Gowling WLG (Canada) LLP is a global law firm, with expertise in commercial litigation and insolvency matters.

Gowlings is legal counsel to an Ad Hoc Committee of shareholders of Crystallex International Corporation (the "Committee") in the ongoing CCAA proceeding in Toronto, Canada. More information on the proceeding can be found on the Crystallex Website here.

Gowlings' mandate is to act on the instructions of the Committee to represent the interests of the Committee members and shareholders who opt in to be represented by the Committee (the "Opt Ins"). This includes:

• assisting the Committee to maximize the financial interest of Opt Ins in the arbitration award arising from the arbitration between Crystallex and the Bolivarian Republic of Venezuela;
• informing and advising the Committee with respect to their rights and interests in the CCAA proceeding and in any related proceeding;
• engaging in negotiations with the Monitor and other stakeholders; and
• contributing to the efficiency of the proceedings by being the single point of contact between the Committee, the Monitor, and other stakeholders.

If you are a current shareholder of Crystallex and are interested in becoming an Opt In, please contact David Cohen, Cliff Prophet or Nick Kluge.

The Committee wishes shareholders to take note of important information which may be relevant to their decision as to whether to seek to become an Opt In represented by the Committee:

1. While it is possible that a shareholder who is NOT an Opt In may derive benefit from the efforts of the Committee and GWLG, neither the Committee nor GWLG represent such shareholders and they owe no duties to such shareholders.
   
   Specifically, the Committee need only consider the interests of the Opt Ins. For example, in representing the Opt Ins the Committee must consider and may choose to accept any settlement offer proposed to the Committee where such an offer includes benefits only for the Opt Ins, excluding other shareholders.


2. Gowling takes instructions from the Committee only. In the normal course, Opt Ins may contact the Committee to raise issues and concerns and the Committee will consult with Gowlings as the Committee deems appropriate.


3. Opt Ins are prohibited from acting in any manner that impairs or otherwise interferes with the Committee executing its mandate. If the Committee deems an Opt In to be acting in such a manner, the Committee may cause that Opt In to cease to be represented.

Motion Materials

1. Crystallex Motion Record of the Moving Parties dated October 30, 2015
2. Factum of the Moving Party dated January 6, 2016;
3. Book of Authorities of the Moving Party dated January 6, 2016;
4. Revised Appointment Order for motion returnable January 11, 2016;
5. Comparison between the Draft Order and revised Appointment Order;
6. Revised Committee By-laws; and,
7. Comparison between draft committee by-laws and Revised Committee By-laws.
8. Motion Record re Opt-In Committee dated February 17, 2016
9. Sworn Affidavit of Justin Fine regarding Opt In Committee, dated 14 March 2016
10. Sworn Affidavit of Justice Fine re Urgency of Motion to Establish a Shareholders Committee, dated 14 March 2016
11. Endorsement of Justice Newbould re Scheduling Motion, dated 17 March 2016
12. Factum of the Proposed Committee of Shareholders, dated 4 April 2016
13. Responding Factum of the Company , dated April 6, 2016
14. Responding Motion Materials of the Company , dated April 6, 2016
15. Responding Factum of the DIP Lender, dated April 11 2015
16. Reply factum of the Proposed Committee of Shareholders, dated 8 April 2016
17. Supplementary Record of DIP Lender for Motion, dated April 11 2016
18. Reply Factum of the DIP Lender, for 11 April 2016 Motion

Court Orders

• Unofficial Transcription of the Reasons of Justice Newbould Decision, dated 18 April 2016
• Endorsement of Justice Newbould Decision, dated 18 April 2016

Correspondence

• Crystallex Letter to M Konyukhova dated December 8, 2015