EXHIBITS PAGE #3 Affidavit #2 of T.

Hakemi

BRITISH COLUMBIA

BC Registry Services

Mailing Address: PO Box 9431 Stn Prov Govt

Victoria BC V8W 9V3

www.corporateonline.gov.bc.ca

Location: 2nd Floor - 940 Blanshard Street Victoria BC

250 356-8626

BC Company Summary
For TUGBOAT ENTERPRISES LTD.
Date and Time of Search: Currency Date: March 14, 2013 03:24 PM Pacific Time February 04, 2013

ACTIVE
Incorporation Number: Name of Company: Recognition Date and Time: Last Annual Report Filed: BC0699657 TUGBOAT ENTERPRISES LTD. Incorporated on July 13, 2004 01:15 PM Pacific Time July 13, 2012 In Liquidation: No Receiver: No

REGISTERED OFFICE INFORMATION Mailing Address: C6 RR#1 PINE TREE PLACE 9573 RANDOM ROAD POWELL RIVER BC V8A 4Z2 CANADA
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Delivery Address: C6 RR#1 PINE TREE PLACE 9573 RANDOM ROAD POWELL RIVER BC V8A 4Z2 CANADA

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RECORDS OFFICE INFORMATION Mailing Address: C6 RR#1 PINE TREE PLACE 9573 RANDOM ROAD POWELL RIVER BC V8A 4Z2 CANADA Delivery Address: C6 RR#1 PINE TREE PLACE 9573 RANDOM ROAD POWELL RIVER BC V8A 4Z2 CANADA

DIRECTOR INFORMATION
Last Name, First Name, Middle Name: Hendrickson, Heidi Mailing Address: 12453 BEL RED ROAD, SUITE 250 BELLEVUE WA 98005 UNITED STATES Delivery Address: PO BOX 1692 BELLEVUE WA 98009 UNITED STATES

This is Exhibit...Q>...referred to in the affidavit of. .X.B.&.^ems sworn (or affirmed) before me on

TOT taking affidavits for British Columbia

BC0699657 Page: 1 of 3

EXHIBITS PAGE #4 Affidavit #2 of T. Hakemi Last Name, First Name, Middle Name: Khoury, Samy Mailing Address: 12453 BEL RED ROAD, SUITE 250 BELLEVUE WA 98005 UNITED STATES Last Name, First Name, Middle Name: LYSTER, JONATHAN Mailing Address: 4623 MARINE AVENUE POWELL RIVER BC V8A 2K8 CANADA Last Name, First Name, Middle Name: WILSON, JUDELINE TYABJI Mailing Address: 4623 MARINE AVENUE POWELL RIVER BC V8A 2K8 CANADA Last Name, First Name, Middle Name: WILSON, GORDON Mailing Address: 4623 MARINE AVENUE POWELL RIVER BC V8A 2K8 CANADA Delivery Address: 4623 MARINE AVENUE POWELL RIVER BC V8A 2K8 CANADA Delivery Address: 4623 MARINE AVENUE POWELL RIVER BC V8A 2K8 CANADA Delivery Address: 4623 MARINE AVENUE POWELL RIVER BC V8A 2K8 CANADA Delivery Address: PO BOX 1692 BELLEVUE WA 98009 UNITED STATES

OFFICER INFORMATION AS AT July 13, 2012 Last Name, First Name, Middle Name: Hendrickson, Heidi Office(s) Held: (Other Office(s)) Mailing Address: PO BOX 1692, ,WA BELLEVUE WA 98009 UNITED STATES Last Name, First Name, Middle Name: Khoury, Samy Office(s) Held: (Other Office(s)) Mailing Address: PO BOX 1692 BELLEVUE WA 98009 UNITED STATES Delivery Address: PO BOX 1692 BELLEVUE WA 98009 UNITED STATES Delivery Address: PO BOX 1692, , WA BELLEVUE WA 98009 UNITED STATES

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BC0699657 Page: 2 of 3

EXHIBITS PAGE #5 Affidavit #2 of T. Hakemi Last Name, First Name, Middle Name: Lyster, Jonathan Sean Office(s) Held: (Secretary) Mailing Address: 8334 HIGHWAY 101 C.6 RR#1 GARNET ROCK POWELL RIVER BC V8A 4Z2 CANADA Last Name, First Name, Middle Name: Wilson, Gordon F.D. Office(s) Held: (Chair, President) Mailing Address: 9573 RANDOM ROAD POWELL RIVER BC V8A 0J4 CANADA
i^impttTtiH^it^^B-vi^f^^.*-E

Delivery Address: PO BOX 43 PARKSVILLE BC V9P 2G3 CANADA

Delivery Address: 9573 RANDOM ROAD POWELL RIVER BC V8A 0J4 CANADA

BC0699657 Page: 3 of 3

EXHIBITS
https://apps.lts&jj

f akemi

:lectionListResults.do

Date: 14-Mar-2013 Requestor: (PA61990) Folio:

