CANADA

PROVINCE OF QUÉBEC SUPERIOR COURT

(CIVIL DIVISION)
DISTRICT OF LONGUEUIL
No: STEVE SALEEN, an individual having his domicile
at 5059 Scholarship, in the city of Irvine, California,
United States of America;

-and-

SALEEN AUTOMOTIVE, INC., a corporation duly

incorporated under the laws of Delaware, having a
place of business at 2735 Wardlow Road, in the
city of Corona, California, United States of America

Plaintiffs

v.

FREDERIC LAMBERT, an individual domiciled at

1623 rue Gaulle, in the city and district of
Longueuil, Province of Québec, J4T 1M7;

-and-

925 LLC, a corporation duly incorporated under

the laws of New York, having a place of business
at 19 Clinton st., in the city of Pleasantville, New
York, United States of America;

-and-

JOHN DOE AND JANE DOE

Defendants

APPLICATION FOR PROVISIONAL, INTERLOCUTORY AND PERMANENT

INJUNCTION, APPLICATION SEEKING AN ORDER TO APPEAR BEFORE THE
COURT TO ANSWER TO AN ACCUSATION OF CONTEMPT OF COURT AND
APPLICATION FOR A DECLARATION IN CONTEMPT OF COURT
(Art. 57 and ff and 509 and ff. C.C.P.)

TO ONE OF THE HONORABLE JUDGES OF THE SUPERIOR COURT OF

QUÉBEC, SITTING IN CHAMBER IN AND FOR THE DISTRICT OF LONGUEUIL
THE PLAINTIFFS SUBMIT:
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I. INTRODUCTION

1. For the reasons expounded below, Plaintiffs, Mr. Steve Saleen (“Mr. Saleen”)
and Saleen Automotive, Inc. (“SAI”), hereby seek an order in contempt of
court against Defendant, Mr. Frédéric Lambert (“Mr. Lambert”) and
provisional, interlocutory and permanent injunctive orders against Defendants,
Mr. Lambert and 925 LLC (“925”), restraining them, inter alia, from posting
defamatory comments with respect to Plaintiffs or to otherwise disseminating
false and highly prejudicial information against them .

2. In short, for unknown reasons, Mr. Lambert has continued posting defamatory
comments on Plaintiffs specifically on 925’s website, Electrek.co, of which he
is the chief editor and co-founder, as well as on Twitter the whole contrary to
the permanent injunction issued against Mr. Lambert, and third parties aware
of the injunction, by the Superior Court of Quebec on July 28, 2015 (the “2015
Order”), as appears from a copy of the judgment, Exhibit P-1.

3. Actually, Mr. Lambert defies this Court’s authority and intentionally disregards
the 2015 Order.

4. Defendants’ actions adversely affect and impact Plaintiffs’ respective

reputations.

5. It is of the utmost importance that this Honourable Court cite Mr. Lambert to
answer to the accusations of contempt of Court and to urgently and
permanently order Defendants to halt all outrageous and unjustifiable
behaviour, which continues unabated to this day.

II. THE PARTIES

6. Mr. Saleen is the president of SAI.

7. After a career as a race-car driver, he founded the predecessor of SAI in

1983.

8. SAI is a Delaware-incorporated corporation which designs, develops,

manufactures and sells high performance vehicles built from of Ford
Mustangs, Chevrolet Camaros, Dodge Challengers and Tesla Model S

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vehicles chassis, as well as a broad line of performance parts, customizable

designs, engineering and certification services the whole as more fully
described in the printed extracts of SAI’s website communicated as Exhibit P-
2, and as appears from SAI’s Offering Circular dated March 31, 2022 filed
with the U.S. Securities and Exchange Commission (the “SEC”)
communicated as Exhibit P-3.

9. SAI’s common shares are quoted on the OTC Bulletin Board, an over-the-
counter market, under the symbol “SLNN”.

10. Mr. Lambert, is an individual residing in Longueuil, Québec. He claims to be

editor in chief and one of the founders of Electrek.co, a website belonging to
Defendant 925, and to have an interest in car-related blogging, as appears
from his professional profile posted on LinkedIn® and the extract from the
website of Electrek.co communicated as Exhibits P-4 and P-5 respectively.

11. According to Mr. Lambert’s LinkedIn® profile, he was responsible for “almost
single-handedly” producing around “95% of the content” on 925’s website
Electrek.co, in his first year of working for them, increasing the website’s
readership from around 20,000 monthly readers and 100,000 monthly views
“to over 1.5 million monthly readers and 6 million monthly views”, a website
which he boasts as being “the biggest website for electric vehicle news”, as
appears from Exhibit P-4.

12. Defendant 925, is a New-York based corporation which owns a number of

websites covering various technology related topics, including the website
Electrek.co, the whole as appears from the extract of their website, Exhibit P-
6 and the extract from the New York Corporations Registry, Exhibit P-7.

III. MR. LAMBERT’S CONTEMPT OF THIS HONOURABLE COURT’S 2015

ORDER ISSUED AGAINST HIM ON JULY 28, 2015

13. Following a series of defamatory comments published by Mr. Lambert on

various websites including “InverstorsHub.com” and “Reddit.com”, which
targeted Plaintiffs Mr. Saleen and SAI, the latter instituted a Motion to Institute
Proceedings for Interlocutory and Permanent Injunction (the “2015 Motion”)

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against Mr. Lambert on July 20, 2015 (file no 410-17-001343-156), the whole
as appears from a copy of the Motion, Exhibit P-8.

14. These posts included, among others, defamatory comments alleging that
Plaintiffs were involved in a “fraud”, “a dishonest scheme”, “a scam” or a
“ponzi scheme/pump&dump”, the whole as appears from the Motion (Exhibit
P-8) and a copy of the articles published by Mr. Lambert in 2014 and 2015,
altogether Exhibit P-9.

15. Following the filing of Plaintiffs’ Motion, the parties reached a settlement
agreement pursuant to which Mr. Lambert agreed to submit to the permanent
injunction requested by Plaintiffs (Exhibit P-8).

