DAVID GAO and CHEN HUA a/k/a HUA CHEN, individually and derivatively as shareholders of TYT EAST CORP., and JIN HUA RESTAURANT, INC.

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1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X TYT EAST CORP., JIN HUA RESTAURANT INC., FEN ZHENG, YI QIU LIN, LU HUI QIU, QIU LIN, HANG ZHU, and HUI SHENG LIN, individually and representing 73.33% of the shareholders of TYT East Corp. and Jin Hua Restaurant Inc., Index No /10 -against- Plaintiffs, NOTICE OF SETTLEMENT OF PROPOSED ORDER/JUDGMENT MICHAEL LAM, DAVID GAO, CHEN HUA, JOHN DOE # 1-10, JANE DOE #1-10, and XYZ CORPORATION #1-10, all names being fictitious and Presently unknown, Defendants X DAVID GAO and CHEN HUA a/k/a HUA CHEN, individually and derivatively as shareholders of TYT EAST CORP., and JIN HUA RESTAURANT, INC., -against- Third-Party Plaintiffs, JI XIONG NI a/k/a JIXIONG NI a/k/a NI JI XIONG, LILI NI a/k/a LI LI NI, YAN ZHUANG a/k/a ZHUANG YAN, NEW MONEY LINK, INC., HONG XING MANAGEMENT CORP., TYT EAST BROADWAY INC. d/b/a YUMMY YUMMY BAKERY, HONG WEI INTERNATIONAL MONEY TRANSFER CORP., PARK REGENT LLC, NEW EAST OCEAN INC., XIN HUI LIU, YAN YU LIU, CONNIE CHEN, JOHN DOE # 1-10, JANE DOE #1-10, and XYZ CORPORATION #1-10, names being fictitious and presently unknown, Third-Party Defendants X COUNSELORS: PLEASE TAKE NOTICE, that annexed is a true copy of an Order/Judgment to be presented to this Court (Hon. Shirley W. Kornreich) at IAS Part 54 at 60 Centre Street 1

2 Room 228, New York, New York for settlement and signature on September 9, Dated: New York, New York August 28, 2014 GALLET DREYER & BERKEY, LLP By: /s/ Morrell I. Berkowitz Pamela Gallagher 845 Third Avenue - 8th Floor New York, New York (212) Attorneys for Third-Party Plaintiff David Gao ANTHONY CHEH, ESQ. TO: Alfred S. Lui, Esq. Alfred S. Lui Law Offices 33 Bowery, New York, NY alfredlui49@hotmail.com Attorneys for Defendant Michael Lam Thomas Gearon, Esq. Law Office of Thomas D. Gearon, P.C Prince Street PHC Flushing, New York By: /s/ Anthony Cheh Anthony Cheh, Esq. 101 West 12th Street, #4B New York, New York aycnyc@verizon.net Attorney for Third-Party Plaintiff Chen Hua 2

3 Attorneys for Third-Party Defendants Xin Hui Liu and Hang Zhu Gregory Mouton, Esq. The Law Office of Gregory P. Mouton, Jr. 305 Broadway, 14th Floor New York, NY Phone & Fax: (646) Attorney for Third-Party Defendant Park Regent LLC and Third-Party Defendant Yan Zhuang a/k/a Zhuang Yan Peter Quan, Esq. Law Offices of Peter L. Quan, PLLC 3901 Main Street, Suite 406 Flushing, NY Attorney for Plaintiff Fen Zheng and Third-Party Defendants Ji Xiong Ni a/k/a Jixiong Ni a/k/a Ni Ji Xiong; Lili Ni a/k/a Li Li Ni; TYT East Broadway Inc. d/b/a Yummy Yummy Bakery; Yan Yu Liu; Connie Chen doc 3

