Case 1:22-cv-00685-MKV Document 1 Filed 01/26/22 Page 1 of 18

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK

SAVILLS INC.,
No.: 22-cv-_____
Plaintiff,
COMPLAINT
v.

4FRONT VENTURES CORP.,

Defendant.

Plaintiff Savills Inc. (“Savills”), by and through its attorneys, Greenberg Traurig, LLP, as

and for its complaint against the defendant, 4Front Ventures Corp. (“4Front”), alleges as follows:

SUMMARY OF THE ACTION

1. Savills brings this action to recover sums due to Savills under a written agreement

between 4Front and Savills. In November 2020 4Front engaged Savills to create, identify or

negotiate for governmental or other economic or business incentives for a commercial cannabis

cultivation and manufacturing facility. In the written agreement between Savills and 4Front

entitled “Engagement Agreement for Business and Economic Incentives for 4Front Plant Project”

(the “Incentives Agreement”), 4Front agreed “to pay Savills a fee (the “Fee”) equal to 15% of

the governmental or other economic or business incentives of Benefits (the “Benefits”) created,

identified or negotiated by Savills for the Client, provided that such Benefits have been approved

by the Client and that any required upfront governmental approvals have been received”. The

Incentives Agreement provides that Savills’ Fee shall be “earned upon approval of such Benefits

by Client and receipt of any required upfront governmental approvals” and that such Fee shall be

paid 50% when earned and 25% upon each of the first and second anniversaries of when earned.

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2. Acting pursuant to the Incentives Agreement and based upon expertise developed

over decades of work, Savills planned, initiated and oversaw all aspects of a process under which

4Front received government incentives conservatively valued at over $129 million for a new

facility in Matteson, Cook County, Illinois, which is now under construction by 4Front. These

incentives include real property tax incentives (the “Real Property Tax Incentives”)

conservatively valued at over $121 million and Enterprise Zone utility tax, sales tax, income tax

and permit fees incentives (the “Enterprise Zone Incentives”) conservatively valued at over $7.7

million. The resulting earned Fee is in excess of $19,000,000.

3. Under the terms of the Incentives Agreement, 4Front is obligated to pay Savills

one-half of its Fee, i.e., approximately $9.7 million, within 30 days of “approval of such Benefits

by the Client and the receipt of any required upfront government approvals”. There can be no

doubt that both of these conditions have been met. 4Front approved the Real Property Tax

Incentives and the Enterprise Zone Incentives by signing the applications for and by actively

participating in the process to obtain the Incentives and, as described more fully below, the

“upfront governmental approvals” have been obtained.

4. In August 2021 4Front closed on a long-term lease of the Matteson site and 4Front

is presently constructing its facility, including availing itself of the government incentives

obtained.

5. On October 27, 2021, Savills presented its invoice for $9,703,048. To date, Savills

has received no payment of this invoice and no payment whatsoever under the Incentives

Agreement, despite over a year of work by Savills, both before and after the date of the Incentives

Agreement, despite 4Front moving forward with its project based on the benefits obtained, and

despite the Fee having been earned.

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6. Although 4Front and Savills had been in contact on an almost daily basis since

before entering into the Incentives Agreement, when Savills delivered its invoice for payment,

4Front went silent. 4Front did not surface until more than a month later, when, under threat of

litigation, it claimed that payment was premature and that Savills ought to be paid when “4Front

receives actual financial benefit”, in other words that Savills ought to be paid over the multi-year

terms of the various benefit programs under which the incentives were awarded, which range up

to 22 years. This is not what the Incentives Agreement provides and is not the basis on which

Savills has been working for over a year. As noted above, the Incentives Agreement expressly

provides that the Fee is earned when 4Front approves the incentives and any upfront governmental

approvals are received. These conditions have clearly been met.

7. Nonetheless, rather that honor its commitment, 4Front seeks to benefit from the

fruits of Savills’ expertise and efforts, while ignoring the terms of the Incentives Agreement under

which Savills provided its services. 4Front is in material breach of contract.

8. Apparently, this is not the first time 4Front has failed to pay its contract parties who

provide significant benefits to it as contracted. In a suit pending in the Superior Court of the State

of California, captioned Brothers For Life LLC v. 4Front Ventures Corp., Case No. 21 ST 28462,

the plaintiff alleges 4Front failed to pay its agreed fee after government approvals were obtained

to allow 4Front to operate its business, which 4Front denies.

