Operation Arms Length · Parallel Investigation

The document library

Every document this site relies on, hosted and organised by register, with what each is and what it shows. Plus the other register that matters: the documents referred to in the record that are not public and not held.
60+ documents · 6 registers v4 · 2026-08-11
⚖️
This is a private, independent, open-source investigation. It is not affiliated with, authorised by, or endorsed by Lithium Ionic Corp. (LTH), Emerita Resources Corp. (EMO), or PM Super Fund. It is compiled from public records for information only. Presumption of innocence: every named individual and entity is presumed innocent; the OSC application and both court proceedings are unproven and untested. Nothing here is legal, financial, or investment advice.
SOURCES

The document library

Every source document hosted on this site, organised by register. Each is the document cited in the text, hosted so a reader can check any claim at the source without an account on any registry.

How the Brazilian registry acts are hosted. The seventeen JUCEMG Certidões de Inteiro Teor (certified full-content copies of registry acts) are hosted in redacted form: national identity numbers, dates of birth and residential addresses are covered, and nothing else. Names, corporate addresses, capital figures, instrument dates, professional credentials, act and protocol numbers and the JUCEMG certification block on every page are preserved, so each act remains revalidatable against the registry at jucemg.mg.gov.br. The redacted copies are re-rendered scans; the originals remain available to any authority from the registry itself. The same principle is applied to the United Kingdom filings: the partial (month and year) birth dates that Companies House prints on officer and control filings are covered in the copies hosted here, and everything else, including every name, address of record and notification date, is untouched; the unaltered originals are permanently available from Companies House itself.

Proceedings

DocumentSize
OSC Application for Enforcement Proceeding, 9 April 2026
The starting allegations: the trust, the diversion, the relinquishment statements, the founder shares. Unproven.
296 KB
Emerita Resources Corp. Statement of Claim, 29 July 2026 (court-record copy)
Ontario Superior Court of Justice CV-26-00015174-0000: Emerita's own action against five individuals, Lithium Ionic Corp., Falcon Metais and MGLIT. Untested.
286 KB
PM Super Fund demand, 14 May 2026
The shareholder demand that preceded the leave application and Emerita's claim.
259 KB

Brazil: JUCEMG certified acts, MGLIT Empreendimentos Ltda. (formerly Malta do Brasil Mineração Ltda.)

DocumentSize
Certidão de Inteiro Teor, act D 31211211627
Constitution as Malta do Brasil Mineracao Ltda., instrument 29 Oct 2018, registered 5 Nov 2018
2.9 MB
Certidão de Inteiro Teor, act RD 8038042
3a alteracao, instrument 1 Oct 2020, registered 5 Oct 2020: 999 quotas from Malta Minerals PLC to Diniz personally, no price stated; rename to MGLIT; annexes include the 4 Dec 2018 power of attorney
14.4 MB
Certidão de Inteiro Teor, act RD 8859466
4a alteracao, instrument 1 Oct 2021, registered 21 Oct 2021: 999 quotas to Li-Ionic Inc.; annexes include the buyer’s Ontario incorporation and the 7 Jul 2021 power of attorney
15.5 MB
Certidão de Inteiro Teor, act RD 9180632
5a alteracao, instrument 10 Feb 2022: last quota to Li-Ionic Inc.; retrospective consent to the 2021 Forbes transfer; capital to R$ 3,000,000
15.4 MB
Certidão de Inteiro Teor, act RD 12546327
Act of 10 Feb 2025, registered 28 Feb 2025, annexing a fresh Lithium Ionic Holdings Corp. power of attorney
8.0 MB
Certidão de Inteiro Teor, act RD 13887655
21a alteracao, instrument 13 May 2026, registered 21 May 2026: capital injection to R$ 213,485,662, 34 days after the OSC application
4.2 MB

Brazil: JUCEMG certified acts, Falcon Metais Ltda.

DocumentSize
Certidão de Inteiro Teor, act D 31208091870
Constitution, instrument 3 Mar 2008, registered 18 Mar 2008
6.9 MB
Certidão de Inteiro Teor, act D 4113032
2a alteracao, instrument 25 Mar 2009, registered 2 Apr 2009: Amazon Potash Corp. enters holding 99.99998%; Diniz signs for all three parties
17.6 MB
Certidão de Inteiro Teor, act RD 5739050
8a alteracao, instrument 16 Mar 2016, registered 25 Apr 2016: capital reduced to R$ 6,079,458 with restitution to Amazon Potash, three months before the option agreement
8.3 MB
Certidão de Inteiro Teor, act RD 7333978
10a alteracao, instrument 21 May 2019, registered 4 Jun 2019: Forbes Empreendimentos Minerais acquires BS1’s quota "conforme acerto apartado"
4.6 MB

Brazil: JUCEMG certified acts, Emerita do Brasil Mineração Ltda. (formerly Irati Energia Participações Ltda.)

