{"id":"court_ctb_1055_0","court":"CTB","case_no":"22-50073","doc_number":1055,"sub_number":0,"doc_type":"ORDER","filed_date":null,"title":"UNITED STATES BANRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION )","summary_zh":null,"summary_en":null,"body_en":"## **UNITED STATES BANRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n)\n\n)\n\n)\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_)\n\nIn re: ) CHAPTER 11\n\nHO WAN KWOK, ) CASE NO. 22-50073 (JAM)\n\nDebtor. ) NOVEMBER 1, 2022\n\n## **HING CHI NGOK AND GREENWICH LAND LLC'S OBJECTION TO MOTION, PURSUANT TO BANKRUPTCY RULE 9006(c)(1), TO EXPEDITE HEARING ON CHAPTER 11 TRUSTEE'S MOTION TO COMPEL**\n\nHing Chi Ngok (\"Mrs. Ngok\") and Greenwich Land LLC (\"Greenwich Land\") (collectively, the \"Respondents\"), by and through their undersigned counsel, hereby object to the *Motion, Pursuant to Bankruptcy Rule 9006(c)(1), to Expedite Hearing on Motion of Chapter 11 Trustee for Entry of Order Compelling . . . Hing Chi Ngok, Greenwich Land LLC . . . to Comply with Rule 2004 Subpoenas* (\"Motion\") (Doc. No. 1048), filed by Luc A. Despins, the Chapter 11 Trustee (the \"Trustee\"), on October 28, 2022. In support of their objection, the Respondents respectfully represent as follows:\n\n1. The Trustee served Rule 2004 Subpoenas on Greenwich Land and Mrs. Ngok on August 22, 2022 and August 23, 2022, respectively (\"Subpoena\" individually, and \"Subpoenas\" collectively).\n\n2. Counsel for the Trustee and counsel for Respondents have met and conferred regarding the Subpoenas on multiple occasions, including September 16, 2022, September 30, 2022, and October 20, 2022.\n\n3. On October 24, 2022, Trustee and Respondents submitted a *Consent Order Regarding Hing Chi Ngok's Motion for Extension of Time to Respond to Subpoena for Rule 2004 Examination* (\"Consent Order\") (Doc. No. 1022).\n\n4. Pursuant to the Consent Order, the Trustee consented to an extension of time for Respondents to produce documents in response to the Subpoenas through November 8, 2022.\n\n5. Respondents have communicated their diligence in searching for responsive documents to the Trustee.\n\n6. At no point have the Respondents or counsel for Respondents represented that they are refusing to search for \"whole categories of documents.\"\n\n7. A history of cooperation, meet-and-confer discussions, a Consent Order on the timing of production, and ongoing assurances that a search for responsive documents is underway provides no basis for an expedited hearing.\n\n8. The Trustee's assertion that the Respondents are \"either impeding the Trustee's investigation or failing to respond altogether\" lacks merit. Motion at ¶ 10. Pursuant to the Consent Order, the Respondents' extended deadline to produce documents is November 8, 2022. Since this date is still over a week away, there is no basis for the Trustee to assert that the Respondents have failed to respond.\n\n9. Further, the Motion seeks to expedite the hearing on the underlying motion to compel to November 7, 2022 (at the earliest) which is *prior to* the consented deadline for production of November 8, 2022. A hearing on such date (or November 8, 2022) would thus be premature.\n\nWHEREFORE, for the foregoing reasons, Hing Chi Ngok and Greenwich Land LLC request that the Court deny the Motion.\n\nDated at Hartford, Connecticut this 1st day of November 2022.\n\n## HING CHI NGOK and GREENWICH LAND LLC\n\nBy: */s/ Evan S. Goldstein*\n\nEvan S. Goldstein, Esq. Federal Bar No. ct22994 UPDIKE, KELLY & SPELLACY, P.C. Goodwin Square 225 Asylum Street, 20th Floor Hartford, Connecticut 06103 Tel. (860) 548-2600 Fax. (860) 548-2680 egoldstein@uks.com *Counsel to Hing Chi Ngok and Greenwich Land LLC*","body_zh":null,"key_entities":["Je","Kwok","Ho Wan Kwok","Despins"],"ecf_references":[],"word_count":534,"status":"published","published_at":null,"created_at":null,"updated_at":"2026-07-07 07:47:28"}