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At IAS Part __ of the Supreme Court
of the State of New York, held in and
for the County of Delaware, at the
courthouse located at 3 Court Street,
Delhi, New York, On the __ day of
April 2022.
PRESENT: Hon. Brian D. Burns
VIKKI HUI XIN HAN,
Petitioner,
v. Index No. EF 2022-182
KARMA TRIYANA [PROPOSED] AMENDED ORDER TO
DHARMACHAKRA MONASTERY,
SHOW CAUSE IN LIEU
INC, & KARMA KAGYU INSTITUTE,
INC., OF NOTICE OF PETITION
Defendants.
In lieu of a Notice of Petition pursuant to Civil Practice Laws and Rules (CPLR) §403(d), UPON the
reading and filing of Petitioner’s Petition for pre-action disclosure and all other supporting
affirmations, papers and documents, it is:
ORDERED that Respondents Karma Triyana Dharmachakra Monastery Inc. and Karma
Kagyu Institute Inc. show cause at the Supreme Court of the State of New York, in Room __ at the
courthouse located at 3 Court Street, Delhi, New York 13753, on the ___ day of _____, 2022 at ____,
or as soon thereafter as counsel can be heard, why an order should not be entered, pursuant to CPLR
§ 3102(c), compelling the following pre-action disclosure by Respondents, to be produced within
fourteen (14) days of service of the entry of this Order:
1. The names of the entities that run the Karme Ling Retreat Center (“KLRC”), and, to the
extent these entities are governed by boards, the names of the individuals on the boards of
directors governing these entities;
2. Sufficient information regarding the structure of these entities and their location of
incorporation for Petitioner to name the proper Defendants in her Complaint and properly
serve a Summons;
3. Financial records sufficient to demonstrate the source of funds sent by parties affiliated
with Respondents to Petitioner on behalf of Ogyen Trinley Dorje;
4. Granting such further relief as the Court deems just and proper.
SUFFICIENT CAUSE BEING ALLEGED THEREFORE, it is further:
ORDERED that service of a copy of this Order to Show Cause, and all supporting papers
upon which it is based, shall be served on Respondents Karma Triyana Dharmachakra Monastery Inc.,
at 335 Mead Mountain Road, Woodstock, New York, and Karma Kagyu Institute Inc., at 352 Mead
Mountain Road, Woodstock, New York, by personal service on or before April ___, 2022, which
shall be deemed good and sufficient service; and it is further
ORDERED that answering papers, if any, shall be served on or before April ____, 2022 via
overnight delivery on McAllister Olivarius, 641 Lexington Ave 13th Floor, New York, NY 10022,
Attn: Ann Olivarius, or via email to aolivarius@mcolaw.com; and it is further
ORDERED that reply papers, if any, be served upon counsel for any Respondents having
filed a notice of appearance via overnight delivery to Respondents’ addresses as listed above by
overnight delivery, on or before May ___, 2022; and it is further
ORDERED that the matter will be heard on a submitted basis and no personal appearances
are required.
Dated: April ___, 2022
Delhi, NY
ENTERED:
_______________________________
J.S.C.
Preview
At IAS Part __ of the Supreme Court of the State of New York, held in and for the County of Delaware, at the courthouse located at 3 Court Street, Delhi, New York, On the __ day of April 2022. PRESENT: Hon. Brian D. Burns VIKKI HUI XIN HAN, Petitioner, v. Index No. EF 2022-182 KARMA TRIYANA [PROPOSED] AMENDED ORDER TO DHARMACHAKRA MONASTERY, SHOW CAUSE IN LIEU INC, & KARMA KAGYU INSTITUTE, INC., OF NOTICE OF PETITION Defendants. In lieu of a Notice of Petition pursuant to Civil Practice Laws and Rules (CPLR) §403(d), UPON the reading and filing of Petitioner’s Petition for pre-action disclosure and all other supporting affirmations, papers and documents, it is: ORDERED that Respondents Karma Triyana Dharmachakra Monastery Inc. and Karma Kagyu Institute Inc. show cause at the Supreme Court of the State of New York, in Room __ at the courthouse located at 3 Court Street, Delhi, New York 13753, on the ___ day of _____, 2022 at ____, or as soon thereafter as counsel can be heard, why an order should not be entered, pursuant to CPLR § 3102(c), compelling the following pre-action disclosure by Respondents, to be produced within fourteen (14) days of service of the entry of this Order: 1. The names of the entities that run the Karme Ling Retreat Center (“KLRC”), and, to the extent these entities are governed by boards, the names of the individuals on the boards of directors governing these entities; 2. Sufficient information regarding the structure of these entities and their location of incorporation for Petitioner to name the proper Defendants in her Complaint and properly serve a Summons; 3. Financial records sufficient to demonstrate the source of funds sent by parties affiliated with Respondents to Petitioner on behalf of Ogyen Trinley Dorje; 4. Granting such further relief as the Court deems just and proper. SUFFICIENT CAUSE BEING ALLEGED THEREFORE, it is further: ORDERED that service of a copy of this Order to Show Cause, and all supporting papers upon which it is based, shall be served on Respondents Karma Triyana Dharmachakra Monastery Inc., at 335 Mead Mountain Road, Woodstock, New York, and Karma Kagyu Institute Inc., at 352 Mead Mountain Road, Woodstock, New York, by personal service on or before April ___, 2022, which shall be deemed good and sufficient service; and it is further ORDERED that answering papers, if any, shall be served on or before April ____, 2022 via overnight delivery on McAllister Olivarius, 641 Lexington Ave 13th Floor, New York, NY 10022, Attn: Ann Olivarius, or via email to aolivarius@mcolaw.com; and it is further ORDERED that reply papers, if any, be served upon counsel for any Respondents having filed a notice of appearance via overnight delivery to Respondents’ addresses as listed above by overnight delivery, on or before May ___, 2022; and it is further ORDERED that the matter will be heard on a submitted basis and no personal appearances are required. Dated: April ___, 2022 Delhi, NY ENTERED: _______________________________ J.S.C.