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  • Makhpal Karibzhanova Application Exhibit.

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    Matias Smith
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    This is part of the application for judicial assistance of Makhpal Karibzhanova consisting of an exhibit. It's a proposed protective order requested by Vladislav Kim.

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    Makhpal Karibzhanova application exhibit.

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    This is part of the application for judicial assistance of Makhpal Karibzhanova consisting of an exhibit. It's a proposed protective order requested by Vladislav Kim.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
    68 views3 pages

    Makhpal Karibzhanova Application Exhibit.

    Uploaded by

    Matias Smith
    This is part of the application for judicial assistance of Makhpal Karibzhanova consisting of an exhibit. It's a proposed protective order requested by Vladislav Kim.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
    of 3

    Case 1:21-mc-00442-KPF Document 39-3 Filed 09/07/21 Page 1 of 3

    EXHIBIT B
    Case 1:21-mc-00442-KPF Document 39-3
    33-3 Filed 09/07/21
    09/05/21 Page 2 of 3

    UNITED STATES DISTRICT COURT


    SOUTHERN DISTRICT OF NEW YORK

    In re Application of Makhpal Karibzhanova


    for Judicial Assistance Pursuant to Case No. 21-mc-00442
    28 U.S.C. § 1782

    [PROPOSED] PROTECTIVE ORDER


    Upon the motion of Vladislav Kim to Intervene and to Modify Subpoenas and for a Protective

    Order and upon good cause shown, it is hereby:

    ORDERED that all subpoenas issued by John Moscow (“Moscow”) of Lewis Baach Kaufmann

    Middlemiss PLLC as Commissioner pursuant to this Court’s June 15, 2021 Order [DE 9] granting

    Makhpal Karibzhanova’s application for judicial assistance pursuant to 28 U.S.C. § 1782 are modified

    to exclude production of any documents or testimony concerning the following entities: LAFONDA

    INVEST PTE. LTD. (Singapore); LAFONDA HOLDING PTE. LTD. (Singapore); LAFONDA

    LIMITED (Cyprus); NAVONO LIMITED (Cyprus); SIGIRIYA LTD (Belize); ENIGMA INVEST

    PTE. LTD. (Singapore); BERGUOLLA LIMITED (Cyprus); ARATAN CAPITAL PTE. LTD.

    (Singapore); and ALGARIA LIMITED (Cyprus) (collectively, the “Subject Entities”);

    ORDERED that to the extent any person or entity subpoenaed by Moscow as Commissioner has

    complied with a request for information concerning the Subject Entities such information shall be

    promptly destroyed and Moscow shall maintain a certification of such destruction for inspection by this

    Court should the need arise;

    ORDERED that to the extent any person or entity subpoenaed by Moscow as Commissioner has

    complied with a request for information concerning the Subject Entities any person or entity in

    possession of such information shall be prohibited from using such information for any purpose;

    1
    Case 1:21-mc-00442-KPF Document 39-3
    33-3 Filed 09/07/21
    09/05/21 Page 3 of 3

    ORDERED that Moscow as Commissioner shall not issue any subpoenas seeking documents or

    testimony concerning the Subject Entities without further order of this Court; and

    ORDERED that Moscow as Commissioner shall serve a copy of this Order on all persons issued

    subpoenas which sought information concerning the Subject Entities.

    Dated: ________, 2021 ____________________________________

    Hon. Katherine Polk Failla

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