Agency for Policy Coordination on State Property et al v. JPMorgan Chase Bank, N.A.
| New York Southern District Court | |
| Judge: | Vernon S Broderick |
| Case #: | 1:21-mc-00178 |
| Cause | M 77 Application to have subpoena issued to person living in this district re: action in foreign cou |
| Case Filed: | Feb 11, 2021 |
| Last checked: Thursday Mar 04, 2021 3:15 AM EST |
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Petitioner
Agency for Policy Coordination on State Property
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Represented By
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Petitioner
Erdenes Oyu Tolgoi LLC
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Represented By
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Petitioner
Erdenet Mining Corporation
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Represented By
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Respondent
JPMorgan Chase Bank, N.A.
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| Docket last updated: 2 hours ago |
| Friday, April 01, 2022 | ||
| 33 | 33
1
pgs
misc
Letter
Fri 04/01 12:38 PM
LETTER addressed to Judge Vernon S. Broderick from J. Emmett Murphy, Esq. dated 4/1/2022 re: updating Court and advising of filing Notice of Voluntary Dismissal. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Murphy, John) |
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| 32 | 32
1
pgs
notice
Notice of Voluntary Dismissal
Fri 04/01 12:31 PM
NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice and without costs against the defendant(s) JPMorgan Chase Bank, N.A.. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). ..(Murphy, John) |
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| Tuesday, March 22, 2022 | ||
| 31 | 31
2
pgs
respm
Response to Motion
Tue 03/22 12:45 PM
LETTER RESPONSE to Motion addressed to Judge Vernon S. Broderick from Orin Snyder dated March 22, 2022 re:29 LETTER MOTION to Stay all deadlines in the matter and to address certain assertions made in the February 28, 2022 letter from Intervenor Sukhbaatar Batbold (ECF Doc. No. 26) addressed to Judge Vernon S. Broderick from J. Emmett Murphy, Es . Document filed by Battushig Batbold, Sukhbaatar Batbold..(Snyder, Orin) |
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| Thursday, March 17, 2022 | ||
| 30 | 30
2
pgs
order
Order on Motion to Stay
Thu 03/17 3:31 PM
ORDER granting29 Letter Motion to Stay re:29 LETTER MOTION to Stay all deadlines in the matter and to address certain assertions made in the February 28, 2022 letter from Intervenor Sukhbaatar Batbold (ECF Doc. No. 26) addressed to Judge Vernon S. Broderick from J. Emmett Murphy, EsQ. APPLICATION GRANTED SO ORDERED. Petitioners are directed to submit a status update on or before April 1, 2022. (Signed by Judge Vernon S. Broderick on 3/17/2022) (jca) |
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| Wednesday, March 16, 2022 | ||
| 29 | 29
motion
Stay
Wed 03/16 10:27 AM
LETTER MOTION to Stay all deadlines in the matter and to address certain assertions made in the February 28, 2022 letter from Intervenor Sukhbaatar Batbold (ECF Doc. No. 26) addressed to Judge Vernon S. Broderick from J. Emmett Murphy, Esq. dated 3/16/2022. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Murphy, John) |
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| Thursday, March 10, 2022 | ||
| 28 | 28
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pgs
notice
Notice of Appearance
Thu 03/10 5:13 PM
NOTICE OF APPEARANCE by Douglas A. Kellner on behalf of Choo Young Cheong, Hak Seon Kim..(Kellner, Douglas) |
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| Tuesday, March 01, 2022 | ||
| 27 | 27
2
pgs
order
Order on Motion for Extension of Time
Tue 03/01 12:18 PM
ORDER granting26 Letter Motion for Extension of Time. APPLICATION GRANTED. SO ORDERED.. (Signed by Judge Vernon S. Broderick on 3/1/2022) (kv) |
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utility
Set/Reset Deadlines
Tue 03/01 12:19 PM
Set/Reset Deadlines: Responses due by 3/25/2022 (kv) |
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| Monday, February 28, 2022 | ||
| 26 | 26
2
pgs
motion
Extension of Time
Mon 02/28 2:53 PM
LETTER MOTION for Extension of Time for Intervenors to file their opposition to the Section 1782 Application addressed to Judge Vernon S. Broderick from Orin Snyder dated February 28, 2022. Document filed by Battushig Batbold, Sukhbaatar Batbold..(Snyder, Orin) |
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| Monday, January 31, 2022 | ||
| 25 | 25
2
pgs
order
Order on Motion to Appear Pro Hac Vice
