TRuot c Rssocis@

ATTESTATION D'AUTH ENTICITE(4rt. 82.1, 2e al. C.p.c.)

J'atteste que le document annex est une copie conformedu fac-simil reu par tlcopieur

Nature du document :

Numro de cour:

Expditeur:

Tlcopieurdel'metteur: 514-982-4099

Lieu de la transmission : Montral

Date de la transmission : 2O juillet 2015

Heure de la transmission : 11h34

1\'r )-

Motion to institute proceedings for interlocutory andpermanent injunction

410-17-001343-1 56

Blake, Cassels et Graydon, avocats

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985, Royale, 2. tage, Trois-Rivires, (Qubec) GgA 4H7T1, : (819) 375-1074 / Tlc. : (819) 375-2084

Couniel : trudel@infoteck.qc.ca

Shawinigan, le 20 juillet 2OLs

Sbastien Boutet, Huissier de justice

795, 5" Rue, Shawinigan, (Qubec) GgN 1G2T1. : (819) 536-5190 / Tlc. : (819) 5364079

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ANADAPROVINCE OF QUBEGISTRICT OF SAINT,MAURICEN: 410-1 7^a>L?./3- l SG

SUPERIOR GOURT

N 4U93 P. ',)

Plaintiffs

|I[VE_.SALEEN, an individuat havtng his domicile at2735 Warlow Road,.n the city of Crona, Cliiornia,Uniterl States of America;-and-

SALEEN AUTOMOTIVE, tNG,, a corporation dulyincorporaled under the laws of Nevada, hving ; irrbusness at 601 E Charleston Btvd., in the-citi of LaiVegas, Nevada, United States of America;

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Defendents

MOTION TO INSTITUTE PROGEEDINGS FOR INTERLOCUTORYAND PERIIIANENT INJUNCTION

(Art, 7F1 and ff C.C.p.)

TO ONE OF THE HONORABLE JUDGES OF THE SUFERIOR GOURT OF QUBEC,SITTING IN THE DISTRICT OF SAINT.MAURICE, THE PLAINTIFFS SUBMIT

I, INTRODUCTION1- For the reasors expounded hereinbelow, the Plaintiffs, Mr. Steve Saleen (,,Mr. saleen")

and Saleen Automotive, lnc- ("SAl"), hereby seek interlocr.rtory and permanent njunctiveorders against the Defendant, Mr. Frdric Larnbert ("Mr. Lamberfl), restraining hirn,

FREDERIG LAMBERT, an individual domlciled at ZgS,9trgr]_n de la Baie, in tfre cty of Saint-Boniface, districioiTrois-Riviros, Province of eubec, GOX 2L0;-and-

JOHN DOE AND JANE DOE

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inter alia' from posting defarnatory commerrts with respet to the plaintiffs or tootherwise disseminating farse and hghry prejudiciar information against them.ln short, for unknown resons, Mr. Lambert, using aliases in most cses, rras beenposting defamatory comments on the Plaintiffs on various websites and blogs, whichadversely affected and impacted the Plaintiffs' respective reputation and even fhotrading volume and price of SAI's stocks.

It is of the utmost importance that this Honourable court urgently and perrnanenyorclers Mr' Larnhert to halt this outrageous and unjustfiabre behaviour, which conlinuesunabated-

THE PARTIES

Mr. Saleon is the president of SAl,

After a Garr as a racing driver, he founded the predecessor of sAr in 1gg3,

sAl s a Nevada-based corporaton which designs, develops, manufactures and sellshigh performance vehicles built from of Ford Mustangs, Chevrolet Camaros, DodgeChallengers and Tesle Model S vehcles chassis, as well as a broacl line of performanceparts, customizable designs, engineering and certifcation services the whole as morefully described in the printed extracts of SAI's website communicated as Exhibit p-',and as apears from $Al's Annual Report (Form 10-K) for the year ended March 31,2a filed with the u.s. securities and Exchange commssion (the 'sEc,)communicatecl as Exhibit p-p.

SAI's common shares are quoted on the OTG Bulletin Board, an over-the-countermarket, under the symbol "SLNN".

