[sheet: Cover]

Field	Value
Document Title	Exhibit List and Index for Affirmation of Yuki Nakamura in Opposition to Defendant's Motion to Dismiss
Case Caption	Ironside Capital Management LP v. Vantor Holdings Corp.
Court	New York Supreme Court, Commercial Division, New York County
Index No.	650312/2025
Assigned Justice	Hon. Richard Torrance, J.S.C.
Filing Date of Affirmation	March 21, 2025
Date of Index	March 19, 2025
Prepared By	Carlos Espinoza, Associate, Calderwood & Harkness LLP
Reviewed By	Yuki Nakamura, Lead Associate, Calderwood & Harkness LLP
Firm Address	Calderwood & Harkness LLP, 51 West 52nd Street, 40th Floor, New York, NY 10019
Plaintiff	Ironside Capital Management LP
Defendant	Vantor Holdings Corp.
Total Exhibits	14

[sheet: Exhibit Index]

Exhibit No.	Bates Range Start	Bates Range End	Total Pages	Document Date	Document Title / Description	Author / Source	Document Type	Affirmation ¶ Reference	Authentication Notes
A	ICM-MTD-000001	ICM-MTD-000047	47	June 15, 2017	Master Fund Administration Agreement between Ironside Capital Management LP (on behalf of Ironside Credit Opportunities Fund LP, Ironside Structured Alpha Fund LP, and Ironside Special Situations Fund LP) and Vantor Holdings Corp. (Ref: VHC-ICM-2017-0615) — Executed copy including Schedules A through D; key provisions: § 3.1 (Scope of Services including NAV calculation and independent pricing/valuation of Level 2 and Level 3 assets), § 4.2 (Valuation Standard — GAAP compliance and reasonably prudent professional fund administrator standard of care), § 9.1 (Indemnification for negligence, fraud, willful misconduct, or material breach), § 9.3 (Limitation of Liability — aggregate cap at 2× trailing 12-month fees), § 9.4 (Attorneys' fees), § 12.2 (Termination for Cause), § 14.2 (New York governing law), § 14.3 (NY Supreme Court, NY County; jury trial waiver). Original fee: 4.0 bps on aggregate administered NAV, paid quarterly.	Ironside Capital Management LP / Vantor Holdings Corp.	Contract	¶¶ 5–12	Authenticated by Katherine Lim, General Counsel & CCO, Ironside Capital Management LP, as a true and correct copy of the fully executed agreement maintained in the ordinary course of business. Original held in Ironside legal files.
B	ICM-MTD-000048	ICM-MTD-000058	11	March 1, 2019	First Amendment to Master Fund Administration Agreement — Adding Ironside Special Situations Fund LP (Fund III, ~$680M NAV) as a covered fund vehicle under the FAA; extending all terms of the original FAA to Fund III; updating Schedule A to reflect three administered funds.	Ironside Capital Management LP / Vantor Holdings Corp.	Contract Amendment	¶ 13	Authenticated by Katherine Lim as a true and correct copy of the executed First Amendment maintained in the ordinary course of business.
C	ICM-MTD-000059	ICM-MTD-000066	8	June 10, 2022	Second Amendment to Master Fund Administration Agreement — Confirming auto-renewal of FAA and adjusting administration fee from 4.0 bps to 4.5 bps on aggregate administered NAV, effective June 10, 2022. At peak administered NAV of ~$3.59B (Q2 2022), quarterly fee approximately $404,125 (~$1.616M annualized).	Ironside Capital Management LP / Vantor Holdings Corp.	Contract Amendment	¶ 14	Authenticated by Katherine Lim as a true and correct copy of the executed Second Amendment maintained in the ordinary course of business.
