{"id":"court_ctb_1070_0","court":"CTB","case_no":"22-50073","doc_number":1070,"sub_number":0,"doc_type":"ORDER","filed_date":"2022-11-07","title":"| UNITED STATES BANKRUPTCY COURT | |--------------------------------|","summary_zh":null,"summary_en":null,"body_en":"| UNITED STATES BANKRUPTCY COURT |\n|--------------------------------|\n| DISTRICT OF CONNECTICUT        |\n| BRIDGEPORT DIVISION            |\n\n| ----------------------------------------------------------- | x           |                            |\n|-------------------------------------------------------------|-------------|----------------------------|\n|                                                             | :           |                            |\n| In re:                                                      | :           | Chapter 11                 |\n| 1<br>HO WAN KWOK,<br>et al.,                                | :<br>:<br>: | Case No. 22-50073 (JAM)    |\n| Debtors.                                                    | :<br>:      | (Jointly Administered)     |\n| ----------------------------------------------------------- | x           |                            |\n|                                                             | :           |                            |\n| In re:                                                      | :           | Chapter 11                 |\n|                                                             | :           |                            |\n| GENEVER HOLDINGS LLC,                                       | :           | Case No. 22-50592<br>(JAM) |\n|                                                             | :           |                            |\n| Debtor.                                                     | :           |                            |\n|                                                             | :           |                            |\n| ----------------------------------------------------------- | x           |                            |\n\n## **MOTION OF (A) CHAPTER 11 TRUSTEE FOR CHAPTER 11 CASE OF HO WAN KWOK, (B) GENEVER HOLDINGS CORPORATION, AND (C) GENEVER HOLDINGS LLC FOR ENTRY OF ORDER (I) DIRECTING JOINT ADMINISTRATION OF RELATED CHAPTER 11 CASES AND (II) GRANTING RELATED RELIEF**\n\nLuc A. Despins, in his capacity as the chapter 11 trustee (the \"Trustee\") appointed in the chapter 11 case of Ho Wan Kwok (the \"Individual Debtor\"), Genever Holdings Corporation (the \"Genever (BVI) Debtor\"), and Genever Holdings LLC ( \"Genever (US) Debtor\" and, together with the Trustee and the Genever (BVI) Debtor, the \"Movants\") jointly file this motion (the \"Motion\") requesting entry of an order, substantially in the form attached hereto as **Exhibit A** (the \"Proposed Order\"): (i) directing procedural consolidation and joint administration of the chapter 11 case of the Genever (US) Debtor and the jointly administered chapter 11 cases of the\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595) and Genever Holdings Corporation. The mailing address for the Trustee and the Genever (BVI) Debtor is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\nIndividual Debtor and the Genever (BVI) Debtor (the three chapter 11 cases, collectively, the \"Chapter 11 Cases\"); and (ii) granting related relief. Pursuant to Rule 1015-1 of the Local Rules of Bankruptcy Procedure of the United States Bankruptcy Court for the District of Connecticut (the \"Local Rules\") the Movants incorporate herein by reference the *Affidavit of Luc A. Despins in Support of Motion for Entry of Order (I) Directing Joint Administration of Related Chapter 11 Cases and (II) Granting Related Relief* (the \"Despins Affidavit\"), attached hereto as **Exhibit B**, setting forth facts warranting the joint administration of the Chapter 11 Cases. In support of this Motion, the Movants respectfully state as follows.\n\n### **JURISDICTION, VENUE, AND STATUTORY BASES**\n\n1. The United States Bankruptcy Court for the District of Connecticut (the \"Court\") has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the *Standing Order of Reference* from the United States District Court for the District of Connecticut (as amended). This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2).\n\n2. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.\n\n3. The bases for the relief requested herein are Bankruptcy Rule 1015 and Local Rule 1015-1.\n\n### **BACKGROUND**\n\n### **A. Individual Debtor's and Genever (BVI) Debtor's Cases**\n\n4. On February 15, 2022, the Individual Debtor filed with the Court a voluntary petition for relief under chapter 11 of title 11 of the United States Code (the \"Bankruptcy Code\").\n\n5. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (\"Committee\") in the Individual Debtor's chapter 11 case. No examiner has been appointed in the Individual Debtor's chapter 11 case.