Mr. Lambert' is an individual residing in $aint-Boniface, eubec. He claims to be amarketing specialist and to have an interest in car-related blogging, as appears from hisprofessonal profile posted on Linkedln@ communicated as Exhibit p_1.

He also owns the dornain narne of the website "Blacksheepplanet,'(http://blacksheepplanet'com/), which focuses on Tesla products and dsparaging thePlaintiffs, nd l6i products, as appears from the printed extracts of the said website

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-3-olmun0ated, en /iasse, as Exhibit P'4 and lhe extract of the narne domain registrycommunicated as Exhibit p-5.

10' Moreover, as further demonstrated below, Mr. Lambert uses the alias ,,Fredvestor,, (the"Alins') to post defamatory comments on the website ,,lnvestor$Hub,com"("lnvestorsHub"), as well as other aliases and even his own nme to post on otherblogs and websites listed below (see Section lV below).

III. THE DISSEMINATION OF DEFAMATORY COMMENTS11' The Alias' profile was created on lnvestorsHub on March 19, 2014, the whole as

apprs from printed copies of the Alias' profile communicated as Exhibit p-6.

12' For several rnonths, to the Plalntiffs' best knowledge, since at least July 2014, the Alias,who had been posting messeges on lnvestorsHub's messeg board relating to SAI (the"Board") since March 2014, stafted to post prejudicial and defamatory commentsrelating to the Plaintiffs (the "Defamatory Postings-), the whole as appears frorn theprinted extracts of the Board communicated, sn |iasse, as Exhibit p-2.

13' As appears from the Alias'profile (Exhibit P-G), as of Juty 16, zgts, this Alias had posted1,118 comments, at all hours, multiple times any given day, on the Board (out of a totelof I ,150 comments posted by this Alias on the lnvestorsHub).

14' ln fact, the Alias is currently a moderato of the Board and is, by far, the rnost acvebloggers of the Eoard, e$ eppers from the Posfor Summaryof the Board communicatedas Exhibit P-8.

15. Below are just a few examples of the Defamatory Postings published by the Alias:

I guess it depends on your defnition of a scam,Google tells uslQuote;

a dishonest sheme; a fraud_

canare

hisrn

youeand

sohfraud,d

Safeendishonestabout

Stv

f0r

lking

As

aWhifel.

act.lega

when

iIal

ceiflegstn

strictlyanng

not

rhi

dabout

an

subjectivetalking

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dishonesl

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Lo.y.*,r,t'. depending on your defintion of scam, the ailegarions thatSLNN is a scam are based on facti.

hethe

Frederic Lambsrt is not a lro[. H wrote aicles about saleen based onverifable sources that are linked to the articles_http:/lacksheeFplanet.com/inrlex, php/category/oars/To this day no one has been abla tSaleen. Only invalid claimswhich was never actually m temails, which s even morehe was forging emails in whSLNN is a scam and always been a scm:t..1

I'll make it even more clear,

Beware thle lE only a pump and dumpI..I

pq qre.rur peogle, this is crearry a puMp and DUMP- Loot< at ail thelinks betweeh SLNN and ARy.Both companies issued a bunch of toxic notes to the same shadylenders:

I.l

Alert Pump and Dump

bad actors, David Weine Fred Knolland Eric

Th whol csaleen \a h shadY PeoPle' steveHe was invo a mulfitude of lawsuite.ole mllions fiom adozen of dealerships,The l(BM guys, the Kraher brothers, they had to settle with the SEC abunch of times.,.