TITLE SEARCH PRINT HAKEMI & RIDGEDALE LLP TITLE - BW452769

Time: 15:18:35 Page 001 of 002

VANCOUVER

LAND TITLE OFFICE

TITLE NO: BW452769 FROM TITLE NO: BM234136 29 SEPTEMBER, 2004 20 OCTOBER, 2004

APPLICATION FOR REGISTRATION RECEIVED ON: ENTERED:

REGISTERED OWNER IN FEE SIMPLE: GORDON FREDERICK DAVID WILSON, BUSINESSMAN JUDELINE KIM TYABJI WILSON, BUSINESSWOMAN C-6 PINETREE ROAD, R.R. #1, POWELL RIVER, BC V8A 4Z2 AS JOINT TENANTS TAXATION AUTHORITY: COURTENAY ASSESSMENT AREA

This is Exhibit..^.....referred to in the affidavit of IL&<?..ten\ sworn (or affirmed) before me on

' A?ffl.ttmZzi9J3.
loner for taking^ffidavits for British Columbia

DESCRIPTION OF LAND: PARCEL IDENTIFIER: 015-832-490 DISTRICT LOTS 5135, GROUP 1 NEW WESTMINSTER DISTRICT, EXCEPT PORTIONS IN PLANS 9259, 9450, 9812, 10924, AND 13014 AND EXPLANATORY PLAN 7091 LEGAL NOTATIONS: NONE CHARGES, LIENS AND INTERESTS: NATURE OF CHARGE CHARGE NUMBER DATE TIME MORTGAGE BB584304 2007-10-05 09:43 REGISTERED OWNER OF CHARGE: CIBC MORTGAGES INC. INCORPORATION NO. 33457A BB584304 MORTGAGE BB586495 2007-10-12 09:20 REGISTERED OWNER OF CHARGE: SERIN INVESTMENTS LTD. INCORPORATION NO. 183677 BB586495 ASSIGNMENT OF RENTS BB586496 2007-10-12 09:20 REGISTERED OWNER OF CHARGE: SERIN INVESTMENTS LTD. INCORPORATION NO. 183677 BB586496 MORTGAGE CA1486934 2010-03-15 07:41 REGISTERED OWNER OF CHARGE: CREST CAPITAL CORPORATION

lof2

13-03-14 3:19 P M

EXHIBITS PAGE #7
https://appsJts^(^^SJWebmtleSelectionListResults.do
INCORPORATION NO. 47 3361 Date: 14-Mar-2013 TITLE SEARCH PRINT Requestor: (PA61990) HAKEMI & RIDGEDALE LLP Folio: TITLE - BW452769 CA1486934 ASSIGNMENT OF RENTS CA1486935 2010-03-15 07:41 REGISTERED OWNER OF CHARGE: CREST CAPITAL CORPORATION INCORPORATION NO. 473361 CA1486935 CERTIFICATE OF PENDING LITIGATION BB1351130 2011-10-18 14:27 REGISTERED OWNER OF CHARGE: SERIN INVESTMENTS LTD. BB1351130 CERTIFICATE OF PENDING LITIGATION BB1351131 2011-10-18 14:28 REGISTERED OWNER OF CHARGE: CREST CAPITAL CORPORATION BB1351131 CERTIFICATE OF PENDING LITIGATION BB2009244 2012-01-18 10:18 REGISTERED OWNER OF CHARGE: CIBC MORTGAGES INC. BB2009244 JUDGMENT CA2757800 2012-09-06 14:28 REGISTERED OWNER OF CHARGE: CAPITAL ONE BANK (CANADA BRANCH) CA2757800 REMARKS: AS TO THE INTEREST OF JUDELINE KIM TYABJI WILSON "CAUTION - CHARGES MAY NOT APPEAR IN ORDER OF PRIORITY. SEE SECTION 28, L.T.A." DUPLICATE INDEFEASIBLE TITLE: NONE OUTSTANDING TRANSFERS: NONE PENDING APPLICATIONS: 015-832-490 CA3029115

Time: 15:18:35 Page 002 of 002

JUDGMENT

*** CURRENT INFORMATION ONLY - NO CANCELLED INFORMATION SHOWN ***

2 of 2

13-03-14 3:19 P M

This is Exhibit...?...referred to in the affidavit

SUPREME.COURT OF 3RITISH COLUMBIA

r-VUIDrro

DAr>r: # Q

of

XHatex

SEAL
31-Jul-12

sworn (or afifinned) before me on

iM'Mfe^

7* . . '#2 ? of ,? ... Affidavit T. Hakemi r * " ' ' " " -" '' '
court File NO. VLCSS-125354

A comrriisisioneTfor taking affidavits for British Columbia

No. Vancouver Registry

Vancouver REGISTRY

In the Supreme Court of British Columbia

Between:

