This page contains the Applicant’s Notice of Motion (NOM #2), dated January 31, 2025, in McLean v. TDHA et al, brought as an urgent opposed motion under Rules 37.05(3), 37.12(4), and 37.13(2)(a) of the Rules of Civil Procedure. Motion #2 seeks multiple categories of relief, including: (1) a preliminary order confirming that the presiding motion judge must not be an associate judge or any justice formerly employed by or partnered with Epstein Cole LLP; (2) directions regarding the status, hearing, and unresolved components of Motion #1, including the Tribunal’s ongoing failure to file the Record of Proceeding under section 10 of the Judicial Review Procedure Act and section 20 of the Statutory Powers Procedure Act; (3) recusal‑based relief concerning Madam Justice Shore arising from a reasonable apprehension of conflict of interest involving a former Epstein Cole client; (4) an order converting the motion in writing into a motion for judgment, or alternatively listing the JRPA Application for hearing in February 2025; and (5) administrative and costs‑related orders addressing Rule 68 compliance, Practice Direction obligations, Case Center access, nunc pro tunc amendments, and respondent factum deadlines. NOM #2 relies on the JRPA Application, Factum, Application Record, Motion Records #1 and #2, affidavits, requisitions, and the Applicant’s COI Recusal Submissions. This page forms part of LawCap’s public‑interest archive documenting judicial independence, procedural fairness, statutory compliance, and Divisional Court oversight in administrative law.