The application made by Nunavut Iron Ore, Inc. ("NIO"), Baffinland Iron Mines Corporation ("BIM Corp."), and 12334992 Canada Inc. ("123 Canada Inc.") (the "Applicants" and, together with Baffinland Iron Mines LP ("BIM LP"), the "Debtors"), for an order, substantially in the form attached at Tab 3 of this Application Record for an order (the "Initial Order"), pursuant to the Companies' Creditors Arrangement Act, R.S.C. 1985, c. C-36, as amended (the "CCAA", among other things:

1. declaring that the Applicants are debtor companies to which the CCAA applies;
2. declaring that BIM LP shall be bound by, and entitled to the protections and benefits of, the Initial Order as though it were an Applicant;
3. granting a stay of proceedings against the Debtors for an initial period of not more than ten days, subject to further order of this Court;
4. appointing FTI Consulting Canada Inc. ("FTI" or the "Monitor") as the court-appointed monitor of the Debtors;
5. authorizing the Debtors to continue using their existing cash management system;
6. granting the following charges against the property of the Debtors, in the following order of priority:
7. first, an administration charge in the amount of $2 million to secure the fees and disbursements of the Monitor, counsel to the Monitor, and counsel to the Debtors (the "Administration Charge");
1. second, a directors' and officers' charge in the amount of $14 million to indemnify the directors and officers of the Debtors or any member of the Operating Committee (defined below) to the extent such member is or was directly or indirectly exercising the powers of the directors of any of the Debtors for any obligations and liabilities they may incur in their capacities as directors or officers, or in the case of members of the Operating Committee, in their capacity as persons exercising the powers of directors during these proceedings (the "D&O Charge"); and
1. setting a date for a comeback hearing (the "Comeback Hearing") to be held within ten days of the Initial Order.

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