16. As such, on July 28, 2015, the Honourable Manon Lavoie, j.s.c., issued
permanent injunction orders against Mr. Lambert and against any other
persons and entities aware of the orders, ordering that they remove any
defamatory online posts regarding Plaintiffs and cease releasing, publishing
or sharing such posts in the future, i.e. the 2015 Order (Exhibit P-1); The
relevant extracts of the 2015 Order are the following:

[5] ORDERS the Defendant, Frederic Lambert (“Mr. Lambert”) and any
and all persons acting on behalf of or in conjunction with Mr. Lambert, and
any and all persons having notice of this injunction, to cease and desist
from disseminating, releasing, posting, publishing, sharing, linking, or
otherwise communicating or causing to be communicated in any fashion
whatsoever either through himself, his agent or otherwise, on any media
whatsoever, including on the websites “InvestorsHub.com”, “Reddit.com”,
and “BlackSheepPlanet.com”, any comment relating to the Plaintiff Steve
Saleen or the Plaintiff Saleen Automotive, Inc. or its past, current and future
affiliates, subsidiaries, directors, officers, management, employees, agents,
representatives or shareholders (collectively, the “Saleen Persons”),
stating, declaring, alluding or otherwise suggesting that the Saleen Persons:
a) participated in, or are otherwise involved in a “fraudulent
scheme”, a “fraud”, a “scam”, a “pump and dump scheme” or
any other behaviour of that nature;

b) are being investigated by the U.S. Securities and

Exchange Commission or any other organization of that
nature;

c) that the Saleen Persons have committed any criminal or

penal infractions; or

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d) any other defamatory comments;

[6] ORDERS Mr. Lambert to place a formal written request to the

webmasters of the website “InvestorsHub.com” to withdraw, delete or
remove the postings published under the alias “FredVestor” or any other
aliases (the “InvestorsHub Postings”) from the website and to withdraw,
delete or remove any link to the InvestorsHub Postings from the [sic] within
five (5) days of the order to be issued and to provide a copy of such written
request and the proof of receipt by the webmaster to the Plaintiffs’ counsel
of record within ten (10) days of the order to be issued herein;

[7] ORDERS Mr. Lambert to place a formal written request to the

webmaster of the website “Reddit.com” to withdraw, delete or remove
the postings relating to the Saleen Persons published under the alias
“FredTesla” or any other aliases (the “Reddit.com Postings”,
collectively with the InvestorsHub Postings and any similar postings,
the “Postings”) from the website and to withdraw, delete or remove
any link to the Reddit Postings from the [sic] within five (5) days of the
order to be issued and to provide a copy of such written request and
the proof of receipt by the webmaster to the Plaintiffs’ counsel of
record within ten (10) days of the order to be issued herein;

[8] DECLARES that this order is enforceable against any person,

including corporate persons, who has participated or otherwise
collaborated in the posting, publishing or communication of the
Postings, and who has been made aware of this order;

[9] ORDERS that any person directed by this order not to do something
shall not do it himself or herself, nor through others acting on its, his or
her behalf, or on its, his or her instructions, or with its, his or her
encouragement or acquiescence, nor in any other way whatsoever;

17. The 2015 Order was rendered in the presence of Mr. Lambert and his
attorneys, and with his accord, as appears from the Court Record.

18. Notwithstanding the clear 2015 Order, Mr. Lambert has ignored the
permanent injunction and has intentionally refused to submit to it, writing,
releasing and sharing a new defamatory article on July 6, 2022, posted on
Defendant’s website, as their “Editor in chief and Main Writer”, entitled
“Saleen launches shady financing effort and teases modified Tesla vehicles
again”, the whole as appears from a copy of the article, Exhibit P-10 (the
“Defamatory Article”).

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19. The Defamatory Article includes the following disparaging statements:

“Saleen Automotive has launched a new shady financing effort to bring

the company back from the dead, and the legendary car tuner is
dangling modified Tesla vehicles in the process again. (…)

A few years later, Steve Saleen tried to relaunch the company, but he
had to use some shady financing to make it happen.

The new “Saleen Automotive” was brought public on the penny stock
market (OTC) through a shell company owned by a financier named
David Weiner, who is known to bring small companies public on the
OTC, offering them toxic notes with ridiculous conversion rates, and
then dumping those stocks. (…)

Saleen took millions of dollars in customer deposits for the Foursixteen

and other vehicles, but it only ended up delivering a few units. (…)

The new shares were unloaded on small retail investors, who believed
Saleen would find success with its modified Tesla vehicles and future
EV projects they were teasing at the time. The stock went from ~$1 a
share to being completely worthless over the next few years, and it was
eventually delisted by the SEC after becoming delinquent on its
financial reporting. (…)

Now in 2022, Saleen is trying to do another comeback; if the

company’s history is not enough of a warning, there are plenty of new
red flags with the latest version of the venture. (…)

Where things get shady is that people investing in the Saleen offering
have to give up their voting proxy to Steve Saleen. (…)

As a kid, I was a fan of the Saleen S7, and I got curious about them
going electric, but my interest went away quickly as I looked at the
financial dealings around the company.

To me, everything looked like a classic pump and dump. I posted my

findings at the time to let other potential investors know, as I expected
stock to become worthless due to the toxic convertible notes and no
clear path for Saleen to achieve what they claim they would achieve
with its Tesla tuning effort.

Saleen ended up suing me to shut me up about those dealings.”

20. In fact, Mr. Lambert even admits to willingly and knowingly breaking the 2015
Order, posting a link in the Defamatory Article leading to his Twitter thread in
which he re-posts the same defamatory postings about Plaintiffs from a year

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prior, the whole as appears from Exhibit P-11 and the extract of Mr.
Lambert’s Twitter thread below:

« Last year, I broke my silence about the situation and explained

everything in detail in a Twitter thread that is worth reading if you have
about 10 minutes:

‘6 years ago, I was sued by Saleen Automotive & Steve Saleen

himself who wanted to silence me for saying there was a “pump
& dump” scheme on their stock (SLNN) and they were using
customer deposits in a similar way as a Ponzi scheme uses
investments. They put a gag order on me. (…)

Now 6 years later, I am in a much better position to defend

myself financially and also to communicate what was happening
with Saleen around that time since I literally barely spoke
English back then. So here we go. Screw your injunction. (…)

Saleen Automotive (SLNN) was a brand new company Steve

Saleen put together through some financing deals that were, in
my opinion, quite shady. More on that later. (…)

I started seeing signs of a pump & dump, which consists of

shareholders in a company directly or indirectly attempting to
boost stock price through social media, press, etc. w/ the
purpose of dumping shares on small investors getting in based
on those social media posts, etc.

Saleen started issuing vague press releases touting exciting

projects that never came about, like making their own electric
car (…).

For context, Saleen often had less than $25,000 in the bank
while taking millions in customer deposits, which they admitted
to using for “general expenses & operations” (aka exec salaries
& marketing) instead of parts/labor on making cars promised to
customers. All in SEC filings.