Stoppe in shacly ompanis:are allimplicatedpublic by

nhagen, whichItwas brought

8Kpuug.

toridiculo

issuirrgeopl

rSp

IS

start

Thfg

they

cettncoue

bank,

bounuld

osh

their

f0r

byweed

nipulted on the OTC, t'r1oes way beyonct that. lt.e notpump from the companieswas entirely sotup to be a

624s

6489

6988

6993

Friday, May22,2A166:04:29 PM

Thursday,June 4, 201512:51:53 PM

Sunday,June 7, 2015l1:47:t6 AM

Sundy,June 7,201F01:08:43 FM

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"vested intregt" is a broad term. I havestock one way or the other.But bad actore around SLNN made sure to natte me personallyinvolved n this so here I am and I'lt ,J* iiio ifi* END.'

no financialintelest in Saleen,s

My findirrgs we rot more afarming than a simpre bad investmentopporturrity, it insiead unavere_d stoir manipuuon

"mJng iiffiminaractivities. r shared my findings wiffrne sEG and snce rhenthlngs have ntensified.

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lf you want to rearn about these bad.actors, you shourd start byun derstan d in g the rinks twen sareen's dwn erships nli

"t,suspicious entities: http://. i mgur.*omlt tnmZNpr.jpg't.1

n party_ressed as a

Both these guys have criminalcases against them including rape.These are the type of peopte Saleen cloes business with.,.This is on scrathcing the surface. there's nruch fiore about these guysand also $teve saleen himself- But you shourd rearn a Iot,Jrrf lr,Ltpretg soon.

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And now thrs Greentech business wth guys seiling fest tracrr toAmericar citizenships to Ghinese uusinsiman tofinance theirofipery, Their atso undr SEc invasttation BTW.Ths thing ts getting uglier every day.

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All I see from steve sareen is an attempt at rransfering his financiarexposule to the orc marr(et. My best gess is that t Jo"s*i"rabout his SLNN shares. all he cares is-getting rld of the few debt he ispersonally accountable for at SLNN.

I.I

11117

11121

11434

11547

Wednesday,July 01,201508;33:15 AM

Wednesday,July 01,20159:26:14 AM

Monday,July 13,201509:07:26 PM

Thursday,July 16,2015B:19:18 AM

16 All of these statements, reproduced hereinabove, re highly prejudicial. The notions of"fraud", "scam" and 'pump and dump schme" (which constitutes cminal allegations ofa fraud on the markei), amongst others, are negative, destructive and harrnful in natureartd advergely impact the Plaintiffs' respective reputations in a severe and rreparablefashion.

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The statements published by the Alias also suggest that the plaintiffs are beinginvestigated by the sEC in relation with the alleged,,pump and dump scheme,,, which, tothe Plaintiff's krrowledge, s simply false.

The Defamatory poslings referred expliciily to plaintiffs by name thror.rghout, are cfearlyahout and targeting the Plaintiffs, and were so understod by those who read theposting.

The Defamatory Postings are also cited on multiple instances on olher investmentwebsites, including the website "board reade/', on Saleen's Topic profile page, asappears from a printed extract of the Saleen's Topic Profile page "board reade' websteas of July 16, 2015 communicated as Exhlbt p-l0.

Moreover, Mr. Lambeft chose to publish the Defamatory Postings on lnvestorsHub,when he knew that $Al had purchased advertisement rights on this websile, sgmngly

19' The entirety of the statements calling Mr. $aleen a fraudster and scammer and statngthat sAl is not a ieal business and is inslead a "pump and dump scarn,, are false as theypertain to Plaintiff' More specifically, the statements as listed n paragraph 15 aboveand the other Defamatory postings are patenfly farse.

20- Tho Defarnatory Posting$ ale lbelous on their face: they clearly expose plaintiffs tohatred, contempt, ridicule and obloquy as it charges Mr. $aleen wth havirrg engaged incriminal activity ancl charges Mr. saleen and sAl with engaging in investor fraud andregulatory vlolations relating to the sale of ihares in $Al, The Defamatory postings alsoaccuse the Plaintiffs of running an orchestrated scam_

21' The Defamatory Postings were seen and read on or about the date of their posting andthereafter by members of the Board and/or other internet users searching for informationregarding the Plaintiffe, as prospecfive investors in SAI and/or custorners interested inordering a vehicle from the plaintitfs.

22. For instance, using another alias, "FredTesla", on a website dedicated to Tesla carsLan:bert urged potential buyers of the Saleen Tesla vehicles to reconsider their decisionin a disparaging comment which started with the following stetemnt ,'Saleen is runningsomething closely resembring a ponzi scheme/pump&dun.p,', s ppears from theprinted extracts of the said website cornmunicated as Exhbt p-g.

