TRuot c Rssocis

ATTESTATION D'AUTH ENTICITE

(4rt. 82.1, 2e al. C.p.c.)
J'atteste que le document annex est une copie conforme
du fac-simil reu par tlcopieur

Nature du document

Motion to institute proceedings for interlocutory and

permanent injunction

Numro de cour:

410-17-001343-1 56

Expditeur:

Blake, Cassels et Graydon, avocats

Tlcopieurdel'metteur: 514-982-4099
Lieu de la transmission

Montral

Date de la transmission

2O

Heure de la transmission

juillet 2015

11h34

Shawinigan, le 20 juillet 2OLs

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Sbastien Boutet, Huissier de justice

985, Royale, 2. tage, Trois-Rivires, (Qubec) GgA 4H7

T1, : (819) 375-1074 / Tlc. : (819) 375-2084

Couniel : trudel@infoteck.qc.ca

795, 5" Rue, Shawinigan, (Qubec) GgN 1G2

Tlc. : (819) 5364079

T1. : (819) 536-5190 /

N 4U93 P.

',)

ANADA
PROVINCE OF QUBEG
ISTRICT OF SAINT,MAURICE
N:

410-1

7^a>L?./3- l SG

SUPERIOR GOURT

|I[VE_.SALEEN, an individuat havtng his domicile at

2735 Warlow Road,.n the city of Crona,
Cliiornia,
Uniterl States of America;

-and-

SALEEN AUTOMOTIVE, tNG,,

corporation duly
incorporaled under the laws of Nevada, hving
;
busness at 601 E Charleston Btvd., in the-citiirr
of Lai
Vegas, Nevada, United States of America;
Plaintiffs

t)
Ja

v.

FREDERIG LAMBERT, an individual domlciled

at ZgS,
de
la
Baie,
in
tfre
cty
of
Saint-Boniface,
districioi
9trgr]_n
Trois-Riviros, Province of eubec, GOX 2L0;
-andJOHN DOE AND JANE DOE

Defendents
MOTION TO INSTITUTE PROGEEDINGS FOR INTERLOCUTORY
AND PERIIIANENT INJUNCTION
(Art, 7F1 and ff C.C.p.)

TO ONE OF THE HONORABLE JUDGES OF THE SUFERIOR GOURT

OF QUBEC,
SITTING IN THE DISTRICT OF SAINT.MAURICE, THE
PLAINTIFFS SUBMIT

I,
1-

INTRODUCTION
For the reasors expounded hereinbelow, the Plaintiffs,
Mr. Steve Saleen (,,Mr. saleen")
and Saleen Automotive, lnc- ("SAl"), hereby seek interlocr.rtory and permanent
njunctive
orders against the Defendant, Mr. Frdric Larnbert ("Mr. Lamberfl),
restraining hirn,

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4893 P, 3

inter alia' from posting defarnatory commerrts

with respet to the plaintiffs or to

otherwise disseminating farse and hghry prejudiciar

information against them.
2

ln short, for unknown resons, Mr. Lambert, using

aliases in most cses, rras been
posting defamatory comments on the Plaintiffs
on various websites and blogs, which
adversely affected and impacted the Plaintiffs' respective
reputation and even fho
trading volume and price of SAI's stocks.

It is of the utmost importance that this Honourable court urgently

and perrnaneny
orclers Mr' Larnhert to halt this outrageous
and unjustfiabre behaviour, which conlinues
unabated-

ll.

THE PARTIES

4.

Mr. Saleon is the president of SAl,

5.

After a Garr as a racing driver, he founded the predecessor

of sAr in 1gg3,

6.

sAl s a Nevada-based corporaton which designs, develops, manufactures

and sells
high performance vehicles built from of Ford Mustangs,
Chevrolet Camaros, Dodge
Challengers and Tesle Model S vehcles chassis, as well as
a broacl line of performance
parts, customizable designs, engineering and certifcation
services the whole as more
fully described in the printed extracts of SAI's website communicated
p-',

as Exhibit
and as apears from $Al's Annual Report (Form 10-K)
for the year ended March 31,

2a filed with the u.s.

securities and Exchange commssion (the 'sEc,)

communicatecl as Exhibit p-p.