9. Savills seeks now to recover from 4Front the approximately $9.7 million currently

owed to it under the Incentives Agreement, interest at the contractually specified rate of 12 percent

per annum, and a declaration from the Court that the 2nd and 3rd installments of the Fee will be

due in 2022 and 2023. Savills is also entitled to an award of its legal fees and expenses incurred

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in having to prosecute this action to collect its Fee, as the parties expressly agreed in the Incentives

Agreement.

THE PARTIES

10. Plaintiff Savills is a New York corporation with its principal place of business

located in New York, New York. Savills offers a wide range of commercial real estate brokerage

and advisory services, including tenant representation, capital markets, project management,

workforce/incentives and workplace strategy/occupant experience. Savills is a wholly owned

subsidiary of Savills plc, a 160-year-old publicly owned English corporation with offices around

the world. Savills has extensive expertise in locating suitable sites for clients and securing

economic benefits from state and municipal governments. This is the very expertise for which

4Front retained Savills.

11. Defendant 4Front Ventures Corp. is a British Columbia corporation with its

principal place of business in Phoenix, Arizona. 4Front cultivates, manufactures and dispenses

over 25 cannabis brands through retail outlets and dispensaries. It operates through approximately

six subsidiary companies located in North America. 4Front common stock trades over the counter

under the ticker symbol FFNTF. 4Front is reported to have a market capitalization of

approximately $663 million CAD ($530 million USD).

JURISDICTION AND VENUE

12. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1332 because

the citizenship of Savills (New York) is diverse from the citizenship of 4Front (Arizona) and the

amount in controversy, exclusive of interest and costs, exceeds the sum of seventy-five thousand

dollars ($75,000.00).

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13. In the Incentives Agreement 4Front consented to personal jurisdiction of this Court;

the relevant provision reads “[a]ny action or proceeding under this Agreement shall be brought

and maintained solely in the state and federal courts sitting in the County and State of New York,

to the exclusive jurisdiction of which the parties hereto hereby submit.”

14. Venue is proper in this forum under the same contract clause.

BACKGROUND

A. Savills begins to help 4Front identify and acquire a suitable site or facility.

15. In August 2020, Savills brokerage services division began to work with 4Front with

a view to identifying and helping 4Front acquire a suitable facility or site for a new cannabis

cultivation and manufacturing facility that 4Front would own and operate. 4Front had particular

specifications for its site or facility. The site or facility needed to be located where cannabis

production was lawfully permitted and to be zoned for industrial use.

16. The initial focus of the search was Cook County, Illinois, where 4Front had an

existing license for cultivation and processing. On or about November 13, 2020, Savills and 4Front

entered in an agreement under which Savills “accept[ed] the appointment as your exclusive real

estate advisor through May 31, 2021 to locate, negotiate and advise 4Front Ventures and its

subsidiaries on its real estate requirement in Cook County, IL.” This agreement provides that any

brokerage commission earned would be paid by the seller, not 4Front. The seller of the site paid

the commission due when 4Front acquired the property identified and now being developed by

4Front as its facility. Savills is not asserting any claim against 4Front under this agreement.

B. Savills work expands to include governmental incentives

17. Of special importance to 4Front was the availability of governmental incentives. In

early November 2020 representatives of Savills governmental incentives division joined the

Savills team working for 4Front.

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18. On or about November 17, 2020, Savills entered into the Incentives Agreement.

19. The Incentives Agreement describes a series of tasks and services that Savills was

to perform including Savills’ developing, detailing, and subsequently executing a seven-step

“turnkey” strategy to locate and deliver to 4Front a “ready-to-go” facility location. Savills further

agreed that it would “coordinate the incentive negotiations and approvals with the timing of the

Client’s [4Front’s] acquisitions, leases and expansions to meet project deadlines.” Savills also

expressly agreed “to provide the governmental incentives consulting services described in the

Proposal (the “Services”) with a view to obtaining for the Client governmental or other economic

or business incentives or benefits (together, the ‘Benefits’) for or in connection with the project

identified in the Proposal (the ‘Project’).”

20. Under the terms of the Incentives Agreement, in exchange for Savills services

4Front is obligated to pay a fee to Savills “equal to 15% of the governmental or other economic or

business incentives or benefits (the ‘Benefits’) created, identified or negotiated by Savills for the

Client, provided that such Benefits have been approved by the Client and that any required upfront

governmental approvals have been received, plus approved travel expenses.”

