`Transaction ID 77053607 g-‘f«w";*, e :
`Case No. 2025-0959-LWW {2 &5 77 ¢/
`
`IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE "/ 2T 7
`
`AMI SHAFRIR BERG, )
`Plaintiff, %
`SHAI BAR LAVI and SAUL ) C.A.No.2025-0959-LWW
`BIENENFELD, )
`Defendants. %
`)
`INDEX OF EXHIBITS TO
`
`UNSWORN DECLARATION OF AMIT SHAKED IN SUPPORT OF
`OPPOSITION TO PLAINTIFF’S MOTION FOR STATUS QUO ORDER
`
`Exhibit Description
`1 Vestigo Certificate of Formation
`2 Tracki Inc. Delaware Certificate of Incorporation
`3 Trackimo Inc. Certificate of Incorporation
`3A Vestigo Technologies Ltd.-Tracki Inc. Reseller Agreement
`4 Tracki Trademark/Service Mark Application
`5 Convertible Promissory Note
`6 Tracki Inc. — Totoco Inc. Consulting Agreement
`7 April 9, 2024 — Vestigo Technologies Ltd. — Demand Letter
`April 19, 2024 — Email exchange re: Vestigo Technologies Ltd.
`8 Demand Letter
`July 3, 2024 — Berg v. Bar Lavi, Tel Aviv-Jaffa District Court —
`9 Hearing Protocol
`10 August 29, 2024 — Termination Notice
`11 September 8, 2024 — Notice of Procedural Agreement
`May 14, 2025 — Letter from Yaron Alon to Hai Michael re: False
`12 and Misleading Appeals to the Company’s Funding Entities
`June 4, 2025 — Email exchange re: The information you have
`13 requested
`14 June 5, 2025 — Additional Preliminary Notice
`September 2, 2025 — Email exchange from Hai Michael to Yaron
`15 Alon re: Westigo [sic] Technologies Ltd.
`16 Cancelled transactions
`
`
`
`
`
`
`
`
`
`Exhibit
`
`Description
`
`August 22 2025 — Notarized Translation of Motion for Interim
`
`17 Relief and Decision
`
`August 23 2025 — Notarized Translation of Motion for Interim
`18 Relief and Decision
`
`August 19, 2025 — Notarized Translation of Ami Shafrir Berg
`19 Affidavit
`
`Part A — Ami Shafrir Berg Statement of Claim
`20 Part B — Vestigo Technologies Ltd. Statement of Claim
`
`Part A — Ami Shafrir Berg Urgent Application for Interim Relief
`21 Part B — Vestigo Technologies Ltd. Application for Interim Relief
`22 Urgent Application for Consolidation of Proceedings
`23 September 3, 2025 — Decision re: Interim Relief
`24 Excerpt from Ami Shafrir Berg Statement of Claim (p. 271)
`25 September 15, 2020 — Loan Agreement
`26 September 15, 2020 — Tracki Inc. Continuing Guarantee
`
`September 15, 2020 — Trackimo, Inc. Unlimited Security
`27 Agreement
`
`September 15, 2020 — Tracki Inc. Intellectual Property Security
`28 Agreement
`
`September 15, 2020 — Trackimo, Inc. Intellectual Property
`29 Security Agreement
`
`September 14, 2020 — Email exchange between Yair Mintus and
`30 Ami Shafrir Berg
`
`September 14, 2020 — Executed Undertaking and Subordination
`31 Agreement
`32 May 27, 2021 — Loan Agreement
`
`September 13, 2020 — Waiver of Preemptive Rights and Co Sale
`33 Rights
`34 March 4, 2025 — Outline for Settlement
`
`December 2023 — WhatsApp Chat with Accompanying
`35 Documents re: Trackimo Presentation
`
`January 13, 2022 — WhatsApp Chat with Accompanying
`36 Document re: Letter of Common Ownership
`
`January 19, 2021 — Email exchange re: Unanimous Action of
`37 Directors — Tracki Inc.
`
`May 2022 — WhatsApp Chat between Ami Shafrir Berg and Shai
`38 Bar-Lavi
`39 WhatsApp Chat between Ami Shafrir Berg and Shai Bar-Lavi
`
`
`
`
`
`
`
`
`
`Dated: September 11, 2025
`
`BLANK ROME LLP
`
`David A. Dorey
`
`David A. Dorey (No. 5283)
`James G. Gorman III (No. 6284)
`1201 N. Market Street, Suite 800
`Wilmington, Delaware 19801
`Telephone: (302) 425-6418
`Facsimile: (302) 428-5102
`David.Dorey@blankrome.com
`James.Gorman@blankrome.com
`
`Attorneys for Defendants
`
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