1. the activities of the Monitor since the issuance of the Initial Order; and
2. the relief sought by the Applicants at the Comeback Hearing, including, among other things approval of the amended and restated Initial Order (the "ARIO"), which, inter alia:
1. increases the quantum of certain of the CCAA Charges (defined below) and elevates the priority ascribed to the CCAA Charges over all Encumbrances (as defined in the ARIO);
2. seeks authorization for the Applicants to pay reasonable expenses incurred by them in operating the business in the ordinary course, including making payments of obligations owing in respect of goods and services supplied to the Applicants prior to the date of the Initial Order by critical vendors to the extent required to ensure ongoing supply of critical goods and services, subject to prior approval by the Monitor up to a maximum aggregate amount of $290,000;
3. authorizes the Applicants to file a plan of compromise or arrangement;
4. prohibits any person from setting off amounts that: (a) are or may become due to the Applicants in respect of obligations arising prior to the date of the Initial Order with any amounts that are or may become due from the Applicants and respective obligations arising on or after the date of the Initial Order; or (b) are or may become due from the Applicants in respect of obligations arising prior to the date of the Initial Order with any amounts that are or may become due to the Applicants in respect of obligations arising on or after the date of the Initial Order without the consent of the Applicants and the Monitor or further Order of this Court; and
5. extends the Stay Period until and including June 11, 2026.

1. FTI's qualifications to act as Monitor, if appointed;
2. the activities of FTI to date;
3. FTI's comments regarding the Applicants' cash management system;
4. FTI's comments regarding the Applicants' proposed stakeholder communication plan (the "Communication Plan");
5. the Applicants' proposed treatment of certain pre-filing payables in the Proposed Initial Order;
6. the Applicants' consolidated 9-week cash flow projections of its receipts and disbursements to June 12, 2026 (the "Cash Flow Projection") and the reasonableness thereof, in accordance with section 23(1)(b) of the CCAA;
7. the Applicants' proposed administration charge (the "Administration Charge") and proposed directors' and officers' charge (the "D&O Charge" and together with the Administration Charge the "Proposed CCAA Charges");
8. A discussion of the Applicants' intended next steps in the CCAA Proceedings, including relief that the Proposed Monitor understands the Applicants intend to seek at a proposed comeback hearing (the "Comeback Hearing") if the requested Proposed Initial Order is granted, including:
1. amendments to the amounts and rankings of the Proposed CCAA Charges; and
2. an extension to the Stay of Proceedings to June 11, 2026; and
9. FTI's views with respect to the proposed CCAA Proceedings and certain of the relief sought in the Proposed Initial Order.

Contact FTI

FTI Consulting
TD Waterhouse Tower
79 Wellington Street West
Suite 2010, P.O. Box 104
Toronto, Ontario M5K 1G8

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