Summary

ptGf78MYTikcgh0w9Q5GBzrbeQThHGiz5FgPb3y_sdA2oNtEpV_hDdAdccm1-iYkwPvQzRb3Ge5ML0wyCEHwTzEnObbvTBhn_Q==
  1. Properties - Meeting Date: Not specified - Meeting Type: Call - Note Type: Summary - Attendees: Scott Warner; David McHugh

  2. Meeting Summary We focused on finalizing our bankruptcy proof of claim and aligning on committee participation and advisor follow-ups. I will file the claim at approximately 1,200,000, reflecting the debtor's default and the settlement acceleration with 1.5% per month interest from the initial date. Per David's guidance, Question 5 on the claim form should be marked No, and the claim described as an unsecured claim for goods sold and delivered, with no collateral and no litigation. We will not list counsel on the form at this stage; we can supplement later and will receive notices regardless. If advisable, we may send the debtor a courtesy notice about our disclosure, but that is not a blocker to filing.

On the unsecured creditors' committee, I will submit Amity's request now. David and Beth may apply to represent the committee, which would support our position and is not a conflict. There is a non-zero chance of recovery given the debtor's stated assets vs. liabilities, though we are not banking on it.

On restructuring, CLA's deliverable appears to be a limited, high-level review. David will forward the context and spreadsheet to Olga and ask what she needs to validate or redo the analysis and define scope. We need to decide quickly whether to have CLA complete the work or shift to AFS once Olga clarifies requirements. I will also resend the 2025 Canadian Baskin invoices to David. David will update Rachel on current status and coordination with Beth, who is on maternity leave but still advising as needed.

  1. Attendee List - Scott Warner - David McHugh

  2. Action Items - Scott - File the proof of claim at approximately 1,200,000 with corrected entries: - Set Q5 to No. - Describe as unsecured claim for goods sold and delivered. - Note no collateral and no litigation. - Do not list counsel at this time. - Scott - Submit Amity's request to join the unsecured creditors' committee. - David - Coordinate with Beth and consider applying to represent the unsecured creditors' committee; confirm whether a courtesy notice to the debtor about our disclosure is recommended. - David - Forward the CLA context and spreadsheet to Olga, request her scope and requirements to validate or redo the analysis, and copy me. - Scott - Resend the 2025 Canadian Baskin invoices to David. - David - Update Rachel on the bankruptcy claim status, committee approach, and Beth's involvement. - Scott - Set up email filters to triage bankruptcy notice traffic. - Scott and David - Decide whether to have CLA complete the analysis or shift to AFS once Olga provides scope and required source materials.

  3. Relevant Timelines - Proof of claim filing - Immediate. - Creditors' committee request - Immediate. - Olga scoping response for restructuring workplan - This week, pending her reply to David's outreach. - Canadian invoices - Resend immediately. - Rachel update - ASAP.

  4. Additional Notes - Claim details recap: Original balance 1.6M; debtor paid 600k; default occurred pre-bankruptcy; settlement default triggered acceleration; interest accrues at 1.5% per month from the initial date; current claim calculated at approximately 1.2M. - We may provide a courtesy notice to the debtor about our disclosure, but disclosure is permissible in the bankruptcy context and should not delay filing. - Expect heavy notice traffic from the court docket; filters and triage will be important. - Ignore cold-call pitches to influence committee representation; proceed through our counsel. David and Beth potentially representing the committee would bolster our position without creating a conflict. - CLA's work was a limited high-level review of books, records, and tax returns; Olga will likely need the same underlying materials to validate or rebuild the analysis. Coordination will determine whether we re-engage CLA or proceed with AFS.