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At the IAS Part 72 Supreme Court,

County of Kings, held in the Supreme
Courthouse in the City of Brooklyn,

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New York, on the
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Plaintiff,
EMERGENCY
-against- ORDER TO SHOW
CAUSE
HSBC BANK USA, N.A.,
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FOR January 13,2011

SIRS/MADAMS :
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Upon the reading and filing of the annexed affirmation of Lee M Nigen, Esq.,

dated January 12,2010, together with the exhibits annexed thereto and upon all prior
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pleadings and proceedings had herein,

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LET DEFENDANT OR DEFENDANT’S ATTORNEY SHOW CAUSE at the

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Supreme Court, County of Kings IAS, Part 1&:’3360 Adams Street, Brooklyn, New York,

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11201, on the 27 of dd&R 2011, at 9:30 o’clock in the forenoon, or as soon

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thereafter as counsel can be heard:

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WHY AN ORDER SHOULD NOT BE MADE A N D ENTERED HEREIN

AS FOLLOWS:
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1. For a Temporary Restraining Order (“TRO”) staying any commencement of a

public sale of Plaintiffs shares of personal property, located at 135 Ocean Parkway, Unit
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16D, Brooklyn, New York, 11218, as Plaintiff was never served with a Notice of Sale,

pending a hearing on this matter, and as Plaintiff has meritorious defenses to such sale

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and will be irreparably harmed if the public sale is not stayed; and

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2. For such other and further relief which this Court may deem just and proper.

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NOW, IT IS ORDERED THAT EXECUTION OF ANY PUBLIC SHARES

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OF PLAINTIFF’S PROPERTY, LOCATED AT 135 OCEAN PARKWAY, UNIT

16-D, BROOKLYN, NEW YORK, 11218, SHALL BE STAYED PENDING THE

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DEFENDANT HSBC BANK USA, N.A. BE BTAYED FROM EXECUTING A

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PUBLIC SALE OF PLAINTIFF’S SHARE OF STOCK ON JANUARY 13,2011 at
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2:OO P.M.
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SUFFICIENT CAUSE THEREFORB: APPEARING, LEfservice of a cop of
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this Order together with the papers upon which it is based’and annexed hereto, Ppon

Defendant HSBC BANK USA, N.A. and/or their attorney,

or

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or before ‘f 13‘‘ 3
- 2011 be deemed good and
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sufficient service.
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