July 22, 2003

Court No: 25-082885

Estate No: 25-082885

Trustee’s Third Report

In the Matter of the Bankruptcy of Bartizan Capital Corporation

 

Assignment

On September 9, 2002 an Assignment for the general benefit of creditors was made by Bartizan Capital Corporation (“Bartizan” or the “Company”) and was filed with the Official Receiver on September 10, 2002. Operations of the Company have been discontinued.

Appointment of Inspectors

The First Meeting of Creditors (“FMC”) was held in Calgary on September 26, 2002. It should be noted that no Inspectors were appointed at the FMC.  Since the first meeting and in the absence of Inspectors, the Trustee has sought the approval of the court in respect of the disposal of assets or the settlement of other matters including outstanding litigation involving the Company.  

The Trustee has been in contact with counsel for The Milton Shoong Foundation (“Shoong”), a creditor with a sizable claim against the Company. Counsel for Shoong has indicated that a representative of Shoong is willing to act as an Inspector, and as such a Second Meeting of Creditors is to be convened on Friday August 8th, 2003 at 10:00 AM in Calgary, Alberta for the purpose of appointing Shoong as an Inspector in the estate.  

Books and Records

The Company’s corporate filings, including GST and corporate tax returns have been completed up to the date of bankruptcy.

Canada Customs and Revenue Agency has contacted the Trustee with respect to arranging for payroll and GST audits on the Company’s records. These audits are expected to be conducted shortly.

Assets

The Trustee has continued to investigate matters outstanding as at the date of the Trustee’s Second Report, being December 20, 2002. These issues are discussed below in reference to each of the assets listed in the Company’s Statement of Affairs.


Cash and Funds Held in Trust

As at June 30, 2003, the Trustee has $381,580 in trust. It should be noted that $100,000 is also being held in trust by Parlee McLaws pledged as security by Bartizan’s Director’s in respect of Directors and Officers Liability Insurance. These funds were pledged to indemnify the Company’s Director’s and Officers’ (“D&O”), as the Company was unsuccessful in its efforts to secure D&O coverage through traditional channels. The D&O of Bartizan have filed secured claims in respect of these funds. As noted in the Trustee’s report of December 20, 2002, Hustwick Wetsch was holding $50,000 in trust in respect of an outstanding legal matter. This matter has since been settled and approved by the Court with all funds being released under the settlement agreement.

Amounts Due From Shareholder

As at the date of this report, $210,883 was owing to the Company in respect of funds advanced by way of a shareholder loan to Keith Talbot, a former Director. The Trustee has requested repayment of this loan and Mr. Talbot has responded that he does not believe that this debt is owing to the Company. Mr. Talbot has not provided sufficient evidence to indicate that this amount has been repaid. Consequently, the Trustee has instructed counsel to proceed with legal action regarding the repayment of this amount.

Investments in Real Estate

As at the date of Bartizan’s last audited financial statement, the Company had investments in two real estate properties, one located in Miami, Florida and the other in Regina, Saskatchewan.

The Florida property was valued by the Company at $1,083,593 as at December 31, 2001. Further documents provided to the Trustee indicate that ownership of the property is in question. The Trustee’s legal counsel has been instructed to investigate this matter to determine if Bartizan does in fact have an interest in this property. As at the date of this report, Trustee’s counsel has not made any determinations with respect to the ownership of this property.

The Trustee had entered into an agreement to sell a 28 unit apartment complex located in Regina, Saskatchewan. The sale was completed in early 2003 from which the net proceeds to the estate totaled $ 240,429. The corresponding mortgage on this property has been discharged.

Mortgages and Notes Receivable

As noted in the Trustee’s Preliminary Report, the Trustee has confirmed the full repayment of all outstanding mortgages with the various legal parties involved in each particular transaction. Additionally, the Trustee continues to collect funds in respect of a mortgage receivable of $45,009 that is secured by real property in Sangudo, Alberta.


Other Investments

The Company has a number of investments including investments in private companies, investments in joint ventures, and investments in wholly owned subsidiaries.

Investment in AMC Technologies Corporation

AMC Technologies Corporation (“AMC”) is a private Alberta company established to develop and supply micro fabricated products for bio analysis and telecommunications.

According to Bartizan records, the Company purchased 3,408,333 shares of AMC Technologies Corporation (“AMC”) with a book value of $369,621. However, we have been unable to locate any documentation to substantiate the nature of this investment. AMC was contacted by the Trustee to confirm the amount and nature of this investment and was informed through their counsel that they had no record of having received funds for investment in AMC from Bartizan.

The Trustee has received documents from AMC counsel and Lawrence Cunningham (“Cunningham”), the Company’s former solicitor in respect of this matter. The AMC documents indicate that the shares were issued in Cunningham’s name on October 14, 2000. Subsequent to the issuance of the shares, the shares were subject to a Hypothecation Agreement dated November 14, 2000. This agreement indicates that the shares were pledged as security in respect of a purchase agreement between AMC and Micralyne Inc. and were eventually realized on by the secured party when the Company defaulted on its obligations. The Trustee is in the process of analyzing all information with the aid of counsel to determine if there are any opportunities remaining in which the Trustee might realize some value from this investment.

