saaa7 SUPERIOR COURT CANADA PROVINCE OF QUEBEC DISTRICT OF SAINT-MAURICE. we 490-17-001943-156 DATE: JULY 28, 2015 PRESIDING: THE HONOURABLE MANON LAVOIE, J.8.C. STEVE SALEEN “and: SALEEN AUTOMOTIVE, INC. Plainitts FREDERIC LAMBERT Defendant ‘ORDER [1] WHEREAS on July 20, 2015, the Plaintfts, M, Steve Saleen and Saleen Automotive, Ine, fled a Motion to insthute Procoadings for Inerioeutory and Permanent Injunction (the ‘Mction’), predicated on the defamatory comments made by the Defendant, M. Frederic amber, on various websites including “InvestorsHub.com and “Reddit. com™, using various aliases, including "Fredvestor’ and ‘FredTesia' [2] WHEREAS, the Plaintifs are essentially seeking the following by their Motion: 75, _ ORDER the defendant, Frederic Lambert (Mr. Lambert) and any {and all persons acting on behalf of oF in conjunction with Mr. Lambert, and any and all persone having notice of this injunction, 1o cease and asist rom disseminating, releasing, posting, publishing, sharing, linking, fr otherwise communicating or causing to be communicated in any {ashion whatsoever ether through himself, his agent or otherwise, on any media whatsoever, including on the websites InvestorsHub.com or on the twebste BlackSheepPlanet.com, any comment relating to the Plant Steve Saloon of the Plainttt Saleen Automotive, Inc. or its past, current and future affiates, subsidiaries, rectors, lficers, management mployees, agents, representatives or shareholders (collectively, the ‘Saloon Persons), stating, declaring, alluding or otherwise suggesting that the Saleen Persons:49097-001349-156 2 2) participated in, or are otherwise involved in a “fraudulent scheme", ‘seam’, ‘pump and dump scheme" or any other behaviour of ‘that nature; b) are being investigated by the U.S. Securties and Exchange ‘Commission or any other organization ofthat nature; ©) have committed any criminal or penal infractions; oF 1) any other defamatory comments; 76. ORDER Mr. Lambert to place a formal writen request 10 InvestorsHub com's webmaster 0 withdraw, delete or remove the postings published under the alas "FredVestor’ (he “Postings’ from this fwobsite and to withdraw, delete or remove any link to the Postings from {the within five (8) days of the order to be issued and to provide a copy of uch writen request and the proat of receiot by the webmaster to the Indersigned counsel of record within ton (10) days of the order to be issued herein; 18) WHEREAS the parties have settled this matter out of court and that as part of the ‘Settlement, the Defendant agrees that this order be issued against him: FOR THESE REASONS, THE COURT HEREBY: [4] PRAYS ACT OF the sottiement entered into between the parties; (5) ORDERS the Defendant, Frederic Lambert (Mr. Lambert’) and any and all persons Sting on behatf of or in conjunction with Mr, Lambert, and any and all persons having notice of this Injunction, to cease and desit from disseminating, releasing, posting, publishing, eharing, linking, of otherwise communicating or causing to be communicated in any fashion whatsoever bother trough himself, is agent or otherwise, on any media whatsoever, including on the Rebslies “InvestorsHub.com:, "Reddit.com, and "BlackSheepPlanet.com’, any comment hating to the Paint Stove Saleen or tha Plaintt! Saleen Aulomotive, Inc. or its past, current Gnd. foture “aifiaias, subsidiaries, directors, officers, managemerit, employees, agents, Fepresentatives or shareholders (colectvely, the “Saleen Persona’), stating, declaring, alucing ‘or otherwise suggesting thatthe Saleen Persons: 12) participated in, or are otherwise involved in a “fraudulent scheme". a ‘fraud’, & scam, @pump and clump scheme” or any other behaviour ofthat nature b) are being investigated by the U.S. Securtles and Exchange Commission or any ‘ther organization ofthat nature ©) thatthe Saleen Persons have commited any criminal or penal infractions; or 4) anyother defamatory comments: (6) _ ORDERS Wr. Lambert to place a formal written request to the webmasters of the Hrpsite “investorsHub.com to withdraw, delete or remove the postings published under the ‘Mlas "FredVestor"o¢ any other aliases (the "InvestorsHub Postings’) from the website and to Sitncra, delete of remove any ink To the InvestorsHub Postings from the within five (5) days of the order to be issued and to provide a copy of such written request and the proct of receipt By410-17.001349-186 3 ‘the webmaster to the Plaintifs' counsel of record within ton (10) days of the order to be issued horain; T71___ ORDERS Mr. Lambert to place a formal writen request to the webmaster of the Jebste “Reddit com’ fo withdraw, delete or remove the postings relating to the Saleen Persons published under the alias "FredTesia" or any other aliases (the “Reddit.com Postings”, Colectively with the InvestorsHud Postings and any similar postings, the “Postings') from the Website and to withdraw, delete of removo any link to the Reda Postings from the within five (6) days ofthe order tobe issued and fo provide a copy of such writon request and the proot of feveipt by the webmaster to the Plaintis: counsel of record within ten (10) days of the order to bb issued herein; [8] DECLARES that this order is enforceable against any person, including corporate persons, who has participated or otherwise collaborated in the posting, publishing or Communication of the Postings, and who has been mace aware ofthis order; [6] ORDERS that any person directed by this order not to do something shall not do it himself or horse, nor through offers acting on its, his or her behalf, or on its, his or her insvuctions, or wih its, his oF her encouragement or acquiescence, nor in any other way ‘whatsoever, [10] DECLARES that the service of this order. via process server, bailiff, facsimile, [egistered mail or email, including outeio of legal hours and on non-jurcical days, is suficient ‘ind valid for all legal intents and purposes including, without limtation, for the purposes of [ticle 756 of the Code of Civil Procedure of Québec; 4) ‘THE WHOLE without cost. (ene MANON LAVOIE, J.S.C. ‘cassels & Graydon LLP i Mare-Anaré Landry ome coe COMFOME Mm aviane Bisallon a Atorneys for he Plait MOMs Vassih Grettier(e)-adjoin(e) cain Lamarre If* Kathneryne Destossée Over Passe [Attomeys forthe Defendant