Medi --

Dear ICC member,

In the interests of transparency, we are communicating to you that the ICC has been served a legal motion by applicants Babak Payami, Kamnoosh Shahabi, Mehrdokht Hadi, and Shayan Moin ("Payami et al."). You may find the full motion at this link. Because the motion is nearly 192 pages, we have extracted two of the demands of the motion, regarding the removal of directors and stopping the upcoming SGM, respectively, below:

7. An order pursuant to section 332 of the Corporations Act, R.S.O. 1990 (“Act”) removing the Directors and an order appointing an interim board of directors (“Interim Board”) until the 2019 ICC Annual General Meeting (“AGM”) and election have been held

12. An order for an interim/interlocutory injunction restraining the ICC or any person acting on its behalf or at its direction from holding the Special General Meeting ("SGM") currently scheduled for October 31st, 2020, from introducing any motions with respect to the "future of the organization" or from making an assignment into bankruptcy pending a final determination by this Honourable Court of the matters at hand

We will keep you posted as further developments occur.

Sincerely,

Board of Directors,

Iranian Canadian Congress