21. Notably, the Fee is not due when 4Front ultimately realizes the Benefits in a

particular tax year. Under the Incentives Agreement, the Fee is “(a) earned upon approval of such

Benefits by [4Front] and receipt of any required upfront governmental approvals, and (b) payable

as follows: (i) 50% within thirty (30) days of being earned, (ii) 25% one year after being earned,

and (iii) 25% two years after being earned.”

22. In the context of negotiating the Incentives Agreement, Savills provided 4Front

with a detailed written illustrative example of how Savills Fee is calculated and how it is paid.

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4Front never objected to the method of calculation or the timing of payment as reflected in that

example.

23. Article 8 of the Incentives Agreement provides in part that, “[s]hould any such sums

[due under the Incentives Agreement] be collected by or through an attorney at law, Client [4Front]

shall in addition be liable to Savills for attorneys’ fees.”

C. Savills oversees a multi-state competition for incentives.

24. In order to obtain maximum governmental incentives, Savills presented the project

to the economic development divisions of Illinois, Michigan and Massachusetts, three states in

which 4Front had licenses to operate. Savills investigated the applicable programs and regulatory

attitudes toward cannabis of each state, met (via Zoom) with representatives of each state, and

prepared detailed requests for proposal (RFPs). In early January 2021, after 4Front had reviewed

and approved the RFP’s, Savills submitted them to the economic development division of each

respective state. These RFPs were preceded and followed by many conversations with each state

government in order to explain the project benefits, all so as to obtain the maximum incentives for

4Front. For example, each state was provided with estimates of the project’s construction costs

and the number of full-time equivalent jobs the project would create. Savills obtained competitive

proposals from Illinois and Massachusetts.

25. Savills analyzed these proposals, including preparing detailed financial models, and

4Front, with Savills assistance, decided to focus on Illinois, specifically Cook County which

offered the most attractive incentive package including potential EDGE credits, Class 8

classification and Enterprise Zone benefits, and in which 4Front already had an existing operation.

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D. Savills identifies, and 4Front and Savills focus on, a site in Matteson, Cook County,
Illinois.

25. Because of the density of Cook County finding a suitable and available location

proved to be difficult. Savills surveyed the county from north to south and identified 16 potentially

viable sites. Savills worked with 4Front to narrow the list of candidates site to four, with the timing

of commencement of construction and likely governmental incentives packages of critical

importance.

26. With guidance from Savills, 4Front began to focus on a site which Savills had

identified in Matteson, Cook County, Illinois. This site presented numerous obstacles including

a. that a special use permit would be required for the cannabis use, as is the case

for any site in Illinois,

b. that portions of the site violated the Illinois law prohibiting a cannabis facility

within 2,500 feet of a school, place of worship or residence,

c. that the site needed to be subdivided to separate from other property owned by

the seller, and to the divide the purchased parcel to permit financing and to

satisfy the 2,500-foot requirement, and

d. that a zoning variance would be required to accommodate the phased

configuration of 4Front’s intended facility and to permit the smaller lots created

in order to effect the subdivision.

27. Nonetheless, 4Front and Savills agreed that if these issues could be overcome and

if the right price and incentives could be negotiated this site would be suitable for 4Front.

28. Savills led separate but coordinated lengthy negotiations with the owner of the site

for a contract to purchase and with the Village of Matteson for the maximum incentives.

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29. On or about February 22, 2021, 4Front entered into a purchase and sale agreement

with the owner of the site for a purchase price of approximately $6.5 million. The terms of the

purchase and sale agreement gave 4Front and Savills the time needed to conclude the incentives

negotiations and approvals and for all parties to address the other site issues identified above.

30. Savills was deeply involved in overcoming each of the obstacles referred to in

paragraph 26 above. Savills oversaw the preparation of the 298-page special use permit

application and the 50-page variance application. Because these two applications were so lengthy,

Savills created a written summary narrative for the Village of Matteson Planning Commission and

the Village of Matteson Board of Trustees. Savills also created presentations which were jointly

presented by Savills and 4Front to a Village of Matteson planning workshop session, the Village

of Matteson Planning Commission and the Village of Matteson Board of Trustees. Savills working

with 4Front obtained the unanimous approval of all bodies.

