Introduction

[1] The plaintiff's application in encl 1 is for the following orders:

(a) a declaration that the defendant is not entitled to present a winding up petition for the winding up of the plaintiff based on the sum of USD6,519,874.08;

(b) an injunction to restrain the defendant from presenting a winding up petition based on the same amount in the notice of demand dated 29 October 2012; and