4 At an IAS Part 54 of the Supreme Court of the State of New York, County of New York, located at 60 Centre Street, Room 228, New York, NY, on the P R E S E N T: day of September, 2014 Hon. Shirley Werner Kornreich, J.S.C. Presiding SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X TYT EAST CORP., JIN HUA RESTAURANT INC., FEN ZHENG, YI QIU LIN, LU HUI QIU, QIU LIN, HANG ZHU, and HUI SHENG LIN, individually and representing 73.33% of the shareholders of TYT East Corp. and Jin Hua Restaurant Inc., Plaintiffs, -against- MICHAEL LAM, DAVID GAO, CHEN HUA, JOHN DOE # 1-10, JANE DOE #1-10, and XYZ CORPORATION #1-10, all names being fictitious and Presently unknown, Defendants X DAVID GAO and CHEN HUA a/k/a HUA CHEN, individually and derivatively, as shareholders of TYT EAST CORP., and JIN HUA RESTAURANT, INC., Index No /10 PROPOSED ORDER AND JUDGMENT Third-Party Plaintiffs, -against- JI XIONG NI a/k/a JIXIONG NI a/k/a NI JI XIONG, LILI NI a/k/a LI LI NI, YAN ZHUANG a/k/a ZHUANG YAN, NEW MONEY LINK, INC., HONG XING MANAGEMENT CORP., TYT EAST BROADWAY INC. d/b/a YUMMY YUMMY BAKERY, HONG WEI INTERNATIONAL MONEY TRANSFER CORP., PARK REGENT LLC, NEW EAST OCEAN INC., XIN HUI LIU, YAN YU LIU, CONNIE CHEN, JOHN DOE # 1-10, JANE DOE #1-10, and XYZ CORPORATION #1-10, names being fictitious and presently unknown, Third-Party Defendants X

5 WHEREAS, an Answer With Counterclaims was filed in the action on May 26, 2010, by Defendants David Gao, Chen Hua a/k/a Hua Chen and Michael Lam [Dkt. no. 4]. WHEREAS, a Summons and Third-Party Complaint was filed in the action on May 16, 2012, by Third-Party Plaintiffs David Gao ( Gao ) and Chen Hua a/k/a Hua Chen ( Chen Hua ) [Dkt. nos. 31 and 31-1] alleging, inter alia, that Gao invested $639,000 in Plaintiff TYT East Corp.( TYT ) commencing in October 2008, due to representations by the Third Party Defendants, and Chen Hua invested $220,000 in TYT East Corp. starting in July 2008 and loaned $30,000 to TYT on or about May 10, 2009, due to representations by the Third Party Defendants; and WHEREAS, all Plaintiffs, Defendants, Third-Party Plaintiffs and Third-Party Defendants initially appeared in the action and were represented by counsel, and all of the Third-Party Defendants filed Answers to the Third-Party Complaint [Dkt. nos. 54, 60, 61, and 63]; and WHEREAS, Plaintiff TYT East Corp. filed a voluntary petition for relief under Chapter 11 of the U.S. Bankruptcy Code on March 23, 2013, Case No (SHL), in the United States Bankruptcy Court for the Southern District of New York [Dkt. no. 116] and the automatic stay pursuant to 11 U.S.C. 362 remains in effect with respect to TYT East Corp. only; and WHEREAS, several of the parties have not participated or otherwise appeared in the above-captioned action since the filing of their Third-Party Answers; and WHEREAS, Gao and Chen Hua filed motions for summary judgment and default judgments against various parties in the action [Dkt. nos. 187 and 222, respectively] on February 17, 2014, at an IAS Part in the Commercial Division of the Supreme Court, State of New York, New York County, before Hon. Shirley Werner Kornreich, J.S.C.; and 2

