S.NO.

DATE PARTICULARS

1. 24 November 2021 Byju's Alpha Inc. ("Byju's Alpha" / "Borrower") (a

company incorporated in the United States of America
and presently in bankruptcy) availed a loan facility
aggregating to USD 1.2 Billion ("Term Loan")
pursuant to a Credit and Guaranty Agreement dated 24
November 2021

The following entities were parties to this agreement:

1.Byjus's Alpha - Borrower

2.Think & Learn Private Limited - Parent Guarantor
3.GLAS Trust Company - Administrative Agent /
Collateral Agent
4.Morgan Stanley and JP Morgan - Joint Lead
Arrangers and Joint Bookrunners

("Credit Agreement") [a Pg. 25/ I.A. No. 466 of 2025

("IA 466")].
2. 24 November 2021 In accordance with the terms of the Credit Agreement.
Think & Learn Private Limited (“TLPL / “Corporate
Debtor") issued a Guarantee (the Onshore
Guarantee”) [@Pg 731/ Reply to IA 466] in favour of
the GLAS Trust Company LLC (“GLAS”) (in its
capacity as Administrative Agent) for the benefit the
Secured Parties.

Under the terms of the Credit Agreement, each Lender

(which includes each Financial Creditor) and GLAS is a
Secured Party. Additionally, the Corporate Debtor under
this guarantee has unconditionally and irrevocably
guaranteed the obligations of the Borrower, including its
repayment obligations.

A master consent to assignment was also granted by the

Borrower to JP Morgan which permitted JP Morgan to
assign its debt to the entities mentioned in the schedule
therein, including Redwood Capital. [@,Pg 997/ Reply
to IA 466]
3. 5 April 2022 The Corporate Debtor (on behalf of itself and as agent
for the Loan Parties), GLAS and the Required Lenders
(as defined under the Credit Agreement) entered into a
temporary waiver of certain of the Corporate Debtor’s
obligations under the Credit Agreement, whereby the
Required Lenders agreed to temporarily waive the
requirements to obtain the guarantee from Whitehat
Educational Technology Pvt Ltd, provided that such
waiver would expire and be of no effect on and after 8
October 2022
4. April-July 2022 The Borrower (at the instructions of the Corporate
Debtor and without the Lenders’ knowledge)
fraudulently transferred a total of approximately
USD 533 million (being approximately 45% of the
original Term Loan) to Camshaft Capital Fund. LP
(“Camshaft"), a sham hedge fund based in the United
States.
5. 4 October 2022- The Corporate Debtor (on behalf of itself and as agent
12 January 2023 for the Loan Parties) and the Required Lenders entered
into eight amendments to the Credit Agreement dated
4 October 2022, 12 October 2022 [@Pg 749/ Reply to
IA 466], 24 November 2022 [@Pg 800/ Reply to IA
466], 13 December 2022, 20 December 2022, 28
December 2022, 6 January 2023 [@Pg 826/ Reply to
IA 466] and 12 January 2023.
6. 6 January 2023 A Forbearance Agreement (the “Forbearance
Agreement") [@Pg 826/ Reply to LA 466] was
executed, whereby the Corporate Debtor acknowledged
and agreed that:
(a) as on 6 January 2023, the Corporate Debtor and
the other Loan Parties were severally indebted to
the Lenders under the Term Loan in the
aggregate principal amount of UD
1,191,000,000, together with all accrued and
unpaid costs and expenses (together, the
“Amount”) and
(b) the Amount constitutes a “financial debt” of the
Corporate Debtor and is a “financial creditor”
for the purposes of the Code.
Under the Forbearance Agreement, the Required
Lenders agreed to forbear and accelerate the Term Loan
until 10 February 2023 (“Forbearance Period”).
The Forbearance Agreement came into effect on 13
January 2023.

