First affidavit of Daniel Mathew Bryant - Arnold Bloch Leibler

Project Documents which is referrable to the trees. We would seek the Courl'sdirection before exercising this right.150The Growers' rights following the proposed Power of Sale amendments are differentfrom their current rights. However, as the Grower Leases and Forestry Right Deedswill most probably be terminated, currently the Growers' only right would be a claimas unsecured creditors. Under the proposed Power of Sale amendments, the risk oftermination other than for value is removed and replaced with an entitlement toreceive value for the termination of their rights. We consider that this position is morefavourable for the Growers than the current position of uncertainty and risk.Therefore, we consider that the proposed Power of Sale amendments will notadversely affect Growers' rights.Sale Process151 Gunns'primary assets include(a)approximately 200,000 hectares of freehold land located in Tasmania (GunnsLimited Land) of which 50% is planted with trees. Of those trees:(i)approximately 56,041 hectares of the planted trees relate to the GunnsWoodlot Schemes (Freehold Scheme Trees);(ii)approximately 29,976 hectares of planted trees are owned by GunnsLimited in its personal capacity (Gunns-owned Freehold Trees); and(i¡i) approximately 6,499 hectares of trees are owned by a joint venture,Tamar Tree Farms (TTF), 62% of which is controlled by a GunnsGroup entity and 38% controlled by a third party;(b) GPL's leasehold interest in the Gunns Limited Land;(c)approximately 165,026 hectares of leasehold land located in Tasmania(Tasmanian Leasehold Land) of which :(i)approximately 27,039 hectares of the planted trees relate to the GunnsWoodlot Schemes (Leasehold Scheme Trees);(ii) approximately 8,175 hectares of planted trees are owned by GunnsLimited in its personal capacity (Gunns-owned Leasehold Trees);(d) port operations for the export of woodchips at Burnie and Tamar;34