Motion Materials / Requêtes

Attached please find the factum of the Applicants in connection with their motion returnable March 9, 2012 for an Order, inter alia: (a) approving the Stalking Horse Agreement, (b) approving the DIP Amendment, (c) approving the Bidding Procedures, (d) approving certain protections granted to the Stalking Horse Bidder, (e) providing that Timminco shall not be required to hold any meeting of its shareholders during the Stay Period, and (f) approving the Third and Fourth Reports / Rapports of the Monitor. We do not intend to provide hard copies of the factum and book of authorities unless otherwise requested.

Book of Authorities of the Applicants, returnable March 9, 2012

March 7, 2012

Attached please find the Book of Authorities in connection with the Applicants motion returnable March 9, 2012 for an Order, inter alia: (a) approving the Stalking Horse Agreement, (b) approving the DIP Amendment, (c) approving the Bidding Procedures, (d) approving certain protections granted to the Stalking Horse Bidder, (e) providing that Timminco shall not be required to hold any meeting of its shareholders during the Stay Period, and (f) approving the Third and Fourth Reports / Rapports of the Monitor. We do not intend to provide hard copies of the factum and book of authorities unless otherwise requested.

Timminco Notice of Appearance

March 5, 2012

The Notice of Appearance of Mercer (Canada) Limited in its capacity as administrator of the Haley Pension Plan

Draft Order

March 5, 2012

Draft Order in respect of the Authorization and Direction to Enter into the Stalking Horse Agreement, Approval of the Bidding Procedures and DIP Amendment, and Postponement of the Annual Meeting of Shareholders

Motion Record of the Applicants

Motion Record Part 1

Motion Record Part 2

March 2, 2012

USW - Notice of Motion for Leave to Appeal

February 24, 2012

USW - Notice of Motion for Leave to Appeal

February 24, 2012

Notice of Motion to appeal decision of Justice Morawetz February 9, 2012

February 23, 2012

Notice of Motion for leave to appeal the decision of Justice Morawetz February 2, 2012

February 23, 2012

The Book of Authorities of the Communications, Energy and Paperworkers Union of Canada

Timminco BOA

Timminco Factum

Timminco Motion Record

February 3, 2012

Timminco Factum, motion for, inter alia, approval of DIP Facility

January 25

Timminco Book of Authorities, motion for, inter alia, approval of DIP Facility

Timminco Book of Authorities, motion for, inter alia, approval of DIP Facility - Part 1

Timminco Book of Authorities, motion for, inter alia, approval of DIP Facility - Part 2

January 25, 2011

Companies Motion to Extend Stay and for approval of DIP Financing

January 20

Respondent's Motion Materials / Requêtes

Motion Record

CEP BOA

Factum

January 11, 2011

Responding materials filed by the Communications, Energy and Paperworkers Union of Canada

Timminco Factum

January 9, 2012

The factum of the Applicants in connection with their motion returnable January 12, 2012 for an Order, inter alia: (a) suspending the Timminco Entities’ obligations to make certain pension contributions with respect to their pension plans, (b) approving the KERPs and a KERP Charge, and (c) granting increased priority to the Administration Charge and the D&O Charge.

Motion Record Part I – Notice of Motion, Affidavit of Peter A.M. Kalins, sworn January 5, 2012, Exhibit A

Motion Record Part II – Exhibit A (continued), Exhibit B-D, Draft Order

January 5, 2012

Motion filed by the Timminco Entities for an order (a) suspending the Timminco Entities’ special payment obligations with respect to their Pension Plans, (b) approving the KERPs and a KERP Charge, and (c) granting super-priority to the Administration Charge and the D&O Charge.

Notice of Initial Application

January 3, 2012

Initial Application

Application Part 1

Application Part 2

Application Part 3

Application Part 4

Factum

January 3, 2012

The attached files include the Applicants initial application for an order under the CCAA, the Index below summarizes the contents of the files. Page numbers within the application can be found in the top right hand corner.

TAB	DOCUMENT	PAGE#
1	Notice of Application	1 – 7
2	First Affidavit of Peter A.M. Kalins, sworn January 2, 2012	8 - 51
A	Exhibit “A” – Corporate chart of the Timminco Entities and their subsidiaries	52 - 53
B	Exhibit “B” – Redacted Framework Agreement dated August 10, 2010	54 – 139
C	Exhibit “C” – Transfer Agreement dated September 30, 2010	140 – 154
D	Exhibit “D” – Limited Partnership Agreement dated October 1, 2010	155 - 221
E	Exhibit “E” – Shareholders Agreement dated October 1, 2010	222 – 257
F	Exhibit “F” – Redacted Supply Agreement dated October 1, 2010	258 – 278
G	Exhibit “G” – Term Loan Agreement datedJuly 10, 2009 (executed copy in French followed by unofficial English translation)	279 – 322
H	Exhibit “H” - Copies of the guarantee granted by Timminco and of the hypothec granted by BSI	323 – 338
I	Exhibit “I” - Amendments to Term Loan Agreement (executed copies in French followed by unofficial English translations)	339 – 368
J	Exhibit “J” –2010 Annual Audited Consolidated Financial Statements and Management Discussion and Analysis	369 – 442
K	Exhibit “K” – First Quarter 2011 Interim Consolidated Financial Statements and Management Discussion and Analysis	443 - 537
L	Exhibit “L” – Second Quarter 2011 Interim Consolidated Financial Statements and Management Discussion and Analysis	538 – 592
M	Exhibit “M” – Third Quarter 2011 Interim Consolidated Financial Statements and Management Discussion and Analysis	593 – 656
N	Exhibit “N” – Cashflow Forecast and Management Report on Cash flow	657 – 659
3	Draft Initial Order	660 – 680
4	Blackline to Model Initial Order	681 - 706

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