AGENCY, LLC, THE WALT DISNEY COMPANY, a : MIRAMAX FILM NY, LLC f/k/a MIRAMAX FILM :

Melodie Han, Esq., having applied to this court for admission pro hac vice to represent

Plaintiff Julia Ormond, in this action, and said applicant having submitted a motion to appear pro hac vice dated March 14, 2025, an affirmation of Lawrence M. Pearson, Esq., a member of the Bar of the State of New York and attorney of record herein for Plaintiff Julia Ormond, dated March 14, 2025, an affidavit of the applicant dated March 14, 2025, and Certificate of Good Standing from the jurisdiction in which the applicant is admitted to the practice of law, and the court having reviewed the foregoing submissions and due deliberation having been had, it is now therefore ORDERED that the motion for leave to appear pro hac vice is granted and Melodie Han, Esq. is permitted to appear and to participate in this action on behalf of Plaintiff Julia Ormond, and it is further ORDERED that she shall at all times during this action be associated with counsel who is a member in good standing of the Bar of the State of New York and is attorney of record for the aforesaid party; and it is further ORDERED that all pleadings, briefs, and other papers filed with the court shall be signed by the attorney of record, who shall be responsible for such papers and for the conduct of this action; and it is further ORDERED that, pursuant to Section 520.11 of the Rules of the Court of Appeals and Section 602.2 of the Rules of Appellate Division, First Department, the attorney hereby admitted pro hac vice shall be familiar with and abide by the standards of professional conduct imposed upon members of the New York Bar, including the rules of the courts governing the conduct of attorneys and the Rules of Professional Conduct; and it is further ORDERED that she 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 said counsel shall notify the court immediately of any matter or event in this or any other jurisdiction which affects her standing as a member of the Bar.

Dated: ________________________

In Defendants’ responses in opposition to the Motion, Defendants argue that the Court need not delay the briefing process any further to allow a second round of jurisdictional discovery.

The Sino Global Defendants (as defined in their Response) argue that Plaintiffs have failed to serve any of the Sino Global Defendants properly, and it is unclear how additional jurisdictional discovery is relevant to Case 1:23-md-03076-KMM Document 844 Entered on FLSD Docket 02/21/2025 Page 2 of 3 opposing their motion to dismiss for insufficient service of process.

The only argument proffered as to why the Court should not continue briefing deadlines absent a peek at the merits of the Jurisdictional Discovery Motion, is linked to the Court’s December 18, 2023 Order.

This argument, however, disregards the posture of the MDL at that time, wherein the Court was considering the jurisdictional discovery request for multiple tracks of Defendants, and the respective motions to dismiss were fully briefed.

The Parties’ briefing deadlines with respect to Defendants’ Rule 12(b)(2) and (5) Motions to Dismiss (ECF Nos. 815–817, 819) are hereby Case 1:23-md-03076-KMM Document 844 Entered on FLSD Docket 02/21/2025 Page 3 of 3 STAYED.

Uponthe foregoing papers, the motions to dismiss by Harvey Weinstein, The Walt Disney

supervision claims against Weinstein, Miramax Film NY, LLC, and The Walt Disney Company

liberal construction and the court must accept astrue the facts alleged in the complaint, accord the

the defendant acquired actual or constructive notice of the alleged abuse is an evidentiary fact, to

sufficient to put employeron notice that employee would share intimate images of women without

Plaintiffs and the Settling Defendants seek to resolve this dispute pursuant to the terms and conditions set forth in several settlement agreements, which have been filed with this Court (the “Settlement Agreements”) (ECF No. 565-2).

�e Court preliminarily finds, solely for purposes of effectuating the proposed settlement, that the Class satisfies the applicable factors under Federal Rule of Civil Procedure 23, specifically: i.

Contains reference and a hyperlink to a dedicated webpage established by JND Legal Administration LLC (“JND” or “Administrator”), which will include relevant documents and information regarding Class Representatives’ claims against Defendants in the FTX MDL.

�e Notice of Intention to Appear must include copies of any papers, exhibits, or other evidence that the objecting Class Member will present to the District Court in connection with the Final Approval Hearing.

