Court File No. A- Ud -19 FEDERAL COURT OF APPEAL. BETWEEN: SNC-LAVALIN GROUP INC., SNC-LAVALIN INTERNATIONAL INC. AND SNC-LAVALIN CONSTRUCTION INC, A =. tye P Lo aes 8 5 8 IMRANA AHMED E THE DIRECTOR OF PUBLIC PROSECUTIOW{STORONTO,ON [| FEDERAL COURPOFARPEAL COUR D'APPEL FEDERALE p Respondent NOTICE OF APPEAL TO THE RESPONDENTS: A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the appellants. The relief claimed by the appellants appears on the following page. THIS APPEAL will be heard by the Court at a time and place to be fixed by the Judicial Administrator, Unless the Court directs otherwise, the place of hearing will be as requested by the appellant. The appellants request that this appeal be heard at the Federal Court of Appeal in Montréal IF YOU WISH TO OPPOSE THIS APPEAL, to receive notice of any step in the appeal or to be served with any documents in the appeal, you or a solicitor acting for you must prepare a notice of appearance in Form 341 prescribed by the Federal Courts Rules and serve it on the appellants’ solicitor, or where the appellant is self-represented, on the appellant, WITHIN 10 DAYS of being served with this notice of appeal IF YOU INTEND TO SEEK A DIFFERENT DISPOSITION of the order appealed from, you must serve and file a notice of cross-appeal in Form 341 prescribed by the Federal Courts ‘Rules instead of serving and filing a notice of appearance. Copies of the Federal Courts Rules, information concerning the local offices of the Court and other necessary information may be obtained on request to the Administrator of this Court at Ottawa (telephone 613-992-4238) or at any local office.Oe IF YOU FAIL TO OPPOSE THIS APPEAL, JUDGMENT MAY BE GIVEN IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. IMRANA AHMED Regis Date _ April 4, 2019 Issued by gistry Officer (Registry” er) Address of local office: 180 Queen Street West Suite 200 Toronto, Ontario MSV 316 TO Perley-Robertson, Hill & McDougall LLP 1400-340 Albert St. Ottawa, ON KIR OAS Tel: 613.238.2022 Fax: 613.238.8775 David Migicovsky Tel: 613.566.2833 Andrew Lenz Tel: 613.556.2842 Solicitors for the RespondentAPPEAL THE APPELLANTS APPEAL to the Federal Court of Appeal from the Order of Justice Kane (Court File No. T-1843-18) dated March 8, 2019, by which Justice Kane allowed the Respondent's motion to strike the Notice of Application pursuant to Rule 221 of the Federal Courts Rules without leave to amend (the “Order”). THE APPELLANTS ASK that this appeal be allowed and that an order be granted: 1. setting aside the Order and dismissing the Respondent’s motion to strike; 2. permitting the Appellants to amend their Notice of Application as per the proposed amended pleading attached hereto as Appendix “A”; 3. awarding the Appellants their cost of this appeal and the motion below; and 4, such further and other relief as this Honourable Court deems just. ‘THE GROUNDS OF APPEAL ARE AS FOLLOWS: 1. This appeal arises in the context of an application for judicial review of the decision of the Respondent, the Director of Public Prosecutions (the “DPP”), not to issue an invitation to negotiate a remediation agreement to the Applicants, SNC-Lavalin Group Inc., SNC-Lavalin International Inc. and SNC-Lavalin Construction Inc. ‘The Parties 2. SNC-Lavalin Group Ine. is a global fully integrated professional services and project management company and a major player in the ownership of infrastructure. From headquarters in Montréal, SNC-Lavalin Group Inc.’s employees provide comprehensive capital investment, consulting, design, engineering, construction management, sustaining capital and operations and maintenance services to clients across oil and gas, mining and metallurgy, infrastructure, clean power, nuclear energy and EDPM (engineering design and project management). SNC-Lavalin International Ine. and SNC-Lavalin Construction Ine. are wholly-owned subsidiaries of SNC- Lavalin Group Ine.