DocumentSize
Certidão de Inteiro Teor, act D 31210203906
Constitution as Irati Energia Participacoes Ltda., instrument 10 Jun 2014, registered 12 Aug 2014
11.5 MB
Certidão de Inteiro Teor, act RD 6391670
3a alteracao, instrument 12 Sep 2017, registered 19 Dec 2017: Emerita acquires the company, no consideration stated; renamed Emerita do Brasil; Hood signs for Emerita
16.5 MB
Certidão de Inteiro Teor, act RD 8815838
Distrato, instrument 21 Sep 2021, registered 27 Sep 2021: dissolution; the partners receive nothing; books to Diniz’s custody
12.1 MB

Brazil: JUCEMG certified acts, Valitar Participações S.A.

DocumentSize
Certidão de Inteiro Teor, act D 31213755276
Constitution records of the Valitar vehicle (as a limitada)
2.8 MB
Certidão de Inteiro Teor, act D 31300154173
Transformation into Valitar Participacoes S.A., 8 Mar 2023; Lithium Ionic Holdings Corp. a direct 10% shareholder
12.0 MB
Certidão de Inteiro Teor, act RD 10599098
EGM of 2 Jun 2023: creation of the preferred class convertible into 99.99% of voting capital, held by Lithium Ionic Holdings Corp.
7.3 MB
Certidão de Inteiro Teor, act RD 11749568
AGO/relocation acts of 30 Apr 2024 (inter-municipal relocation to Belo Horizonte)
8.0 MB

Brazil: gazette, mining agency and federal registers

DocumentSize
DOU, 1 February 2021
Anuência prévia and averbação of the cessão total, Falcon Metais to MGLIT: the only registered assignment of the seven processos in the ANM data.
1.6 MB
DOU, 8 March 2021: Despacho Relação nº 51/2021
All seven processos in 60-day cessão compliance phase to MGLIT.
2.4 MB
ANM SCM Cessões dataset, Falcon / Bandeira extract (CSV)
The assignments record for the seven processos from the ANM open-data portal.
2 KB
ANM TAH dataset, Falcon / Bandeira extract (CSV)
Every recorded annual-fee payment on the seven claims: payer, date, amount.
4 KB
Receita Federal CNPJ comprovante: Falcon Metais Ltda.
Federal register record, emitted 21 May 2026.
403 KB
Receita Federal CNPJ comprovante: MGLIT Empreendimentos Ltda.
Federal register record, emitted 21 May 2026.
421 KB
Receita Federal CNPJ comprovante: Lithium Ionic Holdings Corp.
The Canadian owner's Brazilian registration, emitted 21 May 2026.
365 KB
Receita Federal CNPJ record: Forbes Participações Ltda.
The former Forbes Empreendimentos Minerais Ltda., Falcon's second corporate sócio.
197 KB

United Kingdom: Companies House, Malta Minerals PLC (11450032)

DocumentSize
Incorporation (NEWINC), filed 5 July 2018
Constitution of the vendor's owner; subscribers Gower, Tallarico and Diniz.
1.2 MB
AP03: secretary appointed, 10 September 2018
Christine Lagace appointed company secretary.
17 KB
TM02: secretary terminated, 10 September 2018
Karine Desjardins ceases as secretary the same day.
13 KB
SH50: application for trading certificate, filed 25 September 2018
A public company may not trade or borrow before this certificate.
67 KB
CERT8A: trading certificate, 28 September 2018
The certificate itself.
16 KB
AP01: director appointed 8 November 2018, filed 18 July 2019
David Patrick Gower appointed director; the filing reached the register 252 days later.
157 KB
SH01: return of allotment, 8 January 2019
8,285,000 shares allotted to 21 people, paid otherwise than in cash, by promissory note.
129 KB
CS01: confirmation statement made up to 4 July 2019
The only register of members the company ever filed: 24 holders, 18,685,000 shares. Names and share counts only.
74 KB
AP01: director appointed 9 July 2019
Peter James Shippen appointed director.
156 KB
CH01: director details changed, filed 6 September 2019
Change to Shippen's registered details.
130 KB
AA: dormant accounts to 31 July 2019, filed 23 December 2019
Dormancy declaration signed by Gower; states £186,850 as cash at bank, difficult to reconcile with the promissory-note allotment.
21 KB
CS01: confirmation statement filed 16 July 2020
Capital only, no shareholder details: the last statement before the vehicle was disposed of.
28 KB
GAZ1: first gazette notice for compulsory strike-off, 6 July 2021
The registrar begins striking the company off.
11 KB
DISS16: strike-off suspended, 17 August 2021
"An objection to the striking off has been received by the Registrar." The objector is not named; the suspension runs two years and four months.
8 KB
GAZ2: final gazette, dissolved 12 December 2023
The company is dissolved while the Brazilian registration it opened remains active.
6 KB
Register capture: company overview, 6 August 2026
The company's public page as captured.
80 KB
Register capture: officers, 6 August 2026
The officer list as captured.
78 KB
Register capture: persons with significant control, 6 August 2026
The PSC register as captured: the 2018 notifications, never updated after the 2019 allotment.
206 KB
Register capture: filing history index, 6 August 2026
The complete filing index as captured.
91 KB

