The Joint Liquidators of BANK OF ASIA (BVI) LTD (in liquidation) v. AXIOM FINANCIAL GROUP LTD (formerly known as BOA FINANCIAL GROUP LTD)

HCMP 990/2026

[2026] HKCFI 4694

IN THE HIGH COURT OF THE

HONG KONG SPECIAL ADMINISTRATIVE REGION

COURT OF FIRST INSTANCE

MISCELLANEOUS PROCEEDINGS NO 990 OF 2026

___________________

___________________

BETWEEN

__________________

_________________________________

REASONS FOR JUDGMENT

_________________________________

1.  By originating summons filed on 22 June 2026 (“OS”), the joint liquidators [1] (“JLs”) of Bank of Asia (BVI) Limited (in liquidation) (“Company”) apply for:

(1) Recognition of the Company’s liquidation and the JL’s appointment by the Eastern Caribbean Supreme Court of the British Virgin Islands (“BVI Court”);

(2) Assistance in the form of the powers set out in the draft order to the OS as amended by the revised draft order lodged on 5 August 2026; and

(3) An order requiring the Defendant to produce the information and documents relating to the Company set out in Schedule 1 and Schedule 2 of the OS.

BACKGROUND

2.  The Company was incorporated in the BVI on 11 August 2015. Before its demise, the Company was a financial entity licensed and regulated by the Financial Services Commission (“FSC”) in the BVI and offered a variety of financial services including offshore banking and wealth management.[2]

3.  The 2 founders of the Company are both bankrupts and trustees in bankruptcy have been appointed by the BVI Court over their estates.[3]

4.  The Defendant is a company incorporated in Hong Kong and is part of the Bank of Asia group of companies. According to the group structure chart prepared by the JLs, the Defendant has 4 shareholders[4] one of which[5] is wholly owned by BOA International Financial Group Limited (a BVI company).[6]

5.  The Company and the Defendant entered into a Service Agreement dated 1 February 2017 (“Service Agreement”) whereby the Defendant agreed to provide various “back office and IT services” to the Company. The Service Agreement was subsequently amended by extending the scope of service to providing middle and back-office support to the Company, which allowed the Defendant to have access to and possession of critical information of the operations and assets of the Company.[7]

6.  On 27 May 2025, Virgin Islands Deposit Insurance Corporation (“DIC”), an entity established by the Virgin Islands Government to provide protection for depositors against the loss of insured deposits placed within member institutions, applied to the BVI Court for appointment of joint provisional liquidators (“JPLs”) of the Company on the grounds that the Company was insolvent and they were concerned about the way the volume of questionable related party loans entered into by the Company such that there was a need to carry on urgent investigation into such loans.[8]

7.  On 28 May 2025, the JPLs were appointed over the Company.[9]

8.  Following their appointment, the JPLs requested the Defendant to provide documents relating to the Company but the Defendant refused to cooperate:

(1) After the JPLs informed the Defendant of their appointment and requested for the records, data and information of the Company, the JPLs and the Defendant’s officers held 2 meetings on 30 May 2025 and 6 June 2025.[10]

(2) In its letter dated 3 June 2025, the Defendant proposed a set of confidentiality conditions in allowing the JPLs to gain access to the Company’s information.[11] The JPLs agreed to the conditions but the Defendant only disclosed part of the information and documents requested by the JPLs.[12]

(3) In its letter dated 18 June 2025, the Defendant requested for additional time to address the JPLs’ queries. However, despite having been given additional time to comply with the request, only piecemeal information was provided. The JPLs’ multiple requests for meetings and clarifications were met with no response.[13]

9.  Thereafter, the Defendant took various steps which appears to have been designed to frustrate or delay the JPLs’ effort in obtaining the documents and information relating to the Company:

(1) In late June 2025, the Defendant changed its name and registered office.[14]

(2) On 1 August 2025, the Defendant acknowledged that they had failed to pay certain invoices and warned the JPLs that the Company would lose access to solutions and data due to non-payment of fees.[15]

(3) From August 2025 to October 2025, the JPLs were informed by the Chairman of the Defendant that the Defendant had run out of funds, ceased operations, surrendered its office, and dismissed all the employees. The Defendant was uncertain whether all the books, records and assets of the Company had been preserved.[16] At the hearing, Ms Lam confirms that despite the Chairman’s assertions, the Defendant remains in existence.