6 WHEREAS, Chen Hua entered into a Stipulation [Dkt no. 314] with Albert Togut in his capacity as the Chapter 7 Trustee for TYT East Corp., agreeing, inter alia, that all claims asserted by TYT East Corp. against Chen Hua in this action, including any claims brought derivatively, are deemed discontinued without prejudice to the rights and claims in favor of the Chapter 7 Trustee on behalf of the Debtor's estate; and that all counterclaims asserted by Chen Hua in this action against TYT East Corp., brought derivatively in the Counterclaim or otherwise, are deemed discontinued without prejudice, provided, however, that Chen Hua's claims against the other plaintiffs and the Third-Party Defendants are unaffected by said Stipulation; and said Stipulation was So Ordered by the Honorable Sean H. Lane, United States Bankruptcy Judge, on February 24, 2014 [Dkt. No. 314]; and WHEREAS, the Court heard oral argument by the appearing parties on June 10, 2014 [Dkt. no. 315]; and WHEREAS, by Order of Hon. Shirley Werner Kornreich, J.S.C. dated August 5, 2014, and entered August 7, 2014, this Court granted the motions by Gao and Chen Hua in their entirety and denied the motion by Third-Party Defendants Yan Zhuang a/k/a Zhuang Yan and Park Regent LLC, and the cross-motion by Plaintiff Hui Sheng Lin in their entirety [Dkt. no. 316]; and WHEREAS, the following parties are in default of this Court s Orders dated September 10, 2013 [Dkt. no. 132]; January 28, 2014 [Dkt. no. 153]; and August 7, 2014 [Dkt. no. 316]: i) Plaintiff Jin Hua Restaurant Corp.; ii) Plaintiff Qiu Lin; iii) Plaintiff Lu Hui Qiu; iv) Plaintiff Yi Qiu Lin; v) Plaintiff Hui Sheng Lin; vi) Plaintiff Fen Zheng; vii) Third-Party Defendant Hong Xing Management Corp.; viii) Third-Party Defendant New Money Link, Inc.; 3

7 ix) Third-Party Defendant Hong Wei International Money Transfer Corp.; and x) Third-Party Defendant New East Ocean Inc. (collectively, the Defaulting Parties ); UPON all of the foregoing, IT IS HEREBY ORDERED and ADJUDGED, that judgment is granted in favor of Third-Party Plaintiff David Gao, having an address of 15 Jay Lane, Holbrook, NY 11741, and against: i) Plaintiff Jin Hua Restaurant Corp., having a last-known address of 35 East Broadway, New York, New York 10002; ii) iii) iv) Plaintiff Qiu Lin, having a last-known address of 25 Boerum Street, #11N, Brooklyn, NY 11206; Plaintiff Lu Hui Qiu, having a last-known address of 20 East Broadway, #302, New York. NY 10002; Plaintiff Yi Qiu Lin, having a last-known address of 40 Monroe Street, Apt. FE1, New York, New York 10002; v) Plaintiff Hui Sheng Lin, having a last-known address of Sanford Avenue, #6, Flushing, NY 11355; v) Plaintiff Fen Zheng, having a last-known address of 30 Henry Street, Apt. 11, New York, NY 10002; vii) viii) ix) Third-Party Defendant Hong Xing Management Corp., having a lastknown address of 32 East Broadway, New York, New York 10002; Third-Party Defendant New Money Link, Inc., having a last-known address of 35 East Broadway, New York, New York 10002; Third-Party Defendant Hong Wei International Money Transfer Corp., having a last-known address of 37 East Broadway, New York, New York 10002; x) Third-Party Defendant New East Ocean Inc., having a last-known address of 35 East Broadway, New York, New York 10002; 4

8 xi) xii) xiii) xiv) xv) Third-Party Defendant Park Regent LLC, having a last-known address of Kissena Boulevard, Unit 101E, Flushing, New York 11355; Third-Party Defendant Ji Xiong Ni a/k/a Jixiong Ni a/k/a Ni Ji Xiong, having a last-known address of 30 Henry Street, Apt. 11, New York, NY 10002; Third-Party Defendant Lili Ni a/k/a Li Li Ni, having a last-known address of 30 Henry Street, Apt. 11, New York, NY 10002, Third-Party Defendant Yan Zhuang a/k/a Zhuang Yan, having a lastknown address of 50 Bayard Street, Apt. 7E, New York, NY 10013; Third-Party Defendant TYT East Broadway Inc. d/b/a Yummy Yummy Bakery, having a last- known address of 32 East Broadway, New York, New York 10002; xvi) Third-Party Defendant Yan Yu Liu, having a last-known address of 29 East Broadway, #4C, New York, NY 10002; and xvii) Connie Chen, having a last-known address of 200 Mercer Street, Apt. 1I, New York, NY 10012, and it is further ORDERED and ADJUDGED, that Third-Party Plaintiff David Gao, having an address of 15 Jay Lane, Holbrook, NY 11741, has judgment and does recover against the above seventeen parties [i-xvii], jointly and severally, in the amount of Six Hundred Thirty-Nine Thousand Dollars [$639,000], plus interest from October, 2008, together with costs and disbursements to be taxed by the Clerk; and it is further ORDERED and ADJUDGED, that judgment is granted in favor of Defendant Chen Hua a/k/a Hua Chen, having an address of 23 Cedar Place, First Floor, Yonkers, NY 10705, granting summary judgment pursuant to CPLR 3212, dismissing any claims by Plaintiffs against Defendant Chen Hua a/k/a Hua Chen not already discontinued under the Stipulation So Ordered by the Honorable Sean H. Lane, United States Bankruptcy Judge, on February 24, 2014 [Dkt. no. 314] together with costs and disbursements to be taxed by the Clerk; and it is further 5