Canada: certified Ontario Business Registry and Corporations Information Act filings

DocumentSize
Profile report: Emerita Resources Corp. (OCN 1981913)
Certified, retrieved 22 June 2026.
262 KB
Profile report: Lithium Ionic Corp. (OCN 2802172)
The former POCML 6 Inc. Certified, retrieved 22 June 2026.
254 KB
Profile report: Lithium Ionic Inc. (OCN 2851751)
The PrivateCo, incorporated 5 July 2021 as LI-Ionic Inc. Certified, retrieved 22 June 2026.
234 KB
Articles: 1000088600 Ontario Inc.
The single-purpose merger sub, incorporated 20 January 2022.
185 KB
Profile report: Lithium Ionic Holdings Corp. (OCN 1000208066), 22 June 2026
Certified; shows Gower and Guy as directors and no officers on file as at its date. Superseded by the filings below.
232 KB
Amalgamation Agreement, executed 7 February 2022
Signed by D'Onofrio for POCML 6 and the Subco and by Lopez for the PrivateCo; defines "Brazil Subco" as MGLIT.
422 KB
Articles of Amalgamation, 19 May 2022
Lithium Ionic Inc. + 1000088600 Ontario Inc. form Lithium Ionic Holdings Corp. (Amalco).
208 KB
Certificate of Amalgamation, 19 May 2022
The certificate for the amalgamation.
162 KB
Initial return, 30 March 2026
The Amalco's initial return, filed nearly four years after formation.
201 KB
Notice of Change, effective 8 July 2026
Records that Gower and Guy ceased as directors on 20 April 2026, with Hylands elected sole director that day; 79 days after the effective date.
203 KB
Notice of Change, 23 July 2026
Registers the subsidiary's only officer, bearing an appointed date of 3 November 2022.
182 KB
Annual return 2023, filed 27 July 2026
Filed three minutes apart from the 2024 return.
168 KB
Annual return 2024, filed 27 July 2026
Filed three minutes apart from the 2023 return.
168 KB
Annual return 2025, filed 31 July 2026
The last of five certified filings in twenty-three days.
168 KB
Profile report: Lithium Ionic Holdings Corp., 8 August 2026
Certified; Hylands sole director, Olesinski sole officer.
238 KB

SEDAR+ filings hosted here

DocumentSize
EMO Agency Agreement and Schedule "A", filed 13 January 2021
Signed 11 December 2020; Schedule "A" lists all seven processos as "the Corporation's Mining Properties".
431 KB
EMO audited annual financial statements FY2018, 29 January 2019
Carries the option's stated expiry and its September 2018 exercise, unreconciled; auditor UHY McGovern Hurley LLP.
1.1 MB
EMO audited annual financial statements FY2019, 28 January 2020
The Salobro write-off and the collapse of the Brazilian cost base.
1.4 MB
EMO audited annual financial statements FY2020, 28 January 2021
Note 5(b): a "100% interest in the Falcon Litio MG Project", a month after the claimed transfer.
1.3 MB
EMO annual MD&A, 28 January 2022
Repeats the "as of December 2020" relinquishment.
680 KB
EMO interim MD&A, 27 May 2021
The first "relinquished" statement, with no date attached.
468 KB
EMO interim MD&A, 26 August 2021
The relinquishment re-dated to "as of December 2020".
608 KB
EMO news release, 15 July 2021
The CAD 20,000,750 bought deal.
38 KB
EMO news release, 20 April 2026
Gower and Guy resign at Emerita.
101 KB
POCML 6 Inc. Filing Statement, 12 May 2022
The acquirer's own listing document: the 23 December 2020 acquisition sentence, the founder-share tables, the non-arm's-length disclosures.
2.0 MB
LTH report of exempt distribution, 15 December 2021
The CAD 0.20 placement.
485 KB
LTH report of exempt distribution, 23 December 2021
The second tranche.
485 KB
LTH report of exempt distribution, 16 February 2022
The CAD 0.70 subscription receipts.
516 KB
LTH news release, 24 May 2022
Trading begins on the TSXV.
342 KB
LTH news release, 1 June 2022
Option grants at CAD 1.24.
146 KB
LTH NI 43-101 technical report on Bandeira, 11 August 2023
The first technical report on the former Falcon ground as LTH's "flagship asset".
7.3 MB
LTH NI 43-101 technical report on Bandeira, 27 May 2024
Records the TAH instalment history on the flagship claim.
12.5 MB
LTH management information circular, 17 June 2024
Director biographies, including Diniz's Forbes & Manhattan history.
1.9 MB
LTH management information circular, 22 July 2025
The 2025 circular.
19.3 MB
LTH audited annual financial statements FY2025, 5 June 2026
Going-concern uncertainty; "Regulatory Matters" key audit matter; related-party note on Falcon Metais and Valitar.
777 KB
LTH news release, 14 April 2026
The Waratah requisition.
155 KB
LTH news release, 20 April 2026
Gower, Guy and Diniz resign as directors; Lopez as Corporate Secretary.
201 KB
LTH news release, 22 April 2026
Deloitte pauses the FY2025 audit; MCTO applied for.
178 KB
LTH news release, 5 June 2026
The FY2025 filings and the audit-delay explanation.
167 KB