10.  On 16 September 2025, the BVI Court issued a Letter of Request to the Hong Kong court seeking recognition of and assistance to the JPLs in carrying out their functions and duties in Hong Kong (“1^st LOR”).[17] No application for recognition has been made by the JLs.

11.  Since 20 October 2025, there has been no communication between the JPLs and the Company. The emails sent to the Chairman of the Defendant were returned.[18]

12.  On 22 October 2025, after hearing the submissions of DIC, Justice Abbas Mithani of the BVI Court ordered that the Company be wound up in accordance with the provisions of the Insolvency Act 2003 (“Act”). In the same order, the JPLs were appointed as the JLs of the Company (“Appointment Order”).[19]

13.  On 2 May 2026, the BVI Court issued another Letter of Request to the Hong Kong court, seeking recognition of and assistance to the JLs to facilitate the exercise of their powers when dealing with the affairs of the Company in Hong Kong (“2^nd LOR”).[20] In the 2^nd LOR, the BVI Court:

(1) requested the Hong Kong court to recognise the liquidation of the Company and the appointment of the JLs, and provide assistance to the JLs for the exercise of their powers under the BVI insolvency law in respect of the Company to the fullest extent permitted by Hong Kong law;

(2) confirmed that the JLs have the powers prescribed in the BVI insolvency law, including the powers at s.186 and Schedule 2 of the Act; and

(3) confirmed that the JLs have the powers as a matter of BVI insolvency law to do the followings:

(a) require any written notice for information concerning the Company, including its promotion, formation, business, dealings, accounts, assets, liabilities or affairs as the JLs reasonably require;

(b) request and receive documents and information to which the Company appears to be entitled, contractually or otherwise, including but not limited to those concerning its promotion, formation, business dealings, accounts, assets, liabilities or affairs; and

(c) locate, protect, secure, and take into their possession and control the books, papers, and record of and in relation to the Company and its business including the accounting and statutory records within the jurisdiction of the Hong Kong court and to continue their investigation into the assets and affairs of the Company.

DISCUSSION

14.  The principles governing application for recognition of and assistance to office-holders appointed by a foreign court are summarized in Re USUM Investment Group Ltd [2026] HKCFI 1320:

(1) Recognition of the fact of a foreign officeholder’s appointment and his powers over a company’s affairs is a matter of ordinary private international law (§53(1)).

(2) The court may recognise the appointment of a foreign insolvency officeholder where:

(a) The foreign proceedings are collective insolvency proceedings;

(b) The foreign proceedings are conducted in the jurisdiction of the company’s place of incorporation or where its centre of main interests (COMI) is located; and

(c) Recognition is not barred on grounds of public policy, fraud or breach of natural justice, or the enforcement of foreign penal or revenue laws (§59(1)).

(3) Assistance refers to the grant of specific power by the domestic/assisting court in furtherance of officeholders’ functions (§53(4)).

(4) The court may grant assistance to a foreign insolvency officeholder or specific relief where:

(a) The appointment of the foreign insolvency officeholder is recognised under Hong Kong law;

(b) The power which the officeholder invites the court to exercise or confer is of a nature which the court has recognised at common law or which is proper for the court to exercise having regard to the proper exercise of the judicial function;

(c) The order sought is one which can be made under the law by which they were appointed;

(d) The assistance is necessary for the administration of the foreign winding-up or the performance of the officeholder’s functions; and

(e) The order sought is consistent with the substantive law and policy of the Hong Kong court (§59(2)).

RECOGNITION & ASSISTANCE

15.  The requirements for recognition (§1 of the OS/draft Order) are satisfied.

16.  First, the Company has since 22 October 2025 been in liquidation in the BVI under the supervision of the BVI Court. The JLs were appointed by the BVI Court pursuant to the Appointment Order, and the proceedings are collective insolvency proceedings conducted for the benefit of the creditors as a whole.

17.  Second, the liquidation of the Company has been commenced and conducted in the BVI, which is the Company’s place of incorporation and its COMI. The Company was incorporated and headquartered in the BVI. It held a General Banking Licence issued by the FSC and has substantial assets in the BVI.[21]

18.  Third, there is no public policy concern which may bar this Court from granting an order recognising the liquidation and the appointment of the JLs.

19.  The requirements for the order for assistance (§2 of the OS/draft Order) are also met.

20.  First, the appointment of the JLs is recognised under Hong Kong law.

21.  Second, the powers which the JLs sought by way of assistance are concerned with obtaining information and documents relating to the Company. Such powers have been regularly granted by the court in exercising the power under common law to recognise and assist foreign officeholders.

