Krejci in his capacity as liquidator of Myoora Land Pty Ltd (in liq) v Myoora Land Pty Ltd

INTRODUCTION 1 This is an application by Peter Krejci, the liquidator of Myoora Land Pty Ltd (in liq) for orders under ss 596A, 596B and 597(9) of the Corporations Act 2001 (Cth) to: summons five individuals for examination about Myoora's examinable affairs; require them and Interhotel Finance Ltd, a company incorporated in the Special Administrative Region of Hong Kong in the People's Republic of China with a business and bank account in the Republic of France, to produce documents; and allow each of those five individuals and Interhotel to be served overseas. 2 Myoora owned the sites of two tourist attractions, the now defunct museum and amusement park, Old Sydney Town and the existing, well known attraction, Australian Reptile Park, which were both located next to each other on the old Pacific Highway on the Central Coast of New South Wales. In 2018, Myoora and a related entity, Somersby Property Pty Ltd (in liq), also now in liquidation but with a different liquidator, sold the five properties on which those businesses were conducted for about $22 million. Myoora went into liquidation in November 2022 and Mr Krejci was appointed its liquidator. Mr Krejci is seeking to ascertain what happened to the money paid as Myoora's share of that sale.

BACKGROUND 3 The evidence before me comprises confidential affidavits by Mr Krejci, made on 22 December 2022, and a solicitor acting for him, Alexander Blackie, made on 22 May 2023, that are in support of the application for each of the summonses. Those two affidavits are subject to rr 11.3(4A) and (7) of the Federal Court (Corporations) Rules 2000 (Cth) and so are not available for inspection by any person without the leave of the Court. There is also evidence before me as to the proposed methods of service in the affidavits of Mr Blackie affirmed on 18 May 2023 and another solicitor for Mr Krejci, Blake O'Neill, affirmed on 22 December 2022. 4 Myoora and Somersby leased part of the five properties to a related entity, Five Continents Amusement Parks Pty Ltd (in liq), which subleased part of the properties to Warwick Amusements Pty Ltd (in liq), the operator of Old Sydney Town which ceased operating, apparently, in 2003. The remaining part of the five properties is occupied under a lease in favour of Australian Reptile Park Pty Ltd with a term ending on 29 July 2067. Australian Reptile Park commenced operating in about 1996 and continues to do so on that leased land and other land unrelated to land owned by Myoora or its associates. 5 In about May 2018, Myoora and Somersby entered into a contract of sale of the five properties for about $22 million to World Cultural Tourism Village Pty Ltd and that sale completed in July 2018. At the time of the sale and until late November 2022, the directors of Myoora were an Australian resident, Paul Kiley, who is not the subject of the present application, Richard Chiu, also known as Dick Tak-Sang Chiu, who has residential addresses in both Hong Kong and London in the United Kingdom, and Ulla Schneider, a resident of France. 6 Mr Krejci has applied for summonses for examination under s 596A and for production of documents under s 597(9) to issue and be served on Richard Chiu in both Hong Kong and London and on Ms Schneider in France. He also has applied for the issue of examination summonses under s 596B and production summonses under s 597(9) in respect of three other persons whom he contends may be able to give information about the examinable affairs of Myoora, namely Stephen Linch, a resident of France, and two of Richard Chiu's children, Clare Annabel Chiu, a resident of Hong Kong, and Warren Chiu, a resident of New York in the United States of America.

THE LEGISLATIVE SCHEME 7 Relevantly, s 596A provides that the Court must summon a person for examination about a corporation's examinable affairs if an eligible applicant, such as its liquidator, applies for the summons and the Court is satisfied that the person to be summonsed was an officer, during or after the two years ending, where the corporation is under administration, on the s 513C day. Those criteria are satisfied here in respect of Richard Chiu and Ms Schneider. There is no discretion as to the making of such an order under s 596A once the criteria that it prescribes are established. 8 In contrast, s 596B gives the Court a discretion to make an examination order and provides: 596B Discretionary examination (1) The Court may summon a person for examination about a corporation's examinable affairs if: (a) an eligible applicant applies for the summons; and (b) the Court is satisfied that the person: (i) has taken part or been concerned in examinable affairs of the corporation and has been, or may have been, guilty of misconduct in relation to the corporation; or (ii) may be able to give information about examinable affairs of the corporation. (2) This section has effect subject to section 596A. 9 The Court also has a discretion under s 597(9) to order a person to produce documents at an examination, and it provides: The Court may direct a person to produce, at an examination of that or any other person, books that are in the first-mentioned person's possession and are relevant to matters to which the examination relates or will relate. 10 Rule 10.44 of the Federal Court Rules 2011 now provides: Any document other than an originating application may be served outside Australia with the leave of the Court, which may be given with any directions that the Court considers appropriate. 11 Rule 10.46 allows service on a person outside Australia to be made in accordance with the law of the country concerned, including if that law does not require personal service, and r 10.45(b)(ii) allows service on a person outside Australia in the same way as the Federal Court Rules apply to persons in Australia, to the extent its provisions are relevant and consistent with Div 10.4 of the Rules and the Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters done at The Hague on 15 November 1965 (the Hague Convention). Relevantly, Art 10(a) and (b) of the Hague Convention provides: Provided the State of destination does not object, the present Convention shall not interfere with - (a) the freedom to send judicial documents, by postal channels, directly to persons abroad, (b) the freedom of judicial officers, officials or other competent persons of the State of origin to effect service of judicial documents directly through the judicial officers, officials or other competent persons of the State of destination. (emphasis added) 12 In addition, s 1140 of the Companies Act 2006 (UK) provides that a person who is a director or secretary of a company incorporated under that Act in the United Kingdom may be served with a document by leaving it at, or sending it by post to, the person's registered address, whatever the purpose of the document in question and regardless of whether the service has any connection to the person's holding of office.

THE RELATIONSHIP BETWEEN MYOORA AND THE PERSONS TO WHOM THE LIQUIDATOR WISHES TO SUMMON 13 The liquidator wishes to obtain information about Myoora's examinable affairs and seeks the issue of the five examination summonses and summonses to produce documents, largely in the same form, to each of the examinees and Interhotel. Because each of the examinees and Interhotel are to be served outside Australia, the liquidator applied under r 10.44 for leave to do so. 14 A number of those individuals were officers of one or more of Myoora and or other companies that appear to have had financial dealings or associations with Myoora and to have been part of a corporate group or were associated entities because of those various common, but not always entirely overlapping, directorships. The evidence before me suggests that, because of their apparent interactions with Myoora, it can be inferred that those companies and their officers, being Richard Chiu, Ms Schneider, Mr Linch, Warren Chiu and Ms Chiu, may be able to give information about "examinable affairs" of Myoora within the meaning of that expression in the Act. 15 On 31 July 2018, Richard Chiu and Ms Schneider, as directors of both Myoora and Somersby, directed those companies' solicitors to remit to Interhotel the whole of the about $22 million proceeds of sale of the five properties to its bank account in France, almost $20 million of which was payable to Myoora and $2 million to Somersby. 16 As at 5 December 2022, Richard Chiu, Ms Chiu, Mr Linch and Ms Schneider were all directors of Interhotel. That company appears to have been financially involved in the affairs of Myoora. 17 Warren Chiu and Mr Kiley were directors of both Five Continents and Warwick Hotels Pty Ltd, which was deregistered by the Australian Securities and Investments Commission on 6 February 2020. Mr Kiley, Richard and Warren Chiu were directors of Warwick Amusements. David Hambleton, the liquidator of Warwick Amusements, in a report to creditors, listed Myoora as an unsecured creditor owed $10 million.

CONSIDERATION 18 I am satisfied by the evidence of Mr O'Neill and Mr Blackie that Art 10(a) of the Hague Convention allows service in each of the United Kingdom, France, Hong Kong and the United States of America. 19 A search at Companies House revealed that Richard Chiu is a director of Warwick Hotel Cambridge Ltd, which is incorporated in the United Kingdom, and that he has a correspondence address in London. I am satisfied that for the purposes of the law of the United Kingdom, Richard Chiu may be served by post or personally at his registered address both pursuant to s 1140 of the Companies Act and Art 10(a) of the Hague Convention. 20 Mr O'Neill's evidence establishes that the Republic of France has not opposed service of documents being made under Art 10(a) of the Hague Convention. Mr O'Neill also proposed to avail of an alternate method of service under Art 10(b) of the Hague Convention using a Huissier de Justice accredited with the Chambre Nationale des Huissiers de Justice Service des Actes Internationaux (CNHJ), that is, by a person nominated by the Republic of France as a judicial officer, official or other competent person for service under Art 10(b). 21 During the hearing, I sought identification of the role of a Huissier de Justice. In supplementary evidence, Jeremy Gadsden, a solicitor employed in Mr O'Neill's firm, made an affidavit on 26 May 2023. Mr Gadsden obtained evidence from Fabien Cordiez, who was both a French avocat and member of the Aix-en-Provence bar as well as a non-practising solicitor of England and Wales about the roles and functions of Huissiers de Justice (or bailiffs) and CNHJ. 22 Mr Cordiez explained that, on 1 July 2022, bailiffs and auctioneers in France had created a new, amalgamated, profession of judicial commissioner or Commissaire de Justice and a new professional body, that is part of the French Department of Justice, called Chambre Nationale des Commissaires de Justice. Mr Cordiez said that despite this recent change, most French bailiffs still refer to themselves as Huissiers de Justice. He said that, now, Commissaires de Justice are the professionals designated by French law to serve summonses, court orders and subpoenas and that when the Ministère de la Justice, as the French Central Authority under the Hague Convention, receives a request for service, it forwards the documents to the Chambre. 23 Mr Cordiez said that Commissaires de Justice are permitted under French law to effect service of judicial documents in France under Art 10(b) of the Hague Convention. I accept that evidence. 24 Accordingly, each of Ms Schnieder and Mr Linch can be served in France by post from Australia and by a Commissaire de Justice. 25 Service on Richard Chiu and Ms Chiu in Hong Kong can be effected under the law of Hong Kong applicable under Art 10(a) and (b) of the Hague Convention. The Hague Convention website states that in respect of Hong Kong, China has no opposition to service under Art 10(a) and allows private agents, usually a firm of solicitors, to be appointed directly to effect service under Art 10(b) without the need to go through the Government or the Judiciary of Hong Kong. Thus, each of Richard Chiu, Ms Chiu and Interhotel can be served in Hong Kong by post and or through Mr Krejci appointing solicitors to do so. 26 Warren Chiu can be served in New York again under Art 10(a) because the United States of America has no opposition to such service under Art 10(a) or the use of the entity appointed by the Central Authority, ABC Legal, to serve documents under Art 10(b). 27 I am satisfied that it is possible to serve, outside Australia, each of the proposed individual examinees and Interhotel with the summonses for examination and production of documents.