That's what prompted me to comment that they are using

customer deposits "in a similar way as a Ponzi Scheme", which
they claimed was defamatory as part of their legal actions
against me. (…)

For example, commenters that were promoting Saleen on the

iHub board looked suspiciously like professional pumpers. I
pulled their posting history and they were all posting only on
boards of stocks where the same funds were holding notes.(…)

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I was posting those findings on iHub to warn the small times

investors on those boards, most of which were likely mostly
being shares being dumped by those toxic noteholders, of the
situation and I was consistently attacked by those pumpers. (…)

Now I don’t know what level of involvement Steve Saleen

himself had with all this. From what I hear from people who
know him, he is more of a car driver and tuner and not a very
savvy businessman. He might have been played in all this for all
I know.

But he and his daughter were getting paid while the stock was
crashing. Their salaries came from money coming into the
company through those convertible notes and customer
deposits. While not illegal, that's definitely shady in my opinion.

But what I find truly disgusting is how he is being portrayed as a

victim in the media now over his Saleen Chinese venture that
completely flopped. (…)

In all the press coverage that followed, there was no mention

that Saleen’s stock had just been driven to zero by all this
sketchy financial maneuvering talked about above that resulted
in small investors that believe in Steve losing a ton of money.

He acts like it never happened, pump and dump or not. He and

the media reporting on this just talked about his Chinese venture
failing, which was unsuprising since they were trying to sell this
piece of crap toy car for $22,000(…).’

21. Defendant 925 was also clearly aware of the 2015 Order, choosing to publish
the above Defamatory Article and link in which Mr. Lambert clearly states
“screw your injunction”, and refused to remove the article even after receiving
a copy of the 2015 Order from Plaintiffs.

22. In fact, after learning of the Defamatory Article, Plaintiffs’ attorneys summoned
Defendants to immediately withdraw, delete and remove the Defamatory
Article from the Electrek.co website and publish a retraction and correction, in
all publications where the Defamatory Article was published, stating that it
was published in violation of a valid injunction, with a copy of the 2015 Order,
the whole as appears from the letter sent by Mr. Walker on July 12, 2022,
Exhibit P-12 (the “Demand Letter”).

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23. Notwithstanding this Demand Letter, Defendants refused to comply with the
2015 Order.

24. Instead, Mr. Lambert replied to Plaintiffs that he will be starting the process to
have the 2015 Order “thrown out”, the whole as appears from a copy of Mr.
Lambert’s reply dated July 12, 2022, Exhibit P-13.

25. Mr. Lambert even posted the Demand Letter on his Twitter thread, in which he
reaffirmed his refusal to remove the Defamatory Article and his willingness to
disobey the 2015 Order by “hir[ing] lawyers to have it thrown out”, the whole
as appears from the Twitter postings from July 12, 2022, Exhibit P-14
(Exhibits P-14 and P-11 altogether the “Twitter Postings”).

26. Mr. Lambert then goes on to post the following disparaging comments
regarding the Plaintiff in the same Twitter thread from July 12, 2022:

“To me, it looks like they don't want the truth to be out there. Saleen is
looking to raise money again and their past is haunting them.

People should know Saleen's past before investing. That's just fair. I
plan on fighting back to keep the truth out there. I won't be bullied any
longer. I also plan to publicly document everything that comes out for
complete transparency. The dirty laundry will be out.”

(our underlining)

the whole as appears from Exhibit P-14.

27. It also appears that the Defamatory Article is being shared and re-posted on
other webpages, the whole as appears from extracts of the websites
“flipboard.com” and “sucpost.com”, altogether Exhibit P-15.

28. 925 is also promoting the Defamatory Article through its podcast on its
website in which it re-iterates Mr. Lambert’s accusations that Plaintiffs are
running a “pumping and dumping scheme”, the whole as appears from the
recording on the Electrek.co website, Exhibit P-16.

29. By these acts, Mr. Lambert directly violates the 2015 Order.

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30. It also appears that, notwithstanding the 2015 Order, Mr. Lambert still has not
removed or obtained the removal of the article published on “Reddit.com”
from 2014, in which he urged potential buyers of the Saleen Tesla vehicles to
reconsider their decision in a disparaging comment which started with the
following statement: “Saleen is running something closely resembling a Ponzi
scheme/pump&dump”, as appears from the printed extracts of the said
website, Exhibit P-17.

31. Furthermore, notwithstanding the clear 2015 Order regarding Mr. Lambert’s
posts on the website of investorshub.com, the latter posts have also still not
been removed from said website, as appears from the extracts of the website,
Exhibit P-18.

32. Plaintiffs are therefore well founded in asking that Mr. Lambert be cited to
answer to an accusation of contempt of court, and be found guilty of such
contempt, in that :

a) The 2015 Order and its scope were patently clear and are binding on
Mr. Lambert, particularly in light of paragraph 5 of the 2015 Order
which clearly states the following:

[5] Defendant, Frederic Lambert ("Mr. Lambert") and any and all
persons acting on behalf of or in conjunction with Mr. Lambert, and any
and all persons having notice of this injunction, to cease and desist
from disseminating, releasing, posting, publishing, sharing, linking, or
otherwise communicating or causing to be communicated in any
fashion whatsoever either through himself, his agent or otherwise, on
any media whatsoever, including on the websites "InvestorsHub.com",
"Reddit.com", and "BlackSheepPlanet.com", any comment relating to
the Plaintiff Steve Saleen or the Plaintiff Saleen Automotive, Inc. or its
past, current and future affiliates, subsidiaries, directors, officers,
management, employees, agents, representatives or shareholders
(collectively, the "Saleen Persons"), stating, declaring, alluding or
otherwise suggesting that the Saleen Persons:

a) participated in, or are otherwise involved in a "fraudulent

scheme", a "fraud", a "scam", a "pump and dump scheme" or
any other behaviour of that nature;

b) are being investigated by the U.S. Securities and Exchange

Commission or any other organization of that nature;

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c) that the Saleen Persons have committed any criminal or

penal infractions; or

d) any other defamatory comments”

(our underlining)
the whole as appears from the 2015 Order, Exhibit P-1.

b) At all relevant times, Mr. Lambert was well aware of the existence of
the 2015 Order, having himself agreed to voluntarily submit to said
2015 Order, and yet having intentionally published the Defamatory
Article and Twitter Postings mentioning it was being published
notwithstanding the Court Order and with the intent of having the 2015
Order “thrown out”;

c) Mr. Lambert clearly did not comply with the 2015 Order, having allowed
the publishing, communication and dissemination of defamatory and
disparaging comments against Plaintiffs, violating the terms of the
Court Order, as outlined above and

d) Mr. Lambert had specific knowledge that his actions would contravene
the 2015 Order, writing and publishing the Defamatory Article and
Twitter Postings which specifically included the statement “screw the
injunction”, even after being given the opportunity to conform to the
2015 Order when he received a Demand Letter from Plaintiffs asking
that the Defamatory Article be removed.