All orders and findings entered in connection with the Settlements shall become null and void and have no further force and effect, shall not be used or referred to for any purposes whatsoever, and shall not be admissible or discoverable in any other proceeding; ii.

952010/2023 ZIFF, SARA vs. LOMBARDO, FABRIZIO ET AL Motion No. 004 005 007 Page 3 of 8 books; and reviewing, approving and paying the business expenses of Miramax” (Id. at ¶22) precludes Miramax from being his employer.

Notably, “[c]auses of action alleging … negligent supervision are not statutorily required to be pleaded with specificity” (Feaster v Poly Prep Country Day School, 227 AD3d 668, 670 [2d

At this juncture, the Court must credit plaintiff’s allegations that Lombardo was employed by each of these defendants (See Engelman v Rofe, 194 AD3d 26, 33-34 [1st Dept 2021], mod on other grounds by Police Benevolent Assn.

To the extent that certain allegations in the complaint indicate that the Disney Defendants or Miramax (or both) were Lombardo’s employer, any ambiguity at this juncture is properly resolved in favor of plaintiff and reserved as an issue for discovery rather than grounds for dismissal.

v PJT Partners, Inc., 40 NY3d 150, 159-60 [2023] [internal citations omitted]) and there is sufficient similarity between Lombardo’s alleged facilitation of sexual assaults by Weinstein and his own alleged sexual assault of plaintiff (See Gupta v YM Pro Corp., 197 NYS3d 189, 190 [1st Dept 2023] [knowledge that employee had “aggressive attitude” was “extremely argumentative” and hostile sufficient to put employer on notice of employee’s propensity to commit assault]; Waterbury v New York City Ballet, Inc., 205 AD3d 154, 160–161 [1st Dept 2022] [knowledge that employee “aggressively pursued young women and denigrated them in text messages” sufficient to put employer on notice that employee would share intimate images of women without consent]).

In motion sequences 005 and 007, Miramax Film NY, LLC (“Miramax” and, with the Disney Defendants, the “Corporate Defendants”) and Harvey Weinstein each move for the same relief, offering very similar arguments.

952010/2023 ZIFF, SARA vs. LOMBARDO, FABRIZIO ET AL Motion No. 004 005 007 Page 3 of 8 books; and reviewing, approving and paying the business expenses of Miramax” (Id. at ¶22) precludes Miramax from being his employer.

Notably, “[c]auses of action alleging … negligent supervision are not statutorily required to be pleaded with specificity” (Feaster v Poly Prep Country Day School, 227 AD3d 668, 670 [2d

At this juncture, the Court must credit plaintiff’s allegations that Lombardo was employed by each of these defendants (See Engelman v Rofe, 194 AD3d 26, 33-34 [1st Dept 2021], mod on other grounds by Police Benevolent Assn.

To the extent that certain allegations in the complaint indicate that the Disney Defendants or Miramax (or both) were Lombardo’s employer, any ambiguity at this juncture is properly resolved in favor of plaintiff and reserved as an issue for discovery rather than grounds for dismissal.

952010/2023 ZIFF, SARA vs. LOMBARDO, FABRIZIO ET AL Motion No. 004 005 007 Page 3 of 8 books; and reviewing, approving and paying the business expenses of Miramax” (Id. at ¶22) precludes Miramax from being his employer.

Notably, “[c]auses of action alleging … negligent supervision are not statutorily required to be pleaded with specificity” (Feaster v Poly Prep Country Day School, 227 AD3d 668, 670 [2d

At this juncture, the Court must credit plaintiff’s allegations that Lombardo was employed by each of these defendants (See Engelman v Rofe, 194 AD3d 26, 33-34 [1st Dept 2021], mod on other grounds by Police Benevolent Assn.