SHOULD LEAVE TO SERVE OUTSIDE AUSTRALIA BE GRANTED? 28 The test, on an ex parte application, for the grant of leave to serve a person outside Australia under the Federal Court Rules is that the applicant must satisfy the Court that there is a prima facie case for relief and that if the material before the Court permits inferences to be drawn and those inferences translated into findings of fact, they would support the relief claimed: Ho v Akai Pty Ltd (in liq) (2006) 247 FCR 205 at 208 [10] per Finn, Weinberg and Rares JJ. 29 The question here, unlike that in cases for service of originating process, is whether there is any impediment to service outside Australia of an order compelling a person resident in, or a citizen of, another country to obey that order. This can raise issues of public international law as to whether such an order, if made, could interfere with the sovereignty of the country of service. 30 In Waller v Freehills (2009) 177 FCR 507 at 521 [58], Finn, Dowsett and Siopis JJ held that each of ss 596A and 596B evinced the intention of the Parliament that the Court have both jurisdiction and power to summons persons falling within the ambit of those sections to attend the Court and be examined in relation to a company in liquidation's examinable affairs, whether or not such persons are resident in, or citizens of, Australia. 31 Ordinarily, courts exercise caution in making orders for service out of the jurisdiction on persons not otherwise subject to their jurisdiction as impinging on a foreign state's sovereignty. Their Honours referred to the legislative intention apparent in s 5(7) of the Corporations Act that stated that each provision of the Act applied, according to its tenor, to natural persons, whether resident in Australia or not, and or bodies corporate whether formed or carrying on business in Australia or not. Their Honours held that this legislative intention displaced any presumption that the Corporations Act operates only territorially. In addition, I would observe that s 3(3) of the Act provides that its operation outside Australia, leaving aside the external territories, is based on the legislative power of the Parliament under s 51(xxix) of the Constitution and any other power under s 51. 32 Finn, Dowsett and Siopis JJ held that the Court has no discretion as to whether it will order service outside Australia when the two criteria in s 596A are satisfied but s 596B confers a discretion to order service outside Australia. They held that the Parliament had determined that, whatever risk there may be of adversely affecting international comity, s 596B recognised and accommodated that risk by giving a discretion to the Court, provided that the Court is satisfied of there being a sufficient connection between that person and the company's examinable affairs. They said (at 521 [61]): Thus, it appears that the legislative scheme seeks to meet in some respect international law concerns regarding comity by vesting in the Court discretion as to whether to issue a summons for the examination of a nonresident in the first place, as opposed to giving the Court a power to determine whether such summons once issued, should be served. 33 Their Honours went on to hold that (at 529 [96]): It is to be inferred that the Parliament would have appreciated that the exercise by the Court of the jurisdiction to summons foreigners or nonresidents to appear before it pursuant to ss 596A and 596B, would necessarily involve an invasion of the sovereignty of the state in which the foreigner or nonresident is resident. It is further to be inferred that Parliament has decided that any international opprobrium attached to the passing of extraterritorial legislation is justified in the public interest for the protection of the interests of Australian creditors and contributories. Accordingly, the fact that the issue of an examination summons would involve an invasion of sovereignty per se carried little weight as a discretionary consideration in determining whether leave should be granted to serve the summons in a foreign country. 34 In addition, their Honours held an examination summons under s 596B was not an originating process so that an analogue of what is now in r 10.44 applied to regulate the grant of leave to serve outside Australia. There is no substantive difference in the nature of an examination summons under s 596A or a summons to produce documents under s 597(9), and neither in my opinion is an originating process. 35 In Palmer v Ayres (2017) 259 CLR 478 at 491-493 [28]-[36], Kiefel, Keane, Nettle and Gordon JJ held that the power under s 596A is a procedure that gives a liquidator the right to seek to examine certain persons involved in a corporation about its affairs and thereby seek to establish, and then enforce, a potential right to relief against those with liabilities to the corporation, including alleged wrongdoers, and that this was a sufficient controversy to constitute a matter. 36 By parity of reasoning, ss 596B and 597(9) involve the conferral of similar powers on the liquidator once the criteria for the issue of summons each section prescribes are met and the Court is satisfied, in the exercise of its discretion, that it is appropriate to order service of the summons on a person outside Australia. 37 Having regard to material in the evidence in the confidential affidavits, I am satisfied that it is appropriate to issue summonses under s 596B of the Act to each of Mr Linch, Ms Chiu and Warren Chiu because, first, Mr Krejci, as liquidator of Myoora, has made the application and, secondly, each of them may be able to give information about examinable affairs of Myoora. 38 Likewise, I am satisfied by that evidence that it is appropriate to issue summonses pursuant to s 597(9) of the Act to produce books in the possession of each of the five examinees and Interhotel in the form sought in the summonses, as amended during the course of argument today, which the liquidator proposes to serve on each of them. That is because the categories of material in the books for which the liquidator seeks production appear to be relevant to matters to which the examination relates or will relate, to the extent that they are in the possession of each person to whom the respective summons is addressed.

CONCLUSION 39 For these reasons, I will make orders granting the liquidator leave to serve the summons by prepaid registered post under ss 596A and 597(9) on Richard Chiu in both the United Kingdom and Hong Kong, under ss 596A and 597(9) on Ms Schneider in France, under ss 596B and 597(9) on Mr Linch in France, under ss 596B and 597(9) on Ms Chiu, and under s 597(9) on Interhotel, in Hong Kong, and under ss 596B and 597(9) on Warren Chiu in New York and, to the extent that the liquidator seeks, also on each such person by use of a process in accordance with Art 10(b) of the Hague Convention. I certify that the preceding thirty-nine (39) numbered paragraphs are a true copy of the Reasons for Judgment of the Honourable Justice Rares.

Associate: Dated: 9 June 2023 Order FEDERAL COURT OF AUSTRALIA No. NSD22/2023 District Registry: NEW SOUTH WALES DIVISION: GENERAL IN THE MATTER OF: MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) PETER KREJCI IN HIS CAPACITY AS LIQUIDATOR OF MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) Plaintiff Before: Rares J Where made: Sydney Date of Order: [x] May 2023 THE COURT ORDERS THAT: -

1. Pursuant to section 597(9) of the Corporations Act 2001 (Cth), Richard Chiu, also known as 'Dick Tak-Sang Chiu' (Richard Chiu) attend before the Court for production of the documents and things specified in the schedule to these orders (Production Schedule) to the Federal Court of Australia, Law Courts Building, Queens Square, Sydney NSW at 9:30am Wednesday 28 June 2023.
2. In order to comply with Order 1, Richard Chiu may, instead of attending before the Court on the date and time specified in Order 1, deliver or send the documents or things specified in the Production Schedule to the Court at the physical or email address below, so that they are received by the Court not less than 2 clear business days before the date specified in Order 1. The Registrar Federal Court of Australia Level 17, Law Courts Building Queens Square 184 Phillip Street Sydney NSW 2000 OR nswreg@fedcourt.gov.au
3. Richard Chiu need not comply with these orders if the Plaintiff fails to serve, or cause to be served, a copy of these orders (including the Production Schedule) personally on Mr Chiu by 5:00pm 8 June 2023 (AEST). PRODUCTION SCHEDULE- RICHARD CHIU ALSO KNOWN AS 'DICK TAK-SANG CHIU' Richard Chiu, you must produce each of the documents mentioned below: In this Schedule the following definitions apply: Defined Term Definition Accounts Any account, cheque account, loan account, credit card account, investment account, term deposit, cash management fund, on call deposit, insurance bond, investment insurance policy and trust account. Act Corporations Act 2001 (Cth). Associated Entities means the following entities: (a) Somersby Property Pty Limited (in liquidation) (ACN 089 634 220); (b) Warwick Amusements Pty Ltd (in liquidation) (ACN 002 276 217); (c) Five Continents Amusement Parks Pty Ltd (in liquidation) (ACN 002 995 066); (d) Warwick Hotels Pty Ltd (ACN 002 273 850); (e) Carnavon Shipping SA; (f) Warwick Holdings SA; and (g) Texon Investments Inc. Asset An asset of any description, including but not limited to real or personal property, whether tangible or intangible, present or future, vested or contingent, wherever situated, whether held beneficially or as trustee for a trust. Books Any Document, being: (a) a register; and (b) any other record or information; and (c) Financial Records, Financial Reports or Financial Statements; and (d) insurance policies. Classic Holdings Classic Holdings Ltd. Company Myoora Land Pty Limited (in liquidation) (ACN 089 634 131). Conditsis Lawyers Conditsis & Associates Pty Limited (ACN 114 761 410) trading as Conditsis Lawyers and includes any director, officer, employee or agent of Conditsis Lawyers. Crowe Horwath Findex Pty Ltd (ACN 006 466 351) formerly trading as Crowe Horwath and currently trading as Findex and includes any director, officer, employee or agent of Crowe Horwath. Directors includes all current and former directors of the Company: (a) Richard Chiu also known as Dick Tak-Sang Chiu; (b) Ulla Schneider; (c) Paul Edward Kiley; and (d) George McMillan. Documents All original documents (and if originals are not available, then copies of those documents) in your possession, custody or control, including but not limited to: all files, correspondence, memoranda, notes, file notes, diary notes, letters, working papers, emails, text messages, instant messages, contracts, agreements, finance agreements, reports, applications forms, journals, security and charge documents, settlement statements, drawings, maps, plans, photographs, rental statements, receipts, quotations, invoices, deeds, Financial Records, Financial Reports, Financial Statements and any records of information, however compiled, recorded or stored and whether in physical or electronic form. Financial Records Any document (whether in draft or final form) that sets out or summarises any financial information including but not limited to: balance sheets and trial balance sheets, profit and loss statements, general ledgers and transaction ledgers (including cash ledgers, debtors' ledgers and creditors' ledgers), asset registers, stock records, depreciation schedules, books of account, bank account statements, credit card statements, deposit books, cheque butts, business activity statements, taxation returns and cash flow statements. Financial Reports Has the meaning attributed to those words in section 9 of the Act, being an annual financial report or a half-year financial report prepared under chapter 2M of the Act, including drafts. Financial Statements includes: (a) income statement; (b) balance sheet; (c) statement of cash flows; (d) statement of shareholders' equity; and (e) accompanying disclosures. Grant Thornton Grant Thornton Australia Limited (ACN 127 556 389) and includes any director, officer, employee or agent of Grant Thornton. Horizon Horizon Accounting Solutions Pty Ltd (ACN 659 810 689) and includes any director, officer, employee or agent of Horizon. Interest any legal, beneficial or equitable interest or estate of any kind whatsoever. ITR 2019 The Company's income tax return for the financial year ended 30 June 2019. Interhotel Finance Interhotel Finance Ltd (CR No. 1600801). Interhotel Finance Loan means the loan or advance from the Company to Interhotel Finance in the amount of $16,895,142.58 in or about 2018. person includes an individual, corporation, partnership or other organisation. Properties means, separately and or collectively, as the context requires: (a) the entirety of the land located at and known as 66 Myoora Road, Somersby NSW 2250, comprising Title Reference 20/859538; and/or (b) the entirety of the land located at and known as 945 Old Pacific Highway, Somersby NSW 2250 comprising Title References 204/747845, 205/747845, 206/747845 and 21/859538. Sale of the Properties means the sale of the Properties by the Company and Somersby to WCTV in 2018. See Accounting Group Central Coast Business Solutions Pty Ltd (ACN 143 040 779) trading as See Accounting Group and includes any director, officer, employee or agent of See Accounting Group. Somersby Somersby Property Pty Ltd (in liquidation) (ACN 089 634 220). Transactions includes: (a) a conveyance, transfer or other disposition of property; (b) a charge created on property; (c) a guarantee; (d) a payment made; (e) an obligation incurred; (f) a release or waiver; (g) a loan; and includes such a transaction that has been completed or given effect to, or that has terminated. WCTV World Cultural Tourism Village Pty Ltd (ACN 626 149 988). Written Communications Anything imparting information in both physical and or electronic means and includes, but is not limited to, letters, emails, SMS messages, messages through messaging applications (such as those transmitted over WhatsApp, WeChat, etc.) and social media platforms and notes.