HAKEMI AND COMPANY LAW CORPORATION Plaintiff

and: JUDY TYABJI WILSON and TUGBOAT ENTERPRISES LTD. Defendants

NOTICE OF CIVIL CLAIM This action has been started by the plaintiffs) for the relief set out in Part 2 below. If you intend to respond to this action, you or your lawyer must (a) file a response to civil claim in Form 2 in the above-named registry of this court within the time for response to civil claim described below, and (b) serve a copy of the filed response to civil claim on the plaintiff(s). If you intend to make a counterclaim, you or your lawyer must (a) file a response to civil claim in Form 2 and a counterclaim in Form 3 in the above-named registry of this court within the time for response to civil claim described below, and (b) serve a copy of the filed response to civil claim and counterclaim on the plaintiff(s) and on any new parties named in the counterclaim. JUDGMENT MAY BE PRONOUNCED AGAINST YOU IF YOU FAIL to file the response to civil claim within the time for response to civil claim described below. Time for response to civil claim A response to civil claim must be filed and served on the plaintiff(s), (a) if you were served with the notice of civil claim anywhere in Canada, within 21 days after that service, (b) if you were served with the notice of civil claim anywhere in the United States of America, within 35 days after that service, (c) if you were served with the notice of civil claim anywhere else, within 49 days after that service, or (d) if the time for response to civil claim has been set by order of the court, within that time.

EXHIBITS PAGE #9 Affidavit #2 of T. Hakemi

CLAIM OF THE PLAINTIFF Part 1: STATEMENT OF FACTS

The Parties 1. The Plaintiff Hakemi and Company Law Corporation is a law firm located at 1500885 West Georgia Street, Vancouver, British Columbia. 2. The Defendant Judi Tyabji Wilson ("Tyabji") is a businesswoman who resides at C6 RR#1 Pine Tree Place, 9573 Random Road, Powell River, British Columbia. 3. The Defendant Tugboat Enterprises Ltd. (Tugboaf) is a British Columbia company with a registered and records office at C6 RR#1 Pine Tree Place, 9573 Random Road, Powell River, British Columbia. 4. At all material times Tyabji was an officer and a director of Tugboat.

The Agreement 5. In or about September 28, 2008, an action was commenced by Kelly Wilson and Blair Wilson against Tyabji, Tugboat, Mark Allan Marissen, Elaine O'Connor, CanWest Publishing Inc. and Steve Janke, alleging that the defendants in that action, among other things, conspired to defame Blair Wilson (the "Action"). 6. In or about October of 2008, Tyabji and Tugboat (collectively, the "Clients") retained the law firm of Lang Michener LLP (now McMillan LLP) ("Lang") to represent them with respect to the Action. The lawyer primarily responsible for the conduct of the matter was Tom Hakemi. 7. On or about July 7, 2009, Mr. Hakemi informed the Clients that he would be leaving Lang to start his own practice, the Plaintiff. Mr. Hakemi requested that the Clients advise as to whether they wished to have the Plaintiff represent them in the Action or if they preferred to maintain Lang as their counsel. On July 8, 2009, the Clients agreed to have their file transferred to the Plaintiff and have the Plaintiff represent them in the Action and provide legal services to them, beginning on or about July 10,2009, based on certain terms (the "Agreement'). 8. The Plaintiff provided legal services to the Clients pursuant to the Agreement, and

EXHIBITS PAGE #10 Affidavit #2 of T. Hakemi

the Clients accepted them and agreed to pay for them, from approximately July 2009 to approximately April of 2010. During the time that the Plaintiff provided legal services to the Clients, nine invoices reflecting fees and disbursements were sent to the Clients, of which one was partially paid, particulars of which are as follows (as of June 8, 2012):
Date September 1,2009 October 6,2009 November 1,2009 December 3, 2009 January 7,2010 February 2,2010 March 7,2010 April 7,2010 May 7,2010 Invoice Number 9 21 36 71 77 94 111 131 166 Past Amount Due $5,080.32 7,006.98 2,263.39 10,435.73 778.4 2,866.08 4,105.92 2,304.96 1,567.45 Payment Received $4,500.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

10. The total amount outstanding as of June 8, 2012, is $31,909.23 (the "Fees and Disbursements Owing") plus interest of $13,772.41 (the "Contractual Interest") for a total of $45,681.64 (the "Amount Owing"). 11. Despite demand, the Clients have neglected or refused to pay the Amount Owing. 12. As a result of the Clients neglect or refusal to pay the Amount Owing the Plaintiff has suffered and will continue to suffer loss and damage. 13. Further or in the alternative, the Clients have been unjustly enriched by the legal services provided to them by the Plaintiff, there is no juristic reason for the enrichment and the Plaintiff has suffered a corresponding deprivation. Part 2: 1. 2 c.79; RELIEF SOUGHT

Judgment against the Clients for the Fees and Disbursements Owing; Judgment against the Clients for the Contractual interest or in the alternative, pre

and post-judgment interest pursuant to the Court Order Interest Act, R.S.B.C. 1996,

EXHIBITS PAGE #11 Affidavit #2 of T. Hakemi

3. 4.

Costs; and Such further and other relief as to this Honourable Court may seem just. LEGAL BASIS

Part 3: 1.