D	ICM-MTD-000067	ICM-MTD-000089	23	January 1, 2020	Ironside Valuation Policy, Version 3.2, effective January 1, 2020 — Establishes waterfall valuation procedures for Level 1, Level 2, and Level 3 assets across all Ironside fund vehicles; referenced and incorporated by FAA § 4.2 as the 'applicable fund's valuation policy.' Details required use of independent broker quotes, frequency of re-pricing, escalation procedures for stale marks, and governance over model-based adjustments.	Ironside Capital Management LP	Policy Document	¶¶ 15–17	Authenticated by Derek Holt, Head of Operations, Ironside Capital Management LP, as a true and correct copy of the valuation policy in effect during the relevant period (Q1 2021–Q3 2023), maintained in the ordinary course of business.
E	ICM-MTD-000090	ICM-MTD-000112	23	Various (Q1 2021–Q3 2023)	Selected Vantor Holdings Corp. internal emails (16 emails) among Nathan Orris (SVP, Valuation Services) and Deepa Rajaram (VP, Client Valuation Operations) and other Vantor personnel — Documenting awareness that broker quotes used for Ironside position marks were stale (6–12 months old), discussion of internally generated 'model adjustments' inflating marks, acknowledgment that waterfall valuation procedures under Ironside's valuation policy were not being followed, and concealment of these facts from Ironside. Obtained via pre-suit subpoena to DataVault Solutions Inc. (14 Commerce Drive, Cranford, NJ 07016) pursuant to CPLR § 3102(c).	Vantor Holdings Corp. (Nathan Orris, Deepa Rajaram, et al.)	Email Correspondence	¶¶ 18–28	Obtained via pre-suit subpoena to DataVault Solutions Inc. pursuant to CPLR § 3102(c); produced in native format and converted to Bates-stamped PDF. Authenticity subject to further verification in discovery; offered on information and belief based on metadata and custodian identification by DataVault.
F	ICM-MTD-000113	ICM-MTD-000126	14	August 4, 2023	Letter from Rajiv Subramanian (CFO, Ironside) to Nathan Orris (SVP, Valuation Services, Vantor) — Written inquiry requesting supporting documentation for 23 illiquid credit and structured-product positions following identification of a $12.6 million pricing discrepancy across 7 CLO equity positions between Vantor's Q2 2023 marks and independent price indications from Northpoint Securities LLC.	Ironside Capital Management LP (Rajiv Subramanian)	Correspondence	¶ 29	Authenticated by Rajiv Subramanian, CFO, Ironside Capital Management LP, as a true and correct copy of the letter sent to Vantor on August 4, 2023, maintained in the ordinary course of business.
G	ICM-MTD-000127	ICM-MTD-000139	13	August 18, 2023	Response letter and partial document production from Nathan Orris (Vantor) to Rajiv Subramanian (Ironside) — Materially incomplete response providing pricing packages for only 9 of 23 requested positions; no internal valuation model documentation included.	Vantor Holdings Corp. (Nathan Orris)	Correspondence / Document Production	¶ 30	Authenticated by Rajiv Subramanian as a true and correct copy of the response received from Vantor on August 18, 2023, maintained in the ordinary course of business.
H	ICM-MTD-000140	ICM-MTD-000148	9	September 22, 2023	Executive Summary of Harmon-Bryce Valuation Advisors LLC Preliminary Report (Ref: HBVA-2023-0922-IRON) — Summary of independent re-pricing of 47 illiquid credit and structured-product positions across Fund I, Fund II, and Fund III; findings: aggregate overvaluation of $287.0 million ($156.4M Fund I, $88.7M Fund II, $41.9M Fund III); average mark inflation of 14.3% above observable inputs; NAV overstatement ranging from 3.8% (Q1 2021) to 8.6% (Q4 2022); peak single-quarter overvaluation of $52.3M in Q4 2022. Misvaluation period: 11 quarters (Q1 2021–Q3 2023). Prepared by Dr. Lena Galbraith, CFA, ASA, Principal.	Harmon-Bryce Valuation Advisors LLC (Dr. Lena Galbraith)	Expert Report Summary	¶¶ 31–36	Authenticated by Yuki Nakamura as a document provided to Calderwood & Harkness LLP by Harmon-Bryce Valuation Advisors LLC in connection with its engagement as valuation expert. Full report reserved for expert discovery.