The documents or things that you must produce are as follows: Books of the Company

1. Books of the Company, including any copies that differ in any way to the originals.
2. To the extent not covered by category 1 above, copies of any Documents, including Written Communications: (a) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Interhotel Finance (including, without limitation, the Interhotel Finance Loan and any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (b) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Classic Holdings (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (c) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, any of the Associated Entities (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the other Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (d) recording, referring to or otherwise discussing any loans or advances to or form, on one hand, the Company, and to or from, on the other hand, any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (e) purporting to be the source of, or the circumstances that gave rise to "management fees" or "licence fees" purportedly paid by the Company in the years ended 31 December 2015, 31 December 2016, 31 December 2017, 31 December 2018 and 31 December 2019 (and any earlier periods, if applicable), including but not limited to any management agreements, receipts and invoices; (f) to the extent not covered by paragraph (e) above, recording, referring to or otherwise discussing the payment of any "management fees" or "licence fees" by the Company; (g) recording, referring to or otherwise discussing any lease or sub-lease in respect of the Properties or any part thereof (whether entered into by the Company or any of the Associated Entities), including, without limitation, registered lease number 5864266 to Australian Reptile Park Pty Limited, including, without limitation, copies of any lease agreement, sub-lease agreement, and any variations thereto; (h) recording, referring to or otherwise discussing the payment of any rent (including any contribution to operating costs) in relation of the Properties (or any part thereof) (whether paid to the Company or any of the Related Parties); (i) purporting to be the source of, or the circumstances that gave rise to, the following payments from the Company's bank account with the description "P Kiley Part repayment of loan PKLoan": (i) payment of $9,000 dated 10 December 2019; (ii) payment of $9,000 dated 13 December 2019; and (iii) payment of $7,135 dated 20 December 2019. (j) recording, referring to or otherwise discussing the payment of any council rates, water rates, land tax, electricity or other operating costs in relation to the Properties; and (k) recording or relating to the appointment of George McMillan as director of the Company.
3. All Written Communications sent by or on behalf of the Company to, or received by the Company (or any of its directors, officers, employees or agents) from See Accounting Group, Jennie Hawkshaw or Horizon at any time since 1 January 2016. Sale of the Properties
4. All Documents, including Written Communications, referring or relating to the Sale of the Properties.
5. To the extent not covered by category 4 above, all Documents, including Written Communications, referring or relating to the payment and/or allocation of any amounts payable by or on behalf of WCTV in respect of the Sale of the Properties, including, without limitation, any direction to pay or settlement statement.
6. All Documents, including Written Communications, referring or relating to the ultimate destination of any amounts paid by or on behalf of WCTV in respect of the Sale of the Properties.
7. All Documents, including Written Communications, which record or evidence any directions or instructions given, by or on behalf of the Company to any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Properties (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, At any time since 1 November 2017.
8. All Documents, including Written Communications, recording or otherwise discussing any advice or recommendation given to the Company or to any other person by any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Property (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, At any time since 1 November 2017. Involvement of Stephen Geoffrey Linch
9. All Documents, including Written Communications, created, sent or received at any time since 1 January 2016, recording or evidencing any direction, instruction, advice or recommendation given by Stephen Geoffrey Linch in relation to the operation or management of the Company, the Sale of the Properties, the ITR 2019 and/or any of the Associated Entities.
10. To the extent not covered by category 9 above, all Written Communications sent by you to, or received by you from, Stephen Geoffrey Linch, at any time since 1 January 2016. Associated Entities
11. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to any of the Associated Entities by or on behalf of the Company at any time since 1 January 2016.
12. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from any of the Associated Entities to the Company at any time since 1 January 2016.
13. Financial Statements and Financial Reports prepared with respect to each of the Associated Entities (both on an individual basis and consolidated basis, if so prepared) created at any time since 1 January 2016.
14. To the extent not covered by categories 2(a) to (d) above, copies of all Documents, including Written Communications, recording, referring to or otherwise discussing any loans or advances between any of the Associated Entities, Interhotel Finance, Classic Holdings and/or any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto.
15. All Documents recording or evidencing any Interest that any of the Associated Entities has in any Asset (worldwide) with a market value of AUD $10,000 or more.
16. All tax returns prepared for or by any of the Associated Entities, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
17. Bank statements with respect to any Account in any of the Associated Entities' names, whether held singularly or jointly, created at any time since 1 January 2016.
18. All Documents, including Written Communications, recording or relating to the appointment of Kevin George McMillan as director of any of the Associated Entities.
19. Any Document, created at any time since 1 January 2011, recording a corporate group structure for Myoora, Interhotel Finance, the Associated Entities and any other related entities and/or affiliates of any of the aforementioned entities. Interhotel Finance
20. All Documents recording, created at any time since 1 January 2011, evidencing or otherwise discussing the directorship and/or ownership of Interhotel Finance (including, without limitation, the ultimate owner/s of Interhotel Finance).
21. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Interhotel Finance by or on behalf of the Company at any time since 1 January 2016.
22. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Interhotel Finance to the Company at any time since 1 January 2016.
23. Financial Statements and Financial Reports prepared with respect to Interhotel Finance created at any time since 1 January 2016.
24. All Documents recording or evidencing any Interest Interhotel Finance has in any Asset (worldwide) with a market value of AUD $10,000 or more.
25. All tax returns prepared for or by Interhotel Finance, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
26. Bank statements with respect to any Account in Interhotel Finance's name, whether held singularly or jointly, created at any time since 1 January 2016. Classic Holdings
27. All Documents, created at any time since 1 January 2011, recording, evidencing or otherwise discussing the directorship and/or ownership of Classic Holdings (including, without limitation, the ultimate owner/s of Classic Holdings).
28. All Documents recording, referring to or otherwise discussing the issuing, transferring or assignment of shares in the Company to Classic Holdings.
29. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Classic Holdings by or on behalf of the Company at any time since 1 January 2016.
30. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Classic Holdings to the Company at any time since 1 January 2016.
31. Financial Statements and Financial Reports prepared with respect of Classic Holdings created at any time since 1 January 2016.
32. All Documents recording or evidencing any Interest Classic Holdings has in any Asset (worldwide) with a market value of AUD $10,000 or more.
33. All tax returns prepared for or by Classic Holdings, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
34. Bank statements with respect to any Account in Classic Holding's name, whether held singularly or jointly, created at any time since 1 January 2016. Your Financial Position
35. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to you by the Company at any time since 1 January 2016.
36. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from you to the Company at any time since 1 January 2016.
37. All Documents recording or evidencing any Interest you have in any Asset with a market value of AUD $10,000 or more.
38. All tax returns prepared for or by you, whether lodged with the Australian Taxation Office or not and including any drafts, created at any time since 1 July 2019.
39. Bank statements with respect to any Account in your name, whether held singularly or jointly, created at any time since 1 December 2022.
40. All Documents, including Written Communications, recording or referring to any Australian visa issued to you. Order FEDERAL COURT OF AUSTRALIA No. NSD22/2023 District Registry: NEW SOUTH WALES DIVISION: GENERAL IN THE MATTER OF: MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) PETER KREJCI IN HIS CAPACITY AS LIQUIDATOR OF MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) Plaintiff Before: Rares J Where made: Sydney Date of Order: [x] May 2023 THE COURT ORDERS THAT: -
41. Pursuant to section 597(9) of the Corporations Act 2001 (Cth), Ulla Schneider attend before the Court for production of the documents and things specified in the schedule to these orders (Production Schedule) to the Federal Court of Australia, Law Courts Building, Queens Square, Sydney NSW at 9:30am Wednesday 28 June 2023.
42. In order to comply with Order 1, Ulla Schneider may, instead of attending before the Court on the date and time specified in Order 1, deliver or send the documents or things specified in the Production Schedule to the Court at the physical or email address below, so that they are received by the Court not less than 2 clear business days before the date specified in Order 1. The Registrar Federal Court of Australia Level 17, Law Courts Building Queens Square 184 Phillip Street Sydney NSW 2000 OR nswreg@fedcourt.gov.au
43. Ulla Schneider need not comply with these orders if the Plaintiff fails to serve, or cause to be served, a copy of these orders (including the Production Schedule) personally on Ms Schneider by 5:00pm 8 June 2023 (AEST). PRODUCTION SCHEDULE- ULLA SCHNEIDER Ulla Schneider, you must produce each of the documents mentioned below In this Schedule the following definitions apply: Defined Term Definition Accounts Any account, cheque account, loan account, credit card account, investment account, term deposit, cash management fund, on call deposit, insurance bond, investment insurance policy and trust account. Act Corporations Act 2001 (Cth). Associated Entities means the following entities: (h) Somersby Property Pty Limited (in liquidation) (ACN 089 634 220); (i) Warwick Amusements Pty Ltd (in liquidation) (ACN 002 276 217); (j) Five Continents Amusement Parks Pty Ltd (in liquidation) (ACN 002 995 066); (k) Warwick Hotels Pty Ltd (ACN 002 273 850); (l) Carnavon Shipping SA; (m) Warwick Holdings SA; and (n) Texon Investments Inc. Asset An asset of any description, including but not limited to real or personal property, whether tangible or intangible, present or future, vested or contingent, wherever situated, whether held beneficially or as trustee for a trust. Books Any Document, being: (e) a register; and (f) any other record or information; and (g) Financial Records, Financial Reports or Financial Statements; and (h) insurance policies. Classic Holdings Classic Holdings Ltd. Company Myoora Land Pty Limited (in liquidation) (ACN 089 634 131). Conditsis Lawyers Conditsis & Associates Pty Limited (ACN 114 761 410) trading as Conditsis Lawyers and includes any director, officer, employee or agent of Conditsis Lawyers. Crowe Horwath Findex Pty Ltd (ACN 006 466 351) formerly trading as Crowe Horwath and currently trading as Findex and includes any director, officer, employee or agent of Crowe Horwath. Directors includes all current and former directors of the Company: (e) Richard Chiu also known as Dick Tak-Sang Chiu; (f) Ulla Schneider; (g) Paul Edward Kiley; and (h) George McMillan. Documents All original documents (and if originals are not available, then copies of those documents) in your possession, custody or control, including but not limited to: all files, correspondence, memoranda, notes, file notes, diary notes, letters, working papers, emails, text messages, instant messages, contracts, agreements, finance agreements, reports, applications forms, journals, security and charge documents, settlement statements, drawings, maps, plans, photographs, rental statements, receipts, quotations, invoices, deeds, Financial Records, Financial Reports, Financial Statements and any records of information, however compiled, recorded or stored and whether in physical or electronic form. Financial Records Any document (whether in draft or final form) that sets out or summarises any financial information including but not limited to: balance sheets and trial balance sheets, profit and loss statements, general ledgers and transaction ledgers (including cash ledgers, debtors' ledgers and creditors' ledgers), asset registers, stock records, depreciation schedules, books of account, bank account statements, credit card statements, deposit books, cheque butts, business activity statements, taxation returns and cash flow statements. Financial Reports Has the meaning attributed to those words in section 9 of the Act, being an annual financial report or a half-year financial report prepared under chapter 2M of the Act, including drafts. Financial Statements includes: (a) income statement; (b) balance sheet; (c) statement of cash flows; (d) statement of shareholders' equity; and (e) accompanying disclosures. Grant Thornton Grant Thornton Australia Limited (ACN 127 556 389) and includes any director, officer, employee or agent of Grant Thornton. Horizon Horizon Accounting Solutions Pty Ltd (ACN 659 810 689) and includes any director, officer, employee or agent of Horizon. Interest any legal, beneficial or equitable interest or estate of any kind whatsoever. ITR 2019 The Company's income tax return for the financial year ended 30 June 2019. Interhotel Finance Interhotel Finance Ltd (CR No. 1600801). Interhotel Finance Loan means the loan or advance from the Company to Interhotel Finance in the amount of $16,895,142.58 in or about 2018. person includes an individual, corporation, partnership or other organisation. Properties means, separately and or collectively, as the context requires: (c) the entirety of the land located at and known as 66 Myoora Road, Somersby NSW 2250, comprising Title Reference 20/859538; and/or (d) the entirety of the land located at and known as 945 Old Pacific Highway, Somersby NSW 2250 comprising Title References 204/747845, 205/747845, 206/747845 and 21/859538. Sale of the Properties means the sale of the Properties by the Company and Somersby to WCTV in 2018. See Accounting Group Central Coast Business Solutions Pty Ltd (ACN 143 040 779) trading as See Accounting Group and includes any director, officer, employee or agent of See Accounting Group. Somersby Somersby Property Pty Ltd (in liquidation) (ACN 089 634 220). Transactions includes: (a) a conveyance, transfer or other disposition of property; (b) a charge created on property; (c) a guarantee; (d) a payment made; (e) an obligation incurred; (f) a release or waiver; (g) a loan; and includes such a transaction that has been completed or given effect to, or that has terminated. WCTV World Cultural Tourism Village Pty Ltd (ACN 626 149 988).

