THIS MATTER having been presented to the Court by ROBERT J. HANTMAN, ESQ., attorney for the defendants Shangri-LA 9F, Inc., and Yi Xia, a/k/a Richard Zia, upon Motion for an Order pursuant to 22 NYCCR § 602.2 (a), granting pro hac vice admission to George Murray Hudson, Esq., and having reviewed and considered with due deliberation the Notice of Motion for Admission Pro Hac Vice of Attorney Hudson, his Affidavit and Certificate of Good Standing, it is hereby:

ORDERED, that George Murray Hudson, Esq., be admitted to practice in this department pro hac vice, to participate in any and all proceedings relative to the above-captioned matter, until such time as the matter has been completely resolved in this Court and any and all New York State Supreme Courts as this matter may be transferred to.

PLEASE TAKE NOTICE, that upon the annexed Memorandum in support, dated February 14, 2024, the undersigned moves this Court at the Centralized Motion Part at the Courthouse located at 88- 11 Sutphin Boulevard, Jamaica, New York 11435, Room 140, on March 7, 2025 at 11:00 a.m., or as soon thereafter as counsel can be heard, for an Order striking the “Notice of Appearance and Conditional Assertion of Claim to Surplus Monies” (NYSCEF Doc. No 26).

PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering papers, if any, shall be electronically filed with the Court no later than seven (7) days before the return date set forth above.

Dated: January 19, 2025

United States Attorney

Shangri-La 9F and Xia deny the allegations in paragraph 22 and affirmatively state that CTBC has filed and is pursuing the same relief in two (2) other substantially related actions involving two different real estate parcels with the same Guarantor, all of which stem from the same lending practices, representations, and obligations which led to the financial transaction that is the subject of each case.

In August 2021, Shangri-La 9F, Shangri-La Green Inc., and Manekineko Group LLC sought to borrow funds from the Bank to purchase and re-develop three (3) commercial, mixed-use real estate projects in Flushing, New York which serves New York’s largest Chinese community with approximately 30,000 people born in China.

In 2020 and 2021, the Bank became convinced that the Covid pandemic and related government stay-at-home mandates created substantial and unprecedented financial distress for commercial office buildings dependent upon tenant income to operate and satisfy debt and loan obligations.

The federal court action and freeze of funds, however, rendered it impossible for Shangri-La 9F, Shangri-La Green Inc., and Manekineko Group LLC and the Fleet entities to independently pay the financial obligations on the Bank loans.

The Bank was and remains obligated to refrain from engaging in any act or omission that will destroy or ignore the right of Shangri-La 9F, Shangri-La Green Inc., Manekineko Group LLC, and/or Xia to receive the fruits of the contractual agreements between the parties.

PLEASE TAKE NOTICE, that upon the annexed Affidavit of George Murray Hudson, Esq., dated December 20, 2024, his Certificate of Admission in Good Standing, and all other papers annexed thereto, the undersigned moves this Court to admit George Murray Hudson, Esq., pro hac vice to represent defendants Shangri-La Green, Inc., and Yi Xia, a/k/a Richard Zia on the above-referenced action.

Mr. Hudson is highly qualified and competent in the matters of this case and his assistance is necessary, as set forth in his attached Affidavit.

Mr. Hudson simultaneously seeks pro hac vice admission in the following related cases, CTBC Bank Corp. (USA), v. Manekineko Group, LLC., and Yi Xia, a/k/a Richard Zia, et al,, Supreme Court of the State of New York, County of Queens, Index No.: 718109/2024; and CTBC Bank Corp. (USA), v. Shangri-La Green Inc., and Yi Xia, a/k/a Richard Zia, et al,, Supreme Court of the State of New York, County of Queens, Index No.: 718112/2024.

PLEASE TAKE FURTHER NOTICE, that the motion is returnable at 9:30 am, on January, 21, 2025, at the Courthouse located at 88-11 Sutphin Blvd, Jamaica, NY 11435.

The Plaintiff is hereby given notice that the motion will be submitted on the papers and their personal appearance in opposition is neither required nor permitted.

Plaintiff CTBC Bank Corp. (USA) (“CTBC” or “Lender”) by its attorneys, Zeichner Ellman & Krause LLP, complains and alleges, upon information and belief, as follows:

They are named as defendants to designate any and all persons, occupants, tenants, individuals or corporations, if any, having or claiming an interest in or lien on the Premises.

This is a commercial foreclosure action to foreclose a mortgage encumbering the Premises, to secure payment of a note in the original principal amount of $2,080,000 held by CTBC (the “Loan”).

As a result of Borrower’s Default under the Loan Documents, Borrower and Guarantor are jointly and severally indebted to CTBC in the aggregate principal sum of $2,080,000 together with accrued and unpaid interest, default interest, late charges, prepayment consideration and such other costs and expenses as set forth in the Loan Documents, including without limitation, reasonable attorneys’ fees.

In order to protect its security, CTBC may be compelled during the pendency of this action to pay taxes, assessments, water rents, water meter charges, insurance premiums and any other charges affecting the Premises and CTBC requests that any sum so paid by it be added to the sum otherwise due and deemed secured by the Consolidated Mortgage and adjudged a valid lien on the Premises.

On February filed a "Notice of Appearance and Conditional 5, 2025, the United States Securities and Exchange Commission (the Assertion of Claim to Surplus Monies".

Additionally, on July 9, 2024, the federal district court released the real property at issue from any injunctive or freeze relief and authorized the parties to exercise their rights with respect to the real property and the c.ollateral secured thereby loan documents.

Finally, in the event those funds "shall be deposited into separate, segregated, accounts in each of the Mortgage Borrower's name

proceedings, the Defendants respectfully "Notice of Appearance and Conditional request Dated: February .._14, 2025.

otherwise complied with and the SECis notified of redemption under § 2410(c), and is further it may exercise its of the sale such that right of any surplus proceeds.

CTBC lacks knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph four.

Defendants fail to state a counterclaim entitling them to a return of any money or property given to CTBC in connection with the transaction.

CTBC did not owe any duties to the Defendants as the relationship between the parties was solely governed by the relevant subject mortgage loan documents.

demands judgment dismissing the Counterclaims, together with the costs and disbursements of this action, including without limitation an award of reasonable attorneys’ fees and expenses.

ANTHONYROSARIO,affirms to be true under of the following the penalties to CPLR2106: I am over the age of eighteen years, amnot a party pursuant perjury that in Bronx County, NewYork, and that on the 11tl¹ day of February, 2025, herein, and reside I served a true copy of the within PLAINTIFF'S VERIFIED REPLYTODEFENDANTSSHANGRI- LA 9F INC. ANDYIA XIA A/K/A RICHARDXIA'S COUNTERCLAIMSupon the party named at stated by depositing the place hereinafter the same, properly enclosed in a hereinafter care and custody of a U.S. Post office the exclusive addressed wrapper, into properly post-paid, regularly maintained within NewYork for delivery by first depositary class mail, to said party at last known address given below: its G. Murray Hudson, Esq. Murray Hudson Law, PLLC Pro Hac Vice Admission Pending 5255 N. Federal Highway, Suite 318 Boca Raton, Florida 33487 appearing parties by NYSCEF *All 11 th day of February 2025, under of perjury under I affirm this the penalties the laws of New York, which may include a fine or that the imprisonment, this document maybe filed is true, and I understand that in an action or foregoing proceeding in a court of law.