33. Furthermore, at the time of the 2015 Order, Mr. Lambert was a resident of the
Saint-Maurice district, but is now domiciled in Longueuil, and Plaintiffs have
every reason to believe that Defamatory Postings were therefore published
and disseminated in that district.

34. In light of the above, Plaintiffs are well founded in asking that Mr. Lambert be
immediately cited to answer to an accusation of Contempt of Court and be
sanctioned by this Court for his clear, continued and intentional violations of
the 2015 Order.

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IV. THE PLAINTIFFS ARE ENTITLED TO THE ISSUANCE OF INJUNCTION ORDERS

35. The Defamatory Article and Twitter Postings (together the “Defamatory
Postings”) include statements against Plaintiffs which are highly prejudicial to
them.

36. In fact, the Defamatory Postings as listed in paragraphs 19, 20 and 26 above
are either completely misleading or patently false.

37. The notions of a “shady financing effort” “dumping stocks”, “classic pump and
dump” and “Ponzi scheme” (which constitute criminal allegations of a fraud on
the market), amongst others, are negative, destructive and harmful in nature
and adversely impact the Plaintiffs’ respective reputations in a severe and
irreparable fashion.

38. For example, Defendants erroneously stated that Plaintiffs “took millions in
deposits” from customers without delivering vehicles, which is a complete
fabrication, since every SAI customer has received the vehicle they ordered
and paid for.

39. Furthermore, contrary to Defendants’ misleading allusions of a “shady

financing effort”, SAI’s process of raising capital through the offering circular
filed with the SEC is a legal, standard and regulated procedure.

40. If anything, Defendants clearly do not understand what this process entails
and the legal and regulatory framework through which SAI is raising capital,
preferring to thwart SAI’s efforts by erroneously defaming Plaintiffs.

41. Instead, the Defamatory Article falsely alludes to an illegal “pump and dump”
scheme and the Twitter Postings warn investors about Saleen’s so-called past
which is “haunting them” and pretends to alert readers that Saleen’s “dirty
laundry will be out”.

42. The Defamatory Postings refer explicitly to Plaintiffs by name throughout, are
clearly about gratuitously targeting Plaintiffs, and were so understood by
those who read these postings.

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43. The Defamatory Postings associate Mr. Saleen to fraudulent and illegal
schemes, and to a scammer stating that SAI is not a real business and is
instead a "pump and dump scheme".

44. The Defamatory Postings are libelous on their face: clearly exposing Plaintiffs
to hatred, contempt, ridicule and obloquy as they allude to Mr. Saleen having
engaged in criminal activity and Mr. Saleen and SAI in having engaged in
investor fraud and regulatory violations relating to the sale of shares in SAI.

45. Defendants’ postings essentially accuse Plaintiffs of running an orchestrated

scam.

46. The Defamatory Postings were seen and read on or about the date of their
posting and thereafter by internet users searching for information regarding
Plaintiffs, as prospective investors in SAI and/or customers interested in
ordering a vehicle from the Plaintiffs.

47. In fact, according to Electrek.co’s website, it receives over 25 million monthly

views, and its Electrek Podcast and Quick Charge Podcasts boast over
550,000 and 25,000 monthly streams and downloads respectively, the whole
as appears from the extracts of Electrek.co’s website, Exhibit P-19.

48. As a proximate result of the Defamatory Postings and the other

aforementioned defamatory statements, the Plaintiffs have suffered damages
to their reputation, shame, embarrassment, and, possibly, loss of business
sales which cannot be assessed, at least for the moment. These ongoing
damages are unquantifiable and irreparable.

49. It is equally reasonable to assume that Defendants’ Defamatory Postings

have had and may still have adverse impacts on SAI’s sale of shares through
its recently commenced SEC Offering circular from March 31, 2022 (Exhibit P-
3).

50. In conclusion, the Defamatory Postings and the aforementioned defamatory

statements are patently ill-founded and are destined at harming Plaintiffs’
reputation and business prospects.

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51. Plaintiffs are thus entitled, on the merits of this matter, to seek an order that
Mr. Lambert be prevented from publishing, issuing, releasing or otherwise
disseminating defamatory comments related or directed at Plaintiffs and that
925 stop facilitating the dissemination of those defamatory statements.

V. THE RIGHT TO THE ISSUANCE OF PROVISIONAL AND INTERLOCUTORY

INJUNCTIONS

52. Plaintiffs hereby seek mandatory orders destined at, inter alia, at halting
Defendants from posting, sharing, linking or otherwise disseminating any
further messages, comments, allegations or any other communications,
released via any media (whether verbal, written or virtual), defaming,
disparaging, offending, denigrating or otherwise of a harmful nature relating to
Plaintiffs on an urgent basis and pending the judicial process.

53. Considering that Plaintiffs cannot assess whether Defendants have benefited
or benefit from the participation of accomplices or otherwise, conspire or
collaborate with third parties with respect to the above-described defamatory
scheme, it is necessary that any orders to be rendered herein be enforceable
against such third parties becoming aware of such orders.

A. Plaintiffs’ Prima Facie Right to the Orders Sought

54. For the reasons set forth above, Plaintiffs are entitled to the orders sought: the
Defamatory Postings cited in Section III above are bereft of any foundation
and are extremely prejudicial.

55. In short, these comments constitute pure defamation.

56. Mr. Lambert’s conduct is simply unjustified and plainly unjustifiable.

57. In addition, Mr. Lambert’s disregard of the 2015 Order entitles Plaintiffs to a
fresh order from this Court restating Mr. Lambert’s obligation to not harm
third-parties’ reputation, that is to say that of the Plaintiffs.

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58. Mr. Lambert admitting having control of 925 and/or of its publications,
Plaintiffs are entitled to an order seeking that 925 stop being the primary
vehicle of Mr. Lambert’s egregious behaviour.

59. This Court has jurisdiction to issue such injunctions.

60. Finally, Plaintiffs are entitled to the complete execution and implementation of
the 2015 Order and Mr. Lambert must thus remove the defamatory comments
that predicated the 2015 Motion, entirely and immediately.