Breach of contract and unjust enrichment. c/o Hakemi & Company Law Corporation 1500 - 885 West Georgia Street Vancouver, BC V6C 3E8

Plaintiffs address for service:

Place of trial:

Vancouver, BC 800 Smithe Street Vancouver, British Columbia V6Z 2E1

The address of the registry is:

Date: July 30, 2012

Tom A. Hakemi Nicholas Ellegood HAKEMI & COMPANY LAW CORPORATION 1500 - 885 West Georgia Street Vancouver, BC V6C 3E8 Telephone: (604) 601-2020 Rule 7-1 (1) of the Supreme Court Civil Rules states: (1) Unless all parties of record consent or the court otherwise orders, each party of record to an action must, within 35 days after the end of the pleading period, (a) prepare a list of documents in Form 22 that lists (i) all documents that are or have been in the party's possession or control and that could, if available, be used by any party at trial to prove or disprove a material fact, and (ii) all other documents to which the party intends to refer at trial, and (b) serve the list on all parties of record.

EXHIBITS PAGE #13 Affidavit #2 of T. Hakemi

^u , -^m^ 20 July, 2012 1:06 PM Tom Hakemi <thakemi@hakemi.com> To- Nicholas Ellegood <nellegood@hakemi.com> Fwd Hakemi & Company Law Corporation - Statement of Account ^ )
r w u

"

TWs4frExWbit.^T^eferrettto1nihe affidavit of X..rt<?Km.1.

sworn (or affirmed) before me on

Please see below. Begin forwarded message:

J . $JMa&J.U&.
..^Q^...

A commissioner for taking affidavits for British Columbia

From: Judi Tyabji <jtyahjiw@amail.com> Subject: Re: Hakemi & Company Law Corporation - Statement of Account (2009-17) Date: 20 July, 2012 11:41:02 AM PDT To: Tom Hakemi <thakemi@hakemi.com> Hello Tom, Just had a half hour call with our lawyers in Berlin, who confirmed that their bank has the funds now en route to the trust fund. Confidentially, I can tell you that the amount to be transferred to McMillan will be CAD$25,000,000, and our lawyer in Berlin tells us that their bank will hold funds for up to ten days before the transfer as part of the standard bank protocol. He expects to see the funds in his account Tuesday or Wednesday at the latest. At that point, a letter with full legal authority will be sent from their firm to Karl Gustafson confirming the funds are waiting to be sent. So, realistically, with our long weekend holiday coming up, we are looking at early to midAugust to pay you, since your bill is on the short list of priority payments. I will send you a copy of the letter, in confidence, if you like once we have it. I am not contesting that money is owed to you, nor the amount, nor that I am also personally liable for the money. If you still want to talk this afternoon, please let me know. I now have a meeting at 2 pm but can call you just after. Thanks, Judi On Tue, Jul 17, 2012 at 11:48 AM, Tom Hakemi <thakemi@hakemi.com>

EXHIBITS PAGE #14 Affidavit #2 of T. Hakemi

wrote: Hi Judi, I'm available at 2pm of Friday. Please give me a call then and we can discuss this further. Regards, Tom Tom Hakemi HAKEMI & COMPANY LAW CORPORATION 1500 - 885 West Georgia Street Vancouver, BC, Canada V6C 3E8 TEL: (604)601-2021 (direct) FAX: (604) 648-9170 (direct) TEL: (604) 601-2020 (main) thakemi@hakemi.com

UAvw.hakemi.com \vw\v.litig-ationbrief.ca

This email and its attachments are confidential, may be privileged, and are intended for the recipient(s) only. If you are not the intended recipient, please notify us by telephone f604-601-2020) or return email immediately and delete all copies of this email and its attachments. Any inadvertent or unauthorized disclosure of this email is not intended as a waiver of the confidentiality or privileges that would otherwise apply.

On 2012-07-17, at 8:04 AM, Judi Tyabji wrote: Tom, Why don't we talk about this on Friday, at which time I expect to have more certainty on timing of funds? Thanks, Judi On Mon, Jul 16, 2012 at 5:22 PM, Tom Hakemi <thakemi@hakemi.com>

EXHIBITS PAGE #15 Affidavit #2 of T. Hakemi

wrote: Hi Judi, I hope you understand and can see that I do not want to start a lawsuit against you. On the other hand, I'm not sure that I have much of a choice, unless I'm prepared to wait indefinitely for payment, and I'm not. One idea you might want to consider is consenting to the entry of judgment on the condition that we don't enforce it for a period of time. If we can agree on the details of that arrangement, it would mean neither of us have to devote significant resources to a lawsuit; I would get some certainty; and you would get some time. I can't, however, give you legal advice with respect to this suggestion or any arrangement like this that we may enter into. I urge you to please seek independent counsel and let me know if this is of any interest. Regards, Tom

On 2012-07-16, at 2:03 PM, Judi Tyabji wrote: Tom, I understand that you have to do what you feel is appropriate, and if you feel that a lawsuit is your next step, that is your choice. However, can assure you this will not result in anything other than additional allocation of your resources pursuing a debt that is already acknowledged by both parties. Tugboat has no funds, with the freezing of the opportunity for share sales eighteen months ago pending the buyout. Gordon and I also have very limited resources since we have put all our efforts into this deal for almost two years. As I mentioned earlier, we are apparently almost concluded all the terms for the payout. It has been delayed considerably, however the deal is live and has made progress every week. In this economic climate, we see a delay as a 'win'. No one will be happier to see the funds transfer than Gordon and myself, so that we can actually get our lives back.