I	ICM-MTD-000149	ICM-MTD-000161	13	January 10, 2025	Executive Summary of Kessler Forensic Accounting Group PC Damages Report (Ref: KF-2025-0110-ICM) — Quantification of damages: direct overvaluation losses ($287.0M), investor redemption overpayments ($43.2M across 217 redemptions at inflated NAV), excess management fees subject to disgorgement ($4.3M, based on 1.5% management fee rate applied to average overstatement), regulatory remediation costs ($2.8M), investor litigation defense costs ($6.1M for three pending LP arbitrations against Ironside), and estimated reputational/AUM loss ($38.6M based on approximately $860M in net outflows, capitalized). Total claimed damages approximately $382M. Prepared by Martin Kessler, CPA/CFF, Lead Forensic Accountant.	Kessler Forensic Accounting Group PC (Martin Kessler)	Expert Report Summary	¶¶ 37–42	Authenticated by Yuki Nakamura as a document provided to Calderwood & Harkness LLP by Kessler Forensic Accounting Group PC in connection with its engagement as forensic accounting expert. Full report reserved for expert discovery.
J	ICM-MTD-000162	ICM-MTD-000168	7	October 3, 2023	Notice of Termination for Cause — Ironside Capital Management LP to Vantor Holdings Corp. pursuant to FAA § 12.2, effective immediately, citing material breach and fraud in the performance of valuation services under §§ 3.1 and 4.2 of the FAA.	Ironside Capital Management LP (Katherine Lim)	Correspondence / Contractual Notice	¶ 43	Authenticated by Katherine Lim, General Counsel & CCO, Ironside Capital Management LP, as a true and correct copy of the termination notice sent to Vantor on October 3, 2023, maintained in the ordinary course of business.
K	ICM-MTD-000169	ICM-MTD-000179	11	November 15, 2023	Demand Letter from Calderwood & Harkness LLP (Samuel Eklund) to Vantor Holdings Corp. (cc: Whitfield, Dane & Corcoran LLP, Gregory Dane) — Asserting claims of fraud and material breach under the FAA, demanding $287 million in compensatory damages plus consequential damages, and preserving all remedies including punitive damages and attorneys' fees under FAA § 9.4.	Calderwood & Harkness LLP (Samuel Eklund)	Correspondence / Demand Letter	¶ 44	Authenticated by Yuki Nakamura as a true and correct copy of the demand letter sent by Calderwood & Harkness LLP on behalf of Ironside Capital Management LP, maintained in the firm's files.
L	ICM-MTD-000180	ICM-MTD-000190	11	December 20, 2023	Response Letter from Whitfield, Dane & Corcoran LLP (Gregory Dane) on behalf of Vantor Holdings Corp. — Denying all allegations of fraud and breach; asserting that FAA § 9.3 liability cap limits any Vantor exposure to $2.98 million (2× trailing 12-month fees of ~$1.49M paid Oct. 2022–Sept. 2023).	Whitfield, Dane & Corcoran LLP (Gregory Dane)	Correspondence	¶ 45	Authenticated by Yuki Nakamura as a true and correct copy of the response letter received by Calderwood & Harkness LLP from Whitfield, Dane & Corcoran LLP, maintained in the firm's files.
M	ICM-MTD-000191	ICM-MTD-000198	8	July 2023	Northpoint Securities LLC Independent Pricing Indications for Q2 2023 — Pricing data for 7 CLO equity positions provided by Northpoint Securities (Dana Crossley, Relationship Manager) to Ironside, showing $12.6 million aggregate discrepancy from Vantor's corresponding Q2 2023 marks; initial trigger for Ironside's investigation.	Northpoint Securities LLC (Dana Crossley)	Financial Data / Pricing Report	¶¶ 46–47	Authenticated by Rajiv Subramanian as pricing data received from Northpoint Securities LLC in the ordinary course of the prime brokerage relationship. Northpoint is Ironside's prime broker (390 Madison Avenue, 12th Floor, New York, NY 10017).