E. Savills Secures Valuable Tax and Other Economic Incentives.

Savills Identifies, and Qualifies 4Front for, Class 8 Benefits

31. Cook County Class 8 benefits substantially reduce real estate tax liability by

reducing the assessed value of the land and any improvements on the land from 25% of market

value to 10% of market value (a 60% reduction) for a period of ten years, followed by an 11th year

at 15% of market value (a 40% reduction) and a 12th year at 20% of market value (a 20%

reduction). Savills identified the Class 8 program to 4Front and handled all aspects of 4Front

qualifying for it, including negotiating with government officials, securing their support, preparing

the application and, after it had been signed by 4Front, filing it as required.

32. In order for a project to be classified in Class 8, the municipality in which the

project is located must support the private party’s application. Since the Matteson site met all the

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technical requirement of the Class 8 program, obtaining the Village of Matteson’s support was the

crucial step. Savills handled all aspects of obtaining that support.

33. In March 2021, during the process of Savills’ obtaining the Village of Matteson’s

support for the Class 8 classification, 4Front ignored Savills advice and several warnings and made

a public announcement of the project which caused the project to be disqualified from receiving

EDGE credits. The availability of EDGE credits had factored significantly in 4Front’s decision to

select the Matteson site and their loss adversely affected the project’s economics.

34. To overcome this loss, Savills conceived the idea of seeking an additional ten-year

term for the Class 8 classification. While additional terms are authorized by the Class 8 program

rules, the Village had never before supported an additional term for any project and, in order to

persuade them to do so in this instance, Savills conceived and arranged for (and 4Front paid for)

an Economic Impact Study to be prepared by an independent economic consulting firm. The $12

billion of economic impact identified in that report helped persuade the Village to support the

additional 10 years of the Class 8 classification.

35. 4Front readily acknowledged Savills’ critical role in obtaining the Village’s support

for the Class 8 classification. That support was officially given by the Board of Trustees on April

26, 2021. That evening, after the Board had acted, Ann Marie Collins, the head of Savills incentive

team, emailed 4Front that “Class 8 Just Was Approved at the City Council Meeting!” and later

that evening 4Front replied “This is fantastic news. I cannot thank you enough for the continued

hard work on this, as well as all of the incentives opportunities.”

36. Importantly, the Village of Matteson Board of Trustees supported both the regular

12-year term and the additional 10 years.

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37. Throughout the entire Class 8 process and continuing until and even after 4Front

closed on the purchase of the site, Savills refined and presented to 4Front Savills’ calculation of

the dollar value of the Class 8 classification. This calculation was based on very conservative

assumptions, including that there would be no increase in the project budget and no growth in the

tax rate or the Cook County Equalization Factor during the 22 years. An increase in either will

increase the value of the incentives. Even using these conservative assumptions, the value to

4Front of the Class 8 benefits for the 22-year term is over $121,000,000.

38. Clearly, with respect to the Class 8 Benefits, Savills has earned its Fee, and the

initial 50% of its Fee is overdue.

Savills Identifies, and Qualifies 4Front for, Enterprise Zone Benefits

39. Enterprise Zones are governmentally designated economically distressed

geographic areas in which, in order to spur growth and development, Illinois and its local

governments provide tax and other incentives. The site that Savills identified in Matteson, Illinois,

is located in the Will Cook Enterprise Zone, which covers portions of Will and Cook counties.

The Will Cook Enterprise Zone provides a package of business development tax

incentives, including exemptions from state, city and county sales tax, utility tax exemptions,

investment tax credits and reduced permitting fees.

40. Savills identified the availability of these Enterprise Zone incentives and oversaw

all aspects of the application process, dealing with the government officials as necessary, and

preparing 4Front’s application. 4Front signed the application on April 2, 2021, and Savills then

filed it with the government.

41. On May 5, 2021, the Enterprise Zone application was accepted. 4Front has already

begun to enjoy Enterprise Zone benefits. For example, 4Front has received a Building Materials

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Exemption Certificate confirming the exemption from sales tax of the materials bought for the

project. In another example, just last month a building permit was issued to 4Front upon payment

of a 50% discounted filing fee that is only available to qualified participants in the Enterprise Zone.

42. Throughout 2021, Savills refined and presented to 4Front its calculation of the

value of the Enterprise Zone incentives, demonstrating that the value of those incentives is not less

than $7,796,399 over 11 years.

43. As concerns the Enterprise Zone Benefits, Savills has earned its Fee, and the initial

50% of its Fee is overdue.

