Preview
FILED: QUEENS COUNTY CLERK 03/25/2024 02:39 PM INDEX NO. 706390/2024
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/25/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
JINZHOU GROUP CO. LTD.,
Plaintiff, NOTICE OF MOTION FOR
SUMMARY JUDGEMENT IN
-against- LIEU OF COMPLAINT
Index No.
WANJUN ZHANG and DYX
INTERNATIONAL INC.,
Defendants.
NOTICE OF MOTION FOR SUMMARY JUDGMENT IN LIEU OF
COMPLAINT
PLEASE TAKE NOTICE that, upon the Summons in this action, dated March 25, 2024,
and the Affidavit of Carolyn Gurland, dated March 25, 2024, with attached exhibits, and upon all
pleadings and proceedings in this action, the Plaintiff will move this Court, at the Courthouse, 88-
11 Sutphin Boulevard, Jamaica, New York, before an IAS judge to be assigned, at 9:30 a.m. (ET)
on the 20th day of May, 2024, or a soon as counsel may be heard, for an order pursuant to CPLR
3213 and under CPLR Articles 53 and 62, (a) recognizing a foreign judgment rendered in the
People’s Republic of China on April 29, 2021, against Defendant Wanjun Zhang, (b) ordering a
related attachment, including the attachment of Wanjun Zhang’s shares in DYX International Inc.
and the assets of DYX International Inc., (c) directing entry of judgment in favor of the Plaintiff
against Defendant Wanjun Zhang and awarding damages in the amount of the aggregate amount
of RMB 26,932,900 or approximately $3,725,574.19, including (1) the deficiency of the Judgment
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FILED: QUEENS COUNTY CLERK 03/25/2024 02:39 PM INDEX NO. 706390/2024
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/25/2024
in the amount of RMB 26,618,000 or approximately $3,682,014.70; (2) interest at a rate of 0.02%
on RMB 30 million from January 17, 2020 until the date of payment, at the time of filing
approximately RMB 24,000 or $3,319.87 (3) RMB 95,900 or approximately $13,265.66 for court
fees assessed by the Wuxing District Court; and (4) RMB 195,000 or approximately $26,973.96
for court fees assessed by the People’s Court of Huzhou appellate court. See Gurland Affidavit, ¶
17. and (d) any other relief that this Court may seem just and proper, along with the costs of this
motion. This action is grounded upon an unsatisfied foreign judgment in favor of the Plaintiff.
PLEASE TAKE FURTHER NOTICE that all answering papers shall be served on the
undersigned on or before the 30th day after personal delivery of this Summons to you.
Dated: New York, New York
March 25, 2024
White & Case LLP
By: _______________________________
Carolyn Gurland
White & Case LLP
111 South Wacker Drive
Suite 5100
Chicago, Illinois 60606-4302
Tel: (312) 881-5400
Fax: (312) 881-5450
-and-
Francis Zou
Livy Mezei
White & Case LLP
1221 6th Avenue
New York, New York 10020
Tel: (212) 819-8200
Fax: (212) 354-8113
Attorneys for Plaintiff Jinzhou Group Co.
Ltd.
2
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FILED: QUEENS COUNTY CLERK 03/25/2024 02:39 PM INDEX NO. 706390/2024
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/25/2024
To:
Wanjun Zhang
No. 601, Building 6
Songfang Yuan, Shangdi Xili
Haidian District, Beijing, People’s Republic of China
3
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Preview
FILED: QUEENS COUNTY CLERK 03/25/2024 02:39 PM INDEX NO. 706390/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/25/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS JINZHOU GROUP CO. LTD., Plaintiff, NOTICE OF MOTION FOR SUMMARY JUDGEMENT IN -against- LIEU OF COMPLAINT Index No. WANJUN ZHANG and DYX INTERNATIONAL INC., Defendants. NOTICE OF MOTION FOR SUMMARY JUDGMENT IN LIEU OF COMPLAINT PLEASE TAKE NOTICE that, upon the Summons in this action, dated March 25, 2024, and the Affidavit of Carolyn Gurland, dated March 25, 2024, with attached exhibits, and upon all pleadings and proceedings in this action, the Plaintiff will move this Court, at the Courthouse, 88- 11 Sutphin Boulevard, Jamaica, New York, before an IAS judge to be assigned, at 9:30 a.m. (ET) on the 20th day of May, 2024, or a soon as counsel may be heard, for an order pursuant to CPLR 3213 and under CPLR Articles 53 and 62, (a) recognizing a foreign judgment rendered in the People’s Republic of China on April 29, 2021, against Defendant Wanjun Zhang, (b) ordering a related attachment, including the attachment of Wanjun Zhang’s shares in DYX International Inc. and the assets of DYX International Inc., (c) directing entry of judgment in favor of the Plaintiff against Defendant Wanjun Zhang and awarding damages in the amount of the aggregate amount of RMB 26,932,900 or approximately $3,725,574.19, including (1) the deficiency of the Judgment 1 of 3 FILED: QUEENS COUNTY CLERK 03/25/2024 02:39 PM INDEX NO. 706390/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/25/2024 in the amount of RMB 26,618,000 or approximately $3,682,014.70; (2) interest at a rate of 0.02% on RMB 30 million from January 17, 2020 until the date of payment, at the time of filing approximately RMB 24,000 or $3,319.87 (3) RMB 95,900 or approximately $13,265.66 for court fees assessed by the Wuxing District Court; and (4) RMB 195,000 or approximately $26,973.96 for court fees assessed by the People’s Court of Huzhou appellate court. See Gurland Affidavit, ¶ 17. and (d) any other relief that this Court may seem just and proper, along with the costs of this motion. This action is grounded upon an unsatisfied foreign judgment in favor of the Plaintiff. PLEASE TAKE FURTHER NOTICE that all answering papers shall be served on the undersigned on or before the 30th day after personal delivery of this Summons to you. Dated: New York, New York March 25, 2024 White & Case LLP By: _______________________________ Carolyn Gurland White & Case LLP 111 South Wacker Drive Suite 5100 Chicago, Illinois 60606-4302 Tel: (312) 881-5400 Fax: (312) 881-5450 -and- Francis Zou Livy Mezei White & Case LLP 1221 6th Avenue New York, New York 10020 Tel: (212) 819-8200 Fax: (212) 354-8113 Attorneys for Plaintiff Jinzhou Group Co. Ltd. 2 2 of 3 FILED: QUEENS COUNTY CLERK 03/25/2024 02:39 PM INDEX NO. 706390/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/25/2024 To: Wanjun Zhang No. 601, Building 6 Songfang Yuan, Shangdi Xili Haidian District, Beijing, People’s Republic of China 3 3 of 3