7

SAI's common shares are quoted on the OTG Bulletin Board, an

over-the-counter
market, under the symbol "SLNN".

8_

Mr. Lambert' is an individual residing in $aint-Boniface, eubec.

He claims to be a
marketing specialist and to have an interest in car-related blogging,
as appears from his
professonal profile posted on Linkedln@ communicated
as Exhibit p_1.

He also owns the

dornain narne

of the

website

"Blacksheepplanet,'

(http://blacksheepplanet'com/), which focuses on Tesla products

and dsparaging the
Plaintiffs, nd l6i products, as appears from the printed
extracts of the said website

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-3olmun0ated, en /iasse, as Exhibit P'4 and lhe extract

of the narne domain registry
communicated as Exhibit p-5.

10'

Moreover, as further demonstrated below, Mr. Lambert

uses the alias ,,Fredvestor,, (the
"Alins')
post defamatory comments on the website ,,lnvestor$Hub,com"

to

("lnvestorsHub"), as well as other aliases and even

his own nme to post on other
blogs and websites listed below (see Section lV below).

III.
11'
12'

THE DISSEMINATION OF DEFAMATORY COMMENTS

The Alias' profile was created on lnvestorsHub on March

19, 2014, the whole as
apprs from printed copies of the Alias' profile communicated
as Exhibit p-6.
For several rnonths, to the Plalntiffs' best knowledge, since
at least July 2014, the Alias,

who had been posting messeges on lnvestorsHub's messeg

board relating to SAI (the
"Board") since March 2014, stafted to post prejudicial
and defamatory comments
relating to the Plaintiffs (the "Defamatory Postings-), the
whole as appears frorn the
printed extracts of the Board communicated, sn |iasse,
as Exhibit p-2.

13'

14'

15.

As appears from the Alias'profile (Exhibit P-G), as of Juty 16, zgts,

this Alias had posted
1,118 comments, at all hours, multiple times any given
day, on the Board (out of a totel
of I ,150 comments posted by this Alias on the lnvestorsHub).

ln fact, the Alias is currently a moderato of the Board and is, by

far, the rnost acve
bloggers of the Eoard, e$ eppers from the Posfor Summaryof
the Board communicated
Exhibit
as
P-8.
Below are just a few examples of the Defamatory Postings published by
the Alias:

Saturday,
July 19,

2439

I guess it depends on your defnition of a scam,

2014

Google tells usl

01:27:58 PM

Quote;
a dishonest sheme; a fraud_

Wh ich ls q subjective rhi ng stn ce when a lking about d fraud, you

are
most lif<ely talking about an ifleg al act. Whife dishonest soh
e rn can
Jus be dishonesl an d not strictly iI lega l. As f0r Stv Safeen and his

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-4the
he

depending on your defintion of scam, the

Lo.y.*,r,t'.
ailegarions that
SLNN is a scam are based on facti.
Friday, May

624s

22,2A16

I'll make it even more clear,

Frederic Lambsrt is not a lro[. H wrote aicles
about saleen based on
verifable sources that are linked to the articles_

6:04:29 PM

http:/lacksheeFplanet.com/inrlex, php/category/oars/
To this day no one has been abla t
Saleen. Only invalid claims
which was never actually
emails, which s even more
he was forging emails in wh

SLNN is a scam and always been a scm:

t..1

Thursday,

6489

June 4, 2015
12:51:53 PM
Sunday,

Beware thle lE only a pump and dump

I..I

6988

June 7, 2015
l1:47:t6 AM

Alert Pump and Dump

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

I.l
Sundy,

6993

nipulted on the OTC, t'r1

oes way beyonct that. lt.e not

June 7,201F
01:08:43 FM

pump from the companies

was entirely sotup to be a

Itwas brought public by bad actors, David Weine Fred Knolland

Eric
Stoppe nhagen, which are allimplicated in shacly ompanis:

Th whol c

\a
He was invo

saleen

dozen of dealerships,

h shadY PeoPle' steve

a mulfitude of lawsuite.
ole mllions fiom a

The l(BM guys, the Kraher brothers, they had to settle with
the SEC a
bunch of times.,.

by their bank, they start issuirrg 8K

we sh o uld e ncou fg p eopl to pu
ed f0r boun cett Th IS rS ridiculo ug.

