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Mitel Networks Corporation - Motion Materials

The following motion materials have been filed in the proceedings:

 Factum of the Applicant (Motion for Confirmation Recognition and Termination Order)
 Motion for Confirmation Recognition and Termination Order
April 24, 2025
 
 Factum of the Applicant (Application for Initial Recognition Order and Supplemental Order) March 17, 2025
 
 Factum of the Applicant (Application for Interim Stay Order) March 10, 2025
The Applicant, Mitel Networks Corporation ("MNC"), makes this Application on its own behalf and in its capacity as the proposed foreign representative (in such capacity, the "Foreign Representative") for certain relief pursuant of Part IV of the Companies' Creditors Arrangement Act (the "CCAA"). MNC seeks an order from this Court granting a stay of proceedings in Canada (the "Interim Stay") in respect of MNC and its directors and officers (the "Interim Stay Order"). MNC anticipates returning before this Court on March 19, 2025, which will be following the First Day Hearing of the U.S. Bankruptcy Court, to seek additional orders to, among things:

(a) declare MNC as the Foreign Representative in respect of the Chapter 11 Cases;

(b) recognize the Chapter 11 Cases as a "foreign main proceeding" in respect of MNC;

(c) recognize certain First Day Orders granted by the U.S. Bankruptcy Court; and

(d) obtain certain other relief, including the appointment of an information officer and the granting of certain charges over MNC's property in Canada.
 
 Application Record March 10, 2025
This is the Application Record of Mitel Networks Corporation ("MNC"), as the proposed foreign representative in respect of the Chapter 11 Cases, for the following relief pursuant to Part IV of the Companies' Creditors Arrangement Act, R.S.C. 1985, c. C-36, as amended (the "CCAA") and Section 106 of the Courts of Justice Act, RSO 1990, as amended (the "CJA"):

(a) the Interim Stay Order, which seeks a stay of proceedings in Canada in respect of MNC and its directors and officers;

(b) the Initial Recognition Order, which seeks recognition of: (i) Chapter 11 Cases as a "foreign main proceeding" in respect of MNC, and (ii) MNC as the foreign representative (the "Foreign Representative") in respect of the Chapter 11 Cases;

(c) the Supplemental Order, which seeks: (i) recognition of certain interim and final orders issued by the U.S. Bankruptcy Court, (ii) granting a stay of proceedings in Canada in respect of MNC and its directors and officers that will replace the Interim Stay; (iii) appointment of FTI Consulting Canada Inc. ("FTI Canada") as the information officer in respect of these proceedings (the "Information Officer"); and (iv) granting of Administration Charge, D&O Charge, and DIP Charge, among other things.
 

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