Savills Identifies and Pursues EDGE Credit Benefits for 4Front, Which 4Front Forfeits

44. Savills also identified and pursued EDGE Credit qualification on 4Front’s behalf.

EDGE Credits are negotiable economic incentives that provide businesses income tax credits that

are calculated based on the withholding tax revenue that results from new job creation. In order

to obtain EDGE Credits, the applicant must demonstrate that the credit is a “but-for” cause of the

development project, meaning the project would not have occurred but for the EDGE Credit

incentive.

45. Prior to securing EDGE Credit qualification, and despite Savills’ warning that

doing so would cost it a valuable incentive, 4Front announced that it would be constructing a new

manufacturing facility in Illinois. This announcement caused the 4Front project to be disqualified

from consideration for the EDGE credit on the ground that 4Front failed the legally required “but

for” test.

Development Agreement

46. To provide greater assurance to 4Front that it would receive the additional 10 years

of Class 8 incentives, Savills, with counsel engaged by 4Front, negotiated a detailed development

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agreement outlining Matteson’s commitments to 4Front, including a specific commitment

covering the additional 10 years. 4Front approved the development agreement, which Matteson

signed on October 7, 2021, locking in the benefits that Savills had obtained for 4Front.

Summary

47. All told, Savills created, identified or negotiated for 4Front incentives exceeding

$129 million in value: (a) $7,796,399 over 11 years for the Enterprise Zone incentives and (b)

$121,577,578 over 22 years for the Class 8 incentives.

48. Under the terms of the Incentives Agreement, 4Front is obligated to pay Savills a

Fee calculated based on 15 percent of the Benefits obtained upon its “receipt of any required

upfront government approvals,” with half the amount to be paid within 30 days, an additional 25

percent to be paid one year later, and the last 25 percent to be paid one more year later.

49. The Incentives Agreement also provides that the Fee calculation shall be updated

(up or down) to reflect actual information or updated estimates when the 2nd installment is due and

again when the 3rd installment is due and that if there is any such adjustment the amount payable

as the 2nd installment shall instead be equal to 75% of the updated Fee, less the amount of the first

installment, and the amount of the 3rd installment shall instead be equal to 100% of the updated

Fee, less the amount of the first and second installments. For example, as indicated above, the

original calculation was based, in part, on the assumption that the Cook County Equalization

Factor would not increase over the 22-year period of the incentives. However, it has already

increased by 10 percent from 2.916 to 3.2234. Savills is expressly reserving its rights under that

provision of the Incentives Agreement and fully expects that that adjustment will be upward.

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F. 4Front Materially Breaches the Incentives Agreement By Refusing to Pay Savills for Its
Services.

50. On October 22, 2021, Savills offered 4Front an accommodation to allow it to

manage its cash flow. Instead of an approximately $9.7 million payment due immediately, with

two subsequent payments of approximately $4.85 million, Savills stated that it would accept a

payment plan with a $6 million current payment, followed by four annual payments of $3.35

million if 4Front agreed to this payment plan by October 25, 2021. However, 4Front did not reply

to Savills’ offer by Savills’ deadline, and it was subsequently withdrawn.

51. On or about October 27, 2021, Savills sent 4Front an invoice for its services in the

amount due and owing of $9,703,048. That invoice expressly indicated that the 2nd and 3rd

installments would be billed in accordance with the Incentives Agreement. 4Front did not respond

to the invoice.

52. Having heard nothing from 4Front for more than a month, Savills, on December 1,

2021, through its General Counsel, informed 4Front by letter that it would refer the matter to

outside counsel if within ten days of 4Front’s receipt of the letter Savills did not receive payment

or a written proposal regarding payment.

53. On December 16, 2021, 4Front finally responded to Savills’ requests for payment

in a letter from 4Front’s CEO, Leo Gontmakher. In the letter, 4Front states it would not be making

any payments anytime soon, contending that, “[f]rom 4Front’s perspective, payments to Savills

are generated when 4Front agrees to planned benefits, necessary governmental approvals have

been received, and when 4Front receives actual financial benefit.”

54. The Incentives Agreement expressly provides for all the incentives described in this

Complaint to the contrary of 4Front’s stated position about when the Savills Fee is earned and

when it is due. That Agreement expressly provides that the Fee is earned and requires 4Front to

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begin paying the Fee upon the receipt of the “up-front government approvals” for the Benefits, not

when 4Front itself receives the actual financial benefit over a period of 22 years. As the Agreement

states: “The Fee with respect to any Benefits shall be (a) earned upon approval of such Benefits

by the Client and receipt of any required upfront governmental approvals, and (b) payable as

follows: (i) 50% within thirty (30) days of being earned, (ii) 25% one year after being earned, and

(iii) 25% two years after being earned.”