IMPORTANT: One of the Amendments at page 829

clearly prohibited the borrower from designating the
Forbearance Lenders as a disqualified lender. Most
of the lenders mentioned in the Disqualification
notices are signatories to the forbearance agreement
and could not have been disqualified.
7. 3 March 2023 After the expiration of the Forbearance Period, GLAS
(acting on the instructions of the Required Lenders)
issued a notice of default and acceleration to inter alia
the Borrower and the Corporate Debtor (the "Default
and Acceleration Notice") [@Pg 883/ Reply 1o
IA 466]. By the Default and Acceleration Notice, GLAS
(in its capacity as Administrative Agent) notified inter
alia the Borrower and the Corporate Debtor that the
entire outstanding principal amount of the Term Loan,
 plus accrued and unpaid interest, and any other amounts
due under the Credit Agreement were due and payable
immediately, GLAS (in its capacity as Collateral
Agent) also demanded that all amounts due and
owing be paid in full in cash by inter alia the
Borrower and the Corporate Debtor pursuant to the
terms of the Credit Agreement (aggregating to USD
1,273,611,336.97 computed as on 3 March 2023).
8. 3 March 2023 The issuance of the Default and Acceleration Notice
also constituted a "Trigger Event", which entitled GLAS
immediately to enforce the security provided by Loan
Parties under the Loan Documents, pursuant to which
GLAS took a series of steps on 3 March 2023 that
resulted in the removal of all pre-existing director(s) and
officer(s) of the Borrower, including Mr. Riju
Ravindran, and the appointment of Mr. Timothy R. Pohl
("Mr. Pohl") as sole director of the Borrower. Mr. Pohl
then appointed himself as sole officer, specifically CEO
and secretary of the Borrower. TLPL's purported
authority expired when Timothy Pohl took control
over the affairs of Alpha on 3 March 2023.
9. 5 March 2023 Mr. Pohl issued a notice that he was the sole
representative of Alpha, including for the Credit
Agreement (thereby rescinding TLPL's authority);
[@Pg 987/ Reply to IA 466]
10. 5 June 2023 TLPL issued a disqualification notice under the Creditor
First Agreement and disqualified three Redwood entities.
Disqualification [@Pg 257/IA 466]
Notice
11. 7 June 2023 Mr. Pohl issued de-designation notices to nullify the
impact of any disqualification notices that had been
issued previously. [@Pg 989/ Reply to IA 466]
12. 23 September The Board of Control for Cricket in India ("BCCI") in
2023 respect of an operational debt filed the petition CP (IB)
No. 149/BB/2023 (the "Section 9 Petition") under
Section 9 of the Code against the Corporate Debtor.
13. 6 December 2023 Pursuant to the terms of the Onshore Guarantee, GLAS
(acting on the instructions of the Required Lenders)
issued a notice of demand (the "Notice of Demand") to
the Corporate Debtor invoking the Onshore Guarantee
and directing the Corporate Debtor to pay an
aggregate amount of USD 1,367,940,737.50
computed as on 6 December 2023 (which sum falls
within the maximum aggregate liability for the
Corporate Debtor under the Onshore Guarantee),
immediately and in any case not later than 5:00 p.m.
New York City time on 12 December 2023.
As on 6 December 2023, the Corporate Debtor was in
default for an aggregate amount of USD
1,367,940,737.50 which is owed to all Lenders under
 the Credit Agreement.
More specifically, an amount of USD 984,333,223,70 is
owed to the Financial Creditors, computed as on the
date of issuance of Notice of Demand.
14. 13 December 2023 The Corporate Debtor failed to make the payments
required to be made by it pursuant to the Onshore
Guarantee and the Credit Agreement, as demanded in
the Notice of Demand.
Accordingly, the Corporate Debtor has committed
default of its payment obligations under the Notice of
Demand issued in respect of the Onshore Guarantee on
13 December 2023, which default continues.
15. 22 January 2024 GLAS, for and on behalf of the Financial Creditors,
filed the petition bearing number CP (IB) No.
GLASS Section 7 55/BB/2024 under Section 7 of the Code ("Section 7
Petition filed. Petition") in respect of the financial debt owed by the
Corporate Debtor to the Financial Creditors.
16. 25 January 2024 TLPL disqualified 82 lenders after the filing of the
Section 7 Petition. [@Pg 294/IA 466]
Second
Disqualification
Notice.
17. 28 January 2024 Mr. Pohl issued a de-designation notice in reference to