Mon 01/31 5:15 PM
ORDER FOR ADMISSION PRO HAC VICE OF ALEXANDER KAZAM granting20 Motion for Alexander Kazam to Appear Pro Hac Vice. (Signed by Judge Vernon S. Broderick on 1/31/2022) (tg) |
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misc
Notice Regarding Pro Hac Vice Motion
Mon 01/31 9:30 AM
>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 20 MOTION for Alexander Kazam to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25652202. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu) |
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| Friday, January 28, 2022 | ||
| 24 | 24
5
pgs
respm
Declaration in Support of Motion
Fri 01/28 11:36 PM
DECLARATION of Andrew Gilliland in Support re:21 AMENDED MOTION for Discovery - Amended Ex Parte Petition For Assistance In Aid Of A Foreign Proceeding Pursuant To 28 U.S.C. § 1782 .. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Murphy, John) |
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| 23 | 23
8
pgs
respm
Declaration in Support of Motion
Fri 01/28 11:33 PM
DECLARATION of Sarah Y. Walker (Third Declararion) in Support re:21 AMENDED MOTION for Discovery - Amended Ex Parte Petition For Assistance In Aid Of A Foreign Proceeding Pursuant To 28 U.S.C. § 1782 .. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Murphy, John) |
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Att: 1
24 pgs
Exhibit 1 - Dismissal Order,
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Att: 2
50 pgs
Exhibit 2- BVI Statement of Claims
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| 22 | 22
31
pgs
respm
Memorandum of Law in Support of Motion
Fri 01/28 11:25 PM
MEMORANDUM OF LAW in Support re:21 AMENDED MOTION for Discovery - Amended Ex Parte Petition For Assistance In Aid Of A Foreign Proceeding Pursuant To 28 U.S.C. § 1782 . - Memorandum Of Law In Support Of Petitioners Amended Ex Parte Petition For Judicial Assistance Pursuant To 28 U.S.C. § 1782 . Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Murphy, John) |
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| 21 | 21
9
pgs
motion
Discovery
Fri 01/28 11:21 PM
AMENDED MOTION for Discovery - Amended Ex Parte Petition For Assistance In Aid Of A Foreign Proceeding Pursuant To 28 U.S.C. § 1782 . Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Murphy, John) |
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| 20 | 20
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pgs
motion
Appear Pro Hac Vice
Fri 01/28 1:57 PM
MOTION for Alexander Kazam to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25652202. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Kazam, Alexander) |
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Att: 1
4 pgs
Declaration in Support of Pro Hac Admission with Exhibit 1 - Certificate of Good Standing from DC Court of Appeals,
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Att: 2
2 pgs
Proposed Order
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| Monday, January 10, 2022 | ||
| 19 | 19
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pgs
order
Memo Endorsement ~Util - Set Deadlines
Mon 01/10 1:34 PM
MEMO ENDORSEMENT on re:18 Letter, filed by Erdenet Mining Corporation, Erdenes Oyu Tolgoi LLC, Agency for Policy Coordination on State Property. ENDORSEMENT: APPLICATION GRANTED SO ORDERED. (Motions due by 1/28/2022., Responses due by 3/4/2022, Replies due by 3/16/2022.) (Signed by Judge Vernon S. Broderick on 1/10/2022) (jca) |
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| Friday, January 07, 2022 | ||
| 18 | 18
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misc
Letter
Fri 01/07 7:38 PM
LETTER addressed to Judge Vernon S. Broderick from J. Emmett Murphy, Esq. dated 1/7/2022 re: proposed joint scheduling order on the merits of the Petitioners' 1782 application seeking documents from JP Morgan Chase Bank pursuant to Order17 . Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Murphy, John) |
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| Wednesday, October 20, 2021 | ||
| 16 | 16
1
pgs
notice
Notice of Appearance
Wed 10/20 11:29 PM
NOTICE OF APPEARANCE by John Emmett Murphy on behalf of Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Murphy, John) |
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| Monday, March 22, 2021 | ||
| 15 | 15
2
pgs
respm
Reply to Response to Motion
Mon 03/22 2:03 PM
LETTER REPLY to Response to Motion addressed to Judge Vernon S. Broderick from Orin Snyder dated March 22, 2021 re:8 LETTER MOTION for Discovery / Intervene addressed to Judge Vernon S. Broderick from Orin Snyder dated March 9, 2021. . Document filed by Battushig Batbold, Sukhbaatar Batbold..(Snyder, Orin) |