22.  Third, the powers sought by the JLs are conferred by the Appointment Order and the BVI law. The BVI Court has confirmed in the 2^nd LOR that the JLs are entitled to exercise such powers.

23.  Fourth, the assistance sought is necessary to assist the JLs in performing their functions as liquidators in Hong Kong for the following reasons:

(1) The Defendant failed to comply with the JLs’ requests for data, information and documents which are essential to their investigations of the Company’s affairs.

(2) The JLs need to secure the documents, information, book and records of the Company in order to conduct further investigation into the assets and affairs of the Company (§§2(a), 2(b), 2(c), 2(f), 2(g), 2(h), 2(i) of the OS).

(3) The JLs need to retain legal advisers and agents to assist them in the execution of their powers and duties including taking part in legal proceedings in Hong Kong (§§2(d), 2(e) of the OS).

24.  The assistance sought is consistent with the substantive law and policy of the Hong Kong court.

25.  The powers granted by way of assistance are powers which the JLs have under BVI law and the Appointment Order, as confirmed by the 1^st and 2^nd LORs. A table comparing the powers granted and the corresponding paragraphs in the 1^st and 2^nd LORs is set out in Annex A hereto.

PROVISION OF INFORMATION AND DOCUMENTS

26.  The court may in the exercise of the common law power to assist a foreign officeholder order a person within the jurisdiction to provide information and documents to the officeholder. The officeholder has to satisfy the court that the information or documents sought are reasonably required to enable him to carry out his functions, and the court must endeavour to strike a balance between the office-holder’s reasonable requirement and the need to avoid making an order that is unreasonable, unnecessary or oppressive to the party from whom the document or information is sought (Angela Barkhouse, The Official Liquidator of Bridge Global Absolute Return Fund SPC (in Official Liquidation) v Leading Securities Company Ltd (formerly known as CRIC Securities Company Ltd) and Others [2024] HKCFI 1160, §25).

27.  The information and documents sought from the Defendant fall into 2 categories:

(1) Category 1: The information and documents relating to the Company’s (a) investments and assets, (b) accounting records, (c) IT infrastructure, vendors and service providers, (d) bank statements, (e) service providers engaged, (f) monthly meetings of the Assets and Liabilities Committee, (g) assets and liabilities[22]. The Company is entitled to these information and documents pursuant to the Service Agreement (“Category 1”); and

(2) Category 2: The information and documents relating to the Company’s personnel and financing and investment activities[23]. These relate to the affairs of the Company and are necessary for the JLs to perform their functions (“Category 2”).

28.  Ms Lam submits that the reason for putting the information and documents into 2 categories is to distinguish between information and documents which the Company has a contractual entitlement to obtain from the Defendant (Category 1) and those which the Company does not have any contractual entitlement to obtain but are reasonably required by the JLs to perform their functions (Category 2).

29.  In my view, the distinction only goes to the exercise of discretion if the court does have the power under common law to grant the relief sought by the JLs. The prior issue which the court needs to be satisfied is whether the power to assist foreign officeholders extends to making an order requiring the Defendant to provide the information and documents sought by the JLs. This goes to the criteria discussed in Re USUM §59(2) (see §14(4)(b)-(c) above) to which I now turn.

30.  Section 282 of the Act provides that an office-holder may by notice in writing require a specified person to provide information requested by the office-holder.

(1) A specified person includes a person “employed by the company, including a person employed under a contract of services” and a person who has been an accountant (s.282(2)(d)-(e)).

(2) The information which may be requested is information concerning the company, including the promotion, formation, business, dealings, accounts, assets, liabilities or affairs as the office-holder reasonably requires (s.282(1)(a)).

(3) A person who receives a notice and without reasonable excuse fails to comply with it, commits an offence (s.282(3)).

(4) The above provisions make clear that the JLs have the power under s.282 of the Act to require the Defendant to provide the information falling within both Category 1 and 2 without an order of the BVI Court.

31.  For production of documents, ss.284 and 285 of the Act provide that an officeholder may apply to the BVI Court for an order requiring a specified person to produce at the examination “any books, records or other documents in his or her possession or control that relate to the company, or a connected company, including the promotion, formation, business, dealings, accounts, assets, liabilities or affairs of the company or connected company”.