The documents or things that you must produce are as follows: Books of the Company

1. Books of the Company, including any copies that differ in any way to the originals.
2. To the extent not covered by category 1 above, copies of any Documents, including Written Communications: (a) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Interhotel Finance (including, without limitation, the Interhotel Finance Loan and any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (b) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Classic Holdings (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (c) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, any of the Associated Entities (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the other Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (d) recording, referring to or otherwise discussing any loans or advances to or form, on one hand, the Company, and to or from, on the other hand, any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (e) purporting to be the source of, or the circumstances that gave rise to "management fees" or "licence fees" purportedly paid by the Company in the years ended 31 December 2015, 31 December 2016, 31 December 2017, 31 December 2018 and 31 December 2019 (and any earlier periods, if applicable), including but not limited to any management agreements, receipts and invoices; (f) to the extent not covered by paragraph (e) above, recording, referring to or otherwise discussing the payment of any "management fees" or "licence fees" by the Company; (g) recording, referring to or otherwise discussing any lease or sub-lease in respect of the Properties or any part thereof (whether entered into by the Company or any of the Associated Entities), including, without limitation, registered lease number 5864266 to Australian Reptile Park Pty Limited, including, without limitation, copies of any lease agreement, sub-lease agreement, and any variations thereto; (h) recording, referring to or otherwise discussing the payment of any rent (including any contribution to operating costs) in relation of the Properties (or any part thereof) (whether paid to the Company or any of the Related Parties); (i) purporting to be the source of, or the circumstances that gave rise to, the following payments from the Company's bank account with the description "P Kiley Part repayment of loan PKLoan": (iv) payment of $9,000 dated 10 December 2019; (v) payment of $9,000 dated 13 December 2019; and (vi) payment of $7,135 dated 20 December 2019. (j) recording, referring to or otherwise discussing the payment of any council rates, water rates, land tax, electricity or other operating costs in relation to the Properties; and (k) recording or relating to the appointment of George McMillan as director of the Company.
3. All Written Communications sent by or on behalf of the Company to, or received by the Company (or any of its directors, officers, employees or agents) from See Accounting Group, Jennie Hawkshaw or Horizon at any time since 1 January 2016. Sale of the Properties
4. All Documents, including Written Communications, referring or relating to the Sale of the Properties.
5. To the extent not covered by category 4 above, all Documents, including Written Communications, referring or relating to the payment and/or allocation of any amounts payable by or on behalf of WCTV in respect of the Sale of the Properties, including, without limitation, any direction to pay or settlement statement.
6. All Documents, including Written Communications, referring or relating to the ultimate destination of any amounts paid by or on behalf of WCTV in respect of the Sale of the Properties.
7. All Documents, including Written Communications, which record or evidence any directions or instructions given, by or on behalf of the Company to any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Properties (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017.
8. All Documents, including Written Communications, recording or otherwise discussing any advice or recommendation given to the Company or to any other person by any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Property (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017. Involvement of Stephen Geoffrey Linch
9. All Documents, including Written Communications, created, sent or received at any time since 1 January 2016, recording or evidencing any direction, instruction, advice or recommendation given by Stephen Geoffrey Linch in relation to the operation or management of the Company, the Sale of the Properties, the ITR 2019 and/or any of the Associated Entities.
10. To the extent not covered by category 9 above, all Written Communications sent by you to, or received by you from, Stephen Geoffrey Linch, at any time since 1 January 2016. Associated Entities
11. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to any of the Associated Entities by or on behalf of the Company at any time since 1 January 2016.
12. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from any of the Associated Entities to the Company at any time since 1 January 2016.
13. Financial Statements and Financial Reports prepared with respect to each of the Associated Entities (both on an individual basis and consolidated basis, if so prepared) created at any time since 1 January 2016.
14. To the extent not covered by categories 2(a) to (d) above, copies of all Documents, including Written Communications, recording, referring to or otherwise discussing any loans or advances between any of the Associated Entities, Interhotel Finance, Classic Holdings and/or any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto.
15. All Documents recording or evidencing any Interest that any of the Associated Entities has in any Asset (worldwide) with a market value of AUD $10,000 or more.
16. All tax returns prepared for or by any of the Associated Entities, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
17. Bank statements with respect to any Account in any of the Associated Entities' names, whether held singularly or jointly, created at any time since 1 January 2016.
18. All Documents, including Written Communications, recording or relating to the appointment of Kevin George McMillan as director of any of the Associated Entities.
19. Any Document, created at any time since 1 January 2011, recording a corporate group structure for Myoora, Interhotel Finance, the Associated Entities and any other related entities and/or affiliates of any of the aforementioned entities. Interhotel Finance
20. All Documents recording, created at any time since 1 January 2011, evidencing or otherwise discussing the directorship and/or ownership of Interhotel Finance (including, without limitation, the ultimate owner/s of Interhotel Finance).
21. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Interhotel Finance by or on behalf of the Company at any time since 1 January 2016.
22. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Interhotel Finance to the Company at any time since 1 January 2016.
23. Financial Statements and Financial Reports prepared with respect to Interhotel Finance created at any time since 1 January 2016.
24. All Documents recording or evidencing any Interest Interhotel Finance has in any Asset (worldwide) with a market value of AUD $10,000 or more.
25. All tax returns prepared for or by Interhotel Finance, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
26. Bank statements with respect to any Account in Interhotel Finance's name, whether held singularly or jointly, created at any time since 1 January 2016. Classic Holdings
27. All Documents, created at any time since 1 January 2011, recording, evidencing or otherwise discussing the directorship and/or ownership of Classic Holdings (including, without limitation, the ultimate owner/s of Classic Holdings).
28. All Documents recording, referring to or otherwise discussing the issuing, transferring or assignment of shares in the Company to Classic Holdings.
29. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Classic Holdings by or on behalf of the Company at any time since 1 January 2016.
30. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Classic Holdings to the Company at any time since 1 January 2016.
31. Financial Statements and Financial Reports prepared with respect of Classic Holdings created at any time since 1 January 2016.
32. All Documents recording or evidencing any Interest Classic Holdings has in any Asset (worldwide) with a market value of AUD $10,000 or more.
33. All tax returns prepared for or by Classic Holdings, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
34. Bank statements with respect to any Account in Classic Holding's name, whether held singularly or jointly, created at any time since 1 January 2016. Your Financial Position
35. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to you by the Company at any time since 1 January 2016.
36. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from you to the Company at any time since 1 January 2016.
37. All Documents recording or evidencing any Interest you have in any Asset with a market value of AUD $10,000 or more.
38. All tax returns prepared for or by you, whether lodged with the Australian Taxation Office or not and including any drafts, created at any time since 1 July 2019.
39. Bank statements with respect to any Account in your name, whether held singularly or jointly, created at any time since 1 December 2022.
40. All Documents, including Written Communications, recording or referring to any Australian visa issued to you. Order FEDERAL COURT OF AUSTRALIA No. NSD22/203 District Registry: NEW SOUTH WALES DIVISION: GENERAL IN THE MATTER OF: MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) PETER KREJCI IN HIS CAPACITY AS LIQUIDATOR OF MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) Plaintiff Before: Rares J Where made: Sydney Date of Order: [x] May 2023 THE COURT ORDERS THAT: -
41. Pursuant to section 597(9) of the Corporations Act 2001 (Cth), Stephen Geoffrey Linch attend before the Court for production of the documents and things specified in the schedule to these orders (Production Schedule) to the Federal Court of Australia, Law Courts Building, Queens Square, Sydney NSW at 9:30am Wednesday 28 June 2023.
42. In order to comply with Order 1, Stephen Geoffrey Linch may, instead of attending before the Court on the date and time specified in Order 1, deliver or send the documents or things specified in the Production Schedule to the Court at the physical or email address below, so that they are received by the Court not less than 2 clear business days before the date specified in Order 1. The Registrar Federal Court of Australia Level 17, Law Courts Building Queens Square 184 Phillip Street Sydney NSW 2000 OR nswreg@fedcourt.gov.au
43. Stephen Geoffrey Linch need not comply with these orders if the Plaintiff fails to serve, or cause to be served, a copy of these orders (including the Production Schedule) personally on Mr Chiu by 5:00pm 8 June 2023 (AEST). PRODUCTION SCHEDULE- STEPHEN GEOFFREY LINCH Stephen Geoffrey Linch, you must produce each of the documents mentioned below: In this Schedule the following definitions apply: Defined Term Definition Accounts Any account, cheque account, loan account, credit card account, investment account, term deposit, cash management fund, on call deposit, insurance bond, investment insurance policy and trust account. Act Corporations Act 2001 (Cth). Associated Entities means the following entities: (o) Somersby Property Pty Limited (in liquidation) (ACN 089 634 220); (p) Warwick Amusements Pty Ltd (in liquidation) (ACN 002 276 217); (q) Five Continents Amusement Parks Pty Ltd (in liquidation) (ACN 002 995 066); (r) Warwick Hotels Pty Ltd (ACN 002 273 850); (s) Carnavon Shipping SA; (t) Warwick Holdings SA; and (u) Texon Investments Inc. Asset An asset of any description, including but not limited to real or personal property, whether tangible or intangible, present or future, vested or contingent, wherever situated, whether held beneficially or as trustee for a trust. Books Any Document, being: (i) a register; and (j) any other record or information; and (k) Financial Records, Financial Reports or Financial Statements; and (l) insurance policies. Classic Holdings Classic Holdings Ltd. Company Myoora Land Pty Limited (in liquidation) (ACN 089 634 131). Conditsis Lawyers Conditsis & Associates Pty Limited (ACN 114 761 410) trading as Conditsis Lawyers and includes any director, officer, employee or agent of Conditsis Lawyers. Crowe Horwath Findex Pty Ltd (ACN 006 466 351) formerly trading as Crowe Horwath and currently trading as Findex and includes any director, officer, employee or agent of Crowe Horwath. Directors includes all current and former directors of the Company: (i) Richard Chiu also known as Dick Tak-Sang Chiu; (j) Ulla Schneider; (k) Paul Edward Kiley; and (l) George McMillan. Documents All original documents (and if originals are not available, then copies of those documents) in your possession, custody or control, including but not limited to: all files, correspondence, memoranda, notes, file notes, diary notes, letters, working papers, emails, text messages, instant messages, contracts, agreements, finance agreements, reports, applications forms, journals, security and charge documents, settlement statements, drawings, maps, plans, photographs, rental statements, receipts, quotations, invoices, deeds, Financial Records, Financial Reports, Financial Statements and any records of information, however compiled, recorded or stored and whether in physical or electronic form. Financial Records Any document (whether in draft or final form) that sets out or summarises any financial information including but not limited to: balance sheets and trial balance sheets, profit and loss statements, general ledgers and transaction ledgers (including cash ledgers, debtors' ledgers and creditors' ledgers), asset registers, stock records, depreciation schedules, books of account, bank account statements, credit card statements, deposit books, cheque butts, business activity statements, taxation returns and cash flow statements. Financial Reports Has the meaning attributed to those words in section 9 of the Act, being an annual financial report or a half-year financial report prepared under chapter 2M of the Act, including drafts. Financial Statements includes: (a) income statement; (b) balance sheet; (c) statement of cash flows; (d) statement of shareholders' equity; and (e) accompanying disclosures. Grant Thornton Grant Thornton Australia Limited (ACN 127 556 389) and includes any director, officer, employee or agent of Grant Thornton. Horizon Horizon Accounting Solutions Pty Ltd (ACN 659 810 689) and includes any director, officer, employee or agent of Horizon. Interest any legal, beneficial or equitable interest or estate of any kind whatsoever. ITR 2019 The Company's income tax return for the financial year ended 30 June 2019. Interhotel Finance Interhotel Finance Ltd (CR No. 1600801). Interhotel Finance Loan means the loan or advance from the Company to Interhotel Finance in the amount of $16,895,142.58 in or about 2018. person includes an individual, corporation, partnership or other organisation. Properties means, separately and or collectively, as the context requires: (e) the entirety of the land located at and known as 66 Myoora Road, Somersby NSW 2250, comprising Title Reference 20/859538; and/or (f) the entirety of the land located at and known as 945 Old Pacific Highway, Somersby NSW 2250 comprising Title References 204/747845, 205/747845, 206/747845 and 21/859538. Sale of the Properties means the sale of the Properties by the Company and Somersby to WCTV in 2018. See Accounting Group Central Coast Business Solutions Pty Ltd (ACN 143 040 779) trading as See Accounting Group and includes any director, officer, employee or agent of See Accounting Group. Somersby Somersby Property Pty Ltd (in liquidation) (ACN 089 634 220). Transactions includes: (a) a conveyance, transfer or other disposition of property; (b) a charge created on property; (c) a guarantee; (d) a payment made; (e) an obligation incurred; (f) a release or waiver; (g) a loan; and includes such a transaction that has been completed or given effect to, or that has terminated. WCTV World Cultural Tourism Village Pty Ltd (ACN 626 149 988). Written Communications Anything imparting information in both physical and or electronic means and includes, but is not limited to, letters, emails, SMS messages, messages through messaging applications (such as those transmitted over WhatsApp, WeChat, etc.) and social media platforms and notes.