To the extent that certain allegations in the complaint indicate that the Disney Defendants or Miramax (or both) were Lombardo’s employer, any ambiguity at this juncture is properly resolved in favor of plaintiff and reserved as an issue for discovery rather than grounds for dismissal.

v PJT Partners, Inc., 40 NY3d 150, 159-60 [2023] [internal citations omitted]) and there is sufficient similarity between Lombardo’s alleged facilitation of sexual assaults by Weinstein and his own alleged sexual assault of plaintiff (See Gupta v YM Pro Corp., 197 NYS3d 189, 190 [1st Dept 2023] [knowledge that employee had “aggressive attitude” was “extremely argumentative” and hostile sufficient to put employer on notice of employee’s propensity to commit assault]; Waterbury v New York City Ballet, Inc., 205 AD3d 154, 160–161 [1st Dept 2022] [knowledge that employee “aggressively pursued young women and denigrated them in text messages” sufficient to put employer on notice that employee would share intimate images of women without consent]).

952010/2023 ZIFF, SARA vs. LOMBARDO, FABRIZIO ET AL Motion No. 004 005 007 Page 3 of 8 books; and reviewing, approving and paying the business expenses of Miramax” (Id. at ¶22) precludes Miramax from being his employer.

Notably, “[c]auses of action alleging … negligent supervision are not statutorily required to be pleaded with specificity” (Feaster v Poly Prep Country Day School, 227 AD3d 668, 670 [2d

At this juncture, the Court must credit plaintiff’s allegations that Lombardo was employed by each of these defendants (See Engelman v Rofe, 194 AD3d 26, 33-34 [1st Dept 2021], mod on other grounds by Police Benevolent Assn.

To the extent that certain allegations in the complaint indicate that the Disney Defendants or Miramax (or both) were Lombardo’s employer, any ambiguity at this juncture is properly resolved in favor of plaintiff and reserved as an issue for discovery rather than grounds for dismissal.

v PJT Partners, Inc., 40 NY3d 150, 159-60 [2023] [internal citations omitted]) and there is sufficient similarity between Lombardo’s alleged facilitation of sexual assaults by Weinstein and his own alleged sexual assault of plaintiff (See Gupta v YM Pro Corp., 197 NYS3d 189, 190 [1st Dept 2023] [knowledge that employee had “aggressive attitude” was “extremely argumentative” and hostile sufficient to put employer on notice of employee’s propensity to commit assault]; Waterbury v New York City Ballet, Inc., 205 AD3d 154, 160–161 [1st Dept 2022] [knowledge that employee “aggressively pursued young women and denigrated them in text messages” sufficient to put employer on notice that employee would share intimate images of women without consent]).

952010/2023 ZIFF, SARA vs. LOMBARDO, FABRIZIO ET AL Motion No. 004 005 007 Page 3 of 8 books; and reviewing, approving and paying the business expenses of Miramax” (Id. at ¶22) precludes Miramax from being his employer.

Notably, “[c]auses of action alleging … negligent supervision are not statutorily required to be pleaded with specificity” (Feaster v Poly Prep Country Day School, 227 AD3d 668, 670 [2d

At this juncture, the Court must credit plaintiff’s allegations that Lombardo was employed by each of these defendants (See Engelman v Rofe, 194 AD3d 26, 33-34 [1st Dept 2021], mod on other grounds by Police Benevolent Assn.

To the extent that certain allegations in the complaint indicate that the Disney Defendants or Miramax (or both) were Lombardo’s employer, any ambiguity at this juncture is properly resolved in favor of plaintiff and reserved as an issue for discovery rather than grounds for dismissal.

v PJT Partners, Inc., 40 NY3d 150, 159-60 [2023] [internal citations omitted]) and there is sufficient similarity between Lombardo’s alleged facilitation of sexual assaults by Weinstein and his own alleged sexual assault of plaintiff (See Gupta v YM Pro Corp., 197 NYS3d 189, 190 [1st Dept 2023] [knowledge that employee had “aggressive attitude” was “extremely argumentative” and hostile sufficient to put employer on notice of employee’s propensity to commit assault]; Waterbury v New York City Ballet, Inc., 205 AD3d 154, 160–161 [1st Dept 2022] [knowledge that employee “aggressively pursued young women and denigrated them in text messages” sufficient to put employer on notice that employee would share intimate images of women without consent]).

in In federal court, area of law, such as the Private Securities the absence of a statute to a certain Litigation specific Reform Act at the hling of a motion to dismiss or a motion for summary issue in Camelot, In NewYork courts, where the trend judgment ordinarily does not automatically stay discovery.

adequately As to the former, assertion of the privilege is an insulucient against "[t]he self-incrirnination 59 AD3d250, 250 discovery" I LP v Netschi, Credit Opportunities basis for precluding (Fortress Inc. v DeCicco, 302 AD2d48, $2-53 [1st Dept 2002].

