Operation Arms Length · Parallel Investigation

Recurring parties and gatekeepers

Who administered each step of the chain, in what documented capacity, from the registers and filings only. No person or firm on this page is alleged to have done anything wrong.
JUCEMG · CRC · SEDAR+ · Companies House v4 · 2026-08-11
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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.
SCOPE

Recurring parties and gatekeepers

A transaction chain is administered by professionals: auditors, sponsors, accountants, lawyers, translators, notaries. This page records, from the registers and filings only, which professionals and repeat entities appear at more than one point of this chain, and in what documented capacity. It is confined to parties with documented roles in this record.

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Read this first. No person or firm named on this page is an OSC respondent or a defendant in Emerita's claim, except where expressly stated. Performing a professional act for a client, auditing two companies, sponsoring a capital-pool company, or serving as a company's accountant or administrator is ordinary professional work. Nothing here alleges misconduct by any professional or firm; every person named is presumed to have acted properly. The facts are recorded because a reader tracing the chain needs to know who administered each step, and because several of these roles recur across notionally arm's-length parties.
SEDAR

The auditor on both sides

McGovern Hurley. Emerita's audited annual financial statements through the option period, including the FY2018 statements that carry both the option's stated expiry and its later exercise, were audited by UHY McGovern Hurley LLP (FY2018 statements, 29 January 2019). Three years later, McGovern Hurley LLP was the auditor of Lithium Ionic Inc., the founder-share vehicle, for the financial statements reproduced in the POCML 6 Filing Statement, which carries the firm's report and its statement of independence. The same firm therefore audited the company said to have lost the asset, in the years the option was acquired and exercised, and the private vehicle through which the asset was taken public. Auditors act for many clients and nothing turns on the overlap by itself; it is recorded because any examination of what each company's records showed about the Falcon Project will pass through the same firm's files twice.

Deloitte LLP, Lithium Ionic Corp.'s auditor, paused the FY2025 audit on 22 April 2026 following the OSC application; the statements filed 5 June 2026 carry an unmodified opinion with a Material Uncertainty Related to Going Concern and a Key Audit Matter on the OSC allegations "surrounding the origin of the Bandeira Lithium Project", and Note 1 records that title-verification steps "do not guarantee the Company's title" (LTH FY2025 statements).

SEDAR · OBR

The capital-pool sponsor

POCML 6 Inc., the shell that became Lithium Ionic Corp., was a capital-pool company sponsored by PowerOne Capital Markets (principals named in the filing statement: D'Onofrio, DiCapo, Parsons). David D'Onofrio, PowerOne's CFO, appears at three points: as a principal of the sponsor; as sole director, president and secretary of 1000088600 Ontario Inc., the single-purpose merger sub on the 19 May 2022 amalgamation (articles, certified Ontario Business Registry); and, from 3 September 2024, as a director of Lithium Ionic Corp. itself. Sponsoring a CPC and directing its merger sub is exactly what a capital-pool sponsor does; the recurrence is recorded because the merger sub's paper trail is part of the asset's Ontario chain of title.

JUCEMG · CRC

The accountant behind the transfer filings

Mario Danilo Paes, contador, CRC-MG registration MG-063377/O, signed the statutory Declaração de Autenticidade (the accountant's declaration that annexed foreign corporate documents and powers of attorney are authentic) behind each of the three transfers that moved MGLIT: act RD 8038042 (declaration dated 1 October 2020, the day of the instrument itself), act RD 8859466 (19 October 2021) and act RD 9180632 (14 February 2022), and again on the 2025 act RD 12546327. On the one act in this set that survives as a native digital file, his ICP-Brasil signature carries the same name and date, so the identification is on the face of the documents. His firm, B&P Consultoria Contábil of Belo Horizonte, is the registered administrative contact for entities on both sides of the chain, including Falcon Metais and Lithium Ionic Holdings Corp.; B&P is an ordinary accounting practice with a large client book, so shared contact fields evidence a shared accountant rather than a link between the companies, and authenticating a client's foreign documents is exactly what a contador does. The registry-grade fact is narrower and stated as such: one professional's signature sits behind every ownership change of the vehicle, from UK parent, to Diniz personally, to the Canadian acquirer.

Two further professional signatures recur on the file: Roberta Paes Leme Bousas, OAB/MG 116355, signatory on the authentication of Malta do Brasil's constitution in October 2018 (a name that also appears, by four-element match, on the Malta Minerals PLC register of members); and Mario Miguel Fernandez Escaleira, sworn translator, JUCESP matrícula 1399, whose translations are annexed to the 2020 and 2021 transfer acts. The Ontario notarisations and Brazilian consular legalisations on the 2021 acquisition documents are set out on the vehicle page.

