At IAS Part _______ of the Supreme Court of the State of New York, held in and for the County of Queens, at ________________, _______________, New York on the _____ day of January, 2025.

Upon the reading and the filing of the supporting Affirmation of Anthony R. Jackson, Esq., dated January 3, 2025 together with the supporting exhibits, and all prior proceedings heretofore had herein LET Defendants, along with non-parties Chang Xian Zou and Xiangjun Zhang a/k/a Xiang Jun Zhang appear and show cause before

this Court at IAS Part _________, Room ________, to be held at the Courthouse located at _______________, __________, New York on _____________, 2025 at 9:30 o'clock in the forenoon of that day, or as soon thereafter as counsel can be heard, why an Order should not be made and issued herein: (a) pursuant to CPLR § 2308(b) directing non-party CHANG XIAN ZOU (“Zou”) and non-party XIANGJUN ZHANG a/k/a Xiang Jun Zhang (“Zhang”) to produce documents in response to the subpoenas served upon them in this action and to appear for a deposition on a date designated by the Court; and (b) pursuant to Judiciary Law § 773 and/or 22 NYCRR 130-1.1 and 130-1.2 awarding the costs and reasonable attorneys’ fees incurred in compelling the non-parties’ depositions to Defendant, Yong Hua Dong in the event non-parties Zhang and Zou again fail to produce documents and/or fail to appear for a deposition on a date to be designated by the Court; and (c) granting Defendant Yong Hua Dong such other relief as the Court deems just and proper.

ORDERED, that a copy of this Order to Show Cause, together with the papers upon which it is based shall be served upon non- parties Chang Xian Zou and Xiangjun Zhang both of 182 South Street, Apt.

#11B, New York, NY 10038 by _________mail and upon all counsel of record via NYSCEF, on or before January ____, 2025, and same service shall be good and sufficient notice hereof