Exhibit 30 for Affidavit of Daniel Mathew Bryant - Arnold Bloch Leibler

IN THE SUPREME COURT OF VICTORIA AT MELBOURNE
COMMERCIAL AND EQUITY DIVISION
COMMERCIAL COURT
CORPORATIONS LIST
s cl 201 3 2774
IN THE MATTER OF THE GUNNS WOODLOT PROJECTS 2002, 2003, 2004,2005, 2006
AND 2OO8
cUNNS FTNANCE LTMTTED (lN LTQUTDATTONXRECETVERS AND MANAGERS
APPOINTED) (ACN 091 861 700)AND OTHERS (according to the attached schedule)
and
Plaintiffs
WA BLUE GUM LIMITED (ACN 060 179 982) AND OTHERS (according to the attached
schedule)
Defendants
CERTIFICATE IDENTIFYING EXHIBIT
Date of document
Filed on behalf of:
Prepared by:
ARNOLD BLOCH LEIBLER
Lawyers and Advisers
Level 21
333 Collins Street
MELBOURNE 3OOO
6 June 2013
the Plaintiffs
Solicitor's Code: 54
DX 38455 Melbourne
Tel: 9229 9999
Fax: 9229 9900
Ref: 01-1758295
(Kimberley MacKay - kmackay@abl.com.au)
This is the exhibit marked "DMB-30" now produced and shown to DANIEL MATHEW
BRYANT at the time of affirming his affidavit on 6 June 2013.
JULIA PAULA KR ETZENBACHER
Arnold Blodì Leibler
Lev€|21, æ3 Coltrs $noot
lvlelboune il00
Before me
Exh¡b¡t "DMB-30"
Copy of the letter from Mr Lucas to PPB
Advisory dated 17 May 2013
ABU2861 1 54v3

kDmB-3o"
Macquarie Forestry Services Pty Limited
ABN '17 093 752 946
A Member of the l\4acquarie Group of Companies
No 1 lMartin Place
SYDNEY NSW 2OOO
GPO Box 4294
SYDNEY NSW 1 164
AUSTRALIA
Telephone
Email
lnternel
1800 640 145
Gunnsschemes@macquarie com
macquarie.com.au/GunnsSchemes
17 May 2013
Daniel Bryant
PPB Advisory
Level21, 181 William Street
Melbourne VIC 3000
Dear Mr Bryant
MACQUARIE
Gunns Plantations Limited (ln Liquidation) (Receivers and Managers Appointed)
Gunns Plantations Woodlot Schemes 2002to 2008 (Schemes)
I refer to your letter of 15 May 2013 to W.A. Blue Gum Limited (WABG) in which you set out two concerns in
relation to the restructure proposal (Proposal) jointly released by WABG and Macquarie Forestry Services
Pty Limited (Macquarie). WABG has instructed Macquarie to respond on their behalf.
Responses to your specific concerns are set out below but as a general point I note that the Explanatory
Memorandum (EM) released to investors was subject to a detailed due diligence process involving senior
executives from WABG and Macquarie together with their legal advisors and that process has provided a high
level of assurance that all issues relevant to investors when making their decisions about the Proposal have
been fully disclosed and that the EM is not misleading.
1. Scheme Liabilities: Outstanding Rent
We note that any liability that exists in relation to these Commercial Leases is an existing liability of the current
Schemes and that nothing being undertaken in the Proposal will impact these existing liabilities either in
quantum or timing of when due. These liabilities will also need to be satisfied if you pursue a Power of Sale. ln
any event, we have performed extensive due diligence on the arrangements concerning the Commercial
Leases and on the basis of this we are comfortable that the EM adequately discloses the risks associated with
these leases. The most relevant point is that the Proposal involves the reconstitution of the Schemes on a
different basis to the form they exist today. Relevantly, the Commercial Leases and the trees on that land will
not form part of the reconstituted Schemes. Any rights that investors have to any value in the standing timber,
as well as any liabilities for unpaid rent or maintenance obligations will remain with GPL. ln any event, we
seek confirmation from you that you will not breach your fiduciary duties to Growers by seeking to reach an
agreement with the relevant landlords that might prejudice the value of the investor's interest in the standing
timber or adversely impact the commercial position of the Growers in the event that they do elect to proceed
with the Proposal,
2. Termination of the Gunns Limited Leases
The question of who has standing to apply for relief against forfeiture will depend on who is the responsible
entity (RE) at the time an attempt is made to terminate the Peppercorn Leases. Assuming the Growers elect
to proceed with the Proposal and a new RE is appointed to the Schemes by the time the Receiver attempts to
terminate the Plantation Leases, WABG will be the newly appointed RE and thus will have standing to make a
relief against forfeiture application.
lf the Receiver seeks to terminate the leases while GPL is still the RE (which would be hard to imagine having
regard to the terms of the Standstill Agreement), then GPL will have standing and no doubt the Growers
would expect that GPL will make that application in their best interests. We note that Growers may also have
the ability to make such an application if GPL refuses to do so. lf you as the Liquidators of GPL would not be
prepared to make that application in this circumstance, we think that the Growers we would expect you to
None of lhe enlities noted in this document is an
The obligations of lhese entities do nol represent
or otherwise provide assurance in respect of the obligations of these entities.
Banking Act 1959 (Commonwealth of Austral¡a).
46 008 583 542 (MBL). MBL does not guarantee

Macquarie Forestry Services Pty Limited
immediately inform the Growers as that may be an issue important to the Growers' consideration as to
whether or not to replace GPL as the RE of the Schemes or, as we say, make their own relief against
forfeiture application.
ln addition, we understand the Liquidators are obliged as trustee of the Growers' interests in the trees to
undertake steps to protect those trees, including taking steps to protect the head leases. Do you intend to take
steps to enforce the Standstill Agreement and prevent the Receivers terminating the leases prior to WABG's
appointment?
3. Letter to lndustryEdge dated 16 May 2013
We understand that you have also written to lndustry Edge on 15 May setting out your concerns with their
report without attributing the source of your concerns.
It is difficult to assess or evaluate your concerns without detailed written analysis direct from the "experts" on
whom you purport to rely. Perhaps these experts are URS, from whom we understand you have
commissioned a report some time ago. Of course it is not possible for us to assess whether the views you
have asserted reflect URS's view since you have continuously and over an extended period refused Growers'
demands for the release of the report (despite your presumed plans to recover costs of its preparation from
Grower assets).
Suffice to say, the lndustryEdge report was prepared by two recognised experts (one a noted forestry analysis
expert, the other an experienced economist). lndustryEdge has confirmed to us that it continues to stand by
its report and has taken into account the various matters listed in your letter to them of 15 May 2013 in arriúing
at its conclusions. On this basis we believe this matter to be closed, however, if you wish to immediately
provide further written and attributed analysis we will, of course, be happy to consider it.
Can you separately confirm to us whether you have any further concerns about the EM or any other
information we have provided to Growers so that we can deal with them promptly and well before the meeting
called by Growers.
Yours faithfully
Macquarie Forestry Services Pty Limited
Peter Lucas
Director
cc:
Paul Eastment, Ray Merrick, ASIC
Tom May, W.A. Blue Gum Limited
WS : FP_Sydney :57 I 997 4:v1