FIRST CAUSE OF ACTION

BREACH OF CONTRACT
(Non-Payment of Savills Fee When Due)

55. Savills repeats and realleges Paragraphs 1-54 as if fully set forth herein.

56. The Incentives Agreement is a binding contract between 4Front and Savills.

57. Savills has performed all of its obligations under the Incentives Agreement

necessary to earn its Fee.

58. 4Front’s failure and refusal to pay the amount of the Fee now due and owing to

Savills is a material breach of the Incentives Agreement.

59. As a result of 4Front’s material breach, Savills has sustained damages in an amount

no less than $9,703,048.

SECOND CAUSE OF ACTION

DECLARATORY JUDGMENT
(Balance of Savills Fee Accrues on Specified Anniversary Dates)

60. Savills repeats and realleges Paragraphs 1-59 as if fully set forth herein.

61. An actual case or controversy presently exists between Savills and 4Front regarding

Savills’ entitlement to the second and third payments due under the Incentives Agreement.

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62. Savills contends that the 2nd installment of its Fee is due no later than the first

anniversary of when the 1st installment became due and that the 3rd installment of its Fee is due no

later than the second anniversary of when the 1st installment became due.

63. 4Front contends that Savills is not entitled to any fee until 4Front actually receives

the financial benefit in the form of reduced tax payments over a period of 22 years.

64. 4Front’s letter to Savills of December 16, 2021, demonstrates that it does not intend

to pay the second and third fee installments when they come due under the Incentives Agreement.

65. Declaratory relief is therefore appropriate under 28 U.S.C. § 2201 to determine the

rights and obligations of the parties under the Incentives Agreement, as concerns when the second

and third payments of the fee are due.

THIRD CAUSE OF ACTION

BREACH OF CONTRACT
(Costs of Collection)

66. Savills repeats and realleges Paragraphs 1-65 as if fully set forth herein.

67. Article 8 of the Incentives Agreement provides that, “[s]hould any such sums [due

under the Incentives Agreement] be collected by or through an attorney at law, Client [4Front]

shall in addition be liable to Savills for attorneys’ fees.”

68. Savills informed 4Front by letter dated December 1, 2021, that, “[i]f, by the 10th

day after the day of this letter, we do not receive payment or a written proposal from you with

respect to payment, we will be forced to assume that you intend not to honor your obligations to

us and we will turn this matter over to our outside counsel for further action.”

69. 4Front did not respond within 10 days of the letter. When it did respond, 4Front

did not include payment or a written proposal with respect to payment. As a result, Savills was

forced to retain counsel to collect the Fee owed.

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70. Under Article 8 of the Incentives Agreement, 4Front is liable to Savills for the legal

fees and expenses Savills incurs in seeking to collect its duly earned Fee from 4Front, including

those incurred in prosecuting this action.

PRAYER FOR RELIEF

WHEREFORE, Savills requests judgment in its favor and against 4Front as to each Cause

of Action as follows:

(a) On the First Cause of Action, an award of compensatory damages in the amount of

$9,703,048;

(b) On the Second Cause of Action, a declaration that the 2nd installment of Savills’ fee

under the Incentives Agreement has been earned will become payable on the first anniversary of

the due date of the 1st installment, and that 3rd installment of Savills’ fee under the Incentives

Agreement has been earned and will become payable on the second anniversary of the due date of

the 1st installment;

(c) On the Third Cause of Action, under Article 8 of the Incentives Agreement an award

of Savills’ attorney’s fees and expenses it has incurred and will incur to collect its Fee from 4Front,

including the legal fees and expenses incurred in prosecuting this action;

(d) An award of Savills’ pre-judgment interest at the contractual rate of 12 percent per

annum; and

(e) Such other and further relief as this Court deems just and proper.

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Dated: New York, New York Respectfully submitted,

January 26, 2022
GREENBERG TRAURIG, LLP

James W. Perkins
Daniel Friedman
One Vanderbilt Avenue
New York, New York 10017
(212) 801-9200
(212) 801-6400 (facsimile)
perkinsj@gtlaw.com
friedmand@gtlaw.com

Attorneys for Plaintiff Savills Inc.

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