On November 14, 2024, upon the application of certain Canadian investors, the Court of King's Bench of Alberta (the "Court") issued an order under the Companies' Creditors Arrangement Act, R.S.C. 1985, c. C-36, as amended (the "CCAA") (the "Initial Order") with respect to Angus A2A GP Inc., Angus Manor Park A2A GP Inc., Angus Manor Park A2A Capital Corp., Angus Manor Park A2A Developments Inc., Windridge A2A GP Inc., Windridge A2A Developments, LLC, Fossil Creek A2A GP Inc., Fossil Creek A2A Developments, LLC, A2A Developments Inc., Serene Country Homes (Canada) Inc. (collectively, the "Companies"). Alvarez & Marsal Canada Inc. was appointed pursuant to the CCAA as monitor (the "Monitor") of the business and financial affairs of the Companies, with expanded powers to operate the day to day business of the Companies.

The Initial Order provides for, among other things, a stay of proceedings to November 24, 2024 (the "Initial Stay Period"). The Initial Stay Period may be further extended by the Court from time to time. The Initial Order also provides a stay of proceedings against Angus A2A Limited Partnership, Angus Manor A2A Limited Partnership, Windridge A2A LP, Hills of Windridge A2A Trust, Fossil Creek A2A Limited Partnership, and Fossil Creek A2A Trust.

A comeback hearing (the "Comeback Hearing") has been scheduled to be heard on November 21, 2024 at 2:00 pm MST where the Court will hear arguments with respect to the relief granted in the Initial Order, an extension of the Initial Stay Period, and any additional relief that may be sought at the Comeback Hearing.  At the Comeback Hearing, the Monitor will seek to increase charges on the property of the Companies and expand the charges to attach to the undivided financial interests of certain investors in real estate purchased through investments raised by one or more of the Companies. Such charge will rank in priority to all other security interests, trusts, liens, charges and encumbrances, and claims of secured creditors, statutory or otherwise in favour of any person. The purposes of the charges are to secure payment for the professionals involved in the proceeding and to secure the funding made available by an interim lender. These amounts, in aggregate, are expected at this time to be $2,500,000 (excluding interest, costs and expenses) and are secured against all of the projects included in the CCAA filing.