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4893 P,

-5Wednesday,
July 01,
2015
08;33:15 AM

11117

"vested intregt" is a broad term. I have

no financialintelest in Saleen,s
stock one way or the other.
But bad actore around SLNN made sure
to natte me personally
involved n this so here I am and I'lt ,J* iiio

ifi*

Wednesday,
July 01,
2015
9:26:14 AM

11121

END.'

r..l
My findirrgs we rot more afarming than a
simpre bad investment
opporturrity, it insiead unavere_d stoir manipuuon
ii
ffiminaractivities. r shared my findings wiffrne
sEG "mJng
and snce rhen
thlngs have ntensified.
t,.1

lf you want to rearn about these bad.actors, you

shourd start by
d in g the rinks twen sareen's
dwn erships nli
suspicious entities: http://. i mgur.*omlt tnmZNpr.jpg'
"t,
un derstan

t.1

n party_
ressed as a
Both these guys have criminalcases against
them including rape.
These are the type of peopte Saleen cloes business
with.,.

This is on scrathcing the surface. there's nruch

fiore about these guys
and also $teve saleen himself- But you shourd rearn a Iot,Jrrf
lr,Lt
pretg soon.
Monday,

11434

July 13,
2015
09:07:26 PM

And now thrs Greentech business wth guys seiling fest

tracrr to
Americar citizenships to Ghinese uusinsiman tofinance
their
ofipery, Their atso undr SEc invasttation BTW.
Ths thing ts getting uglier every day.
Thursday,
July 16,
2015
B:19:18 AM

16

11547

I.I
All I see from steve sareen

is an attempt at rransfering his financiar

exposule to the orc marr(et. My best gess is that t Jo"s*i"r
about his SLNN shares. all he cares is-getting rld of the few debt
he is
personally accountable for at SLNN.

All of these statements, reproduced hereinabove, re highly prejudicial.

The notions of
"fraud", "scam" and 'pump and dump schme" (which constitutes
cminal allegations of
a fraud on the markei), amongst others, are negative, destructive
and harrnful in nature
artd advergely impact the Plaintiffs' respective reputations in
a severe and rreparable
fashion.

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-617

The statements published by the Alias also suggest

that the plaintiffs are being
investigated by the sEC in relation with the alleged,,pump
and dump scheme,,, which, to

the Plaintiff's krrowledge, s simply false.

18.

The Defamatory poslings referred expliciily to plaintiffs

by name thror.rghout, are cfearly
ahout and targeting the Plaintiffs, and were so understod
by those who read the
posting.

19'

The entirety of the statements calling Mr. $aleen a

fraudster and scammer and statng
that sAl is not a ieal business and is inslead a "pump
and dump scarn,, are false as they
pertain to Plaintiff' More specifically, the statements
as listed n paragraph 15 above
and the other Defamatory postings are patenfly farse.

20-

Tho Defarnatory Posting$ ale lbelous on their face: they

clearly expose plaintiffs to
hatred, contempt, ridicule and obloquy as it charges Mr. $aleen
wth havirrg engaged in
criminal activity ancl charges Mr. saleen and sAl with engaging
in investor fraud and
regulatory vlolations relating to the sale of ihares in $Al,
The Defamatory postings also
accuse the Plaintiffs of running an orchestrated scam_

21'

The Defamatory Postings were seen and read on or about

the date of their posting and
thereafter by members of the Board and/or other internet users
searching for information
regarding the Plaintiffe, as prospecfive investors in SAI and/or
custorners interested in
ordering a vehicle from the plaintitfs.

22.

For instance, using another alias, "FredTesla", on a website dedicated to

Tesla cars
Lan:bert urged potential buyers of the Saleen Tesla vehicles to reconsider their
decision
in a disparaging comment which started with the following stetemnt ,'Saleen
is running
something closely resembring a ponzi scheme/pump&dun.p,',
s ppears from the
printed extracts of the said website cornmunicated as Exhbt p-g.

23.