23.

24_

25,

28.

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30.

28' lt is equally reasonable to assume that the Defamatory Postings hv and may stilldvsrssy inrpact the price of SAI's stock

29. ln fact' the volume of trades of SAI's stock has recently increased dramatically, spigingat2?1,228,304 shares traded on or about June 21,2A15 (Exhibit p-1ll and the price ofsAlrs stock has significantly declined over the last three rnonths, l.e. -g4% of lts valueover the last three months end -33% of its value over the last month (Exhibt p-1?);

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IIV, LAMBERT IS USING THE ALIASESaa As mentioned above, since spring 2015 a dramatic increase in the pubtication of

Defamatory Postings is noticeable.

33' Given the increasing nurnber of Defmatory Postings, the personal attack$ includedtherein and the seeming impact of the Defamatory Postings on sAl,s stoct{, the plaintiflsbegan investigating the real identity of the Aljas.

Following a thorough nvestigation, they have been able to unequivocally establish thatMr. Lambeft is using the Atias.

On August 31, 2014, the Alias postecl on the Board a link to an email belonging to himshowinghisemailaddress(andhisfullname,a$appears frorn the posting communicated as Exhlbit p-13,

36. on August 18, 2014, the same narne and email address were used irr a webforrrsubmission to SAl, Mr, Lambsrt posed as a potential customr, es appars from theprinted copy of the said submission communicated as xhibit p-14.

On August 21,2014, the same emait acldress and neme were used in an email was sentin to the sAl's Public Relation Department's mailbox requestng information, this time, asan editor for BlackSheepPlanet.com, as apears from a printed copy of the said emailcommunicated as Exhibit p-15

38. The website BlackSheepPlanet.com has only a handful of afticles, all written by thesame editor named "Fred Lambert" (Exhibit p_4).

Whols, a web service providing information on domairr narnes revealed that the dornainname "BlackSheepPlanet.com" is owhed by Mr. Lambert and that the latter uses thesafn email address, and provided his street address and phone number, as apprsfrom the printed extracts of the whors wehsite (Exhibit p-b).

40 A reverse regearch on the sam website listed additional domains owned by the samename and email address, One of these sites is "ZalKoh.corr", as ppears from theprinted extracts of the said website communicated es Exhibit p-6.

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A research on the "ZarKon-com" domain nm reveared that the sne nme, emair, andcontact address as "Bracksheepplanet.00m" were used by Mr, Lambert, s appearsfrom the printed extracts of the research results communicated as Exhibit p-17.

Mr' Lambert has published on the "ZalKon.com" webpage an image of himself (ExhibitP-r6).

43. The Twitter profle of the "ZalKon-com" webpflge links the Twlter profile of Mr. Lambeftthat also shows a picture of the latter, as appears from the printed extracts of the saidprofile comrnunicated as Exhiblt p-,f g,

44 A Linkedln profile searclr for Mr. Lambert (Exhibit P-3) also tinks same to a profle withthe same name and pictures than those used on Mr. Lambert's Twitter profite (Exhibit p-18).

45. A Facebook profile search for Mr. Larnbert links to a profile with the same image arrdname as used on the "ZalKon.com" webpage (Exhibit P-1), es eppears from the printedextracts of Mr. Lambe1's Facebook profile communicated as Exhibit p-1g.

46. Moreover, the fact the Mr. Lambert pubtishes on various websites using aliasescommencing with "Fred", i,e. "Fred Lambert" on BlacksheepFlanet.corn, ,,Fredresta'onhttp:/futww-reddit.com/r/teslamotors and the Alias on invertorsHub, makes evdent fhatonly one individual

- who has a special interest in Tesla products and disparaging SAI

-

i behind lhese aliases.

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Furthermore, the cross-references between sorlle of the Defarratory postirrgs (see, forexamples, Defamatory Posting number 624t, Exhibit P-7 en /iasse) and Mr, Lambert'swebsite (Exhibit P-4) corroborate the relationship between Mr. Lambert and theaforementioned aliases.

ln light of the foregoing, it s urrquestionable that Mr. Lambert is the author of theDefamatory Postings.

