Defendant, LAW OFFICE OF JINCONG WU, P.C., by and through their attorneys,

LEWIS BRISBOIS BISGAARD & SMITH, LLP, as and for its answer to the Cross-Claims of defendant TBILLICK LAW PLLC, contained in its Answer with Cross-Claims, dated March 18, 2022, respectfully states upon information and belief as follows:

WHEREFORE, Defendant LAW OFFICE OF JINGCONG WU, P.C., demands judgment dismissing the Complaint and all cross-claims, together with the costs and disbursements of the within action, or in the alternative, in the event that Plaintiff recovers any verdict and/or judgment against the answering Defendant, the answering Defendant demands 4888-3099-2664.1 judgment over and against co-defendants HUANG & ASSOCIATES, P.C., LAN &

DOES 1-10 and ABC COMPANIES 1-10., in whole or in part, in accordance with the cross- claims asserted herein, together with the costs, disbursements and counsel fees incurred in the defense of this action.

New York, New York 10007 Erin Durba Michael W. Freudenberg Harrington, Ocko & Monk, LLP Local Counsel for Defendant

PLEASE TAKE NOTICE that annexed hereto is a true and accurate copy of the Order in the above-captioned action duly issued by the Honorable Lizette Colon, J.S.C.

Notice of Motion (MS#001)- And Affirmations Annexed Plaintiff's Memorandum of Law in Opposition to MS#001 Plaintiff's Answering Affirmation to MS#001 Defendant Huang & Associates, P.C s Memorandum of Law in Opposition to MS#001 Defendant Law Omec of Jingcong Wu, P.C/s Reply Affirmation in Support of MS#001 Notice of Motion (MS#002)- And Amdavits Affirmations Annexed Plaintiff's Memorandum of Law in Opposition to MS#002 Plaintiff's Answering Affirmation to MS#002 Defendant Huang & Associates, P.C.'s Memorandum of Law in Opposition to MS#002 Defendant Lan & Associates, P.C.'s Reply Memorandum of Law in Support of MS#002 Defendant Lan & Associates, P.C.'s Reply Memorandum of Law in Opposition to Hyang & Associates, P.C s Opposition to MS#002 Notice of Motion (MS#003)- And Affidavits/Affirmations Annexed Plaintiff's Memorandum of Law in Opposition to MS#003 Plaintiff's Answering Affirmation to MS#003 Defendant TBillick Law's Reply Memorandum in Support of MS#003 Notice of Motion (MS#004)- And Affidavits/Affirmations Annexed Plaintiffs Memorandum of Law in Opposition to MS#004 Plaintiffs Answering Affirmation to MS#004 Notice of Motion (MS#005)- And Affidavits/Affirmations Annexed Answering Affidavit (Af1irmation) Reply Affidavit (Affirmation) Affidavit (Affirmation) Virtual oral arguments held via Microsoft Teams.

Law Office Plaintiff's state a cognizable of Jingcong Complaint, cause Wu's together motion with of action against denied Answer as premature and pre-discovery within days.

with Defendant opposition, shall is serve Defendant dismissing fails to hereby and file Defendant Lan & Associates, Complaint Plaintiff's P.C.'s motion for an order pursuant and all other claims asserted on the basis that the claims are without merit to CPLR 3211(a)(7) Lan & Associates against state a cause and fail to with 002), Defendant opposition, shall serve is hereby and file denied Answer as premature and pre-discovery in this within days.

against Defendant an order pursuant Al DiGeronimo to CPLR the basis on with opposition, is hereby denied as premature that and l(a)(7) it fails dismissing state to pre-discovery a cause in this s motion for an order pursuant to CPLR Huang and Associates

I am a member of the bar of this State and counsel with the law firm Riker, Danzig, Scherer, Hyland & Perretti LLP, attorneys for plaintiff Liting Zhang in this action.

On the date set forth below, I caused a copy of the Notice of Entry regarding the Court’s February 17, 2022 Order to be served via NYSCEF on all counsel of record: Erin A. O’Leary, Esq. Lewis Brisbois Bisgaard & Smith LLP Attorneys for Defendant Law Office of Jingcong Wu, P.C. 77 Water Street, Suite 2100 New York, New York 10005 Joseph L. Francoeur, Esq. Wilson, Elser, Moskowitz, Edelman & Dicker, LLP Attorneys for Defendant Lan & Associates, P.C. 150 East 42nd Street New York, New York 10017 Timothy J. Staines, Esq. Raimond & Staines, LLC Attorneys for Defendant Huang & Associates, P.C. 305 Broadway, 7th Floor New York, New York 10007 Adam E. Engel, Esq.

The Engel Law Group, PLLC Attorneys for Defendants Jiayi Hu and Sheng Ye 280 Madison Avenue – Ste.

Attorneys for Defendant TBillick Law Klinedinst, P.C. 701 Fifth Avenue, Suite 4150 Seattle, Washington 98104 Michael W. Freudenberg, Esq. Harrington, Ocko & Monk, LLP Attorneys for Defendant TBillick Law 81 Main Street, Suite 215 White Plains, New York 10601 Joseph R. Costello, Esq. Menicucci Villa Cilmi, PLLC Attorneys for Defendant Al DiGeronimo 2040 Victory Boulevard Staten Island, New York 10314

Pursuant to CPLR 2106, I affirm under penalties of perjury that the

WHEREFORE, Zhang seeks judgment against the Billick Firm for compensatory damages, interest, costs of suit, including reasonable attorney’s fees, and for such other relief as the Court deems just and equitable.

WHEREFORE, Zhang seeks judgment against the Huang Firm for compensatory damages, interest, costs of suit, including reasonable attorney’s fees, and for such other relief as the Court deems just and equitable.

The Fraudsters emailed other defendants, pretended to be the Sellers’ Counsel, and intentionally provided fraudulent wiring instructions in order to abscond with the funds from the Transaction.

WHEREFORE, Zhang seeks judgment against the Fraudsters for compensatory damages, interest, costs of suit, including reasonable attorney’s fees, and for such other relief as the Court deems just and equitable.

Upon information and belief, the Fraudsters, unknown at this time and together with co-conspirators and aiders and abbettors, planned and agreed to the fraudulent scam as set forth above to abscond with the Proceeds from the Transaction.

Index No. 151220/2021 Liting Zhang - v. - Law Office of Jingcong Wu, P.C. et al

Lizette Colons (Supreme Court, Richmond County, Part IAS 21) Motion Notice You are directed to VIRTUALLY appear before Hon.

Lizette Colon on February 1, 2022 at 10:00am for oral arguments on the above captioned matter.

Microsoft Teams meeting Motion Virtual Calendar Join on your computer or mobile app at designated date and time.

The parties may also resolve motions and efile a consent order prior to the scheduled appearance (at least two days before appearance is recommended to ensure timely receipt) (Use Short Form Order).

To the Clerk of this Court and all parties of record: Please enter my appearance as counsel in this case for Defendant

LAW (the "Defendant").

Please direct all future correspondence to the undersigned at the firm's White Plains address.

Dated: White January New York Plains, 3, 2022