N	ICM-MTD-000199	ICM-MTD-000206	8	Various (Q1 2021–Q3 2023)	Summary Schedule of Quarterly Overvaluation by Fund — Tabular compilation prepared by Kessler Forensic Accounting Group PC showing quarter-by-quarter overvaluation across Fund I (Ironside Credit Opportunities Fund LP, total $156.4M), Fund II (Ironside Structured Alpha Fund LP, total $88.7M), and Fund III (Ironside Special Situations Fund LP, total $41.9M) over 11 quarters; aggregate total $287.0M; highlights peak quarter Q4 2022 ($52.3M aggregate).	Kessler Forensic Accounting Group PC (Martin Kessler)	Demonstrative / Summary Schedule	¶ 48	Prepared as demonstrative summary by Kessler Forensic Accounting Group PC based on underlying financial data. Authenticated by Yuki Nakamura as a document prepared under the supervision of Calderwood & Harkness LLP for use in this proceeding.

[sheet: Summary Statistics]

Metric	Value
Total Number of Exhibits	14
Total Pages (All Exhibits)	206
Bates Range (Full)	ICM-MTD-000001 through ICM-MTD-000206
Contracts / Amendments	3 (Exhibits A, B, C)
Policy Documents	1 (Exhibit D)
Vantor Internal Emails	1 set / 16 emails (Exhibit E)
Correspondence (Ironside–Vantor)	2 (Exhibits F, G)
Expert Report Summaries	2 (Exhibits H, I)
Contractual Notices	1 (Exhibit J)
Demand / Response Letters	2 (Exhibits K, L)
Financial Data / Pricing Reports	1 (Exhibit M)
Demonstrative Summary Schedules	1 (Exhibit N)
Affirmation Filing Date	March 21, 2025
Affiant	Yuki Nakamura, Lead Associate, Calderwood & Harkness LLP
Case Index No.	650312/2025
Court	NY Supreme Court, Commercial Division, New York County
Assigned Justice	Hon. Richard Torrance, J.S.C.

[sheet: Cover]
Field | Value
Document Title | Exhibit List and Index for Affirmation of Yuki Nakamura in Opposition to Defendant's Motion to Dismiss
Case Caption | Ironside Capital Management LP v. Vantor Holdings Corp.
Court | New York Supreme Court, Commercial Division, New York County
Index No. | 650312/2025
Assigned Justice | Hon. Richard Torrance, J.S.C.
Filing Date of Affirmation | March 21, 2025
Date of Index | March 19, 2025
Prepared By | Carlos Espinoza, Associate, Calderwood & Harkness LLP
Reviewed By | Yuki Nakamura, Lead Associate, Calderwood & Harkness LLP
Firm Address | Calderwood & Harkness LLP, 51 West 52nd Street, 40th Floor, New York, NY 10019
Plaintiff | Ironside Capital Management LP
Defendant | Vantor Holdings Corp.
Total Exhibits | 14
[sheet: Exhibit Index]
Exhibit No. | Bates Range Start | Bates Range End | Total Pages | Document Date | Document Title / Description | Author / Source | Document Type | Affirmation ¶ Reference | Authentication Notes
A | ICM-MTD-000001 | ICM-MTD-000047 | 47 | June 15, 2017 | Master Fund Administration Agreement between Ironside Capital Management LP (on behalf of Ironside Credit Opportunities Fund LP, Ironside Structured Alpha Fund LP, and Ironside Special Situations Fund LP) and Vantor Holdings Corp. (Ref: VHC-ICM-2017-0615) — Executed copy including Schedules A through D; key provisions: § 3.1 (Scope of Services including NAV calculation and independent pricing/valuation of Level 2 and Level 3 assets), § 4.2 (Valuation Standard — GAAP compliance and reasonably prudent professional fund administrator standard of care), § 9.1 (Indemnification for negligence, fraud, willful misconduct, or material breach), § 9.3 (Limitation of Liability — aggregate cap at 2× trailing 12-month fees), § 9.4 (Attorneys' fees), § 12.2 (Termination for Cause), § 14.2 (New York governing law), § 14.3 (NY Supreme Court, NY County; jury trial waiver). Original fee: 4.0 bps on aggregate administered NAV, paid quarterly. | Ironside Capital Management LP / Vantor Holdings Corp. | Contract | ¶¶ 5–12 | Authenticated by Katherine Lim, General Counsel & CCO, Ironside Capital Management LP, as a true and correct copy of the fully executed agreement maintained in the ordinary course of business. Original held in Ironside legal files.
