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Trion - Motion Materials

The following motion materials have been filed in the proceedings:

 Bench Brief re AVO and CCAA Termination May 5, 2026
1. This brief is submitted on behalf of TRION BATTERY TECHNOLOGIES INC. ("Trion" or the "Applicant") in support of its application on May 6, 2026.
2. The Applicant seeks an Order(s), among other things:
(a) Approving the transaction contemplated by the equity and asset purchase agreement between the Applicant and Rockford Equity PTY Ltd. (the "Purchaser") dated as of April 29, 2026 (the "Sale Agreement");
(b) Vesting the Purchased Assets (as defined in the Sale Agreement) in the Purchaser, free and clear of all encumbrances;
(c) Approving the activities of the Monitor;
(d) Approving the fees and disbursements of the Monitor and its legal counsel;
(e) Terminating the proceedings commenced by the Applicant under the Companies’ Creditors Arrangement Act1;
(f) Approving the releases in favour of the Monitor and its legal counsel; and
(g) Extending the stay of proceedings.
 
 Approval of Sale Transaction May 4, 2026
The Applicant, TRION BATTERY TECHNOLOGIES INC. ("Trion" or the "Applicant") respectfully seeks:
(a) an Order substantially in the form attached hereto as Schedule "A":
(i) abridging the time for service of this Application and the supporting materials, as necessary, and deeming service thereof to be good and sufficient;
(ii) approving the transaction contemplated by the equity and asset purchase agreement entered into between the Applicant and Rockford Equity PTY Ltd. (the "Purchaser") dated May, 2026 (the "Sale Agreement");
(iii) vesting the Purchased Assets (as defined in the Sale Agreement) in the Purchaser, free and clear of all encumbrances; and
(iv) sealing the unredacted copy of the Sale Agreement;
(b) an Order substantially in the form attached hereto as Schedule "B":
(i) abridging the time for service of this Application and the supporting materials, as necessary, and deeming service thereof to be good and sufficient;
(ii) approving the activities of FTI Consulting Canada Inc. ("FTI"), in its capacity as monitor (the "Monitor") as detailed in the reports filed with this Honourable Court;
(iii) approving the fees and disbursements of the Monitor and its legal counsel, Bennett Jones LLP;
(iv) approving a wind-up reserve in the amount of $125,000;
(v) approving the discharge of the Monitor;
(vi) terminating the within proceedings upon the Monitor filing a certificate confirming that all matter in respect of such proceedings have been completed (the "Termination Time"); and
(vii) extending the stay of proceedings until the earlier of May 22, 2026 and the Termination Time;
(c) such further and other relief as counsel may request and this Honourable Court may deem appropriate in the circumstances.
 
 Bench Brief of the Applicant re: Extension of Stay of Proceedings and Approval of the Sale and Investment Solicitation Process March 2, 2026
The Applicant seeks:
(a) an amended and restated initial order ("ARIO") pursuant to the Companies' Creditors Arrangement Act, which, in addition to the relief granted pursuant to the Initial Order of Justice L.K. Harris dated February 20, 2026 (the "Initial Order") extends the stay of proceedings to May 15, 2026;
(b) an order approving the Sale and Investment Solicitation Process (the "SISP").
 
 Initial Application February 20, 2026
Motion for the issuance of an initial order in respect of TRION BATTERY TECHNOLOGIES INC. (the "Applicant"), along with TRION Battery GmbH, TRION Battery Germany GmbH and TRION ENERGY SOLUTIONS CORP. (the "Non-Applicant Stay Parties", and collectively with the Applicant, the "Trion Group").
 

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