\n\n6. On June 15, 2022, the Court entered a memorandum of decision and order [Docket No. 465 in Case No. 22-50073 (JAM)] (the \"Trustee Order\") directing the United States Trustee to appoint a chapter 11 trustee in the Individual Debtor's chapter 11 case. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of the Trustee as the chapter 11 trustee in the Individual Debtor's chapter 11 case [Docket No. 523 in Case No. 22-50073 (JAM)].\n\n7. On August 10, 2022, the Court entered an order [Docket No. 717 in Case No. 22- 50073 (JAM)] (the \"Corporate Governance Rights Order\") which, among other things, (a) confirms the Trustee holds all of the Individual Debtor's economic and governance rights with respect to all corporate entities owned and/or controlled by the Individual Debtor, including the Genever (BVI) Debtor and (b) directs the Individual Debtor to \"cooperate with the Trustee to enable the Trustee to perform his duties\" and \"surrender to the Trustee all property of the estate and any recorded information, including, without limitation, books, documents, records, and papers relating to property of the estate (including, without limitation, his shares in Genever (BVI) and all related corporate governance documents).\" Corporate Governance Rights Order ¶¶ 2, 3.\n\n8. In accordance with the Corporate Governance Rights Order, the Individual Debtor's shares in the Genever (BVI) Debtor were transferred to the Trustee and such transfer was registered with the registered agent for the Genever (BVI) Debtor in the British Virgin Islands (\"BVI\").\n\n9. On September 14, 2022, the Trustee removed Ho Wan Kwok as the sole director of the Genever (BVI) Debtor, replacing him with Claire Abrehart of Harneys Corporate Services Limited (a BVI company that provides, among other things, director services to clients incorporated in the BVI).\n\n10. On October 11, 2022, Genever (BVI) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.\n\n11. No trustee or official committee of unsecured creditors has been appointed in Genever (BVI)'s chapter 11 case.\n\n12. October 14, 2022, the Court entered an order granting joint administration of the Individual Debtor's chapter 11 case and Genever (BVI)'s chapter 11 case [Docket No. 970].\n\n### **B. Genever (US) Debtor's Chapter 11 Case**\n\n13. On October 12, 2020, the Genever (US) Debtor filed its chapter 11 petition in the United State Bankruptcy Court for the Southern District of New York (the \"New York Bankruptcy Court\").\n\n14. The Genever (US) Debtor is a wholly owned subsidiary of the Genever (BVI) Debtor.\n\n15. On the Genever (US) Debtor's Schedules of Assets and Liabilities, the Genever (US) Debtor's only scheduled assets are the Residence at the Sherry Netherland Hotel in New York, New York, and a related security deposit for a total scheduled value of approximately \\$73 million.\n\n16. On September 30, 2022, the Trustee and Genever (US) Debtor filed their joint motion to transfer venue of the Genever (US) Debtor's chapter 11 case to this Court [Docket No. 211 in Case No. 20-12411 (JLG)] (the \"Venue Transfer Motion\").\n\n17. By order dated November 3, 2022, the New York Bankruptcy Court granted the\n\nVenue Transfer Motion, transferring the chapter 11 case of the Genever (US) Debtor to this\n\nCourt.\n\n## **RELIEF REQUESTED**\n\n18. The Movants request that the Court maintain one file and one docket for the\n\nChapter 11 Cases under the case of the Individual Debtor, and that the Chapter 11 Cases be\n\nadministered under the following caption:\n\n# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| --------------------------------------------------------------- | x                            |\n|-----------------------------------------------------------------|------------------------------|\n|                                                                 | :                            |\n| In re:                                                          | :<br>Chapter 11              |\n|                                                                 | :                            |\n| 1<br>HO WAN KWOK,<br>et al.,                                    | :<br>Case No. 22-50073 (JAM) |\n|                                                                 | :                            |\n| Debtors.                                                        | :<br>(Jointly Administered)  |\n| --------------------------------------------------------------- | x                            |\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\n19. The Movants further request that the Court order that the foregoing caption\n\nsatisfies the requirements set forth in section 342(c)(1) of the Bankruptcy Code.