EXHIBITS PAGE #16 Affidavit #2 of T. Hakemi

All the best, Judi On Mon, Jul 16, 2012 at 1:49 PM, Tom Hakemi <thakemi@hakemi.com> wrote: Hi Judi, Thanks for your email. While I hope that the issues with Tugboat's funding work themselves out, I'm afraid we cannot wait any longer for them to do so. Unless we can work out satisfactory terms, we plan to, among other things, file papers in the form attached to this email by the end of this week, commencing suit against you and Tugboat. It will be our position in any hearing of this matter that you have personal liability for our bills as both you and Tugboat were our clients. I believe I also have written assurances from you that we will be paid. If you believe we can work out a suitable arrangement to avoid this, please let me know. Thanks. Regards, Tom

On 2012-07-16, at 1:01 PM, Judi Tyabji wrote: Hi Tom, Thanks for your patience, and for the information regarding the Straith matter. I cannot believe it is still active, and we intend to do something to wrap it up as soon as the funds arrive. We had a series of delays relating to the BC Security Commission. It does appear the last documents will be filed this week, and that should release the funds next week to McMillan. If all goes as planned, we will have your bill paid, realistically, just after the long weekend. All the best,

EXHIBITS PAGE #17 Affidavit #2 of T. Hakemi

Judi On Mon, Jul 16, 2012 at 12:49 PM, Tom Hakemi <thakemi@hakemi.com> wrote: Judi and Gordon: Could you please let me know when we can expect payment with respect to this bill? Thanks. Regards, Tom Begin forwarded message: From: Billing - Hakemi and Company <billinq@hakemi.com> Subject: Hakemi & Company Law Corporation - Statement of Account (2009-17) Date: 16 July, 2012 12:16:43 PM PDT To: itvabiiw@gmail.com Cc: Tom Hakemi <thakemi@hakemi.com> Good afternoon Ms. Tyabji Wilson: Please see the attached statement of account for services rendered. Should you have any questions or concerns, please do not hesitate to contact me.

Best regards, Lynn Siemens Office Manager HAKEMI & COMPANY LAW CORPORATION 1500 - 885 West Georgia Street Vancouver, BC, Canada V6C 3E8 Tel: (604) 601-2049 (direct) Fax: (604)648-9170 (direct) Tel: (604) 601-2020 (main) Email: lsiemens@hakemi.com

EXHIBITS PAGE #23 Affidavit #2 of T. Hakemi

VANCOUVER REGISTRY

m 1 2 OT
ENTERED

No. S-125354 Vancouver Registry

In the Sbpreme Court of British Columbia

etwi Between
HAKEMI & COMPANY LAW CORPORATION Plaintiff

and
JUDY TYABJI WILSON and TUGBOAT ENTERPRISES LTD. Defendants CONSENT ORDER BEFORE

) [ j A &6>I^T*M<Z ) ) )

FEB 0 8 2013

ON THE APPLICATION of the Plaintiff, without a hearing and by consent THIS COURT ORDERS that 1. Hakemi & Company Law Corporation is granted judgment against the Defendants, jointly and severally, in the sum of $35,853.33. THE FOLLOWING PARTIES APPROVE THE FORM OF THIS ORDER AND CONSENT TO EACH OF THE ORDERS NOTED ABOVE: Signature of the Plaintiff Tom. A HakejnL Signature of theVjefendant Judy TyabjiWilson. Signature of the defendant Tugboat Enterprises Ltd. Judy. TyabjrWnsofT" This is Exhibit..VrT...referred to in the affidavit of .X..tt.?.ferr.i|. sworn (or affirmed) before me on

' J.^t).d.L?r9.!3.
Sioner for taking affidavits for British Columbia

EXHIBITS PAGE #25 Affidavit #2 of T. Hakemi

LAND TITLB ACT FORM B (Section 225) MORTGAGE - PART 1 Provmee of British Cotambta Your electronic signature is a representation that you are a subscriber as defined by the Land Title Act, RSBC 1996 c.250, and that you have applied your electronic signature in accordance with Section 168.3, and a true copy, or a copy of (bat tree copy, is in your possession. APPLICATION: (Name, address, phone number of applicant, applicant's solicitor or agent) PAGE OF PAGES

Tom A. Hakemi, Barrister and Solicitor Hakemi & Company Law Corporation 1500-885 West Georgia Street Vancouver BC
I

Tel: (604) 601 -2020 File No: 2011-176 V6C3E8

Deduct LTSA Fees? Yes

PARCmmENTIFIER AND I i G A L DESCRIPTION OF LAND:

(

0%-832-480

3.