THE ORDERS SOUGHT AND THE RIGHT TO THE ISSUANCE OF PROVISIONALAND INTERLOGUTORY INJU NCTIONS

As further described below. the Plaintiffs hereby seek manc,aiory orders destined at,inter alia, halting Mr' Lambert from posting, sharing, linking or otherwise dissemnating

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any further messages, comments, allegations or eny other communications, released viaany media (whether verbal, written or virtual), defaming, clisparaging, offending,denigratng or otherwise of a hannful nature relating to the ptaintiffs.

50' Considering that the Plaintffs cannot ssess whether Mr. Lambert has benefiied orbenefits from the participation of accomplices o[ othenrise, conspires or collaborateswith thircl parties with respect to the above-described defamatory scheme, it isnecessary that any orders to be rencferecl herein be enforceable against such thirdpartes becoming awae of such orders.

At the lnterlocutory Stage: the Plaintiffsr Prima Facie Right to the Sought ordersFor the reesons set forth above, the Plaintiffs are entfied to the sought orders: theDefamatory Postings and the other detamalory comrnents cited in Section lll above arebereft of arry foundation and are extremely prejudicial-

ln short, these comments constitute pure defamation.

Mr, Lambed's condut is simpry unjustified and plainly unjustifiable.

At the Interlocutory stage: the praintffs suffer lrreparahle harmAs described hereinabove, the Defamatory Postings ceuse irreparable harrn to thePlaintiffs' reputation.

Being acused of fraud on the rnarltet conspraces is one of the most prejudicialaccusations for a publicly-traded corporalion such as SAI_

At this stage, il is impossble to assss or otherwise determine the extent of thedantages caused by the Defamatory Fostings.

Moreover, this Honourable Court cannot ignore the prejudicial impact of the DefamatoryPostings on the trading of SAI's stock, which rlirectly irnpact SAI's finan6ng capcity butthe merket as well.

C. At the lnterlocutory Stage: the Balartce of lnconvenlerrces Favours the plaintiffs58- ln light of the foregoing, it s abundantly clear that the balance of inconveniences favours

the Plaintiffs.

A.

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59' In fact, Mr' Lambert -

and any of his accomplices, as the case may be -

would not sufferany prejudice should he be prevented from pursuing his defamatory scheme.

60' Any limitation to Mr' Lambert's capacity to communicate in regaids to the plaintiffs andtheir business would he of n0 or limitecl effect compred to allowng Mr, Lambert tocontnue spreding false and harrnful statements about the plaintiffs.

6l' Freedom of speech does not allow one to so blatantly slander anothe/s reputation.62' Should lhe sought orders not be granted, the Plaintiffs' reputation will continue to be

harmed.

. Necessity to hear the Motlon for lnterlocutory lnjuncffon as $oon ar possible63. lt is crucial that thia Honourable Court issue the sought interlocutory ordrs as soon as

possible, and in any evenl no tonger than five (5) days following the filing of the presentproceedings, given the following reason:

a) Mr. Lambert has recently increased the frequency of publication of theefamatory Postngs and continues to persistently, and on a daily basis, issuesuch Defamatory postings;

b) The volume of trades of SAI's stock has reoently increased drarnatically, spikinga|221,228,304 shares traded on or about June 19, 2015 (Exhibit p-12);

c) The price of sAl's stock has significantly declined over the last three months, i,e.94% of its velue over the last three months and 33% of its value over the tastmonth (Exhibit P-12);

64. The recent evoluton of SAI's stock is highly alarming.65. Moreover, considering the undeniable impact of Mr. Lambed's Defamatory postings on

Mr- Saleen's reputation, ths ongoing disparaging act has to stop forthwith.

66. ln short, this untenable siiuation rnust stop immediately and without delay.87. The Plaintffs therefore request that the Mofion for Interlocutory lnjuncton be heard no

later than five (s) days of the filing of the present proceedings.