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Att: 1
4 pgs
Exhibit 1- Erdenet Mining Corporation Letter,
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Att: 2
4 pgs
Exhibit 2- Erdenes Oyu Tolgoi LLC Letter,
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Att: 3
4 pgs
Exhibit 3- State Agency Letter,
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Att: 4
7 pgs
Exhibit 4- Gilchrist Declaration,
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Att: 5
Exhibit 5- State Court Notice of Voluntary Discontinuance,
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Att: 6
Exhibit 6- So-ordered State Court Stipulation
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| Wednesday, March 17, 2021 | ||
| 14 | 14
4
pgs
respm
Declaration in Opposition to Motion
Wed 03/17 3:54 PM
DECLARATION of Sarah Y. Walker in Opposition re:8 LETTER MOTION for Discovery / Intervene addressed to Judge Vernon S. Broderick from Orin Snyder dated March 9, 2021.. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Berger, James) |
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| 13 | 13
19
pgs
respm
Declaration in Opposition to Motion
Wed 03/17 3:52 PM
DECLARATION of Nyamdorj Sharavdorj in Opposition re:8 LETTER MOTION for Discovery / Intervene addressed to Judge Vernon S. Broderick from Orin Snyder dated March 9, 2021.. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Berger, James) |
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Att: 1
3 pgs
Exhibit A - Constitution of Mongolia, 13 January 1992,
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Att: 2
Exhibit B - Article 20.1 of the Law on Prosecutor, dated 9 June, 2017,
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Att: 3
Exhibit C - Article 3.1.1 of Law on the Regulation of Public and Private Interests and Prevention of Conflict of Interest in Public Service, dated 19 January 2012,
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Att: 4
Exhibit D - Article 18.3 of the Law on Procedure of Administrative Court, dated 4 February 2016,
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Att: 5
Exhibit E - Sub-section 4.2.2 of the Mongolian Law on State and Local Property, dated 27 May 1996,
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Att: 6
Exhibit F - Letter from the Agency to Chairperson of the Department for Representing the State in the Courts, dated 6 July 2020,
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Att: 7
Exhibit G - Letter From Chairperson of the Department for Representing the State in the Courts to Ts. Nasanbat, dated 28 July 2020,
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Att: 8
Exhibit H - Letter From Chairperson of the Department for Representing the State in the Courts to the Bayanzurkh NS-1 District Civil Court of First Instance, dated 13 October 2020,
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Att: 9
Exhibit I - Letter from Ts. Nasabat to Sarah Walker, dated 6 November 2020,
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Att: 10
Exhibit J - Defense Statement of Su. Batbold, dated 17 November 2020
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| 12 | 12
4
pgs
respm
Response in Opposition to Motion
Wed 03/17 3:07 PM
LETTER RESPONSE in Opposition to Motion addressed to Judge Vernon S. Broderick from James E. Berger dated 3/1/7/2021 re:8 LETTER MOTION for Discovery / Intervene addressed to Judge Vernon S. Broderick from Orin Snyder dated March 9, 2021. . Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Berger, James) |
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Att: 1
20 pgs
Exhibit A - Singapore Courts February 26, 2021 decision,
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Att: 2
Exhibit B -Transcript of the New York Courts December 2, 2020 proceedings,
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Att: 3
Exhibit C - So-ordered stipulation
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| Wednesday, March 10, 2021 | ||
| 11 | 11
1
pgs
notice
Notice of Appearance
Wed 03/10 6:33 PM
NOTICE OF APPEARANCE by Karin Portlock on behalf of Battushig Batbold, Sukhbaatar Batbold..(Portlock, Karin) |
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| Tuesday, March 09, 2021 | ||
| 10 | 10
1
pgs
notice
Notice of Appearance
Tue 03/09 10:43 PM
NOTICE OF APPEARANCE by Lee Ross Crain on behalf of Battushig Batbold, Sukhbaatar Batbold..(Crain, Lee) |
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| 9 | 9
1
pgs
notice
Notice of Appearance
Tue 03/09 9:04 PM