B. Plaintiffs Suffer Irreparable harm

61. As described hereinabove, the Defamatory Postings cause irreparable harm

to Plaintiffs’ reputation.

62. Being accused of fraudulent schemes on the market is one of the most
prejudicial accusations for a publicly traded corporation such as SAI.

63. At this stage, it is impossible to assess or otherwise determine the extent of

the damages caused by these defamatory statements.

64. Moreover, this Honourable Court cannot ignore the prejudicial impact of the
Defamatory Postings on the sale of SAI’s stock, which directly impact SAI’s
financing capacity and the market as well.

65. Actually, Mr. Lambert admitted in 2015 that these types of comments were
defamatory by nature which further justifies this Court’s swift intervention.

C. The Balance of Inconveniences Favours Plaintiffs

66. In light of the foregoing, it is abundantly clear that the balance of

inconveniences favours Plaintiffs.

67. In fact, Defendants – and any of their accomplices, as the case may be –
would not suffer any prejudice should they be prevented from pursuing their
defamatory scheme.

68. Any limitation to Defendants’ capacity to communicate with regards to

Plaintiffs and their business would be of no or limited effect compared to

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allowing Defendants to continue spreading false and harmful statements

about Plaintiffs.

69. Freedom of speech does not allow one to blatantly slander another’s
reputation.

70. Should the orders not be granted, Plaintiffs’ reputation will continue to be
harmed.

D. Necessity to hear the Application for Provisional and Interlocutory

Injunctions as soon as possible

71. It is crucial that this Honourable Court issue the interlocutory orders sought as
soon as possible, and in any event no longer than five (5) days following the
filing of the present proceedings, given the following reasons:

a) Mr. Lambert has recently continued to post disparaging comments on

Plaintiffs, issuing the Twitter Postings on July 12, 2022, alleging that
Saleen’s “past is haunting them” and their “dirty laundry will be out”;

b) the undeniable impact of the Defamatory Postings on Mr. Saleen’s

reputation requires that this ongoing disparaging act must stop
forthwith;

c) SAI is seeking public financing through the OTC and the defamatory
comments are sabotaging SAI’s efforts.

72. Moreover, the stake holders of SAI are adversely impacted by the defamatory
comments.

73. Mr. Lambert must immediately stop issuing, releasing, publishing or otherwise
disseminating defamatory comments.

74. It is shocking to see Mr. Lambert repeating the behaviour that he had agreed
to stop doing.

75. It is even more astonishing to read Mr. Lambert’s disrespect for this
Honourable Court.

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76. In short, this untenable situation must stop immediately and without delay.

77. Plaintiffs therefore request that the Application for an Interlocutory Injunction
be heard no later than five (5) days of the filing of the present proceedings.

78. Should this Honourable Court deem necessary to schedule the hearing of the
Application for an Interlocutory Injunction at a later date, Plaintiffs hereby
request that safeguard orders be issued in the interim.

VI. NECESSITY TO PRESERVE EVIDENCE

79. Given the nature of this matter, it is of the utmost importance that this Court
orders Defendants to preserve all and any electronic evidence of the
defamatory comments.

80. As a matter of fact, Mr. Lambert uses computers or other electronic devices to
publish his defamatory comments whether on Twitter, Electrek.co or on other
online platforms.

81. It is impossible for Plaintiffs to know at this point which electronic device(s)
was/were used to publish these defamatory postings.

82. Plaintiffs are therefore requesting that this Honourable Court issue an order
against Defendants preventing them from destroying or otherwise altering any
data, software, or the actual electronic devices used by Mr. Lambert at any
point in time since July 2022.

VII. A SECURITY FOR COSTS IS UNNECESSARY

83. Given the nature of this matter and that Plaintiffs are not (at this point) seeking
any monetary conclusions from Defendants, they respectfully request that no
security for costs be awarded.

FOR THESE REASONS, MAY IT PLEASE THE COURT TO:

A. On the Contempt of Court

ORDER Mr. Lambert to appear before the Court on the day and at the time
indicated by the Court, to hear the evidence relating to the acts held against
him and to assert his grounds of defense, so as to avoid the pronouncement

#1678973v5
 18

of sanctions to punish a contempt of court, including the payment of a punitive

monetary amount, the performance of compensatory community work, and in
addition, if he refuses to comply with the order or injunction, a penalty of
imprisonment.

DECLARE by final judgment in contempt of court, that Mr. Lambert is guilty of

contempt of Court and CONDEMN Mr. Lambert to the sanctions the Court
sees fit pursuant to section 62 C.C.P.

B. At the Provisional Stage

i. GRANT the Application for a Provisional Injunction, and ISSUE the

following orders to be valid for ten (10) days;

ii. ORDER Defendants Frederic Lambert (“Mr. Lambert”) and 925 LLC
(“925”) and any and all persons acting on behalf of or in conjunction
with Mr. Lambert and 925, and any and all persons having notice of
this injunction, to cease and desist from disseminating, releasing,
posting, publishing, sharing, linking, or otherwise communicating or
causing to be communicated in any fashion whatsoever either through
himself, his agent or otherwise, on any media whatsoever, including on
the websites Electrek.co, Twitter, InvestorsHub.com or Reddit.com,
any comment relating to Plaintiff Steve Saleen or Plaintiff Saleen
Automotive, Inc. or its past, current and future affiliates, subsidiaries,
directors, officers, management, employees, agents, representatives or
shareholders (collectively, the “Saleen Persons”), stating, declaring,
alluding or otherwise suggesting that the Saleen Persons:

A) participated in, or are otherwise involved in a “fraudulent

scheme”, “shady financing”, a “fraud”, a “scam”, a “pump and
dump scheme”, a “ponzi scheme” or any other behaviour of that
nature;

B) are being investigated by the U.S. Securities and Exchange

Commission or any other organisation of that nature;

C) that the Saleen Persons have committed any criminal or penal

infractions; or

D) any other defamatory comments;