The documents or things that you must produce are as follows: Books of the Company

1. Books of the Company, including any copies that differ in any way to the originals.
2. To the extent not covered by category 1 above, copies of any Documents, including Written Communications: (a) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Interhotel Finance (including, without limitation, the Interhotel Finance Loan and any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (b) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Classic Holdings (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (c) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, any of the Associated Entities (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the other Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (d) recording, referring to or otherwise discussing any loans or advances to or form, on one hand, the Company, and to or from, on the other hand, any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (e) purporting to be the source of, or the circumstances that gave rise to "management fees" or "licence fees" purportedly paid by the Company in the years ended 31 December 2015, 31 December 2016, 31 December 2017, 31 December 2018 and 31 December 2019 (and any earlier periods, if applicable), including but not limited to any management agreements, receipts and invoices; (f) to the extent not covered by paragraph (e) above, recording, referring to or otherwise discussing the payment of any "management fees" or "licence fees" by the Company; (g) recording, referring to or otherwise discussing any lease or sub-lease in respect of the Properties or any part thereof (whether entered into by the Company or any of the Associated Entities), including, without limitation, registered lease number 5864266 to Australian Reptile Park Pty Limited, including, without limitation, copies of any lease agreement, sub-lease agreement, and any variations thereto; (h) recording, referring to or otherwise discussing the payment of any rent (including any contribution to operating costs) in relation of the Properties (or any part thereof) (whether paid to the Company or any of the Related Parties); (i) purporting to be the source of, or the circumstances that gave rise to, the following payments from the Company's bank account with the description "P Kiley Part repayment of loan PKLoan": (vii) payment of $9,000 dated 10 December 2019; (viii) payment of $9,000 dated 13 December 2019; and (ix) payment of $7,135 dated 20 December 2019. (j) recording, referring to or otherwise discussing the payment of any council rates, water rates, land tax, electricity or other operating costs in relation to the Properties; and (k) recording or relating to the appointment of George McMillan as director of the Company.
3. All Written Communications sent by or on behalf of the Company to, or received by the Company (or any of its directors, officers, employees or agents) from See Accounting Group, Jennie Hawkshaw or Horizon at any time since 1 January 2016. Sale of the Properties
4. All Documents, including Written Communications, referring or relating to the Sale of the Properties.
5. To the extent not covered by category 4 above, all Documents, including Written Communications, referring or relating to the payment and/or allocation of any amounts payable by or on behalf of WCTV in respect of the Sale of the Properties, including, without limitation, any direction to pay or settlement statement.
6. All Documents, including Written Communications, referring or relating to the ultimate destination of any amounts paid by or on behalf of WCTV in respect of the Sale of the Properties.
7. All Documents, including Written Communications, which record or evidence any directions or instructions given, by or on behalf of the Company to any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Properties (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017.
8. All Documents, including Written Communications, recording or otherwise discussing any advice or recommendation given to the Company or to any other person by any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Property (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017. Involvement of Stephen Geoffrey Linch
9. All Documents, including Written Communications, created, sent or received at any time since 1 January 2016, recording or evidencing any direction, instruction, advice or recommendation given by you in relation to the operation or management of the Company, the Sale of the Properties, the ITR 2019 and/or any of the Associated Entities.
10. To the extent not covered by category 9 above, all Written Communications sent by you to, or received by you to, or received by you from, any of the following: a. Any of the Directors; b. See Accounting Group; c. Jennie Hawkshaw; d. Horizon; e. Grant Thornton; f. Crowe Horwath; g. Conditsis Lawyers; h. Kevin George McMillan, At any time since 1 January 2016 Associated Entities
11. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to any of the Associated Entities by or on behalf of the Company at any time since 1 January 2016.
12. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from any of the Associated Entities to the Company at any time since 1 January 2016.
13. Financial Statements and Financial Reports prepared with respect to each of the Associated Entities (both on an individual basis and consolidated basis, if so prepared) created at any time since 1 January 2016.
14. To the extent not covered by categories 2(a) to (d) above, copies of all Documents, including Written Communications, recording, referring to or otherwise discussing any loans or advances between any of the Associated Entities, Interhotel Finance, Classic Holdings and/or any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto.
15. All Documents recording or evidencing any Interest that any of the Associated Entities has in any Asset (worldwide) with a market value of AUD $10,000 or more.
16. All tax returns prepared for or by any of the Associated Entities, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
17. Bank statements with respect to any Account in any of the Associated Entities' names, whether held singularly or jointly, created at any time since 1 January 2016.
18. All Documents, including Written Communications, recording or relating to the appointment of Kevin George McMillan as director of any of the Associated Entities.
19. Any Document, created at any time since 1 January 2011, recording a corporate group structure for Myoora, Interhotel Finance, the Associated Entities and any other related entities and/or affiliates of any of the aforementioned entities. Interhotel Finance
20. All Documents recording, created at any time since 1 January 2011, evidencing or otherwise discussing the directorship and/or ownership of Interhotel Finance (including, without limitation, the ultimate owner/s of Interhotel Finance).
21. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Interhotel Finance by or on behalf of the Company at any time since 1 January 2016.
22. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Interhotel Finance to the Company at any time since 1 January 2016.
23. Financial Statements and Financial Reports prepared with respect to Interhotel Finance created at any time since 1 January 2016.
24. All Documents recording or evidencing any Interest Interhotel Finance has in any Asset (worldwide) with a market value of AUD $10,000 or more.
25. All tax returns prepared for or by Interhotel Finance, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
26. Bank statements with respect to any Account in Interhotel Finance's name, whether held singularly or jointly, created at any time since 1 January 2016. Classic Holdings
27. All Documents, created at any time since 1 January 2011, recording, evidencing or otherwise discussing the directorship and/or ownership of Classic Holdings (including, without limitation, the ultimate owner/s of Classic Holdings).
28. All Documents recording, referring to or otherwise discussing the issuing, transferring or assignment of shares in the Company to Classic Holdings.
29. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Classic Holdings by or on behalf of the Company at any time since 1 January 2016.
30. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Classic Holdings to the Company at any time since 1 January 2016.
31. Financial Statements and Financial Reports prepared with respect of Classic Holdings created at any time since 1 January 2016.
32. All Documents recording or evidencing any Interest Classic Holdings has in any Asset (worldwide) with a market value of AUD $10,000 or more.
33. All tax returns prepared for or by Classic Holdings, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
34. Bank statements with respect to any Account in Classic Holding's name, whether held singularly or jointly, created at any time since 1 January 2016. Your Financial Position
35. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to you by the Company at any time since 1 January 2016.
36. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from you to the Company at any time since 1 January 2016.
37. All Documents recording or evidencing any Interest you have in any Asset with a market value of AUD $10,000 or more.
38. All tax returns prepared for or by you, whether lodged with the Australian Taxation Office or not and including any drafts, created at any time since 1 July 2019.
39. Bank statements with respect to any Account in your name, whether held singularly or jointly, created at any time since 1 December 2022.
40. All Documents, including Written Communications, recording or referring to any Australian visa issued to you. Order FEDERAL COURT OF AUSTRALIA No. NSD22/2023 District Registry: NEW SOUTH WALES DIVISION: GENERAL IN THE MATTER OF: MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) PETER KREJCI IN HIS CAPACITY AS LIQUIDATOR OF MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) Plaintiff Before: Rares J Where made: Sydney Date of Order: [x] May 2023 THE COURT ORDERS THAT: -
41. Pursuant to section 597(9) of the Corporations Act 2001 (Cth), Clare Annabelle Chiu, attend before the Court for production of the documents and things specified in the schedule to these orders (Production Schedule) to the Federal Court of Australia, Law Courts Building, Queens Square, Sydney NSW at 9:30am Wednesday 28 June 2023.
42. In order to comply with Order 1, Clare Annabelle Chiu may, instead of attending before the Court on the date and time specified in Order 1, deliver or send the documents or things specified in the Production Schedule to the Court at the physical or email address below, so that they are received by the Court not less than 2 clear business days before the date specified in Order 1. The Registrar Federal Court of Australia Level 17, Law Courts Building Queens Square 184 Phillip Street Sydney NSW 2000 OR nswreg@fedcourt.gov.au
43. Clare Annabelle Chiu need not comply with these orders if the Plaintiff fails to serve, or cause to be served, a copy of these orders (including the Production Schedule) personally on Ms Chiu by 5:00pm 8 June 2023 (AEST). Production Schedule- CLARE ANNABELLE CHIU Clare Annabelle Chiu, you must produce each of the documents mentioned below: In this Schedule the following definitions apply: Defined Term Definition Accounts Any account, cheque account, loan account, credit card account, investment account, term deposit, cash management fund, on call deposit, insurance bond, investment insurance policy and trust account. Act Corporations Act 2001 (Cth). Associated Entities means the following entities: (v) Somersby Property Pty Limited (in liquidation) (ACN 089 634 220); (w) Warwick Amusements Pty Ltd (in liquidation) (ACN 002 276 217); (x) Five Continents Amusement Parks Pty Ltd (in liquidation) (ACN 002 995 066); (y) Warwick Hotels Pty Ltd (ACN 002 273 850); (z) Carnavon Shipping SA; (aa) Warwick Holdings SA; and (bb) Texon Investments Inc. Asset An asset of any description, including but not limited to real or personal property, whether tangible or intangible, present or future, vested or contingent, wherever situated, whether held beneficially or as trustee for a trust. Books Any Document, being: (m) a register; and (n) any other record or information; and (o) Financial Records, Financial Reports or Financial Statements; and (p) insurance policies. Classic Holdings Classic Holdings Ltd. Company Myoora Land Pty Limited (in liquidation) (ACN 089 634 131). Conditsis Lawyers Conditsis & Associates Pty Limited (ACN 114 761 410) trading as Conditsis Lawyers and includes any director, officer, employee or agent of Conditsis Lawyers. Crowe Horwath Findex Pty Ltd (ACN 006 466 351) formerly trading as Crowe Horwath and currently trading as Findex and includes any director, officer, employee or agent of Crowe Horwath. Directors includes all current and former directors of the Company: (m) Richard Chiu also known as Dick Tak-Sang Chiu; (n) Ulla Schneider; (o) Paul Edward Kiley; and (p) George McMillan. Documents All original documents (and if originals are not available, then copies of those documents) in your possession, custody or control, including but not limited to: all files, correspondence, memoranda, notes, file notes, diary notes, letters, working papers, emails, text messages, instant messages, contracts, agreements, finance agreements, reports, applications forms, journals, security and charge documents, settlement statements, drawings, maps, plans, photographs, rental statements, receipts, quotations, invoices, deeds, Financial Records, Financial Reports, Financial Statements and any records of information, however compiled, recorded or stored and whether in physical or electronic form. Financial Records Any document (whether in draft or final form) that sets out or summarises any financial information including but not limited to: balance sheets and trial balance sheets, profit and loss statements, general ledgers and transaction ledgers (including cash ledgers, debtors' ledgers and creditors' ledgers), asset registers, stock records, depreciation schedules, books of account, bank account statements, credit card statements, deposit books, cheque butts, business activity statements, taxation returns and cash flow statements. Financial Reports Has the meaning attributed to those words in section 9 of the Act, being an annual financial report or a half-year financial report prepared under chapter 2M of the Act, including drafts. Financial Statements includes: (a) income statement; (b) balance sheet; (c) statement of cash flows; (d) statement of shareholders' equity; and (e) accompanying disclosures. Grant Thornton Grant Thornton Australia Limited (ACN 127 556 389) and includes any director, officer, employee or agent of Grant Thornton. Horizon Horizon Accounting Solutions Pty Ltd (ACN 659 810 689) and includes any director, officer, employee or agent of Horizon. Interest any legal, beneficial or equitable interest or estate of any kind whatsoever. ITR 2019 The Company's income tax return for the financial year ended 30 June 2019. Interhotel Finance Interhotel Finance Ltd (CR No. 1600801). Interhotel Finance Loan means the loan or advance from the Company to Interhotel Finance in the amount of $16,895,142.58 in or about 2018. person includes an individual, corporation, partnership or other organisation. Properties means, separately and or collectively, as the context requires: (g) the entirety of the land located at and known as 66 Myoora Road, Somersby NSW 2250, comprising Title Reference 20/859538; and/or (h) the entirety of the land located at and known as 945 Old Pacific Highway, Somersby NSW 2250 comprising Title References 204/747845, 205/747845, 206/747845 and 21/859538. Sale of the Properties means the sale of the Properties by the Company and Somersby to WCTV in 2018. See Accounting Group Central Coast Business Solutions Pty Ltd (ACN 143 040 779) trading as See Accounting Group and includes any director, officer, employee or agent of See Accounting Group. Somersby Somersby Property Pty Ltd (in liquidation) (ACN 089 634 220). Transactions includes: (a) a conveyance, transfer or other disposition of property; (b) a charge created on property; (c) a guarantee; (d) a payment made; (e) an obligation incurred; (f) a release or waiver; (g) a loan; and includes such a transaction that has been completed or given effect to, or that has terminated. WCTV World Cultural Tourism Village Pty Ltd (ACN 626 149 988). Written Communications Anything imparting information in both physical and or electronic means and includes, but is not limited to, letters, emails, SMS messages, messages through messaging applications (such as those transmitted over WhatsApp, WeChat, etc.) and social media platforms and notes.

