Acknowledges in its own way that the Sept 15 default was intentionial and that the transfer of Ten cash and delay of sale, and the ad hoc 8% noteholders support of the Asper bid for Canwest assets part of the applicants plan
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http://65.200.149.14/cmi/docs/Responding%20Factum%20of%20the%20Applicants%20re%20Leave%20to%20Appeal.PDF
