Ad Hoc Group of Noteholders
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October 22, 2023 |
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Cross-Motion for an Amended and Restated Initial Order ("ARIO"), among other things, approving DIP financing to be provided by the Ad-Hoc Group
Motion Record of the Ad Hoc Group of Noteholders (Returnable October 24, 2023)
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October 16, 2023 |
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Supplementary application record in support of the proposed KERP and the Solicitation Process
Supplementary Application Record
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October 15, 2023 |
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Motion for the issuance of an initial order in respect of Tacora Resources Inc. along with the factum of the applicant
Application Record of Tacora Resources Inc
Factum of the Applicant
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October 10, 2023 |
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