B | ICM-MTD-000048 | ICM-MTD-000058 | 11 | March 1, 2019 | First Amendment to Master Fund Administration Agreement — Adding Ironside Special Situations Fund LP (Fund III, ~$680M NAV) as a covered fund vehicle under the FAA; extending all terms of the original FAA to Fund III; updating Schedule A to reflect three administered funds. | Ironside Capital Management LP / Vantor Holdings Corp. | Contract Amendment | ¶ 13 | Authenticated by Katherine Lim as a true and correct copy of the executed First Amendment maintained in the ordinary course of business.
C | ICM-MTD-000059 | ICM-MTD-000066 | 8 | June 10, 2022 | Second Amendment to Master Fund Administration Agreement — Confirming auto-renewal of FAA and adjusting administration fee from 4.0 bps to 4.5 bps on aggregate administered NAV, effective June 10, 2022. At peak administered NAV of ~$3.59B (Q2 2022), quarterly fee approximately $404,125 (~$1.616M annualized). | Ironside Capital Management LP / Vantor Holdings Corp. | Contract Amendment | ¶ 14 | Authenticated by Katherine Lim as a true and correct copy of the executed Second Amendment maintained in the ordinary course of business.
D | ICM-MTD-000067 | ICM-MTD-000089 | 23 | January 1, 2020 | Ironside Valuation Policy, Version 3.2, effective January 1, 2020 — Establishes waterfall valuation procedures for Level 1, Level 2, and Level 3 assets across all Ironside fund vehicles; referenced and incorporated by FAA § 4.2 as the 'applicable fund's valuation policy.' Details required use of independent broker quotes, frequency of re-pricing, escalation procedures for stale marks, and governance over model-based adjustments. | Ironside Capital Management LP | Policy Document | ¶¶ 15–17 | Authenticated by Derek Holt, Head of Operations, Ironside Capital Management LP, as a true and correct copy of the valuation policy in effect during the relevant period (Q1 2021–Q3 2023), maintained in the ordinary course of business.
E | ICM-MTD-000090 | ICM-MTD-000112 | 23 | Various (Q1 2021–Q3 2023) | Selected Vantor Holdings Corp. internal emails (16 emails) among Nathan Orris (SVP, Valuation Services) and Deepa Rajaram (VP, Client Valuation Operations) and other Vantor personnel — Documenting awareness that broker quotes used for Ironside position marks were stale (6–12 months old), discussion of internally generated 'model adjustments' inflating marks, acknowledgment that waterfall valuation procedures under Ironside's valuation policy were not being followed, and concealment of these facts from Ironside. Obtained via pre-suit subpoena to DataVault Solutions Inc. (14 Commerce Drive, Cranford, NJ 07016) pursuant to CPLR § 3102(c). | Vantor Holdings Corp. (Nathan Orris, Deepa Rajaram, et al.) | Email Correspondence | ¶¶ 18–28 | Obtained via pre-suit subpoena to DataVault Solutions Inc. pursuant to CPLR § 3102(c); produced in native format and converted to Bates-stamped PDF. Authenticity subject to further verification in discovery; offered on information and belief based on metadata and custodian identification by DataVault.
F | ICM-MTD-000113 | ICM-MTD-000126 | 14 | August 4, 2023 | Letter from Rajiv Subramanian (CFO, Ironside) to Nathan Orris (SVP, Valuation Services, Vantor) — Written inquiry requesting supporting documentation for 23 illiquid credit and structured-product positions following identification of a $12.6 million pricing discrepancy across 7 CLO equity positions between Vantor's Q2 2023 marks and independent price indications from Northpoint Securities LLC. | Ironside Capital Management LP (Rajiv Subramanian) | Correspondence | ¶ 29 | Authenticated by Rajiv Subramanian, CFO, Ironside Capital Management LP, as a true and correct copy of the letter sent to Vantor on August 4, 2023, maintained in the ordinary course of business.