Figures

DocumentSize
The entity swimlane (interactive)
Six entities, one time axis; every mark carries its source on hover.
57 KB
The entity swimlane (PNG, high resolution)
Static export of the same figure.
1.4 MB
The entity swimlane (PDF)
Print export of the same figure.
199 KB

Referred to but not held

An investigation is disciplined by what it does not have. The following documents are referred to in the record but are not public and are not held here; several would settle questions this site can only frame. Anyone holding a copy can reach this investigation at the address in the footer.

DocumentWhat it would settle
The binding letter agreement of 13 June 2016 (the Falcon / Option Agreement itself), and any amendment to itWhether the option could be extended by mutual agreement, the exact trust and fee terms, and the royalty and Resource Consideration clauses as agreed rather than as described
The TSXV filing for the 12 September 2018 third-tranche issuanceThe recipient of the exercise tranche
The "release letter" dated 5 February 2020 attributed to EmeritaThe central disputed document; its provenance is contested (OSC AEP ¶¶33 to 35)
The 23 December 2020 cessão instrument itselfThe terms, and any price, of the Falcon Metais to MGLIT assignment; it is not a listed material contract in the POCML 6 Filing Statement and appears on no register searched
JUCEMG act RD 7104229 (instrument 4 December 2018)The act by which Malta Minerals PLC entered the vehicle, referred to in the recitals of the 2020 instrument
JUCEMG act RD 6326251 (instrument 11 August 2017)Where Forbes and Manhattan (Barbados) Inc. leaves the Falcon Metais register
The "acerto apartado" side agreement referred to in JUCEMG act RD 7333978The actual terms of the 2019 transfer of Falcon’s minority quota
MGLIT’s intermediate capital-increase acts, 2022 to 2026The step-by-step path from R$ 3,000,000 to R$ 213,485,662
Operation Arms Length, the Falcon / Bandeira case file. · Updated 11 August 2026 (v4) · the public companion to the parallel investigation. This is a private, independent, open-source investigation compiled solely from public records. It is not affiliated with, authorised by, or endorsed by Lithium Ionic Corp., Emerita Resources Corp., the Ontario Securities Commission or any other government or regulatory body, any court, or PM Super Fund.
Primary sources: OSC Application for Enforcement Proceeding (9 April 2026); Emerita's Statement of Claim, Ontario Superior Court of Justice CV-26-00015174-0000 (29 July 2026, court-record copy); EMO continuous disclosure 2016 to 2026 and the Agency Agreement with Schedule "A" (SEDAR+); POCML 6 Inc. Filing Statement (SEDAR+, 2022-05-12); LTH continuous disclosure including the FY2025 audited statements (SEDAR+, 2026-06-05); DOU / ANM publications and the ANM open-data TAH and Cessões datasets; JUCEMG Certidões de Inteiro Teor (seventeen certified acts, hosted in redacted form); Brazilian Receita Federal CNPJ records; Companies House, Malta Minerals PLC 11450032; certified Ontario Business Registry records through 8 August 2026; O Globo (Lauro Jardim), 2026-04-14; and 2026 LTH / EMO governance news releases. The document library lists every hosted document.
Presumption of innocence. Every named individual and entity is presumed innocent; the OSC application is an unproven allegation, both court claims are untested, and the Brazilian matters are disputed and unresolved. Gatekeepers and third parties named here are not OSC respondents and are presumed to have acted properly. Non-respondent family members are referenced by relationship only. No material non-public information is used. Nothing here is legal, financial, or investment advice.