Investment in Consolidated Kaitone Holdings Ltd.

The last audited financial statements for the Company indicated ownership of common shares in Consolidated Kaitone Holdings Ltd. (“Kaitone”) a company trading on the Toronto Venture Exchange.

Bartizan records indicate a book value of $74,186 for the Kaitone shares; the number of shares however is unknown. As noted in the Trustee’s previous reports, we have, despite our efforts, been unable to confirm ownership of Kaitone shares. Accordingly, the Trustee has instructed counsel to issue a demand letter to Bank Hapoalim B.M. (“Hapoalim”) confirming all transactions and any other details in respect of the Company’s account from the date of it’s inception. As at the date of this report, we have not yet received any information from Hapoalim in this regard.


Investment in 955091 Alberta Ltd. (a Joint Venture)

This joint venture was established to develop and market single and multi-family homes in Fort McMurray, Alberta.

As noted in the Trustee’s report of December 20, 2002, the Trustee had not intended to issue a   Statement of Claim against Larcon for the unpaid monies advanced to the joint venture until such time as Inspectors were appointed. However, the Trustee has decided to go forward with issuing the Statement of Claim in the absence of Inspectors and has been given approval by the Court to do so. As at the date of this report, a Statement of Defense has not yet been received. The Trustee will evaluate potential courses of action with respect to finalizing this matter  

Investment in Diamond Holdings LLC (“Diamond”)

As noted in the Trustee’s Preliminary Report, the value of this investment is tied to the legitimacy of the quitclaim registration on the Miami property. Trustee’s counsel is endeavoring to determine the nature and extent of the Company’s interest in this property.

Investment in 3851281 Canada Inc. o/a Overseas Development Corp. (“Overseas”)

Bartizan is believed to have purchased shares for $149,800 in the above company whose principal business was to develop and market single and multi-family homes in a joint venture with the Government of Jamaica. It should be noted however that 3851281 Canada Inc. (“385”) is a shareholder in Overseas Development Corp. along with Bartizan, rather than 385 being previously identified as the company in which Bartizan had invested.  It should also be noted that a corporate search has indicated 385 has changed its name to A&W Trade Marks Inc.

The Trustee has met with legal counsel to 385 to discuss the nature of their involvement with Overseas. It should be noted that according to Tony Mayer, a former Director of Bartizan that the Unanimous Shareholder Agreement (“USA”) in respect of Overseas was executed by Khan Agha (“Agha”) on behalf of 385. After meeting with counsel for 385, various corporate documents were produced indicating that Agha was never a Director or Officer of 385 and, as such, Agha was not in a capacity to enter into such an agreement. A copy of the Notice of Directors effective as at the date the USA was entered into is attached as Appendix “A” to this report.

The execution of the USA by an unauthorized representative of 385 has raised serious issues regarding the legitimacy of Overseas. It should be noted that Agha had access to the monies advanced to Overseas and that all efforts made by the Trustee to contact Agha have been unsuccessful. It is the intention of the Trustee to refer this matter to the RCMP for investigation.    

Investments in Bartizan Management and Bartizan Capital (US) LLC

These companies are wholly owned subsidiaries of Bartizan and contain no cash or other assets. As such, the value of these investments is nil.

Investments in Kingman Fund Inc., Kingman Mortgage Investment Fund and Kingborough Equities

These companies are wholly owned subsidiaries of Bartizan that were advanced funds from the Company. The Trustee’s information regarding these investments is limited to unaudited Notice to Reader financial statements for all companies dated June 30, 2001. Details regarding the nature of these investments are not known, however, the financial statements indicate that there are no assets in these companies and all liabilities are owed to Bartizan.

Claims of Creditors

As at July 22, 2003, Alger & Associates Inc. has received provable claims for $1,827,532 with known claims according to the Statement of Affairs filed by the company totaling $14,285,226. The claims are broken down as follows:

Per Statement
Of Affairs

Proven
Secured $ 971,804 $ 20,000
Preferred $ unknown $ 6,018
Unsecured $13,309,183 $1,801,514
Total $14,285,226
===========
$1,827,532
===========

Pending Legal Actions

As noted in the Trustee’s Preliminary Report, the Company is involved in a number of outstanding legal actions. We have recently achieved settlement on a longstanding lawsuit.  The Company had previously deposited the value of a former trade’s lien together with security for costs.  On application to the court, settlement was achieved and Discontinuance of Action filed.  Counsel for the Trustee is in the process of finalizing full and final releases.

Receipts and Disbursements

Attached, as Appendix “B” to our report is a statement of Receipts and Disbursements to July 18, 2003.

Realization and Projected Distribution

Given the complex nature of the debtor’s affairs, including the number of contingent claims that may exist, it is impossible for the Trustee to accurately project the realization and distribution to the creditors.


Other Matters

Notification of RCMP

As a result of missing information on a number of investments made by the Company, the legitimacy of these investments have been placed into question. As such, the Trustee believes that should additional information to support these transactions not be found, that a request will be made to the office of the Superintendent of Bankruptcy to consider a police investigation.

 

DATED at Calgary, Alberta, July 22, 2003   ALGER & ASSOCIATES INC.
(FORMERLY COLLINS BARROW
LIMITED)