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79' oRDER Mr' Lambert to provide to the Plaintiffs' counsel of record, within forty-eight (4g)hours of the order t0 be issued, a written list all of the aliases that he has used or is stillusing when disseminatng, releasng, posting, publishing, sharing, linking, or otherwisecommunicating the Comments;

80, ORDER provisional execution of the conclusons notwithstanding appeal;8f ' RESERVE lhe Plaintiffs their rights following receiving of the information refe'ed to in

paragraph 77 above, to seek such additional relief es may be appropriate in thecircumstances;

82' ORDER that the Plaintiffs do not have to post any security for costs herein;83' DEGLARE that the order to be issued can be enforceable against eny prson, including

corporate per$ons' who have partioipated or otherwse collaborated in the posting,publishing or communication of the Defamatory postings;

84' oRDER that any person directed by this order not to do somerhing shall not do it himselfor herself, nor through others acting on its, his or her behalf, or on its, his or herinslructions, or with its, his or her encouragement or acquiescence, nor in any other waywhatever;

85' AUTHORIZE service of the order outside of legal hours and on non-juridical days issufficient and valid for all legal intents and purposes irrcluding, wthout limitation, for thepurposes of Ailicle 7s6 of the Gode of civit procerlure of euebec;

Bo' DEoLARE that the prsentatlon of th Motion for lnterlocutory lnjunction within five (s)days of th filing of lhe present proceedings is sufficient and valid;

87 ' DEGLARE that the order to he issued wilt remain Valid and enforceable until finaljuclgment ls rendered herein;

88' IS'SUE ny other order that this Court may find necessary or useful in the circumstances;89. THE WHOLE wth cost against Mr. Lambert;At the Permanent Staseg0' GRANT this Motion to lnstitute Proceedings for Permanent lnjunction;

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-15-g1 oRDER the deierrdant, Frederic Lambert (,,Mr. Lambert") and any and a persons

ac[ing on behalf of or in conjunction with Mr. Lambert, and any and all persons havingnotice of ths injunctiort, to cease and desist frorn dissemirrating, releasing, postng,publishing, sharing, linkng, or otherwise comrnunicating or causing to be communicatedin any fashion whatsoever either through himself, his agent or othanruise on any mediawhatsoever, including on the websites lnvestorsHub.corrr or on the websiteBlackSheepPlanet.com, any comment relatng to the plaintiff Steve Saleen or thePlainliff saleen Automotive, lnc. or ils past, current and future affiliates, subsidiaries,directors, officers, mangement, employees, agents, representatives or shareholders(collectively, the "$afeen Person"), stating, declaring, alluding or otherwjse suggostingthat the $aleen Persons:

a) participatecl n, or are othenvise nvolved in a 'Traudulent scheme,', a ,,fraud,,, a"scam", a 'pump and dump schme" or any other behaviour of that nature;

b) are being nveetigated by the u-s. Securities and Exchange Commission or anyother organisation of that nature;

c) that the $aleer Persons have committed any crirninal or penal infiactions; ord) any other defamatory comrnents;ORDER provisional execution of the onclusions notwithstanding appeal;

DEGLARE that the order to be issued can be enforceable agenst eny person, includingcorporate prsons, who have prtiptd or othenryise collaborated in the posting,publishng or cmmunication of the Defarnatory postings;

oRDER that any prson drected by this order not to do something shall not do it himselfol herself, nor through others acting on its, his or her behalf, or on its, his or herinstructions, or with its' his or her encouragement or acquiescence, nor in any other waywhatever;

AUTHoRIZE service of the order outside of legal hours and on non-juridical days issufficient and valid for all legal intents and purposes including, without limitation, for thepurposes of Article 756 of the code of civilprocedure of euehec,

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96 ISSUE ny othr ordr that this Courl may fnd necessary or useful in the circumstances;

97. THE WHOLE with cost against Mr. Lambert.Montral, July 17,2018

Attorneys for the Plaintiffs

PELL&

N +yJ t, lE-17 _

NOTICE OF PRESENTATION

To Frederic Lambert795, Chemin de la BaieSanlEonifaoe, eubec GOX 2L0

-nd- John oe and Jane Doe

Defendants

TAKE NoTlcE lhat the Moton for lnterlocutory and Permanent lnjunction of the plantiffswlll be presented for decision before one of the Honoumble judges of the supeor ourt ofth in person or vfa vrdeoconference, n Tuesoay, juty 2g, 2019,at e rocated lz1?,6e Rue, $hawrnrgan, euebec, at i0:00 a.m,,0r selmay be heard, in room 2.02.DO GOVERN YOURSELVES AGCORDINGLY.