32.  The issue is whether the power under common law to assist foreign officeholders extends to making an order to compel the Defendant to produce the documents sought when the BVI Court has not in fact made an order under ss.284-285 of the Act. In my view, the power of assistance extends to granting relief which could have been made by the foreign court even though no such order has in fact been made. This is consistent with the principles governing the grant of relief to assist foreign officeholders as discussed in Re USUM:

(1) For the court to exercise the power to assist foreign officeholders, the court needs to be satisfied that it has an equivalent power in common law, based on established case law or permissible judicial development the common law provide for it (§§44(3), 56, 59(2)(b));

(2) The power is not available to enable the officeholders to do what they could not do under the law by which they were appointed (§44(3)(b)); and

(3) Putting it in another way, the relief or order granted by way of assistance is one which can be or could have been made by the foreign court (§§45(1)[24], 56, 59(2)(c)).

33.  In the present case, the Company is a specified person under both limbs in that:

(1) The Defendant was employed “as an agent to provide back office and IT services” (clause 1 of the Service Agreement) and, therefore, was a person employed under a contract of services within s.282(2)(d) of the Act; and

(2) The Defendant was engaged to render accounting services, maintain accounting records, and assist in the filing of reports on behalf of the Company (clause 2.1 of the Service Agreement). Thus, the Defendant was employed as an accountant within s.282(2)(e) of the Act.

34.  The information and documents sought by the JLs under Category 1 and 2 are information and documents which concern the Company including its business, dealings, accounts, assets, liabilities or affairs, and are reasonably required by the JLs for the purpose of carrying out their functions as liquidators of the Company given that:

(1) The Defendant was engaged “as an agent to provide back office and IT services” (clause 1 of the Service Agreement). Although clause 7 describes the Defendant as an independent contractor, it does not change the fact that the services were rendered to the Company;

(2) The information and documents fall within the scope of services under clause 2 of the Service Agreement;

(3) The Defendant never disputed its obligation to provide the information and documents sought by the JLs. To the contrary, in its letter dated 18 June 2025, the Defendant stated that it had been “actively working on gathering the information and documentation”, and was “committed to providing our full cooperation”; and

(4) The JLs have already sent multiple notices to the Defendant requiring them to provide the information but to no avail.

35.  I am satisfied that it is necessary for the court to make an order to compel the Defendant to produce the information and documents falling within Category 1 and 2 having regard to the fact that despite the stated commitment to cooperate with the JLs, the Defendant has failed to comply with the requests and has since October 2025 become uncontactable.

36.  The order sought by the JLs is consistent with the substantive law and public policy of Hong Kong court.

DISPOSITION & COSTS

37.  It is in the circumstances appropriate for this Court to make an order in the terms set out in Annex B.

38.  The JLs’ own costs is a matter for the BVI Court, being the court supervising the liquidation of the Company (Re USUM, §76(9)).

39.  I consider that the Defendant should be ordered to pay the costs of and occasioned by the application which deals with production of information and documents as the application was necessitated by the refusal on the part of the Defendant in complying with the JLs’ requests. The costs assessed has been reduced from HK$369,592 to reflect the fact that part of the costs incurred relate to the JLs seeking recognition and assistance from the court which are not occasioned by the Defendant.

Annex A

Annex B

1. The liquidation of the Company and the appointment of Russell Crumpler and David Holukoff both of Teneo (BVI) Limited, and Chan Mei Lan of Teneo Asia Limited, as the Joint Liquidators of the Company by the Eastern Caribbean Supreme Court of the British Virgin Islands (“BVI Court”), and any successor(s) who may be appointed in their place as the Joint Liquidators of the Company (“JLs” or “Plaintiffs”), be recognised by this Court.

2. The JLs have and may exercise in the Hong Kong Special Administrative Region the following rights and powers for the purpose of carrying out the functions for which they are appointed:

a. To take possession of and preserve any books and records of the Company;

b. To identify any assets which may remain in the possession or control of the Company, and to take such steps as may be necessary to protect any such assets from removal or dissipation;

c. To take all necessary steps to obtain from any persons, any documents or copy documents which belong to the Company or which have been created or maintained on its behalf or which the Company has a right to obtain or inspect;

d. To retain and employ barristers, solicitors or attorneys, accountants and/or such other agents or professional persons as the JLs considers appropriate for the purpose of advising or assisting in the execution of their powers and duties under this Order;

e. To commence, continue, discontinue or defend any action or other legal proceedings in Hong Kong in the name and on behalf of the Company;

f. To investigate the affairs of the Company so far as necessary to protect and, if necessary, to retrieve any assets and records of the Company;

g. To require by written notice that:

