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At an Ex Parte Motion Term of the
Supreme Court of the State of New
York, held in and for the County of
New York, at 60 Centre Street, New
York, New York, onthe _ day of
March, 2017
PRESENT:
Hon. , Justice
PREG ERE RE SHEERS R SSE EES ESE eeesees x
Index No.: 655978/2016
TROJAN MARITIME INC.,
Plaintiff,
- against - $ [PROPOSED] ORDER TO
: SHOW CAUSE
TPG SPECIAL SITUATIONS PARTNERS, LLC, :
Defendant. :
woe eee eee eee eee eee eee eee -
Upon the affirmation of Rosanne E. Felicello, Esq., attorney for defendant TPG Special
Situations Partners, LLC, dated March 28, 2017, and upon all the exhibits annexed thereto, and
upon the accompanying memorandum of law in support of defendant’s motion to stay discovery
pending its motion to dismiss the Complaint, and upon all the pleadings and proceedings hereto
had herein, and sufficient cause appearing thereby it is hereby
ORDERED that Plaintiff Trojan Maritime Inc., or its attorney, show cause before the
Justice presiding at IAS Part___ of this Court at the Courthouse, Street,
New York, New York, Room on the day of , 2017, at o’clock
inthe m. on that day, or as soon thereafter as counsel may be heard, why an order should notbe issued pursuant to CPLR 3214(b), staying discovery pending determination of the defendant’s
motion to dismiss and granting such other and further relief as to the Court may seem just and
proper; and it is further
ORDERED that, answering papers, if any, shall be e-filed no later than 5:00 p.m. on or
before > 2017 upon Felicello & Melchionna LLP, counsel for defendant;
and it is further
ORDERED that e-filing of this Order to Show Cause and the accompanying papers on
behalf of defendant upon Lennon Murphy & Phillips LLC, Attn.: Anne C. LeVasseur, Esq. and
Patrick F. Lennon, Esq., 420 Lexington Avenue, Suite 300, New York, New York 10170,
counsel for plaintiff, on or before , 2017, shall be deemed good and sufficient
service thereof.
Dated: New York, New York
March _, 2017
ENTER:
JSC.