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

24_

Moreover, Mr. Lambeft chose to publish the Defamatory Postings

on lnvestorsHub,
when he knew that $Al had purchased advertisement rights
on this websile, sgmngly

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4893 P, I

-7with a vew to impede SAI's mart<eting efforts, s ppears

from a copy of an article
published by "Fred Lambert" on July 15,2014 on the
website "BlackSheepFlanet,,
entitled Saleen is Trying to Ride on les/a's sucres and aTG |rrvestr'
Money (the
"Articlo" in whioh the Defendant mentioned SAt's advertsement
on lnvestorsHub,
corrtmunicated as Exhibt p-i,1,

25,

ln ths article, Mr' Lambert acctlsed the Plaintiffs of baing nvolved n a fraudulent
scheme also involving the lnvestorsHub website and also engaged in personal
attacks
against Mr. Saleen's daughter, the whole as ppears from Exhibit p_11.

28.

As a proximate result of the Defamatory Postings and the other

aforementioned

defamatory statements, the Plaintiffs have suffered damages to their reputation, shame,
embarrassmnt, and, possibly, loe of business sales which cannot be assessecl,
at
least for the moment. These ongoing damages are unquantifiable and irreparable.
?7

It is noteworthy that, since April 2015, the Alias has markedly increased the frequency
of

his Defamatory Postings, Remarkably, the volume of trades of SAI's slocks has grown
significantly over the same periorl of time, as hs the levet of stock volatility,
as appers
from an extract from $Al's website communicated as Exhibit p-12.

28'

lt is equally

reasonable

to assume that the Defamatory Postings hv and may still

dvsrssy inrpact the price of SAI's stock

29.

ln fact' the volume of trades of SAI's stock has recently increased dramatically, spiging
at2?1,228,304 shares traded on or about June 21,2A15 (Exhibit p-1ll and the price of
sAlrs stock has significantly declined over the last three rnonths, l.e. -g4% of lts value
over the last three months end -33% of its value over the last month (Exhibt p-1?);

30.

ln

conclusion, the Defamalory Postings and the other aforementioned defamatory

statements are patently ill-founded and are clestined ai harming the plaintiffs'reputation

and business prospects. They are also seemingly affecting fhe market and may thus
cause damages io ihird parties and other nvestors.
31

As appears, inter alra, from the Defamatory Posting number 11117 (Exhibit p-Z), the
Alias'goal is to continue his destructive defamatory act, or, as he puts it, "se it to the
ND'.

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IV,
aa

LAMBERT IS USING THE ALIASES

As mentioned above, since spring 2015 a dramatic increase in

the pubtication of
Defamatory Postings is noticeable.

33'

Given the increasing nurnber of Defmatory

Postings, the personal attack$ included
therein and the seeming impact of the Defamatory Postings
on sAl,s stoct{, the plaintifls
began investigating the real identity of the Aljas.

34.

Following a thorough nvestigation, they have

been able to unequivocally establish that
Mr. Lambeft is using the Atias.

35,

On August 31, 2014, the Alias postecl on the Board a link to

an email belonging to him

showinghisemailaddress(andhisfullname,a$
appears frorn the posting communicated as Exhlbit p-13,
36.

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

37

On August 21,2014, the same emait acldress and neme were used
in an email was sent
in to the sAl's Public Relation Department's mailbox requestng
information, this time, as

an editor for BlackSheepPlanet.com, as apears from a printed copy

of the said email
communicated as Exhibit p-15
38.

The website BlackSheepPlanet.com has only a handful of afticles,

all written by the
same editor named "Fred Lambert" (Exhibit p_4).

39

Whols, a web service providing information on domairr narnes revealed

that the dornain
name "BlackSheepPlanet.com" is owhed by Mr. Lambert and that the latter
uses the
safn email address, and provided his street address and phone number,
as apprs
from the printed extracts of the whors wehsite (Exhibit p-b).

40

A reverse regearch on the sam website listed additional domains owned by

the same
name and email address, One of these sites is "ZalKoh.corr", as ppears from
the

printed extracts of the said website communicated es Exhibit p-6.

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41

A research on the "ZarKon-com" domain nm reveared that the sne

nme, emair, and
contact address as "Bracksheepplanet.00m" were used by
Mr, Lambert, s appears
from the printed extracts of the research results communicated
as Exhibit p-17.

42

Mr' Lambert has published on the "ZalKon.com" webpage an image

of himself (Exhibit
P-r6).