(i) An officer or former officer of the Company;

(ii) Any member or former member of the Company;

(iii) Any person who was involved in the promotion of formation of the Company;

(iv) Any person who is, or at any time has been, employed by the Company, including a person employed under a contract for service;

(v) Any person who is, or at any time has been, a receiver, accountant or auditor of the Company;

(vi) Any person who is or who, at any time has been, an officer of or in the employment of a company which is an officer of the Company; or

(vii) Any person who has acted as administrator, liquidator or provisional liquidator of the Company,

do provide such information concerning the Company, including its promotion, formation, business, dealings, accounts, assets, liabilities or affairs as the JLs reasonably require, and to attend at such reasonable time and at such place as may be specified in the notice, and / or be examined on oath or affirmation;

h. To request and receive documents and information to which the Company appears to be entitled, contractually or otherwise, including but not limited to those concerning its promotion, formation, business dealings, accounts, assets, liabilities or affairs;

i. To locate, protect, secure and take into their possession and control the books, papers, and records of and in relation to the Company and its business including the accounting and statutory records and to continue their investigation into the assets and affairs of the Company; and

j. To take all other steps as may be incidental to the exercise of the above functions and powers.

3. The Defendant shall within 14 days (or such other time as may be agreed in writing between the JLs and the Defendant) from the service of this Order (either in physical copies or by electronic means):

a. provide to the JLs all information requested in Schedule 1; and

b. deliver up to the JLs all the documents, records and data as set out in Schedule 2 that are in the possession of the Defendant.

4. Without prejudice to paragraph 2(g), the Defendant shall provide to the JLs in writing any other information and deliver up to the JLs any documents concerning the Company (either in physical copies or by electronic means), including its promotion, formation, business, dealings, accounts, assets, liabilities or affairs as the JLs reasonably request within 7 days of such request (or such other time as may be agreed in writing between the JLs and the Defendant).

5. In the event that the Defendant asserts that it is not in possession of any of the information or documents requested in paragraph 3 above, it shall within 14 days from the service of the Order file and serve an affidavit stating whether it has at any time had in its possession, custody or power such requested information or document or any part of them, when it parted with the same and what has become of the same.

6. Liberty to apply.

7. There be a costs order nisi that the Defendant do pay the costs of and occasioned by the application for production of information and documents including the costs of the hearing and further submissions, which is assessed at HK$220,000.

Schedule 1: Requested Information

Part A: Information to which the Company is entitled pursuant to the Service Agreement dated 1 February 2017 between the Company and the Defendant, as amended from time to time (“Services Agreement”)

Accounting services and records

1. A summary of all investments and assets (whether tangible or intangible) in which the Company has any legal or beneficial interest, whether held by the Company or through third parties including but not limited to custodians, nominees, brokers, centralised or decentralised cryptocurrency exchanges, or non-custodial wallets, wherever such assets may be located (whether within or outside the Hong Kong) (“Assets”).

2. For each such Asset, a full description of its nature, its current whereabouts, the most recent available valuation (including the valuation date and source of information), and where such Asset is held with any third party, including all relevant details necessary to enable the JLs to identify and take control of the holdings.

3. A detailed breakdown of all the Company’s account receivables (“Account Receivables”) and account payables (“Account Payables”).

4. The reasons and objectives for the transactions referenced in Note 12 of the Company’s audited financial statements for the year ended 31 December 2023, namely:

(a) The transfer of a receivable of US$200,000 from BOA GPEC Group Limited to the Defendant; and

(b) The transfer of a receivable of US$1,148,238 from the Defendant to BOA International Financial Group Limited (collectively, “Receivables Transfers”).

5. Any current or historical guarantees or contractual arrangements related to the Company or the Services Agreement.

IT Infrastructure vendors and service providers

6. The following information regarding the vendors, IT-related service providers and data service providers engaged by the Defendant for or on behalf of the Company (whether such engagement is still ongoing or not) (“Vendors and IT Service Providers”):

(a) Details of the Company’s Microsoft 365 (“M365”) and Amazon Web Services (“AWS”) environments, including:

(i) details of all Microsoft 365 subscriptions, licences, billing arrangements and administrative accounts associated with the Company.

(ii) details of the primary AWS account and any associated sub-accounts, subscriptions and billing arrangements, administrative access to such account(s).

