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At Part 48 of the Supreme Court of
the State of New York, County of
New York, at the Courthouse, located
at 60 Centre Street, New York, New
York, on the __ day of January 2024.
PRESENT: HON. ANDREA MASLEY, J.S.C.
TS FALCON I, LLC,
Plaintiff, Index No.: 655783/2023
-v-
Motion Sequence No. 8
GOLDEN MOUNTAIN FINANCIAL CORP.,
[PROPOSED] ORDER TO
GOLDEN MOUNTAIN FINANCIAL HOLDINGS, CORP.
SHOW CAUSE PURSUANT
and GMF MIDCO, LLC,
to 22 N.Y.C.R.R § 216.1
Defendants, DIRECTING SEALING OF
CERTAIN EXHIBITS
UPON the reading and filing of the accompanying Memorandum of Law, the Affirmation
of Eric Roman and supporting exhibit in Support of Defendants Golden Mountain Financial Corp’s
(“GMFC”), Golden Mountain Financial Holdings Corp.’s (“GMFHC”), and GMF Midco, LLC’s
(“GMF Midco,” and together with GMFC and GMFHC, “Defendants”) Motion to Seal by Order to
Show Cause, dated January 22, 2024, and all pleadings and proceedings herein:
LET Defendants show cause before this Court at Commercial Division Part 48, Room 242
of the Courthouse located at 60 Centre Street, New York, New York, 10007 on the __ day of January
2024 at __ o’clock __.m., or as soon thereafter as counsel may be heard, as to why an Order pursuant
to 22 NYCRR § 216 should be entered permitting the unredacted forms of (i) the Affidavit of Shivan
Govindan In Support of Defendants’ Application For Temporary Restraining Order and Preliminary
Injunctive Relief (the “Govindan Affidavit,” NYSCEF No. 87) and (ii) Memorandum of Law In
Support of Defendants’ Application For Temporary Restraining Order and Preliminary Injunctive
Relief (the “MOL” NYSCEF No. 86) to remain under seal to anyone other than the parties, their
respective attorneys, and authorized court personnel;
IT IS FURTHER ORDERED that, pending the hearing and determination of this Order
to Show Cause, pursuant to 22 N.Y.C.R.R. § 202.5-b(k)(2), the Clerk is directed to deny access to
the sealed versions of the Govindan Affidavit and the MOL (NYSCEF Nos. 87 and 86) to anyone
other than the parties, their respective attorneys, and authorized court personnel;
IT IS FURTHER ORDERED that service of a copy of this Order to Show Cause and all
supporting papers upon which it is based on or before __________, 2024, shall be deemed
good and sufficient service; and
IT IS FURTHER ORDERED that answering papers by Plaintiff TS FALCON I, LLC
(“Falcon” or “Plaintiff”), if any, shall be electronically served and filed via the NYSCEF system
on or before 5:00 p.m. on __________, 2024.
Dated: New York, New York
January __, 2024
ENTER:
____________________________________
ANDREA MASLEY, J.S.C.
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