YES STC7 ') r BORROWERS) (MORTOAGORfS)): (including postal addresses) and postal code(s))

DISTRICT LOTS 5135, GROUP 1 NEW WESTMINSTER DISTRICT, EXCEPT PORTIONS IN PLANS 9259,9450,9812,10924, AND 13014 AND >i EXPLANATORY PLAN 7091

GORDON FREDERICK DAVID WILSON, BUSINESSMAN JUDEUNE KIM TYABJI WILSON, BUSINESSWOMAN, AS JOINT TENANTS C-6 PINETREE ROAD, R.R. #1 POWELL RIVER BRITISH COLUMBIA V8A4Z2 CANADA
LENDER(S) (MORTGAGEE^)): (including occupatic9{8), postal address(es) and postal code(s))

HAKEMI & COMPANY LAW CORPORATION 1500 - 885 WEST GEORGIA STREET VANCOUVER CANADA
S. PAYMENT PROVISIONS: (a) Principal Amount: (b) Interest Rate:

BRITISH COLUMBIA V6C3E8

Incorporation BC0856421

$35,853.33
(d) Interest Calculation Period:

5.00% per annum

(e) Payment Dates: N/A (h) Interest Act (Canada) Statement The equivalent rate of interest calculated half yearly not in advance is N/A %perannum. (k) Place of payment:

(c) Interest Adjustment Date: N/A ( 0 Hrst Payment Date: N/A (i) Last Payment Date: N/A

M D

Monthly
(g) Amount of each periodic payment

N/A

0 Assignment of Rents which the applicant wantsregistered?

YEsn

Nogg

Postal Address in Kern 4

(I) Balance Doe Date: O N DEMAND

If YEsTpage and paragraph number

EXHIBITS PAGE #26 Affidavit #2 of T. Hakemi

MORTGAGE-PARTI 6. MORTGAGE contains floating charge on land ? PAGE MORTGAGE secures a current or running account ?

OF

PAGES

YESQ

NO0

YES0

NOQ

INTEREST MORTGAGED:

Freehold 0 Other (specify)

MORTGAGE TERMS: Part 2 of this mortgage consists of (select one only): (a) Prescribed Standard Mortgage Terms ( ! D F Number (b) Filed Standard Mortgage Terms Q (annexed to this mortgage as Part 2) (c) Express Mortgage Terms l""l A selection of (a) or (b) includes any additional or modified terms referred to in item 10 or in a schedule annexed to this mortgage. 10. ADDITIONAL OR MODIFIED TERMS:

11. PRIOR ENCUMBRANCES PERMITTED BY LENDER:

12. EXECUTION^): This mortgage charges the Borrower's interest in the land mortgaged as security for payment of all money due and perfonnance of all obligations in accordance with the mortgage terms referred to in item 9 and the Borrowers) and every other signatory agree(s)tobe bound by, and acknowledges) receipt of a true copy of, those terms. Officer Signatures) Execution Date

Borrowers) Signatures)

Gordon Frederick David Wilson

OFFICER CERTIFICATION: Your signature constitutes a representation that you are a solicitor, notary public or other parson authorized by the Evidence Act, R.S.B.C. 1996 c 124 to take affidavits for use in British Columbia and certifies the matters set out in Part 5 or the Land Title Act as they pertain to the execution of this' instrument PFTPRft (<?>MJMP

EXHIBITS PAGE #27 Affidavit #2 of T. Hakemi

Joel Hill # 4 December, 2012 11:02 AM <jhill@hakemiridgedale.com> To: Gordon Wilson <gordon@myselkie.com> Re: Outstanding Accounts
1 Attachment, 879 KB

Dear Mr. Wilson. Further to the below, where is the money to which you refer? Also, it was a term of our agreement that you would grant us a mortgage in the form emailed to you previously. Although you did send a copy signed by you and Ms. Tyabji-Wilson, those signatures were not witnessed as required. Please courier us a copy of the mortgage, a copy of which is reattached to this email, this time duly executed by you both in the presence of a lawyer or notary.
This is Exhibit...! referred to in the affidavit

Kind regards,
Joel H i l l

of.

.X..tf.&kjna.'

sworn (or affirmed} before me on .......^V^ _ ^ . Arommisslonerfor taking affidavit

HAKEMI&RIDGEDALELLP
1500 - 885 West Georgia Street Vancouver, British Columbia Canada V6C 3E8(604) 648-9170 Tel: (604) 601-2049 Main: (604) 601-2020 Fax: (604) 648-9170 jhiH@hakemiridgedale.com HakemiRidgedale.com

British Columbia

This email and its attachments are confidential, may be privileged, and are intended for the recipient(s) only. If you are not the intended recipient, please notify us by telephone (604-6012020) or return email immediately and delete all copies of this email and its attachments. Any inadvertent or unauthorized disclosure of this email is not intended as a waiver of the confidentiality or privileges that would otherwise apply.