nullify the impact of the disqualification notice issued
on 25 January 2024. [@Pg 993/ Reply to IA 466]
18. 28 February 2024 The Borrower (through Mr. Pohl) filed an application
before the United States Bankruptcy Court, District of
Delaware ("Delaware Court") seeking preliminary
injunctive relief in respect of the fraudulently
transferred USD 533 million.
19. 18 March 2024 The Delaware Court passed an order of preliminary
injunction, among other things, restraining Riju
Ravindran (former sole director of the Borrower and a
former director of the Corporate Debtor), Inspilearn
LLC (a wholly-owned subsidiary of the Corporate
Debtor), Camshaft, two further Camshaft entities -
Camshaft Capital Advisors, LLC and Camshaft Capital
Management, LLC - and any other persons who are in
active concert or participation with the foregoing,
expressly including Biju Raveendran and Divya
Gokulnath (former director of the Corporate Debtor) -
from taking any steps to spend, transfer, exchange,
convert, dissipate, liquidate, or otherwise move or
modify any rights related to the USD 533 million
fraudulently transferred from the Borrower to Camshaft.
20. 16 July 2024 CIRP was initiated against, and a moratorium was
declared with respect to, the Corporate Debtor, by way
of an order dated 16 July 2024 (the "Section 9 Order")
[@Pg 41/ Reply 10 LA 466]
21. 25 July 2024 A direction letter was issued by the lenders to GLAS
 directing it to vile its claim under the CIRP of the
Direction letter Corporate Debtor.
signed by 95% of
the lenders Not on Record
22. 2 August 2024 The Ld. NCLAT passed the Impugned Judgment
whereby the Ld. NCLAT has set aside the Section 9
Order.
23. 7 August 2024 GLAS filed Civil Appeal No. 9986 of 2024 against the
order dated 02 August 2024. By way of order dated 23
October 2024, the Supreme Court set aside the order of
the NCLAT and observed that the CoC was already in
existence. [@ Pg 147/ Reply to IA 466]
24. 11 September The IRP filed an application before the NCLT placing
2024 on record that the CoC has confirmed the IRP as the RP
of TLPL being I.A. No. 671 of 2024 (filed on
31.08.2024 registered on 11.09.2024).
25. 25 October 2024 An application was moved by GLAS being I.A. No. 820
of 2024 (“CoC Inclusion Application") before the Ld.
NCLT for its inclusion in the CoC.
26. 29 January 2025 NCLT passed an order confirming GLAS as a member
of the CoC and reverted back to the position as on
21.08.2024. hence allowing the CoC Inclusion
Application. The NCLT had through its order dated 29
January 2025. decided, among others that
(a)Disqualifications of the Facility Lenders does not
alter TLPL’s liability or GLAS ability to seek remedial
action in case of an event of default, and (b) the
Delaware Supreme Court has affirmed that Alpha had in
fact committed an event of default under the Credit
Agreement... [Pg 269, Relevant para 19 @pg- 291f
Reply to IA 466]
27. 17 February 2025 The NCLT disposed of 1A 671 of 2025 as infructuous
and thus upheld the constitution of CoC.
28. 19 February 2025 Mr. Byju Raveendran filed CA(AT)(CH)(lns) No. 120
of 2025 challenging the order dated 29.01.2025 and
challenged the constitution of the CoC as on21.08.2025.
29. 01 April 2025 Mr. Byju Raveendran filed Company Appeal (AT)(CH)
(Ins) No. 416 of 2025 challenging the order dated 17
February 2025.
30. 09 May 2025 Mr. Riju Ravindran filed Civil Appeal No. 6613 of 2025
wherein grounds relating to disqualification of
GLAS were raised by Mr. Riju Ravindran. [(@Pg
10/ Memo for production of documents.]
31. 14 May 2025 Mr. Riju Ravindran filed a SLP(Civil) No. 19647-19648
of 2025 before the Supreme Court of India challenging
the order dated 17.02.2025. The same order is being
impugned by Mr. Byju Raveendran in Company Appeal
(AT)(CH)(Ins)No. 416 of 2025.[@Pg 1217/ Memo for
production of documents.]
32. 21 July 2025 The Supreme Court dismissed SLP(Civil) No. 19647-
 19648 of 2025 and Civil Appeal No. 6613 of 2025 in
limine. [(@Pg 1217/ Memo for production of
documents.]
33. 12 August 2025 The NCLAT dismissed Company Appeal (AT) No. 120
of 2025 and upheld the constitution of the CoC as on
21.08.2024. Thereafter, Mr. Byju Raveendran
proceeded to remove the defects in Company Appeal
(AT)(CH)(lns) No. 416 of 2025. [@pg 2103/
Memo for production of documents.]
34. 11 September Both Mr. Byju Raveendran and Mr. Riju Ravindran
2025 filed an appeal before the Supreme Court challenging
the order dated 12.08.2025 passed by the NCLAT.