43.

The Twitter profle of the "ZalKon-com" webpflge links the

Twlter profile of Mr. Lambeft
that also shows a picture of the latter, as appears from the printed extracts
of the said
profile comrnunicated as Exhiblt p-,f g,

44

A Linkedln profile searclr for Mr. Lambert (Exhibit P-3) also tinks same to a profle
with
the same name and pictures than those used on Mr. Lambert's
Twitter profite (Exhibit p18).

45.

A Facebook profile search for Mr. Larnbert links to a profile with the same image

arrd

name as used on the "ZalKon.com" webpage (Exhibit P-1), es eppears from the printed
extracts of Mr. Lambe1's Facebook profile communicated as Exhibit p-1g.

46.

Moreover, the fact the Mr. Lambert pubtishes on various websites using aliases
commencing with "Fred", i,e. "Fred Lambert" on BlacksheepFlanet.corn, ,,Fredresta'on
http:/futww-reddit.com/r/teslamotors and the Alias on invertorsHub, makes evdent fhat
only one individual - who has a special interest in Tesla products and disparaging
SAI
i behind lhese aliases.

47.

Furthermore, the cross-references between sorlle of the Defarratory postirrgs (see, for
examples, Defamatory Posting number 624t, Exhibit P-7 en /iasse) and Mr, Lambert's

website (Exhibit P-4) corroborate the relationship between Mr. Lambert and the
aforementioned aliases.
48.

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

V,

THE ORDERS SOUGHT AND THE RIGHT TO THE ISSUANCE OF PROVISIONAL

AND INTERLOGUTORY INJU NCTIONS

49

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

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-10any further messages, comments, allegations or eny other

communications, released via

any media (whether verbal, written or virtual), defaming, clisparaging,

offending,
denigratng or otherwise of a hannful nature relating to the ptaintiffs.

50'

Considering that the Plaintffs cannot ssess whether

Mr. Lambert has benefiied or
benefits from the participation of accomplices o[ othenrise,
conspires or collaborates
with thircl parties with respect to the above-described defamatory scheme, it
is
necessary that any orders to be rencferecl herein be enforceable
against such third
partes becoming awae of such orders.

A.

At the lnterlocutory Stage: the Plaintiffsr Prima Facie Right to the Sought
orders

51

For the reesons set forth above, the Plaintiffs are entfied to the sought
orders: the
Defamatory Postings and the other detamalory comrnents cited
in Section lll above are
bereft of arry foundation and are extremely prejudicial-

52.

ln short, these comments constitute pure defamation.

53,

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

E.

At the Interlocutory stage: the praintffs suffer lrreparahle harm

54.

As described hereinabove, the Defamatory Postings ceuse irreparable harrn to the

Plaintiffs' reputation.

55.

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

56_

At this stage, il is impossble to assss or otherwise determine the extent of the

dantages caused by the Defamatory Fostings.

57.

C.
58-

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

At the lnterlocutory Stage: the Balartce of lnconvenlerrces Favours the plaintiffs

ln light of the foregoing, it s abundantly clear that the balance of inconveniences favours
the Plaintiffs.

I /

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12

-11 -

59'
60'

6l'
62'

In fact, Mr' Lambert

and any of his accomplices, as the case may be would not

suffer
any prejudice should he be prevented from pursuing his defamatory
scheme.

Any limitation to Mr' Lambert's capacity to communicate in regaids to

the plaintiffs and
their business would he of n0 or limitecl effect compred to allowng Mr,
Lambert to
contnue spreding false and harrnful statements about the plaintiffs.
Freedom of speech does not allow one to so blatantly slander anothe/s
reputation.

Should lhe sought orders not be granted, the Plaintiffs' reputation will
continue to be
harmed.

.
63.

Necessity to hear the Motlon for lnterlocutory lnjuncffon as $oon ar possible

lt is crucial that thia Honourable Court issue the sought interlocutory ordrs as
soon as
possible, and in any evenl no tonger than five (5) days following
the filing of the present
proceedings, given the following reason:

a)

b)
c)

64.
65.
66.
87.

