Mostly just bickering about the appointment of the "special master" that will be appointed to sell the shares.

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As  directed  by  the  Court,  the  parties  and  ConocoPhillips  exchanged  their  respective  lists  of  potential candidates on February 4, 2021.  Following multiple meet and confer sessions as well as separate conversations with several of the proposed  special masters, the parties and ConocoPhillips were unable to reach agreement on a single candid ate. They have, however, agreed to limit the number  of  candidates  put  forward  to  this  Court  to  one  nominee  from  Crystallex,  Judge  Sue  L.  Robinson  (ret.),  and  two  nomin ees  jointly  from  the  Republic  of  Venezuela,  PDVSA,  PDVH,  CITGO, and ConocoPhillips, Robert Pincus and David Schulte.

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Supplemental Position of the Republic, PDVSA, PDVH, and CITGO

On February 12, 2021, the Republic, PDVSA, PDVH, and CITGO filed Notices of Appeal of the Court’s January 14 Order, D.I. 239, 240, 241, and jointly filed a motion to stay the sale proceedings in the District Court pending the appeal, D.I. 242 , 243.  Thus, the special master proposals in this letter  are  made  subject  to  the  appeal  and  the  motion  to  stay.    Assuming  the  sale  process  goes  forward, as Crystallex has been repeatedly advised, the Republic, PDVSA, PDVH, and CITGO will do everything they can to support the special master and a reasonable sale process.  Indeed, it is in their best interest to do so.  Although rates for Messrs. Pincus and Schulte have been proposed, payment for financial and legal advisors to the special master must still be determined.  During the meet and confer process, PDVH a nd CITGO raised with Crystallex  that its $1 million advancement offer would likely be insufficient, that PDVH and CITGO were discussing how and to what extent they would contribute, and that the  parties should meet and confer to further address payment of the special master.  PDVH and CITGO are willing to consider advancing at least a portion of these fees in order to ensure the most professional sales process and to maximize the value of the sale of PDVH shares, and request that the parties continue to meet and confer, on a schedule ordered by  the  Court,  over  payment  of  the  special  master  and  the  special  master’s  advisors,  including  allocation of the advancements amongst the interested parties.