{"id":"court_ctb_1341_0","court":"CTB","case_no":"22-50073","doc_number":1341,"sub_number":0,"doc_type":"ORDER","filed_date":"2022-12-07","title":"UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT In re:","summary_zh":null,"summary_en":null,"body_en":"## UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT\n\nIn re:\n\nChapter 11\n\nCase No. 22-50073 (JAM)\n\nHO WAN KWOK, *et al.*\n\nDebtors.\n\n## **LIMITED OBJECTION OF HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC AND MEI GUO TO CHAPTER 11 TRUSTEE'S NOTICE OF FILING OF INVOICE OF ENGINEERING OPERATIONS AND CERTIFICATION SERVICES, LLC FOR INSPECTION SERVICES**\n\nHK International Funds Investments (USA) Limited, LLC (\"HK USA\") and Mei Guo (\"Guo\"), by and through their undersigned attorneys, file this limited objection (the \"Limited Objection\") to the Chapter 11 Trustee's Notice of Filing of Invoice of Engineering Operations and Certification Services, LLC for Inspection Services (the \"Notice of Inspection Services\") [Dkt. 1290], and in support of the Limited Objection, HK USA and Guo respectfully state as follows:\n\n## **PRELIMINARY STATEMENT**\n\n1. On December 9, 2022, Luc A. Despins, in his capacity as the Chapter 11 Trustee (the \"Trustee\") appointed in the above-captioned Chapter 11 case, filed a motion seeking authorization to retain and employ Engineering Operations and Certification Services, LLC (\"EOCS\") pursuant to a letter agreement dated December 7, 2022, by and between the Trustee and EOCS, to provide inspection services with respect to the Lady May yacht, effective as of November 23, 2022 (Dkt. 1212, the \"Motion\").\n\n2. By Order dated January 4, 2023, the Court granted the Motion, which authorized the Trustee to retain and employ EOCS effective as of November 23, 2022 (Dkt. 1285, the \"EOCS Retention Order\").\n\n3. In accordance with paragraph 5 of the EOCS Retention Order, \"[i]n lieu of filing fee applications, the Trustee is authorized to file a notice with the Court attaching EOCS's invoices for the Inspection Services. Parties in interest shall then have fourteen (14) days to object to such invoices.\"\n\n4. On January 4, 2023, the Trustee filed the Notice of Inspection Services [Dkt. 1290], which included a request for payment of an EOCS invoice in the amount of \\$9,710.00 (\"EOCS Invoice\"). Notably, the majority of the EOCS Invoice was comprised of services rendered by EOCS for the preparation of a final report (\"EOCS Final Report\"). Presumably, since EOCS has submitted the EOCS Invoice for payment, it has finalized the EOCS Final Report.\n\n5. Notwithstanding repeated attempts by HK USA and Guo, through counsel, to obtain a copy of the EOCS Final Report from the Trustee, the Trustee has not produced any such document to them. Although there is no court order specifically requiring production of the EOCS Final Report by a date certain, the Trustee's counsel had agreed to produce same by no later December 16, 2022, following a sea trial of the Lady May on December 13, 2022. No explanation has been given for the more than one-month delay.\n\n6. As the Court is aware, under the Stipulated Order Compelling HK International Funds Investment (USA) Limited, LLC to Transport and Deliver that Certain Yacht, the \"Lady May,\" HK USA \"shall cause, at its sole expense, the service and maintenance identified in the\n\n2\n\nDeclaration [of Russell Stockil] and otherwise, if necessary, to restore the Lady May to good working order.\" [Dkt. 299].\n\n7. To the extent that the Trustee asserts that HK USA is responsible for the cost to repair the Lady May, there is no reason whatsoever that the EOCS Final Report should not be immediately produced to HK USA by the Trustee.\n\n8. The Trustee is in no position to request payment for the EOCS Invoice when he has failed to provide a copy of the EOCS Final Report to HK USA, the owner of the Lady May.\n\n9. Therefore, the EOCS Invoice should not be paid and the Limited Objection should be sustained at this time.\n\nWHEREFORE, for each of the reasons set forth above, HK USA and Guo respectfully request that the Court deny for payment the Notice of Inspection Services and grant such other or further relief as may be appropriate.\n\nDated: January 18, 2023 Respectfully submitted,\n\n*/s/ Aaron A. Romney* Aaron A. Romney (ct28144) ZEISLER & ZEISLER, P.C. 10 Middle Street, 15th Floor Bridgeport, CT 06604 (203) 368-4234 [aromney@zeislaw.com](mailto:aromney@zeislaw.com)\n\n-and-\n\nLee D. Vartan (admitted *pro hac vice*) Sam Della Fera, Jr. (admitted *pro hac vice*) CHIESA SHAHINIAN & GIANTOMASI PC One Boland Drive West Orange, NJ 07052 (973) 325-1500 [lvartan@csglaw.com](mailto:lvartan@csglaw.com) [sdellafera@csglaw.com](mailto:sdellafera@csglaw.com)\n\n*Attorneys for HK International Funds Investments (USA) Limited, LLC and Mei Guo*\n\n## **CERTIFICATE OF SERVICE**\n\nI hereby certify that on this 18th day of January, 2023, a copy of foregoing was filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice ofElectronic Filing. Parties may access this filing through the Court's CM/ECF System.\n\n> */s/ Aaron A. Romney* Aaron A. Romney","body_zh":null,"key_entities":["Guo","Je","Kwok","Ho Wan Kwok","Despins"],"ecf_references":[{"doc_number":299,"court":"CTB"},{"doc_number":1212,"court":"CTB"},{"doc_number":1285,"court":"CTB"},{"doc_number":1290,"court":"CTB"}],"word_count":794,"status":"published","published_at":"2022-12-07 00:00:00","created_at":"2022-12-07","updated_at":"2026-07-07 07:50:29"}