Mr. Lambert has recently increased the frequency of publication of

the
efamatory Postngs and continues to persistently, and on a daily basis, issue
such Defamatory postings;

The volume of trades of SAI's stock has reoently increased drarnatically, spiking
a|221,228,304 shares traded on or about June 19, 2015 (Exhibit p-12);
The price of sAl's stock has significantly declined over the last three months,
i,e.
94% of its velue over the last three months and 33% of its value over the tast
month (Exhibit P-12);

The recent evoluton of SAI's stock is highly alarming.

Moreover, considering the undeniable impact of Mr. Lambed's Defamatory postings on
Mr- Saleen's reputation, ths ongoing disparaging act has to stop forthwith.
ln short, this untenable siiuation rnust stop immediately and without delay.

The Plaintffs therefore request that the Mofion for Interlocutory lnjuncton be heard no
later than five (s) days of the filing of the present proceedings.

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-14-

79'

80,
8f

'

82'
83'

84'

oRDER Mr' Lambert to provide to the Plaintiffs'

counsel of record, within forty-eight (4g)
hours of the order t0 be issued, a written list all of
the aliases that he has used or is still
using when disseminatng, releasng, posting, publishing,
sharing, linking, or otherwise
communicating the Comments;
ORDER provisional execution of the conclusons
notwithstanding appeal;
RESERVE lhe Plaintiffs their rights following receiving
of the information refe'ed to in
paragraph 77 above, to seek such additional
relief es may be appropriate in the
circumstances;
ORDER that the Plaintiffs do not have to post any security
for costs herein;

DEGLARE that the order to be issued can be enforceable

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

oRDER that any person directed by this order not to do somerhing

shall not do it himself
or herself, nor through others acting on its, his or her behalf, or
on its, his or her
inslructions, or with its, his or her encouragement or acquiescence,
nor in any other way
whatever;

85'

Bo'
87

'

AUTHORIZE service of the order outside of legal hours and on

non-juridical days is
sufficient and valid for all legal intents and purposes irrcluding,
wthout limitation, for the
purposes of Ailicle 7s6 of the Gode of civit procerlure
of euebec;
DEoLARE that the prsentatlon of th Motion for lnterlocutory lnjunction
within five (s)
days of th filing of lhe present proceedings is sufficient and
valid;
DEGLARE that the order

to he issued wilt remain Valid and enforceable until final

juclgment ls rendered herein;

88'
89.

IS'SUE ny other order that this Court may find necessary or useful
in the circumstances;

THE WHOLE wth cost against Mr. Lambert;

At the Permanent Stase

g0'

GRANT this Motion to lnstitute Proceedings for Permanent lnjunction;

f\l 4U93 lJ, l

-15g1

oRDER the deierrdant, Frederic Lambert (,,Mr.

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

a)
b)
c)
d)

participatecl n, or are othenvise nvolved

in a 'Traudulent scheme,', a ,,fraud,,, a
"scam", a 'pump and dump schme" or any other
behaviour of that nature;

are being nveetigated by the u-s. Securities and Exchange

Commission or any
other organisation of that nature;
that the $aleer Persons have committed any crirninal or penal
infiactions; or
any other defamatory comrnents;

g2

ORDER provisional execution of the onclusions notwithstanding

appeal;

93.

DEGLARE that the order to be issued can be enforceable

agenst eny person, including
corporate prsons, who have prtiptd or othenryise collaborated
in the posting,
publishng or cmmunication of the Defarnatory postings;

94

oRDER that any prson drected by this order not to do something

shall not do it himself
ol herself, nor through others acting on its, his or her behalf, or on its, his or
her
instructions, or with its' his or her encouragement or acquiescence,
nor in any other way
whatever;

95.

AUTHoRIZE service of the order outside of legal hours and on

non-juridical days is
sufficient and valid for all legal intents and purposes
including, without limitation, for
the

purposes of Article 756 of the code of civilprocedure

of euehec,

vv

r r4vr

LV tJ

i\r +UYJ

I tr-Tvrilil

l, )l

-16.96

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

97.

THE WHOLE with cost against Mr. Lambert.