The documents or things that you must produce are as follows: Books of the Company

1. Books of the Company, including any copies that differ in any way to the originals.
2. To the extent not covered by category 1 above, copies of any Documents, including Written Communications: (a) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Interhotel Finance (including, without limitation, the Interhotel Finance Loan and any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (b) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Classic Holdings (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (c) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, any of the Associated Entities (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the other Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (d) recording, referring to or otherwise discussing any loans or advances to or form, on one hand, the Company, and to or from, on the other hand, any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (e) purporting to be the source of, or the circumstances that gave rise to "management fees" or "licence fees" purportedly paid by the Company in the years ended 31 December 2015, 31 December 2016, 31 December 2017, 31 December 2018 and 31 December 2019 (and any earlier periods, if applicable), including but not limited to any management agreements, receipts and invoices; (f) to the extent not covered by paragraph (e) above, recording, referring to or otherwise discussing the payment of any "management fees" or "licence fees" by the Company; (g) recording, referring to or otherwise discussing any lease or sub-lease in respect of the Properties or any part thereof (whether entered into by the Company or any of the Associated Entities), including, without limitation, registered lease number 5864266 to Australian Reptile Park Pty Limited, including, without limitation, copies of any lease agreement, sub-lease agreement, and any variations thereto; (h) recording, referring to or otherwise discussing the payment of any rent (including any contribution to operating costs) in relation of the Properties (or any part thereof) (whether paid to the Company or any of the Related Parties); (i) purporting to be the source of, or the circumstances that gave rise to, the following payments from the Company's bank account with the description "P Kiley Part repayment of loan PKLoan": (x) payment of $9,000 dated 10 December 2019; (xi) payment of $9,000 dated 13 December 2019; and (xii) payment of $7,135 dated 20 December 2019. (j) recording, referring to or otherwise discussing the payment of any council rates, water rates, land tax, electricity or other operating costs in relation to the Properties; and (k) recording or relating to the appointment of George McMillan as director of the Company.
3. All Written Communications sent by or on behalf of the Company to, or received by the Company (or any of its directors, officers, employees or agents) from See Accounting Group, Jennie Hawkshaw or Horizon at any time since 1 January 2016. Sale of the Properties
4. All Documents, including Written Communications, referring or relating to the Sale of the Properties.
5. To the extent not covered by category 4 above, all Documents, including Written Communications, referring or relating to the payment and/or allocation of any amounts payable by or on behalf of WCTV in respect of the Sale of the Properties, including, without limitation, any direction to pay or settlement statement.
6. All Documents, including Written Communications, referring or relating to the ultimate destination of any amounts paid by or on behalf of WCTV in respect of the Sale of the Properties.
7. All Documents, including Written Communications, which record or evidence any directions or instructions given, by or on behalf of the Company to any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Properties (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017.
8. All Documents, including Written Communications, recording or otherwise discussing any advice or recommendation given to the Company or to any other person by any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Property (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017. Involvement of Stephen Geoffrey Linch
9. All Documents, including Written Communications, created, sent or received at any time since 1 January 2016, recording or evidencing any direction, instruction, advice or recommendation given by Stephen Geoffrey Linch in relation to the operation or management of the Company, the Sale of the Properties, the ITR 2019 and/or any of the Associated Entities.
10. To the extent not covered by category 9 above, all Written Communications sent by you to, or received by you from, Stephen Geoffrey Linch, at any time since 1 January 2016. Associated Entities
11. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to any of the Associated Entities by or on behalf of the Company at any time since 1 January 2016.
12. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from any of the Associated Entities to the Company at any time since 1 January 2016.
13. Financial Statements and Financial Reports prepared with respect to each of the Associated Entities (both on an individual basis and consolidated basis, if so prepared) created at any time since 1 January 2016.
14. To the extent not covered by categories 2(a) to (d) above, copies of all Documents, including Written Communications, recording, referring to or otherwise discussing any loans or advances between any of the Associated Entities, Interhotel Finance, Classic Holdings and/or any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto.
15. All Documents recording or evidencing any Interest that any of the Associated Entities has in any Asset (worldwide) with a market value of AUD $10,000 or more.
16. All tax returns prepared for or by any of the Associated Entities, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
17. Bank statements with respect to any Account in any of the Associated Entities' names, whether held singularly or jointly, created at any time since 1 January 2016.
18. All Documents, including Written Communications, recording or relating to the appointment of Kevin George McMillan as director of any of the Associated Entities.
19. Any Document, created at any time since 1 January 2011, recording a corporate group structure for Myoora, Interhotel Finance, the Associated Entities and any other related entities and/or affiliates of any of the aforementioned entities. Interhotel Finance
20. All Documents recording, created at any time since 1 January 2011, evidencing or otherwise discussing the directorship and/or ownership of Interhotel Finance (including, without limitation, the ultimate owner/s of Interhotel Finance).
21. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Interhotel Finance by or on behalf of the Company at any time since 1 January 2016.
22. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Interhotel Finance to the Company at any time since 1 January 2016.
23. Financial Statements and Financial Reports prepared with respect to Interhotel Finance created at any time since 1 January 2016.
24. All Documents recording or evidencing any Interest Interhotel Finance has in any Asset (worldwide) with a market value of AUD $10,000 or more.
25. All tax returns prepared for or by Interhotel Finance, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
26. Bank statements with respect to any Account in Interhotel Finance's name, whether held singularly or jointly, created at any time since 1 January 2016. Classic Holdings
27. All Documents, created at any time since 1 January 2011, recording, evidencing or otherwise discussing the directorship and/or ownership of Classic Holdings (including, without limitation, the ultimate owner/s of Classic Holdings).
28. All Documents recording, referring to or otherwise discussing the issuing, transferring or assignment of shares in the Company to Classic Holdings.
29. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Classic Holdings by or on behalf of the Company at any time since 1 January 2016.
30. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Classic Holdings to the Company at any time since 1 January 2016.
31. Financial Statements and Financial Reports prepared with respect of Classic Holdings created at any time since 1 January 2016.
32. All Documents recording or evidencing any Interest Classic Holdings has in any Asset (worldwide) with a market value of AUD $10,000 or more.
33. All tax returns prepared for or by Classic Holdings, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
34. Bank statements with respect to any Account in Classic Holding's name, whether held singularly or jointly, created at any time since 1 January 2016. Your Financial Position
35. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to you by the Company at any time since 1 January 2016.
36. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from you to the Company at any time since 1 January 2016.
37. All Documents recording or evidencing any Interest you have in any Asset with a market value of AUD $10,000 or more.
38. All tax returns prepared for or by you, whether lodged with the Australian Taxation Office or not and including any drafts, created at any time since 1 July 2019.
39. Bank statements with respect to any Account in your name, whether held singularly or jointly, created at any time since 1 December 2022.
40. All Documents, including Written Communications, recording or referring to any Australian visa issued to you. Order FEDERAL COURT OF AUSTRALIA No. NSD District Registry: NEW SOUTH WALES DIVISION: GENERAL IN THE MATTER OF: MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) PETER KREJCI IN HIS CAPACITY AS LIQUIDATOR OF MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) Plaintiff Before: Rares J Where made: Sydney Date of Order: [x] May 2023 THE COURT ORDERS THAT: -
41. Pursuant to section 597(9) of the Corporations Act 2001 (Cth), Warren Chiu attend before the Court for production of the documents and things specified in the schedule to these orders (Production Schedule) to the Federal Court of Australia, Law Courts Building, Queens Square, Sydney NSW at 9:30am Wednesday 28 June 2023.
42. In order to comply with Order 1, Warren Chiu may, instead of attending before the Court on the date and time specified in Order 1, deliver or send the documents or things specified in the Production Schedule to the Court at the physical or email address below, so that they are received by the Court not less than 2 clear business days before the date specified in Order 1. The Registrar Federal Court of Australia Level 17, Law Courts Building Queens Square 184 Phillip Street Sydney NSW 2000 OR nswreg@fedcourt.gov.au
43. Warren Chiu need not comply with these orders if the Plaintiff fails to serve, or cause to be served, a copy of these orders (including the Production Schedule) personally on Mr Chiu by 5:00pm 8 June 2023 (AEST). PRODUCTION SCHEDULE- WARREN CHIU Warren Chiu, you must produce each of the documents mentioned below: In this Schedule the following definitions apply: Defined Term Definition Accounts Any account, cheque account, loan account, credit card account, investment account, term deposit, cash management fund, on call deposit, insurance bond, investment insurance policy and trust account. Act Corporations Act 2001 (Cth). Associated Entities means the following entities: (cc) Somersby Property Pty Limited (in liquidation) (ACN 089 634 220); (dd) Warwick Amusements Pty Ltd (in liquidation) (ACN 002 276 217); (ee) Five Continents Amusement Parks Pty Ltd (in liquidation) (ACN 002 995 066); (ff) Warwick Hotels Pty Ltd (ACN 002 273 850); (gg) Carnavon Shipping SA; (hh) Warwick Holdings SA; and (ii) Texon Investments Inc. Asset An asset of any description, including but not limited to real or personal property, whether tangible or intangible, present or future, vested or contingent, wherever situated, whether held beneficially or as trustee for a trust. Books Any Document, being: (q) a register; and (r) any other record or information; and (s) Financial Records, Financial Reports or Financial Statements; and (t) insurance policies. Classic Holdings Classic Holdings Ltd. Company Myoora Land Pty Limited (in liquidation) (ACN 089 634 131). Conditsis Lawyers Conditsis & Associates Pty Limited (ACN 114 761 410) trading as Conditsis Lawyers and includes any director, officer, employee or agent of Conditsis Lawyers. Crowe Horwath Findex Pty Ltd (ACN 006 466 351) formerly trading as Crowe Horwath and currently trading as Findex and includes any director, officer, employee or agent of Crowe Horwath. Directors includes all current and former directors of the Company: (q) Richard Chiu also known as Dick Tak-Sang Chiu; (r) Ulla Schneider; (s) Paul Edward Kiley; and (t) George McMillan. Documents All original documents (and if originals are not available, then copies of those documents) in your possession, custody or control, including but not limited to: all files, correspondence, memoranda, notes, file notes, diary notes, letters, working papers, emails, text messages, instant messages, contracts, agreements, finance agreements, reports, applications forms, journals, security and charge documents, settlement statements, drawings, maps, plans, photographs, rental statements, receipts, quotations, invoices, deeds, Financial Records, Financial Reports, Financial Statements and any records of information, however compiled, recorded or stored and whether in physical or electronic form. Financial Records Any document (whether in draft or final form) that sets out or summarises any financial information including but not limited to: balance sheets and trial balance sheets, profit and loss statements, general ledgers and transaction ledgers (including cash ledgers, debtors' ledgers and creditors' ledgers), asset registers, stock records, depreciation schedules, books of account, bank account statements, credit card statements, deposit books, cheque butts, business activity statements, taxation returns and cash flow statements. Financial Reports Has the meaning attributed to those words in section 9 of the Act, being an annual financial report or a half-year financial report prepared under chapter 2M of the Act, including drafts. Financial Statements includes: (a) income statement; (b) balance sheet; (c) statement of cash flows; (d) statement of shareholders' equity; and (e) accompanying disclosures. Grant Thornton Grant Thornton Australia Limited (ACN 127 556 389) and includes any director, officer, employee or agent of Grant Thornton. Horizon Horizon Accounting Solutions Pty Ltd (ACN 659 810 689) and includes any director, officer, employee or agent of Horizon. Interest any legal, beneficial or equitable interest or estate of any kind whatsoever. ITR 2019 The Company's income tax return for the financial year ended 30 June 2019. Interhotel Finance Interhotel Finance Ltd (CR No. 1600801). Interhotel Finance Loan means the loan or advance from the Company to Interhotel Finance in the amount of $16,895,142.58 in or about 2018. person includes an individual, corporation, partnership or other organisation. Properties means, separately and or collectively, as the context requires: (i) the entirety of the land located at and known as 66 Myoora Road, Somersby NSW 2250, comprising Title Reference 20/859538; and/or (j) the entirety of the land located at and known as 945 Old Pacific Highway, Somersby NSW 2250 comprising Title References 204/747845, 205/747845, 206/747845 and 21/859538. Sale of the Properties means the sale of the Properties by the Company and Somersby to WCTV in 2018. See Accounting Group Central Coast Business Solutions Pty Ltd (ACN 143 040 779) trading as See Accounting Group and includes any director, officer, employee or agent of See Accounting Group. Somersby Somersby Property Pty Ltd (in liquidation) (ACN 089 634 220). Transactions includes: (a) a conveyance, transfer or other disposition of property; (b) a charge created on property; (c) a guarantee; (d) a payment made; (e) an obligation incurred; (f) a release or waiver; (g) a loan; and includes such a transaction that has been completed or given effect to, or that has terminated. WCTV World Cultural Tourism Village Pty Ltd (ACN 626 149 988). Written Communications Anything imparting information in both physical and or electronic means and includes, but is not limited to, letters, emails, SMS messages, messages through messaging applications (such as those transmitted over WhatsApp, WeChat, etc.) and social media platforms and notes.