Montral, Ju 20, 2015

L&

Attorneys for the plaintifis

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NOTICE TO DEFENANT(Article 119 of the C.G.p.)

Take notice that the Plainliffs have filed this action or applioailon in the office of the superlorCourt of the judicialdistrict of Saint-Mauric.To file an answeg !r advocare; TiqijlLitjiTf'f."ffiifffi_,",1,1Qubec, GgN EB s Moilon.lf you fall to flle an Appearance withtn the tfm limlt indicated_, a judgment by default rrray berendered against vou wirhout turrher norice upon rhe eipl oitr. ro--d;t ir

n will be preserrted before the Court onof the Shawinigan Courthouse. On thet

lesswiththe

ff.tli* of the presenl Motion to Inslituta Proceedrirgq rhe ptainriffs disclosa rhe fottowingP-t;

P.2l

Printed extracts from SAI's website, erl liasse;

sAl's Annual Report (fgrm. lO-K) for the year ended March g1, z01F fled wfththe U.S. Securilios and Exchange Commision;Llnkedln@ profll of Frederic Lambert, as of July 1T,ZO16iPrinted exlracts from ,,BlackSheepplanet" website, en fbsse,;Printed xtrect from 'whots" wobsile - information on ,,BfacksheepFlanet"domain name registry;

Printed extracts from "lnvestorsHub,com" website -

profilo of "Fredvosto, as ofJuly 16, 2015, en 'asso;P'7: Printed extract

.

from 'lnvestorsHub.com,, website - sample of DefanratoryPostlngs by F/dvstr, e /rasse:P-8: Printed exttact from "lnvestorsHub.conr" websile - posfer Summary for saleenAutomotive lnc., as of July 16, p0l5;P-9; Printed extracl from "reddil.com" wesite - posilngs frorn ',Fredresla';P'10: Ptinted extract from "boarlreader.com" websile - Saleen,s Topic profil pg

webste as of July 16, Z01S;

P'11; Printed extracl from."BlackSheepFlanet" website - articte lilled Trying to ride onres/a's suess and the oTC lnvestors' Money pulirreo ny;rrJo iai"u,r" nJuly 15, 2014;

P'3:

P4:

P-5:

P-6:

ssr rv, LvtJ I t.-Tl'ltYl

-19-

P'12: Prlnted extracl ftom "lnvestorsHub.com'website -

posting from ,,Fredvestof,dated August 31,2014;

P''13: web form submisson from Frdric Lambert to sAl, dated August 1g, 2014;P-14: Effieit fr.m Frderic Lambert to SAl, dafed August 21,2014;P-1S; Prlnted extrac,ts from "ZalKon.com" website;P-16: Printed extract from SAI'$ website

- chart lllustrating the avolution of sAl stoclrfrom April 17,Z}ISto July 16,2015;

P'17;'Prinfod extract from 'Whole" webste - lnforrnation on ,,ZalKon' domain nameregtstry

P-18: Prinled extract oJ lF fry,lt"r proflle of ,Fred Lamberr' tinkad to the ,zalKon"webslle, as of July 16, Z01gP'19: Prfnted extract of the Facebook profire of ,'Fred Lamberf, as of Jury 16, 2015.The exhltts being annexed hereto.Request for transfer of a smatt claim

t exceed $7,000 and if you could have flledesf to the clerk forof MlProcedurccould be liable for

Montral, July 12,2018

BLAKE CASSELS &846343.tr

Altorneys for the plalntiffs