NOTICE OF APPEARANCE by Orin Snyder on behalf of Battushig Batbold, Sukhbaatar Batbold..(Snyder, Orin) |
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| 8 | 8
5
pgs
motion
Discovery
Tue 03/09 9:01 PM
LETTER MOTION for Discovery / Intervene addressed to Judge Vernon S. Broderick from Orin Snyder dated March 9, 2021. Document filed by Sukhbaatar Batbold, Battushig Batbold..(Snyder, Orin) |
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| Friday, February 12, 2021 | ||
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misc
Notice to Court Regarding Proposed Order
Fri 02/12 8:33 AM
***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. 2 Proposed Order was reviewed and approved as to form. (km) |
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| Thursday, February 11, 2021 | ||
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2
pgs
misc
Rule 7.1 Corporate Disclosure Statement
Thu 02/11 10:36 PM
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent State of Mongolia for Agency for Policy Coordination on State Property; Corporate Parent Agency for Policy Coordination on State Property for Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Berger, James) |
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| 6 | 6
24
pgs
respm
Declaration in Support of Motion
Thu 02/11 10:30 PM
DECLARATION of Sarah Y. Walker in Support re:1 MISCELLANEOUS CASE INITIATING DOCUMENT - MOTION for Discovery - Ex Parte Petition for Assistance in Aid of A Foreign Proceeding Pursuant To 28 U.S.C. § 1782 . (Filing Fee $ 49.00, Receipt Number ANYSDC-23908132). Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Berger, James) |
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Att: 1
30 pgs
Ex. 1:Mongolian Claim (10/14/20),
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Att: 2
12 pgs
Ex. 2:Judicial Decree (10/18/20),
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Att: 3
2 pgs
Ex. 3:Letter from Yuan Wang to Battushig Batbold (12/18/08),
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Att: 4
22 pgs
Ex. 4:Genetrade Contracts E-2011 01-Mo and E-2012 01-Mo,
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Att: 5
11 pgs
Ex. 5:GreyList Report (2/26/20),
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Att: 6
38 pgs
Ex. 6:Catrison Contracts and Related Amendments,
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Att: 7
10 pgs
Ex. 7:Email correspondence between Karen McCarthy and Kelly Savopoulos (with attachments),
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Att: 8
6 pgs
Ex. 8:Amendment No. 1 to Second Cliveden Contract,
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Att: 9
45 pgs
Ex. 9:Cliveden Contracts and Related Amendments,
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Att: 10
6 pgs
Ex. 10:Apartments 711 + 716 Premier Edge Limited Ownership,
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Att: 11
2 pgs
Ex. 11:Samadi Batbold, UK Drivers License,
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Att: 12
16 pgs
Ex. 12:Knightsbridge Apartments,
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Att: 13
21 pgs
Ex. 13: New York Properties,
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Att: 14
14 pgs
Ex. 14:Thai Properties,
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Att: 15
3 pgs
Ex. 15:Premier Edge Limited, Register of Members,
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Att: 16
Ex. 16:Anti-Corruption Law [EN],
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Att: 17
5 pgs
Ex. 17:Emails between Ocean Partners and Erdenet,
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Att: 18
2 pgs
Ex. 18:Premier Edge Ltd, Register of Individual Directors,
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Att: 19
3 pgs
Ex. 19:Winrock Invest Limited, Certificate of Incorporation,
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Att: 20
7 pgs
Ex. 20:Winrock Invest Limited Registers of Members and Directors,
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Att: 21
5 pgs
Ex. 21:Winrock Invest Limited - Batbold resignation and transfer of shares,
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Att: 22
8 pgs
Ex. 22:Moonbell Group Ltd and Moonbell LLC corporate documents,
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Att: 23
2 pgs
Ex. 23:Winrock Invest Limited, Transfer of Shares,
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Att: 24
3 pgs
Ex. 24:Grandcastle Assets Inc Search Report,
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Att: 25
7 pgs
Ex. 25:Grandcastle Assets corporate documents,
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Att: 26
2 pgs