9 ORDERED and ADJUDGED, that judgment is granted in favor of Defendant/Third- Party Plaintiff Chen Hua a/k/a Hua Chen having an address of 23 Cedar Place, First Floor, Yonkers, NY 10705, and against: i) Plaintiff Jin Hua Restaurant Corp., having a last-known address of 35 East Broadway, New York, New York 10002; ii) iii) iv) Plaintiff Qiu Lin, having a last-known address of 25 Boerum Street, #11N, Brooklyn, NY 11206; Plaintiff Lu Hui Qiu, having a last-known address of 20 East Broadway, #302, New York. NY 10002; Plaintiff Yi Qiu Lin, having a last-known address of 40 Monroe Street, Apt. FE1, New York, New York 10002; v) Plaintiff Hui Sheng Lin, having a last-known address of Sanford Avenue, #6, Flushing, NY 11355; vi) vii) viii) ix) Plaintiff Fen Zheng, having a last-known address of 30 Henry Street, Apt. 11, New York, NY 10002; Third-Party Defendant Hong Xing Management Corp., having a lastknown address of 32 East Broadway, New York, New York 10002; Third-Party Defendant New Money Link, Inc., having a last-known address of 35 East Broadway, New York, New York 10002; Third-Party Defendant Hong Wei International Money Transfer Corp., having a last-known address of 37 East Broadway, New York, New York 10002; x) Third-Party Defendant New East Ocean Inc., having a last-known address of 35 East Broadway, New York, New York 10002; xi) xii) Third-Party Defendant Park Regent LLC, having a last-known address of Kissena Boulevard, Unit 101E, Flushing, New York 11355; Third-Party Defendant Ji Xiong Ni a/k/a Jixiong Ni a/k/a Ni Ji Xiong, having a last-known address of 30 Henry Street, Apt. 11, New York, NY 10002; 6

10 xiii) xiv) xv) Third-Party Defendant Lili Ni a/k/a Li Li Ni, having a last-known address of 30 Henry Street, Apt. 11, New York, NY 10002, Third-Party Defendant Yan Zhuang a/k/a Zhuang Yan, having a lastknown address of 50 Bayard Street, Apt. 7E, New York, NY 10013; TYT East Broadway Inc. d/b/a Yummy Yummy Bakery, having a lastknown address of 32 East Broadway, New York, New York 10002; and xvi) Connie Chen, having a last-known address of 200 Mercer Street, Apt. 1I, New York, NY 10012, and xvii) Third-Party Defendant Yan Yu Liu, having a last-known address of 29 East Broadway, #4C, New York, NY 10002; and it is further ORDERED and ADJUDGED, that Defendant/Third-Party Plaintiff Chen Hua a/k/a Hua Chen having an address of 23 Cedar Place, First Floor, Yonkers, NY 10705, has judgment and does recover against the above seventeen parties [i-xvii], jointly and severally, in the amount of Two Hundred Fifty Thousand Dollars [$250,000], plus interest pursuant to Article 50 of the CPLR as follows: Interest Accrual Date Amount 7/24/08 $30, /02/08 $81, /08/08 $70, /20/08 $3, /04/09 $26, /17/09 $5, /18/10 $5,

11 5/10/09 $30, together with costs and disbursements to be taxed by the Clerk; and it is further ORDERED and ADJUDGED, that the Clerk is directed to enter judgment forthwith as set forth herein and Defendants/Third-Party Plaintiffs David Gao and Chen Hua a/k/a Hua Chen shall have execution therefore. Dated: New York, New York September, 2014 ENTER: SHIRLEY WERNER KORNREICH, J.S.C doc 8