[Ist Dept 2009], citing Access Capital, that a coun is not required to stay a civil law is clear action until a pending related "[t}he Further, has been terminated so that a party can avoid the difficulty of choosing prosecution criminal between presenting evidence in his or her own behalf'and his or her Fifth Amendment asserting (Campbell v NewYork City Trans.

the broad language of CPLR2201, this court by these is constrained Here, despite pmsecution where there stay based on pending criminal not to grant a discretionary holdings is has identity fact with the civil no argument or evidenec that such prosecution of party or action.

to meet and confer within 20 days the court encourages all parties fraught In this context, of entry of this order and make a diligent, good-faith to a reasonable discovery to stipulate effort the deadline to pmduce balances the need to proceed with the reality schedule that equitably that in February could be on the eve of, It maybe if not beyond, the date the appeals are decided.

in In federal court, area of law, such as the Private Securities the absence of a statute to a certain Litigation specific Reform Act at the hling of a motion to dismiss or a motion for summary issue in Camelot, In NewYork courts, where the trend judgment ordinarily does not automatically stay discovery.

adequately As to the former, assertion of the privilege is an insulucient against "[t]he self-incrirnination 59 AD3d250, 250 discovery" I LP v Netschi, Credit Opportunities basis for precluding (Fortress Inc. v DeCicco, 302 AD2d48, $2-53 [1st Dept 2002].

[Ist Dept 2009], citing Access Capital, that a coun is not required to stay a civil law is clear action until a pending related "[t}he Further, has been terminated so that a party can avoid the difficulty of choosing prosecution criminal between presenting evidence in his or her own behalf'and his or her Fifth Amendment asserting (Campbell v NewYork City Trans.

the broad language of CPLR2201, this court by these is constrained Here, despite pmsecution where there stay based on pending criminal not to grant a discretionary holdings is has identity fact with the civil no argument or evidenec that such prosecution of party or action.

to meet and confer within 20 days the court encourages all parties fraught In this context, of entry of this order and make a diligent, good-faith to a reasonable discovery to stipulate effort the deadline to pmduce balances the need to proceed with the reality schedule that equitably that in February could be on the eve of, It maybe if not beyond, the date the appeals are decided.

in In federal court, area of law, such as the Private Securities the absence of a statute to a certain Litigation specific Reform Act at the hling of a motion to dismiss or a motion for summary issue in Camelot, In NewYork courts, where the trend judgment ordinarily does not automatically stay discovery.

adequately As to the former, assertion of the privilege is an insulucient against "[t]he self-incrirnination 59 AD3d250, 250 discovery" I LP v Netschi, Credit Opportunities basis for precluding (Fortress Inc. v DeCicco, 302 AD2d48, $2-53 [1st Dept 2002].

[Ist Dept 2009], citing Access Capital, that a coun is not required to stay a civil law is clear action until a pending related "[t}he Further, has been terminated so that a party can avoid the difficulty of choosing prosecution criminal between presenting evidence in his or her own behalf'and his or her Fifth Amendment asserting (Campbell v NewYork City Trans.

the broad language of CPLR2201, this court by these is constrained Here, despite pmsecution where there stay based on pending criminal not to grant a discretionary holdings is has identity fact with the civil no argument or evidenec that such prosecution of party or action.

to meet and confer within 20 days the court encourages all parties fraught In this context, of entry of this order and make a diligent, good-faith to a reasonable discovery to stipulate effort the deadline to pmduce balances the need to proceed with the reality schedule that equitably that in February could be on the eve of, It maybe if not beyond, the date the appeals are decided.