G | ICM-MTD-000127 | ICM-MTD-000139 | 13 | August 18, 2023 | Response letter and partial document production from Nathan Orris (Vantor) to Rajiv Subramanian (Ironside) — Materially incomplete response providing pricing packages for only 9 of 23 requested positions; no internal valuation model documentation included. | Vantor Holdings Corp. (Nathan Orris) | Correspondence / Document Production | ¶ 30 | Authenticated by Rajiv Subramanian as a true and correct copy of the response received from Vantor on August 18, 2023, maintained in the ordinary course of business.
H | ICM-MTD-000140 | ICM-MTD-000148 | 9 | September 22, 2023 | Executive Summary of Harmon-Bryce Valuation Advisors LLC Preliminary Report (Ref: HBVA-2023-0922-IRON) — Summary of independent re-pricing of 47 illiquid credit and structured-product positions across Fund I, Fund II, and Fund III; findings: aggregate overvaluation of $287.0 million ($156.4M Fund I, $88.7M Fund II, $41.9M Fund III); average mark inflation of 14.3% above observable inputs; NAV overstatement ranging from 3.8% (Q1 2021) to 8.6% (Q4 2022); peak single-quarter overvaluation of $52.3M in Q4 2022. Misvaluation period: 11 quarters (Q1 2021–Q3 2023). Prepared by Dr. Lena Galbraith, CFA, ASA, Principal. | Harmon-Bryce Valuation Advisors LLC (Dr. Lena Galbraith) | Expert Report Summary | ¶¶ 31–36 | Authenticated by Yuki Nakamura as a document provided to Calderwood & Harkness LLP by Harmon-Bryce Valuation Advisors LLC in connection with its engagement as valuation expert. Full report reserved for expert discovery.
I | ICM-MTD-000149 | ICM-MTD-000161 | 13 | January 10, 2025 | Executive Summary of Kessler Forensic Accounting Group PC Damages Report (Ref: KF-2025-0110-ICM) — Quantification of damages: direct overvaluation losses ($287.0M), investor redemption overpayments ($43.2M across 217 redemptions at inflated NAV), excess management fees subject to disgorgement ($4.3M, based on 1.5% management fee rate applied to average overstatement), regulatory remediation costs ($2.8M), investor litigation defense costs ($6.1M for three pending LP arbitrations against Ironside), and estimated reputational/AUM loss ($38.6M based on approximately $860M in net outflows, capitalized). Total claimed damages approximately $382M. Prepared by Martin Kessler, CPA/CFF, Lead Forensic Accountant. | Kessler Forensic Accounting Group PC (Martin Kessler) | Expert Report Summary | ¶¶ 37–42 | Authenticated by Yuki Nakamura as a document provided to Calderwood & Harkness LLP by Kessler Forensic Accounting Group PC in connection with its engagement as forensic accounting expert. Full report reserved for expert discovery.
J | ICM-MTD-000162 | ICM-MTD-000168 | 7 | October 3, 2023 | Notice of Termination for Cause — Ironside Capital Management LP to Vantor Holdings Corp. pursuant to FAA § 12.2, effective immediately, citing material breach and fraud in the performance of valuation services under §§ 3.1 and 4.2 of the FAA. | Ironside Capital Management LP (Katherine Lim) | Correspondence / Contractual Notice | ¶ 43 | Authenticated by Katherine Lim, General Counsel & CCO, Ironside Capital Management LP, as a true and correct copy of the termination notice sent to Vantor on October 3, 2023, maintained in the ordinary course of business.