JUCEMG · RF · SEDAR

The Forbes & Manhattan orbit, as the registers record it

"Forbes & Manhattan" is a Toronto merchant-banking group. Its presence in this chain is not an inference from names; it is on the Brazilian registers, and in the acquirer's own listing document, in the following documented forms.

Register factDetail and source
Falcon Metais's founding orbitOn the 25 March 2009 act (registered 2 April 2009), Forbes and Manhattan (Barbados) Inc. ceded 159,999,998 quotas and Diniz his single quota to Amazon Potash Corp. (a Toronto-addressed company), which entered holding 99.99998% of Falcon's capital. Diniz signed for all three parties, as procurador of both companies; the Amazon Potash power of attorney had been signed at Toronto in February 2009 by Anthony John Wonnacott. JUCEMG act D 4113032, hosted here.
Capital out before the optionFalcon's capital was reduced twice, in 2014 and again by an instrument of 16 March 2016 (resolution of 16 December 2015) that returned the nominal value of 2,720,542 extinguished quotas to Amazon Potash as "excess capital for the purposes of the company's object", three months before the 13 June 2016 option agreement. JUCEMG act RD 5739050, hosted here.
The second corporate sócioBy instrument of 21 May 2019 (registered 4 June 2019), Forbes Empreendimentos Minerais Ltda. (renamed Forbes Participações Ltda. in 2022, now owned by Forbes & Manhattan Resources Inc. of Canada, administrator Neil Said from September 2023) acquired BS1 Mineração's single Falcon quota "por compra e venda, a valor contábil, ... conforme acerto apartado": a sale at book value on terms in a side agreement that is not on any register. JUCEMG act RD 7333978, hosted here; Receita Federal records.
The same company inside the vehicleThe same Forbes Empreendimentos Minerais Ltda. held the minority quota of Malta do Brasil / MGLIT from 2018, consented to the 2020 transfer to Diniz, and was the co-seller on the 2021 transfer to the Lithium Ionic side. JUCEMG acts RD 8038042 and RD 8859466, hosted here.
Emerita's own subsidiary began as an orbit vehicleThe company Emerita used in Brazil was not incorporated by Emerita: it was constituted in June 2014 as Irati Energia Participações Ltda. by Forbes Empreendimentos Minerais Ltda. and a Delaware LLC, both represented by Diniz, and Emerita acquired it in September 2017 (no consideration stated), renaming it Emerita do Brasil. JUCEMG acts D 31210203906 and RD 6391670, hosted here.
The self-descriptionDiniz's own director biography in the acquirer's listing document states that he "went on to set up several companies, such as Falcon Metais and HDX Consultoria", and that he "founded and developed several companies for the Forbes & Manhattan Inc. group", naming Brazil Potash, Aguia Metais, Belo Sun Mining and Irati Petroleo. POCML 6 Filing Statement, hosted here.
A continuing commercial relationshipLithium Ionic's audited FY2025 statements disclose payments to Falcon Metais Ltda. of $29,623 in FY2025 and $37,611 in FY2024 for "various administrative services", describing Diniz as an officer of Falcon Metais; equivalent related-party notes appear in each annual filing since the 2022 listing. The vendor of the asset has remained a paid service provider to its acquirer. LTH FY2025 statements, Note 19.
The surface-rights loopMGLIT lent R$ 10,000,000 at 1% to Valitar Participações S.A., which bought the surface rights over the Bandeira ground and leases them back to MGLIT; Valitar is 90% held by a Diniz company, and on the registry record Lithium Ionic Holdings Corp. holds the other 10% as preferred shares convertible at its sole discretion into 99.99% of Valitar's voting capital, created by an act of 2 June 2023, four days after the loan was announced. JUCEMG acts RD 31300154173 and RD 10599098, hosted here; LTH FY2025 statements, Note 19.
The company secretary's companyThe largest outside holder on the Malta Minerals PLC register, Isatis Capital Group Inc. (11.56%), was a Québec company administered by the plc's own company secretary. It has been in bankruptcy since 8 July 2026. Companies House CS01, hosted here; Québec enterprise register.

Sources as stated in each row. Amazon Potash Corp., Forbes and Manhattan (Barbados) Inc., Forbes Empreendimentos Minerais / Forbes Participações Ltda., Forbes & Manhattan Resources Inc., BS1 Mineração Ltda., Valitar Participações S.A., Isatis Capital Group Inc., B&P Consultoria Contábil, McGovern Hurley, PowerOne Capital Markets and every individual named in this section other than the OSC respondents are not parties to any proceeding referenced on this site, and no allegation is made against any of them.

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.