\n\n20. Additionally, the Movants request that an entry be made on the Genever (US)\n\nDebtor's chapter 11 case docket substantially similar to the following:\n\nAn order has been entered in accordance with Rule 1015(b) of the Federal Rules of Bankruptcy Procedure and Rule 1015-1 of the Local Rules of Bankruptcy Procedure of the United States Bankruptcy Court for the District of Connecticut directing joint administration of the chapter 11 cases of Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases; last four digits of tax identification number: 9595), Genever Holdings Corporation, and Genever\n\nHoldings LLC. The docket in the chapter 11 case of Ho Wan Kwok, Case No. 22-50073 (JAM) should be consulted for all matters affecting this case.\n\n### **Basis for Relief**\n\n21. Bankruptcy Rule 1015(b) provides that \"[i]f . . . two or more petitions are pending in the same court by or against . . . a debtor and an affiliate, the court may order a joint administration of the estates.\"<sup>2</sup> The debtors in the Chapter 11 Cases are \"affiliates\" as that term is defined in section 101(2) of the Bankruptcy Code. Accordingly, the Bankruptcy Code and Bankruptcy Rules authorize the Court to grant the relief requested herein.\n\n22. Joint administration is generally non-controversial, and courts in this district routinely order joint administration in cases with affiliated debtors. *See, e.g.*, *In re Latex Foam Int'l, LLC*, Case No. 19-51064.\n\n23. Given that the Trustee is administering the Individual Debtor's estate and is the registered owner of the shares in the Genever (BVI) Debtor, of which the Genever (US) Debtor is a wholly owned subsidiary, and given that the Genever (BVI) Debtor's case is already being jointly administered with the Individual Debtor's case, joint administration of the Chapter 11 Cases will provide significant administrative convenience without harming the substantive rights of any party in interest. Many of the motions, hearings, and orders in the Chapter 11 Cases will affect the Individual Debtor, Genever (US) Debtor, and the Genever (BVI) Debtor. The entry of the Order directing joint administration of the Chapter 11 Cases will reduce fees and costs by avoiding duplicative filings and objections. *See, e.g.*, *In re I.R.C.C., Inc.*, 105 B.R. 237, 238 (Bankr. S.D.N.Y. 1989) (joint administration promotes administrative convenience without affecting substantive rights); *In re Stuery*, 94 B.R. 553, 554 (Bankr. N.D. Ind. 1988) (same); *In*\n\n<sup>2</sup> FED. R. BANKR. P. 1015(b).\n\n*re Parkway Calabasas Ltd.*, 89 B.R. 832, 836 (Bankr. C.D. Cal. 1988) (same) *aff'd* 949 F.2d 1058 (9th Cir. 1991). Joint administration also will allow the Office of the United States Trustee and all parties in interest to monitor the Chapter 11 Cases with greater ease and efficiency.\n\n24. Moreover, joint administration will not adversely affect the Individual Debtor's, the Genever (BVI) Debtor's, or the Genever (US) Debtor's (together, collectively, the \"Debtors\") respective constituencies because this Motion seeks only administrative, **not** substantive, consolidation of the Debtors' estates. Parties in interest will not be harmed by the relief requested; instead, parties in interest will benefit from the cost reductions associated with the joint administration of the Chapter 11 Cases. Accordingly, the Movants submit that the joint administration of the Chapter 11 Cases is in the best interests of the three Debtors' estates, their creditors, and all other parties in interest.\n\n### **No Previous Request**\n\n25. No previous request for the relief sought herein has been made to this or any Court.\n\n### **Notice**\n\n26. The Movants will provide notice of this Motion to all parties-in-interest appearing in the (i) Individual Debtor's Chapter 11 case, (ii) Genever (BVI)'s chapter 11 case, and (iii) Genever (US)'s chapter 11 case qualified to receive electronic notice via the Court's CM/ECF service, with copies to be served by United States Postal Service on the Individual Debtor, the Genever (BVI) Debtor, Genever (US) Debtor, the Committee, the United States Trustee, the holders of claims filed in the Genever (US) case, the holders of the 20 largest unsecured claims against the Genever (BVI) Debtor, and any other parties entitled to notice pursuant to Local Rule 2002-1. The Movants submit that, in light of the nature of the relief requested, no other or further notice need be given.\n\nWHEREFORE, the Movants respectfully requests entry of the Proposed Order\n\n(a) granting the relief requested herein, and (b) granting such other relief as is just and proper.