2025.07.01 Opposition to Plaintiff's Notice of Petition to Confirm Arbitration Award

Mahender Makhijani (“Makhijani”); Continuum Analytics, Inc.; MOM AS Investor Team LLC; MOM BS Investor Group LLC; Mother CA Investor Group LLC; MOM AS Supervisor LLC; MOM BS Manager LLC; and Mother CA Manager LLC (the “MOM Functions”) submit this Opposition to Mohammad Honarkar (“Honarkar”) and his functioning entity, 4G Wi-fi, Inc.’s (the “Honarkar Functions”) Petition to substantiate Arbitration Award (“Petition to Confirm”). I. INTRODUCTION This dispute occurs from the monetary rescue that saved a sinking enterprise—only to be repaid with lousy religion efforts to unwind the very deal that stored the enterprise afloat. In 2021, Honarkar confronted economic spoil. Deeply in check here financial debt and underneath instant menace of foreclosure, he was not able to acquire $145 million essential to prevent the collapse of his housing portfolio. Honarkar turned to Makhijani and also other buyers, proposing a joint venture wherein he would contribute his assets in exchange for their support to refinance his defaulted financial loans. The buyers did just that—completin