The documents or things that you must produce are as follows: Books of the Company

1. Books of the Company, including any copies that differ in any way to the originals.
2. To the extent not covered by category 1 above, copies of any Documents, including Written Communications: (a) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Interhotel Finance (including, without limitation, the Interhotel Finance Loan and any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (b) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Classic Holdings (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (c) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, any of the Associated Entities (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the other Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (d) recording, referring to or otherwise discussing any loans or advances to or form, on one hand, the Company, and to or from, on the other hand, any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (e) purporting to be the source of, or the circumstances that gave rise to "management fees" or "licence fees" purportedly paid by the Company in the years ended 31 December 2015, 31 December 2016, 31 December 2017, 31 December 2018 and 31 December 2019 (and any earlier periods, if applicable), including but not limited to any management agreements, receipts and invoices; (f) to the extent not covered by paragraph (e) above, recording, referring to or otherwise discussing the payment of any "management fees" or "licence fees" by the Company; (g) recording, referring to or otherwise discussing any lease or sub-lease in respect of the Properties or any part thereof (whether entered into by the Company or any of the Associated Entities), including, without limitation, registered lease number 5864266 to Australian Reptile Park Pty Limited, including, without limitation, copies of any lease agreement, sub-lease agreement, and any variations thereto; (h) recording, referring to or otherwise discussing the payment of any rent (including any contribution to operating costs) in relation of the Properties (or any part thereof) (whether paid to the Company or any of the Related Parties); (i) purporting to be the source of, or the circumstances that gave rise to, the following payments from the Company's bank account with the description "P Kiley Part repayment of loan PKLoan": (xiii) payment of $9,000 dated 10 December 2019; (xiv) payment of $9,000 dated 13 December 2019; and (xv) payment of $7,135 dated 20 December 2019. (j) recording, referring to or otherwise discussing the payment of any council rates, water rates, land tax, electricity or other operating costs in relation to the Properties; and (k) recording or relating to the appointment of George McMillan as director of the Company.
3. All Written Communications sent by or on behalf of the Company to, or received by the Company (or any of its directors, officers, employees or agents) from See Accounting Group, Jennie Hawkshaw or Horizon at any time since 1 January 2016. Sale of the Properties
4. All Documents, including Written Communications, referring or relating to the Sale of the Properties.
5. To the extent not covered by category 4 above, all Documents, including Written Communications, referring or relating to the payment and/or allocation of any amounts payable by or on behalf of WCTV in respect of the Sale of the Properties, including, without limitation, any direction to pay or settlement statement.
6. All Documents, including Written Communications, referring or relating to the ultimate destination of any amounts paid by or on behalf of WCTV in respect of the Sale of the Properties.
7. All Documents, including Written Communications, which record or evidence any directions or instructions given, by or on behalf of the Company to any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Properties (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017.
8. All Documents, including Written Communications, recording or otherwise discussing any advice or recommendation given to the Company or to any other person by any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Property (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017. Involvement of Stephen Geoffrey Linch
9. All Documents, including Written Communications, created, sent or received at any time since 1 January 2016, recording or evidencing any direction, instruction, advice or recommendation given by Stephen Geoffrey Linch in relation to the operation or management of the Company, the Sale of the Properties, the ITR 2019 and/or any of the Associated Entities.
10. To the extent not covered by category 9 above, all Written Communications sent by you to, or received by you from, Stephen Geoffrey Linch, at any time since 1 January 2016. Associated Entities
11. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to any of the Associated Entities by or on behalf of the Company at any time since 1 January 2016.
12. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from any of the Associated Entities to the Company at any time since 1 January 2016.
13. Financial Statements and Financial Reports prepared with respect to each of the Associated Entities (both on an individual basis and consolidated basis, if so prepared) created at any time since 1 January 2016.
14. To the extent not covered by categories 2(a) to (d) above, copies of all Documents, including Written Communications, recording, referring to or otherwise discussing any loans or advances between any of the Associated Entities, Interhotel Finance, Classic Holdings and/or any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto.
15. All Documents recording or evidencing any Interest that any of the Associated Entities has in any Asset (worldwide) with a market value of AUD $10,000 or more.
16. All tax returns prepared for or by any of the Associated Entities, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
17. Bank statements with respect to any Account in any of the Associated Entities' names, whether held singularly or jointly, created at any time since 1 January 2016.
18. All Documents, including Written Communications, recording or relating to the appointment of Kevin George McMillan as director of any of the Associated Entities.
19. Any Document, created at any time since 1 January 2011, recording a corporate group structure for Myoora, Interhotel Finance, the Associated Entities and any other related entities and/or affiliates of any of the aforementioned entities. Interhotel Finance
20. All Documents recording, created at any time since 1 January 2011, evidencing or otherwise discussing the directorship and/or ownership of Interhotel Finance (including, without limitation, the ultimate owner/s of Interhotel Finance).
21. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Interhotel Finance by or on behalf of the Company at any time since 1 January 2016.
22. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Interhotel Finance to the Company at any time since 1 January 2016.
23. Financial Statements and Financial Reports prepared with respect to Interhotel Finance created at any time since 1 January 2016.
24. All Documents recording or evidencing any Interest Interhotel Finance has in any Asset (worldwide) with a market value of AUD $10,000 or more.
25. All tax returns prepared for or by Interhotel Finance, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
26. Bank statements with respect to any Account in Interhotel Finance's name, whether held singularly or jointly, created at any time since 1 January 2016. Classic Holdings
27. All Documents, created at any time since 1 January 2011, recording, evidencing or otherwise discussing the directorship and/or ownership of Classic Holdings (including, without limitation, the ultimate owner/s of Classic Holdings).
28. All Documents recording, referring to or otherwise discussing the issuing, transferring or assignment of shares in the Company to Classic Holdings.
29. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Classic Holdings by or on behalf of the Company at any time since 1 January 2016.
30. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Classic Holdings to the Company at any time since 1 January 2016.
31. Financial Statements and Financial Reports prepared with respect of Classic Holdings created at any time since 1 January 2016.
32. All Documents recording or evidencing any Interest Classic Holdings has in any Asset (worldwide) with a market value of AUD $10,000 or more.
33. All tax returns prepared for or by Classic Holdings, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
34. Bank statements with respect to any Account in Classic Holding's name, whether held singularly or jointly, created at any time since 1 January 2016. Your Financial Position
35. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to you by the Company at any time since 1 January 2016.
36. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from you to the Company at any time since 1 January 2016.
37. All Documents recording or evidencing any Interest you have in any Asset with a market value of AUD $10,000 or more.
38. All tax returns prepared for or by you, whether lodged with the Australian Taxation Office or not and including any drafts, created at any time since 1 July 2019.
39. Bank statements with respect to any Account in your name, whether held singularly or jointly, created at any time since 1 December 2022.
40. All Documents, including Written Communications, recording or referring to any Australian visa issued to you. Order FEDERAL COURT OF AUSTRALIA No. NSD District Registry: NEW SOUTH WALES DIVISION: GENERAL IN THE MATTER OF: MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) PETER KREJCI IN HIS CAPACITY AS LIQUIDATOR OF MYOORA LAND PTY LIMITED (IN LIQUIDATION) (ACN 089 634 131) Plaintiff Before: Rares J Where made: Sydney Date of Order: [x] May 2023 THE COURT ORDERS THAT: -
41. Pursuant to section 597(9) of the Corporations Act 2001 (Cth), the Proper Officer, Interhotel Finance Limited (CR 1600801) (Interhotel Finance) attend before the Court for production of the documents and things specified in the schedule to these orders (Production Schedule) to the Federal Court of Australia, Law Courts Building, Queens Square, Sydney NSW at 9:30am Wednesday 28 June 2023.
42. In order to comply with Order 1, Interhotel Finance may, instead of attending before the Court on the date and time specified in Order 1, deliver or send the documents or things specified in the Production Schedule to the Court at the physical or email address below, so that they are received by the Court not less than 2 clear business days before the date specified in Order 1. The Registrar Federal Court of Australia Level 17, Law Courts Building Queens Square 184 Phillip Street Sydney NSW 2000 OR nswreg@fedcourt.gov.au
43. Interhotel Finance need not comply with these orders if the Plaintiff fails to serve, or cause to be served, a copy of these orders (including the Production Schedule) personally on Interhotel Finance by 5:00pm 8 June 2023 (AEST). PRODUCTION SCHEDULE- THE PROPER OFFICER, INTERHOTEL FINANCE LIMITED (CR 1600801) The Proper Officer of Interhotel Finance, you must produce each of the documents mentioned below: In this Schedule the following definitions apply: Defined Term Definition Accounts Any account, cheque account, loan account, credit card account, investment account, term deposit, cash management fund, on call deposit, insurance bond, investment insurance policy and trust account. Act Corporations Act 2001 (Cth). Associated Entities means the following entities: (jj) Somersby Property Pty Limited (in liquidation) (ACN 089 634 220); (kk) Warwick Amusements Pty Ltd (in liquidation) (ACN 002 276 217); (ll) Five Continents Amusement Parks Pty Ltd (in liquidation) (ACN 002 995 066); (mm) Warwick Hotels Pty Ltd (ACN 002 273 850); (nn) Carnavon Shipping SA; (oo) Warwick Holdings SA; and (pp) Texon Investments Inc. Asset An asset of any description, including but not limited to real or personal property, whether tangible or intangible, present or future, vested or contingent, wherever situated, whether held beneficially or as trustee for a trust. Books Any Document, being: (u) a register; and (v) any other record or information; and (w) Financial Records, Financial Reports or Financial Statements; and (x) insurance policies. Classic Holdings Classic Holdings Ltd. Company Myoora Land Pty Limited (in liquidation) (ACN 089 634 131). Conditsis Lawyers Conditsis & Associates Pty Limited (ACN 114 761 410) trading as Conditsis Lawyers and includes any director, officer, employee or agent of Conditsis Lawyers. Crowe Horwath Findex Pty Ltd (ACN 006 466 351) formerly trading as Crowe Horwath and currently trading as Findex and includes any director, officer, employee or agent of Crowe Horwath. Directors includes all current and former directors of the Company: (u) Richard Chiu also known as Dick Tak-Sang Chiu; (v) Ulla Schneider; (w) Paul Edward Kiley; and (x) George McMillan. Documents All original documents (and if originals are not available, then copies of those documents) in your possession, custody or control, including but not limited to: all files, correspondence, memoranda, notes, file notes, diary notes, letters, working papers, emails, text messages, instant messages, contracts, agreements, finance agreements, reports, applications forms, journals, security and charge documents, settlement statements, drawings, maps, plans, photographs, rental statements, receipts, quotations, invoices, deeds, Financial Records, Financial Reports, Financial Statements and any records of information, however compiled, recorded or stored and whether in physical or electronic form. Financial Records Any document (whether in draft or final form) that sets out or summarises any financial information including but not limited to: balance sheets and trial balance sheets, profit and loss statements, general ledgers and transaction ledgers (including cash ledgers, debtors' ledgers and creditors' ledgers), asset registers, stock records, depreciation schedules, books of account, bank account statements, credit card statements, deposit books, cheque butts, business activity statements, taxation returns and cash flow statements. Financial Reports Has the meaning attributed to those words in section 9 of the Act, being an annual financial report or a half-year financial report prepared under chapter 2M of the Act, including drafts. Financial Statements includes: (a) income statement; (b) balance sheet; (c) statement of cash flows; (d) statement of shareholders' equity; and (e) accompanying disclosures. Grant Thornton Grant Thornton Australia Limited (ACN 127 556 389) and includes any director, officer, employee or agent of Grant Thornton. Horizon Horizon Accounting Solutions Pty Ltd (ACN 659 810 689) and includes any director, officer, employee or agent of Horizon. Interest any legal, beneficial or equitable interest or estate of any kind whatsoever. ITR 2019 The Company's income tax return for the financial year ended 30 June 2019. Interhotel Finance Interhotel Finance Ltd (CR No. 1600801). Interhotel Finance Loan means the loan or advance from the Company to Interhotel Finance in the amount of $16,895,142.58 in or about 2018. person includes an individual, corporation, partnership or other organisation. Properties means, separately and or collectively, as the context requires: (k) the entirety of the land located at and known as 66 Myoora Road, Somersby NSW 2250, comprising Title Reference 20/859538; and/or (l) the entirety of the land located at and known as 945 Old Pacific Highway, Somersby NSW 2250 comprising Title References 204/747845, 205/747845, 206/747845 and 21/859538. Sale of the Properties means the sale of the Properties by the Company and Somersby to WCTV in 2018. See Accounting Group Central Coast Business Solutions Pty Ltd (ACN 143 040 779) trading as See Accounting Group and includes any director, officer, employee or agent of See Accounting Group. Somersby Somersby Property Pty Ltd (in liquidation) (ACN 089 634 220). Transactions includes: (a) a conveyance, transfer or other disposition of property; (b) a charge created on property; (c) a guarantee; (d) a payment made; (e) an obligation incurred; (f) a release or waiver; (g) a loan; and includes such a transaction that has been completed or given effect to, or that has terminated. WCTV World Cultural Tourism Village Pty Ltd (ACN 626 149 988).