#1678973v5
 19

iii. ORDER Mr. Lambert to withdraw, delete or remove postings or links on

the InvestorsHub.com website published under the alias “FredVestor”
(the “Postings”) (Exhibit P-18) within five (5) days of the order to be
issued and to provide a proof of such removal to the undersigned
counsel of record within ten (10) days of the order to be issued herein;

iv. ORDER Mr. Lambert to place a formal written request to the

webmasters of the website “InvestorsHub.com” to withdraw, delete or
remove the postings published under the alias “FredVestor” or any
other aliases (the “InvestorsHub Postings”) from the website and to
withdraw, delete or remove any link to the InvestorsHub Postings within
five (5) days of the order to be issued and to provide a copy of such
written request and the proof of receipt by the webmaster to the
Plaintiffs’ counsel of record within ten (10) days of the order to be
issued herein;

v. ORDER Mr. Lambert to place a formal written request to the

webmaster of the website “Reddit.com” to withdraw, delete or remove
the postings relating to the Saleen Persons published under the alias
“FredTesla” or any other aliases (the “Reddit.com Postings”,
collectively with the InvestorsHub Postings and any similar postings,
the “Postings”) from the website and to withdraw, delete or remove any
link to the Reddit Postings within five (5) days of the order to be issued
and to provide a copy of such written request and the proof of receipt
by the webmaster to the Plaintiffs’ counsel of record within ten (10)
days of the order to be issued herein;

vi. ORDER Defendants to communicate to the Plaintiffs’ counsel of

record, within five (5) days of the order to be issued, an electronic
copy, including all the metadata, of all Postings, the Defamatory Article
and Twitter Postings and of any other comments relating to the Saleen
Persons, disseminated, released, posted, published, shared, linked or
otherwise communicated by him, directly or indirectly, on the Internet
and whether anonymously or not (collectively with the Postings,
Defamatory Article and Twitter Postings, the “Defamatory

#1678973v5
 20

Statements”), as well as the names and Internet addresses of the

websites on which the Defamatory Statements were communicated
and the aliases used by Mr. Lambert, as the case may be;

vii. ORDER Mr. Lambert to preserve all electronic evidence of the

Defamatory Statements, including the metadata, and more specifically,
not to delete, change or otherwise alter such electronic evidence and
not to destroy, modify or otherwise alter any electronic devices used
(even if not owed by Mr. Lambert), by Mr. Lambert in order to
disseminate, release, post, publish, share, link or otherwise
communicate the Defamatory Statements;

viii. ORDER provisional execution notwithstanding appeal;

ix. ORDER that Plaintiffs do not have to post any security for costs herein;

x. DECLARE that the order to be issued can be enforceable against any

person, including corporate persons, who have participated or
otherwise collaborated in the posting, publishing or communication of
the Defamatory Statements;

xi. ORDER that any person directed by this order not to do something
shall not do it himself or herself, nor through others acting on its, his or
her behalf, or on its, his or her instructions, or with its, his or her
encouragement or acquiescence, nor in any other way whatever;

xii. AUTHORIZE service of the order outside of legal hours and on non-
juridical days as sufficient and valid for all legal intents and purposes
including, without limitation, for the purposes of Article 512 of the
Quebec Code of Civil Procedure;

xiii. DECLARE that the presentation of the Application for an Interlocutory

Injunction within five (5) days of the filing of the present proceedings is
sufficient and valid;

xiv. DECLARE that the order to be issued will remain valid and enforceable
until final judgment is rendered herein;

#1678973v5
 21

xv. ISSUE any other order that this Court deems necessary or useful in the
circumstances;

xvi. THE WHOLE with costs against Defendants;

C. At the Interlocutory Stage

xvii. GRANT the Application for an Interlocutory Injunction, and ISSUE the
following orders to be valid until the judgment on the merits of the
matter;

xviii. ORDER Defendants and any and all persons acting on behalf of or in
conjunction with Mr. Lambert and 925, and any and all persons having
notice of this injunction, to cease and desist from disseminating,
releasing, posting, publishing, sharing, linking, or otherwise
communicating or causing to be communicated in any fashion
whatsoever either through himself, his agent or otherwise, on any
media whatsoever, including on the websites Electrek.co, Twitter,
InvestorsHub.com or Reddit.com, any comment relating to Plaintiff
Steve Saleen or Plaintiff Saleen Automotive, Inc. or its past, current
and future affiliates, subsidiaries, directors, officers, management,
employees, agents, representatives or shareholders (collectively, the
“Saleen Persons”), stating, declaring, alluding or otherwise suggesting
that the Saleen Persons:

A) participated in, or are otherwise involved in a “fraudulent

scheme”, “shady financing”, a “fraud”, a “scam”, a “pump and
dump scheme”, a “ponzi scheme” or any other behaviour of that
nature;

B) are being investigated by the U.S. Securities and Exchange

Commission or any other organisation of that nature;

C) that the Saleen Persons have committed any criminal or penal

infractions; or

D) any other defamatory comments;

xix. ORDER Mr. Lambert to preserve all electronic evidence of the

Defamatory Statements, including the metadata, and more specifically,
not to delete, change or otherwise alter such electronic evidence and

#1678973v5
 22

not to destroy, modify or otherwise alter any electronic devices used

(even if not owed by Mr. Lambert), by Mr. Lambert in order to
disseminate, release, post, publish, share, link or otherwise
communicate the Defamatory Statements;

xx. ORDER provisional execution notwithstanding appeal;

xxi. ORDER that Plaintiffs do not have to post any security for costs herein;

xxii. DECLARE that the order to be issued can be enforceable against any
person, including corporate persons, who have participated or
otherwise collaborated in the posting, publishing or communication of
the Defamatory Statements;

xxiii. ORDER that any person directed by this order not to do something
shall not do it himself or herself, nor through others acting on its, his or
her behalf, or on its, his or her instructions, or with its, his or her
encouragement or acquiescence, nor in any other way whatever;

xxiv. AUTHORIZE service of the order outside of legal hours and on non-
juridical days as sufficient and valid for all legal intents and purposes
including, without limitation, for the purposes of Article 512 of the
Quebec Code of Civil Procedure;

xxv. DECLARE that the presentation of the Application for an Interlocutory

Injunction within five (5) days of the filing of the present proceedings is
sufficient and valid;

xxvi. DECLARE that the order to be issued will remain valid and enforceable
until final judgment is rendered herein;

xxvii. ISSUE any other order that this Court deems necessary or useful in the
circumstances;

xxviii. THE WHOLE with costs against Defendants;

