1. UPM (Corporation and Shareholders) v. Berg (“Chairman and Senior Executive Officer”) Repap Board of Directors Ontario Superior Court of Justice [Commercial List] , Lax J. Group 6 : Mini Boparai Sean Frank Alex Joseph David Milia Jon Remmer Roehl Romero

2. Oppressed Mr. Berg UPM-Kymmene Miramichi Inc. Shareholders

3. Mr. Berg breach his fiduciary duties to Repap? Compensation Committee & Board of Directors fail obligations to establish a prudent or reasonable process? Berg Agreement unfairly disregards shareholders?

4. "business judgment rule" shield Agreement from judicial scrutiny? Berg knowingly or recklessly make false representations to Board which relied on in approving the Agreement?

5. Directors & Corporations Shareholders Due Diligence Oppression Remedy

6. the defence rests