EXHIBITS PAGE #28 Affidavit #2 of T. Hakemi

Adobe

2012-09-2....pdf (879 KB)

On 2012-11 -16, at 8:21 AM, Gordon Wilson <aordon@mvselkie.com> wrote: Good morning Joel, We received word from the law firm in Germany this morning that finally funds related to the sale of Tugboat Enterprises Ltd are moving and that we can expect the first tranche early next week. Those funds will provide sufficient money to make a substantial payment against our outstanding account if not retire it in full. In light of this information, I would ask that no further action be taken on this matter until at least Wednesday next week. I will keep you fully informed as to the progress we are making in this regard. Yours truly, Gordon Wilson On Tue, Nov 13, 2012 at 3:10 PM, Joel Hill <ihill@hakemiridgedale.com> wrote: Dear Mr. Wilson, As we have not yet received any further payments on behalf of Ms. Tyabji Wilson or the company, I am writing to remind you that pursuant to our Security Agreement dated October 22, 2012, we will cease forbearing collection after this Friday, November 16, 2012. Kind regards,

JOEL HILL

1500 - 885 WEST GEORGIA STREET VANCOUVER, BRITISH COLUMBIA CANADA V6C 3E8

TEL: (604)601-2058 MAIN: (604) 601 -2020

EXHIBITS PAGE #29 Affidavit #2 of T. Hakemi

FAX: (604) 909-2799

JHILL@HAKEMIRIDGEDALE.COM HAKEMIRIDGEDALE.COM

This email and its attachments are confidential, may be privileged, and are intended for the recipient(s) only. If you are not the intended recipient, please notify us by telephone (604-601-2020) or return email immediately and delete all copies of this email and its attachments. Any inadvertent or unauthorized disclosure of this email is not intended as a waiver of the confidentiality or privileges that would otherwise apply.

On 2012-10-25, at 12:01 PM, Gordon Wilson wrote: Dear Joel, Find attached a scanned copy of originals that will be in the mail to you this afternoon. I will email a tracking number to you when the documents are sent. Best, Gordon Wilson On Wed, Oct 24, 2012 at 5:27 PM, Joel Hill <jhill@hakemi.com> wrote: Dear Mr. Wilson, I can confirm that we will not take your guarantee of Tugboat Enterprises Ltd.'s debts to our firm to be a guarantee of any other debts owned by that company. We can also forebear from enforcing the judgment until November 16, 2012. Please send the agreement and order without delay, and provide us with the tracking information for the hard copy of those documents. Kind regards,

Joel Hill
HAKEMI & COMPANY LAW CORPORATION

EXHIBITS PAGE #30 Affidavit #2 of T. Hakemi

1500 - 885 West Georgia Street Vancouver, BC, Canada V6C 3E8 Tel: (604) 601-2058 Main: f604) 601-2020 Fax: (604) 909-2^99 jhill@hakemi.com
HAKEMI & COMPANY LITIGATION BRIEF

This email and its attachments are confidential, may be privileged, and are intended for the recipient(s) only. If you are not the intended recipient, please notify us by telephone (604601-2020) or return email immediately and delete all copies of this email and its attachments. Any inadvertent or unauthorized disclosure of this email is not intended as a waiver of the confidentiality or privileges that would otherwise apply.

On 2012-10-24, at 3:48 PM, Gordon Wilson wrote: Dear Mr. Hill, Neither Judi nor I are currently in a financial position that will permit us to hire legal counsel. I am not sure how familiar you are with this file. Mr. Hakemi was retained by both Tugboat Enterprises Ltd and Ms.Tyabji Wilson personally to sever us from what we believe to be completely unsubstantiated charges brought against the company and Judi by Blair Wilson. Regrettably Mr. Hakemi was unable to have either Tugboat Enterprises Ltd or Judi Tyabji Wilson removed from the proceedings and noting our inability to pay, he stopped representing us. To date he has been courteous, most patient, and understanding with respect to the unpaid amount owing. We are most grateful for that and completely understand that he is anxious to have this matter resolved and we share that desire. Regrettably, we still face action by Mr. Wilson and his lawyer Mr. Jay Straith despite their inability to provide a shred of evidence linking either Tugboat Enterprises Ltd or Judi Tyabji Wilson to the alleged charges he has been presented on behalf of his client. I raise this background because the consent order requires me to guarantee amounts owed by both Tugboat Enterprises Ltd and Ms. Judi Tyabji Wilson. I would like it understood and accepted that I have as a

EXHIBITS PAGE #31 Affidavit #2 of T. Hakemi

matter of record not been prepared to personally guarantee the debts of Tugboat Enterprises Ltd generally. My willingness to sign this consent order in favour of Mr. Hakemi is an exception and should in no way constitute evidence to the contrary. If at some later date it is possible to provide a detailed billing that differentiates the time spend and billing generated on behalf of Tugboat Enterprises Ltd and that spent defending Judi personally I would greatly appreciate it. Last, in light of my knowledge on the progress being made on the closing of the sale of Tugboat Enterprises Ltd I would like by consent to move the date that you will permit prior to seeking to enforce the Judgement from November 6, 2012 to November 16, 2012 in order to provide sufficient time to have funds properly received and disbursed. If there is agreement I will send copies of the scanned consent order followed by originals in the mail later today. Thank you for your patience and understanding on this matter. Sincerely, Gordon F.D. Wilson I trust you will understand that at this critical juncture in the sale of Tugboat it is very important that the record show that this personal undertkaing On Wed, Oct 24, 2012 at 1:11 PM, Joel Hill <jhill@hakemi.com> wrote: Dear Mr. Wilson, In the circumstances, it would be best to have all our correspondence in writing - please send me an email with the issues you wish to discuss, as well as your position on same. Kind regards,

