1.

June 2015-Ador negotiated with DON ffor acquisition of Brand (Empire)

2. Feb. 2016-SPA was executed
3. Feb. 25, 2016-ADOR and Empire signed SPA (Don also signed but not a party) and Deed of
Guaranty and Indemnity (not signed by Ador) and Cover Agreement signed by DON and EMPIRE
4. After FEB 2016-DON agreed that Ador would acquire 95.8% of Brand from Empire (US$ 280.7
million)
5. June 2016-Ador paid Empire US$ 250 million for purchase of shares of Brand; Ador paid another
30 million into escrow-to be released by July 2017 on condition that no additional liability of
Brand was discovered;
6. Jan. 20 2017-Brand was made to pay 82million as addl taxes and penalties
7. ADOR set off escrow amount
8. After lapse of 20 days Empire failed to reimburse Ador
9. Ador demanded payment from DON under Contract of Guaranty
10. DON alleges that guarantee is not valid
11. RTC decision issued invalidating Guaranty
12. DON alleges that it was EMPIREs fault that Brand did not pay its taxes