#1678973v5
 23

D. At the Permanent Stage

xxix. GRANT the Application for a Permanent Injunction;

xxx. ORDER Defendants Frederic Lambert (“Mr. Lambert”) and 925 LLC
(“925”) and any and all persons acting on behalf of or in conjunction
with Mr. Lambert and 925, and any and all persons having notice of
this injunction, to cease and desist from disseminating, releasing,
posting, publishing, sharing, linking, or otherwise communicating or
causing to be communicated in any fashion whatsoever either through
himself, his agent or otherwise, on any media whatsoever, including on
the websites Electrek.co, Twitter, InvestorsHub.com or Reddit.com,
any comment relating to Plaintiff Steve Saleen or Plaintiff Saleen
Automotive, Inc. or its past, current and future affiliates, subsidiaries,
directors, officers, management, employees, agents, representatives or
shareholders (collectively, the “Saleen Persons”), stating, declaring,
alluding or otherwise suggesting that the Saleen Persons:

A) participated in, or are otherwise involved in a “fraudulent

scheme”, “shady financing”, a “fraud”, a “scam”, a “pump and
dump scheme”, a “ponzi scheme” or any other behaviour of that
nature;

B) are being investigated by the U.S. Securities and Exchange

Commission or any other organisation of that nature;

C) that the Saleen Persons have committed any criminal or penal

infractions; or

D) any other defamatory comments;

xxxi. ORDER provisional execution notwithstanding appeal;

xxxii. DECLARE that the order to be issued can be enforceable against any
person, including corporate persons, who have participated or
otherwise collaborated in the posting, publishing or communication of
the Defamatory Statements;

xxxiii. ORDER that any person directed by this order not to do something
shall not do it himself or herself, nor through others acting on its, his or

#1678973v5
 24

her behalf, or on its, his or her instructions, or with its, his or her
encouragement or acquiescence, nor in any other way whatsoever;

xxxiv. AUTHORIZE service of the order outside of legal hours and on non-
juridical days as sufficient and valid for all legal intents and purposes
including, without limitation, for the purposes of Article 512 the Quebec
Code of Civil Procedure;

xxxv. ISSUE any other order that this Court deems necessary or useful in the
circumstances;

xxxvi. THE WHOLE with costs against the Defendants.

Montréal, July 20, 2022

LCM ATTORNEYS INC.

Attorneys for Plaintiffs
Mtre Marc-André Landry
Mtre Anaïs Kadian
600 de Maisonneuve Blvd. West, suite 2700
Montréal, Québec H3A 3J2
Tel. : 514.312.0339 (MAL)
Tel. : 514.375.2673 (AK)
Emails : malandry@lcm.ca
akadian@lcm.ca
Fax : 514.905.2001
Our ref.: 71588.1

#1678973v5
 SUMMONS
(articles 145 and following C.C.P.)

Take notice that the plaintiff has filed this originating application in the office of the
Superior Court in the judicial district of Longueuil.
You must answer the application in writing, personally or through a lawyer, at the
courthouse of Longueuil situated at 1111 Jacques-Cartier Boulevard East, within 15 days
of service of the application or, if you have no domicile, residence or establishment in
Québec, within 30 days. The answer must be notified to the plaintiff’s lawyer or, if the
plaintiff is not represented, to the plaintiff.
If you fail to answer within the time limit of 15 or 30 days, as applicable, a default
judgement may be rendered against you without further notice and you may, according
to the circumstances, be required to pay the legal costs.
In your answer, you must state your intention to:

• negotiate a settlement;
• propose mediation to resolve the dispute;
• defend the application and, in the cases required by the Code, cooperate with
the plaintiff in preparing the case protocol that is to govern the conduct of the
proceeding. The protocol must be filed with the court office in the district
specified above within 45 days after service of the summons or, in family matters
or if you have no domicile, residence or establishment in Québec, within 3
months after service;
• propose a settlement conference.
The answer to the summons must include your contact information and, if you are
represented by a lawyer, the lawyer's name and contact information.
You may ask the court to refer the originating application to the district of your domicile
or residence, or of your elected domicile or the district designated by an agreement with
the plaintiff.
If the application pertains to an employment contract, consumer contract or insurance
contract, or to the exercise of a hypothecary right on an immovable serving as your main
residence, and if you are the employee, consumer, insured person, beneficiary of the
insurance contract or hypothecary debtor, you may ask for a referral to the district of your
domicile or residence or the district where the immovable is situated or the loss occurred.
The request must be filed with the special clerk of the district of territorial jurisdiction after
it has been notified to the other parties and to the office of the court already seized of the
originating application.
If you qualify to act as a plaintiff under the rules governing the recovery of small claims,
you may also contact the clerk of the court to request that the application be processed

LCM Attorneys inc.

 -2-

according to those rules. If you make this request, the plaintiff's legal costs will not exceed
those prescribed for the recovery of small claims.
Within 20 days after the case protocol mentioned above is filed, the court may call you to
a case management conference to ensure the orderly progress of the proceeding. Failing
this, the protocol is presumed to be accepted.
In support of the originating application, the plaintiff intends to use the following:
- See the list of exhibits attached.
These exhibits are available on request.

If the application is an application in the course of a proceeding or an application under

Book III, V, excepting an application in family matters mentioned in article 409, or VI of
the Code, the establishment of a case protocol is not required; however, the application
must be accompanied by a notice stating the date and time it is to be presented.

Montréal, July 20, 2022

LCM ATTORNEYS INC.

Attorneys for Plaintiffs
Mtre Marc-André Landry
Mtre Anaïs Kadian
600 de Maisonneuve Blvd. West, suite 2700
Montréal, Québec H3A 3J2
Tel. : 514.312.0339 (MAL)
Tel. : 514.375.2673 (AK)
Emails : malandry@lcm.ca
akadian@lcm.ca
Fax : 514.905.2001
Our ref.: 71588.1

LCM Attorneys inc.

 NOTICE OF PRESENTATION

TO : FREDERIC LAMBERT, an individual domiciled at 1623 rue Gaulle, in the city and
district of Longueuil, Province of Québec, J4T 1M7

-and-

925 LLC, a corporation duly incorporated under the laws of New York, having a
place of business at 19 Clinton st., in the city of Pleasantville, New York, United
States of America

PLEASE BE ADVISED THAT the APPLICATION FOR PROVISIONAL INJUNCTION forming part
of the APPLICATION FOR PROVISIONAL, INTERLOCUTORY AND PERMANENT INJUNCTION,
APPLICATION SEEKING AN ORDER TO APPEAR BEFORE THE COURT TO ANSWER TO AN ACCUSATION
OF CONTEMPT OF COURT AND APPLICATION FOR A DECLARATION IN CONTEMPT OF COURT shall
be presented for adjudication before the honourable judge Yves Poirier sitting in chamber
2.13 of the Superior Court, situated at 1, Notre-Dame East, Montreal, on July 22, 2022,
at 9h00.
DO GOVERN YOURSELF ACCORDINGLY.