Joel Hill

EXHIBITS PAGE #32 Affidavit #2 of T. Hakemi

HAKEMI & COMPANY LAW CORPORATION

1500 - 885 West Georgia Street Vancouver, BC, Canada V6C 3E8 Tel: (604) 601-2058 Main: (6041 601-2020 Fax: (604) 909-2799 jhill(a),hakemi.com
HAKEMI & COMPANY LITIGATION BRIEF

This email and its attachments are confidential, may be privileged, and are intended for the recipient(s) only. If you are not the intended recipient, please notify us by telephone (604-601-2020) or return email immediately and delete all copies of this email and its attachments. Any inadvertent or unauthorized disclosure of this email is not intended as a waiver of the confidentiality or privileges that would otherwise apply.

On 2012-10-24, at 12:33 PM, Gordon Wilson wrote: Hi Joel, I did leave you a message this morning. I am not requesting more time as we have the documents witnessed and signed and will send them off to you today. We have delayed sending them as we have been focused on getting funds from the sale of our company into BC so that we can settle this account. That is after all the proper remedy here. I simply wanted to touch base first to make sure that we are all on the same page here. Best, Gordon Wilson

On Tue, Oct 23, 2012 at 7:24 PM, Joel Hill <ihiJI@hakemi.com> wrote: Dear Mr. Wilson, What do you wish to discuss? If you only want more time to respond to the draft form of security sent to you by Nick nearly a month ago, the conversation will be of very little utility - as I set out in my email, we

EXHIBITS PAGE #33 Affidavit #2 of T. Hakemi

need a substantive response or we will apply for default judgment. Kind regards, Joel Hill
HAKEMI & COMPANY LAW CORPORATION

1500 - 885 West Georgia Street Vancouver, BC, Canada V6C 3E8 Tel: (604) 601-2058 Main: (604)601-2020 Fax: (604) 909-2799 jhm@hakemi.com
HAKEMI & COMPANY LITIGATION BRIEF

This email and its attachments are confidential, may be privileged, and are intended for the recipient(s) only. If you are not the intended recipient, please notify us by telephone (604-601 -2020) or return email immediately and delete all copies of this email and its attachments. Any inadvertent or unauthorized disclosure of this email is not intended as a waiver of the confidentiality or privileges that would otherwise apply.

On 2012-10-23, at 6:17 PM, Gordon Wilson wrote: Hello Joel, I didn't send the response to you this afternoon as I would like to have a quick phone call before I do. Are you available to take a call in the morning - Wednesday Oct 24th? Best, Gordon On Mon, Oct 22, 2012 at 3:18 PM, Gordon Wilson <qordon@mvselkie.com> wrote: Hello Joel,

EXHIBITS PAGE #34 Affidavit #2 of T. Hakemi

My apologies for the long delay. I will properly respond to you by tomorrow afternoon latest. Thank you for your consideration, Gordon Wilson On Mon, Oct 22, 2012 at 11:38 AM, Joel Hill <ihill@hakemi.com> wrote: Dear Mr. Wilson, ; We have still not heard from you with respect to the below. If a ; substantive answer is not received by Wednesday, we anticipate ; filing an application for default judgment without any further notice to you. Kind regards, Joel Hill
HAKEMI & COMPANY LAW CORPORATION

1500 - 885 West Georgia Street Vancouver, BC, Canada V6C 3E8 Tel: (604) 601-2058 Main: (604) 601-2020 Fax: (604) 909-2799 jhill@hakemi.com
HAKEMI & COMPANY LITIGATION BRIEF

This email and its attachments are confidential, may be privileged, and are intended for the recipient(s) only. If you are not the intended recipient, please notify us by telephone (604-601-2020) or return email immediately and delete all copies of this email and its attachments. Any inadvertent or unauthorized

EXHIBITS PAGE #35 Affidavit #2 of T. Hakemi

disclosure of this email is not intended as a waiver of the confidentiality or privileges that would otherwise apply.

On 2012-10-15, at 2:20 PM, Nick Ellegood wrote: Mr. Wilson, I am following up on my below email. Please respond to Tom this week. Regards, Nick
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ill!
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On 2012-09-26, at 3:01 PM, Nick Ellegood <nelleaood@hakemi.com> wrote: Mr. Wilson, Further to your conversation with Tom from a few weeks ago, attached please find a draft form of security agreement. Given that you and Ms. Tyabji Wilson own your property as joint tenants we have included you in the agreement as a guarantor. Please review the attached carefully and let us know if it is acceptable. Please note that we cannot give you advice regarding this agreement and you should both seek legal advice regarding it before agreeing to its terms. Please contact Tom if you would like to discuss. Regards, Nick Ellegood

Nicholas P. Ellegood HAKEMI & COMPANY LAW CORPORATION