Ex. 26:Battushig Batbold CV, undated,
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Att: 27
107 pgs
Ex. 27:Correspondence about Grandcastle change of agent,
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Att: 28
2 pgs
Ex. 28:Invoice from Trident Trust to Grandcastle Assets Inc (12/1/08),
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Att: 29
2 pgs
Ex. 29:Receipt Advice (9/18/09),
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Att: 30
9 pgs
Ex. 30:Trident Emails,
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Att: 31
7 pgs
Ex. 31:Emails between Cheong Choo Young and Yuan Wang,
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Att: 32
8 pgs
Ex. 32:Genetrade Limited corporate documents,
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Att: 33
4 pgs
Ex. 33: Correspondence between Kang Eun Joo and Erdenet,
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Att: 34
2 pgs
Ex. 34:Mining License MV-00010224,
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Att: 35
11 pgs
Ex. 35:Elmbridge Assets corporate documents,
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Att: 36
14 pgs
Ex. 36:PAM LLC documents,
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Att: 37
10 pgs
Ex. 37:Bisley, Gyantbayalag and Biluutmining corporate registers,
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Att: 38
11 pgs
Ex. 38:Agency for Policy Coordination on State Property and Ors v Batbold Sukhbaatar and Ors 2020 EWHC 3179 (Comm),
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Att: 39
19 pgs
Ex. 39:Hong Kong Injunction Order,
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Att: 40
8 pgs
Ex. 40:Singapore Freezing Order,
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Att: 41
16 pgs
Ex. 41:Jersey Freezing Order,
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Att: 42
5 pgs
Ex. 42:NY Stipulation,
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Att: 43
9 pgs
Ex. 43:BVI Sealed Order
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3
pgs
respm
Declaration in Support of Motion
Thu 02/11 9:44 PM
DECLARATION of Maizorig Janchivdorj in Support re:1 MISCELLANEOUS CASE INITIATING DOCUMENT - MOTION for Discovery - Ex Parte Petition for Assistance in Aid of A Foreign Proceeding Pursuant To 28 U.S.C. § 1782 . (Filing Fee $ 49.00, Receipt Number ANYSDC-23908132). Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Berger, James) |
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| 4 | 4
26
pgs
respm
Memorandum of Law in Support of Motion
Thu 02/11 9:33 PM
MEMORANDUM OF LAW in Support re:1 MISCELLANEOUS CASE INITIATING DOCUMENT - MOTION for Discovery - Ex Parte Petition for Assistance in Aid of A Foreign Proceeding Pursuant To 28 U.S.C. § 1782 . (Filing Fee $ 49.00, Receipt Number ANYSDC-23908132) . Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation..(Berger, James) |
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| 3 | 3
3
pgs
misc
Miscellaneous Cover Sheet
Thu 02/11 9:30 PM
MISCELLANEOUS COVER SHEET filed..(Berger, James) |
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| 2 | 2
1
pgs
misc
Proposed Order
Thu 02/11 9:27 PM
PROPOSED ORDER. Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation. Related Document Number: [1 - Ex Parte Petition for Assistance in Aid of A Foreign Proceeding Pursuant To 28 U.S.C. § 1782]..(Berger, James) Proposed Order to be reviewed by Clerk's Office staff. |
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| 1 | 1
3
pgs
motion
Discovery
Thu 02/11 9:21 PM
MISCELLANEOUS CASE INITIATING DOCUMENT - MOTION for Discovery - Ex Parte Petition for Assistance in Aid of A Foreign Proceeding Pursuant To 28 U.S.C. § 1782 . (Filing Fee $ 49.00, Receipt Number ANYSDC-23908132)Document filed by Agency for Policy Coordination on State Property, Erdenes Oyu Tolgoi LLC, Erdenet Mining Corporation.(Berger, James) |
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Att: 1
Exhibit A - Form of Subpoena
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utility
Case Designated ECF
Thu 02/11 11:18 PM
Case Designated ECF. (bcu) |
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notice
Miscellaneous Case Opening Initial Assignment Notice
Thu 02/11 11:23 PM
MISCELLANEOUS CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Vernon S. Broderick. Please download and review the Individual Practices of the assigned District Judge, located at[LINK:https://nysd.uscourts.gov/judges/district-judges] . Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at[LINK:http://https://nysd.uscourts.gov/rules/ecf-related-instructions] . .(bcu) |
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