The documents or things that you must produce are as follows: Books of the Company

1. Books of the Company, including any copies that differ in any way to the originals.
2. To the extent not covered by category 1 above, copies of any Documents, including Written Communications: (a) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Interhotel Finance (including, without limitation, the Interhotel Finance Loan and any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (b) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, Classic Holdings (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (c) recording, referring to or otherwise discussing any loans or advances to or from, on one hand, the Company, and to or from, on the other hand, any of the Associated Entities (including, without limitation, any loans or advances for which the Company is jointly or jointly and severally liable with any of the other Associated Entities), including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (d) recording, referring to or otherwise discussing any loans or advances to or form, on one hand, the Company, and to or from, on the other hand, any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto; (e) purporting to be the source of, or the circumstances that gave rise to "management fees" or "licence fees" purportedly paid by the Company in the years ended 31 December 2015, 31 December 2016, 31 December 2017, 31 December 2018 and 31 December 2019 (and any earlier periods, if applicable), including but not limited to any management agreements, receipts and invoices; (f) to the extent not covered by paragraph (e) above, recording, referring to or otherwise discussing the payment of any "management fees" or "licence fees" by the Company; (g) recording, referring to or otherwise discussing any lease or sub-lease in respect of the Properties or any part thereof (whether entered into by the Company or any of the Associated Entities), including, without limitation, registered lease number 5864266 to Australian Reptile Park Pty Limited, including, without limitation, copies of any lease agreement, sub-lease agreement, and any variations thereto; (h) recording, referring to or otherwise discussing the payment of any rent (including any contribution to operating costs) in relation of the Properties (or any part thereof) (whether paid to the Company or any of the Related Parties); (i) purporting to be the source of, or the circumstances that gave rise to, the following payments from the Company's bank account with the description "P Kiley Part repayment of loan PKLoan": (xvi) payment of $9,000 dated 10 December 2019; (xvii) payment of $9,000 dated 13 December 2019; and (xviii) payment of $7,135 dated 20 December 2019. (j) recording, referring to or otherwise discussing the payment of any council rates, water rates, land tax, electricity or other operating costs in relation to the Properties; and (k) recording or relating to the appointment of George McMillan as director of the Company.
3. All Written Communications sent by or on behalf of the Company to, or received by the Company (or any of its directors, officers, employees or agents) from See Accounting Group, Jennie Hawkshaw or Horizon at any time since 1 January 2016. Sale of the Properties
4. All Documents, including Written Communications, referring or relating to the Sale of the Properties.
5. To the extent not covered by category 4 above, all Documents, including Written Communications, referring or relating to the payment and/or allocation of any amounts payable by or on behalf of WCTV in respect of the Sale of the Properties, including, without limitation, any direction to pay or settlement statement.
6. All Documents, including Written Communications, referring or relating to the ultimate destination of any amounts paid by or on behalf of WCTV in respect of the Sale of the Properties.
7. All Documents, including Written Communications, which record or evidence any directions or instructions given, by or on behalf of the Company to any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Properties (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017.
8. All Documents, including Written Communications, recording or otherwise discussing any advice or recommendation given to the Company or to any other person by any of the persons itemised in paragraphs (a) - (e) below, in relation to the Company, the Sale of the Property (including, without limitation, the proposed sale of the Properties prior to any contract for sale being entered into) and/or the ITR 2019: (a) Grant Thornton; (b) Crowe Horwath; (c) See Accounting Group; (d) Horizon; and (e) Conditsis Lawyers, at any time since 1 November 2017. Involvement of Stephen Geoffrey Linch
9. All Documents, including Written Communications, created, sent or received at any time since 1 January 2016, recording or evidencing any direction, instruction, advice or recommendation given by Stephen Geoffrey Linch in relation to the operation or management of the Company, the Sale of the Properties, the ITR 2019 and/or any of the Associated Entities. Interhotel Finance
10. All Documents recording, created at any time since 1 January 2011, evidencing or otherwise discussing the directorship and/or ownership of Interhotel Finance (including, without limitation, the ultimate owner/s of Interhotel Finance).
11. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Interhotel Finance by or on behalf of the Company at any time since 1 January 2016.
12. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Interhotel Finance to the Company at any time since 1 January 2016.
13. Financial Statements and Financial Reports prepared with respect to Interhotel Finance created at any time since 1 January 2016.
14. All Documents recording or evidencing any Interest Interhotel Finance has in any Asset (worldwide) with a market value of AUD $10,000 or more.
15. All tax returns prepared for or by Interhotel Finance, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
16. Bank statements with respect to any Account in Interhotel Finance's name, whether held singularly or jointly, created at any time since 1 January 2016. Associated Entities
17. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to any of the Associated Entities by or on behalf of the Company at any time since 1 January 2016.
18. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from any of the Associated Entities to the Company at any time since 1 January 2016.
19. Financial Statements and Financial Reports prepared with respect to each of the Associated Entities (both on an individual basis and consolidated basis, if so prepared) created at any time since 1 January 2016.
20. To the extent not covered by categories 2(a) to (d) above, copies of all Documents, including Written Communications, recording, referring to or otherwise discussing any loans or advances between any of the Associated Entities, Interhotel Finance, Classic Holdings and/or any of the Directors, including but not limited to any loan agreements, personal guarantee and/or indemnity agreements, security agreements and any variations thereto.
21. All Documents recording or evidencing any Interest that any of the Associated Entities has in any Asset (worldwide) with a market value of AUD $10,000 or more.
22. All tax returns prepared for or by any of the Associated Entities, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
23. Bank statements with respect to any Account in any of the Associated Entities' names, whether held singularly or jointly, created at any time since 1 January 2016.
24. All Documents, including Written Communications, recording or relating to the appointment of Kevin George McMillan as director of any of the Associated Entities.
25. Any Document, created at any time since 1 January 2011, recording a corporate group structure for Myoora, Interhotel Finance, the Associated Entities and any other related entities and/or affiliates of any of the aforementioned entities. Classic Holdings
26. All Documents, created at any time since 1 January 2011, recording, evidencing or otherwise discussing the directorship and/or ownership of Classic Holdings (including, without limitation, the ultimate owner/s of Classic Holdings).
27. All Documents recording, referring to or otherwise discussing the issuing, transferring or assignment of shares in the Company to Classic Holdings.
28. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made to Classic Holdings by or on behalf of the Company at any time since 1 January 2016.
29. All Documents, including Written Communications, recording or referring to any payments (whether cash, bank transfers or otherwise) made from Classic Holdings to the Company at any time since 1 January 2016.
30. Financial Statements and Financial Reports prepared with respect of Classic Holdings created at any time since 1 January 2016.
31. All Documents recording or evidencing any Interest Classic Holdings has in any Asset (worldwide) with a market value of AUD $10,000 or more.
32. All tax returns prepared for or by Classic Holdings, whether lodged with the relevant authority or not and including any drafts, created at any time since 1 July 2019.
33. Bank statements with respect to any Account in Classic Holding's name, whether held singularly or jointly, created at any time since 1 January 2016