Montréal, July 20, 2022

LCM ATTORNEYS INC.

Attorneys for Plaintiffs
Mtre Marc-André Landry
Mtre Anaïs Kadian
600 de Maisonneuve Blvd. West, suite 2700
Montréal, Québec H3A 3J2
Tel. : 514.312.0339 (MAL)
Tel. : 514.375.2673 (AK)
Emails : malandry@lcm.ca
akadian@lcm.ca
Fax : 514.905.2001
Our ref.: 71588.1
 NOTICE OF PRESENTATION

TO : FREDERIC LAMBERT, an individual domiciled at 1623 rue Gaulle, in the city and
district of Longueuil, Province of Québec, J4T 1M7

-and-

925 LLC, a corporation duly incorporated under the laws of New York, having a
place of business at 19 Clinton st., in the city of Pleasantville, New York, United
States of America

PLEASE BE ADVISED THAT the APPLICATION FOR INTERLOCUTORY INJUNCTION forming

part of the APPLICATION FOR PROVISIONAL, INTERLOCUTORY AND PERMANENT INJUNCTION,
APPLICATION SEEKING AN ORDER TO APPEAR BEFORE THE COURT TO ANSWER TO AN ACCUSATION
OF CONTEMPT OF COURT AND APPLICATION FOR A DECLARATION IN CONTEMPT OF COURT shall
be presented for adjudication before the honourable judge sitting in chamber 2.13 of the
Superior Court, situated at 1, Notre-Dame East, Montreal, on July 29, 2022, at 9h00.
DO GOVERN YOURSELF ACCORDINGLY.

Montréal, July 20, 2022

LCM ATTORNEYS INC.

Attorneys for Plaintiffs
Mtre Marc-André Landry
Mtre Anaïs Kadian
600 de Maisonneuve Blvd. West, suite 2700
Montréal, Québec H3A 3J2
Tel. : 514.312.0339 (MAL)
Tel. : 514.375.2673 (AK)
Emails : malandry@lcm.ca
akadian@lcm.ca
Fax : 514.905.2001
Our ref.: 71588.1
CANADA

PROVINCE OF QUÉBEC SUPERIOR COURT

DISTRICT OF LONGUEUIL (CIVIL DIVISION)

No: STEVE SALEEN

-and-
SALEEN AUTOMOTIVE, INC.
Plaintiffs
v.
FREDERIC LAMBERT
-and-
925 LLC
-and-
JOHN DOE AND JANE DOE
Defendants

PLAINTIFFS’ LIST OF EXHIBITS

EXHIBIT P-1 Judgment of the Superior Court of Quebec dated July 28, 2015;
EXHIBIT P-2 Extracts of SAI’s website;
EXHIBIT P-3 SAI’s Offering Circular dated March 31, 2022;
EXHIBIT P-4 Mr. Lambert’ s profile posted on LinkedIn;
EXHIBIT P-5 Extract from the website of Electrek.co;
EXHIBIT P-6 Extract from the website of 925 LLC;
EXHIBIT P-7 Extract from the New York Corporations Registry;
EXHIBIT P-8 Motion to Institute Proceedings for Interlocutory and Permanent
Injunction, dated July 20, 2015 (file no 410-17-001343-156);
EXHIBIT P-9 Copy of the articles published by Mr. Lambert in 2014 and 2015;
EXHIBIT P-10 Defamatory article from July 6, 2022;
EXHIBIT P-11 Mr. Lambert’s Twitter postings;
EXHIBIT P-12 Demand letter sent by Mr. Walker on July 12, 2022;
EXHIBIT P-13 Mr. Lambert’s reply to the Demand Letter dated July 12, 2022;
EXHIBIT P-14 Mr. Lambert’s Twitter postings from July 12, 2022;
EXHIBIT P-15 Extracts of the websites “flipboard.com” and “sucpost.com”;
EXHIBIT P-16 Extract of Electrek.co website podcast page;
EXHIBIT P-17 Extract of the article published on “Reddit.com”;
EXHIBIT P-18 Extract of the website “investorshub.com”;

#1681784v2
EXHIBIT P-19 Electrek website extracts.

Montréal, July 20, 2022

LCM ATTORNEYS INC.

Attorneys for Plaintiffs
Mtre Marc-André Landry
Mtre Anaïs Kadian
600 de Maisonneuve Blvd. West, suite 2700
Montréal, Québec H3A 3J2
Tel. : 514.312.0339 (MAL)
Tel. : 514.375.2673 (AK)
Emails : malandry@lcm.ca
akadian@lcm.ca
Fax : 514.905.2001
Our ref.: 71588.1

#1681784v2
NO:

COUR SUPÉRIEURE
DISTRICT DE LONGUEUIL

STEVE SALEEN, an individual having his domicile at 5059

Scholarship, in the city of Irvine, California, United States of America;
-and-
SALEEN AUTOMOTIVE, INC., a corporation duly incorporated under
the laws of Delaware, having a place of business at 2735 Wardlow
Road, in the city of Corona, California, United States of America
Plaintiffs
v.
FREDERIC LAMBERT, an individual domiciled at 1623 rue Gaulle, in
the city and district of Longueuil, Province of Québec, J4T 1M7;
-and-
925 LLC, a corporation duly incorporated under the laws of New York,
having a place of business at 19 Clinton st., in the city of Pleasantville,
New York, United States of America;
-and-
JOHN DOE AND JANE DOE
Defendants

APPLICATION FOR PROVISIONAL, INTERLOCUTORY AND

PERMANENT INJUNCTION, APPLICATION SEEKING AN ORDER
TO APPEAR BEFORE THE COURT TO ANSWER TO AN
ACCUSATION OF CONTEMPT OF COURT AND APPLICATION
FOR A DECLARATION IN CONTEMPT OF COURT (Art. 57 and ff
and 509 and ff. C.C.P.), SWORN STATEMENT, SUMMONS,
NOTICES OF PRESENTATION(2) AND LIST OF EXHIBITS

ORIGINAL

Code BL5788 Our ref. : 71558.1

tre
M Marc-André Landry Telephone: : 514.312.0339
MaLandry@lcm.ca Fax : 514.905.2001
Mtre Anaïs Kadian Telephone : 514.375.2673
AKadian@lcm.ca

LCM Avocats inc. | LCM Attorneys Inc.

600, boul. de Maisonneuve Ouest/West, #2700
Montréal (Québec) H3A 3J2