Updated Briefing and Discovery Schedule FOR Citgo Sale Hearing
UPDATED BRIEFING AND DISCOVERY SCHEDULE FOR CITGO SALE HEARING
Pembroke, Bermuda – June 11, 2025 – Gold Reserve Ltd. (TSX.V: GRZ) (OTCQX:
GDRZF) (“Gold Reserve” or the “ Company”) announces that the U.S. District Court for
the District of Delaware (the “ Court”) issued an order adopting the following revised
schedule for briefing and discovery deadlines proposed by the Special Master given the
expiration of the Topping Period on June 18, 2025 and rescheduled start date for the Sale
Hearing to August 18, 2025, as previously announced here.
Event Deadline
Deadline for the Special Master to submit his Final Recommendation July 2
Deadline to serve written discovery on the party (or parties) whose bid
is selected as the Final Recommendation
July 7
Opening expert reports due July 7
Deadline for the filing of any objections to the Special Master’s Final
Recommendation
July 9
Deadline for any Competing Objector to disclose its own bid materials
(such materials to be commensurate with those disclosed by the
Special Master of the recommended bid)
July 9
Deadline to serve written discovery on a Competing Objector July 11
Deadline to serve responses and objections for discovery requests
served after the Final Recommendation
July 15
Deadline to meet and confer regarding the scope of discovery to be
produced in response to discovery requests served after submission
of the Final Recommendation
July 16
Deadline to serve witness disclosures pursuant to FRCP 26(a)(3) July 18
Deadline to notice witness depositions July 21
Deadline to serve responsive expert reports July 21
Deadline to complete document productions in response to discovery
requests served before the submission of the Final Recommendation
July 22
and substantially complete document productions in response to
discovery requests served after the submission of the Final
Recommendation
Deadline to serve reply expert reports, if any July 25
Conclusion of the discovery period July 31
Deadline for the filing of responses to objections to the Special
Master’s Final Recommendation
August 1
Deadline for the filing of replies regarding any objections to the
Special Master’s Final Recommendation
August 8
Deadline for the filing of sur-replies to replies regarding any objections
to the Special Master’s Final Recommendation (only to the extent
new arguments are raised in reply briefing)
August 12
Deadline for the Special Master to submit Joint Status Report August 13
Deadline to disclose exhibits pursuant to FRCP 26(a)(3) August 13
Deadline to serve objections to FRCP 26(a)(3) exhibit disclosures August 15
Commencement of the Sale Hearing August 18
A copy of the Court’s complete order can be found here.
A complete description of the Delaware sale proceedings can be found on the Public
Access to Court Electronic Records system in Crystallex International Corporation v.
Bolivarian Republic of Venezuela, 1:17- mc-00151-LPS (D. Del.) and its related
proceedings.
Cautionary Statement Regarding Forward-Looking statements
This release contains “forward-looking statements” within the meaning of applicable
U.S. federal securities laws and “forward-looking information” within the meaning of
applicable Canadian provincial and territorial securities laws and state Gold Reserve’s
and its management’s intentions, hopes, beliefs, expectations or predictions for the
future. Forward-looking statements are necessarily based upon a number of estimates
and assumptions that, while considered reasonable by management at this time, are
inherently subject to significant business, economic and competitive uncertainties and
contingencies. They are frequently characterized by words such as "anticipates", "plan",
"continue", "expect", "project", "intend", "believe", "anticipate", "estimate", "may", "will",
"potential", "proposed", "positioned" and other similar words, or statements that certain
events or conditions "may" or "will" occur. Forward-looking statements contained in this
press release include, but are not limited to, statements relating to any bid submitted by
the Company for the purchase of the PDVH shares (the “Bid”).
We caution that such forward-looking statements involve known and unknown risks,
uncertainties and other risks that may cause the actual events, outcomes or results of
Gold Reserve to be materially different from our estimated outcomes, results,
performance, or achievements expressed or implied by those forward-looking
statements, including but not limited to: the discretion of the Special Master to consider
the Bid, to enter into any discussions or negotiation with respect thereto and that the
Special Master may reject the Bid at any time; the Special Master may choose not to
recommend a Base Bid or Final Bid to the Court; the failure of the Company to
negotiate the Bid, including as a result of failing to obtain sufficient equity and/or debt
financing; that Bid submitted by the Company will not be selected as the “Base Bid” or
the “Final Recommend Bid” under the Bidding Procedures, and if selected may not
close due to the Sale Process not being completed, including as a result of not
obtaining necessary regulatory approval to close on the purchase of the PDVH shares,
including but not limited to any necessary approvals from the U.S. Office of Foreign
Asset Control (“OFAC”), the U.S. Committee on Foreign Investment in the United
States, the U.S. Federal Trade Commission or the TSX Venture Exchange; failure of the
Company or any other party to obtain any required shareholders approvals for, or
satisfy other conditions to effect, any transaction resulting from the Bid; that the
Company forfeit any cash amount deposit made due to failing to complete the Bid or
otherwise; that the making of the Bid or any transaction resulting therefrom may involve
unexpected costs, liabilities or delays; that, prior to or as a result of the completion of
any transaction contemplated by the Bid, the business of the Company may experience
significant disruptions due to transaction related uncertainty, industry conditions, tariff
wars or other factors; the ability to enforce the writ of attachment granted to the
Company; the timing set for various reports and/or other matters with respect to the
Sale Process may not be met; the ability of the Company to otherwise participate in the
Sale Process (and related costs associated therewith); the amount, if any, of proceeds
associated with the Sale Process; the competing claims of other creditors of Venezuela,
PDVSA and the Company, including any interest on such creditors’ judgements and any
priority afforded thereto; uncertainties with respect to possible settlements between
Venezuela and other creditors and the impact of any such settlements on the amount of
funds that may be available under the Sale Process; and the proceeds from the Sale
Process may not be sufficient to satisfy the amounts outstanding under the Company’s
September 2014 arbitral award and/or corresponding November 15, 2015 U.S.
judgement in full; and the ramifications of bankruptcy with respect to the Sale Process
and/or the Company’s claims, including as a result of the priority of other claims. This
list is not exhaustive of the factors that may affect any of the Company’s forward-looking
statements. For a more detailed discussion of the risk factors affecting the Company’s
business, see the Company’s Management’s Discussion & Analysis for the year ended
December 31, 2024 and other reports that have been filed on SEDAR+ and are
available under the Company’s profile at www.sedarplus.ca.
Investors are cautioned not to put undue reliance on forward-looking statements. All
subsequent written and oral forward-looking statements attributable to Gold Reserve or
persons acting on its behalf are expressly qualified in their entirety by this notice. Gold
Reserve disclaims any intent or obligation to update publicly or otherwise revise any
forward-looking statements or the foregoing list of assumptions or factors, whether as a
result of new information, future events or otherwise, subject to its disclosure obligations
under applicable rules promulgated by applicable Canadian provincial and territorial
securities laws.
NEITHER THE TSX VENTURE EXCHANGE NOR ITS REGULATION SERVICES
PROVIDER (AS THAT TERM IS DEFINED IN POLICIES OF THE TSX VENTURE
EXCHANGE) ACCEPTS RESPONSIBILITY FOR THE ADEQUACY OR ACCURACY
OF THIS RELEASE.
For further information regarding Dalinar Energy, visit: https://www.dalinarenergy.com.
For further information regarding Gold Reserve Ltd., visit https://www.goldreserve.bm or
contact:
Kathryn Houlden
(441) 295-4653
A.S. Cooper Building, 7th Floor, 26 Reid Street, Hamilton, HM 11, Bermuda