FILED: NEW YORK COUNTY CLERK 09/03/ :13 PM

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1 INDEX NO /2014 FILED: NEW YORK COUNTY CLERK 09/03/ :13 PM NYSCEF DOC. NO. 72 RECEIVED NYSCEF: 09/03/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK RELIABLE ABSTRACT CO., LLC, Index No.: /14 Hon. Lawrence Marks J.S.C. Plaintiff, - against 45 JOHN LOFTS, LLC, CHAIM MILLER a/lc/a HARRY MILLER, CHUN PETER DONG, ANNE HSIUNG, and JOHN DOES 1-10, NOTICE OF MOTION TO ADMIT COUNSEL PRO HAC VICE Defendants. PLEASE TAKE NOTICE that, upon the annexed affirmation of Wojciech F. Jung, Esq., dated August 20, 2015, the Affidavit of David Van Grouw, Esq., sworn to on August 20, 2015, and the exhibits thereto, Defendant Ann Hsiung will move this Court, at the Motion Support Part, Room 130, at the New York County Courthouse, located at 60 Centre Street, New York, on September 14, 2015 or as soon thereafter as counsel can be heard, for an Order pursuant to Section of the Rules of the Court of Appeals and Section 602.2(a) of the Rules of the Appellate Division, First Department, admitting David A. Van Grouw, Esq. to the bar of this Court pro hac vice as counsel for Defendant. A proposed order is attached hereto for the convenience of the Court as Exhibit A. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), answering affidavits, if any, are required to be served upon the undersigned at least two (2) days before the retunr date of this motion. Dated: New York, New York September 3, 2015 LOWENSTEIN SANDLER LLP By: /s/ Wojciech F. Jung Wojciech F. Jung 1251 Avenue of the Ameircas New York, NY (212) Telephone (212) Facsimile Attorneys for Defendant Ann Hsiung 31404/3 09/03/

2 TO: MCSHAPIRO LAW GROUP, PC Jacob H. Nemon Mitchell C. Shapiro 15 Cutter Mill Road # 207 Great Neck, New York (212) Telephone (212) Facsimile Attorneys for Plaintiff TO: SILVERMAN SHIN BYRNE & GILCHREST PLLC Donald F. Schneider Andrew Achiron 381 Park Avenue South, 16th Floor New York, NY (212) Telephone Attorneys for Defendant 45 John Lofts, LLC & Chun Peter Dong -2-

3 EXHIBIT A

4 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK RELIABLE ABSTRACT CO., LLC, Plaintiff, Index No.: /14 Hon. Lawrence Marks J.S.C. - against - 45 JOHN LOFTS, LLC, CHAIM MILLER a/lc/a HARRY MILLER, CHUN PETER DONG, ANNE HSIUNG, and JOHN DOES 1-10, ORDER ADMITTING DAVID A. VAN GROUW PRO HAC VICE Defendants. This matter having come before the Court by Motion for an Order admitting David A. Van Grouw pro hac vice to represent Defendant Ann Hsiung ("Defendant") in this matter pursuant to Section (a)(1) of the Rules of the Court of Appeals and Section 602.2(a) of the Rules of the Appellate Division, First Department, and upon reading and filing of the supporting Affirmation of Wojciech F. Jung, Esq., the Affidavit of David A. Van Grouw, and the exhibits annexed thereto; IT IS hereby ORDERED that: David A. Van Grouw be and hereby is admitted to appear before this Court on behalf of Defendant on a pro hac vice basis in this matter, and it is further ORDERED, that David A. Van Grouw shall abide by any and all rules of the Courts of the State of New York and, further, that he may be subject to all disciplinary rules and regulations of the Courts of the State of New York, and it is further ORDERED, that David A. Van Grouw shall at all times be associated herein with an attonrey of record who is a member in good standing of the Bar of the State of New York and all 31404/3 09/03/

5 pleadings, briefs, and other papers filed with the Court shall be signed by the attonrey of record, who shall be held responsible for such papers and for the conduct of this action, and it is further ORDERED, that David A. Van Grouw shall be subject to the jurisdiction of the Courts of the State of New York with respect to any acts occurring during the course of his participation in this matter, and it is further ORDERED, that David A. Van Grouw shall notify the Court immediately of any matter or event in this or any other juirsdiction that affects his standing as a member of the Bar. SO ORDERED: Dated:, 2015 Honorable Lawrence Marks, J.S.C. -2-