\n\nDated: November 7, 2022 New Haven, Connecticut\n\n### GENEVER HOLDINGS LLC\n\nBy: /s/Douglas S. Skalka\n\nDouglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 821-2000 dskalka@npmlaw.com plinsey@npmlaw.com\n\n*and*\n\nKevin J. Nash, Esq. GOLDBERG WEPRIN FINKEL GOLDSTEIN LLP 1501 Broadway, 22nd Floor New York, New York 10036 (212) 221-5700\n\n*Counsel for Genever Holdings LLC Debtor and Debtor-in-Possession*\n\n## GENEVER HOLDINGS CORPORATION\n\nBy: /s/Douglas S. Skalka Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 821-2000 dskalka@npmlaw.com plinsey@npmlaw.com\n\n*Counsel for Genever Holdings Corporation Debtor and Debtor-in-Possession*\n\n## LUC A. DESPINS, CHAPTER 11 TRUSTEE\n\nBy: /s/Douglas S. Skalka\n\nDouglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 821-2000 dskalka@npmlaw.com plinsey@npmlaw.com\n\n*and*\n\nNicholas A. Bassett *(pro hac vice*) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com\n\n*and*\n\nDouglass Barron (*pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 douglassbarron@paulhastings.com\n\n*Counsel for the Chapter 11 Trustee*\n\nCase 22-50073 Doc 1070 Filed 11/07/22 Entered 11/07/22 15:46:29 Page 9 of 18\n\n## **EXHIBIT A**\n\n**Proposed Order**\n\n| UNITED STATES BANKRUPTCY COURT<br>DISTRICT OF CONNECTICUT<br>BRIDGEPORT DIVISION |                                       |  |\n|----------------------------------------------------------------------------------|---------------------------------------|--|\n| -----------------------------------------------------------                      | x                                     |  |\n| In re:                                                                           | :<br>:<br>Chapter 11                  |  |\n| 1<br>HO WAN KWOK,<br>et al.,                                                     | :<br>:<br>Case No. 22-50073 (JAM)     |  |\n| Debtors.                                                                         | :<br>:<br>(Jointly Administered)<br>: |  |\n| -----------------------------------------------------------                      | x<br>:                                |  |\n| In re:                                                                           | :<br>Chapter 11                       |  |\n| GENEVER HOLDINGS LLC,                                                            | :<br>:<br>Case No. 22-50592<br>(JAM)  |  |\n| Debtor.                                                                          | :<br>:                                |  |\n| -----------------------------------------------------------                      | :<br>x                                |  |\n\n# **ORDER DIRECTING JOINT ADMINISTRATION OF RELATED CHAPTER 11 CASES**\n\nUpon the motion (the \"Motion\")<sup>2</sup> of Luc A. Despins, in his capacity as the chapter 11 trustee (the \"Trustee\") appointed in the chapter 11 case of Ho Wan Kwok (the \"Individual Debtor\"), Genever Holdings Corporation (the \"Genever (BVI) Debtor\") and Genever Holdings LLC ( \"Genever (US) Debtor\" and, together with the Trustee and the Genever (BVI) Debtor, the \"Movants\") for entry of an order (this \"Order\"): (a) directing procedural consolidation and joint administration of the chapter 11 case of the Genever (US) Debtor and the chapter 11 cases of the Individual Debtor and Genever (BVI) Debtor (collectively, the \"Chapter 11 Cases\") and (b) granting related relief, all as more fully set forth in the Motion; and this Court having\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595) and Genever Holdings Corporation. The mailing address for the Trustee and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\n<sup>2</sup> Capitalized terms used but not otherwise defined herein have the meanings given to such terms in the Motion.\n\njurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the *Standing Order of Reference* from the United States District Court for the District of Connecticut (as amended); and this Court having found that this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and this Court having found that venue of this proceeding and the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and this Court having found that the relief requested in the Motion is in the best interests of the estates of the Individual Debtor, the Genever (BVI) Debtor, and the Genever (US) Debtor, their creditors, and other parties in interest; and this Court having found that the Movants' notice of the Motion and opportunity for a hearing on the Motion were appropriate under the circumstances and no other notice need be provided; and this Court having reviewed the Motion and having heard the statements in support of the relief requested therein at a hearing before this Court (the \"Hearing\"); and this Court having determined that the legal and factual bases set forth in the Motion and at the Hearing establish just cause for the relief granted herein; and upon all of the proceedings had before this Court; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT:\n\n1. The Motion is granted as set forth herein.