Pioneer GP Limited

Application by Pioneer Recovery Fund LP and Champlain Investment Holdings Ltd., both of the Cayman Islands, to take discovery from Amanda Wilson, Pedro Santiago, Astrid Pillay, and Charles Holzer regarding "a series of purported frauds perpetrated by the late Mr. Lance Valdez and subsequent directors and officers of the Fund [Pioneer Recovery Fund], who used the Fund as the instrument of a fraud perpetrated against the Fund's founder, Vermeer Investments Limited" for use in legal proceedings in the Bahamas against Subacu Investment Partners LP, of the Bahamas; Beecham Ltd., of the Bahamas; Crescent Advisers Ltd., of the Cayman Islands; Pioneer Investment Management Ltd., of the Bahamas; Universal Corporate Limited, of Ireland; Jason Sweeney, Dasha Valdez, nee Dasha Pastoukhova, a resident of the Bahamas; London Capital Holdings Ltd., of the British Virgin Islands; PCH Ltd., of the Bahamas; Subacu Holdings Ltd., of the British Virgin Islands; Guam Investment Services, of the British Virgin Islands; 10 East 63rd Street Inc., of New York, and Amanda Wilson, of New York, filed at the U. S. District Court for the Southern District of New York.