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Case 1:08-cv-06978-TPG Document 749 Filed 02/26/15 Page 1 of 2

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NMLCAPITAL, LTD.
Plaintiff,
-againstTHE REPUBLIC OF ARGENTINA,
Defendant.

03 Civ.
05 Civ.
06 Civ.
07 Civ.
07 Civ.
07 Civ.
08 Civ.
08 Civ.
08 Civ.
09 Civ.
09 Civ.

8845 (TPG)
2434 (TPG)
6466 (TPG)
1910 (TPG)
2690 (TPG)
6563 (TPG)
2541 (TPG)
3302 (TPG)
6978 (TPG)
1707 (TPG)
1708 (TPG)

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ORDER TO SHOW CAUSE
UPON the accompanying Declaration of Kaitlyn Kerrane, Esq., signed on February 25,
2015, and the exhibits annexed thereto, and upon all of the papers, pleadings, oral argument and
all prior proceedings in the above-captioned actions,
LET NON-PARTIES DEUTSCHE BANKAG, DEUTSCHE BANK AMERICA
HOLDING CORP., DEUTSCHE BANK SECURITIES INC., DEUTSCHE BANK TRUST
COMPANY AMERICA AND TAUNUS CORPORATION (COLLECTIVELY "DB")
AND JPMORGAN CHASE & CO. AND JPMORGAN CHASE BANK, N.A.
(COLLECTIVELY "JPMC") SHOW CAUSE, before Judge Thomas P. Griesa, room 26B, at
the United States Courthouse located at 500 Pearl Street, New York, on the 25th day of February
at 4:00p.m., or as soon thereafter as counsel may be heard, why an order should not be made and
entered as follows:
1.

Requiring non-parties DB and JPMC to:

(a)

immediately produce to NML's counsel any and all readily available

documents responsive to the subpoenas served by NML Capital, Ltd. ("NML") on DB and JMPC

15512423.1.LITIGATION

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Case 1:08-cv-06978-TPG Document 749 Filed 02/26/15 Page 2 of 2

on February 9, 2015 (the "Subpoenas") seeking information about the imminent issuance by the
Republic of Argentina ("Argentina") of approximately $2.0 billion in Bonar 2024 bonds (the
"Bonar 2024s") but, in any event, documents sufficient to describe the flow of funds with respect
to the Bonar 2024s from DB and JPMC to Argentina; and
(b)

produce by Noon on February 26, 2015 to NML's counsel all remaining

documents in their possession, custody and control responsive to the Subpoenas by email or hand
delivery; and
(c)

produce a witness or witnesses for a deposition at 3:00pm on February 26,

2015 at the offices of Quinn Emanuel Urquhart & Sullivan LLP, 51 Madison Avenue, 22nd
Floor, New York, New York 10010 to testify as to all topics identified in the Subpoenas.
2.

And for such other and further relief as this Court may deem, just, proper and

necessary under the circumstances.

SUFFICIENT CAUSE BEING ALLEGED THEREFORE, IT IS HEREBY:

ORDERED that email service of this Order to Show Cause, and the papers upon which it
is based, upon counsel for DB, Moses & Singer LLP, attention: Philippe Zimmerman and
counsel for JPMC, Levi Lubarsky & Feigenbaum LLP, attention: Andrea Likwomik Weiss, Esq.,
on or before the 4:00 pm on February 25, 2015, shall be deemed good and sufficient service;

Dated: New York, New York

February 25, 2015

Thomas P. Griesa
U.S. District Judge

15512423.1.LITIGATION