(b) Details of any other cloud-based servers (namely, virtual servers with cloud storage systems);

(c) Details of any other logical servers or resources, wherever located;

(d) A list of all administrative users prior to the above-mentioned access restriction;

(e) A list of all users and their respective licensed services prior to the above-mentioned access restriction;

(f) Details of any retention and backup policies (including but not limited to details of retention policies with regard to user level data and email deletion privileges) in effect prior to the above-mentioned access restriction;

(g) Confirmation of the current status for all IT-related service contracts entered into by the Defendant on behalf of the Company. In respect of each such contract, whether it remains in force or has been terminated, full particulars of the billing and payment status thereunder, including details of all invoices issued, payments made, any outstanding amounts and the periods for which they are owed;

(h) Details of the accounts and methods used by the Company to settle previous IT-related service bills; and

(i) A complete list of all individuals who have or used to have access to any email mailboxes under the domain “boafg.com”, including for each person full name, associated email address(es), telephone number(s) (including personal emails and telephone numbers for continued communication in the event that the “boafg.com” emails could no longer be accessed by that person), login details for all the email account(s) with the “boafg.com” domain to which they have access.

7. Other than the IT Service Providers, a list of any other types of service providers engaged by the Company directly, or by the Defendant on behalf of the Company, including but not limited to auditor, agent, legal advisor (“Other Service Providers”).

Part B: Information available to the Defendant that is related to the affairs of the Company and which is necessary to allow the JLs to perform their functions

Company administration and management

8. Organisation chart of all of the Defendant’s employees (employed at any time between 28 May 2025 to the date of the order), their roles, email addresses and telephone numbers who holds or used to hold functional roles in the Company.

9. Without prejudice to the forgoing, names, roles (in the Defendant, the Company, and in other entities associated with the Company) emails, telephone numbers of the following individuals:

(a) Kenneth Yiu;

(b) Hoiling Chung;

(c) Calvin Ching;

(d) Andy Chan;

(e) Alina Cuizon; and

(f) Any other individuals who are or used to be in the positions / functional divisions of customer service and KYC onboarding (or similar) in or for the Company.

For the purposes of paragraph 8 and 9 above, emails and telephone numbers shall include all contact email and telephone numbers available for an individual.

Schedule 2: Requested Documents

Part A: Documents to which the Company is entitled pursuant to the Services Agreement

1. Copies of all available statements and all correspondence in relation to any bank account(s) of the Company.

2. All agreements and transaction records including correspondence (i) between the Company and/or the Defendant and any Vendors and IT Service Providers, and (ii) between the Company and/or the Defendant and Other Service Providers.

3. All the accounting records of the Company from its incorporation to the date of the order to be made, including but not limited to general ledgers, monthly management accounts (including trial balance, profit and loss account, balance sheet), vouchers (including but not limited to receipt vouchers, payment vouchers and journal vouchers with supporting documents), and bank reconciliation statements that the Defendant maintains.

4. All the accounting records of BOA Investment Services Limited, a subsidiary of the Company, from its incorporation to the date of the order to be made, including but not limited to general ledgers, monthly management accounts (including trial balance, profit and loss account, balance sheet), vouchers (including but not limited to receipt vouchers, payment vouchers and journal vouchers with supporting documents), and bank reconciliation statements that the Defendant maintains.

5. All agreements and correspondence (including but not limited to emails and letters) with the Company’s customers relating to any advances made by the Company to the customers.

6. All correspondence and records (including but not limited to emails, letters and meeting notes) with the Company, its agents, representatives, advisors, or any other person or entity purporting to represent the Company, including but not limited to any instructions received by the Defendant from the Company.

7. All correspondence with any third parties, including but not limited to individuals, private, public or government entities, in respect of the Company.

8. All notes of monthly meetings of the Assets and Liabilities Committee, any details, schedule, breakdown and supporting documents of any management fees charged by Defendant since the Company’s date of incorporation to the date of the order to be made.

9. The terms and conditions, and any supporting documents for the Receivables Transfers.

10. All documents relating the assets and liabilities of the Company including the Account Receivables and Account Payables, including but not limited to any contract(s) and correspondence (emails, letters and any other written communications).

Part B: Documents in the possession of the Defendant that are related to the affairs of the Company and which are necessary to allow the JLs to perform their functions

11. All documents relating to any preference shares or similar issued by the Company, including but not limited to any allotment notices, from its incorporation to the date of the order to be made.

12. All debt instruments, US Treasury Bills and Bonds, purchased on behalf of Company since its date of incorporation, including purchase agreements, contracts and any other associated documentation.