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  • Fermion Capital Management Ag v. Planet Project Solutions Llc, The Legal Representative Of The Estate Of John Storaska, Bret Storaska, Dean Mastrangelo, Mast High Fish Nets, Llc, Levantian Embrolios Trust Commercial - Contract - Commercial Division document preview
  • Fermion Capital Management Ag v. Planet Project Solutions Llc, The Legal Representative Of The Estate Of John Storaska, Bret Storaska, Dean Mastrangelo, Mast High Fish Nets, Llc, Levantian Embrolios Trust Commercial - Contract - Commercial Division document preview
  • Fermion Capital Management Ag v. Planet Project Solutions Llc, The Legal Representative Of The Estate Of John Storaska, Bret Storaska, Dean Mastrangelo, Mast High Fish Nets, Llc, Levantian Embrolios Trust Commercial - Contract - Commercial Division document preview
  • Fermion Capital Management Ag v. Planet Project Solutions Llc, The Legal Representative Of The Estate Of John Storaska, Bret Storaska, Dean Mastrangelo, Mast High Fish Nets, Llc, Levantian Embrolios Trust Commercial - Contract - Commercial Division document preview
  • Fermion Capital Management Ag v. Planet Project Solutions Llc, The Legal Representative Of The Estate Of John Storaska, Bret Storaska, Dean Mastrangelo, Mast High Fish Nets, Llc, Levantian Embrolios Trust Commercial - Contract - Commercial Division document preview
  • Fermion Capital Management Ag v. Planet Project Solutions Llc, The Legal Representative Of The Estate Of John Storaska, Bret Storaska, Dean Mastrangelo, Mast High Fish Nets, Llc, Levantian Embrolios Trust Commercial - Contract - Commercial Division document preview
						
                                

Preview

At Part _____ of the Supreme Court of the State of New York, County of New York, held at the Courthouse located at ________________, New York, New York on the ________ of August 2023. Present: Hon. __________________________ SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK _______________________________________________ FERMION CAPITAL MANAGEMENT AG, Petitioner, Index No. _____/2023 -against- PLANET PROJECT SOLUTIONS LLC, THE LEGAL [PROPOSED] ORDER TO SHOW CAUSE FOR AN REPRESENTATIVE OF THE ESTATE OF JOHN ORDER OF PRE- STORASKA, BRET STORASKA, DEAN ACTION DISCOVERY MASTRANGELO, MAST HIGH FISH NETS, LLC, PURSUANT TO CPLR § 3102(C) AND LEVANTIAN EMBROLIOS TRUST Respondents. _______________________________________________ On reading the Verified Petition dated August 23, 2023 the affirmation of Michael S. Devorkin, Esq., dated August 23, 2023, and the Memorandum of Law dated August 23, 2023, it is hereby ORDERED that Planet Project Solutions LLC, The Legal Representative of the Estate of John Storaska, Bret Storaska, Dean Mastrangelo, Mast High Fish Nets, LLC, and Levantian Embrolios Trust (each a “Respondent” and collectively, the “Respondents”) or their attorney show cause before the Hon. _________________, a Justice of this Court, at Part ____, Room ____, at the New York County Supreme Court courthouse located at _________________, New York, NY on the [Petitioner requests date between August 26 and 28]______ day of ____, 2023 at ______am/pm (the “Return Date”) or as soon thereafter as counsel may be heard, why an Order should not be entered: 1. Granting Petitioner, pursuant to CPLR § 3102(c), leave to serve on each Respondent a subpoena for: a. the production of documents identified in Paragraph 30 of the annexed Verified Petition, to be produced within seven (7) days of service of the relevant subpoena; b. a deposition of each Respondent, each lasting no longer than seven (7) hours, excluding breaks, and each to be taken within ten (10) business days of that Respondent’s production of the documents requested by Petitioner; 2. Directing Respondents to preserve all evidence relating to the matters described in the annexed Verified Petition, pursuant to CPLR § 3102(c); and 3. Granting such other and further relief as the Court deems just and proper. ORDERED that a copy of this Order, together with the papers upon which it is based, shall be served upon each Respondent by email and overnight mail or express delivery service, to the extent Petitioner has such information, and if not such service is waived, on or before ___________, 2023; and it is further 2 ORDERED that answering papers, if any, shall be served on or before 4:00 p.m. one day before the above return date by email to mdevorkin@golenbock.com and kdavis@golenbock.com. Petitioner shall upload each response to the NYSCEF upon receipt. ENTER: _______________________ J.S.C. 3