K | ICM-MTD-000169 | ICM-MTD-000179 | 11 | November 15, 2023 | Demand Letter from Calderwood & Harkness LLP (Samuel Eklund) to Vantor Holdings Corp. (cc: Whitfield, Dane & Corcoran LLP, Gregory Dane) — Asserting claims of fraud and material breach under the FAA, demanding $287 million in compensatory damages plus consequential damages, and preserving all remedies including punitive damages and attorneys' fees under FAA § 9.4. | Calderwood & Harkness LLP (Samuel Eklund) | Correspondence / Demand Letter | ¶ 44 | Authenticated by Yuki Nakamura as a true and correct copy of the demand letter sent by Calderwood & Harkness LLP on behalf of Ironside Capital Management LP, maintained in the firm's files.
L | ICM-MTD-000180 | ICM-MTD-000190 | 11 | December 20, 2023 | Response Letter from Whitfield, Dane & Corcoran LLP (Gregory Dane) on behalf of Vantor Holdings Corp. — Denying all allegations of fraud and breach; asserting that FAA § 9.3 liability cap limits any Vantor exposure to $2.98 million (2× trailing 12-month fees of ~$1.49M paid Oct. 2022–Sept. 2023). | Whitfield, Dane & Corcoran LLP (Gregory Dane) | Correspondence | ¶ 45 | Authenticated by Yuki Nakamura as a true and correct copy of the response letter received by Calderwood & Harkness LLP from Whitfield, Dane & Corcoran LLP, maintained in the firm's files.
M | ICM-MTD-000191 | ICM-MTD-000198 | 8 | July 2023 | Northpoint Securities LLC Independent Pricing Indications for Q2 2023 — Pricing data for 7 CLO equity positions provided by Northpoint Securities (Dana Crossley, Relationship Manager) to Ironside, showing $12.6 million aggregate discrepancy from Vantor's corresponding Q2 2023 marks; initial trigger for Ironside's investigation. | Northpoint Securities LLC (Dana Crossley) | Financial Data / Pricing Report | ¶¶ 46–47 | Authenticated by Rajiv Subramanian as pricing data received from Northpoint Securities LLC in the ordinary course of the prime brokerage relationship. Northpoint is Ironside's prime broker (390 Madison Avenue, 12th Floor, New York, NY 10017).
N | ICM-MTD-000199 | ICM-MTD-000206 | 8 | Various (Q1 2021–Q3 2023) | Summary Schedule of Quarterly Overvaluation by Fund — Tabular compilation prepared by Kessler Forensic Accounting Group PC showing quarter-by-quarter overvaluation across Fund I (Ironside Credit Opportunities Fund LP, total $156.4M), Fund II (Ironside Structured Alpha Fund LP, total $88.7M), and Fund III (Ironside Special Situations Fund LP, total $41.9M) over 11 quarters; aggregate total $287.0M; highlights peak quarter Q4 2022 ($52.3M aggregate). | Kessler Forensic Accounting Group PC (Martin Kessler) | Demonstrative / Summary Schedule | ¶ 48 | Prepared as demonstrative summary by Kessler Forensic Accounting Group PC based on underlying financial data. Authenticated by Yuki Nakamura as a document prepared under the supervision of Calderwood & Harkness LLP for use in this proceeding.
[sheet: Summary Statistics]
Metric | Value
Total Number of Exhibits | 14
Total Pages (All Exhibits) | 206
Bates Range (Full) | ICM-MTD-000001 through ICM-MTD-000206
Contracts / Amendments | 3 (Exhibits A, B, C)
Policy Documents | 1 (Exhibit D)
Vantor Internal Emails | 1 set / 16 emails (Exhibit E)
Correspondence (Ironside–Vantor) | 2 (Exhibits F, G)
Expert Report Summaries | 2 (Exhibits H, I)
Contractual Notices | 1 (Exhibit J)
Demand / Response Letters | 2 (Exhibits K, L)
Financial Data / Pricing Reports | 1 (Exhibit M)
Demonstrative Summary Schedules | 1 (Exhibit N)
Affirmation Filing Date | March 21, 2025
Affiant | Yuki Nakamura, Lead Associate, Calderwood & Harkness LLP
Case Index No. | 650312/2025
Court | NY Supreme Court, Commercial Division, New York County
Assigned Justice | Hon. Richard Torrance, J.S.C.

[sheet: Cover]

Record

Parties

Dates

Amounts