Letter,Correspondence: Employees Retirement System For The City Of Providence, Derivatively As A Shareholder Of Credit Suisse Group Ag On Behalf Of Credit Suisse Group Ag v. Urs Rohner, Iris Bohnet, Christian Gellerstad, Andreas Gottschling, Michael Klein, Shan Li, Seraina Macia, Richard Meddings, Kai S. Nargolwala, Ana Paula Pessoa, Joaquin J. Ribeiro, Severin Schwan, John Tiner, Eric Varvel, Thomas P. Gottstein, Lara J. Warner, Brian Chin, David Miller, Parshu Shah, Radhika Venkatraman, Credit Suisse Group Ag, Nominal Defendant

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                                SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK: COMMERCIAL DIVISION


    EMPLOYEES RETIREMENT SYSTEM FOR THE
    CITY OF PROVIDENCE, derivatively as a
    shareholder of CREDIT SUISSE GROUP AG on                  Index No. 651657/2022
    behalf of CREDIT SUISSE GROUP AG,

                                 Plaintiff,                   Hon. Andrea Masley

    v.                                                        Part 48

    URS ROHNER, et al.,

                                 Defendants,

    - and -

    CREDIT SUISSE GROUP AG,

                                  Nominal Defendant.



       [PROPOSED] ORDER TO SHOW CAUSE FOR UNOPPOSED ISSUANCE OF
     LETTERS OF REQUEST FOR DISCOVERY PURSUANT TO HAGUE EVIDENCE
                              CONVENTION

          Upon reading the Affirmation of Jeremy P. Robinson (the “Robinson Affirmation”),

Dated May 10, 2024, the exhibits annexed thereto, the accompanying Memorandum of Law, and

in consideration of the prior proceedings held herein and that Defendants do not oppose the

issuance of the requested letters of request, it is hereby:

          ORDERED that Defendants1 show cause before this Court at Part 48 thereof, at the

Courthouse, located at 60 Centre Street, New York, New York on the __ day of ____, 2024 at __



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  Defendants include Urs Rohner, Iris Bohnet, Christian Gellerstad, Andreas Gottschling,
Michael Klein, Shan Li, Seraina Macia, Richard Meddings, Kai S. Nargolwala, Ana Paula
Pessoa, Joaquin J. Ribeiro, Severin Schwan, John Tiner, Eric Varvel, Thomas P. Gottstein, Lara
J. Warner, Brian Chin, David Miller, Radhika Venkatraman, and nominal defendant Credit
_.m., or as soon thereafter as counsel can be heard, why an order should not be entered pursuant

to CPLR 3108, in accordance with Hague Convention of 18 March 1970 on the Taking of

Evidence Abroad in Civil or Commercial Matters (the “Hague Evidence Convention”):

           a) That this Court shall sign and affix the seal of the Court on a copy of the Letters

               of Request attached to the Robinson Affirmation as Exhibits 2-4, for the purpose

               of taking the oral depositions of Defendants Urs Rohner, Thomas Gottstein, and

               Christian Gellerstad;

           b) That this Court shall sign and affix the seal of the Court on a copy of the Letter of

               Request attached to the Robinson Affirmation as Exhibit 1, for the purpose of

               obtaining the production of documents from UBS Group AG, which absorbed

               nominal defendant Credit Suisse Group AG by way of a merger, announced in

               March 2023 and completed on June 12, 2023;

           c) Counsel for Plaintiff is authorized to obtain certified translations of the Letters of

               Request and to transmit the signed and sealed Letters of Request and certified

               translations to the Central Authority of the Requested State or other competent

               judicial authority in Switzerland, to assist in such transmittal.

        IT IS FURTHER ORDERED that service upon counsel for Defendants of a copy of this

Order, and the papers upon which it is based, by electronic means so as to be received on or

before May __, 2024, shall be deemed good and sufficient service; and

        IT IS FURTHER ORDERED that Defendants’ answering papers, if any, shall be served

on Plaintiff’s counsel by electronic means so as to be received no later that 5 p.m. on May __,

2024.


Suisse Group AG, which was absorbed by UBS Group AG as further described below.

                                                  2
Dated: ____________, 2024



ENTERED


_____________________________
Hon. Andrea Masley, J.S.C




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