\n\n2. The Chapter 11 Cases are consolidated for procedural purposes only and shall be jointly administered by this Court under Case No. 22-50073 (JAM).\n\n3. The caption of the jointly administered cases shall read as follows:\n\n## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ---------------------------------------------------------------             | x                                     |\n|-----------------------------------------------------------------------------|---------------------------------------|\n|                                                                             | :                                     |\n| In re:                                                                      | :<br>Chapter 11                       |\n| 1<br>HO WAN KWOK,<br>et al.,                                                | :<br>:<br>Case No. 22-50073 (JAM)     |\n| Debtors.<br>--------------------------------------------------------------- | :<br>:<br>(Jointly Administered)<br>x |\n|                                                                             |                                       |\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\n4. The foregoing caption satisfies the requirements set forth in section 342(c)(1) of\n\nthe Bankruptcy Code.\n\n5. An entry shall be made on the Genever (US) Debtor's chapter 11 case docket that\n\nis substantially similar to the following:\n\nAn order has been entered in accordance with Rule 1015(b) of the Federal Rules of Bankruptcy Procedure and Rule 1015-1 of the Local Rules of Bankruptcy Procedure of the United States Bankruptcy Court for the District of Connecticut directing joint administration of the chapter 11 cases of Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases; last four digits of tax identification number: 9595), Genever Holdings Corporation, and Genever Holdings LLC. The docket in the chapter 11 case of Ho Wan Kwok, Case No. 22-50073 (JAM) should be consulted for all matters affecting this case.\n\n6. The Trustee, the Genever (BVI) Debtor, and the Genever (US) Debtor shall\n\nmaintain, and the Clerk of the United States Bankruptcy Court for the District of Connecticut\n\nshall keep, one consolidated docket, one file, and one consolidated service list.\n\n7. Nothing contained in the Motion or this Order shall be deemed or construed as\n\ndirecting or otherwise effecting a substantive consolidation of the Chapter 11 Cases.\n\n8. The Trustee, the Genever (BVI) Debtor, and the Genever (US) Debtor are authorized to take all actions necessary to effectuate the relief granted in this Order in accordance with the Motion.\n\n9. This Court retains exclusive jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order.\n\nCase 22-50073 Doc 1070 Filed 11/07/22 Entered 11/07/22 15:46:29 Page 14 of 18\n\n### **EXHIBIT B**\n\n**Despins Declaration**\n\n| UNITED STATES BANKRUPTCY COURT |\n|--------------------------------|\n| DISTRICT OF CONNECTICUT        |\n| BRIDGEPORT DIVISION            |\n\n| ----------------------------------------------------------- | x           |                            |\n|-------------------------------------------------------------|-------------|----------------------------|\n|                                                             | :           |                            |\n| In re:                                                      | :           | Chapter 11                 |\n| 1<br>HO WAN KWOK,<br>et al.,                                | :<br>:<br>: | Case No. 22-50073 (JAM)    |\n| Debtors.                                                    | :<br>:      | (Jointly Administered)     |\n| ----------------------------------------------------------- | x           |                            |\n|                                                             | :           |                            |\n| In re:                                                      | :           | Chapter 11                 |\n|                                                             | :           |                            |\n| GENEVER HOLDINGS LLC,                                       | :           | Case No. 22-50592<br>(JAM) |\n|                                                             | :           |                            |\n| Debtor.                                                     | :           |                            |\n|                                                             | :           |                            |\n| ----------------------------------------------------------- | x           |                            |\n\n## **AFFIDAVIT OF LUC A. DESPINS IN SUPPORT OF MOTION FOR ENTRY OF ORDER (I) DIRECTING JOINT ADMINISTRATION OF RELATED CHAPTER 11 CASES AND (II) GRANTING RELATED RELIEF**\n\nI, Luc A. Despins, being duly sworn, hereby depose and say:\n\n1. I am the chapter 11 trustee (the \"Trustee\") appointed in the chapter 11 case of Ho Wan Kwok (the \"Individual Debtor\") and the registered owner of the shares in Genever Holdings Corporation (the \"Genever (BVI) Debtor\"), of which Genever Holdings LLC (the \"Genever (US) Debtor\") is a wholly owned subsidiary. By virtue of these positions and my participation in the relevant events, I have personal knowledge of the facts set forth herein. I provide this affidavit (the \"Affidavit\") in support of the *Motion of (A) Chapter 11 Trustee for Chapter 11 Case of Ho*\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595) and Genever Holdings Corporation. The mailing address for the Trustee and the Genever (BVI) Debtor is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\n*Wan Kwok, (B) Genever Holdings Corporation, and (C) Genever Holdings LLC for Entry of Order (I) Directing Joint Administration of Related Chapter 11 Cases and (II) Granting Related Relief* (the \"Motion\").<sup>2</sup>\n\n2. Given that the Trustee is administering the Individual Debtor's estate and is the registered owner of the shares in the Genever (BVI) Debtor, of which the Genever (US) Debtor is a wholly owned subsidiary, and given that the Genever (BVI) Debtor's case is already being jointly administered with the Individual Debtor's case, joint administration of the Chapter 11 Cases will provide significant administrative convenience without harming the substantive rights of any party in interest. Many of the motions, hearings, and orders in the Chapter 11 Cases will affect the Individual Debtor, the Genever (BVI) Debtor and the Genever (US) Debtor. The entry of the Order directing joint administration of the Chapter 11 Cases will reduce fees and costs by avoiding duplicative filings and objections. Joint administration also will allow the Office of the United States Trustee and all parties in interest to monitor the Chapter 11 Cases with greater ease and efficiency.\n\n3. The Motion does not request and the Movants do not seek substantive consolidation of the Chapter 11 Cases.\n\nI declare upon penalty of perjury that the foregoing is true and correct.\n\nDated: November 7, 2022\n\n*/s/ Luc A. Despins* Luc A. Despins Chapter 11 Trustee for the Chapter 11 Estate\n\nof Ho Wan Kwok\n\n<sup>2</sup> Capitalized terms used but not otherwise defined herein have the meanings given to such terms in the Motion.\n\n# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| -----------------------------------------------------------<br>x |             |                            |  |\n|------------------------------------------------------------------|-------------|----------------------------|--|\n| In re:                                                           | :<br>:<br>: | Chapter 11                 |  |\n| HO WAN KWOK,<br>et al.                                           | :           | Case No. 22-50073 (JAM)    |  |\n| 1<br>Debtors.                                                    | :<br>:      | Jointly Administered       |  |\n| -----------------------------------------------------------      | :<br>x      |                            |  |\n| In re:                                                           | :<br>:      |                            |  |\n| GENEVER HOLDINGS LLC,                                            | :<br>:      | Chapter 11                 |  |\n| Debtor.                                                          | :<br>:      | Case No. 22-50592<br>(JAM) |  |\n| -----------------------------------------------------------      | :<br>x      |                            |  |\n\n# **CERTIFICATE OF SERVICE**\n\nThe undersigned hereby certifies that on November 7, 2022, the foregoing Motion was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case by operation of the Court's electronic filing (\"CM/ECF\") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing.<sup>2</sup> Parties may access this filing through the Court's CM/ECF system.\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595) and Genever Holdings Corporation. The mailing address for the Trustee and the Genever (BVI) Debtor is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\n<sup>2</sup> To the extent that the foregoing was filed outside regular business hours, service by mail on recipients unable or not qualified to accept electronic notice was made on the next business day.\n\nDated: November 7, 2022 New Haven, Connecticut\n\nBy: /s/Douglas S. Skalka\n\nDouglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 821-2000 dskalka@npmlaw.com plinsey@npmlaw.com","body_zh":null,"key_entities":["Kwok","Ho Wan Kwok","Despins","Guo","Miles Guo","Paul Hastings","Je","Finkel","CIPA"],"ecf_references":[],"word_count":4256,"status":"published","published_at":"2022-11-07 00:00:00","created_at":"2022-11-07","updated_at":"2026-07-07 07:47:39"}