Montral, July 17,2018

E
&
Attorneys for the Plaintiffs

P
LL

-17

N +yJ t,

NOTICE OF PRESENTATION

To

Frederic Lambert
795, Chemin de la Baie

SanlEonifaoe, eubec GOX 2L0

-nd- John

oe and Jane Doe

Defendants

TAKE NoTlcE lhat the Moton for lnterlocutory and Permanent

lnjunction of the plantiffs
wlll be presented for decision before one of the Honoumble judges
of the supeor ourt of
in person or vfa vrdeoconference, n Tuesoay, juty 2g, 2019,
e rocated lz1?,6e Rue, $hawrnrgan, euebec, at i0:00 a.m,,
selmay be heard, in room 2.02.

th
at
0r

DO GOVERN YOURSELVES AGCORDINGLY.

Montral, Ju 20, 2015

L
&

Attorneys for the plaintifis

lE

f\l'

-18-

4893 P,

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

Take notice that the Plainliffs have filed

this action or applioailon in the office of the superlor
Court of the judicialdistrict of Saint-Mauric.

advocare;
EB

To file an answe

g !r

TiqijlLitjiTf'f."ffiifffi_,",1,1

Qubec, GgN

s Moilon.

lf you fall to flle an Appearance withtn the tfm limlt

indicated_, a judgment by default rrray be
rendered against vou wirhout turrher norice upon rhe

eipl oitr. ro--d;t ir

n will be preserrted before the Court on

of the Shawinigan Courthouse. On thet
less
with
the

ff.tli*

of the presenl Motion

to

Inslituta Proceedrirgq rhe ptainriffs disclosa rhe fottowing

P-t;

Printed extracts from SAI's website, erl liasse;

P.2l

sAl's Annual Report (fgrm. lO-K) for the year ended March g1, z01F
fled wfth
the U.S. Securilios and Exchange Commision;

P'3:

Llnkedln@ profll of Frederic Lambert, as of July 1T,ZO16i

P4:

Printed exlracts from ,,BlackSheepplanet" website, en

fbsse,;

P-5:

Printed xtrect from 'whots" wobsile

domain name registry;

P-6:

P'7:

information on ,,BfacksheepFlanet"

Printed extracts from "lnvestorsHub,com" website

July 16, 2015, en 'asso;

Printed extract . from 'lnvestorsHub.com,, website

Postlngs by F/dvstr, e /rasse:

P-8:
P-9;

Printed exttact from "lnvestorsHub.conr" websile

Automotive lnc., as of July 16, p0l5;

sample

- posfer

of

Defanratory

Summary for saleen

Printed extracl from "reddil.com" wesite - posilngs frorn

',Fredresla';

P'10: Ptinted extract from

"boarlreader.com" websile
webste as of July 16, Z01S;

P'11;

profilo of "Fredvosto, as of

Saleen,s Topic profil pg

Printed extracl from."BlackSheepFlanet" website - articte lilled Trying

to ride on
res/a's suess and the oTC lnvestors' Money pulirreo ny;rrJo
iai"u,r" n

July 15, 2014;

ssr

rv,

LvtJ

I t.-Tl'ltYl

-19P'12: Prlnted extracl ftom "lnvestorsHub.com'website

dated August 31,2014;

P''13: web form submisson from Frdric Lambert

P-14:

posting from ,,Fredvestof,

to sAl, dated August 1g, 2014;

Effieit fr.m Frderic Lambert to SAl, dafed August

21,2014;

P-1S; Prlnted

extrac,ts from "ZalKon.com" website;

P-16: Printed extract from SAI'$ website chart

from April 17,Z}ISto July 16,2015;

lllustrating the avolution of

sAl

stoclr

P'17;'Prinfod extract from 'Whole" webste - lnforrnation

on ,,ZalKon' domain name
regtstry

P-18: Prinled extract

oJ

proflle of ,Fred Lamberr' tinkad to the ,zalKon"

lF fry,lt"r

webslle, as of July 16, Z01g

P'19:

Prfnted extract of the Facebook profire of ,'Fred Lamberf,

as of Jury 16, 2015.

The exhltts being annexed hereto.

Request for transfer of a smatt claim

t exceed

$7,000 and if you could have flled

esf to the clerk for

of MlProcedurc
could be liable for
Montral, July 12,2018

BLAKE CASSELS &

846343.tr

Altorneys for the plalntiffs